Privacy Policy
PRIVACY POLICY
- WHO DOES THIS PRIVACY POLICY APPLY TO?
This Privacy Policy explains how MD International d.o.o. Beograd, corporate ID no. 17175122 (“Company”, “we”, “us”), processes personal data relating to the following categories of individuals:
- job applicants – individuals who apply for employment with the Company or are contacted for recruitment purposes;
- clients and business contacts – current or prospective clients who are natural persons, as well as individuals representing or working for corporate clients (e.g. employees, authorized representatives, shareholders, or signatories);
- website users – individuals who access and browse our website (please also refer to our Cookie Policy for further details); and
- suppliers and partners – individuals working for or representing entities that provide goods or services to the Company (including contractors, consultants, and authorized signatories).
In this Privacy Policy, “you” refers to any individual whose personal data we process.
We are committed to handling personal data responsibly, transparently, and in accordance with applicable data protection laws. We process your personal date in accordance with the Serbian Personal Data Protection Act (Zakon o zaštiti podataka o ličnosti). We do not use automated decision-making.
- WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA?
MD International d.o.o. Beograd acts as the data controller for all processing activities described in this Privacy Policy. This means we determine the purposes and means of processing your personal data.
- WHAT PERSONAL DATA DO WE PROCESS AND FOR WHAT PURPOSES?
We process different categories of personal data depending on your relationship with us and the purpose of processing.
Further detailed information on specific categories of data and purposes is provided in the relevant sections of this Privacy Policy or in supplementary information provided to you at the time of data collection.
- LEGAL GROUNDS FOR PROCESSING
The table below provides an overview of the main categories of personal data we process, together with the purposes and legal bases from the Serbian Personal Data Protection Act:
| Cookies Purpose: website analytics, improving user experience, functionality Data: cookie identifiers, browsing behaviour, device identifiers Legal basis: legitimate interests for necessary cookies (ensuring security and proper functioning of the website) consent for functional and marketing cookies For more detailed information about the cookies we use, their purposes, and how you can manage your preferences, please refer to our Cookie Policy. |
| Job applications (recruitment process) Purpose: recruitment, candidate assessment Data: CV data, contact details, qualifications, interview notes, references Legal basis: contractual necessity (pre-contractual steps at your request) legitimate interests (managing recruitment process and future opportunities, where applicable) consent (for keeping data for future job openings) |
| Client and business relationship management Purpose: provision of services, communication, contract performance, administration Data: contact details, identification data, contract-related data Legal basis: contractual necessity legitimate interests (business relationship management) legal obligations (e.g. accounting and tax requirements) |
| Supplier and service provider management Purpose: procurement of goods and services, supplier communication, contract management Data: contact persons’ details, contractual data, payment-related information Legal basis: contractual necessity legitimate interests (supplier management and operations) legal obligations (e.g. accounting and tax requirements) |
| Communication and inquiries (service inquiries forms, emails) Purpose:responding to inquiries, providing information or services Data:name, contact details, message content Legal basis: legitimateinterests (responding to business inquiries) contractual necessity (if related to service request or pre-contractual steps) |
Where processing is based on legitimate interests, we perform a balancing test to ensure that your fundamental rights and freedoms are not overridden. You may request more information about this assessment, and you have the right to object to such processing at any time.
- HOW DO WE COLLECT YOUR DATA?
We collect personal data through several channels:
- direct communication – when you contact us via email, phone, website forms, social media, or in person;
- third parties – such as your employer, business partners, recruitment agencies, or references you provide;
- cookies – when you visit our website, we will gather information about your use of the website by using cookies. Our website may contain links to external websites that are not covered by this Privacy Policy or our Cookie Policy. If you choose to access such third-party websites, the operators of those websites may collect and process your personal data in accordance with their own privacy policies, which may differ from ours.We do not control and are not responsible for the content, privacy practices, or data processing activities of such third-party websites. We encourage you to review the privacy policies of any external websites you visit;
- public sources – such as official registers, company websites, or professional networking platforms (e.g. LinkedIn).
We may also create certain data internally, such as notes, reports, or evaluations relevant to our business relationship or recruitment processes.
- APPLICATIONS VIA THIRD-PARTY PLATFORMS
Where you apply for a job through third-party platforms (such as job boards or professional networking services), your personal data may be collected and processed by those platforms independently in accordance with their own privacy policies.
We are not responsible for the data processing practices of such third-party platforms.
Once we receive your application, we process your personal data in accordance with this Privacy Policy.
Where we wish to retain your personal data for future job opportunities, we will request your explicit consent directly from you, regardless of the application channel.
- WHO DO WE SHARE YOUR DATA WITH?
We may share your personal data, where necessary, with:
- affiliated companies within our corporate group;
- our service providers (e.g. IT support, legal advisors, HR consultants);
- public authorities and courts when required by law or necessary for legal proceedings.
All data sharing is carried out on a need-to-know basis and in compliance with applicable data protection requirements.
- INTERNATIONAL DATA TRANSFERS
Where necessary, we may transfer personal data to countries outside Serbia, including to our parent company located in Hungary.
We will transfer personal data only to countries that are considered to provide an adequate level of personal data protection in accordance with applicable data protection laws, including the GDPR adequacy decisions adopted by the European Commission. A list of countries that are deemed to provide an adequate level of protection is available here:
Where personal data is transferred to countries that are not subject to an adequacy decision, we will ensure that appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) or other legally recognized transfer mechanisms, together with additional technical and organizational measures where necessary to ensure an equivalent level of protection.
- HOW DO WE PROTECT YOUR DATA?
We implement appropriate technical and organizational measures to protect personal data, including:
- data encryption and pseudonymization where appropriate;
- access controls and confidentiality safeguards;
- regular security testing and system monitoring;
- procedures for responding to data incidents.
These measures are designed to ensure the confidentiality, integrity, and availability of personal data.
- DATA RETENTION
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including:
- compliance with legal and regulatory obligations;
- establishment, exercise, or defence of legal claims;
- maintaining business relationships.
Where appropriate:
- Recruitment data may be retained for future job opportunities only where you have given your consent; otherwise, it will be deleted following completion of the recruitment process;
- business contact data may be retained for follow-up communications unless you opt out.
After the retention period expires, data will be securely deleted or anonymized.
- YOUR RIGHTS
Under applicable data protection laws, you have the following rights:
- Right of access – to obtain confirmation and a copy of your personal data;
- Right to rectification – to correct inaccurate or incomplete data;
- Right to erasure – to request deletion of your data in certain circumstances;
- Right to restriction – to limit how your data is used;
- Right to object – particularly where processing is based on legitimate interests;
- Right to data portability – to receive your data in a structured format;
- Right to withdraw consent – at any time, where processing is based on consent;
- Right to lodge a complaint with the competent supervisory authority (in Serbia: Commissioner for Information of Public Importance and Personal Data Protection, Bulevar kralja Aleksandra 15, Belgrade 11120).
- IS PROVIDING YOUR DATA MANDATORY?
Providing personal data is voluntary. However, if certain data is required:
- to comply with legal obligations; or
- to enter into or perform a contract,
failure to provide such data may prevent us from establishing or continuing our relationship with you.
- CONTACT DETAILS
If you have any questions about this Privacy Policy or wish to exercise your rights, you can contact us at:
Address
Žorža Klemansoa 39, 11158 Beograd
Phone