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Privacy policy

Privacy Policy and Notice on the Processing of Personal Data

Your privacy and the security of your data are important to us. Therefore, the company BELGRADE ARBOR DOO – NOVI BEOGRAD (hereinafter: the Company), fulfilling its duty as data controller towards you, as the individual from whom data relating to you is collected, provides you, at the moment of collecting such data and in accordance with the Law on Personal Data Protection ("Official Gazette of the RS", No. 87/2018, hereinafter: the Law), with the information set out below.

This Privacy Policy (hereinafter: the Policy) applies to natural persons, and personal data means any data by which you can be identified, directly or indirectly. All of your personal information is treated as strictly confidential and is adequately safeguarded by the Company and/or our trusted partners. Please read this Privacy Policy carefully. If you do not agree with our practices, please do not provide us with your personal data. By continuing to browse our website, you confirm that you agree to the Policy set out herein.

Information on the Controller and Recipient

Responsibility for the processing of personal data in the capacity of controller lies with: BELGRADE ARBOR DOO BEOGRAD – NOVI BEOGRAD.

The recipient of personal data may be the company Belgrade Arbor.

Should you have any questions or requests regarding the handling or protection of your personal data, you may contact us at the e-mail address info@belgradearbor.rs or in writing at the above-stated address of our registered office.

Scope of the Privacy Policy

This Policy covers the ways in which your personal data is processed when you interact with the Company, i.e. when you express interest in purchasing real estate or contact us in connection with the conclusion of a real estate purchase agreement within the residential and commercial complex, namely when you:

  • visit our website, or the websites used to advertise the Company's projects;
  • visit our profiles on social media platforms;
  • communicate with us by telephone, via the contact form on the website, by e-mail, or in any other manner;
  • use our systems and applications;
  • visit our sales offices;
  • attend our presentations or business events;
  • participate in our promotional or marketing activities (e.g. newsletter sign-up), surveys, and the like;
  • conclude with us an agreement relating to the purchase of real estate or any other agreement.

Only the provision of personal data collected for the fulfilment of specific legal obligations is mandatory. The provision of personal data on all other legal grounds is voluntary; however, please note that if you withhold certain data from us, we may in certain situations be unable to provide you with some of our services.

Personal Data We Collect

1. Personal Data of Visitors to Our Website

When you visit our website, or the websites used to advertise the Company's projects, the browser you use on your device will automatically, and without any action on your part, send to the server of our website: the IP address of the device from which the request was sent and which has internet access, the date and time of access, the name and URL of the retrieved file, the website/application from which access was made (referrer URL), the browser you use and, where applicable, the operating system of your internet-enabled computer, as well as the name of your internet service provider. The server temporarily stores the above data in a so-called log file for the following purposes:

  • ensuring the establishment of an uninterrupted connection;
  • ensuring the comfortable use of our website/application, or the websites used to advertise the Company's projects;
  • assessing system security and stability.

The data is stored temporarily, for the duration of your visit to the website, and is then automatically deleted. The legal basis for processing the IP address is Article 12, paragraph 1, item 6) of the Law on Personal Data Protection (legitimate interest), which arises from the above-stated purpose of data processing.

2. Marketing and Other Activities

For the purposes of sending commercial messages and carrying out marketing activities, personal data is collected exclusively on the basis of the individual's consent (for example, in the case of newsletter sign-up, direct marketing, etc.), so that the data you have provided to us via the contact form, by telephone, or by e-mail is used in accordance with the purpose defined herein. If you have consented to receiving the newsletter via e-mail, SMS, and/or Viber, and/or to receiving other marketing material containing notifications about current offers and promotions relating to the services in our portfolio, we use your e-mail address, telephone number, and first and last name to send information about available real estate, promotions, news, and real estate purchase offers. We store and process this data for the purpose of sending commercial messages, newsletters, and/or other marketing material, including campaigns (offers, promotions, etc.).

The legal basis for processing data when sending commercial messages, newsletters, and/or other marketing material is your consent in accordance with Article 12, paragraph 1, item 1) of the Law on Personal Data Protection. You may withdraw your consent to receiving the newsletter/marketing material at any time. Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent prior to its withdrawal. You may do so, for example, by unsubscribing from the newsletter mailing list on our website or on the website used to advertise the Company's projects. An unsubscribe link can be found at the end of each newsletter, while you may opt out of Viber or SMS notifications directly via the Viber application or by SMS, if you have consented to this form of communication. If you withdraw your consent, we will delete your data. Please be advised that, in connection with sending newsletters/Viber/SMS messages, we may engage external partners to perform these services, in which case your data (e-mail address and telephone number) may be transferred to such parties.

3. Personal Data of Real Estate Buyers

The Company processes the personal data of individuals required for the preparation and conclusion of agreements and the performance of contractual obligations, i.e. the exercise of rights and obligations arising from concluded real estate purchase agreements within the residential and commercial complex. The personal data we collect from you includes: first and last name, address (street, house number, postal code, city, country), Unique Master Citizen Number (JMBG), ID card/passport number, copies of personal documents, and contact details (telephone number, e-mail address). We obtain all of your personal data directly from you.

In addition to the Real Estate Purchase Agreement, the Company may also conclude with you agreements entered into in the phase preceding the purchase process, such as real estate reservation agreements, deposit agreements for the purchase of real estate, and the like, in which case we collect the following data from you: first and last name, address (street, house number, postal code, city, country), and contact details (telephone number, e-mail address). We process your data for the purpose of preparing the Real Estate Purchase Agreement, as well as preparing and concluding the other agreements referred to in this section. The legal basis for processing this data is Article 12, paragraph 1, items 2) and 3) of the Law, having regard to the performance of contractual obligations and legal obligations, respectively.

4. Other Personal Data You Have Provided to Us

We process the personal data that you have voluntarily provided to us upon initial contact, in the course of subsequent communication (e.g. by telephone call, e-mail, questionnaires, etc.), when visiting the Company's website or the websites used to advertise the Company's projects or our social media profiles, as well as personal data arising from our communication or business cooperation, which includes your identification data (first and last name) and your communication data (contact telephone number and e-mail address). We process your data in accordance with the defined purpose, in order to respond to your enquiry based on your expressed interest, present our offer to you in more detail, and provide other requested information.

The legal basis for this data processing is Article 12, paragraph 1, item 6) of the Law on Personal Data Protection (legitimate interest). Our — and at the same time your — (legitimate) interest in such data processing arises from the need to answer your questions, resolve any existing issues where necessary, and thereby ensure your satisfaction as a user of our services and of our website.

If you participate in any of our surveys/questionnaires, such participation is voluntary. In the case of anonymous surveys, we do not store any data that would allow us to identify the survey participant. We store only the date and time of your participation. Any personal data you have provided to us through a survey is considered voluntarily given and is stored in accordance with the provisions of the Law. If you have given your consent to the conduct of a survey, the legal basis for data processing is your consent in accordance with Article 12, paragraph 1, item 1) of the Law on Personal Data Protection. In that case, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent prior to its withdrawal.

By providing personal information, the visitor to the Company's website, or to the website used to advertise the Company's projects, understands and agrees that the security, integrity, and privacy of their data cannot be 100% guaranteed, notwithstanding the fact that the Company continuously undertakes all optimal measures to protect such data.

5. Personal Data of Social Media Users

On the Company's social media pages, the Company processes data for the purpose of informing individuals about the residential and commercial complex, the real estate we offer for sale, the services we provide, promotions, important information, and company news — all with the aim of interacting with visitors to our social media pages, responding to questions, compliments, and criticism, and communicating with individuals interested in our services. Data processing is carried out in the interest of establishing communication, i.e. with the aim of interacting with and improving relations with our followers. The legal basis for processing your data is Article 12, paragraph 1, item 6) of the Law (legitimate interest).

We have only limited influence over the processing of data by social media platform operators (e.g. member administration and information sharing). Where we are able to influence and configure the parameters for the processing of your data so that the social media platform operator acts in compliance with data protection requirements, we take all measures available to us. However, in many respects we are unable to influence the operator's data processing, nor do we know exactly which data the operator processes. The platform operator manages the entire IT infrastructure of the service, adheres to its own data protection rules, and maintains a separate user relationship with you (if you are a registered user of the social media service). Furthermore, the operator is solely responsible for all matters relating to the data in your user profile, to which we, as a company, have no access. More detailed information on data processing by social media platform operators, and on the available means of objection, can be found in their data protection policies.

Content you post on our social media pages, such as comments, videos, images, likes, public announcements, and the like, is published by the platform operator, and we never process it for any purpose other than the intended one. We reserve the right to delete unlawful or inappropriate content where necessary. We also process your data for the purpose of communicating with you. We may share your content on our page where this constitutes a function of the social media platform.

Access to Your Data

We treat your personal data as a business secret and protect it as such in accordance with applicable legal regulations and best practice. Within our company, access to the data you have made available to us is granted only to those organisational units and employees who require it in order to fulfil the purpose for which the personal data was collected. Your personal data will be processed by us, while third parties have the right to access and process your personal data only in the situations described below:

  • our trusted partners, i.e. legal entities with whom we cooperate and who assist us in our regular business operations. These may be entities that develop and maintain IT solutions, platforms, and servers, as well as entities that provide services to you on behalf of the Company, e.g. for marketing purposes. In such cases, these legal entities process your personal data exclusively on our behalf. In accordance with the agreements concluded, these service providers are obliged to use the data entrusted to them solely in accordance with our instructions and strictly for the purpose we have specified, with the obligation to adequately protect your data and keep it confidential;
  • parties with whom we cooperate in business, where we deem it necessary for the protection of our specific and justified interests, e.g. tax advisers, accountants, insurance companies, lawyers, and other advisers. In such cases, these parties process your personal data exclusively on our behalf;
  • competent authorities in the exercise of supervision over the lawfulness of business operations and conduct, as well as other legal entities where this is necessary for the performance of one of our legal obligations, e.g. an auditor. In such cases, these legal entities process your personal data for the purpose assigned to them by law;
  • other parties in connection with business transactions such as the sale of the company or part of the company, reorganisation, merger, joint venture, or any other form of disposal of our company or its assets.

There may also be a need to forward part of your enquiries to our contractual partners (e.g. suppliers, architects, or contractors, in the case of enquiries concerning specific products/materials and the like) for the purpose of processing your enquiry. However, in such cases the enquiry is anonymised beforehand, so that the third party cannot link it to you in any way. If, in an individual case, the forwarding of your personal data becomes necessary, we will inform you thereof in advance and request your consent. Third parties are restricted from using your personal data for any purposes other than those stated, and are obliged to protect and process your personal data in accordance with legal, regulatory, and contractual obligations. All legal entities with whom we cooperate have been selected with great care and, where required by law, are contractually bound to keep personal data confidential, in accordance with Article 45 of the Law on Personal Data Protection.

Transfer of Your Personal Data to Other Countries

In certain cases, we may share your personal data, i.e. transfer it to other countries, in accordance with the Law. When we do so, we transfer your data to servers located in the EU or in a country that ensures an adequate level of protection in accordance with the legislation of the Republic of Serbia. Access will be permitted only to a limited number of persons, i.e. authorised individuals, exclusively for the purpose of maintaining server functionality.

How We Protect Your Personal Data

Some of the protective measures we implement include the following:

  • application of state-of-the-art methods for the protection of, and control of access to, data sources containing personal data;
  • restriction of access to sensitive data and restriction of user accounts that may access certain data, through the introduction of a system of roles and authorisations ensuring that only designated employees who require access to data for the performance of their work duties may view and process the relevant data;
  • continuous monitoring of all resources (physical premises where your data is stored) used for the processing of personal data.

The purpose of implementing these measures is to prevent the risk of destruction, loss, alteration, unauthorised disclosure of, or access to your personal data. We also require the application of appropriate protective measures with respect to your personal data from third parties that have the right to access and process your personal data. All personal data is stored on our server in the Republic of Serbia. Please note that the above protective measures do not apply to information or data that you choose to share publicly via social media or messaging applications.

Retention Period of Your Personal Data

Personal data is retained for as long as necessary to fulfil the purpose for which it was collected. If you have concluded an agreement with us, we retain your data for the duration of the rights and obligations arising from the agreement, and thereafter for as long as required by applicable regulations. We also retain your personal data after the termination of the contractual relationship if it is needed for the establishment, exercise, or defence of legal claims, or for compliance with applicable laws. To the extent possible, we will restrict the processing of your personal data to those limited purposes following the termination of the contractual relationship. Once the purpose has been fulfilled, i.e. upon expiry of the statutory retention period, the personal data will be permanently deleted.

Your Rights

If you decide to exercise one or more of your rights listed below, we are entitled to verify your identity, all for the purpose of protecting personal data. You may exercise your rights free of charge. Exceptionally, if your request is manifestly unfounded or excessive (e.g. you request personal data already in your possession), and in particular if the same request is repeated frequently, we are entitled to charge the necessary costs of acting upon your request or to refuse to act upon it. Please send all questions and requests relating to your rights in writing to the address stated in the section "Information on the Controller". We will respond to your request without delay, and at the latest within one month, unless the exceptional complexity of an individual case requires an extension of this period. In order to protect you as the data subject, you must identify yourself appropriately as the applicant, which will serve as an assurance to the Company that personal data is being disclosed to its rightful owner.

Access to Your Personal Data

You have the right to request information from us as to whether we process your personal data, access to such data, as well as information about the processing in accordance with Article 26 of the Law.

Rectification of Inaccurate Data, Supplementation, Erasure, and Restriction of Use of Personal Data

You have the right to request the rectification of your inaccurate personal data, as well as the right to supplement, erase, and restrict the use of your personal data.

Data Portability

You have the right to obtain and request the transfer of your personal data.

Right to Withdraw Consent and Right to Be Forgotten

You have the right to withdraw your consent to the processing of personal data, as well as to request the permanent erasure of your personal data processed on the basis of your consent.

Objection to the Processing or Handling of Your Personal Data

You have the right to object to the processing of your personal data, as well as to our handling of your personal data in general. Please send your request by e-mail to the address stated in the section "Information on the Controller", indicating "Objection to Processing" in the subject line and explaining the reason for your objection and your request in the body of the message.

Right to Lodge a Complaint with the Commissioner for Information of Public Importance and Personal Data Protection

You have the right, at any time, to lodge a complaint with the competent personal data protection authority — the Commissioner for Information of Public Importance and Personal Data Protection (https://www.poverenik.rs/).

Amendments to the Privacy Policy

The Company reserves the right to amend this Privacy Policy at any time. Each amendment becomes effective upon its publication on the Company's website or in another appropriate manner. In this regard, we recommend that you regularly review the section relating to the Privacy Policy in order to stay informed of the latest updates.

Belgrade, 2 November 2025

Note: Upon completion of the project's construction, minor deviations in the appearance of the facade or details may occur in relation to the renders presented. The numbering of the premises has been carried out in accordance with the real estate registration method of the Cadastre of the Republic of Serbia.