Belgrade, 3 November 2021
Thank you for using the app “Tvoj Centar” (“App”) which is available for shopping centres in Belgrade: Ušće Shopping Center, BEO Shopping Center and Mercator Center Beograd (“Centres”).
Our business policy is based on the principle of legal and transparent processing of personal data, principle of minimization, limited storing and safety of data in line with the Law on Personal Data Protection and General Data Protection Regulation (GDPR).
This policy serves for you to understand which personal data are processed, how we process them and for what we use them.
To make sure the app is running smoothly on your device and that it is easy for you to use, we will collect information about your device and how you use the app.
To make sure the App is used fairly, we require you to register an account in the App if you want to use the loyalty program. If you decide to register an account, we will collect information about you as a person. If you do not wish to register an account, you will not be asked for personal data, but we will process your data as anonymous person.
Data collected about your device and how you use the App after you register for an account, will be linked to the information we collect about your person.
We will use all the information collected to try and show you the most relevant marketing material from the shops in the Centres.
To measure the effect of our marketing on third-party advertisement networks like Facebook and Google, we share data about you with third party advertisement network providers if you decide to register an account.
We ask you to read and understand this privacy notice before you download and use the App.
If you choose to register an account, you can do so either by inputting your information manually or by using your Facebook account. If you are using the iOS version of the app, you can also use Apple ID for registering.
The following information is mandatory for us to create an account for you:
We might ask you for additional information about you during the registration. Each piece of additional information is optional.
If you register an account using your Facebook account, the following information will be collected from your Facebook account:
We use your email address, password, telephone number and Facebook user id (if collected) to authenticate you when you login to your account. We use your name and profile picture to show your name and picture on your profile in the app. We will analyse information collected about you during the registration, information about your device and information about your use of the app to show you the most relevant marketing content in the app.
Information collected after your account registration about your device and your use of the app will be connected to the information registered on your account, but information collected before your account registration will never be connected to the information registered on your account.
The following information about your device will be collected when you use the app:
Information about your usage of the App will be collected using event tracking. When you perform an action in the app, an event describing your action will be registered. An event will be registered every time you do any of the following:
We analyse the device and usage information to make sure the App is running smoothly on the different devices available and to better understand how the App is being used.
If you consent to sharing your location with the app, an event will be registered every time you do any of the following:
The information about your location is used to reward your points for visiting Centres and to let the shops know how many visits a marketing campaign influenced. Your personal data will never be shared with any shop in Centres.
If you consent to receiving notifications from the App, an event will be registered every time you receive a notification.
The information collected about your location and notifications are mixed with the additional usage data and used for the same purposes.
Every time you send a support request an event will be registered along with any information contained in the request. The support requests are registered so we can investigate and resolve your request.
By downloading and using the App, I consent to receiving messages and notifications about services provided by the App, Centres and the shops in Centres.
I also consent to receiving marketing material in the App from the shops in Centres. A list of the shops can always be found in the App.
Finally, I consent to letting Centres target advertisements to me on third-party advertisement platforms using Facebook, Google and Adform, if I decide to register an account in the App. I understand that I will not receive more advertisement, but that the advertisements shown to me might be based on information collected about me in the App. I understand that I can use the App without registering an account, in which case no information collected about me in the app will be shared with third-party advertisement platforms. I understand that I may opt-out of sharing third-party.
Information about you is collected and processed based on your consent which you provide by accepting this Privacy Policy at the first registration of user account.
Gender, date of birth and place of residence are processed based on our legitimate interest to improve the App, develop new activities and benefits, remove problems and optimize the app for your need in order to create most convenient individual experience for the users.
If you provide separate consent, on your email address and phone number we will send you notifications and information, advertisements and other information on the Centres which are part of the App and gifts you can redeem for collected points. At any time, you can withdraw the consent.
When you redeem the gifts, we keep the history of your purchase. Legal ground for such processing is to allow preview and information on already redeemed and used benefits for better preview and pleasure when using the App.
We keep a record of when and how we got consent from you and we keep a record of exactly what information were provided to you at the time.
You can always withdraw your consent to process information about your person by deleting your registered account in the app. If you delete your account, we will delete or anonymise your personal data.
Please note, you are not under any obligation to give us personal data but can always use the App without active user account, but in such case you will not be able to enjoy any loyalty benefits.
We share the personal data with our data processors, who help us collect, process and analyse the personal data.
With all of them we have data processing agreements in place. Thus, their rights and obligations regarding your personal data processing are fully regulated in order to protect your rights to greatest extent.
Your personal data we can reveal to other entities when we believe it is needed to protect your rights, our rights or rights of third parties or if requested by state authority for purpose of investigating criminal act with appropriate warrant.
We use third-party advertisement networks to advertise for the app. If you decide to register an account in the app, we will share with Facebook, Google and Adform, when you registered your account and every time you start the app. This enables us to use the third-party advertisement network providers’ tools for measuring the effects of our app advertisements. You can read the third-party advertisement network providers’ privacy policies here:
If you do not want to have your data shared with third-party advertisement networks, you are able to opt-out using the Profile Settings in the App.
Transfer of your data out of the Republic of Serbia is allowed in following cases:
Security of your personal data is very important for us. Therefore, we choose processors who apply adequate technical , organizational and personal measures in order to remove risks from accidental, or illegal destruction, loss, change, unauthorized revelation of personal data or unauthorized access to personal data.
Our processor provide optimal level of protection and confidentiality of personal data by modern service architecture, taking into account availability, integrity and security of personal data. This is achieved by different technologies, such as use of passwords, codes, limited access, registration of access to personal data, use of firewall, DDoS, back up, virus and spam protection, HTTPS protocols, redundant data storing systems, continuous surveillance of systems and services, as well as other technologies used of enabling safe use of the services.
Still, the data transfer on internet can never be fully safe regardless of all undertaken protection measures. Even though we follow generally acceptable standards to protect provided personal data, it is not possible to guarantee the safety and integrity of the information on internet. Thus, we recommend to apply protection measures in order to protect your data, including passwords, use of safe networks for accessing internet and disconnecting from network services when you stop using your device. Accordingly, the risk of misuse of the data also lies on the provider of the data.
We do not process persona data of persons under 18 , as the app is intended solely for persons above 18 years.
If you believe we process the data of persons under 18 years, please let us know.
Your information is securely stored with our data processors in and outside the EU.
We keep the personal data until the time when you have been inactive for 12 months or you delete your account in the app. We will then dispose your information by erasing it from our servers or anonymising it.
The record of when and how we got consent from you and exactly what were consented to at the time are stored for two years after your account is deleted.
Under data protection law, you have rights, including:
You are not required to pay any charge for exercising your rights. If you make a request, we will respond as soon as possible.
Please send us requests regarding your data protection rights using the support request features in the app or by emailing us at support@emplate.it or on office@mpcproproperties.rs.
If you are unhappy with our processing of your personal data, you can lodge a complaint with Commissioner for information of public importance and personal data protection.
We urge you to contact us before you complain. We will try to assist you the best and shortest way possible.
The following entities are responsible for personal data protection:
Owner of the App:
EMPLATE ApS
Business reg. no. (VAT): DK36031034
Søren Frichs Vej 42Q - 8000 Aarhus C - Denmark (DK)
Tel.: (+45) 5363 1418
E-mail: support@emplate.it
Web page: https://www.emplate.it/
Owners of Centres:
UŠĆE SHOPPING CENTER D.O.O BEOGRAD (corporate id: 20567716)
SHOPPING CENTER IV D.O.O. BEOGRAD (corporate id:: 21169072)
RETAIL CENTER D.O.O. BEOGRAD (corporate id:: 21333387)
E-mail: office@mpcproproperties.rs
Address: Bulevar Mihajla Pupina 6, Beograd, the Republic of Serbia
Contact: Zoran Milićević, data protection officer
If you have any questions regarding Privacy Policy, or you wish to use any of your rights please address the data processing officers: office@mpcproproperties.rs i support@emplate.it
Privacy Policy may be amended in line with the needs and regulations. Any change of this policy shall be published in the App.