PRIVACY POLICY

One2tips

OneTwoWork d.o.o. Belgrade,as the sole and exclusive owner of the platform 'One2tips.rs' which allows guests to financially reward the service provider for the services rendered, with the amount being forwarded to the service provider without compensation, understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website and will only collect and use personal data in the manner described herein, and in accordance with our obligations and your rights under the law. Please carefully read this Privacy Policy and ensure that you understand it. Your acceptance of this Privacy Policy will be deemed to have occurred upon your first use of our website or registration of an account on our site. If you do not accept or agree with this Privacy Policy, you must immediately cease using our website.

Who We Are: We ("OneTwoWork", "we," "our," and "us") are: OneTwoWork d.o.o. Belgrade, located in Serbia, Belgrade, Nikola Pašić Square No. 5, Floor 1, Company Registration Number: 22015702, Tax Identification Number (TIN): 114384377, as the Data Controller, meaning we are responsible for processing and protecting your personal data, in which ownerships platfrom 'One2tips.rs’ is under.

1. Definitions and interpretation

• Personal data means any information relating to an identified or identifiable individual ("data subject"); an identifiable individual is one who can be identified, directly or indirectly, particularly by reference to an identifier such as a name, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that individual;

• Data subject refers to an identified individual or an individual who can be identified, whose personal data is processed by the data controller.

• Processing of personal data means any operation or set of operations performed on personal data, whether automated or non-automated, including the collection, recording, sorting, structuring, storage, adaptation or alteration, retrieval, use, disclosure, transmission, dissemination, or otherwise making available, comparison, restriction, erasure, or destruction of personal data or sets of personal data;

• Automated processing of personal data – the processing of personal data using computer technologies.

• Collected data is used in a manner that allows the identification of individuals – users of the website, in accordance with the personal data protection Law of the Republic of Serbia, the General data protection Regulation (GDPR) of the European Union, the EU (e-Privacy Regulation - ePR), and other relevant legal sources in the field of personal data protection;

• The consent of the data subject means any voluntary, specific, informed, and unambiguous indication of the individual’s will, whereby the individual, through a statement or clear affirmative action, gives consent for the processing of personal data relating to them. An individual who has given consent for the collection and processing of personal data may withdraw their consent at any time and without explanation, which will result in the legal consequence of terminating the user's status on the OneTwoWork website and halting any further data collection by the individual who has withdrawn consent;

• The data controller is a person or legal entity, or an authority, who alone or jointly with others determines the purposes and means of processing;

• The data processor is a person or legal entity, or an authority, who processes personal data on behalf of the data controller;

• The recipient is a person or legal entity, or an authority, to whom personal data is disclosed, regardless of whether they are a third party or not, unless it is an authority that, in accordance with the law, receives personal data for the purpose of investigating a specific case and processes such data in accordance with data protection rules that apply to the purpose of the processing;

• A Third Party is a person or legal entity, or an authority, who is not the data subject, the controller, or the processor, as well as any person authorized to process personal data under the direct authority of the controller or processor.

•  "Cookie" is a small text file placed on your computer or device by our website when you visit certain areas of our site and/or when you use certain features of our site. The details of the cookies used by our site are provided in Section 11 below; and "Cookie Policy" refers to the relevant provisions of the Privacy and Electronic Communications Law (Electronic Communications Directive EC) from 2003.

• Website user means any person or legal entity who accesses or registers an account on the website.

2. What does this policy cover?

This Privacy policy applies to your use of our website and the services provided by OneTwoWork d.o.o. Belgrade, and using the platform One2tips.rs in accordance with the Terms of use. Our website may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites, and we advise you to review the privacy policies of any such websites before providing them with any information.

3. What is personal data?

Personal data is defined by the Personal Data Protection Law (Official Gazette of the Republic of Serbia, No. 87/2018) and the General data protection Regulation (EU Regulation 2016/679) ("GDPR") as 'any information relating to an identified or identifiable individual ("data subject"); an identifiable individual is one who can be identified, directly or indirectly, particularly by reference to an identifier such as a name, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that individual.

Personal data, in simpler terms, refers to any information about you that allows your identification. Personal data includes obvious information such as your name and contact details, but also encompasses less obvious information such as identification numbers, electronic location data, and other online identifiers.

Anonymous information, which we are unable to link to you, does not qualify as personal data.

4. What are your rights?

By law, you have the following rights, which we will always strive to respect:

1. The right to be informed about our collection and use of your personal data. This Privacy Policy should provide you with all the information you need to know, but you can always contact us to learn more or ask questions using the contact details provided in Section 13.

2. The right to access the personal data we hold about you. Section 10 will tell you how to do this.

3. The right to correct your personal data if any of the personal data we hold about you is inaccurate or incomplete. You have the right to request that we correct any personal data we hold. In any case, please be aware that by actively providing your personal data to us through any process, you guarantee that the information is true and accurate and assume responsibility for notifying us of any changes or updates to your data. You are responsible for any loss or damage to the Platform, the entity responsible for the Platform, or any third party resulting from the submission of incorrect, inaccurate, or incomplete data in registration forms. Please remember that, as a general rule, you must provide only your own data, not the data of third parties, unless otherwise permitted under this Privacy and Cookie Policy. To make changes to your data, you can contact us using the details provided in Section 13 to learn more.

4. The right to be forgotten, i.e., the right to request the deletion or otherwise removal of any of your personal data we hold. Please contact us using the details provided in Section 13 to learn more.

5. The right to restrict (i.e., prevent) the processing of your personal data. This means that you can request us to cancel or limit the processing of your personal data, which may include, in certain cases, requesting that we temporarily suspend the processing of data or retain it for longer than necessary.

6. The right to object to the use of your personal data for certain purposes. When the processing of your data is based on our legitimate interest, you also have the right to object to the processing of your data.

7. The right to data portability. This means that, if you have provided us with personal data directly, and we process it based on your consent or for the performance of a contract, and such data is processed by automated means, you may request a copy of that personal data in order to reuse it with another service or business entity in many cases.

8. Rights related to automated decision-making and profiling. The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, if that decision has legal effects concerning the data subject or significantly affects their position.

       The previous paragraph does not apply if the decision is:

1. Necessary for the conclusion or performance of a contract between the data subject and the data controller;
2. Based on law, provided that the law lays down appropriate safeguards for the rights, freedoms, and legitimate interests of the data subject;
3. Based on the explicit consent of the data subject.

It is prohibited to make a decision solely based on automated processing carried out by competent authorities for special purposes, including profiling, if such a decision could produce harmful legal consequences for the data subject or significantly affect their position, unless the decision is based on law and the law provides appropriate safeguards for the rights and freedoms of the data subject, including at a minimum the right to ensure the participation of the data subject under the control of the data controller in the decision-making process.

1. All other rights provided by the legislative regulations in the field of personal data protection. The data subject may exercise their rights by sending a request to our email address: legal@one2tips.rs.

OneTwoWork will provide you with all the necessary additional information to fulfill the stated requests, as well as assistance, in accordance with the terms and in the manner prescribed by the applicable Personal Data Protection Law. We will respond to your request as soon as possible, and no later than 30 days from the receipt of the request. In case of complexity or a large number of requests, we may require an extended period to respond. This period cannot exceed 90 days, and we will specifically inform you about it.

The competent authority for the protection of personal data in the Republic of Serbia is the Commissioner for information of public importance and personal data protection of the Republic of Serbia, an autonomous and independent state body established by law, responsible for overseeing the implementation of the Personal Data Protection Law and other laws prescribed by legislation.

If you have any reason to complain about our use of your personal data, you have the right to file a complaint with the Commissioner for Information of Public Importance and Personal Data Protection. You can contact the authorized body via email at office@poverenik.rs, or by mail at: Bulevar kralja Aleksandra 15, 11000 Belgrade, Republic of Serbia.

5. What data do we collect?

Necessary standards we apply.

Depending on your use of our website, we may collect some or all of the following personal and non-personal data (see also Section 11 regarding our use of cookies and similar technologies):

• Identification data (first name, last name, father’s name, gender, date and place of birth; nationality and passport details - number, issuance date, expiration date; user’s photograph necessary for account verification; data from an ID card or other identification document; taxpayer identification number; residential address or place of residence / registered office address for legal entities as users; registered data from the relevant business entity registry for legal entities as users.)
• Phone number;
• e-mail;
• current account number;
• any other data from any other document that the website user independently enters and uploads through their registered account, which will be considered as consent for the processing of the relevant data.

The controller may also request from the website user a copy of their personal document and any other documents necessary for work on the territory of the Republic of Serbia, as well as any additional information that, in the controller’s assessment, will be necessary and sufficient for the identification of the user, as well as for the conclusion and/or execution of any contract/agreement entered into with clients/customers by the user, and to enable the prevention of abuse and violations of the rights of third parties, including the controller's clients/customers.

For informational security purposes, the controller may create publicly available sources of personal data of the website user, including directories and address books. With the consent of the data subject (the owner of the personal data), the following may be included in publicly available sources: their last name, first name, date and place of birth, occupation, contact phone number, and email address. Information about the data subject may be excluded from publicly available sources of personal data at any time upon their request.

When the User uses the Services, the following data about the end user may be received and processed by OneTwoWork:

- "Technical Information":This refers to various unique identifiers that typically identify a computer, device, browser, or application, such as: browser type, device type and model, CPU, system language, memory, OS version, Wi-Fi status, timestamp and timezone, device movement parameters, and operator.

- "Technical Identifiers": This refers to various unique identifiers that typically identify a computer, device, browser, or application. For example, an IP address (which may also provide general location information), user agent, IDFA (identifier for advertisers), Android ID (on Android devices), Google Advertiser ID, user ID issued by the user, and other similar unique identifiers.

6. How do we collect and use your personal data?

Purpose and legal basis for data processing.

If you decide to become a registered user of our Platform, we need to process your data to identify you as a user of the Platform and to grant you access to its various features and services available to you as a registered user. You can cancel your registered user account by contacting our Customer Service. We hereby inform you that the data we collect about your activities, collected through various channels of the Platform, will remain linked to your account to enable consolidated access to all information. The possible legal basis for the processing of your data may be:

• consent – the website user to whom the data being processed pertains gives consent for one or more specific purposes of processing;
• contract – processing is necessary for the performance of a contract concluded with the website user to whom the data pertains, or for taking steps at the request of the data subject prior to entering into a contract;
• legal obligation of the controller – processing is necessary for compliance with the legal obligations of the controller;
• for the purpose of pursuing the legitimate interests of the controller or a third party.

The main reason is that we must process your data in order to fulfill the contract you enter into with us when you register and use any of our services or features.

Your personal data will be used for one of the following purposes:

• Enabling and managing your access to our Website;
• Full operation and facilitation of the use of the OneTwoWork website;
• Personalizing and customizing your experience on our Website;
• Improving and developing our website;
• Providing our services to you;
• Concluding and/or executing any contract with website users;
• Personalizing and customizing our services for you;
• Sending information via email and/or mail to which you have subscribed.

With your consent and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you via email and/or mail with information, news, and offers regarding our products and/or services. We will not send you unlawful marketing or spam. We will always strive to fully protect your rights and comply with our obligations under the Data Protection Act, the GDPR, and the privacy and electronic communications Regulation (EC Directive) of 2003, and you will always have the opportunity to unsubscribe as outlined below.

In addition to your rights outlined in Section 4, when you provide personal information through our website, you may have the opportunity to limit our use of your personal data. Specifically, we aim to give you strong control over the use of your data for direct marketing purposes (including the ability to prevent receiving emails from us, which you can do by unsubscribing via links provided in our emails and/or through an option in your account settings).

 For certain processing purposes, we process your personal data based on your consent to the processing of personal data, with prior notice of all relevant aspects of the processing. It is important to know that you can withdraw your consent at any time and without explanation, resulting in the cessation of further processing.

We believe we have a legitimate interest in linking your account with data about your activities collected through various channels on the Platform. We also believe we have a legitimate interest in responding to requests or consultations you have made through existing various contact channels. We believe processing this data is also beneficial to you to the extent that it allows us to provide you with assistance in an appropriate manner and respond to the consultations you have made. To show you personalized information, we believe we have a legitimate interest in performing profiling based on the information we have about you (such as your search history, selections) and personal data you have provided to us, such as age or language, as we believe that processing this type of data is also beneficial to you as it enables you to enhance your user experience and access information according to your preferences.

7. How long will we retain your personal data?

We will not retain your personal data longer than necessary, considering the reasons for which they were initially collected or until the withdrawal of the given consent for storage and processing. Therefore, your personal data will be kept as long as the company has a legitimate or legal basis for retaining such records. The data will then be deleted, except in exceptional cases prescribed by law or when deleting the data could obstruct an investigation, detection, or prosecution in a criminal case, as well as prevent claims in civil disputes.

In certain cases, personal data may be stored for a longer period in order to fulfill legal obligations (e.g., the Accounting Law and similar laws or for the purpose of establishing, enforcing, or defending a legal claim, in accordance with applicable regulations and laws)

8. Do we share your personal data? Transfer of personal data.

The international transfer of personal data to foreign countries may only be carried out by OneTwoWork with the consent of the data subject for the international transfer of their personal data. Before the international transfer of personal data takes place, OneTwoWork is required to ensure that the foreign country to which the personal data is being transferred provides adequate protection of the rights of data subjects.

For the purpose of service efficiency, in the case that we transfer data to third countries located outside the European Economic Area that do not provide the same level of data protection as the European Union and may not be on the list of countries ensuring an adequate level of data protection issued by the competent data protection authority in Serbia, we inform you that we transfer your data by applying appropriate security measures to ensure that your data is always secure. In this regard, we use the most suitable tools for international data transfer, in accordance with standard contractual clauses and other relevant supplementary measures. You can review the content of such standard contractual clauses at the following link: https://ec.europa.eu/info/law/law-topic/data-protection/datatransfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

In the event that we sell or transfer our company or resources, in whole or in part, to another company, or if we carry out any other business action due to the reorganization of the company, we may disclose your personal data to the entity that will assume control of the company or resources. In the case of such a sale or transfer, we will make reasonable efforts to ensure that the acquirer follows the use of the personal information you provided in a manner consistent with our Privacy and Cookie Policy. In this case, we consider that we have a legitimate interest in reorganizing the company's structure. Additionally, if you choose to use our Platform across different markets (i.e., if you create user accounts on different markets with the same email address), we may need to disclose or transfer information related to your account or activities to companies operating in those markets, to the extent that they are directly involved in achieving one of the purposes described in Section 6. We consider this necessary in accordance with our shared interests and choices.

Sometimes, we may enter into contracts with certain third parties for the purpose of data storage. If any of your personal data is transferred to a third party, as described above, we will take steps to ensure that your personal data is treated securely and in accordance with your rights, our obligations, and the obligations of the third party, in compliance with the law.

In certain limited circumstances, we may be legally obligated to share certain personal data, including yours, if we are involved in legal proceedings or fulfilling legal obligations, a court order, or instructions from an authorized public authority.

9. Can you retain the information?

You can access certain parts of our Website without providing any personal data. However, in order to use all the functions, capabilities, and services available on our Website, you may need to provide or allow the collection of certain data.

You can limit our use of cookies. For more information, please refer to Section 11.

10. How can you access your personal data?

In addition to the right to be forgotten, you can exercise the following rights at any time:

• You can ask us to provide copies of the personal information we hold about you, or information regarding the processing of such data. This is called a „data subject access request“.
• You can ask us to update and correct any outdated or inaccurate personal information we hold about you.

All data subject access requests must be made in writing and sent to the email address provided in Section 13.

There is generally no charge for a data subject access request. However, if your request is "manifestly unfounded or excessive" (for example, if you make repetitive requests), a fee may be charged to cover the administrative costs of responding.

We will respond to your data subject access request within 30 days of receiving it. Typically, we aim to provide a full response, including a copy of your personal data, within this period. However, in some cases, especially if your request is more complex, it may take longer, up to a maximum of 90 days from the date we receive your request. You will be fully informed of our progress. If you wish to exercise any of these rights, please contact us as described in Section 13.

11. How do we use cookies?

Our Site uses cookies and similar technologies that collect Tracking Data to distinguish you from other users. This helps us provide you with a better experience when accessing the Site and using our Services.

The cookies used on our Site fall into the categories described below. You can use these descriptions to determine whether and how you want to interact with our Websites and other online services:

Strictly necessary cookies: These cookies are essential for enabling navigation on the Websites and using certain features. Without these strictly necessary cookies, the online services provided by the Websites cannot be offered. Therefore, it is not possible to opt out of using these cookies. Additionally, the programming language used to develop the Websites utilizes session cookies, and their use cannot be avoided. These cookies are deleted every time you close your browser. These cookies do not store any information about the visitor after the browser is closed.

Performance Cookies: Our performance cookies collect anonymous information about how you use the Website and its features. For example, our performance cookies gather information about which pages on the Website are most frequently visited.

Analytics Cookies: The Websites may also use other similar cookies for analytics. These cookies are used to collect information about how visitors use the Website. The information is collected anonymously and is used to report on the number of visitors to the Website, where visitors come from, and which pages they have visited. You can also prevent the collection and use of data by Google (cookies and IP address) by downloading and installing the browser plugin available at https://tools.google.com/dlpage/gaoptout. Additional information can be found at http://www.google.com/analytics/terms/gb.html (Google Analytics Terms of Service and Privacy). Additionally, you can prevent Google Analytics from collecting such data on behalf of OneTwoWork by clicking on the following link: https://tools.google.com/dlpage/gaoptout.

Functionality Cookies: Functionality cookies are used to remember choices you make (such as language settings, country location, or other online preferences) and to collect anonymous information.

Our site may set and access certain first-party cookies on your computer or device. First-party cookies are those set directly by us and are used solely by us. We use cookies to facilitate and enhance your experience on our Site and to provide and improve our products and/or services. We have carefully selected these cookies and have taken steps to ensure that your privacy and personal data are respected and protected at all times.

Before cookies are placed on your computer or device, a pop-up window will appear asking for your consent to set these cookies. By giving your consent for the placement of cookies, you allow us to provide you with the best possible experience and service. If you wish, you can decline consent for the placement of cookies; however, certain features of our Site may not function fully or as intended. Some features of our Site depend on cookies to operate, and these cookies are "strictly necessary." Your consent will not be requested for placing these cookies, but it is important to be aware of them. You can still block these cookies by changing your browser settings, but please note that our Site may not work properly if you do so. We have taken care to ensure that your privacy is not compromised by allowing these cookies.

In addition to the controls we provide, you can choose to enable or disable cookies in your web browser. Most web browsers also allow you to choose whether you want to disable all cookies or only third-party cookies. By default, most web browsers accept cookies, but this can be changed.

You can decide to delete cookies on your computer or device at any time; however, you may lose any information that allows you to have faster and more efficient access to our Website, including but not limited to login and personalization settings.

It is recommended that you regularly update your internet browser and operating system, and consult the help and guidelines provided by the developer of your internet browser and the manufacturer of your computer or device if you are unsure how to adjust your privacy settings.

12. Security

To ensure the protection of your personal data, we always strive to apply the necessary standards for data protection and implement all required technical, organizational, and personnel measures in accordance with the applicable Personal Data Protection Law. These measures include, but are not limited to: technical security measures, organizational measures, and staff security measures related to physical access to the location where your data is stored, measures to protect the information security of your data in accordance with applicable regulations, as well as other measures deemed appropriate for processing and necessary to ensure the protection of specific personal data. Third parties processing the data are also obligated to apply all necessary technical, organizational, and personnel measures.

All information received from the client is stored on secure servers, and only authorized personnel have access to this information. We take reasonable precautions to prevent the loss, misuse, or alteration of your personal information. Our employees, contractors, and agents may have access to your personal information that we collect, but their use will be limited to performing their duties in relation to facilitating your use of the Services. Our employees, contractors, and agents who have access to your personal information are required to treat this information as confidential and are not authorized to use it for any other purposes except as outlined above or to address requests you submit to us.

13. Amendment of This Privacy Policy

We may occasionally update this Privacy Policy for various reasons, such as changes in laws and regulations, industry practices, technological developments, or if we alter our business in a way that affects the protection of personal data.

All changes will be immediately posted on our Website, and you will be considered to have accepted the terms of the Privacy Policy upon your first use of our Website after the changes. We recommend that you regularly check this page to stay up to date.

If changes to this Privacy Policy involve a reduction of your rights, we will ask for your explicit consent before you continue using the OneTwoWork website or One2tips website.

14. How can you contact us? Customer Support.

To contact us regarding your personal data and data protection, including submitting a data access request, please reach out to our data protection team at: legal@one2tips.rs.

For any inquiries regarding this Privacy Policy, or questions about the use of your personal information, you can contact us at: legal@one2tips.rs.

15. Privacy Policy Version

The version of the privacy policy dated 01.01.2025.

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