INTRODUCTORY PROVISIONS
This Privacy Policy regulates the purpose and manner of processing personal data of visitors or users of the Veerny website – a platform that enables open communication between parents and kindergartens (“Website”), operated by Smartlabs doo, company registration number: 21813516 (“Controller” or “Veerny”).
For transparency, this Privacy Policy also describes our actions as a processor, when we act on behalf of and for the account of our clients/kindergartens (“Client”), following their instructions, as further regulated by individual personal data processing agreements concluded with Clients in accordance with the Law.
It is considered that a visitor or user of the Website, prior to its use, has read and understood this Privacy Policy, as it, together with our Terms of Use, regulates our entire relationship.
The Privacy Policy is drafted in accordance with the Law on Personal Data Protection of the Republic of Serbia (“Law”). For any questions regarding this Privacy Policy, please contact us at hello@veerny.com.
VEERNY AS CONTROLLER
1. Whose data do we process?
This Privacy Policy applies to:
- all individuals accessing the Website,
- individuals who send us inquiries via e-mail hello@veerny.com,
- individuals who subscribe to our newsletter.
2. What data do we process?
Depending on your use of the Website, we collect and process:
- name, surname, and e-mail address of individuals who contact us via e-mail,
- name, surname, and e-mail address of individuals who subscribe to our newsletter,
- other information you voluntarily share with us via e-mail.
We do not process special categories of personal data (racial or ethnic origin, political opinions, beliefs, genetic or biometric data, sexual life or orientation).
We also do not automatically collect data, as we do not use cookies or similar tracking technologies.
3. Purpose of processing
We process your data for:
- responding to inquiries sent via e-mail,
- providing services to our Clients,
- improving our services,
- informing you about Veerny news and activities.
4. Legal basis for processing
We process data:
- to take steps at your request before entering into a contract,
- for the performance of a contract,
- based on legitimate interest,
- based on your consent (e.g., for the newsletter, with the option to unsubscribe at any time).
5. Data security
We apply technical, organizational, and personnel measures to protect data, including:
- access control,
- integrity and confidentiality protection,
- backups and encryption,
- firewall technology.
6. Data sharing
We do not share your personal data with third parties except:
- with your consent,
- when legally required (e.g., to public authorities).
7. International transfer
Your data may be transferred outside Serbia only:
- to countries with adequate data protection (e.g., EEA countries),
- or with appropriate safeguards in accordance with the Law and GDPR.
8. Data retention
We retain data only as long as necessary for the purpose of processing or until you withdraw consent.
9. Your rights
You have the right to:
- be informed about processing,
- access your data,
- correct inaccurate data,
- request erasure (“right to be forgotten”),
- withdraw consent,
- restrict processing,
- object to processing,
- lodge a complaint with the Commissioner.
10. Commissioner contact details
Commissioner for Information of Public Importance and Personal Data Protection of the Republic of Serbia
Address: Bulevar kralja Aleksandra 15, 11000 Belgrade, Serbia
E-mail: office@poverenik.rs
Phone: +381 11 3408 900
11. Controller contact details
E-mail: hello@veerny.com
VEERNY AS PROCESSOR
1. Whose data do we process?
When acting as a processor, we process personal data on behalf of the Client, including:
- kindergarten teachers and staff,
- parents/guardians of children,
- children whose parents/guardians have consented to their participation in the Veerny platform.
2. What data do we process?
Depending on the contracted functionalities, we may process:
- name, surname, and business e-mail address of teachers,
- name, surname, and e-mail address of parents/guardians,
- child’s data (name, surname, date of birth, allergies, daily activities, etc.),
- special categories of data (health, behavioral) with parental/guardian consent.
3. Purpose of processing
To provide the Client with the contracted service.
4. Legal basis
Legitimate interest and consent provided to the Client, in accordance with the Law.
5. Data security
The Client is responsible for protection, and Veerny assists by applying agreed measures.
6. Data sharing
Possible engagement of sub-processors only with the Client’s written authorization.
We currently use Digital Ocean LLC for data storage.
7. International transfer
Transfers are in accordance with the Client’s instructions or legal obligations.
8. Data retention
After service completion, data is deleted or returned to the Client unless retention is required by law.
9. Exercising rights
Veerny forwards all requests to the Client as Controller.
CHANGES TO THIS PRIVACY POLICY
We reserve the right to update this Privacy Policy to reflect changes in legislation and technical innovations. All changes take effect upon publication on the Website.