Privacy Policy

(Last updated June 1st, 2024)

This Policy was designed to inform the website’s visitors about how personal data is gathered, used, stored or otherwise processed while browsing our website. We are the owner of this website, and we are deemed as the data controller over your personal data. We are: Flow Ninja doo, Milutina Milankovića 11g, 11070 Novi Beograd

We may modify this Policy from time to time, to reflect the changes to our website and in our services. To ensure transparency, please review it for any essential or minor modifications that may have been made in the meantime. Our Policy is also reviewed once a year. This Privacy Policy was reviewed on 1st of April 2024.

Types of data we collect

  • Identification data
  • Financial data
  • Professional details
  • Professional qualifications
  • Personal details
  • Electronic Identification data

More details about the types of data we collect are available below. 

How we use your data

  • Recruitment for job positions
  • Delivering and customizing our service
  • Communicating with you
  • Analytics and statistics
  • Marketing and promotion

More details about how we use your data are available below.

Third parties who process your data

Entities who help us to regularly provide and further develop our services may be the recipients of your data.

We may transfer your personal data outside of Republic of Serbia and/or outside the European Economic Area to provide our services on a regular basis and/or to develop our services further.

If you want to find out more details related to the processing of your personal data by third parties, please read it below. 

We use cookies

The use of cookies enables us to improve site navigation, analyze on-site behavior of everyone who visits the website, and promote our products and services. With cookies we process standard internet log information and details of the behavioral pattern of our website visitors. Read more in our Cookie Policy.

When and how we collect data

We may process various categories of your personal data to provide our services to you, recruit you for a position in our Company, improve your experience with our services, further develop them and to secure and maintain regular functionality of our website, based on:

  • Consent
  • Legitimate interest
  • Entering of performance of the contract

We do not collect or retain your personal data longer than is necessary for the purposes we stated. More details about how and when we collect your data are available below.

Know your rights

  • Right of access
  • Right to deletion
  • Right to rectification
  • Right to object
  • Right to restriction of processing
  • Right to lodge a complaint

If you want to find out more about your rights and how to exercise them, please read the separate policy section about that. If you have any concerns about your privacy or wish to exercise your privacy rights, you may reach out to us via support mail.‍‍

Types of data we collect

By using our services, you may disclose various pieces of information, including those that are considered as personal data. When your personal data is processed, you are a data subject and you are entitled to exercise your rights guaranteed by relevant data protection legislation, as explained in this Policy. 

Considering that we determine the purposes and means of processing personal data on our website, we are legally considered to be data controller over your personal data on this website. Being a data controller provides us with the opportunity to process your personal data, but also obligates us to protect it in the way regulated by applicable legislation.

Please note that different categories will be processed in different situations. Read more about purposes for processing your personal data in the “How we use your data” section of this Policy. 

Check the types of personal data we collect, below:

Identification data

Personally identifiable information 

We process your email address, name, phone number, address, social media accounts and ID assigned by the controller, when you apply for a job position in our Company, apply for our services, subscribe to receive newsletter and other communication from us and create an account on our website.

Electronic identification data

When you use our website, we may process the IP address of the device you use, the type and version of browser and operating system you use, as well as the time of logging in. 

Professional details

We process information about your education, professional qualifications, work experience and current employment when you apply for the job position at our Company. Professional details such as company name and position may be processed from our potential clients when they apply for our services.

Personal details

We process your personal details such as age, date of birth, nationality, sex, date of birth when you apply for the job position in our Company.

Video recordings 

Video recordings are processed when you apply for the job position in our Company.

How we use your data

By using our services, you may disclose various categories of personal data. You may check which categories of personal data we process in the “Types of data we collect” section of this Policy. Check below the purposes for processing your personal data.

Identification data

When you apply for a job position at our Company, we process your email address, name, phone number, address for the purpose of recruitment, getting in contact with the applicants to assess their suitability for the position.

We process email addresses and names when our potential clients apply for our services, for the purpose of business communication and negotiations on possible cooperation.

We may process email addresses and names and ID assigned by the controller, of our website’s visitors for the purpose of communicating with them, sending commercial communication and other materials upon their consent. Same information may be processed when users create an account on our website, for the purpose of delivering our materials, services and courses.

We may process your electronic identification data to enable communication between your device and our server and to determine your approximate geolocation, which may be further used for service customization. Your approximate location may also be used for analytical purposes. The processing of details about the browser and operating system you use is necessary to ensure the regular provision of our services to you. We may also need this data to solve technical problems should they emerge.

Financial data

Information about your credit card number and bank account number are processed when you choose to enroll in our educational courses and masterclasses, for the purpose of processing your payments and providing you with related educational material. 

Professional details

Information about education, professional qualifications, work experience and current employment are processed when you apply for the job position at our Company, for the purpose of recruitment and assessing the applicant's suitability for the position in question. Professional details such as company name and position may be processed from our potential clients when they apply for our services, for the purpose of business communication and negotiations on possible cooperation.

Personal details

Information such as age, date of birth, nationality, sex, date of birth is processed when you apply for the job position in our Company, for the purpose of recruitment and assessing the applicant's suitability for the position in question.

Video recordings

We process video recordings in a form of a Loom video when you apply to the job position at our Company, for the purpose of recruitment and checking the language knowledge level, assessment of personal character, collecting information useful for assessment of a candidate.

Third parties who process your data

We may share your personal data with third-party vendors, and other service providers we engage to perform tasks on our behalf, in certain circumstances. This enables the improvement of our site functionalities, user experience on our products and providing you with our services. The categories of recipients to whom personal data may be disclosed are:

  • Entities who help us to regularly provide and further develop our services (e.g., analytics, maintenance, marketing and development). These entities include website analytics companies, commercial communication providers and others. They are allowed to process your information as reasonably necessary to perform delegated tasks. We engage in proper contractual relations with them to ensure secure processing of your personal data. 
  • Public authorities and law enforcement agencies when we are legally required or permitted to do so.

We will conclude Data Protection Agreements with recipients of your data where required.  

When and how we collect data

Legal basis

According to applicable regulations, processing shall be lawful when the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party. Our use of your personal data, specifically electronic identification data, may be based on the legitimate interest to ensure the improvement of our product’s effectiveness and our service, measure the current effectiveness of the advertising campaigns, solve technical problems should they emerge. We rely on our legitimate interest to enable communication between your device and our server and to determine your approximate geolocation, which may be further used for service customization and for analytical purposes.  

Processing shall be lawful when the data subject has given consent to the processing of his or her personal data for one or more specific purposes. We rely on your consent when using your personal data for recruitment, delivering our services, direct marketing purposes, creating your profile.

More about the above-mentioned purposes for processing your personal data can be found in the “How we use your data” section of this Policy.

Retention and security

We do not collect or retain your personal data longer than is necessary for the purposes explained in this Policy. We store your personal data for different time periods depending on the purpose it was collected.

Some personal data may be deleted automatically based on specific schedule. 

We delete personal data when you withdraw previously given consent, such as data collected for direct marketing purposes and recruitment. Those would be your personally identifiable information, personal preferences. 

Personal data we hold about you will be deleted when you choose to exercise your right to deletion. 

We may further retain some personal data for business practices based on our legitimate interests, such as for the product and services improvement and misuse prevention.

We regularly make sure that your data is kept up to date and stored securely. To achieve that we apply different technical and organizational measures to ensure the protection of your personal data against accidental or unlawful loss, alteration, theft, unauthorized disclosure or access, unauthorized use, potential data breaches and against all other unlawful forms of data processing.

Based on business needs and security requirements we apply restrictions of access control to your personal data. Access to your personal data is only granted to trained staff with authorization, whose knowledge and skills are necessary to process personal data we gather adequately.

Know your rights

Processing of personal data that may occur on this website is about you and your personal data. Therefore, you are regarded as a data subject, under the relevant data protection laws. 

As a data subject you are entitled to exercise the rights listed below:

Right of access

You have the right to obtain confirmation from us as to whether or not personal data concerning you is being processed, information about the processing of your data, your rights and where applicable to request access to the data.

Right to erasure (right to be forgotten)

In certain circumstances you have the right to request that we erase the information we hold about you. These are as follows:

  • Where the data is no longer needed for the purposes, it was collected
  • Where you have withdrawn consent for the processing of your data and there is no other lawful basis on which we can continue to process your data
  • Where you objected to the processing and there are no overriding legitimate grounds to continue
  • Where the data has been unlawfully processed
  • Where the data must be erased for the purpose of compliance with a legal obligation.

We will be exempt from this obligation if it is impossible to comply with or if the identity of the requester cannot be verified, as we are able to act only upon verifiable consumers’ requests.

Right to rectification

You have the right to ask us to delete inaccurate personal data concerning you. Taking into account the purposes of the data processing, you have the right to have incomplete personal data completed and inaccurate data corrected.

Right to object to the processing of your personal data

At any time, you have the right to object to our processing of your data on grounds relating to your situation. Upon your objection, we will stop processing your data unless we can demonstrate compelling legitimate grounds for continuing the processing which override interests of your fundamental freedoms and rights, or if further processing is necessary for the establishment, exercise or defense of legal claims.

Right to restriction of processing

You have the right to seek the restriction of the processing of your personal data in the following circumstances:

  • If the accuracy of the data is contested, processing may be restricted for the period necessary to allow us to verify its’ accuracy;
  • The processing is unlawful, and you request restriction instead of erasure;
  • We no longer need the data for the purposes it was collected, but data is still needed in connection with establishing, exercising and defending legal rights.
  • If you objected to the processing of your personal data while awaiting verification on whether our legitimate interests for processing your data overrides the interest of your fundamental rights and freedoms.

Right not to be the subject of automated decision making

You have the right to object to our processing of your data for automated decision making, including profiling, where such processing produces legal effects concerning you or similarly significantly affects you. Upon your legitimate objection, your personal data will no longer be processed for automated decision making.

Right to data portability

Under certain circumstances you have the right to receive your personal data which you have provided to us in a structured, commonly used and machine-readable format (i.e., in digital form). You have the right to request the transmission of that data to another entity without hindrance from us, if such transmission is technically feasible.

Right to withdraw consent

We rely on your consent to process some categories of your personal data. You can withdraw your consent at any time without giving any reason to us and without any charge to you.

The withdrawal of consent does not affect the lawfulness of processing based on consent before its’ withdrawal.

Right to lodge a complaint

If you feel that your personal data rights have been breached, you have the right to lodge a complaint with your local data protection authority.

As we are established in Serbia you may choose to contact the Commissioner for information of public importance and personal data protection.

How to exercise your rights

If you have any questions regarding the processing of your personal data explained in this Policy or wish to exercise any of your rights listed above, please contact us via support mail.