Who we are

Your personal data are collected and processed by SUPRABIT DOO BEOGRAD-NOVI BEOGRAD, Bulevar Mihajla Pupina 115e, registration no: 21526991 (“Suprabit”) for the purpose of implementing the Reciklomat Benefit Program (“Program”) aimed for rewarding customers who use the smart reverse vending machines (“Reciklomat”), as further detailed in this Personal Data Processing Notice. This means that in accordance with the law, Suprabit is accountable for the processing of your personal data.

We take seriously the responsibility to look after your Data and we are committed to protecting your privacy. The purpose of using your Data is to provide our Services to you.

This Privacy Policy applies to all Services provided by Reciklomat App. This Privacy Policy describes how we collect, store, and use your Data. There are steps you can take to control what we do with your Data and these steps are explained in this Privacy Policy.

Categories of Data, Permissions

Creating accounts and activities in the Reciklomat App

 To enable your membership in the Reciklomat App, when you create the account, we collect the data from the application form: name, surname, date of birth, email, and mobile phone number. The legal basis for processing is a contract created between you and Suprabit by acceptance of the Program Terms and Conditions. Provision of the data is voluntary. Membership can be canceled anytime.

On your membership account, we will record information relevant to your use of the Program such as the number of points earned, points validity, tier in the Program, and saved and redeemed offers.

The legal basis for processing these data is the performance of a contract created between you and Suprabit by acceptance of the Program Terms and Conditions and our legitimate business interest to motivate the recycling process on our devices and to attract and retain you as our valued customer, by a constant upgrade and personalization of Program offerings, as described below in section “Usage Analysis and Marketing”.

If you opted for receiving commercial messages legal basis to contact you in this manner is your consent. An “unsubscribe” link will be available in all such messages for withdrawal of this consent.

Withdrawal of consent has no effect on membership in the Program. After that, we will only send you information of relevance to your membership in the Program (points status, changes to the Program terms, and the like).

Access to functions on your mobile device

 The Program is designed in a way that allows you to be in control and decide how much you want to share. After downloading the application, you will be asked for separate consent/permission for access to certain information on your device:

Location data – If you have consented to so-called geolocalisation when using our app or in the settings of your mobile device via the “Allow permission” dialogue, we will use this function to be able to offer you the nearest Reciklomat machines related to your current location. We will process your location in this way, based on GPS and your network. Your location data will be deleted after closing our app.

Camera – The camera on your mobile device will be used for scanning QR codes on the Reciklomat Machine to collect the reward points and on points of sales when you use collected points in the Participating brands to receive the benefits. Functionality is enabled only if by an “Allow” option you consented to use this functionality.

Wi-Fi connection information – The app uses a Wi-Fi connection on your mobile device in order to set up a connection to the internet.

Other device functions – Accessing the other functions of your mobile device allows our app in particular to retrieve data from the Internet and error messages to be processed. In addition, it also enables our app to run on start-up and deactivate the idle state of the device. Also, as long as you have given your consent, our app can also send you so-called push messages, to keep you informed about current Program offers and promotions. The legal basis for the processing of your data is your consent. You may withdraw your consent/permission at any time by change of app settings and deactivating a particular function. Please note if you do not activate certain application functionalities, it will not be possible for you to use all of the Program rewards.

Usage Analysis and Marketing – We will retain and evaluate your shopping history, with what Brands and what Program offerings and rewards you use, or you click to like. This will enable us to make suggestions to you for other products which we believe you will also be interested in. In other words, to maximize your content with the Program offerings and to show you offerings relevant to your interests, we create dedicated usage profiles. Also, we will retain and evaluate information on your access to and previous activities in the application, to understand how people use the application so that we can make it more intuitive and adjust it to user affinities.

How long we retain your data

The data are kept for 5 years. The retention period is determined based on the time necessary to conclude the trends and improve our offering. The data are kept on our server in the Republic of Serbia. You have the right to object to this type of processing of your data at any time. To exercise this right, you can contact us by email or by mail at the address stated above at the beginning of this document.

Since this is the essential element of the Benefit Program, in some instances we will not be able to stop further processing of your data or to delete your data without deleting your membership account at the same time.

Who do we share your data with

Participating Brands – Participating Brands who participate in the Program with their offerings have access only to the minimum data required so that you can redeem at their establishments the rewards we agreed for you. For example, your membership ID number, and date of birth if you select to use birthday rewards. We do not share with them your contact data or your name. And, with all of them, we have signed a data processing agreement.

Please note that it is likely that some of the Participating Brands themselves already have some of your personal data or that they may collect your data separately from the participation in our Program. In such a case they are exclusively liable for processing your data and your relationship with them is subject to their terms.

Service Providers – For the implementation of the Program, we use various service providers who, in accordance with our instructions, have access to your data as so-called processors.

We can reveal your data to the competent authorities upon their order or when we believe that is necessary for compliance with legal obligations, or to protect our interests.

TRANSFER OUTSIDE OF REPUBLIC OF SERBIA – data we collect are not transferred and processed out of Serbia.

Application Security

We use security measures that we continually optimize according to technical and legal developments in order to make sure that your data is protected from accidental or intentional manipulation, loss, destruction or access by unauthorized third parties.

User Rights

Upon request, you have the right to receive information about your personal data processed by us free of charge. You have the right of rectification and deletion of your personal data, a right to limitation of processing, and a right to data transferability. You have the right to object to processing done by us for our legitimate interests. You have the right not to be subject to a decision based solely on automated means including profiling, if the decision produces legal effects concerning you or significantly affects you. If our processing of your personal data takes place based on your consent, you have the right at any time to revoke this consent. This revocation does not make unlawful the processing that took place before you revoked consent.

In addition, you may complain to the Commissioner for Information of Public Importance and Personal Data Protection, address: 15, Bulevar kralja Aleksandra str, Belgrade 11120, Serbia, оffice@poverenik.rs and you may file a lawsuit to the competent court.

For any questions about the processing of your personal data and to exercise your rights, you can contact us by email or by mail at the address at the beginning of this document.