Ocean GoSoftware (hereinafter: we and/or the Controller), as the intellectual property rights holder of the software solution used by preschool institutions with which we have appropriate contracts, serves as the data processor for the personal data processed through the application.

The Controller handles your data transparently and entirely in accordance with the Law on personal data protection ("Official Gazette of RS" No 87/2018).


The purpose of this Privacy Policy is to inform you of all the details of the processing and use of your personal data that may be collected when you use this app, as well as the rights you have in connection with such processing of your data.


By downloading and/or using this app, you consent to the processing of your personal data in accordance with the terms set out in this Policy. Therefore, please read this Privacy Policy in detail, since it explains how and which of your personal data we collect, for what purposes and on what basis, as well as what rights you have in relation to the processing of your personal data and how you can exercise them.


Personal data we collect, purpose and legal grounds for processing


Firstly, we would like to point out what is considered to be personal data in accordance with the Law on personal data protection. Personal data is any data relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.


When using this app we collect and process certain information about you, so that we can enable you to use this app, to fulfill our legal obligations, to act on your requests, as well as for other purposes specified in this Privacy Policy.


While using our Service, we may require you to provide us with certain personally identifiable information, including but not limited to username, email, your name, address, personal identification number, ID card number, contact details, decision number approving the reimbursement of the costs of staying in preschool, current account, information on invoices issued for kindergarten services, information on notifications that were sent to you (text messages, email, notifications).


Furthermore, we process your child’s personal data such as his or her name, address, personal identification number, date of birth, date of departure to preschool institution, previous experiences with preschool institutions, health information condition (allergens and health problems), health center, description of health problems, notes of the pedagogue/speech therapist/educator/psychologist/doctor, data on the child's absences, photo, personal identification number, as provided by you. You agree and consent to us processing your child’s personal data in accordance with the terms and conditions of this Data Protection Policy.


Please note that your name, contact details, child’s personal data, are obligatory and necessary in order to perform the contract between us, so if we are not allowed to process such information, we may not be able to provide you with the services.


We may also process other personal data such as your activities through the app, information collected through the use of Cookies (as defined below) and in a case of an error in the app we collect

data and information (through third-party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our Service, the time and date of your use of the Service, and other statistics.


Additionally, we also process your data when you contact us for any reason, when sending any request, etc. Data processing in this case is necessary in order to comply with our legal obligations in connection with the request you submitted.


In addition to the purposes of data collection and processing set out in this Privacy Policy, we may occasionally collect data for other purposes, in which case we will notify you in advance of the intended purpose of processing, the data that would be collected and every other circumstances relevant to such collection and processing of your data, so that you could decide if you want to give consent for such data processing.


Cookies


Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites that you visit and are stored on your device's internal memory.


This Service does not use these “cookies” explicitly. However, the app may use third-party code and libraries that use “cookies” to collect information and improve their services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use some portions of this Service.


Who do we share personal data with


Access to your data have only employees of our company who have the right to process it considering the type of work they perform and only to the extent necessary to fulfill the purposes stated in the previous section of this Privacy Policy.


Furthermore, we may, in accordance with the law, transfer your personal data to certain categories of recipients, so your data may be made available to the following recipients:



The transfer to other countries or international organizations is carried out exclusively under the conditions specified by the regulations governing the transfer of personal data. Accordingly, data is transferred only to countries that are members of the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data, that is, which have been determined to provide an adequate level of protection. In the case of transfers to countries that are not members of the mentioned Convention, the transfer of data is carried out on the basis of a contract concluded between us and third parties that contain standard contractual clauses, as well as with the implementation of all necessary technical, organizational and personnel measures for the protection of personal data, which provide the same level of protection of your personal data as domestic

regulations as well as the integrity and confidentiality of personal data. Such measures include prevention of misuse, loss, damage, unauthorized modification, access or processing and other risks to which it may be exposed by human action, physical or natural environment.


Data retention


Unless the law prescribes different retention period, we keep your data for the period necessary to achieve the processing purpose or as required by relevant laws.


We store and process your data on servers located in Serbia.


Please note that your data, in accordance with the consent you have given for processing by our partners, may be stored for periods that are different from those stated here as well as on their servers, therefore we ask you to familiarize yourself with their Privacy Policy.


We do not use automated decision-making or automated profiling.


Your rights regarding processing of your data


Please be informed that you have following rights regarding the collection and processing of your data by us:


Right to access the data - You have the right to be informed about your data we process, as well as the right to request a copy of your personal data.


Right to withdraw the consent - You have the right to withdraw the consent. Please note that in accordance with the law, such withdrawal does not affect the lawfulness of processing based on consent before its withdrawal. The withdrawal can be given in written form, including an e-mail, or you can deactivate your account.


Right to rectification - You have the right to rectification of your inaccurate personal data without undue delay as well as the right to request correction, addition, and update if the data is incomplete.


Right to erasure - You have the right to request the erasure of data where one of the following grounds applies: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, in case of consent withdrawal (where there is no other legal ground for the processing), in case you object to the processing and there are no overriding legitimate grounds for the processing, the personal data have been unlawfully processed, where your personal data have to be erased for compliance with a legal obligation, when the personal data have been collected based on consent of a data subject without the appropriate age to consent.


Right to restriction of processing - You have the right to request restriction of processing if you believe that the data is inaccurate, if the processing is unlawful and you oppose the erasure of the personal data and requests the restriction of their use instead, your data is no longer needed for the purposes of the processing, but you require such data for the establishment, exercise or defense of legal claims, when you have objected to the processing of your data based on legitimate interest.


Right to portability - You have the right to receive the personal data concerning you which you have provided to us, and the right to have such personal data transmitted directly to another controller where technically feasible.

Right to object - If the processing is based on legitimate interests, or is necessary for the purpose of performing tasks in the public interest or the execution of legal regulations, you have the right to submit an objection, after which we will suspend further processing of that data, unless there is an overriding legal basis for processing over your interests, rights or freedoms, or are necessary to submit or exercise a legal claim or defend against it.


Right to lodge a complaint: If you believe that your rights to the protection of personal data have been violated, you can lodge a complaint with the Commissioner for Information of Public Importance and Personal Data Protection: https://www.poverenik.rs.


Collection and processing of children’s data


We do not knowingly directly collect data about children under the age of 13, except for the data on your children that you provide us with. If a parent or guardian of a child under a certain age becomes aware that his/her child has provided us with data without their consent, he/she should contact us at podrska@thinkit.rs, in order to determine all aspects of such processing and disable the same if necessary.


Security of processing


We strive to protect your data at the highest possible level, so in that sense we use technical protection measures such as firewall, encryption, passwords access restriction; physical protection measures such as storing data in special locked rooms with limited access; organizational and personnel measures such as limited access control, adequate training of employees.


Services used to collect and process data via app


The app does use third-party services that may collect information used to identify you.


You can find additional information on such third-party service providers used by the app on the links below:


Google Play Services


Links to Other Sites


This Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.


Changes to the Privacy Policy


This Privacy Policy is effective as of 20-10-2023. Any changes to this Privacy Policy will be posted in the app, so you can familiarize yourself with those changes. Please note that changes to the Privacy Policy will not reduce the level of protection of your data.