PRIVACY POLICY

Anari AI is committed to protecting the rights and freedoms of individuals with regard to the processing of their Personal Data in accordance with the Serbian Law on Protection of Personal Data (Official Gazette of RS no. 87/2018) and EU GDPR. This Privacy Policy serves as a rulebook through which we would like to inform you about the personal information we collect, how it is processed, and for what purpose.

Given the fact that the protection of an individual’s privacy on the internet is vital for the future of all individuals that perform their activities on the internet and for opening the road to a more widespread Real Internet Economy, Anari AI has drafted this Privacy Policy with a great desire to express its strong commitment to the rights of individuals regarding the protection and confidentiality of their Personal Data. This Privacy Policy covers how Personal Data can be processed.

Anari AI processes the Personal Data of individuals in accordance with this Privacy Policy. Any violation of this Privacy Policy can lead to Anari AI, as the Data Controller to be legally responsible for the consequences of that injury.

Α. GENERAL INFORMATION

Validity of this Privacy Policy.

This Privacy Policy applies to Personal Data which is provided originating from the lawful grounds described below. The use of any of the Personal Data collected from Cookies is subject to prior notification and consent of the Data Subject (you) in accordance with the Cookie Policy.

The Data Controller.

The Data Controller for https://anari.ai/ and its content is Anari AI.

Joint Controllers and Data Processors

Anari AI uses tools and software of:

  • Atlassian
  • Mailchimp
  • Hubspot
  • AWS
  • Google

with which Anari AI has a valid legal contract for processing Personal Data where processing is done on the grounds of performance of a contract, on grounds of consent for content on the official website of Anari AI, and based on our legitimate interest.

Atlassian is a company based in Sydney, Australia, and is the Data Processor for the said processing whereas in these cases the Data Subject has all the rights according to the Serbian National Data Protection Law and EU GDPR (object to processing, transfer of data, copy of Personal Data, etc.) which is in more detail explained in Section H below. Here are the links to Atlassian’s Privacy Policy and Terms of Service and here is the link to our Data Processing Addendum.

Mailchimp is a company based in Atlanta, Georgia, US, and is the Data Processor for the said processing whereas in these cases the Data Subject has all the rights according to the Serbian National Data Protection Law and EU GDPR (object to processing, transfer of data, copy of Personal Data, etc.) which is in more detail explained in Section H below. Here are the links to Intuit’s Privacy Policy and Mailchimp’s Terms of Service and here is the link to our Data Processing Addendum.

Hubspot is a company based in Cambridge, Massachusetts, US, and is the Data Processor for the said processing whereas in these cases the Data Subject has all the rights according to the Serbian National Data Protection Law and EU GDPR (object to processing, transfer of data, copy of Personal Data, etc.) which is in more detail explained in Section H below. Here are the links to Hubspot’s Privacy Policy and Terms of Service and here is the link to our Data Processing Agreement.

AWS is a company based in Seattle, Washington, US, and is the Data Processor for the said processing whereas in these cases the Data Subject has all the rights according to the Serbian National Data Protection Law and EU GDPR (object to processing, transfer of data, copy of Personal Data, etc.) which is in more detail explained in Section H below. Here are the links to AWS’s Privacy Notice and Terms of Service and here is the link to our Data Processing Addendum.

Google is a company based in Mountain View, California, US, and is the Data Processor for the said processing whereas in these cases the Data Subject has all the rights according to the Serbian National Data Protection Law and EU GDPR (object to processing, transfer of data, copy of Personal Data, etc.) which is in more detail explained in Section H below. Here are the links to Google’s Privacy Policy and Terms of Service and here is the link to our Data Processing Amendment to Google Workspace and our Data Processing Amendment to Google Analytics.

Anari AI has business partners with which it has established business collaboration in the service industry, these service providers are not performing those services on Anari AI’s exclusive request and they themselves determine how they process Personal Data, for the purpose of carrying out remarketing campaigns and statistical analysis.

In some cases, Anari AI may engage an external expert or contractor for the completion and/or performance of the contract with its clients, users, and subscribers, and in that case, the external expert or contractor will have a separate Data Processing Agreement with Anari AI according to Serbian National Data Protection Law and EU GDPR.

What Personal Data does Anari AI collect?
  • From visitors of the website of Anari AI – IP address, internet service provider, geolocation, country, type of device used to access the internet, name of the site that redirected you to Anari AI website, operating system, and browser type.
  • From subscribers to Anari AI content – IP address, geolocation, name and surname, business name, website URL, email address, time of subscription, and information regarding content and interest subscribers seek.
  • From users and customers of Anari AI products and services – business name, name and surname, email address, gender, time of subscription, and other additional information necessary for the performance of services.
  • From employment candidates of Anari AI – name and surname, address of residence, date, and place of birth, gender, relationship status, unique ID number, nationality, social security number, CV, financial information, communication information, and other additional information necessary for legal requirements.
How does Anari AI use my personal data?

Anari AI will process the Personal Data provided below only as defined in this Privacy Policy. More information can be found in Sections B, C, and D below, whereas information on the processing of Personal Data by Anari AI based on the performance of a contract can be found in Section B below, information on the processing of your Personal Data based on your consent can be found in Section C below and information on the processing of your Personal Data based on our legitimate interest can be found in Section D below.

Duration of processing of personal data.

Anari AI processes and uses your Personal Data for the purpose of performance of a contract (see B below), based on your consent (see C below) and based on its legitimate interest (see D below).

  • In case the legal ground for processing of Personal Data is the performance of a contract, Anari AI will store your Personal Data only for as long as contractual relations remain and, in any case, no longer than 5 years from end of contractual relations.
  • In case the legal ground for processing of Personal Data is consent, Anari AI will process your Personal Data for a period of 2 years from the moment consent was given, after which you will be asked for consent again, and so on every 2 years.
  • In case the legal ground for processing is our legitimate interest, Anari AI will process your Personal Data for a period that does not exceed the duration of its legitimate interest.

Additionally, Anari AI will stop processing your Personal Data if you have a valid objection and if you request so, or if you withdraw your consent (in cases that you have given your consent to Anari AI to use your Personal Data). However, whenever it is required as a legal obligation under the Serbian National Law on Data Protection and EU GDPR, Anari AI will keep your Personal Data for a longer period of time and whenever your Personal Data is required for Anari AI to claim or defend itself against legal claims, your Personal Data will be kept until the end of the corresponding retention period or until such claims are settled.

The use of website and platform by children.

The website and platform are not intended for children under 18 years of age. If you are under 18 years old you may not use the website and platform without the prior consent of your parents or legal guardian.

Links to external websites.

The website and platform may contain links to other external websites. Anari AI is not responsible for the treatment of your Personal Data on other websites or for their privacy policy and the content of external internet sites. Therefore, we suggest that you carefully read the privacy policies of these external internet sites.

Application of the Privacy Policy.

Please note that this Privacy Policy applies to the processing of your personal data when you use any of Anari AI products or services, Anari AI websites, as well as any of our products and service we offer together with our partners, which includes a link to this Privacy Policy.

EXPLICIT CONSENT

Anari AI d.o.o. is based in Novi Sad, Republic of Serbia, and is under the authority and jurisdiction of the Serbian Data Protection Authority (DPA) and as the applicable law, the Serbian Personal Data Protection Law which is why Data Subjects (visitors, subscribers, users and customers under Sections B, C, and D below) give their explicit consent for use of their Personal Data in Serbia and are informed in advance of such use which they agree on. In case the Data Subject does not agree after already giving consent by submitting for content, the conclusion of a contract, or expressing interest by sending its Personal Data to Anari AI, the Data Subject can at any time withdraw consent according to Section I below. Anari AI does not transfer Personal Data out of Serbia to third countries without your explicit consent.

Β. HOW ANARI AI USES YOUR PERSONAL DATA FOR THE PERFORMANCE CONTRACT

In the following cases Anari AI is authorized to process your Personal Data in accordance with the current legislation on the protection of personal data in the Republic of Serbia and the EU for the performance of the contract:

  • If you establish a user account or become our client on the official website https://anari.ai/ in order to obtain content, which includes all content on Anari AI’s official website such as information, e-mails, newsletters, whitepapers, etc., Anari AI is authorized to process the following Personal Data: name and surname, address of residence, banking details, billing information, email address, gender, IP address, geolocation, business name, website URL, time of subscription and other additional information necessary for the performance of the services and contract with you as the user. Anari AI will provide you with the opportunity at any time during the processing of Personal Data to clearly object to the processing of personal data by submitting an email to the official email address at the end of this Privacy Policy. However, in cases where the retention of data is necessary due to legal obligations of Anari AI, then Anari AI retains Personal Data for a longer period of time but only during the existence of that legal obligation or when the personal data is needed for Anari AI to defend against a claim or lawsuit. To see the list of your full rights regarding our processing of your Personal Data please see Section H below.
  • If you sign up to the mailing lists, express interest in establishing contact with us or express interest in receiving content from Anari AI which includes all content on Anari AI’s official website such as information, e-mails, newsletters, whitepapers, etc., Anari AI is authorized to process the following Personal Data: name and surname, address of residence, email address, gender, IP address, geolocation, business name, website URL, time of subscription and other additional information necessary for sending and delivering such content. Anari AI will provide you with the opportunity at any time during the processing of personal data to clearly object to the processing of personal data by submitting an email to the official email address at the end of this Privacy Policy. However, in cases where the retention of data is necessary due to legal obligations of Anari AI, then Anari AI retains Personal Data for a longer period of time but only during the existence of that legal obligation or when the Personal Data is needed for Anari AI to defend against a claim or lawsuit. To see the list of your full rights regarding our processing of your Personal Data please see Section H below.
  • If you use our contact form, or chatbot to send us a message, or contact us through the Anari Customer Service Desk webpage we will use the information in the form only to respond to the question and contact you regarding your queries. The information you provide through our contact form will not be processed in any way and will only be used to communicate with regard to your questions and to provide additional answers if needed and will be retained only until that purpose is fulfilled.
  • If you apply for a job at Anari AI via job forms, Anari AI is authorized to process the following Personal Data: name and surname, email address, CV, IP address, geolocation, time of application submission, and other additional information necessary for the assessment of work candidates and establishing an employment relationship. Anari AI will provide you with the opportunity at any time during the processing of personal data to clearly object to the processing of personal data by submitting an email to the official email address at the end of this Privacy Policy. However, in cases where the retention of data is necessary due to legal obligations of Anari AI, then Anari AI retains Personal Data for a longer period of time but only during the existence of that legal obligation or when the Personal Data is needed for Anari AI to defend against a claim or lawsuit. To see the list of your full rights regarding our processing of your Personal Data please see Section H below.

C. HOW DOES ANARI AI USE YOUR PERSONAL DATA ON THE GROUNDS OF YOUR CONSENT

In the following situations, Anari AI will process your Personal Data in accordance with the current legislation on the protection of personal data in the Republic of Serbia and the EU after consent is given to specific actions of processing.

Cookies on Anari AI’s official website are small files that are installed on your device before you give your consent only in case of necessary Cookies and after your consent is given for all other Cookies i.e., analytics Cookies. The necessary cookies are necessary for the normal operation of the website of Anari AI. Analytics Cookies are used by Anari AI to provide content that best suits you and your interests. They can be used to send targeted ads/offers, limit ad impressions or measure the effectiveness of an ad campaign. They can also be used to keep track of the website you have visited to determine which online marketing channels are more effective and allow us to reward external websites and partners that promoted our website. Personal Data obtained in this way will be used for the personalization of content and ads, to provide social media features, and to analyze traffic. We also reserve the right, in the future to share information on how you use our website with our social media, advertising, and analytics partners that can combine them with other information provided by you or gathered based on the use of other services with the aim of improving our services. Anari AI is authorized to process the following Personal Data: IP address, internet service provider, geolocation, country, type of device used to access the internet, name of the site that redirected you to Anari AI’s website, operating system, and browser type. For more details about cookies and how to turn them off visit CookiePolicy.

Signing up and expressing interest in receiving content from Anari AI which includes all content on Anari AI’s official website such as information, e-mails, newsletters, whitepapers, etc., Anari AI is authorized to process the following Personal Data: name and surname, address of residence, email address, gender, IP address, geolocation, time of subscription and other additional information necessary for sending and delivering such content. You can withdraw your consent at any time by sending an email to the official addresses of Anari AI as described in Section I below and Anari AI will immediately stop processing your Personal Data.

Necessary Cookies or Essential Cookies.

These Cookies are absolutely essential for the proper functioning of the website. They let you search the website and use its options. These cookies do not identify you. Without these cookies, our website cannot function properly.

You can prevent the storage of cookies by selecting “Block cookies” in your browser settings. However, blocking all cookies might have a negative impact on the use of many websites. If you still want to delete and disable cookies, you need to update the settings of your web browser (information on how to delete and disable cookies is available in your browser by choosing Help) or more information can be found at the following addresses:

D.HOW DOES ANARI AI USE YOUR PERSONAL DATA ON THE GROUNDS OF LEGITIMATE INTEREST

In the following cases Anari AI is authorized to process your Personal Data in accordance with the current legislation on the protection of personal data in the Republic of Serbia and the EU when the legitimate interest exists:

  • The legitimate interests of Anari AI provide a legal basis for processing for direct marketing purposes, provided that the interests or the fundamental rights and freedoms of the data subject are not overriding, taking into consideration the reasonable expectations of data subjects based on their relationship with the controller. Such legitimate interest exists where there is a relevant and appropriate relationship between the Data Subject and Anari AI in situations such as where the data subject is a client or in the service of Anari AI, i.e. when the Data Subject is a user/customer (Section B) or a subscriber of Anari AI (Section B and Section C). Such processing will be aimed strictly for direct marketing purposes and Anari AI is authorized to process the following Personal Data: IP address, geolocation, name and surname, and information regarding content and interest subscribers seek for direct marketing purposes for content on social media platforms such as Instagram, Facebook and search engines such as Google.
  • The legitimate interests of Anari AI provide a legal basis for processing for business development purposes, provided that the interests or the fundamental rights and freedoms of the data subject are not overriding, taking into consideration the reasonable expectations of data subjects based on their relationship with the controller. Such legitimate interest exists where there is a relevant and appropriate relationship between the Data Subject and Anari AI in situations such as where the data subject shows interest in getting content created by Anari AI such as whitepapers, eBooks, etc. (Section B and Section C) or is a subscriber of Anari AI (Section B and Section C). Such processing will be aimed at organizing meetings, sending business offers, and developing business opportunities, and Anari AI is authorized to process the following Personal Data: name and surname, address of residence, email address, gender, IP address, geolocation, business name, website URL, time of subscription and other additional information necessary for establishing contact and sending and delivering such content.

E. PROTECTION OF DATA

In accordance with the level of technological advances, and the cost of their implementation, the nature, extent, the circumstances, and the purpose of treatment, as well as the probability of occurrence of a risk and the risk level for the right and freedom of individuals, Anari AI implements the appropriate technical, personal and organizational measures in order to reach an adequate level of security in relation to the risk of data processing.

Anari AI protects your information using the following protective measures:

Antivirus protection;

  • 2 step verification process;
  • Encryption of Personal Data;
  • Pseudonymisation of Personal Data;
  • other appropriate technology and information protection.

Anari AI has taken appropriate measures to all systems, services, and equipment used for the processing of your personal data that meet acceptable standards of information security and protection of personal data. Anari AI carries out regular checks and scans in order to ensure that technical safeguards on hardware and software are functioning properly.

Access to personal data collected by Anari AI is provided only to those who have a legal basis for processing such as specific employees that have user access to the personal data which is stored only on a need-to-know basis. The system of user access defines appropriate levels of access and each user has the right to access the data stored. The system user access defines precisely what data the user has access to and if the user can access the personal data and all the ways in which they can be processed. In this case, users are employees and IT support. User access is used by employees to comply with their roles in the business process in Anari AI and the descriptions of their operations are in accordance with the organization of business within Anari AI. Employees are given access only to those personal data which are necessary for the implementation of their necessary activities and do not excess those needs.

F. TRANSFER OF PERSONAL DATA

Anari AI may transfer Personal Data to third countries. If the Data Subject has given explicit consent to transfer its Personal Data to another country, Anari AI does not in any case transfer Personal Data to any country other than the group of countries signatory to the Convention of the Council of Europe Convention on the Protection of Individuals with regard to Automatic Processing of Personal Data or countries that do not have an appropriate level of protection of personal data.

G. INFORMATION REGARDING THE WEBSITE OF ANARI AI

This information applies only to our website at https://anari.ai/. If you are redirected to other websites via links on our site, please inform yourself about the proper handling of your Personal Data on those websites, Anari AI is not responsible for the processing of your Personal Data on any other website.

Built-in content from other websites

Articles and news on our website may include embedded content (e.g., videos, photos, articles, etc.). Built-in content from other websites that are not owned by Anari AI are to be considered in the same way as if the visitor has visited that website and Anari AI is not responsible for processing your Personal Data on any other website.

These websites may collect information about you using Cookies, install additional third-party tracking, and monitoring your interactions with these embedded contents, including tracking of interaction with the embedded content if you have an account and are logged into the site and Anari AI is not responsible for the processing of your Personal Data on any other website.

Updates and changes to Privacy Policy

Anari AI may change this Privacy Policy at any time. If Anari AI makes changes to this Privacy Policy, it will notify you by publishing information here before the changes take effect and inform you directly of the changes before they come into legal force if you are a subscriber, user, or customer.

H. YOUR RIGHTS

You have the following rights regarding the processing of your Personal Data:

  • The right to request access, correction, or deletion of your Personal Data of Anari AI.
  • The right to request Anari AI to limit processing.
  • The right of protest.
  • The right to data portability.
  • The right to withdraw consent at any time, except that revocation of consent does not affect the admissibility of processing based on consent before revocation.
  • The right to submit complaints to the Serbian Data Protection Authority i.e., the Commissioner for Data Protection (contact details below).
  • The right to information on whether the processing of your Personal
  • Data, access to your personal data, information on the purpose of treatment, the types of data to be processed, the recipient or kind of recipients to whom the personal data is disclosed or will be disclosed, and, in particular, to recipients in other countries or international organizations, the time limit of storage of personal data, or if that is not possible, the criteria for determining the time limit.

At your request, Anari AI will provide you with a copy of the data processed. Anari AI may request reimbursement of necessary costs for making copies of personal data which Data Subject required. If the request for a copy of personal data is submitted electronically, the answer will be delivered in a commonly used electronic format.

These Rights can be enforced by contacting Anari AI in the following ways:

  • Write to us at: Narodnog Fronta 21a/7/605, 21000 Novi Sad, Republic of Serbia
  • Email privacy@anari.ai

I. WITHDRAWAL OF CONSENT

You may at any time withdraw the consent you granted by submitting a request through privacy@anari.ai. In this case, Anari AI will no longer process any Personal Data subject to consent unless legally required. It will be as if you never consented or gave Anari AI Personal Data.

In the event that Anari AI is obliged to retain your Personal Data for legal reasons, your Personal Data will not be further processed and will only be retained for the period required by law. However, withdrawal does not affect prior processing of Personal Data by Anari AI until the time of withdrawal. In addition, if the use of Anari AI service/offer requires your prior consent, Anari AI will no longer be able, after withdrawal of your consent, to provide you with the relevant service, offer or event.

J. DATA PROTECTION AUTHORITY

The competent authority for the protection of personal data is the Commissioner for Information of Public Importance and Personal Data Protection of the Republic of Serbia. The Commissioner can be reached at the address Bulevar kralja Aleksandra 15, 11000 Belgrade, Republic of Serbia, e-mail: office@poverenik.rs or by phone at +381 11 3408 900.

Data Protection Officer

Stefan Sredojević
stefan@anari.ai