PRIVACY POLICY

Obuka.mk guarantees the protection of personal data to all users of the application obuka.mk in accordance with the provisions of the Law on Personal Data Protection.

We ask the users to carefully read this Privacy Policy, in order to be acquainted with how the data and information that Obuka.mk collects from them are used.

By accessing or using this application, the user confirms that he has read, understood and agrees to all the terms of the Privacy Policy and the ways of using the application. If the user does not agree to these terms, please do not access or use this application.

COLLECTING PERSONAL DATA FROM THE USER

When the user accesses and logs in to this application, he / she will be asked for certain personal data. If the user does not provide any data that is required for a particular activity, he will not be able to use this application. When you create a user profile on our platform, you must provide data that is accurate and complete at all times. Failure to comply with this provision constitutes a breach of the Terms of Use, which may result in the immediate deletion of your User Account. You are responsible for the safe storage of your password which you use to access your account on our online platform, as well as for any activities or actions taken from your account under your password.

You agree not to disclose your password to third parties. You must notify us immediately when you become aware of a security breach or unauthorized use of your user profile.

Upon acceptance of the application, it is considered that the user freely and explicitly agrees with the processing of his personal data. When the user visits the application, Obuka.mk and / or its authorized service providers can automatically collect his personal data, using the available electronic tools.

PROCESSING OF PERSONAL DATA

Obuka.mk will process and store your personal data collected through the application in accordance with the Law on Personal Data Protection and other applicable regulations in the MKD. Your personal information will not be disclosed to unauthorized third parties. They will be kept for as long as necessary to fulfill the purpose for which they were collected.

The data and information identifying the user can only be disclosed to the competent state authorities, based on their request or decision based on law.

PUBLICATION OF OTHER DATA AND INFORMATION

Obuka.mk may disclose or share other data and information of the user with his associates and affiliated companies. For example, it may share the collected demographic information (which does not include user-identifiable information) with third parties, including advertising agencies, in order to use content tags to provide content and services that the user may be interested in.
That is, to continuously improve the quality of our websites.
We clarify that this is not personal data of the user, but only information about summarized activities of our users.

PROTECTION OF PERSONAL DATA

Obuka.mk takes precautionary measures to protect the personal data of users in accordance with the positive legal regulations. In order to ensure confidentiality and protection of personal data of entities, we apply appropriate technical and organizational measures to protect against accidental or illegal destruction of personal data, or their accidental loss, tampering, unauthorized disclosure or access and protection against any illegal forms of processing. in accordance with the Law on Personal Data Protection.

The entire documentation for the software programs for personal data processing and all its changes are recorded and kept in accordance with the Rulebook on technical and organizational measures for ensuring confidentiality and protection of personal data processing of the Directorate for Personal Data Protection. To ensure the security of the user’s personal data, they are stored on a server that can only be accessed by authorized persons, encrypting certain sensitive data and information.

However, it must be noted that no data transmission over the Internet or any wireless network can be completely secure. As a consequence, despite the fact that reasonable measures are taken to protect personal data, absolute protection of any information transmitted to or from our application cannot be guaranteed.

Deleting data

If the user contacts the team of obuka.mk to completely deactivate his profile, for the next use of the application it will be necessary to create a new profile.

CHANGING OF THE PRIVACY POLICY

This Privacy Policy may be amended at any time by posting the amended Privacy Policy text of this application. Changes to the Privacy Policy take effect immediately after their publication. It is the responsibility of each user to periodically review the Privacy Policy and read any changes. The continued use of our application by the user, after the entry into force of such changes, implies that the user accepts the terms of the amended Privacy Policy.

CONTACT

If you have any questions regarding personal data protection, please send us an email at the address for personal data protection contact@obuka.mk.

Guide for personal data protection in Obuka.mk

1. Purpose of the Guide

The right to privacy and protection of personal data of users is a priority for Obuka.mk.

Obuka.mk pays great attention to personal data protection in all its business processes, implementing the standards set by the regulations for privacy and personal data protection in the Republic of North Macedonia.

In this sense, an important factor in the functioning of Obuka.mk is the right to privacy and protection of personal data of users of products and services, as personal data subjects. This Guide is a practical tool that clarifies the meaning of the terms used in personal data protection regulations. The Guide also develops the principles for protection of personal data that must be taken into account in each processing of personal data of users, provides users with a more comprehensive information about their rights and defines the key responsibilities of Obuka.mk as a controller of personal collections data, arising from the Law on Personal Data Protection and other regulations in this area.

2. Meaning and definitions of terms used in the Guide

2.1. Terms arising from personal data protection regulations

PERSONAL DATA is information that refers to an identified natural person or an identifiable natural person. An identifiable person is a person whose identity can be established directly or indirectly, based on the citizen ID or on the basis of one or more features specific to his physical, physiological, mental, economic, cultural or social identity.

Personal data are: name and surname, address, date of birth, unique identification number of the citizen, ID card number, photo of identification documents, telephone number, e-mail address, etc.

PERSONAL DATA PROCESSING means an operation or set of operations performed on personal data automatically or otherwise, such as: collecting, recording, organizing, storing, adjusting or modifying, withdrawing, consulting, using, disclosing, publish or otherwise make available, equalize, combine, block, delete or destroy. Obuka.mk performs automatic, but also manual processing of personal data.

SUBJECT OF PERSONAL DATA is a natural person whose personal data are processed in Obuka.mk. The users2 of products and services of Obuka.mk are subjects of personal data.

A PERSONAL DATA CONTROLLER is a natural or legal person, a body of the state government or another body, which independently or together with others determines the goals and the manner of processing the personal data. Obuka.mk is a controller of personal data.

A PERSONAL DATA PROCESSER is a natural or legal person or an authorized body of the state government that processes personal data in the name and for the account of the controller.

PERSONAL DATA PROTECTION OFFICER is a person authorized by the controller to monitor the implementation of personal data protection regulations and to ensure compliance with the principles of personal data protection.

SPECIAL CATEGORIES OF PERSONAL DATA (sensitive data) are personal data that reveal racial or ethnic origin, political, religious, philosophical or other beliefs, trade union membership and data relating to human health, including genetic data. data or data relating to sexual life. Obuka.mk does not process special categories of personal data for users.

2.2. Terms used in the field of electronic communications

CONFIDENTIALITY AND CONFIDENTIALITY OF ELECTRONIC COMMUNICATIONS – The Constitution of the SRM guarantees the freedom and inviolability of all forms of communication. Confidentiality of communications refers to: the content of electronic communications, communications traffic data and location data that are not communications traffic data, and the facts and circumstances of disconnection or unsuccessful attempts to establish a connection. Only on the basis of a court decision, under conditions and in a procedure determined by law, may the secrecy of electronic communications be waived.

USER DATA is the data of the persons who use the electronic communication services, which are collected in order to establish a contractual relationship with Obuka.mk, including the preparation of its content or the change of such contractual relationship.

COMMUNICATION TRAFFIC DATA are data related to the realization of electronic communication services, which in particular include: personal identification data of the user, calling and called numbers, identification numbers for the used service (telephone and fax) and beginning and end. When it comes to data on communication traffic, regardless of whether it refers to individuals or legal entities, this data is in any case subject to the secrecy of electronic communications.

Obuka.mk can store and process the traffic data needed to collect bills, until they are paid. After paying the invoice, this data is deleted. According to the Law on Electronic Communications, Obuka.mk is obliged to store the raw traffic data for the last 12 months.

LOCATION DATA are data that indicate the geographical position of the terminal equipment of the user of the electronic communication service. Location data relating to the user may be processed only in anonymous form or, with the prior consent of the user to the extent or for the duration required to provide value-added service.

The user who has agreed to the processing of location data, has the opportunity in a simple way and free of charge, to cancel further processing of this data. The processing of location data without personal data may be transferred to third parties providing value-added services.

Obuka.mk is obliged to submit the location data related to the emergency numbers to the emergency call service in an appropriate manner.

3. 3. Principles for personal data protection

The culture of respect for privacy and customer care are benefits that make Obuka.mk recognizable in the electronic communications market. Therefore, when processing personal data, Obuka.mk is guided by the following principles for personal data protection:

• To be processed fairly and in accordance with the law

Usually, fair processing of personal data implies respect for the “principle of necessity” – processing of data to the extent necessary to achieve a specific goal. The processing of personal data in accordance with the law implies the existence of a legal basis and compliance with any legal restrictions arising from other laws. The data processed in Obuka.mk on the basis of law can be used for:

• conclusion, supervision and termination of the subscriber agreement
• payment for services
• preparation and issuance of telephone directories  
• To be collected for specific, clear and legally determined goals and to be processed in a way that is in accordance with those goals.

Obuka.mk is guided by the goals and the legal basis for data processing. The use of products and services is not conditioned by the consent of the user for the use of his data for purposes other than the fulfillment of the rights and obligations arising from the subscriber agreement.

• To be relevant, appropriate and not to a greater extent in relation to the goal to be achieved by their processing (data economy)

The “principle of necessity” limits the amount of data that can be processed to only those that are necessary to meet the purposes for which it is processed. For example, the data on the marital status of the user would be irrelevant, inappropriate and excessive in relation to the goal to be achieved by establishing a subscriber relationship. Also, regardless of the type of business relationship established, the processing of the user’s nationality data would be irrelevant, inappropriate and excessive.

• To be accurate, complete and where necessary updated, whereby all appropriate measures will be taken to delete or correct the data, taking into account the purposes for which they were collected or processed (data quality)

This principle refers to the quality of the data, according to which Obuka.mk as a controller of personal data takes care of their accuracy. Updating data means replacing data that was once accurate with new data or supplementing it. At the same time, the user has the right to request that actions be taken to delete or correct his data.

• To be stored in a form that enables user identification, no longer than the time required to meet the purpose for which the data was collected

This principle limits the period in which personal data can be legally processed, and after the termination of the purpose for which they are collected, they should be deleted or destroyed, ie anonymized. Upon termination of the subscriber relationship, these data must be stored for a period of one year from the date of issuance of the last bill of the subscriber for the provided services, and if in that period an order is issued by a competent authority for storage and submission of such data. , within the period specified in the order of the competent authority.

It is considered that it is acted in accordance with the principle of data deletion and in case of deletion of the identification characteristics of the users (anonymization) or replacement of the identification characteristics with other characteristics (pseudonymization). Anonymization and pseudonymization are performed in such a way that the identity of the user can not be revealed or can only be revealed with unreasonably large efforts.

4. Consumer rights
   

Users-subjects of personal data have the right:  

• to be informed about the processing of their personal data  
• to access their personal data and  
• to supplement, modify, delete or request a ban on the use of their personal data

The following is a more detailed explanation regarding these rights:  

• In the function of transparency, Obuka.mk has an obligation to inform the user about the purposes and the legal basis of the processing of his personal data.  
• Every user has the right to access their personal data. The request for access to the data must be submitted in writing. Obuka.mk is obliged to respond to the user within 15 days from the day of receipt of the request, and has no obligation to respond again to the same or similar request, if in the meantime there are no changes in his personal data, unless six months have passed. from the day of submission of the previous request to the new request. If the user does not receive a response to the request for access to personal data, he can submit a request for determining a violation of the right to personal data protection before the Directorate for Personal Data Protection.  
• The user has the right to request addition, modification, deletion or termination of the use of his personal data. At the request of the user, Obuka.mk is obliged to supplement, amend, delete or stop the use of personal data, if the data is incomplete, inaccurate or out of date and if their processing is not in accordance with law. Regardless of whether the user has submitted a request for addition, modification or deletion of personal data, if Obuka.mk determines that the personal data are incomplete, incorrect or out of date, he is obliged to supplement, amend or delete them. Obuka.mk is obliged to inform the personal data subject in writing about the made additions, changes or deletions no later than 30 days from the day of receiving the request.  

5. Obligations of Obuka.mk

5.1. Obligation of employees / employees to protect personal data and maintain the confidentiality of electronic communications

The employees / hired persons in Obuka.mk when undertaking their work tasks and responsibilities:  

• They get acquainted with the regulations for personal data protection, as well as with the adopted documentation for technical and organizational measures for ensuring confidentiality and protection during the processing of personal data.  
• Signature Statement on confidentiality and protection in the processing of personal and data on communication traffic, as well as on the confidentiality of business information; With this Statement they undertake to respect the principles of personal data protection, to perform their processing in accordance with the instructions received from Obuka.mk, unless otherwise regulated by law and to keep the personal data as confidential, as well as the measures for their protection. This statement is valid even after the termination of their employment / engagement in Obuka.mk.
• Attend mandatory training for personal data protection.

Obuka.mk continuously informs the employees / engaged persons about the immediate obligations and responsibilities for personal data protection.

5.2. Informing the user about his rights 

Obuka.mk has an obligation to inform the user about:  

• the identity of the controller;  
• processing purposes;  
• the right to access, modify or delete personal data

5.3. Consent of the user for any additional processing of personal data

For each additional data processing, outside the goals of fulfilling the established subscriber relationship, Obuka.mk provides a special consent. Consent is a freely and explicitly stated statement of the user’s will by which he agrees to have his personal data processed for a specific purpose.

Only with the prior consent of the user, the personal data of the user, the traffic data and the location data can be processed for the purposes of direct marketing and profiling (opt-in principle).

5.3.1. What is direct marketing

Any kind of communication made in any way for the purpose of sending advertising, marketing or propaganda material that is aimed directly at an identified user.

5.3.2. What is profiling

Processing of the personal data of the user and the data for realized traffic, in order to be contacted for offers of products and services, appropriate to his habits and needs.

The user has the right to withdraw the consent at any time, free of charge and using simple means. According to the Law on Electronic Communications, the electronic e-mail addresses of the users of products or services can be used for direct marketing of similar products or services on Obuka.mk, with the obligation to provide users at any time, free of charge and with using simple means, to prevent the use of those addresses (opt-out principle).

5.4. External people 

Legal entities and individuals who enter into a business relationship with Obuka.mk, on the basis of which they have access to documentation and personal data of the users of Obuka.mk, are obliged to confidentiality and protection of personal data with special confidentiality agreements and for processing data.

6. Who should the user contact in order to exercise their rights?

User can contact the Personal Data Protection Officer in Obuka.mk. The personal data protection officer acts in accordance with the internal regulations in order for the rights of the user to be realized in a simple, fast and efficient way without causing unnecessary delays or costs. The user receives a response to the request within 15 days.

6.1. What is the next instance that the user can turn to?

If the user is not satisfied with the answer and the information given by the Personal Data Protection Officer of Obuka.mk and if user thinks that his rights have been violated, user can submit a request for determining the violation of the right to personal data protection to the Directorate for Personal Data Protection. Due to the specificity of this procedure, the Directorate may decide not to disclose the personal data of the user as a submitter of the request of Obuka.mk as an opposite party.

For violation of the right to personal data protection, the inspector for personal data protection from the Directorate, conducts a procedure and decides with a decision, which is final, given that no appeal can be filed against it.

Within 15 days from the day of receiving the decision, a lawsuit for initiating an administrative dispute may be submitted to the Administrative Court.