Last updated: [DATE]

This Privacy Policy and Cookie Notice explains how BGR collects, uses, shares, and protects personal data, and what rights you have over that data. It applies to visitors to bgreklam.com, clients, partners, suppliers, candidates, and anyone else whose personal data we process in connection with our business.

We have written this notice to be readable. If something is unclear, contact us at privacy@bgreklam.com.

QUICK OVERVIEW

Who are we?
BGR is the BG Reklam group of companies – a manufacturer of premium point-of-sale (POS) solutions, with entities in Serbia, Germany, the United Kingdom, and the United States. Full details are in the Data Controllers section below.

What do we do with your data?
We use it to respond to inquiries, run client and supplier projects, recruit, operate our website, run business-to-business marketing on professional channels (primarily LinkedIn and Google), and meet our legal obligations.

On what legal basis?
Mostly performance of a contract, our legitimate business interests, your consent (for marketing and non-essential cookies), and compliance with law.

Your rights.
You can access, correct, delete, port, or restrict the use of your personal data, object to certain processing, and withdraw consent. The Your Rights section below explains how to exercise each.

1. WHO IS THE DATA CONTROLLER?

Depending on which BGR entity you interact with, your controller is one or more of:

Where you have a project, contract, or active relationship with a specific BGR entity, that entity is your primary controller. Other BGR entities act as joint controllers or processors when work is shared across the group.

Privacy contact: privacy@bgreklam.com
Data Protection Officer / Privacy Lead: [name and email]
to be appointed where required by GDPR Article 37 or analogous law)
EU representative (if applicable): [details]
UK representative (if applicable): [details]

2. WHAT PERSONAL DATA WE COLLECT

We collect only the personal data we need. Categories include:

• Business contact data – name, job title, employer, business email, business phone, country, language, and the content of your message when you contact us, submit an RFP, or engage on professional networks.
• Project and commercial data – information exchanged in the course of a client, supplier, or partner project: brief contents, approvals, correspondence, signed agreements, NDAs, invoices, payment records, and delivery details. This data may include personal data of named individuals (project sponsors, signatories, on-site contacts).
• Recruitment data – CV, cover letter, references, work history, qualifications, and any other information you submit through our careers process or via professional networks.
• Website and device data – IP address (truncated where possible), browser type and version, device type, operating system, referring URL, pages viewed, time on page, click events, and approximate location derived from IP.
• Cookie and tracking data – set out in detail in the Cookie Notice below. This includes data collected through Google Analytics, Google Ads, Google Remarketing, Meta Pixel, LinkedIn Insights, and similar.
• Communications and event data – records of your interactions with us by email, phone, video conference, or at trade shows and meetings.

We do not intentionally process special categories of data (health, racial or ethnic origin, religious belief, sexual orientation, biometric data, etc.) and we do not use our website for direct payment processing. If special-category data is shared with us in error, we will delete or return it.

3. WHY WE PROCESS YOUR DATA

 4. LEGAL BASIS

Where we rely on legitimate interest, we have assessed that our interest is not overridden by your rights and interests. You can ask us for a summary of any such assessment.

5. WHO WE SHARE DATA WITH

We share personal data only with parties who need it to support BGR’s operations, and only under appropriate contracts. Categories of recipients:

• Other BGR group entities – to coordinate sales, projects, finance, HR, and IT across Serbia, Germany, the UK, and the US.
• IT and cloud providers – for hosting, email, document storage, CRM, ERP, helpdesk, and similar services.
• Logistics, freight, and installation partners – to ship and install POS units to client locations.
• Professional advisors – lawyers, accountants, auditors, insurers, where engaged.
• Banks and payment processors – for invoicing and bank transfers.
• Marketing and advertising platforms – Google (Analytics, Ads, Tag Manager), Meta (Pixel), LinkedIn (Insights, Ads). These platforms process data as independent or joint controllers; their privacy notices apply alongside ours. Details in the Cookie Notice.
• Authorities – courts, regulators, tax and customs authorities, and law enforcement, where legally required or where we reasonably need to protect rights.
• Acquirers – in the event of a sale, merger, or restructuring of BGR or any group entity, with appropriate safeguards.

We do not sell personal data.

6. INTERNATIONAL TRANSFERS

Personal data is transferred between BGR entities in Serbia, Germany, the UK, and the US, and to service providers and advertising platforms whose infrastructure is located outside the EEA, the UK, and Serbia – primarily in the United States.

Where data is transferred outside the EEA, the UK, or Serbia to a country without an adequacy decision, we rely on appropriate safeguards, in particular:

• The European Commission’s Standard Contractual Clauses (SCCs) and the UK International Data Transfer Addendum.
• The EU-US Data Privacy Framework and its UK Extension, where the recipient is certified.
• Supplementary measures (such as encryption, pseudonymisation, and contractual restrictions) where the transfer-impact assessment indicates they are needed.

You can request a copy of the safeguards that apply to a specific transfer by contacting privacy@bgreklam.com.

7. HOW LONG WE KEEP YOUR DATA

Where law requires longer retention, we keep the data only for the legally required period and only for the legally required purpose.

8. YOUR RIGHTS

Under GDPR, UK GDPR, the Serbian Law on Personal Data Protection, and (where applicable) US state privacy laws, you have the right to:

• Access – obtain confirmation of whether we process your data, and a copy of it.
• Rectification – correct inaccurate data and complete incomplete data.
• Erasure (“right to be forgotten”) – have your data deleted in defined circumstances.
• Restriction – limit how we process your data in defined circumstances.
• Objection – object to processing based on legitimate interest, including direct marketing.
• Portability – receive a machine-readable copy of data you provided to us under contract or consent, and have it transmitted to another controller.
• Withdraw consent – at any time, where processing is based on consent. Withdrawal does not affect the lawfulness of processing before withdrawal.
• Not be subject to solely automated decisions that produce legal or similarly significant effects. BGR does not currently make such decisions about you.
• Lodge a complaint with your supervisory authority (see below).

To exercise any of these rights, email privacy@bgreklam.com. We respond within one month of a verifiable request, extendable by two further months for complex cases. We may ask you to verify your identity before acting.

9. SUPERVISORY AUTHORITIES

You have the right to lodge a complaint with the supervisory authority in your country of residence, place of work, or place of the alleged infringement. The relevant authorities for the BGR group are:

• Serbia – Commissioner for Information of Public Importance and Personal Data Protection (Poverenik), Bulevar kralja Aleksandra 15, Belgrade.
• Germany – Hamburg Commissioner for Data Protection and Freedom of Information (HmbBfDI), or your local Land authority.
• United Kingdom – Information Commissioner’s Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
• United States – your state attorney general or, where applicable, the relevant state privacy regulator (e.g., the California Privacy Protection Agency).

We would prefer the chance to address your concern first. Please contact us at privacy@bgreklam.com before escalating.

10. SECURITY

We apply technical and organisational measures appropriate to the risk, including access controls, encryption in transit, network segmentation, supplier due diligence, and staff training. No system is perfectly secure; if we become aware of a personal data breach affecting your data and likely to result in a risk to your rights, we will notify the relevant supervisory authority and, where required, you, in line with applicable law.

11. CHILDREN

Our website and services are directed at businesses and professionals. We do not knowingly collect personal data from children. If you believe we have, contact us and we will delete it.

12. CHANGES TO THIS POLICY

We may update this Privacy Policy and Cookie Notice. The “Last updated” date at the top reflects the most recent version. Where changes are material, we will notify you by email or through a banner on the website before they take effect.

COOKIE NOTICE

What cookies are

Cookies are small text files placed on your device when you visit a website. They allow the site to recognise you, remember preferences, and collect information about how you interact with it. Some cookies are essential to operate the site; others are optional.

We use the term “cookies” to refer to cookies, pixel tags, local storage, and similar technologies.

How we manage your consent

When you first visit bgreklam.com, our cookie banner asks you to accept, reject, or customize non-essential cookies. Strictly necessary cookies always run; everything else (analytics, advertising, retargeting) only runs after you give consent.

You can change or withdraw your consent at any time by clicking “Cookie Settings” in the website footer. Withdrawing consent does not affect the lawfulness of processing carried out under the previous consent.

We record your consent choice and ID so we can demonstrate consent if required by law.

Categories of cookies we use

Strictly necessary

Required for the site to function – load balancing, security, session integrity, and remembering your cookie consent choice. These do not require consent.

Preferences

Remember settings such as language and region. Set only if you change a default.

Analytics

Help us understand how the website is used, in aggregate. We use these to improve content and navigation. Set only with your consent.

Marketing and advertising

Used to measure ad performance, build audiences, and show relevant BGR content to professional audiences on Google and LinkedIn. Set only with your consent.

These tools transfer data to providers in the United States. We rely on the EU-US Data Privacy Framework (and its UK Extension) and Standard Contractual Clauses where required, as described in section 6 of this Notice. The providers act as independent or joint controllers for their own purposes – see their privacy notices:

• Google: https://policies.google.com/privacy 
• Meta: https://www.facebook.com/privacy/policy 
• LinkedIn: https://www.linkedin.com/legal/privacy-policy 

Live cookie inventory

A complete, automatically scanned list of cookies set on this website – with names, providers, durations, and purposes – is generated and maintained by our cookie consent platform. Open Cookie Settings in the footer to view it.

How to control cookies in your browser

Independent of our consent banner, you can manage cookies through your browser settings – block all cookies, block third-party cookies only, or delete existing cookies. Each browser handles this differently:

• Chrome: Settings → Privacy and security → Cookies and other site data
• Safari: Settings → Privacy → Manage Website Data
• Firefox: Settings → Privacy & Security → Cookies and Site Data
• Edge: Settings → Cookies and site permissions

Blocking strictly necessary cookies will break parts of the site.

Do Not Track

We do not currently respond to “Do Not Track” browser signals because no consistent industry standard has emerged. We do honour the Global Privacy Control (GPC) signal where applicable law requires it.

CONTACT

Questions, requests, or concerns about this Privacy Policy and Cookie Notice: privacy@bgreklam.com
BG Reklam d.o.o.
Beograd, 29. Novembra 1M
11469 Belgrade, Serbia +381 11 785 64 64