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Privacy Policy

AirData DOO – Privacy Statement

Last updated: November 31, 2025 [sic]

We care about your privacy and are committed to protecting your personal data. In this privacy statement, you will find information about how we use your personal data, your privacy rights, and how the law protects you. Please read this privacy statement carefully before using our Services.

Contents

Who are we?
What data do we collect about you?
Do we collect data about children?
Why do we process your personal data?
Data processing integrated into areasell.com services
Data processing within the areasell.com portal services
How will we inform you of changes to our privacy statement?
Your rights
Communication
Who do we share your data with?
International transfers
Where do we store your data and for how long?
Technical and organizational measures and processing security
Links to third-party sites
Contacts
Data Protection Authority

This privacy statement applies to your use of any products, services, content, features, technologies, or capabilities, as well as all related websites, mobile applications, or other online features or applications that we offer to you (collectively referred to as the «Services»).

Who are we?

The main controller of your data for international services is «Air Data» BUDVA, a limited liability company registered at: Žrtava fašizma bb — «AKADEMIJA ZNANJA» building, Budva, which provides you with our Services in accordance with our Terms of Use (hereinafter collectively referred to as «areasell.com», «we», or «our» in this privacy statement). This entity of areasell.com is considered the data controller for the local services provided. Relevant contact details are provided in section 5.

The local entity responsible for processing your personal data is: Limited Liability Company «Air Data» BUDVA. The Company’s registered office and address for receiving official correspondence are located in Budva, at: Žrtava fašizma bb — «AKADEMIJA ZNANJA» building, Budva.

What data do we collect about you?

2.1.1 Data provided through direct interaction

Registration and other account information

When you register to use our Services, we may collect the following information about you:

If you register directly on our platform, you will be asked to provide an email address;
If you register using your Google account: your first name, last name, email address, and the URL of your Google profile picture.
If you register via a Facebook account: first name and last name (depending on your Facebook account), email address, Facebook ID, and Facebook URL for your profile picture. If you have given permission to Facebook in the app’s privacy settings (which are displayed immediately before registering for our Services), we may collect data about your gender, age, or email address depending on the permission you provided.
If you register using your Apple ID: first name, last name, and email address; you may provide us with your email address when signing into your Apple account.

Depending on the choices you make when logging into our Services or during the process of entering into a contract for our Services, you may also provide the following personal data:

Your name;
Email;
Mobile phone number;
Tax identification number;
Private postal address;
Your payment details if you wish to use our paid services defined in our Terms of Use, which, depending on the payment method used, include:n
- Your credit card details (cardholder name, expiration date, credit card type, and the last four digits of your credit card);
- Mobile phone number;
- Your email address.
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Verifying your areasell.com account

We verify areasell.com user accounts via SMS confirmation to ensure that each account is associated with a real, unique user. This verification process begins immediately after you publish your first listing on our Services. To verify your areasell.com account before publishing a listing, we will send you an SMS message to the valid mobile phone number you provided. This procedure is completely free of charge.

If you do not agree to verify your account, it will remain active, and you will be able to use our Services with limited functionality. Limited account functionality means that you will not be able to publish new listings, nor edit, promote, renew, reactivate, deactivate, or delete existing listings until your account is verified via SMS. You will also not be able to receive messages from other users or reply to them.

If you create multiple areasell.com accounts using the same mobile phone number and verify all of them via SMS confirmation, their functionality will be limited, and we will ask you to choose one of them. The account you choose will be restored to full functionality, while the remaining accounts will retain limited functionality.

Any user may request a maximum of 5 SMS messages with verification codes within 24 hours. Account verification is performed only once for each account until the user successfully verifies it.

Once your areasell.com account is verified, it will remain linked to the mobile phone number used for SMS confirmation. If you wish to change the mobile phone number linked to your areasell.com account, please contact our customer support team by sending a message via the contact form.

Communication via chat on our Services

When you use our chat feature to communicate with other users, we collect and process the content and information that you choose to provide to other users using this feature.

Recording telephone conversations with our customers and sales departments

When you contact us by phone or choose to be contacted by phone by one of our customer support representatives, we may occasionally record the conversation, subject to your express consent, for the purpose of improving customer interaction.

Audio and video recording for special customer interaction studies

If you give express consent to participate in interaction studies periodically organized by areasell.com, we will record your interaction with our team. For each study organized by areasell.com, we will provide you with specific information on how we process your personal data and for what purposes.

Participate in our user surveys

From time to time, we will provide you with user surveys to assess overall satisfaction with the quality of our Services. To do this, we will use only a session ID (a random identifier assigned to you when downloading our mobile app or visiting our websites).

Additionally, you may provide us with your contact information, such as your email address and mobile phone number, upon request so that we can contact you and invite you to take part in one of our experiential (UX) tests or an interview with our team. Please note that the information you provide in connection with our survey questions may sometimes contain personal data that you have voluntarily provided in your responses.

Qualifications and feedback

We collect information about your ratings and reviews that you leave for other users after interacting with them, as well as ratings and reviews that you receive from other users, in accordance with our Terms of Use. We do this to assess user satisfaction with the transactional experience and to ensure optimal and effective interaction between them, as well as to identify and prevent inappropriate actions and behavior in the context of using our Services. This information allows us to take necessary and appropriate measures to maintain high standards in the provision of our Services.

2.1.2 Data we collect automatically when you use our Services

When you use our Services, we automatically collect the following information about you:

Device Information

We collect device-specific information such as operating system version and device identifiers. For example, the name of the mobile network you are using, your IP address, device language settings, device brand and type, operating system version, browser type and version, and device software information such as fonts, system and browser time zone, and available video and audio formats. If you are logged in, we associate device identifiers with your areasell.com account.

Location Information

Depending on your device permissions, if you post an item on our Services, we automatically collect and process information about your current location. We use various technologies to determine your location, including IP address, GPS, Wi-Fi access points, and cell towers. Your location data allows you to see items from users near you and helps you post items near you. If we require your location data, we will first show you a pop-up window allowing you to allow or deny us access to your location. If you do not allow us access to your location, you will still be able to use our Services, albeit with limited functionality. If you allow us access to your location, you can always change this choice later in our website or mobile app settings and disable permissions related to location sharing. For more information on the purpose of using your location data and how we process it, see section 4.2 (ii) of this Privacy Statement.

Registration and Client Data

Technical data, including your device’s IP address, time zone, and operating system. We will also store information about your login (date of registration, date of last password change, date of last successful login), browser type and version.

Clickstream Data

We collect information about your activity on our Services, including the websites from which you accessed our Services, the date and time of each visit, searches you performed, lists of advertisements or banners you clicked on, your interaction with them or with lists of advertisements, the duration of your visit, and the order in which you visited content on our Services.

Cookies and Similar Technologies

We use cookies to manage our users’ sessions, save their preferences, preferred language, and show you relevant advertising. Cookies are small text files that a web server transfers to your device’s hard drive. They can be used to collect the date and time of your visit, browsing history, your preferences, and username. You can configure your browser to reject all or some cookies, or to alert you when websites set or use cookies. If you disable or refuse cookies, please note that some sections of our Services may become inaccessible or function incorrectly. For more information about the cookies we use, please see our Policy on Cookies and Similar Technologies. In Section 9, you will find more details on how we share this information with analytics providers and advertising partners.

2.1.3 Data about third parties or available advertising sources

We obtain your personal data from various public and third-party sources, which we may combine or link with the personal data we collect about you through our Services. This includes, in particular, the following information:

If you register using your Google account, we receive the email address associated with that account (to create your areasell.com account and send you system notifications and commercial communications), your Google ID, and your full name (used as your username when using our Services), as well as the URL of your profile photo (to create a profile photo for your areasell.com account).
If you register using your Facebook account, we receive the email address associated with that account (to create your areasell.com account and send you system notifications and commercial communications), as well as your public profile information, including your Facebook ID, your first and last name (used as your username when using our Services) and the URL of your Facebook profile photo (to create a profile photo for your areasell.com account).1

Certain technical and usage information from analytics providers, such as Google Analytics 360, for statistical purposes and analysis of the use of our Services, their improve2ment, and for internet marketing (more details on this in Section 9).

If you choose to store your payment card data with us, we receive from our payment partners, such as eupago and HiPay, the following data regarding your card: first and last name, expiration date, last 4 digits of the card number.
Government authorities provide us with your username, phone number, and email address when they ask areasell.com to conduct checks or provide them with additional information in the context of preventing fraudulent activities.
Ratings and Reviews: If you act as a seller/professional user of our Services, we collect and provide information about ratings and reviews received by you from other users after your interaction with them, in accordance with our Terms of Use. This is part of our Services aimed at assessing user satisfaction with the transactional experience and ensuring an optimal and effective level of interaction between users, as well as identifying and preventing inappropriate actions and behavior in the context of activities carried out on our Services. This information allows us to take necessary and appropriate measures to maintain high standards in the provision of our Services.
Do we collect data about children?

Our services are not intended for children under 16 years of age, and we do not knowingly collect data from persons under 18 years of age. If we become aware that a person under 16 has provided us with personal data, we will delete it immediately.

Why do we process your personal data?

We use your personal data only in cases provided for by law. Most often, we use your personal data in the following cases:

When we need to perform a contract that we are about to enter into or have entered into with you;
When it is necessary for our legitimate interests and we believe that our legitimate interests do not outweigh your or other interests regarding data or fundamental rights and freedoms, for example, to improve our Services and increase their security;
When we need to comply with legal or regulatory obligations.

Under certain circumstances, we may also process your personal data with your consent. In this case, we will inform you of the purpose and category of personal data we will process when we request your consent.

Below we describe the reasons why we use your personal data and the legal bases that allow us to do so. Where applicable, we also indicate our legitimate interests.

4.1. To provide access and provide Services

If you log in using your mobile phone number or email address, we use your first and last name, mobile phone number, and/or email address to identify you as a user and provide you with access to our Services.
If you log in using a Facebook, Google, or Apple ID account, we use your first name, last name, and email address from these accounts, as well as the URL of your profile picture (except for Apple ID), to identify you as a user of our Services and provide you with access to them. The above login data is also used to provide you with Services in accordance with our Terms of Use.

We use third-party payment services to process all your payments for our Services. Depending on the payment method you use, you may be asked to provide us with your payment details and credit card details, which we then provide to the payment service provider to process your payment. We do not store your credit card details unless you choose to do so yourself to ensure recurring payments without the need to re-enter this information. In these cases, we store only the cardholder’s name, expiration date, credit card type, and its last four digits. We do not store any credit card verification values and simply provide these values and your credit card number in encrypted form so that our payment service provider can process your payment.

We store your data related to academic and professional experience, skills, photos, employment information, as well as any information contained in your resume or provided directly by your employers through the Services, to ensure direct communication with you and transfer this data to employers publishing job advertisements in the «Jobs» category. The legal basis for this processing is the conclusion and execution of a contract between areasell.com and you, under which areasell.com can provide you with services related to the «Jobs» category.

We process the above information for the proper performance of our contract with you.

4.2. To improve your experience using our Services

We use site traffic data to:n
- Provide you with personalized content, such as relevant search results, when you use our Services.
- Determine how much time you spend on our Services and how you use them to understand your interests and improve our Services based on this data. For example, we may suggest materials for you to visit based on the content you click on.
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If you choose to provide us with your location information, we use it for the following purposes:n
- To collect anonymous and aggregated information about the characteristics and behavior of areasell.com users, including for commercial analysis, segmentation, and the development of anonymous profiles;
- To improve the performance of our Services and personalize the content we offer you. For example, we use location data to display listings nearby to improve your shopping experience. For this purpose, the Google Maps service is integrated into our Services. Google Maps is provided by us, with Google acting as an independent controller. This means that both Google and we are responsible for processing your location data in the context of Google Maps. In any case, we will not process your location data for any purposes other than those set out in this privacy statement. However, Google may process this location data for its own purposes, as explained in the Google Privacy Policy, which can be found here. Your use of Google Maps through our Services is governed by what Google Maps calls its Terms of Service.
- Using your account contact information, including email address and mobile phone number, we verify the different devices (e.g., desktop computer, mobile phone, and tablet) you use to access our Services. This allows us to track your activity across our Services and provide you with a seamless experience regardless of the device used.
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We use the images you upload, as well as the descriptions and prices you specify in your listings, to train machine learning models to personalize search results based on listing ranking and user interests, which improves search functionality and increases the likelihood of a successful sale. This helps us improve our Services and provide you with a better user experience.
To show and recommend advertisements on our Services that may be of interest to you, we use algorithms that process information about your browsing behavior, purchased items, browsing history, your user ID, and your location if you have given us permission to use them. We use this form of automated decision-making based on our legitimate interests in improving our Services and user experience by providing you with more relevant advertisements.
We access your chat messages with other users of our Services and analyze them to highlight items and provide you with a better user experience (for example, to identify sold items and provide you only with active listings). Therefore, we develop and train machine learning models and algorithms to automatically analyze the content of your conversations. To create and refine our machine learning models, our machine learning experts may manually analyze samples of conversation content. In these circumstances, strictly limited access rights apply to the selected machine learning experts who analyze conversation content. During this analysis process, we anonymize conversation content as much as possible by applying an operational filter to detect and hide personal data such as names, phone numbers, and email addresses. However, there may be cases beyond our control where conversation content may reveal certain personal data that you have chosen to provide.

Using our extended session ID (a random identifier assigned to you when downloading our mobile application or visiting our website), we will periodically offer you user surveys to assess your satisfaction with the quality of our Services. During the survey, we may also request your email address or mobile phone number to contact you or invite you to participate in one of our user experience (UX) tests or interview with our team.
To assess user satisfaction with the transactional experience and ensure optimal and effective interaction between them, as well as to identify and prevent inappropriate actions and behavior in the context of using our Services, we collect information about comments and reviews exchanged by users within our Services. This information allows us to take necessary and appropriate measures to maintain high standards of providing our Services.

We process the above information for the proper performance of our contract with you and based on our legitimate interest in improving your experience using our Services.

4.3. To provide you with safe and secure Services

We use your mobile phone number, registration data, and unique device identifiers to administer and protect our Services (including troubleshooting, data analysis, testing, fraud prevention, system maintenance, support, and data hosting).
We access and analyze your chat messages with other users conducted in the chat of our Services for customer satisfaction and safety, as well as fraud prevention (for example, blocking spam or abusive messages that may have been sent to you by other users). Consequently, we develop and improve machine learning models and algorithms that help us automatically detect and prevent incorrect and fraudulent user behavior. During the analysis and training process, we anonymize chat content as much as possible, making any personal information associated with users undetectable. However, there may be cases beyond our control where chat content may reveal certain personal data that you have chosen to provide. Only in limited cases and circumstances do our security and customer protection experts manually analyze chat content; for example, if we have strong evidence leading us to suspect imminent fraudulent activity. In these circumstances, strictly limited access rights apply to the selected machine learning experts who analyze chat content.

To prevent and detect fraud on our Services, we use algorithms that recognize suspicious or fraudulent user behavior based on information such as user activity and posted content, which may lead to the blocking of certain accounts. Automatic blocking occurs when there is a high degree of certainty that an account or action is fraudulent. Otherwise, it is analyzed by selected customer security experts based on strictly limited access rights. We use this form of automated decision-making based on our legitimate interests in detecting and preventing fraud, as well as ensuring the security and safety of our Services for our users. If you believe your property has been mistakenly blocked, you can contact us via our Contact form, and our team will review the decision to block your account.

We collect certain information from the electronic device from which you access our Services, and related to it, based on our legitimate interest in preventing fraud on our Services. The information we collect includes your user ID (depending on whether you are logged in), the areasell.com country domain, IP address, device language settings, device brand and type, operating system and its version, browser type and version, and specific device software information, such as browser fonts, system and time zone, as well as available video and audio formats. Device-related information is used to determine if the same device is being used when users interact with our Services. We link this information to a user fraud score, based on which we can block certain users. For more information on this topic, please review our Policy on Cookies and Similar Technologies. If you believe your account has been mistakenly blocked, you can contact us via our Contact form, where our team will review the decision to block your account.

We process the above information for the proper performance of our contract with you and based on our legitimate interests in preventing fraud and improving the overall quality and efficiency of our Services.

4.4. To promote and provide you with Services that may be of interest to you.

We use your email address and mobile phone number (via SMS) to make offers and recommendations regarding our Services that may be of interest to you.
To send you emails with offers and recommendations for advertisements or our Services, we use algorithms that process information based on data about your visits. We always provide you with the opportunity to opt out of receiving these messages, including an unsubscribe link. We use this form of automated decision-making based on our legitimate interests: improving our Services, increasing the number of transactions on our Services, and improving user service quality by providing you with more relevant advertisements.

We use traffic data to monitor the effectiveness of campaign implementation and provide reports to our business partners, as well as for internal business analysis.

If you choose to provide us with your location data, we may use it to assess and monitor your interaction with third-party advertising banners that we place on our Services.

We process the above information based on our legitimate interests in developing commercial activities aimed at providing you with Services that may be of interest to you. In particular, you may receive certain commercial communications from us:

Via your preferred media, if you have requested this information from us;
By email, regarding similar products and services, if you are already using our Services or have purchased any of our products;
By phone or email, if you provided us with your contact details when participating in a competition;
By phone or email, if you registered for a promotion.

You can ask us to stop sending you such commercial communications at any time by clicking on the unsubscribe link contained in the email sent to you, or by changing the notification settings in your account.

In cases not listed above, we will use your email address and mobile phone number to send you direct marketing messages (by email, notifications, SMS, or phone calls) only if you have consented to this by checking the appropriate box when registering for our Services. You can always change your decision and revoke your consent in the notification settings of your areasell.com account.

If you have problems changing your notification settings, please contact us using our Contact form.

4.5. To provide you with quality customer support service

We record your telephone conversations with members of our customer support or sales team, subject to your express consent.
If you agree to participate in customer interaction studies organized by areasell.com from time to time, we will film your interaction with our team for the purpose of improving our Services.

We process the above personal data to further analyze your interaction with our customer service or sales department (as the case may be), as well as to improve user service by members of our team.

You may withdraw your consent at any time and free of charge by using our Contact form.

Data processing within the areasell.com Promotion Portal services

The areasell.com Promotion Portal is a tool designed for individuals and legal entities wishing to publish information about their activities on our Services.

To provide areasell.com API services within the areasell.com Promotion Portal, we process the personal data of our users who are software promoters or individual managers/employees of these promoters (collectively referred to as «Promoter» or «Promoters»). For this service, we process the name of the application, the first and last name of the promoter’s manager, and their phone number.

To use areasell.com API services, you must activate your areasell.com account data. Every time the Promoter adds a new request (hereinafter referred to as «Request»), you must fill out a special form and provide us with additional information related to the Request, as well as contact details in accordance with the Terms of Use of the areasell.com portal. Providing the data requested in the form to us is entirely voluntary, although it is necessary to use the areasell.com API service. When using areasell.com API services, we also process data on the Promoter’s activities on the areasell.com website.

We process the above information for the purposes of proper execution of the contract concluded between you and us, improving our Services, and based on our legitimate interest in preventing fraud and abuse.

areasell.com is not responsible for the legality of the processing of users’ personal data within the Application added by the Promoter. The obligation to provide truthful information about the rules of use of the Application, security policy, and other information required by applicable law, in particular, provisions on personal data protection, is the responsibility of each Promoter. areasell.com considers it mandatory for Promoters to update and maintain the Application, in particular, to ensure the security of user data processed through it.

To exercise these rights, in accordance with the provisions on personal data protection, any user of the Application must contact the Promoter directly or the person indicated in the relevant document describing the rules of use of the specific Application.

Data processing within the areasell.com portal services

6.1 Processing of personal data during recruitment

To simplify the process of responding to vacancies in the «Jobs» category, we have provided our users with the ability to add, store, and use their resumes on our site. Users can save their resumes while responding to a specific vacancy, as well as in their account settings in the «Candidate Profile — Resume» section (also available in the «Settings — Your Resume» tab). Only one resume can be attached to your account at a time. Changing or adding a resume during the application process using the form provided on the Platform will result in it being changed or added to your account. Depending on the functions provided by the Platform at the time of application, your resume may be automatically attached to the application you are submitting, which is always displayed on the application form on the Platform. The candidate retains control over sending their resume to the employer. This means that even if the resume is automatically attached to their application as described above, they can always refuse to attach their resume to a specific application using the function provided in the form. You can manage your resumes stored in your areasell.com account by adding or deleting individual files in the «Candidate Profile — Resume Section» tab and using the special button when applying via the form. Since your resume is saved in your account, you will not have to attach a separate file every time you apply for a vacancy.

The resume file remains visible in the User Account until it is deleted by the User, which the User can do at any time, but no later than the date of Account deletion.

The resume file and any other data provided to the selected Employer or stored via areasell.com Services will be processed in the Employer’s Account for 4 months.

From the moment the Candidate provides their personal data to the Employer selected by them, the Employer, in cases provided for by legislation on personal data protection, is responsible for processing the data independently, for recruitment purposes and possibly for other purposes determined by the Employer in accordance with the provisions of the Law, and the Employer may store the Candidate’s data outside the Account and set a specific retention period for them outside the Site.

Thus, the areasell.com Group of Companies, as a personal data controller, is responsible only for processing the Candidate’s data within the Site, i.e., for its own activities described in the Regulations.

In the «Candidate Profile» tab on the Site, you can fill out a Candidate Questionnaire, voluntarily providing your personal data such as first and last name, contact details, education, professional experience, skills, and interests. We store this data to provide our services in accordance with your decision until they are deleted, but no later than the date of Account deletion. Profiling is necessary for the correct operation of the «Jobs» candidate profile portal service; however, it will not lead to automated decision-making that may have legal consequences for you or otherwise significantly affect you. You will always have access to the full catalog of job advertisements, and the recommendations received from us constitute solely suggestions which, based on the assessment of data contained in the Candidate Questionnaire and in the «Your New Job» tab, we consider potentially interesting for you. Employers do not influence the recommendations they receive and are not notified of them.

When applying for an advertisement in the «Jobs» category via the form posted on the areasell.com platform, regardless of the resume file, message, or candidate questionnaire provided to the employer, you will be asked to provide certain data necessary to send your application to the employer. You can save this data in your account in the Candidate Questionnaire and thus save it for future applications. Providing the above data is necessary to use the Service for responding to advertisements in the «Jobs» category on the Site. areasell.com processes this data in this manner to provide this service in accordance with the Terms and Conditions and appendices thereto.

6.2 How we share your data

Responding to a specific job advertisement in the «Jobs» category implies that we provide your personal data to the Employer at your request. After sending the response, the Employer will receive a message which, depending on your choice, settings, or the scope of the Service, may contain your personal data and may include your application in the recruitment process. Please remember that by providing your resume to the Employer, you become an independent data controller and may process your data outside the Site, that is, outside the rules established by areasell.com. We urge you to carefully review the content of some Advertisements in the «Employment» category, as well as the rules for processing personal data specified by Employers.

You provide your personal data and other information to employers based on your own informed decision. Before providing your data, you should carefully assess the risks associated with disclosing your personal data, including your address, contact information, or exact location. Such risks may include, for example, the possibility of your identification by others, loss of privacy, and, in extreme cases, even identity theft.

How will we inform you of changes to our privacy statement?

We may make changes and updates to this privacy statement from time to time. We will notify you of significant changes to this privacy statement as necessary and in accordance with applicable law, for example, by posting a prominent notice on our Services or by sending you a message via our Services or by email. If you do not agree with how we process your personal data and the options we offer, you can close your account at any time by going to account settings and selecting «Delete Account».

Your rights

Under certain circumstances, you have rights under data protection laws regarding your personal data. If you wish to exercise any of the rights listed below, please go to your account privacy settings or contact us via our Help Center:

Right to request access to your personal data (commonly known as a «data subject access request»). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Right to request rectification of any data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Right to request restriction of processing of your personal data. You may ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. See also sections 1 and 2.
Right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You also have the right to object where we are processing your personal data for marketing purposes. You can exercise your right to object in the following ways, depending on the type of processing you want to stop:n
- For receiving marketing emails, click on the unsubscribe link in our emails;
- For marketing SMS, open notifications, or phone calls, change the notification settings in your account to opt out of receiving them.
- For cookies, click «unsubscribe» on the consent platform;
- If you have objections to the processing of your data in general, you can contact us via the Contact form.
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Right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to withdraw your consent to the processing of personal data at any time. This does not affect the lawfulness of any processing we may have carried out based on your prior consent.

No fee usually: You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Time limit to respond: We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Additionally, you have the right to lodge a complaint at any time with the authority responsible for protecting your data, as indicated in section 15.

However, before lodging a complaint with the data protection authority, we would appreciate the chance to address your concerns first; please contact our Privacy Team by completing the Contact form.

Communication

We will communicate with you by email, SMS, or via in-app notifications related to our Services to confirm your account, notify you of the activation/expiration of your advertising listing, as well as to send other transactional messages related to our Services. Since providing these transactional messages to you is mandatory for us, you will not be able to opt out of receiving such messages.

Who do we share your data with?

We may need to share your personal data with the parties set out below for the purposes set out in sections 4 and 5 above.

Third-party service providers. We use third-party services to provide certain elements of our Services, as well as to secure and monitor our Services. In this regard, your personal data may be shared with the following recipients or categories of recipients:123

Clou4d computing service provi5ders such as Amazon Web Services, Inc. (AWS), Google Ireland Limited (Google Cloud), Microsoft Corporation (Microsoft Azure)6, who may receive some of your personal data for cloud storage;7
Other integrated tool providers such as Google Ireland Limit8ed (Google Maps), who may receive your location data for the purpose of improving the performance of our Services and personalizing the content we send you;
Customer support tool providers such as Zendesk, Inc., who may receive some of your data, such as user account data, customer support requests, message content, for the purpose of communicating with our customer support team;
Customer relationship management tool providers such as SFDC Ireland Limited (Salesforce), who may receive some of your data, such as user account data, contact details of potential clients, for processing by our sales team;
Marketing communications service providers such as Intercom, who may receive some of your data for the purpose of organizing and developing marketing communications campaigns.9

These third-party service providers may be located both within and outside the EEA.10

We vet our third-party service providers and require them to respect the security of your per11sonal data and to treat it in accordance with the law. We do not allow them to use your personal data for their own purposes; we only permit them to process your personal data for specified purposes and in accordance with our instructions.

Advertising and Analytics Providers: To improve our Services, we will sometimes share your data with analytics providers such as Google Analytics 360, who (i) help us analyze how people use our Services to improve them and (ii) help us conduct online marketing and interest-based advertising. We often share your data with them in a non-identifiable form to monitor and evaluate the effectiveness of campaigns with our partners and for internal business analysis. This information usually includes a cookie ID, a truncated IP address, a referring URL, and browser and device information. By analyzing the viewing of our Services using cookies and with the help of analytics providers, we can better understand the use of our Services and improve our product, and we can also show you more relevant areasell.com ads when you visit other websites. For advertising purposes, we partner with advertising providers listed in accordance with the Interactive Advertising Bureau (IAB) terms: https://iabeurope.eu/vendor-list/. We may share your cookie ID (first and third-party cookies) with our advertising partners, allowing us to show you more relevant third-party advertising on our Services based on your browsing activity outside of our Services. To manage advertising settings, you can click on the link in the footer of our website. For more on our analytics and advertising service providers, see our Policy on Cookies and Similar Technologies.

Mergers and Acquisitions: If (part of) our business or assets are reorganized, sold, transferred, or merged with another business, your personal data will be disclosed and transferred to the new owners. In these cases, we will act in accordance with the law, including notifying you and giving you the choice of whether to continue using our Services.

Law enforcement, regulators, and others: We may disclose your personal data to law enforcement, regulators, governmental or public bodies, and other relevant third parties in compliance with legal or regulatory requirements.

Publicly Available Information: By posting an advertisement for the sale of an item through our Services, you may make certain personal information available to other areasell.com users. This may include your first name, last name, email address, location, and contact phone number. Some information, such as your rating and reviews from other users, may be automatically published when you post an advertisement. We also publish your rating and reviews, as well as your username, for users for whom you have left reviews. Please remember that any information you provide to other users may be shared by them with third parties, so please be discreet in this regard.

Clients, legal entities, employers on our Services: To provide you with our services in the «Jobs» category and facilitate the sending of your resume directly through our Services when you wish to apply for a vacancy published on areasell.com, we will send employers data regarding your education, professional experience, skills, photos, preferences regarding desired work, as well as other information contained in your resume or sent by you directly to employers using our Services.

International transfers

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

You can obtain a copy of the relevant and implemented safeguards by contacting us using our Contact form.

Where do we store your data and for how long?

The data we collect from you will be stored and processed both within and outside the EEA on secure servers to ensure the best user experience. For example, for fast website or mobile app development: areasell.com user data in the EEA is stored on cloud servers provided by Amazon Web Services, Inc., located in Dublin, Ireland.

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, tax, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We retain personal data associated with your account for as long as you remain a registered user or until you delete your account. In any case, we guarantee the deletion of your data without undue delay and as soon as possible. Depending on the Service you use and the system in which your data is stored, deletion of your data may take up to 3 months from the date of deletion. During this period, access to your data will be limited or immediately blocked.

If there is no activity on your account for more than 36 months, we will close it in accordance with our Terms of Use and delete all personal data from your account, which means that you will no longer be able to access or use it. However, we will not close your account or delete your data if you have open transactions or are entitled to a refund credited to your account by you or us. Before closing your account, we will notify you so you can keep it active, for example, by logging in.

After your account is closed, we may retain certain data to the extent necessary to: comply with our legal obligations, such as tax, accounting, and auditing, or to resolve legal proceedings or disputes, as well as to fulfill a request from a public authority, such as law enforcement. We will only retain data relevant to such purposes and delete it once applicable retention periods or statutory limitation periods have expired or the legal purpose has been achieved.

For customer safety and fraud prevention purposes, we may retain certain data relating to your closed account, such as your listings, your IP address, moderation information, and user experience information, for a maximum period of 14 months following closure.

Personal data related to cookies is stored for the entire lifecycle of the cookie or until it is deleted. For more details, see our Policy on Cookies and Similar Technologies.

If you have questions regarding the retention period of your data, please contact us by filling out our Contact form.

Technical and organizational measures and processing security

All information we receive about you is stored on secure servers, and we have implemented the necessary technical and organizational measures to protect you3r personal data. areasell.com 4continuously evaluates the security of its network and the adequacy of its internal information security program designed to: (a) protect your data from accidental or unlawful loss, access, or disclosure; (b) identify reasonably foreseeable risks to areasell.com network security; (c) minimize risks, including through risk assessment and regular testing. Additionally, we ensure encryption of all payment data using SSL technology.

Please note that despite the measures we have taken to protect your data, transmission of data via the Internet or other open networks is never completely secure, and there is a risk that third parties may gain access to your personal data.

Links to third-party sites

Our Services may contain links to third-party websites or applications. When clicking on one of these links, please remember that each of them has its own privacy policy. We do not control these websites/applications and are not responsible for their policies. When leaving our Serv5ices, we encourage you to read the privacy policy of every website you visit.

Contacts

For further information or to exercise your rights, please check your account/privacy settings or contact our Privacy Department by completing the contact form or contacting customer support. You can also write to us at the following address: at: Žrtava fašizma bb — «AKADEMIJA ZNANJA» building, Budva.

Data Protection Authority

If you have a complaint related to data protection, you may contact a data protection authority. You may exercise this right by contacting the authority in your place of residence or work, or at the location of the data controller.

Privacy Policy

AirData DOO – Privacy Statement

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