Pursuant to the Law on Protection of Personal Data (“RS Official Gazette”, No. 87/2018) and Article 198, paragraph 4 of the Companies Act (“RS Official Gazette”, No. 36/2011, 99/2011, 83/2014 , – ect. Law, 5/2015 and 44/2018) Company LINKS REAL ESTATE DOO Beograd-Zvezdara, on 21.08.2019. brings:



Article 1.

The Rulebook on the protection of personal data (hereinafter: the Rulebook) is a general act, that is, the main document, which was adopted for the purpose of regulating more closely the protection of personal data of persons who are within the organization of the Company, or in connection with it (above all, employees, associates, consultants and persons otherwise engaged by the Company, as well as persons with whom the Company has a certain form of business cooperation, and whose data the Company processes, eg users and clients), in accordance with the Law on Personal Data Protection Of the Republic of Serbia (“Official Gazette of RS”, No. 87/2018).

LINKS REAL ESTATE DOO Beograd-Zvezdara, st. Nikole Čupića 2, ID: 21551830, VAT: 111846464 (hereinafter referred to as “the Operator”) undertakes to guarantee the confidentiality of personal data in the framework of the real estate brokerage in accordance with the Law on Personal Data Protection (hereinafter referred to as the Law). The Operator also guarantees the security and privacy of the Internet platform he uses, located at http://links.realestate.

The aim of passing the Rulebook is to provide legal certainty and transparency regarding to the processing of personal data of the persons referred to in paragraph 1 of this Article, as well as to establish the legal basis, purpose of processing, types of data processed, rights of persons with regard to the processing of personal data personalities, data protection measures, etc.

The Rulebook also establishes obligations of employees regarding the protection of personal data of persons, in accordance with the law.

The term “employee” includes, in addition to employees within the meaning of the Labor Law, persons hired on the basis of employment contracts, copyright contracts, consultancy contracts, and which contracts contain a clause obliging the Company to be hired by complies with the provisions of this Rulebook, and the text from it is annexed and an integral part of each individual contract.


Article 2

• Property Data Protection Law (“RS Official Gazette”, No. 87/2018, hereinafter: “Data Protection Act”, “DPA”);

• Labor Law of the Republic of Serbia (“RS Official Gazette”, 24/2005, 61/2005, 54/2009, 32/2013, 5/2014, 13/2017 – Constitutional Court decision and 113/2017);

• Commissioner for Information of Public Importance and Personal Data Protection of the Republic of Serbia (hereinafter referred to as “the Commissioner”);

• Personality information is any information relating to an individual whose identity is determined or identifiable, directly or indirectly, especially based on an identity tag, such as name and identification number, location data, identifiers in electronic communications networks or one, that is, more features of his physical, physiological, genetic, mental, economic, cultural and social identity;

• Specific types of personal data are data revealing racial or ethnic origin, political opinion, religious or philosophical beliefs or membership in a union, genetic data, biometric data, data on a person’s health, sexual life or sexual orientation;

• Processing personal data is any action or set of actions that is performed automated or non-automated with personal data or data sets, such as collecting, recording, sorting, grouping, or structuring, storing, rendering or modifying, disclosing, insight, use , detecting by transmitting, or delivering, duplicating, disseminating or otherwise making available, comparing, restricting, deleting or destroying (hereinafter: processing);

• The Operator is the Company as a legal entity, which in terms of Property Data Protection Law determines the purpose and manner of processing personal data.

• The Processor is a natural or legal person, who processes personal data on behalf of the Operator.

• “Recipient” means a natural or legal person, or authority, to whom personal data have been disclosed, whether it is a third party or not, unless it is a public authority that in accordance with the law receives personal data within investigate a particular case and process this data in accordance with personal data protection rules pertaining to the purpose of the processing;

• “third party” means a natural or legal person, or authority, other than the data subject, the Operator or the Processor, or the person authorized to process personal data under the direct control of the Operator or Processor;

• “consent” of the data subject is any voluntary, specific, informed and unambiguous expression of the will of that person, by which that person, by a statement or clear affirmative action, consents to the processing of personal data related to him / her;

• “personal data violation” means a violation of personal data security that results in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access to personal data that has been transmitted, stored or otherwise processed;

• “Representative” means a natural or legal person residing or having a head office in the territory of the Republic of Serbia who, in accordance with Article 44 of this Law, is authorized to represent the Operator or Processor in connection with their obligations under this Law.


Article 3

The Company may process the following personal data of employees:

• First and last name, address, date and place of birth, gender, marital status, identification number, ID card, citizenship, health insurance number (LBO);

• Academic and professional qualifications: level of education, titles, data on skills, knowledge of foreign languages, training, employment history, curriculum vitae;

• Financial information: bank account number, earnings data and additional fees;

• Information on performance of work responsibilities: position, assessment of supervisory authority (persons), business e-mail address, IP address, access credentials (eg username and password);

• Communication data: e-mail, telephone number, contact of an emergency relative, as well as other data necessary for the fulfillment of legally prescribed obligations of the employer and the realization of employment contracts, namely another contractual relationship between the employee and the Company.

• The Company may also process certain categories of special types of personal data, such as health data or religious identity data, and in accordance with Article 17 of the LPDP, special types of personal data of employees for the purpose of fulfilling their obligations or exercising their statutory powers in the field of work, social security and social security.

• The Company does not process large number or any other type of personal informations than is necessary to fulfill the stated purpose. If the processing of specific types of data is done on the basis of a person’s consent (for example, in order to adapt the training conditions to the trainees’ health status), that consent must be given in writing, which contains detailed information on the type of data being processed, the purpose of the processing and how data is used.

The Company may process the following customer / client identity information:

• Name and surname, date of birth, place of birth, address of residence, passport number, JMBG (Unique Master Citizen Number), contact e-mail address, contact telephone.

The Company may process the following information on the candidate’s personal identity:

• First and last name, date and place of birth;

• Academic and professional qualifications contained in the CV and cover letter (education level, titles, skills, foreign language skills, training, list of previous employers; communication data:        e-mail, telephone number).

When announcing an open competition for employment, the Company does not determine the form of the CV, but leaves it to the candidate to determine it himself. In this sense, the Company may come into possession of a larger volume of data than presented, by the will of the job candidate. All data collected is stored for up to 1 year for the purpose of ex-post evaluation of the need to hire job applicants.


Article 4

The Company collects (electronically, in written or verbally) personal data directly from the data subject: employee or client.

The Company may collect information about employees and job applicants from other sources, former employers in particular, in case the provided informations are relevant for employment. All data that is not necessary will be permanently deleted.

Collection and processing of personal data of our suppliers

We collect and process the personal data of our suppliers (as well as the personal data of subcontractors and individuals associated with our suppliers and subcontractors) to manage business relationships, conclusion of contracts, engage suppliers and, where relevant, provide professional services to clients.

Collection and processing of personal data of visitors to our website

As a rule, our website visitors have control over the personal informations they share with us. With the help of cookies on our website, we can automatically capture personal information to a limited extent.

These are personal data such as the name of the website visitor, title, company address, email address, telephone and fax numbers that we obtain when a visitor signs up to receive various notifications from us.

In addition, visitors have the opportunity to send us their email through our website. The messages we receive from them contain information such as the user’s nickname and email, as well as all other information that the user wants to provide in the message.

Please do not trust us sensitive informations through our website (such as information on race and ethnicity; political affiliation; religious and philosophical beliefs; trade union membership; physical and mental health, genetic data; biometric data; sexual data life or sexual orientation; criminal record data). However, if you choose, for any reason, to entrust us with sensitive informations, you hereby give us your express consent that we may collect and use sensitive informations in the manner set forth in this Privacy Statement, or in the manner specified in the disclosure of such information.

Collection of personal data in accordance with the law on prevention of money laundering and terrorist financing

The controller collects data on the ultimate owners of the Companies with which we cooperate in accordance with the Law on Prevention of Money Laundering and Terrorist Financing.

The privacy policy of our Company implies the collection of only those personal data that are necessary for clearly defined purposes, and we ask clients to entrust us with personal data only when necessary for the mentioned purposes.

When we need to process personal data for the purpose of providing professional services, we ask clients to inform the data subjects (hereinafter “Data Holders”) that their data will be used. Our clients may use the relevant sections of this Privacy Statement, or instruct data carriers to use them if they find it necessary.

Given the diversity of services we provide to private clients, we process numerous categories of personal data of individuals – client representatives, depending on the service we provide, such as:

  • Contact information,
  • Business activity,
  • Family data,
  • Revenues, taxes and other financial data,
  • Investments and other financial participations

We have the right to collect special categories of personal data, when it comes to certain services, or activities, or in the case when required by law or with the consent of a natural person.

As a rule, we collect personal data directly from clients, or third parties who act in accordance with the instructions they received from clients.

The Company collects most informations about personal data on persons from his agents directly in the field who are authorized to perform these jobs. These informations are used for the purpose of realization of the Agreement on real estate lease with the Principal and mediate between them for the purpose of concluding the Real estate lease. All agents who collect on behalf of the Company personal data of the persons who contact the contracting authorities are authorized by the Ministry of Trade, Tourism and Telecommunications, relatively all agents are licensed real estate agents.

The list of all licensed real estate brokers and the list of licensed agents within each broker is publicly available and is available on the Ministry of Trade, Tourism and Telecommunications website.

The Company collects personal data from the person he brings in relation to the clients for the purpose of mediating in the traffic or leasing of real estate directly in the field (market) through the following licensed real estate agents:

Ime i prezime

Broj licence

Tijana (Dragoslav) Pavlović



Article 5

The Company processes personal data for the purposes specified in the provisions of Article 6-9 of this Ordinance.

No more data or a wider range of data is processed than it is necessary to achieve the stated purposes.


Article 6

The Company processes personal data for the purposes of establishing and implementing employment, including other contractual relationships by which the Company engages associates and consultants, such as data for the purposes of determining the adequacy and qualifications of candidates for certain positions, for managing working hours and absences, to calculate wages, travel expenses and per diems, to determine sickness and other forms of benefits, to evaluate employee progress, to provide additional training and education and to disciplinary action.


Article 7

Links Real Estate provides real estate market research and analysis services, real estate appraisals and presentations as well as all other information related to the sale and purchase process. In cooperation with its partners, it can offer legal services and advice, as well as the help of a personal banker.

If clients decide to rent, sell or buy any type of real estate, a team of high experts will carefully examine and analyze all their needs and find the best solution in accordance with those needs.

Informations that the Operator collects about clients, legal entities, relates solely for business purposes, that is, for the fulfillment of the Mediation Agreement within the meaning of the Law on Real Estate Brokerage and Leasing. Since the Company is engaged in real estate transactions, it is obliged to collect data in accordance with the Law on Prevention of Money Laundering and Terrorist Financing. Basic informations required of the data subject, legal entities, are: name and surname, date of birth, place of birth, address of residence, passport number, JMBG (Unique Master Citizen Number), contact e-mail address, contact telephone. Clients can submit their data by e-mail, but there are also cases where employees collect data in the field.

Customer data is stored on a server or stored in paper form in a locked cabinet.

Real estate brokering and real estate leasing involves the activities of an intermediary in order to find a potential contractor and to contact that person with the principal in the process of negotiating and concluding a real estate lease Contract, and in order to obtain compensation or brokerage fees.

The mediator performs the activities of real estate brokerage and leasing of real estate on the basis of the concluded Agreement on real estate brokerage or leasing of real estate with the principal.

The ordering party under the Law on Real Estate Brokerage and Real Estate Leasing may be the seller, the buyer, the lessor or the lessee or the proxy of any of these persons.

In addition to find and contact the principal with the person with whom the principal will conclude the Contract on the lease or real estate, the real estate broker also performs the following activities: informs the principal about the objective, real prices of real estate on the market or the market amount of the rent, examines the documents proving ownership or any other real right over real estate, performs necessary actions to present real estate in the advertising market, enable real estate inspection and mediate negotiations and strive to reach the conclusion of the real estate contract or lease of real estate.

An intermediary may transfer its rights and obligations under the Intermediation Agreement in whole or in part to another intermediary under the Mediation Agreement, provided that the Principal has explicitly agreed to this in the Mediation Agreement otherwise it is not possible.


Article 8

The Company processes personal data for the purpose of managing and maintaining the functioning of the communication and information network, as well as maintaining information security.


Article 9

The Company processes personal data for the fulfillment of legal obligations and harmonization of operations with the relevant legal regulations, primarily in the field of labor and tax legislation.


Article 10

Only the Operator and the Operators employee have access to personal data.

Personality information will only be available to third parties outside of the Operators in the following cases:

• The Company will only disclose personal information to third parties for the purposes set out below, taking all necessary steps to ensure that personal data are processed and provided in accordance with applicable regulations.

• The Company may engage third parties – service providers – to perform individual data processing operations for the account and on behalf of the Company in which case, the Company has the capacity of Operator and the service providers the capacity of personal data Processor. In this situation, only the data necessary for the accomplishment of the purpose of the contracted processing is given to the processor, and the processor cannot use it for other purposes. In these cases, the terms of the data processing and the responsibility for data protection will be defined by the contract between the Company and the processor.

• Personal data will only be made available to public authorities when required by law.

• If the information needs to be forwarded in order to implement the Contract.

Personal data processors have no right to process personal data provided to them for purposes other than performing the tasks assigned to them by the Operator, based on the Agreement. Processors are obliged to comply with all written instructions of the Operator. The Operator shall take all necessary measures to ensure that the hired operators strictly adhere to the Personal Data Protection Law and the written instructions of the Operator, as well as to take appropriate technical, organizational and personnel measures to protect the personal data.


Article 11

Personal data will not be retained for longer than is necessary for the purpose for which they were processed. If the term of keeping personal data is prescribed by law, the Company shall retain the data within the given legal period. Upon fulfillment of the purpose, meaning, expiry of the statutory time limit for keeping the data, the data will be permanently deleted.

In accordance with the Law on Tourism, we keep all documentation about sold tourist trips, which include the Travel Contract with individuals and their data, in our reservation system for two years, after which we delete the data from the system.

The data is not used for other uses, nor is it sent to third parties.

In certain cases, personal data may be stored for an extended period of time, for the purposes of fulfilling legal obligations or for establishing, exercising or defending a legal claim, in accordance with applicable laws.

Personal data on employees and former employees are permanently stored in the Company’s personnel records in accordance with the Law on Records in the Field of Work.


Article 12

• Right to be informed

Employees and other data subjects have the right to be informed of their rights, obligations and issues related to the processing of their personal data, within the meaning of the Property Data Protection Law, even before the processing of such data begins.

• Right to access

Employees and other data subjects have the right to request from the Company to provide access to their personal data, in means to have the right to determine the subject, manner, purpose and extent of the processing of such data, as well as to ask questions about the processing itself.

• Right to rectification and amendment

Upon completion of the inspection, data subjects have the right to request from the Company to correct, supplement, or update the processed personal data.

• Right to delete

The data subject may require the Company to delete their personal data in accordance with the Property Data Protection Law, as well as to interrupt or temporarily suspend processing.

• Right to withdraw processing consent

In situations where the legal basis for the processing of personal data is the consent of the data subject, that person shall have the right to withdraw that consent at any time, in writing.

• The right to limit processing

The data subject, in accordance with the Property Data Protection Law, has the right to require the operator to restrict the processing of his personal data.

• Right to data portability

The data subject may require the transfer of personal data to another operator, when technically feasible, or when the personal data subject to the transfer request is in a structured and machine-readable format.

• Right to object and to make individual decisions automatically

If it considers it justified in relation to the particular situation it is in, the data subject shall have the right to object at any time to the operator for the processing of his or her data, and not to be subject to a decision taken solely on the basis of automated processing, including profiling, if that decision produces legal consequences for that person or that decision significantly affects his or her position.

The data subject has the right to oppose the processing of personal data for the purpose of direct marketing and to request a restriction of processing in other cases.

In case the data subject is not satisfied with the Company’s response to the request for fulfillment of the rights regarding the protection of personal data, it has the right to file a complaint with the Commissioner for information of public importance and protection of personal data (https://www.poverenik.rs/sr/).


Article 13

Employees are obliged to submit their personal data, which are necessary for the Company to fulfill its legal obligations, as well as to carry on its current business.

Employees are obliged to respect and protect the personal data they process during work, in accordance with the personnel, technical and organizational measures prescribed by the Operator or employer, in order to protect the integrity of the personal data and the rights of the data subject.

Employees can only process data that they are allowed to access, in accordance with the tasks they perform.


Article 14


Contact information about the Operator:

Name of Operator: LINKS REAL ESTATE DOO Beograd-Zvezdara

Address: st. Nikole Čupića 2, Beograd – Zvezdara

Contact phone: 011 770 94 90

Mail: ofiice@links.realestate

Personal Data Protection Officer:

In accordance with Article 56 of the Law on Personal Data Protection, the Operator is not obliged to appoint a person for personal data protection.


Article 15

This Regulation shall apply from 21.08.2019. year, meaning, from the date of application of the Law on Personal Data Protection.


Data Security and Privacy Act


Article 1.

LINKS REAL ESTATE DOO Beograd-Zvezdara, http://links.realestate (hereinafter: the Company), as the handler of personal data, considers that the trust of persons who, in accordance with Article 4, paragraph 1, point ( 1) of the Law on Personal Data Protection “Official Gazette of RS”, no. 87 of 13 November 2018) (hereinafter: the Law) has provided its personal data (hereinafter: the users) by means of a internet presentation on a web address: http://links.realestate (hereinafter: the site) is very important and represents one of the fundamental ethical values of the Company’s operations. In this regard, the Company has taken the necessary measures and actions, in accordance with the Law, to protect and secure the privacy of the personal data provided, which will be presented below in the text of this act, in accordance with Article 23 of the Law.


Article 2.

The Company collects and processes the following information from site users:

  • Identification informations: First name, last name and e-mail address (hereinafter: personal data)
  • Website login and user behavior data (Cookies)


Article 3.

The personal data of the users are processed only with their explicit consent, in accordance with Art. 15 of the Law. The consent request is presented in a way that stands out from other questions, in an understandable and easily accessible form, and by using clear and simple words.


Article 4.

Users submit their personal information by entering it in the contact form available on the site, also in a case of presenting employees (as well as otherwise engaged), clients and partners as references in the sections of the site, called Contact and while using or viewing the site through the Cookies.

The company uses WordPress (WP) , software for editing the look and content of the site, for its site.


Article 5.

The Company collects and processes the personal data of users only for the purpose of communication, in means of, establishing and maintaining contact with persons interested in a certain type of business cooperation with the Company, which may refer specifically (but not exclusively) to inquiries of persons for practice and employment, then upon invitation to make an offer for one of the services provided by the Company, but also for the purpose of representing the data subjects as members of the team, as well as in the provision real estate brokerage and leasing, just like any other form of business communication.

Establishing and maintaining communication involves two-way communication with the persons referred to the ones in paragraph 1 of this Article, which is related on informing those persons, first of all, about their rights in accordance with the Law, and also about all other relevant issues related to business cooperation that they wish to achieve, or which they have achieved with the Company.

Persons who accepted the possibility of being contacted by the Company about the particular form of business cooperation, as in other cases from Articles 2 and 4 of this Act, may at any time withdraw that acceptance in accordance with Art. 15, paragraph 3 of the Law, which will result in the suspension of processing of personal data of the persons to whom the data is related.


Article 6.

Persons to whom the data is referred have the right for transparent way of exercising their rights in accordance with Article 21 of the Law, and that means above all, the right of persons to be provided with all information from Art. 23 and Art. 24 of the Law, that is, information regarding the exercise of the rights referred to in Article 26, Art. 29 to 31, Article 33, Art. 36 to 38 and Art. 53 of the Law, in a concise, transparent, comprehensible and easily accessible manner, using clear and simple words. This information will be provided in writing and other forms, including electronic form, as appropriate. If requested by the data subject, the information may be provided orally in accordance with Article 21, paragraph 1 of the Law.

The rights of the data subject referred to Article 21 are simultaneously determined by the obligations of the data operator and informations about those rights may be provided in combination with standardized icons displayed in electronic form so it could be easy visible and understandable way to provide meaningful insight into the intended processing, in accordance with the Act.

Article 7.

In addition to the rights referred to the Article 6 of this Act, the data subject has the following rights, in accordance with the Law:

1) Right to access:

The data subject has the right to request information from the operator whether he or she processes his personal data, access to such data, and other information in accordance with the Law.


2) Right to correction and amendment:

The data subject has the right to correct his incorrect personal data without undue delay. Depending on the purpose of the processing, the data subject has the right to supplement his / her incomplete personal data, which includes making an additional statement.

3) Right to delete personal data:

The data subject has the right to have his / her personal data erased by the operator, and he or she is obliged to delete that data without undue delay in certain cases provided by law.

4) Right to Restrict Processing:

The data subject shall have the right to restrict the processing of his personal data by the operator if alternatively one of the cases, provided for in Article 31, paragraph 1, is fulfilled.

5) The right of the data subject to be informed about the correction or deletion of data, as well as the restriction of processing:

The operator is obliged to notify all recipients to whom the data is referred about any correction or deletion of the personal data or the restriction of their processing (unless this is impossible or requires excessive time and resources). The operator is also obliged to inform the data subject, at his request, of all recipients to whom the personal data have been disclosed.

6) Right to data portability:

The data subject has the right to receive his personal data, previously handled to the operator, from him in a structured, commonly used and electronically readable form and to have the data transmitted to the other operator without interruption by the operator to whom the data were submitted, subject to legal requirements. This right also includes the right of a person to have his or her personal data transferred directly to another operator by the operator to whom this information was previously provided, if technically possible.


7) The right to object and to automatically make individual decisions:

If it is considered to be justified to the particular situation, the data subject shall have the right to object to the operator about processing of his or her personal data, at any time, which also applies to profiling, and the operator is obliged to suspend the processing of the data of the person which filed the complaintment unless the operator has provided legal grounds for processing which outweighs the interests, rights or freedoms of the data subject or they are about reporting, achieving or defensing the legal claim.

8) Automated decision making and profiling:

The data subject has the right not to be subject to a decision made only on the basis of automated processing, including profiling, if that decision produces legal consequences for that person or that decision significantly affects his or her position.

The data subject may contact the Company, for the purpose of exercising his / her statutory rights.


Article 8.

The personal data from Article 2 of this Act shall not be discovered to anyone outside the organization of the Company. Only the person who, within the Company, is responsible for answering queries from the site, as well as the person or persons participating in the process of deciding how to handle those queries.


Article 9.

The Company protects your information while communicating using an SSL security certificate that encrypts all data transmissions and baners for managing cookies, and it also has an F-secure server license and a special PC license.

The personal data of the users will be kept, first of all, in order to fulfill the purpose of their processing, from the Article 5 of this Act, in accordance with Art. 5, paragraph 1, item. (5) of the Law, that is, as long as there is a need to communicate with users. After the storage period expires, the personal data will be deleted.


Article 10.

Cookies are text files placed on the computer of a person who visited the site for the purpose of collecting standard information regarding the login to the site and the behavior of that person during their stay on the site, which may be sent to a web browser used by that person. The Company may collect / process such information automatically through cookies or similar technologies. For more information on Cookies, visit allaboutcookies.org.

Users who are concerned about the privacy and using the Cookies may set the Internet browser to notify them when they receive a Cookie, and to decline cookies that attempt to send other websites.

Your use of the Site is not conditioned with giving acceptance to the use of Cookies.


Article 11.

There is a possibility that the site has external links pointing to other websites. The provisions of this Privacy and Personal Data Protection Act apply only to the Site, so it does not assume responsibility for the privacy policies of other websites.

Article 12.

The provisions of this Act will be applied from the date of their publication on the Website.

The Company has the exclusive right to unilaterally amendment this act, and also to announce it in the manner provided in paragraph 1 of this Article.