Welcome to ElanWave's Privacy Policy!

ElanWave, as a data controller, collects and processes personal data relating to interactions on the Website and the use of our Service.

This Privacy Policy describes how ElanWave uses and protects any information that you give us. ElanWave understands that personal data protection is of great importance to you and due to that we are committed to ensuring that your privacy is protected.

We strongly urge you to read this Privacy Policy and make sure that you fully understand and agree with it. If you do not agree to this Privacy Policy, please do not access or otherwise use the Website.

This Privacy Policy applies to all individuals who access our website at www.elanwave.com (hereinafter: “Website”), send us inquiries via the Website, engage our professional services (hereinafter: “Services”), or apply for a job or internship in ElanWave doo Novi Sad. However, the Privacy Policy does not apply to information from which no individual can reasonably be identified (anonymized information).

Please read this Privacy Policy given that, along with our Terms & Conditions and Cookie Policy, it constitutes an agreement that applies to you (hereinafter: “Agreement”).

For any questions regarding this Privacy Policy, please contact us at info@elanwave.com.

DEFINITIONS
PERSONAL DATA THAT WE COLLECT
NO INFORMATION ABOUT PERSONS UNDER THE AGE OF 16
HOW DO WE USE YOUR PERSONAL DATA?
KEEPING YOUR PERSONAL DATA
SHARING YOUR PERSONAL DATA
YOUR RIGHTS
HOW DO WE KEEP YOUR PERSONAL DATA SECURE?
CHANGES TO OUR PRIVACY POLICY
HOW TO CONTACT US?

1. DEFINITIONS

When we say “Personal data” or “data” we mean any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Therefore, data about a company or any legal entity is not considered to be personal data. However, the information in relation to one-person companies may constitute personal data where it allows the identification of a natural person. The rules also apply to all personal data relating to natural persons in the course of professional activity, such as the employees of a company/organization, business email addresses like 'forename.surname@company.eu' or employees' business telephone numbers.

When we say “ElanWave”, “we” or “us” we mean:

1) ElanWave doo Novi Sad, with registered seat at Rumenačka Street no. 1, 21000 Novi Sad, the Republic of Serbia, CIN: 21220060, TIN: 109665534, and

2) Elanwave Nederland B.V., with registered seat at Koolstraat 17, 5708 ZM, Helmond, Netherlands, CIN: 66092906.

When we say “You” or “Data subject” we mean any natural person who shares data with us.

When we say “Cookies” we mean small pieces of data stored on your device (computer or mobile device). This information is used to track your use of the Website and to compile statistical reports on website activity. For further information about the use of cookies and how you can manage them, please read our Cookie Policy.

When we say “Data Processors” we mean any natural or legal person who processes the data on behalf of us (Data Controller). We may use the services of various service providers in order to process your data more effectively in accordance with section 6 (Sharing your personal data).

When we say “processing” we mean any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

2. PERSONAL DATA THAT WE COLLECT

2.1. Personal data that we collect from you

Depending on how you use the Website, the information we may collect from you include:

2.1.1. Personal data you share with us voluntarily

Your name,
Your contact information, such as your e-mail address,
Information that you choose to share with us in your inquiry via the Contact page on our Website or otherwise (for example, when booking a call with us),
Information that you choose to share with us during the application process for a job or internship at ElanWave,
Information that you choose to share with us when you engage our Services

If you contact us via Contact page on our Website, or otherwise (including an inquiry at info@elanwave.com or at any other e-mail address available at the Website, social media, a telephone conversation, etc.), we may receive additional information about you, such as home address or business address, your profession, content of the messages or attachments you may send us, or any other information you decide to share with us.

If you contact us at info@elanwave.com in the process of applying for open positions we will ask you to send us your CV and (optionally) your Cover Letter. During the application process for an internship or a job at ElanWave, we may ask you questions regarding your professional life, which can be relevant for your future position.

ElanWave uses your personal data to match your skills, experience and education with the specific roles offered by ElanWave. This information is passed to the relevant hiring managers and persons involved in the recruitment process to decide whether to invite you for an interview. ElanWave will collect further information from you if you are invited to the interview (or equivalent) stage and onwards.

If you engage ElanWave Services, we may ask you to provide any other personal data not described above, which is necessary for us in order to provide you with the Services. These rules only apply to personal data about individuals, they don't govern data about companies or any other legal entities.

When you sign up for our Newsletter, it would be necessary to share with us your e-mail address

2.1.2. Personal data we collect automatically

When you visit our Website, we may collect certain personal data automatically from your device.

More precisely, the information we collect automatically may include information such as your IP address, device type, unique device identification number, browser-type and broad geographic location (e.g. country or city-level location). We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.

Collecting this information enables us to better understand the visitors who visit our Website, where they come from, and what content on our Website is of interest to them.

This information is collected primarily by using cookies and similar tracking technology, as explained further in our Cookie Policy.

2.1.3. Personal data we collect about you from third parties

Sometimes, we may obtain your personal data without you giving us such data directly.

If you are a candidate for a position at ElanWave, we may obtain information about you:

through publicly available sources online - (e.g. on your current employer's website, or on a professional networking site like LinkedIn); and
by reference or word of mouth - for example, through a referral from a former employee/employer or from a referee you have identified.

If you are a client, we will process identification and background information as part of our business acceptance and to fulfill any other legal or regulatory requirements to which we may be subject.

Summary of the Processing Activities

DATA WE COLLECT	PURPOSE	LEGAL BASIS	RETENTION PERIOD
Your first name, last name, email, company name and other information you choose to share with us in your inquiry.	To respond to your inquiries sent: via our Website Contact Page, when booking a call with us, to info@elanwave.com or any other e-mail provided on the Website otherwise.	Processing is necessary for the performance of the agreement or entering into such agreement with you or it is based on our legitimate interest i.e. for the initiation of future collaboration.	In the event an agreement is concluded between you and ElanWave, your data will be processed for the duration of that agreement. If an agreement is not concluded, we may process your data for a period of 3 months based on our legitimate interest to maintain records of communications for follow-ups or clarifications and defend against potential legal claims (e.g., proof of communications).
Your first name, last name, email, CV and (optionally) Cover Letter.	After you send us your job or internship application, we will need to examine it in order to determine whether you fulfill our requirements as a candidate.	Processing is necessary for the performance of the agreement or to enter into such an agreement with you. Sometimes, processing is also based on your consent. Processing of job candidate’s data is covered in more detail in our separate Employment Candidate Privacy Notice which is delivered to all job candidates at ElanWave.	We will keep your data for a period of 6 months after your last application date if your application is not successful. If you have given your consent to keep your data after that period, in that case we will keep your data for a maximum of one year after your last application date. If your application is successful and you establish an employment relationship, we will store your data during the duration of the employment relationship and after the termination of the employment relationship in accordance with our internal rules and procedures.
Email of subscribers to our newsletter.	You can leave us your email address in order to subscribe to our newsletter. This newsletter allows us to inform you of the new products and services, updates, as well as other news relevant to the company. We may use your email address to notify you about any changes to the Website, policies, products and services.	Your consent.	We will keep you on our mailing list until you withdraw your consent. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on the consent prior to such withdrawal. You may unsubscribe from or mailing list at any time, by using the option “unsubscribe” in the email.
Technical and usage data are collected primarily by using cookies and similar tracking technology, as explained further in our Cookie Policy.	Collecting this information enables you to navigate through a website and use the different options or services that exist within it and enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We can also process this data in order to prevent misuse and fraudulent behavior on our Website and thus to protect our business, but also our partners, employees, and other data subjects, we need to process this Personal data.	Processing is based on your consent or our legitimate interest, i.e. for the safe usage and functioning of our Website, the protection of our business, but also the protection of our other Website visitors, which is essential to us.	If the processing is based on your consent, until the withdrawal of your consent. You can withdraw your consent at any time at your cookie setting as explained in our Cookie Policy. The withdrawal of consent does not affect the lawfulness of the processing based on the consent prior to such withdrawal. If the processing is based on our legitimate interest, in accordance with the applicable statutory deadlines.

We do not process data outside the specified purposes, and, especially, we do not:

Sell any kind of personal data,
Disclose this information to other marketers,
Provide your personal information to any third-party individual, government agency, or company at any time unless strictly compelled to do so by law.

3. NO INFORMATION ABOUT PERSONS UNDER THE AGE OF 16

The Website is not intended for children, and we do not knowingly collect data relating to children. If you are under the age of 16, please do not provide any personal information about yourself to us. If we learn that we have collected personal information from a child under the age of 16, we will promptly delete that information. If you believe we have collected personal information from a child under the age of 16, please contact us at info@elanwave.com.

4. HOW DO WE USE YOUR PERSONAL DATA?

We will only use your personal data if we have your consent or if some other valid legal basis applies as explained under Section 2 of this Privacy Policy.

Your personal data will be used only for purposes we collected it for. We will use your personal data only when we have a reasonable and lawful reason to do so.

Our staff is legally bound by professional secret and we use all legal, technical, and organizational measures to prevent any disclosed information is revealed outside the purpose for which was collected.

5. KEEPING YOUR PERSONAL DATA

We do not keep your personal data longer than the time it takes to fulfill the purpose for which is collected, or no longer than the time for which we have your consent.

For example, if you unsubscribe from our Newsletter, your data will be erased automatically.

Data retention periods are described in more detail in section 2 (Personal Data We Collect > Summary of the Processing Activities).

However, as an exception to the data retention periods in Section 2, data may be processed longer for the purpose of submitting, enforcing, or defending a legal claim or counterclaim.

Furthermore, if a specific imperative regulation defines the obligation to retain certain data for a period longer than stated in Section 2, we are obliged to retain the data within that period.

6. SHARING YOUR PERSONAL DATA

ElanWave utilizes external processors for certain processing activities. We use information audits to identify, categorize and record all personal data that is processed outside of the company, so that the information, processing activity, processor and legal basis are all recorded, reviewed and easily accessible. Such external processing includes (but is not limited to):

Affiliates
IT Systems and Services,
Legal Services,
Human Resources,
Direct Marketing Services.

We may be legally required to share certain information, including your personal data, with e.g. public authorities or governmental bodies; in such case, we will not require your further consent in order to share your personal data in such circumstances.

PROCESSOR	ROLE	SEAT
Google LLC	Analytics	United States
Microsoft Corporation	Data Storage	United States
Calendly	Software for scheduling of meetings	United States

DATA RECEPIENTS	ROLE	SEAT
Meta Platforms Inc. And Meta Platfroms Ireland Limted	Owners of the social network Facebook and Instagram	United States, Ireland, Denmark and Sweden
LinkedIn Corporation	Owner of the LinkedIn social network	United States
Google LLC	Owner of googly Analytics and Google Ads	United States

We may transfer your personal data to countries other than the one you reside in. In these cases, we will transfer your personal data only:

To the countries within the EEA where our servers are located.
To the countries which do not form the EEA but are considered to ensure an adequate level of protection;
To the countries which do not belong to those specified under items 1. and 2, but only by applying the appropriate safeguard measure in accordance with the GDPR (for example, applying standard contractual clauses).

7. YOUR RIGHTS

Right to withdraw the Consent	If you have provided your consent to the collection, processing, and transfer of your Personal data, you have the right to withdraw your consent - fully or partly. Once we have received a notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented, unless there is another legal ground for the processing.
Right to access	You can send us a request for a copy of the Personal data we hold about you. We have ensured that appropriate measures have been taken to provide such a copy in a transparent and easily accessible form, using clear and plain language. Such information is provided in writing free of charge. It may be provided by other means when authorized by the Data subject and with prior verification as to the subject’s identity. Information will be provided to the Data subject at the earliest convenience, but at a maximum of 30 days from the date the request was received. Where the retrieval or provision of information is particularly complex or is subject to a valid delay, the period may be extended by two further months where necessary.
Right to correction of your Personal data	If the Personal data we have about you is incorrect, you have the right to request that we correct those data. In such a case, we will rectify the error within 30 days and inform any third party of the rectification if we have disclosed the Personal data in question to them.
Right to be forgotten	You have the right to request from us that your Personal data be deleted in these situations: The personal data are no longer needed for the purpose for which they were collected; You have withdrawn your consent (where the processing was based on consent); You have objected to the processing and no overriding legitimate grounds are justifying us processing the personal data; the Personal data was being unlawfully processed; or the Personal data has to be erased for compliance with a legal obligation. However, this right does not apply where, for example, the processing is necessary to comply with a legal obligation, or for the establishment, exercise, or defence of legal claims.
Right to the restriction of processing	You can exercise your right to the restriction of processing if: the accuracy of the Personal data is contested, the processing is unlawful, but you do not want the data erased, we no longer need the Personal data but you require the data for the establishment, exercise, or defence of legal claims, you have objected to the processing, but the verification of whether the legitimate reasons of the data controller override those of the Data subject is pending.
Right to data portability	In case you have provided your Personal Data to us, and that data is processed using automated means, you have the right to ask us for a copy of such Personal Data, as well as to have those data transmitted to a third-party data controller.
Right to object	You have the right to object to using your Personal Data in case processing is based on our legitimate interest, as well as if the processing is performed with a purpose of direct marketing, which includes profiling.
Right to Lodge a Complaint	If you have any concerns or requests in relation to your Personal data, please contact us at info@elanwave.com and we will respond within 30 days. If you are not satisfied with our response, you can also contact the competent a) supervisory authority in the country where you reside or b) the Commissioner for Information of Public Importance and Personal Data Protection, Bulevar kralja Aleksandra 15, 11120 Belgrade, email office@poverenik.rs or c) the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at Prins Clauslaan 60, 2595 AJ The Hague, Netherlands, or via email at info@autoriteitpersoonsgegevens.nl.

To exercise these rights, please contact us atinfo@elanwave.com.

8. HOW DO WE KEEP YOUR PERSONAL DATA SECURE?

We use appropriate technical and organizational measures to protect the personal data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data.

However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security or confidentiality. If you have any questions about security on the Website or Service, you can contact us atinfo@elanwave.com

9. CHANGES TO OUR PRIVACY POLICY

We reserve the right to change Privacy Policy from time to time at our sole discretion.

Any changes shall enter into force upon being published on our Website. You are cautioned to review our Privacy Policy periodically.

If we have your e-mail address, we may send you the notice of these changes.

If you do not agree to our Privacy Policy, please stop using our Website immediately.

10. HOW TO CONTACT US?

Should you wish to exercise any of the rights you have as a data subject, or you have a question for us regarding this Privacy Policy, please contact us at info@elanwave.com.