Privacy Policy
Last updated: May 2026 · AdaptiveAsk · Tax ID 115672200
AdaptiveAsk ("we", "us", the "Company") respects the privacy of every user. This document explains in detail what data we collect, why, how we protect it, and what your rights are as a data subject in accordance with the GDPR and the Law on Personal Data Protection of the Republic of Serbia (ZZPL).
1. Data Controller
The controller of personal data is:
AdaptiveAsk
Belgrade, Republic of Serbia
Registration Number: 68544254 · Tax ID: 115672200
Email: kontakt@adaptiveask.net
Phone: +381 60 609 1010
2. What Data We Collect
We collect two categories of data:
Data you provide. When you fill out a contact form or questionnaire on the site, we collect: name and surname, email address, company name, website URL, number of SKUs, and any notes. This data is forwarded to our email via the Formsubmit service and is kept exclusively for the purpose of responding to your inquiry and potentially establishing a business relationship.
Data we collect automatically. When you visit the site, we automatically collect technical data: IP address (anonymized), browser type and version, operating system, pages visited, time spent on the page, and referral URL. We collect this data via Google Analytics 4 (GA4), exclusively with your express consent.
3. Legal Basis for Processing
All data processing operations are based on one of the following legal grounds:
- Consent (Art. 6(1)(a) GDPR) — for analytical cookies and marketing tracking. You give consent through our cookie consent banner and can withdraw it at any time.
- Contract Performance (Art. 6(1)(b) GDPR) — for processing data necessary to provide services to clients with whom we have an active contract.
- Legitimate Interest (Art. 6(1)(f) GDPR) — for processing data from contact forms to respond to your inquiries and improve our services.
- Legal Obligation (Art. 6(1)(c) GDPR) — for keeping business and accounting documents for the legally prescribed period.
4. Purpose and Data Retention Period
Data from contact forms is kept until the end of communication and eventual cooperation, and for a maximum of 2 years from the last contact. Analytical data (GA4) is kept for 14 months, which is the minimum period allowed by Google Analytics. Accounting documentation is kept for 10 years in accordance with the Serbian Law on Accounting.
Upon expiration of the retention period, data is permanently deleted or anonymized in a way that prevents identification.
5. Sharing Data with Third Parties
We do not sell, rent, or exchange your data with third parties for commercial purposes. Data may be shared exclusively with the following categories of recipients:
- Google LLC — via Google Tag Manager and Google Analytics 4, exclusively with your consent and using Consent Mode v2.
- Formsubmit.co — as a proxy for delivering messages from contact forms. Messages are not kept for more than 30 days on their servers.
- Accounting service providers — who are bound by a confidentiality agreement and process data exclusively on our behalf.
- Competent state authorities — only when we are legally obliged to do so by law or court order.
All third parties we cooperate with provide an appropriate level of data protection, including standard contractual clauses for data transfer outside the EEA, where applicable.
6. Data Transfer Outside of Serbia and the EEA
Certain tools we use (Google Analytics, Formsubmit) may transfer data to servers outside the Republic of Serbia and the European Economic Area (EEA). In these cases, the transfer is performed based on Standard Contractual Clauses (SCC) approved by the European Commission, or based on an adequacy decision. Google is a signatory to the EU-US Data Privacy Framework, which ensures lawful data transfer.
7. Your Rights as a Data Subject
In accordance with the GDPR and ZZPL, you have the following rights:
- Right of access — you can request a copy of all data we keep about you.
- Right to rectification — you can request the correction of inaccurate data.
- Right to erasure ("right to be forgotten") — you can request the deletion of data, except for those we are obliged to keep by law.
- Right to restriction of processing — you can request a temporary stop to the processing of your data.
- Right to data portability — you can request that we provide your data in a machine-readable format.
- Right to object — you can object to processing based on legitimate interest or performed for direct marketing purposes.
- Right to withdraw consent — you can withdraw consent for analytical cookies at any time without affecting the lawfulness of processing before withdrawal.
To exercise any of the above rights, contact us at kontakt@adaptiveask.net. We will respond within 30 days. If you believe your rights have not been respected, you can file a complaint with the Commissioner for Information of Public Importance and Personal Data Protection of the RS.
8. Data Security
We apply appropriate technical and organizational protection measures, including: HTTPS encryption throughout the site, restricted access to data exclusively for authorized persons, regular security checks of the tools we use, and data processing agreements (DPA) with all third-party processors.
In case of a data breach that may jeopardize your rights and freedoms, we will notify the competent authority within 72 hours, and you — without unnecessary delay, in accordance with legal obligations.
9. Cookies
A detailed overview of the cookies we use, along with instructions for managing consent, is available in our Cookie Policy.
10. Changes to the Privacy Policy
We may change this policy in accordance with changes in legislation or our business processes. The date of the last change is always indicated at the top of the document. For substantive changes affecting your rights, we will notify you via email if you have an active business relationship with us, or via a visible notice on the site.
11. Contact and Complaints
For all questions, requests, or complaints regarding the processing of your personal data, please contact:
AdaptiveAsk
Email: kontakt@adaptiveask.net
Phone: +381 60 609 1010
If you are not satisfied with our response, you have the right to contact the Commissioner for Information of Public Importance and Personal Data Protection (www.poverenik.rs).