EDIT summer school Privacy Policy (International)

1. INTRODUCTION

 

With this Privacy Policy (hereinafter: “Privacy Policy”) we intend to inform you about the scope and purpose of your personal data that may be collected, used and processed during the organisation of the EDIT Summer School in Serbia, Slovenia and Bosnia and Hercegovina int he period from July 27 to July 31, 2026 (hereinafter referred to as “Event”) and while you visit our website https://www.edit.world/ (hereinafter: Website).

 

Following companies are acting as joint controllers:

 

COMTRADE SYSTEM INTEGRATION D.O.O. BEOGRAD, with its registered seat at Savski nasip 7, 11070 Belgrade, Serbia, reg. number: 17335847, VAT: 100181280,

 

COMTRADE SI SISTEMSKE INTEGRACIJE D.O.O., with its registered seat at Letaliska cesta 29b, 1000 Ljubljana, Slovenia, reg. number: 8371741000, VAT: SI 60227818 and

 

COMTRADE SYSTEM INTEGRATION D.O.O. SARAJEVO, with its registered seat at Džemala Bijedića 179, 71000 Sarajevo, Bosnia and Herzegovina („BiH“), reg. number:  65-01-1251-09, VAT: 201204010005

 

Certain terms in this Privacy Policy shall have the following meaning:

• “We”, “us” and “our” shall mean the legal entity that is part of the Comtrade Group with which you have established a relationship. For example, the entity you have a business relationship with, or organizing the event you are attending, or managing the website you are using. We will make it clear to you which entity it is;

• ‘the site/website’ means this website you are visiting or engaging with; and

• “You” and “your” shall mean you, a person who interacts with us, does business with us, registers for our events or services or visits our Website.

 

We are strongly committed to protecting and keeping confidential any information collected in this manner, and to always abide by the applicable laws.

 

2. DATA PROTECTION OFFICER (DPO)

 

Comtrade System Integration d.o.o. Beograd

Danijel Stošić

Address: Savski nasip 7, 11070 Belgrade, Serbia

Phone number: + 381 11 201 5600

E-mail: dpo@comtrade.com

 

3. LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

 

We may collect and process the personal data that you have personally provided us with, that we have collected ourselves or from third parties with whom we work closely, or from publicly available sources.

 

Legal basis for the processing of personal data may be:

• the performance of a contract with you (in compliance with i) Serbia: Article 12(1)(2) of the Law on personal data protection (Official gazette of RS, No. 87/2018 („LPDP RS“); ii) Slovenia: Article 6(1)(b) of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 („GDPR“); iii) BiH: Article 8(1)(b) of the Law on the Protection of Personal Data (Official gazette of BiH, No. 12/2025 („LPPD BiH“)), for example where you have a business relationship with us (for the performance of a contract or in order to take steps prior to entering into a contract) or where you have registered to attend or display at the Event;
• our legitimate interest (in compliance with i) Serbia: Article 12(1)(6) of LPDP RS; ii) Slovenia: Article 6(1)(f) of GDPR; iii) BiH: Article 8(1)(f) of the LPPD BiH, for example our desire to improve the Website; to keep you up to date on our business activities and future events; marketing promotions of the Event itself (printing promotional materials and presenting the Event on the official websites of the controllers and affiliated legal entities that are part of the Comtrade Group, on the  internal websites of the controllers, and on the controllers` official social media accounts such as LinkedIn, Facebook, Instagram, Twitter, and YouTube, as well as those of affiliated legal entities within the Comtrade Group, by publishing photographs and video recordings);
• your consent (in compliance with i) Serbia: Article 12(1)(1) of LPDP RS; ii) Slovenia: Article 6(1)(a) of GDPR; iii) BiH: Article 8(1)(a) of the LPPD BiH, for example when you accept the use of cookies on a website or when you give consent for the processing of your personal data for one or more specific purposes;
• to comply with a legal obligation to which we are subject (in compliance with i) Serbia; Article 12(1)(3) of LPDP RS; ii) Slovenia: Article 6(1)(c) of GDPR; iii) BiH: Article 8(1)(c) of the LPPD BiH).

 

4. PURPOSES OF PROCESSING

 

We may collect and process your personal data for the following purposes:

 

• To enable you to participate in the Event (performance of a contract concluded with you pursuant to: i) Serbia: Article 12(1)(2) of the LPDP RS; ii) Slovenia: Article 6(1)(b) GDPR; iii) BiH: Article 8(1)(b) of the LPPD BiH), in which case we collect the following personal data:

• Pre-registration: first and last name; e-mail address; telephone number; information regarding education (high school, faculty, average grade); year of study (current class) and status of study obligations; knowledge and experience; preferences and interests;
• Registration: first and last name; address; email address; telephone number; shirt size; information about your education (secondary school, university, grade point average); year of study (current year) and status of study obligations; scholarship information; your knowledge and experience; your areas of interest and professional interests; CV/resumé; information, expectations, and previous participation in the Event;

 

We collect the above personal data in order to enable your participation in the Event. If you do not provide the required information, you will not be able to attend the Event.

 

• To ensure the successful and efficient organization of the Event at all locations (legitimate interest pursuant to: i) Serbia: Article 12(1)(6) of the LPDP RS; ii) Slovenia: Article 6(1)(f) GDPR; iii) BiH: Article 8(1)(f) of the LPPD BiH): first and last name; address; email address; telephone number;

 

• For marketing and promotion of the Event itself and of the organizers at all locations (legitimate interest pursuant to: i) Serbia: Article 12(1)(6) of the LPDP RS; ii) Slovenia: Article 6(1)(f) GDPR; iii) BiH: Article 8(1)(f) of the LPPD BiH), which includes printing promotional materials and presenting the Event on the official websites of the controllers and affiliated legal entities that are part of the Comtrade Group, on the  internal websites of the controllers, and on the controllers` official social media accounts such as LinkedIn, Facebook, Instagram, Twitter, and YouTube, as well as those of affiliated legal entities within the Comtrade Group, by publishing photographs and video recordings: first and last name; email address; audio, video, and photographic materials from the Event;

 

• To improve our Website (legitimate interest pursuant to: i) Serbia: Article 12(1)(6) of the LPDP RS; ii) Slovenia: Article 6(1)(f) GDPR; iii) BiH: Article 8(1)(f) of the LPPD BiH): your IP address, geographical location, information about your device, browser type, source from which you accessed the website, duration of your visit, operating system, number of page views, pages viewed, and similar information. For more information about cookies, please see Article 13 below;

 

• To send promotional messages regarding our activities and the activities of affiliated legal entities that are part of the Comtrade Group, including invitations to other events (your consent pursuant to: i) Serbia: Article 12(1)(1) of the LPDP RS; ii) Slovenia: Article 6(1)(a) GDPR; iii) BiH: Article 8(1)(a) of the LPPD BiH): first and last name; address; email address; telephone number;

 

• To provide you with information that you request from us when you contact us, complete a contact form on our Website, or contact us via email (legitimate interest pursuant to: i) Serbia: Article 12(1)(6) of the LPDP RS; ii) Slovenia: Article 6(1)(f) GDPR; iii) BiH: Article 8(1)(f) of the LPPD BiH): first and last name, address, email address, telephone number, and other relevant information that you provide to us directly or through the contact form used to contact us;

 

• For the recruitment of new employees (your consent pursuant to: i) Serbia: Article 12(1)(1) of the LPDP RS; ii) Slovenia: Article 6(1)(a) GDPR; iii) BiH: Article 8(1)(a) of the LPPD BiH): first and last name; address; email address; telephone number; information about your education (secondary school, university, grade point average); year of study (current year) and status of study obligations; scholarship information; your knowledge and experience; your areas of interest and professional interests; CV/resumé.

 

5. PROCESSING OF PERSONAL DATA OF DATA SUBJECTS UNDER 15 YEARS OF AGE

 

Except in those cases where controllers organizes educational events specifically designed for children, we do not intentionally collect the personal data of individuals under 15 years of age. If you are under 15 years of age please do not send us your personal data e.g. your name, address and email address. If you wish to contact the controllers in a way that requires you to submit your personal data (such as for education or similar events) please get your parent, exercising parental rights, or your legal guardian to do so on your behalf.

 

6. DISCLOSURE OF PERSONAL DATA

 

We may disclose your personal data to the following subjects:

• our affiliated companies;
• our business partners;
• contractual data processors (suppliers, service providers, consultants etc.), who might process personal data in our name in accordance with our written instructions and for the purposes as stated above;
• to other recipients, if obliged to do so subject to a court order or order issued by other governement authority or valid law.

 

 

 

7. TRANSFERS OF PERSONAL DATA TO OTHER COUNTRIES AND INTERNATIONAL ORGANIZATIONS

 

We may transfer your personal data to the recipients in third countries or international organisations, located outside of the Republic of Serbia, the EU/EEA or BiH, to our affiliated companies and contractual data processors. Such transfers take place under the safeguard measures as defined in LPDP RS, GDPR and LPPD BiH, depending on the country where you reside.

 

Transfer of personal data to recipients located outside of the named countries („Third countries“), i.e. to our affiliated companies and contractual data processors takes place using the following security measures:

1. Serbia:

• transfer of personal data without prior authorization based on adequate level of personal data protection
• to a Third country, part of its territory or one or more economic sectors in those countries or international organisations can be carried out if it has been determined that said country, part of its territory or one or more economic sectors in those countries and international organisations ensures an adequate level of protection of personal data.

It is considered that an adequate level of protection is provided in the countries and international organizations that have signed the Council of Europe Convention on the Protection of individuals with regard to the automatic processing of personal data and countries, parts of their territories or one or more economic sectors in those countries and international organisations that have been determined by the European Union to provide an adequate level of protection of personal data.

• to another country, to a part of its territory or to one or more economic sectors in those countries and international organisations for which the existence of an adequate level of protection of personal data has not been determined as described above, we will do everything to ensure that your personal data will receive an appropriate level of protection, which includes the use of Standard Contractual Clauses adopted and issued by the Commissioner for Information of Public Importance and Personal Data Protection. The aforementioned clauses and are available in Serbian language at the following link: Oдлукa о утврђивању стандардних уговорних клаузула („Службени гласник РС“, број 5/2020) – Повереник за информације од јавног значаја и заштиту података о личности.

 

• In other cases, we may transfer your personal data to Third countries based on your explicit consent.

 

1. EU/EEA:

• the European Commission has decided, on the basis of Article 45 of GDPR, that the country outside the EU, Third country, in question ensures an adequate level of data protection (European Commission adopted Adequacy decisions);

 

• the European Commission has decided that commercial organisations from the United States, which participate in the EU-US Data Privacy Framework, ensure an adequate level of data protection;

 

• the European Commission has not decided, due to the local legislation of such country or international obligations it has concluded, that such a country ensures an adequate level of protection of personal data. In such cases, we will do everything to ensure that your personal data will receive an appropriate level of protection, which includes the use of Standard contractual clauses for the transfer of personal data outside the EU/EEA, approved by the European Commission for transfer to countries that are not determined as countries that provide an adequate level of protection of personal data, Third countries. Standard contractual clauses are available in various languages on the following link: Publications on the Standard Contractual Clauses (SCCs) – European Commission.

 

• in other cases, we may transfer your personal data to Third countries based on your explicit consent.

 

• BiH:

• transfer of personal data without prior authorization based on adequate level of personal data protection:
• to another country, part of its territory or one or more economic sectors in those countries or international organisations can be carried out if it has been determined that said country, part of its territory or one or more economic sectors in those countries and international organisations ensures an adequate level of protection of personal data.

It is considered that an adequate level of protection is provided in the countries, parts of their territories or one or more economic sectors in those countries and international organisations that have been determined by the European Union to provide an adequate level of protection of personal data.

• to a Third country, to a part of its territory or to one or more economic sectors in those countries and international organisations for which the existence of an adequate level of protection of personal data has not been determined as described above, we are obligated to ensure that your personal data will receive an appropriate level of protection which includes also the protection of enforceable rights and effective judicial protection.

 

• In other cases, we may transfer your personal data to third countries based on your explicit consent.

 

For more information regarding the use of the Standard contractual clauses as detailed in this paragraph you may contact us by sending email to dpo@comtrade.com.

 

8. LINKS TO OTHER WEBSITES

 

Our Website may contain links to third parties websites. We disclaim any control over, relationship with, or endorsement of these sites and shall not be liable for data protection while visiting such websites. Links to other websites are provided only as a convenience and we encourage you to read these third-party websites’ Terms of Use and Privacy Policies.

 

Such websites may be:

The social media platforms such as LinkedIn, Facebook, Instagram, Youtube,  etc. LinkedIn, Facebook, Instagram, Youtube and others are independent personal data controllers and will process your personal data following their privacy policies, such as:

 

LinkedIn Privacy Policy

Meta | Privacy Center | Manage your privacy on Facebook, Instagram and Messenger | Facebook Privacy

Privacy Policy – Privacy & Terms – Google

 

Google, who is an independent personal data controller and services provider (ex. Google Maps, Google Analytics), processes your personal data following their own privacy policy: Privacy Policy – Privacy & Terms – Google.

 

9. RETENTION PERIOD

 

We retain your personal data to the extent reasonably necessary to fulfil the purposes for which we collected or obtained them or to comply with legal requirements/obligations.

 

Where your consent is the legal basis for the processing of your personal data, we shall keep your personal data until you withdraw your consent.

 

10. PROTECTION AND SECURITY

 

We take precautions to protect your personal data from loss, misuse, unauthorised access, disclosure, alteration and destruction. We have taken appropriate technical and organisational measures to protect the information systems on which we store your personal data and we require our data processors to protect your personal data by contractual means.

 

11. YOUR RIGHTS

 

Subject to certain exceptions and restrictions set out in applicable legislation, you may exercise the following rights:

1. Right of access to your personal data (in compliance with i) Serbia: Article 26 of LPDP RS; ii) Slovenia: Article 15 of GDPR; iii) BiH: Article 17 of the LPPD BiH),
2. Right to rectification and supplementation of your personal data (in compliance with i) Serbia: Article 29 of LPDP RS; ii) Slovenia: Article 16 of GDPR; iii) BiH: Article 18 of the LPPD BiH),
3. Right to erasure of your personal data (the right to be forgotten) (in compliance with i) Article 30 of LPDP of RS; ii) Slovenia: Article 17 of GDPR; iii) BiH: Article 19 of the LPPD BiH),
4. Right to restriction of processing of your personal data (in compliance with i) Article 31 of LPDP of RS; ii) Slovenia: Article 18 of GDPR; iii) BiH: Article 20 of the LPPD BiH),

5. The right to data portability (in compliance with i) Article 36 of LPDP of RS; ii) Slovenia: Article 20 of GDPR; iii) BiH: Article 22 of the LPPD BiH),
6. Right to object to the processing of your personal data (in compliance with i) Article 37 of LPDP of RS; ii) Slovenia: Article 21 of GDPR; iii) BiH: Article 23 of the LPPD BiH),
7. Right to withdraw your consent to the processing of your personal data (in compliance with i) Article 15 of LPDP of RS; ii) Slovenia: Article 7(3) of GDPR; iii) BiH: Article 9(3) of the LPPD BiH),
8. Right not be subject to a decision based solely on automated processing, including profiling, which produces legal effects for you or affects you significantly (in compliance with i) Article 38 of LPDP of RS; ii) Slovenia: Article 22 of GDPR; iii) BiH: Article 24(1) of the LPPD BiH),
9. Right to lodge a complaint with the Commissioner for information of public importance and personal data protection regarding personal data processing (in compliance with i) Article 82 of LPDP of RS; ii) Slovenia: Article 77 of GDPR; iii) BiH: Article 108 of the LPPD BiH).

 

You can file a complaint or make a request regarding the processing of your personal data by sending  email to dpo@comtrade.com.

 

You can also lodge a complaint with the competent supervisory authority:

Competent supervisory authority in Serbia: Poverenik za informacije od javnog značaja i zaštitu podataka o ličnosti, Bulevar kralja Aleksandra 15, 11120 Beograd, Serbia, phone: +38111 3408 900, email: office@poverenik.rs

Competent supervisory authority in Slovenia: Informacijski pooblaščenec, Dunajska cesta 22, 1000 Ljubljana,  Slovenia, phone: 00386 1 230 97 30, e-mail: gp.ip@ip-rs.si

Competent supervisory authority in BiH: Agencija za zaštitu ličnih podataka u Bosni i Hercegovini, Dubrovačka br. 6, 71000 Sarajevo, Bosnia and Herzegovina, phone: +387 33 726 250, email: azlpinfo@azlp.ba

 

12. COOKIES 

 

We use cookies and similar technologies to ensure that you get the most out of our Website. We may also use cookies to collect information about how you use our Website and your online behavior. The types of data that we collect in this way may include your previous destination, the type of browser, the operating system, the browser (search engine) used, as well as the duration of your visit to the Website. For more information on how we use cookies and similar technologies and how you can control them, please see our Cookie Policy published at the bottom of the Website.

 

For more information on how to disable email tracking, please check out the following links:

https://www.wikihow.com/Stop-Email-Tracking

https://nordvpn.com/blog/how-to-block-email-tracking/;

https://www.hongkiat.com/blog/detect-disable-email-tracking/

or to the documentation within your e-mail application (if you use it) or your e-mail service provider (if you use an Internet browser to read e-mail).

 

13. CHANGES TO THIS PRIVACY POLICY 

 

We may update our Privacy Policy from time to time. An updated Privacy Policy will be posted on the relevant websites or will be provided to you upon request.

 

 

 

July 2026