Before You Begin…

In this Policy, you will find all the essential information regarding how we use the personal data of our customers and users, regardless of the channel you use to interact with us (online or in person at our physical locations).

We are committed to transparency regarding what we do with your data, ensuring you understand the implications of our processing activities and your rights. This information is permanently available in this Policy, which you can review at any time.

When we refer to our "Platform", we mean any of the following interaction channels:

• Our website.
• Our mobile application.
• Our Telegram bot.
• In-person interaction at our physical stores (where applicable).

1. Who is the controller of your data?

The controller of your data is: PRIME FOOD DOO
Mailing Address: 11183, Serbia, Belgrade, Cara Dusana 166
Data Protection Email: privacy@easyfreezy.rs

We are responsible for the processing and protection of your personal data.

2. For what purposes do we process your personal data?

Depending on how you interact with our Platform, we will process your personal data for the following purposes:

1. Managing your registration as a Platform user If you choose to register, we need to process your data to identify you as a user and grant access to various features and services. You may delete your account at any time by contacting us.
2. Development and execution of the purchase or services contract This purpose includes processing your data to:
   • Contact you regarding updates related to ordered products or services.
   • Manage payment for purchased goods. If you activate the "save card details" feature, we will process this for future purchases with your consent.
   • Activate anti-fraud mechanisms.
   • Manage potential product returns.
3. Processing requests through customer support channels We process only the data strictly necessary to manage your inquiries. Telephone conversations may be recorded for quality control and to address your request.
4. Marketing purposes This includes:
   • Personalizing services and offers based on your profile analysis (purchase and browsing history).
   • If you subscribe to our newsletter, sending personalized information about our products via email or SMS.
   • Displaying internet advertising on websites and social networks, which may be linked to your preferences.
   • Organizing promotional activities (e.g., contests).
   • Publishing your photos on the Platform or our social media with your explicit consent.
5. Usability and quality analysis to improve our services We process your browsing data for analytical and statistical purposes to understand how users interact with our Platform and how we can improve it.

3. What are the legal grounds for processing your data?

1. User Registration Management: Processing is necessary for the performance of the Terms of Use of the Platform. Without this, we cannot register you.
2. Development and Execution of the Purchase Contract: Processing is necessary for the performance of the purchase or services contract with you. Certain processing (e.g., saving card details) is based on your consent. For fraud prevention, we rely on our legitimate interest.
3. Customer Support: We rely on our legitimate interest to respond to your requests. If your request is related to an order, processing is necessary for the performance of the contract. If the request concerns the exercise of your rights, we act under a legal obligation.
4. Marketing: The legal basis is your consent, provided by subscribing to the newsletter, accepting promo terms, or adjusting cookie settings. For personalized information, we rely on our legitimate interest.
5. Usability and Quality Analysis: We rely on our legitimate interest in analyzing Platform performance to improve the user experience.

4. How long will we keep your data?

1. User Registration: We will process your data as long as you remain a registered user (i.e., until you delete your account).
2. Contract Execution: For the time necessary to manage the purchase, including potential returns or claims. Payment data is stored until you choose to delete it.
3. Customer Support: For the time necessary to address your request.
4. Marketing: Until you unsubscribe from the newsletter.
5. Usability and Quality Analysis: We process data periodically during specific campaigns or surveys, or until we anonymize your data.

Upon expiration of these periods, we will store your data in a properly secured manner to comply with legal obligations until the statute of limitations expires. After this, the data will be deleted.

5. Do we share your data with third parties?

To achieve the purposes stated in this Policy, we must provide access to your data to third parties who support us:

• Financial institutions
• Fraud detection and prevention services
• Technology and analytical service providers
• Logistics, transport, and delivery providers
• Customer support service providers
• Marketing and advertising partners (social networks, ad agencies)

Some of these providers may be located outside the European Economic Area (EEA) in countries that do not provide a level of data protection equivalent to the EU. In such cases, we transfer your data with appropriate safeguards, using Standard Contractual Clauses (SCCs) approved by the European Commission. You may review their content via [this link].

6. What are your rights when you provide us with your data?

We are committed to maintaining the confidentiality of your personal data and ensuring you can exercise your rights. You may exercise them free of charge by emailing us at privacy@easyfreezy.rs, stating the reason for your request.

Finally, you have the right to lodge a complaint with the competent data protection authority:

Commissioner for Information of Public Importance and Personal Data Protection of the Republic of Serbia (Poverenik)
Address: Bulevar kralja Aleksandra br. 15, Belgrade.

7. What happens if you provide us with third-party data?

If you provide personal data of third parties (e.g., for a gift certificate), you confirm that you have informed them of the purposes and methods of processing their data.

8. Changes to the Privacy Policy

We may update the information in this Policy. In the event of significant changes, we will notify you via the Platform or email. We recommend reviewing this Policy periodically.

9. Cookie Information

We use cookies and similar technologies to facilitate navigation, analyze your interaction with us, and, in some cases, show advertising based on your browsing habits.

What is a cookie? A small text file that the platform stores on your device. It is essential for facilitating navigation and remembering your preferences.

Types of Cookies:

• By ownership:
  • First-party cookies: Set by our Platform.
  • Third-party cookies: Set by external organizations.
• By purpose:
  • Strictly Necessary (Technical): Essential for site operation (e.g., shopping cart). These are always active.
  • Functional/Personalization: Used to remember preferences (e.g., language or region).
  • Analytical: Help us understand user interaction to improve the site.
  • Advertising: Used to show ads relevant to your interests.

How can I manage cookie usage? You can manage cookie settings at any time via the Cookie Settings Panel on our website. There, you can activate or deactivate all cookies except for strictly necessary ones. You may also change settings in your browser.

Who uses the information stored in cookies? Information from our first-party cookies is used only by us. Information from third-party cookies is used and managed by external organizations to provide us with services. For more info, please review the privacy policies of these third-party services.