1. Introductory Clauses
This Privacy policy refers to the site Complementary Training (hereinafter referred to as: „Site“) owned by Athlete Software Solutions d.o.o. Beograd-Stari Grad, a company based in the Republic of Serbia (hereinafter referred to as: „Service Provider“ or “we”) that acts as the data controller.
Service Provider recognizes that the Service Provider’s Users who use the Site and the services available at the Site value their privacy and require a high level of protection regarding the ownership and the safety of their information on the Site. This Privacy Policy is to help the User to make an informed decision about whether to use or continue using the Site.
This Privacy Policy is also incorporated into and is subject to the Service Provider’s Terms of Use (hereinafter referred to as: „Terms“). Definitions provided in the Terms apply to this Privacy Policy, as the case may be.
2. Details of the Controller
The data controller is Athlete Software Solutions d.o.o. Beograd-Stari Grad, Marsala Birjuzova 32, Belgrade, Serbia, corporate number: 21269832.
Contact email for data protection issues is: office@athletess.com
3. Purpose of Processing, Source of Data and Legal Basis
The personal data of the Users are mainly collected to provide our services as the Service Provider. The processing of data for other purposes is described below. Therefore, the legal basis for us as the data controller for this purpose is the performance of a contract with the User as a data subject.
Depending on the type of service, we collect different types of data.
If you are a User who purchased a tool or a book, we shall collect billing and other information necessary to provide you with the purchased product and make the payment transaction. You can provide us with contact details such are address and phone number in case we need to contact you in relation to the provision of this service.
If you purchase a course from the Site or wish to become a Complementary Training member, you need to make a registration, and for this purpose, we also process your account registration data.
Once you are a registered User, we process various data within your User profile, depending on your use of the Site and its functionalities. You are in control with respect to how you will set up your User profile (general information, photos, work experience, biography, etc.) and which account functionalities you will use (connecting to other Users, participation in the groups, forums, etc.).
Site visitors can also voluntarily subscribe to our newsletter, for which purpose we must process an email address, while you can also provide us with your name. You can unsubscribe at any time.
We also use email address you provided in the course of provision of our service to send you occasional promotional emails, if we assume you may be interested in that sort of information. We deem to have a legitimate interest to do so, but you can also opt out by unsubscribing at any time. Of course, we do not share these emails with anyone outside our organisation.
Other Site visitors’ data may be processed via use of the cookies, as is further explained in below Section 10.
4. Correcting/updating, Downloading or Removing Information
Users may modify or remove most of the personal information they provided by logging into their accounts and editing the account and profile data they have access to.
You also have the option to export your data via the available account setting or to delete your account.
5. Deletion
User’s personal data collected in the course of the provision of services by the Service Provider, as well as other personal data processed in the course of contract performance, will be permanently deleted by the Service Provider after the expiry of the relevant statutes of limitation, even if you delete your account via the available account settings. In principle, we will delete any inactive accounts within 10 years from the last log-in.
In cases where personal data are processed based on your consent, such data will be deleted immediately after the respective consent is withdrawn.
6. Sharing and Disclosure
Except as otherwise described in this Privacy Policy, the Service Provider will not disclose personal data to any third party unless we are required to do so by applicable law, or have been required by or authorized to do so with consent by the User.
Since payment transactions for services acquired via the Site are done via PayPal, there is a necessary exchange of data with PayPal Pte. Ltd. and their subsidiaries or affiliates. We distribute our newsletters via Mailchimp. We may also disclose some personal data to our service providers who act as data processors, in accordance with data processing agreement we entered with the in order to provide safeguards and data protection obligations from their part.
Registered users may see each other’s profiles and pertaining information within the Site, while the User also has the option to restrict access to their profile to any other Users i.e. it is possible to use the Site without engagement with other Users. For details, we refer you to account settings and the Terms.
7. International Data Transfers
In principle, we do not transfer personal data anywhere outside Serbia. However, some data transfers may occur because for the provision of our services, we must engage different service providers that have the role of a data processor and that may do business anywhere in the world.
When we engage processors, we do so on the basis of the agreement where the processor undertakes appropriate personal data protection obligations in accordance with applicable laws, in particular with respect to providing sufficient guarantees to implement appropriate technical and organizational measures to safeguard the data.
8. Data Subject Rights
According to the applicable data protection laws, any person whose personal data are processed by the Service Provider in its capacity of data controller can exercise the following rights, depending on their concrete situation: right to information about data processing, right to get access/copy of their personal data, right to rectification of incorrect data, right to restriction of processing, right to deletion of data, right to data portability and the right to objection.
In order to exercise any of the above-stated rights, you can contact the Service Provider at any time by sending an email to the contact address above.
Data subjects are also entitled to complain about the processing of their personal data by the Service Provider to the Serbian data protection supervisory authority, contact details whereof is available here: https://www.poverenik.rs/en/home.html
9. Automated Decision-making and Profiling
The Service Provider does not perform automated decision-making or profiling based on personal data via the Site.
10. Cookie Policy
Our website uses cookies and other related technologies (for convenience all technologies are referred to as “cookies”). Cookies are also placed by third parties we have engaged. A cookie is a small simple file that is sent along with pages of this website and stored by your browser on the hard drive of your computer or another device. The information stored therein may be returned to our servers or to the servers of the relevant third parties during a subsequent visit.
At this link you can find information about the cookies we use at the Site.
In the document below, we inform you about the use of cookies on our website.
- Technical or functional cookies
Some cookies ensure that certain parts of the website work properly and that your user preferences remain known. By placing functional cookies, we make it easier for you to visit our website. This way, you do not need to repeatedly enter the same information when visiting our website and, for example, the items remain in your shopping cart until you have paid. We may place these cookies without your consent.
- Statistics cookies
We use statistics cookies to optimize the website experience for our users. With these statistics cookies we get insights in the usage of our website. We ask your permission to place statistics cookies.
- Advertising/Marketing/Tracking cookies
On this website we use advertising cookies, enabling us to personalize the advertisements for you, and we (and third parties) gain insights into the campaign results. This happens based on a profile we create based on your click and surfing on and outside http://complementarytraining.com. With these cookies you, as website visitor are linked to a unique ID, so you do not see the same ad more than once for example.
Marketing/Tracking cookies are cookies or any other form of local storage, used to create user profiles to display advertising or to track the user on this website or across several websites for similar marketing purposes. Because these cookies are marked as tracking cookies, we ask your permission to place these.
- Social media
On our website, we have included content from Facebook to promote web pages (e.g. “like”, “pin”) or share (e.g. “tweet”) on social networks like Facebook. This content is embedded with code derived from Facebook and places cookies. This content might store and process certain information for personalized advertising. Please read the privacy statement of these social networks (which can change regularly) to read what they do with your (personal) data which they process using these cookies. The data that is retrieved is anonymized as much as possible. Facebook is located in the United States.
Also, any visitors of the Site are hereby informed that this website uses Google Analytics, a web analytics service provided by Google LLC. On behalf of the Service Provider, Google will use the information generated by the cookie to evaluate your use of the Site, to compile reports on Site activity and to provide us with other services relating to Site and internet use. The information about your use of the Site will be transmitted to and stored by Google on servers, which may be located in different countries. You may refuse the use of these cookies by selecting the appropriate settings on your browser. However please note that if you do this you may not be able to use the Site’s full functionality. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the Site (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available under this link.
- Consent
When you visit our website for the first time, we will show you a pop-up with an explanation about cookies. As soon as you click on “Save preferences”, you consent to us using the categories of cookies and plug-ins you selected in the pop-up, as described in this Cookie Policy. You can disable the use of cookies via your browser, but please note that our website may no longer work properly.
- Enabling/disabling and deleting cookies
You can use your internet browser to automatically or manually delete cookies. You can also specify that certain cookies may not be placed. Another option is to change the settings of your internet browser so that you receive a message each time a cookie is placed. For more information about these options, please refer to the instructions in the Help section of your browser.
Please note that our website may not work properly if all cookies are disabled. If you do delete the cookies in your browser, they will be placed again after your consent when you visit our websites again.
11. Privacy Policy Updates
The Service Provider reserve the right to change this Privacy Policy at any time in which case the Service Provider will inform the User via e-mail, where appropriate. The latest version of the Privacy Policy will always be available on the Site.
