This Privacy Policy regulates the purpose and manner of processing personal data that Questionmark d.o.o. Belgrade, as the data controller, collects from users of the website: www.questionmark.rs (hereinafter: the Website). Please read the provisions of this Privacy Policy carefully to familiarize yourself with all important information regarding the processing of personal data, their protection, and the rights to which users are entitled in accordance with the Law on Personal Data Protection (“Official Gazette of RS”, No. 87/2018, hereinafter: LPDP).

This Privacy Policy applies to the Website and all digital marketing channels associated with it.

Definitions

In accordance with the LPDP, the following terms have the following meanings:

“Personal data” (hereinafter: personal data) means any information relating to a natural person whose identity is identified or can be identified, directly or indirectly, in particular based on an identifier such as a name and identification number, location data, an identifier in electronic communication networks, or one or more characteristics of their physical, physiological, genetic, mental, economic, cultural, or social identity.

“processing of personal data” means any operation or set of operations performed, whether automated or not, on personal data or on sets of personal data, such as collecting, recording, organizing, structuring, storing, adapting or altering, retrieving, using, disclosing by transmission or making available, duplicating, disseminating, or otherwise making accessible, comparing, restricting, erasing, or destroying;

“controller” means a natural or legal person, or a public authority, which alone or jointly with others determines the purposes and means of the processing;

“processor” means a natural or legal person, or a public authority, which processes personal data on behalf of the controller.

Controller

The controller is responsible for the processing of the personal data of the website users (hereinafter: users) as follows:

Questionmark doo Belgrade

Belgrade, Venizelosova no. 33E, local 9

TIN 103570575, registration number 17574396

Email: info@questionmark.rs (hereinafter: Questionmark or us).

Types of Data and Methods of Processing

We manage the processing of those personal data that users provide when visiting the website. Depending on the intended purpose of the processing, the types of personal data we process include the following: first and last name, e-mail address, phone number, residential address information (city, postal code, street, and number), account number, gender, date of birth, and data related to purchases (payments, purchased products, orders, product returns, etc.).

As a rule, we collect only those data that users voluntarily provide and that are necessary to achieve the purpose of the specific processing.

An exception may be data collected through “cookies” and other tracking technologies, as further explained in the Cookie Notice.

Purpose of Data Processing

Questionmark collects and processes personal data for the following purposes:

  • managing the accounts of registered website users;
  • sending newsletters and periodic e-mails to users who have expressed their consent to receive them, regarding topics of their interest;
  • executing purchase agreements;
  • handling customer requests (for: product exchanges, withdrawal from purchase agreements, complaints);
  • personalizing the user experience;
  • improving the website – adapting its content to the needs of users;
  • carrying out promotions, competitions, surveys, or other activities within the website;
  • addressing user inquiries, questions, and/or other requests; and
  • enhancing our services.

A user who provides Questionmark with personal data of third parties guarantees that such third parties are aware that their personal data will be processed and have consented to the purpose and manner of such processing.

Legal Basis for Processing Personal Data

Depending on the purpose of collection and processing, the legal basis for processing users’ personal data may be their consent, the performance of a contract or requested service, compliance with legal obligations requiring the processing of personal data, and the legitimate (justified) interests of Questionmark (processing such as managing and maintaining contractual relationships, responding to specific requests, seeking user feedback to improve the website and products, as well as carrying out other general marketing activities), except where the interests, fundamental rights, and freedoms of the user, or the interests and fundamental rights and freedoms of the data subject, which require the protection of personal data, prevail—particularly if the data subject is a minor.

The legitimate interest of Questionmark covers cases of collection and processing that users interested in Questionmark products can reasonably expect in the normal course of business, as well as instances where processing is necessary without explicit user consent. Questionmark will always seek to obtain user consent for personal data processing and will rely on legitimate interest only when necessary and in the user’s interest.

Personal data such as first and last name and e-mail address collected when creating user accounts on the website are processed based on user consent and the legitimate interest of Questionmark. When creating an account on the website, processing user data is necessary to manage their registration. In this context, relying on its legitimate interest, Questionmark may process users’ personal data, considering that by registering or using the website, the user has expressed interest in further offers and may therefore retain a list of products the user has shown interest in or purchased.

When creating user accounts on the website, Questionmark also requests the user’s consent to send newsletters (periodic e-mails).

Data such as first and last name, e-mail address, phone number, residential address (country, city, street, and number), and account number that we collect for the following purposes—performance of purchase agreements for products bought through the website (in this case, the account number is not collected), processing withdrawal from purchase agreements, product exchanges, and resolving complaints on purchased products—are processed by Questionmark based on applicable laws to fulfill its legal obligations.

Questionmark may retain the data of a user who has withdrawn consent solely for the purpose of proving that processing before the withdrawal of consent was carried out in accordance with the law.

Retention Period of Personal Data

Questionmark stores and retains users’ personal data only for as long as necessary to achieve the purpose of the specific processing, namely:

  • Personal data processed for managing a user’s website account are retained for the entire period the user is registered on the website;
  • Personal data processed for sending newsletters, reminders, or direct advertising by Questionmark are retained until the user unsubscribes or withdraws their consent;
  • Personal data processed for the purpose of executing a purchase agreement for products bought by the user are retained as long as necessary to complete the sale, including the time needed to handle requests for withdrawal from the purchase agreement or product exchanges, except in cases where the user explicitly requests that the data be deleted before the expiration of these periods, in which case the data will be pseudonymized;
  • Personal data processed for handling declared complaints are retained as long as necessary to resolve the complaint;
  • Personal data provided by the user when contacting Questionmark (questions/requests) are retained for the time needed to process the inquiry or until the user requests their deletion; and
  • Personal data collected via cookies are retained as long as they serve their purpose.

Questionmark may also retain users’ personal data beyond the above retention periods for the following purposes: fulfilling legal obligations or protecting Questionmark’s rights (before courts or other competent authorities), in accordance with applicable regulations, or for collecting statistical data and record-keeping.

Questionmark will delete or pseudonymize all personal data of users that are no longer used for any of the lawful processing purposes listed above from its storage systems.

Who Has Access to Personal Data

Depending on the purpose of processing users’ personal data under this policy, and to the extent necessary for achieving that purpose, users’ personal data are accessible to Questionmark employees, its freelance collaborators, franchise partners, and trusted third parties that provide services to Questionmark related to its business activities, such as:

  • marketing agencies;
  • IT agencies or persons providing assistance to Questionmark in the form of platform services, server hosting, database support and maintenance, as well as software and applications; and
  • persons providing product delivery services to Questionmark (postal or courier services).

All such recipients are obliged to align their operations with applicable data protection laws (ZZPL) and to take all necessary technical, organizational, and personnel measures to protect users’ personal data. In cases where Questionmark is the controller of personal data, and processing is carried out on its behalf by a third party as a processor, the parties are required to conclude a contract or another document regulating all essential aspects of personal data processing. The protection of users’ personal data by these third parties must be at the same level as the protection provided by Questionmark.

Users’ personal data may also be disclosed to state authorities when Questionmark is legally obliged to do so or in order to protect its own rights and interests, as well as the rights of users as customers.

Data Controlled by Third Parties

The website may contain links to other websites, as well as objects or elements controlled by third parties.

An example is “plug-ins” that can connect the website to social networks such as Instagram, usually recognizable by the logo of the corresponding social network. By selecting the social network logo on our website, you may initiate the process of sending certain data, such as user ID, website information, date and time of the website visit, and other browser-related information, to the respective social network. Such information will be processed by the social networks, whose owners and operators are third parties, in accordance with their privacy policies.

Questionmark does not have access to or control over the elements, objects, cookies, or other tracking technologies managed by third parties. For their own security, users should familiarize themselves with the privacy policy of the third-party website they access from our website in order to understand the terms applicable to the specific processing of personal data, bearing in mind that this policy applies solely to the Questionmark website.

Use of Cookies

Questionmark uses cookies during every interaction a user has with the website.

Cookies are text files stored on the user’s device (computer and/or phone) that are created during a visit to the website. When a user revisits the website, Questionmark retrieves data from the user’s device contained in these cookies.

Questionmark uses cookies to collect data necessary for improving the website, as well as for services that utilize cookies. These cookies aim to enhance the website so that users can more easily access and use its content, as well as for marketing purposes.

For example, during a visit to the website to browse, read, or download information, we collect and store certain data from users, such as: the domain name and computer from which the internet is accessed, the IP address of the computer used, the date and time of access to the website, the internet addresses of pages through which users access the website, and other similar information.

Cookies enable a better, more accessible, and personalized user experience, as well as optimized website display. Questionmark can also use them to analyze customers, monitor visits, and improve its advertising.

By disabling cookies, users decide whether to allow their storage on their device. Users can adjust cookie settings via their internet browser or by selecting the appropriate option when visiting the website.

For more information about cookies, see the Cookie Notice.

Users’ Rights Regarding Personal Data

Questionmark is committed to keeping users’ personal data confidential and enabling them to exercise the rights they are entitled to under applicable data protection laws (ZZPL).

Users have the following rights in relation to the processing of their personal data:

  • Right of Access: Users have the right to obtain clear, transparent, and easily understandable information about the purpose of processing, the types of personal data being processed, the recipient or categories of recipients to whom personal data have been or will be disclosed, the intended retention period, and the right to request a copy of the personal data being processed.
  • Right to Rectification and/or Completion: Users have the right to request the correction of personal data if it is inaccurate or invalid and/or its completion if it is incomplete.
  • Right to Erasure: Users have the right to request that their personal data be deleted to the extent that the data are no longer necessary for the purposes of processing or if Questionmark is no longer legally permitted to process them.
  • Right to Object and Complain: Users have the right to object to the manner of processing their personal data, which can be submitted directly to Questionmark, or to lodge a complaint with the Commissioner for Information of Public Importance and Personal Data Protection.
  • Right to Restriction of Processing: Users have the right at any time to request a restriction on the processing of their personal data.
  • Right to Withdraw Consent: Users have the right to withdraw consent for the processing of personal data based on consent at any time.
  • Right to Data Portability: Users have the right to receive their personal data from Questionmark’s database for transfer to another database.

To exercise the above rights (except for lodging a complaint with the Commissioner), users can do so in the following ways: by completing and submitting the Request to Exercise Rights Regarding Personal Data form by sending a request using the prescribed form via e-mail to info@questionmark.rs, at the Questionmark store located at Beograd, ul. Venizelosova 33e, local 9, or by mail to Questionmark d.o.o. Beograd, ul. Venizelosova 33e, local 9.

In addition, users can stop receiving newsletters by selecting the “unsubscribe” option included in every message they receive, or by sending an e-mail to info@questionmark.rs, after which Questionmark will no longer send messages of this nature or process their personal data on this basis.

Changes to the Privacy Policy

Questionmark reserves the right to modify the Privacy Policy, with the date of the change indicated at the end of the Policy. Users will not be notified directly about changes. To stay informed about the protection of their personal data and to remain aware of possible updates, it is recommended that users periodically visit this page and review the Privacy Policy. If a user continues to use the website after such changes, it is considered that they have accepted and agreed to them.

Acceptance of Terms

It is in the user’s interest to read the Privacy Policy when accessing the website. By using the website, the user is deemed to have agreed to the terms of this Policy. Otherwise, the user should not access the website.

Final Provisions

This Privacy Policy aims to provide all necessary information to allow you to give or withhold consent for the processing of your personal data as described above.

If you have any questions regarding the protection of your personal data, how we process your personal data, or how we use it, or if you wish to exercise the rights described above, please contact us via e-mail at info@questionmark.rs or at the registered office of Questionmark: Beograd, ul. Venizelosova 33e, local 9.

The person responsible for personal data protection is Katarina Jovanović.

Your Questionmark

01.10.2025.