Privacy Policy

1. Introduction

This Privacy Policy explains how Društvo sa ograničenom odgovornošću "PELICANOS" Podgorica (Pelicanos d.o.o.), Pera Ćetkovića 95, 81000 Podgorica, Montenegro, Registration No. 5-1347780/001, Tax ID 03799921, as the controller, collects, uses, stores and protects personal data of Partners and Users of the Tereni platform.

We process data on the basis of contract performance, legal obligations, our legitimate interest and, for promotional messages, your consent. The legal basis for each purpose is stated in section 3.

2. Data We Collect

2.1 Personal Data

When you register as a partner or user, we may collect the following data:

• Full name
• Email address
• Phone number
• Address (for partners)
• Company/facility information (for partners)
• Bank details (for partners)
• Invoice and payment data (amount, date, status); we do not process payment card details

2.2 Usage Data

• IP address and location
• Device type and operating system
• Time and duration of platform usage
• Pages and features you use
• Booking and transaction data

3. How We Use Your Data

3.1 Providing the Service (basis: performance of contract)

• Creating and managing your account
• Processing bookings and payments
• Communicating with you about bookings
• Providing customer support
• Personalizing your experience

3.2 Improving the Service (basis: legitimate interest)

• Analyzing platform usage and performance
• Developing new features
• Identifying and resolving technical issues
• Preventing misuse and fraud

3.3 Marketing and Communication (basis: consent)

• Sending news notifications (with your consent)
• Promotional materials about relevant services
• User satisfaction surveys

3.4 Legal Obligations (basis: legal obligation and legitimate interest)

• Compliance with applicable laws and regulations
• Responding to requests from competent authorities
• Protecting our rights and interests

4. Data Sharing

4.1 With Partners

We share necessary information with partners (facility owners) for processing your bookings.

4.2 With Service Providers

• Hosting: DigitalOcean (servers in the Netherlands, European Union)
• SMS verification messages: Twilio (United States)
• Push notifications: Expo (United States)
• Email delivery: email delivery service
• Customer support

4.3 Legal Requirements

We may disclose your data if required by law or in good faith that such action is necessary to:

• Comply with legal obligations
• Protect and defend our rights
• Prevent or investigate possible violations
• Protect the safety of users or the public

5. Data Security

5.1 Technical Protection

• SSL encryption for all communications
• Secure servers with restricted access
• Regular security checks and updates
• Backup systems for data recovery
• Monitoring of unusual activities

5.2 Organizational Measures

• Restricted data access to authorized personnel only
• Employee training on data security
• Contractual obligations with service providers
• Regular audits of security procedures

5.3 Your Responsibility

Please keep your access credentials secure and notify us immediately of any suspicious use of your account.

6. Your Rights

6.1 Right of Access

You have the right to request a copy of all personal data we hold about you.

6.2 Right of Rectification

You may request correction of inaccurate or incomplete data.

6.3 Right of Erasure

In certain cases, you may request deletion of your data ("right to be forgotten").

6.4 Right to Restriction

You may request restriction of processing of your data in certain situations.

6.5 Right to Data Portability

You may request that we send you your data in a structured, readable format.

6.6 Right to Object

You may object to the processing of your data, especially for marketing purposes.

7. Data Retention

We retain your data only for as long as necessary to:

• Provide the service you requested
• Comply with legal obligations
• Resolve disputes
• Prevent misuse

Specifically: account data for as long as the account is active and 12 months after closure; bookings and penalty cards for 24 months from the booking date; invoices and payment records for the period required by accounting and tax law; promotional consent until withdrawn. After that, we securely delete or anonymise the data.

8. International Data Transfer

Data is stored on DigitalOcean servers in the Netherlands (European Union). Twilio and Expo process phone numbers, device identifiers and message content in the United States. When data is transferred outside Montenegro:

• We store data in the European Union, which provides an adequate level of protection
• We have agreements with processors containing appropriate data protection clauses
• We comply with the Montenegrin Law on Personal Data Protection

9. Cookies

9.1 Types of Cookies

• Necessary cookies: For signing in and basic platform functionality
• Analytics cookies: We do not use them
• Marketing cookies: We do not use them
• Consent: If we ever introduce non-essential cookies, we will ask for your consent before setting them

9.2 Managing Cookies

You can control cookies through your browser settings. Please note that disabling cookies may affect platform functionality.

10. Policy Changes

We reserve the right to modify this Privacy Policy. We will notify you of significant changes via:

• Email notifications
• Platform notifications
• Updated versions on our website

We recommend that you regularly check this page for the latest information.

11. Contact for Privacy Questions

12. Supervisory Authority

If you believe we have not respected your right to privacy, you may lodge a complaint with the Agency for Personal Data Protection and Free Access to Information (Agencija za zaštitu ličnih podataka i slobodan pristup informacijama), Podgorica, or with the authority in your country of residence.