Introductory provisions

With these Privacy Rules for B2 HOLDING KAPITAL d.o.o. job candidates (hereinafter: “Rules”), B2 HOLDING KAPITAL d.o.o. (hereinafter: “Company”) explains in detail the way in which the job candidates’ (hereinafter: “Candidate”, “Person”/”Persons”) personal data is processed in accordance with the Personal Data Protection Act (“Serbian Official Gazette” b87/2018) (hereinafter: “PDPA)” and other bylaws.

With these Rules, the Company provides information about the data controller, data protection officer, data collected and processed by the Company, the purpose and legal grounds of processing, recipients of personal data, storage period of your personal data, data protection as well as the rights of the data subjects related to such data.
These Rules shall apply as of the effective date of the PDPA.

Who is responsible for the processing of your personal data and who can you contact?

The entity responsible for data processing is:
B2 HOLDING KAPITAL d.o.o. Beograd-Novi Beograd
Vladimira Popovića 6, 11000 Belgrade
Phone: +381 (11) 4409601

Regarding the processing of your personal data, you can contact the Personal Data Protection Officer:

Personal data we collect and process

These Rules apply to the candidates’ personal data the Company collects in the course of recruitment, which it has received through an open job vacancy advertisement and/or open recruitment advertisement, either in person and/or through the Company’s official website and/or by mail and/or e-mail. This includes, but is not limited to, the following data:

  • First and last name, contact details (phone number, e-mail, mobile phone number), permanent/temporary residence address (street, city, postal code);
  • The information provided in the résumé (e.g. previous occupations, education and qualifications, skills and personal interests, foreign languages, driving license, other activities);
  • Work experience (position, duration of employment and name of employer);
  • Any previous applications for vacancies in the Company and positions applied for;
  • Information about the current employment status, notice period and earliest possible start of employment;
  • The desired monthly net earnings in dinars.

During the screening procedure we can invite you for interviews, ask you to complete certain tests and questionnaires.

If required by a particular law, the Company shall process your data from criminal and/or misdemeanors records. The Company collects the above information directly from the candidates. To this end, the Company may require the candidate to submit the appropriate document (e.g. a police clearance certificate, a certificate of no pending misdemeanor proceeding).

Purpose of and legal grounds for personal data processing

We process the personal data referred to in clause 3 of the Rules to select the most appropriate candidate for our team in the screening process, which includes:

  • assessment of employment qualifications and the making of employment decisions;
  • evaluation of the candidate for any other vacancies;
  • reference checks and/or background checks (where applicable);
  • notifying the candidates about the progress of the recruitment process by phone, e-mail, SMS or otherwise;
  • protection of the Company’s rights and fulfillment of legal obligations;
  • contacting candidates listed in the candidate database by phone, e-mail, SMS or otherwise about the vacancies we consider suitable for the candidate.

In case this leads to employment with us, we process your personal data to the extent necessary for this purpose, as well as to outline employment-related rights and obligations, as explained in B2 HOLDING KAPITAL d.o.o. Privacy Rules for workers hired under employment agreements, students employed through licensed student and youth employment agencies, persons undergoing professional training with no employment status, and those who have made copyright or work-for-hire agreements with us.

Legal grounds for personal data processing:

  • So that the Company can take steps at the request of the Person prior to the execution of agreement (Article 12, paragraph 1, point 2) of the PDPA);
  • Based on the consent of Persons submitting an open job application (Article 12, paragraph 1, point 1) of the PDPA). Based on such consent, the Company stores personal data for contact purposes for potential future vacancies.

The candidate may withdraw the consent at any time. The withdrawal of consent does not affect the lawfulness of the consent-based processing carried out before consent withdrawal.

Consent may be withdrawn in the same manner as it was given. This right applies to the withdrawal of the consent given prior to the effective date of the PDPA, i.e. prior to August 21, 2018.

During the recruitment process, the Company does not ask for or collect particular categories of personal data such as racial or ethnic origin, political, religious or philosophical beliefs, union membership, medical, sexual life, or sexual orientation data.

Who has access to your personal data and who we provide your data to

  • Inside the Company

Inside the Company, the access to your personal data is available to the departments involved in the screening process (e.g. HR department, department which advertised the vacancy, etc.).

  • Outside the Company

For certain positions of interest to the Company, the Company also supplies (transmits) your data to its affiliates (e.g. B2HOLDING ASA, and other B2HOLDING Group members). When transmitting the data, the Company takes particular care to protect your personal data during such transmission. The Company pays special attention to the transmission of data to affiliates and third-country group members within the meaning of the PDPA, that is, to the transmission to affiliates and the companies in non-members of the European Union or non-members of the European Economic Area.

Data transmission is based on an agreement that contains standard EU contractual clauses on compliance with data protection rules.

How we protect your data

The protection of your personal data is extremely important to us. The following are some of the protection mechanisms we implement:

  • Introduction of technical and organizational measures necessary to ensure that the processing of personal data is carried out securely;
  • Control of physical and logical access to the Company’s information system and premises;
  • Introduction of technical and procedural measures necessary to implement the IT infrastructure in accordance with the highest international security standards;
  • Implementation of electronic and procedural safeguards related to the collection, storage and disclosure of personal data.

How long is personal data stored?

If the event you do not get a job with us, we store your personal data for 6 months following the application deadline and we delete it afterwards.

If you have consented to the storage of your personal data for the purpose of any future vacancies which would suit your qualifications and interests, the Company will store your personal data in its database for a period of 24 months

Your rights

  • right of access to information (under Article 26 of PDPA)

You have the right to request confirmation about whether we are processing your personal data as well as access to your personal data processed by us. You can also exercise these rights by completing the appropriate Request (hereinafter: Request).

  • right to rectification and supplementation (under Article 29 of PDPA)

You have the right to ask for your personal data to be rectified or supplemented by filing a Request. We will respond to your request as soon as possible, without undue delay.

  • right to erasure (under Article 30 of PDPA)

You have the right to ask us to erase your personal data if: (1) it is no longer necessary for the purposes for which it was collected or otherwise processed; (2) you withdraw the consent on which the processing is based and there are no other grounds for processing; (3) you object to the processing and there is no overriding legitimate processing interest; (4) the data has been processed unlawfully; (5) the data must be erased in order for the Company to fulfill its legal obligations.

  • right to restriction of processing (under Article 31 of the PDPA)

You have the right to request us not to erase your personal data but continue its limited processing (subject to the restrictions you specify) if you need this in order to exercise your other rights.

  • right to data portability (under Article 36 of PDPA)

You have the right to ask us to transmit your data. You can exercise this right by completing the Request. The request must state the categories of personal data, interest as well as the time period your request applies to.

  • right to object (under Article 37 of PDPA)

The data subject has the right to object at any time to the processing of his/her personal data.

  • right to complain to the Commissioner and right to legal protection (under Articles 82-84 of PDPA)

You have the right at any time to file a complaint with the Commissioner for Information of Public Importance and Personal Data Protection (, as well as to obtain protection through other administrative or court proceedings regarding the protection of your personal data.

Instructions regarding the exercise of your rights in relation to the Company

We will reply to your request as soon as possible, but no later than 30 days of the date of receipt of a valid Request.

In the case of a large number of Requests and the complexity of your inquiry, we may need additional time to reply. In that case, we will notify you in a timely manner and you will receive our reply within additional 60 calendar days.

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