Voluntary Pension Fund Management Company Generali, Belgrade (hereinafter: Company) with its registered office at Vladimira Popovića 8, processes your personal data as Data Controller*.
- voluntary pension fund members,
- voluntary pension fund proxy holders,
- beneficiaries, in case of death of a voluntary pension fund member (heir),
- legal representative and beneficial owner of the pension plan organizer or the employer that pays pension contributions for employees,
- our website visitors.
Why the provision of your personal data is required
We process your personal data in order to:
- 1. execute and implement a voluntary pension fund membership contract,
- 2. comply with our legal obligations (e.g. obligations related to the prevention of money laundering and financing of terrorism and implementation of the FATCA regulations),
- 3. assess risks regarding the prevention of money laundering and terrorism financing ;
- 4. provide information about the benefits that the Company provides to members,
- 5. more secure identification when you browse our website,
- 6. respond to your comments, suggestions and questions.
Processing of personal data for the purposes indicated under the point 1 is required in order to execute and implement the voluntary pension fund membership contract.
Processing of personal data for the purposes indicated under the point 2 is necessary to allow the Company to comply with the legal obligations to which it is subject.
Processing of personal data for the purposes indicated under points 3. and 4. is based on the legitimate interest of the Company to increase member satisfaction and provide continuous support, as well as the implementation of the Generali Group Program in order to detect and adequately prevent the possibility of money laundering and terrorism financing.
The processing of personal data for the purposes indicated under the point 5 is based on the Company’s legitimate interest to prevent and identify possible abuses and to enable safe website browsing.
The processing of personal data for the purposes indicated under the point 6 is based on your request to take action for the purpose of execution of a voluntary pension fund membership contract and for the purpose of filing a complaint. In the case of compliments and suggestions regarding the Company’s operations, data processing is based on the Company’s legitimate interest.
Why the provision of your personal data is required
The processing of your personal data is necessary for the execution of the voluntary pension fund membership contract we have entered into with you and for the compliance with our legal obligations.
Failure to provide the requested personal data, or providing partially accurate or incomplete data, makes it impossible for us to comply with our contractual and legal obligations.
We need your personal data to be able to display the website and guarantee its stability and security. You can accept or decline to provide them to us, but without your personal data we cannot provide you with the best user experience possible.
Which personal data we use
For the purposes above indicated, we only process the following personal data:
- Biographical and identification data;
- Contact details;
- Voluntary pension fund membership contract details;
- Bank account number;
- Data on permanent incapacity for work;
- IP addresses - not for collecting personal data, but as browsing data;
- Search data - as aggregate data, for statistical purposes only;
- Cookies and other identification sessions (technical and profile),
- In some cases, we need data on the origin of the funds you deposit under the voluntary pension fund membership contract and information on all the assets.
Personal data is provided by you personally, i.e. the member's legal representatives (parents, guardians), or we receive them through the organizer of the pension plan, the employer that pays pension contributions for its employees.
With whom we share your personal data
Our staff processes your personal data in line with procedures that provide an adequate level of data security and privacy. In this respect, the Company implements the international standard for information security ISO27001 and a number of other technical protection measures.
We can only share your personal data with third parties authorized to process personal data for the above purposes (Generali Group companies, the National Bank of Serbia, Administration for the Prevention of Money Laundering, external auditors, custodian banks, organizations working with telematics, website maintenance and administration needed by the Company).
Our staff and third parties who process your personal data receive explicit instructions on how to conduct the processing
Where we transfer your data
As a general rule, we do not transfer your personal data outside the Republic of Serbia and the countries of the European Union.
In any case, the transfer of your personal data is performed in compliance with the applicable laws and international agreements, implementing suitable safeguards (such as standard contractual clauses, binding business rules, approved codes of conduct, issued certificates, contractual provisions between the Data Controller and Data Processor, approved by the Commissioner).
The rights you can exercise in respect of the processing of your personal data
The rights you can exercise in respect of the processing of your personal data: the right to access, rectify, and erase personal data, the right to restrict data processing, to object, and to transfer the data.
Your right to file a complaint with a competent authority
If you believe that the personal data processing was carried out against the Law on Personal Data Protection, you have the right to file a complaint to the Commissioner for Information of Public Importance and Personal Data Protection* to the address listed on the website https://www.poverenik.rs/sr.
How long we retain your personal data
Your personal data can be retained for different periods of time, depending on the purposes of the processing, in compliance with the applicable privacy laws.
When data processing is performed based on a contract, we are required to retain your personal data for the entire duration of the contractual relationship and for 10 years after the termination of the voluntary pension fund membership contract.
We store data collected based on consent for cookies for 12 months, or until the withdrawal of consent - whichever comes first. The data collected based on legitimate interest is stored until the purpose for which it was collected is fulfilled, i.e. 10 years after the termination of the voluntary pension fund membership contract when it comes to processing for the purpose of money laundering and terrorism financing risk assessment.
Data Protection Officer
The Company has appointed a Data Protection Officer.
If you have any questions about your rights regarding personal data processing, you can contact the Data Protection Officer:
- via Contact Center: 011 222 0 505
- By email at: penzijskifond@generali.rs
- By traditional mail: Generali ad Beograd DUDPF, Vladimira Popovića 8, 11000 Beograd
You can report data breach by filling out the Data Breach Reporting Form at the following email: dpo@generali.rs.
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