Welcome to Silver Bell Group’s Privacy Policy page. We are committed to protecting your privacy and ensuring that your personal information is handled safely and responsibly. Please read the following sections carefully to understand how we collect, use, and protect your personal information.
Welcome to Silver Bell Group’s Privacy Policy page.
Silver Bell Group (“SBG”, “we”, “our” or “us”) is committed to protecting your privacy and ensuring that your personal data is processed lawfully, fairly, transparently, and securely, in accordance with the applicable personal data protection legislation, including the EU General Data Protection Regulation 2016/679 (“GDPR”) and other applicable data protection laws.
This Privacy Notice explains how we collect and use personal data when you visit https://www.silverbellgroup.com/, contact us, request or schedule a consultation, communicate with us as a prospective or existing business contact, apply for a position, or otherwise interact with SBG in circumstances covered by this Policy.
This Privacy Notice provides information about the categories of personal data we process, the purposes and legal bases for processing, the recipients of your personal data, international data transfers, applicable retention periods, your rights as a data subject, and how you can exercise those rights.
Please take a moment to read this Privacy Notice carefully to understand how we collect, use, share, protect, and otherwise process your personal data.
For information regarding the terms and conditions governing the use of our services, please refer to our Terms of Service.
I. OUR CONTACT DATA
SBG processes your personal data in the role of the controller, because it has determined the purpose and means of processing and is responsible for the processing of your personal data. Our contact details are:
Silver Bell Group d.o.o. Beograd
10/7 Kneza Mihaila Street, 11000 Belgrade (Serbia)
Registration No. 21417424
E-mail: marketing@silverbellgroup.com
Contact details of our DPO: dpo@silverbellgroup.com
II. CATEGORIES OF PERSONAL DATA THAT WE PROCESS, PURPOSES OF PROCESSING AND LEGAL GROUNDS
Depending on how you interact with us, we may process different categories of your personal data for the purposes described below.
Purpose | Data typically used | Legal basis |
Receive and respond to inquiries, requests for information and consultation or meeting requests | Identity, business contact, inquiry, communication and meeting data | Pre-contractual steps at your request where you are a prospective contracting party – Art. 12(1)(2) ZZPL / Art. 6(1)(b) GDPR |
Manage proposals, negotiations and business relationships | Identity, business contact, communication and business relationship data | Contract or pre-contractual steps – Art. 12(1)(2) ZZPL / Art. 6(1)(b) GDPR |
Recruit and assess candidates | Identity, contact and recruitment data | Pre-contractual steps at your request – Art. 12(1)(2) ZZPL / Art. 6(1)(b) GDPR |
Use non-essential analytics and advertising technologies | Cookie, device, preference and interaction data | Consent – Art. 12(1)(1) ZZPL / Art. 6(1)(a) GDPR – please see our Cookie Notice |
Send direct marketing and measure interest in our services | Business contact, preference and interaction data | Consent where required – Art. 12(1)(1) ZZPL / Art. 6(1)(a) GDPR; otherwise legitimate interests in promoting relevant B2B services – Art. 12(1)(6) ZZPL / Art. 6(1)(f) GDPR – subject to your right to object and applicable electronic-communications rules |
Operate, maintain and secure the website; diagnose faults; prevent fraud, misuse and cyber incidents | Website, device, security-log and strictly necessary cookie data | Legitimate interests – Art. 12(1)(6) ZZPL / Art. 6(1)(f) GDPR; legal obligation where applicable – Art. 12(1)(3) ZZPL / Art. 6(1)(c) GDPR |
Responding to data subject requests and complaints, complying with requests from competent authorities, and establishing, exercising or defending legal claims | Identification and contact details, information contained in the request or complaint, correspondence, , and other personal data relevant to the particular request, complaint, proceeding or legal claim | Legitimate interests – Art. 12(1)(6) ZZPL / Art. 6(1)(f) GDPR |
Provide an AI-powered chat and voice assistant, respond to enquiries, provide information about our services and facilitate communication with our team | Messages, questions and other content submitted through the chat; voice and audio data and, where applicable, transcripts when the voice function is used; contact and business information voluntarily provided by you; conversation metadata; IP address and device and browser information | Our legitimate interests in responding to enquiries and providing efficient and accessible communication and customer support – Art. 12(1)(6) ZZPL / Art. 6(1)(f) GDPR; taking steps at your request prior to entering into a contract, where applicable – Art. 12(1)(2) ZZPL / Art. 6(1)(b) GDPR |
Depending on how you interact with us, we may collect personal data directly from you (for example, when you contact us through our website or communicate with us) or automatically through your use of our website, including through cookies and similar technologies.
Further information about the cookies and similar technologies used on our website, including their purposes, legal bases, retention periods and your choices, is available in our Cookie Notice.
III. AI-POWERED CHAT AND VOICE ASSISTANT
Our website provides an AI-powered assistant, through which you may communicate with us by text or voice. Before starting the interaction, you will be informed that you are communicating with an artificial intelligence system.
The use of the AI assistant is voluntary, and you may contact us through the other communication channels specified in this Privacy Notice.
When you use the chat function, we process the messages, questions and other content you submit, the responses generated during the conversation, conversation metadata and any personal data you voluntarily provide. If you choose the voice function, your device will request permission to access your microphone, and your voice and audio data will be processed for the purpose of understanding and responding to your request.
The AI assistant is used to provide general information about SBG and its services, respond to enquiries and facilitate communication with the appropriate members of our team. It is not used to make decisions that produce legal effects or similarly significantly affect you. Where necessary, you may request that your enquiry be handled by a member of our team.
Please do not submit special categories of personal data, account credentials, confidential business information or personal data relating to other individuals through the AI assistant unless this is strictly necessary and you are authorized to do so.
IV. OBLIGATION TO PROVIDE PERSONAL DATA
Where you contact us through our website or by other communication channels, the provision of certain personal data is necessary for us to process and respond to your enquiry and, where applicable, to take steps prior to entering into a contractual relationship.
If you choose not to provide the requested information, we may be unable to respond to your enquiry or provide the requested information or services.
V. CONSENT AND WITHDRAWAL OF CONSENT
Where we process your personal data on the basis of your consent, providing such consent is entirely voluntary and is not a legal or contractual requirement, nor a condition for using our website or contacting us.
You may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the consent was withdrawn.
Where we rely on your consent for the use of analytics or marketing cookies, you may withdraw or modify your cookie preferences at any time through our cookie settings. For further information, please refer to our Cookie Notice.
VI. WITH WHOM WE SHARE YOUR PERSONAL DATA (RECIPIENTS OF DATA)
We may share your personal data with carefully selected third parties where this is necessary for the purposes described in this Privacy Notice.
Where third parties process personal data on our behalf, we ensure that they provide appropriate technical and organizational measures to protect your personal data and process it only in accordance with our documented instructions and applicable data protection legislation.
Depending on the nature of the processing, your personal data may be shared with the following categories of recipients:
Recipient | Role | Purpose |
Other members of the SBG group | Processor or independent controller, depending on the purpose of the disclosure and the processing activities performed by the relevant group member in accordance with the Intragroup Sharing Agreement | Internal administration, responding to business enquiries, managing client and business partner relationships, coordinating the provision of services, business development, recruitment and other operational activities within the SBG group |
Website hosting and technical maintenance | Processor | Website hosting, technical maintenance, troubleshooting, security and ensuring the availability and proper functioning of the Website |
Recruitment platforms, applicant tracking systems and recruitment service providers (Zoho) | Processor or independent controller, depending on the provider and the relevant service | Publishing vacancies, receiving and managing applications, communicating with candidates and conducting recruitment activities |
Email hosting and business communication providers (Microsoft) | Processor | Receiving and sending emails, responding to enquiries, arranging meetings and facilitating business communications |
Customer relationship management and sales support platforms | Processor or independent controller, depending on the provider and the relevant service | Recording and managing enquiries, business contacts, communications, meetings and sales activities |
Analytics, advertising and social media platforms | Processor, independent controller or joint controller, depending on the provider and the relevant processing activity | Website analytics, audience measurement, remarketing, displaying and measuring advertisements and evaluating marketing campaigns, subject to the user’s cookie preferences where consent is required |
Professional advisers, including legal, tax, accounting and audit advisers | Independent controller or processor, depending on the nature of the engagement | Provision of professional advice, compliance with legal obligations and establishment, exercise or defence of legal claims |
We may also disclose your personal data where necessary to establish, exercise or defend legal claims, to protect our rights, property or security, or where such disclosure is required by applicable law or a binding request of a competent authority.
VII. TRANSFER OF PERSONAL DATA TO OTHER COUNTRIES
In the course of operating our website and carrying out the processing activities described in this Privacy Notice, personal data relating to individuals in the Republic of Serbia, the European Union and other countries may be made available to members of the SBG group, service providers and other recipients located in countries other than the country in which the relevant data was initially collected or processed.
This may include transfers of personal data outside the Republic of Serbia and, where the processing is subject to the GDPR, transfers of personal data outside the EU, including transfers to the Republic of Serbia.
Where SBG transfers personal data from the Republic of Serbia to another country, the transfer will be carried out in accordance with the requirements of the Serbian Law on Personal Data Protection.
Where the relevant processing or transfer is subject to the GDPR, including where personal data is transferred from the EU to a third country, SBG will also comply with the requirements of Chapter V of the GDPR. Depending on the circumstances, more than one data protection regime may apply to the same processing arrangement.
Before transferring personal data, we assess the destination country, the recipient, the nature of the personal data and the circumstances of the transfer. Where the destination country has not been recognized as providing an adequate level of protection under the applicable data protection legislation, we implement an appropriate transfer mechanism and additional safeguards where required.
Depending on the applicable law and the particular transfer, these safeguards may include: (i) an adequacy decision adopted under the applicable data protection legislation; (ii) the European Commission’s Standard Contractual Clauses, where the transfer is subject to the GDPR; or (iii) another transfer mechanism permitted under the applicable data protection legislation.
Where appropriate, we also apply supplementary technical, organizational and contractual measures intended to ensure that personal data receives a level of protection appropriate to the risks of the transfer.
You may contact us using the details provided in this Privacy Notice to obtain further information about the international transfers relevant to your personal data and the safeguards applied, including information on how to obtain a copy of the relevant safeguards.
VIII. HOW LONG WE RETAIN PERSONAL DATA
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected.
Where we process your personal data for the performance of a contract, we retain such data for the duration of the contractual relationship and thereafter for the period prescribed by the applicable accounting, tax and other legal requirements.
Personal data processed on the basis of your consent will no longer be processed for the relevant purpose following the withdrawal of your consent, unless another legal basis for the processing applies. Withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal.
Personal data relating to enquiries submitted through our website or by other communication channels is retained for as long as necessary to respond to and resolve your request, unless a longer retention period is required for the establishment, exercise or defense of legal claims.
Personal data processed through cookies and similar technologies is retained for the periods specified in our Cookie Notice.
Where personal data is processed for the purpose of protecting our legal rights, preventing misuse or ensuring the security of our website, it may be retained for as long as necessary to establish, exercise or defend legal claims or as otherwise required or permitted by applicable law.
IX. HOW WE PROTECT YOUR PERSONAL DATA
We implement appropriate technical and organizational measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, or any other form of unlawful processing.
These measures include, where appropriate, encryption and pseudonymization, access controls, secure infrastructure, and other security measures designed to safeguard the confidentiality, integrity and availability of personal data.
While we continuously review and improve our security practices, no method of transmission over the Internet or electronic storage can be guaranteed to be completely secure. Accordingly, although we strive to protect your personal data, we cannot guarantee its absolute security.
X. YOUR RIGHTS IN RELATION TO THE PROCESSING OF PERSONAL DATA
Below you will find the rights available to you, insofar as they are applicable to the specific processing activity.
Right of Access | Right to obtain confirmation as to whether we process your personal data and, where that is the case, to access such data and receive additional information about the processing. |
Right to Rectification | Right to request the correction of inaccurate personal data and the completion of incomplete personal data. |
Right to Erasure (“Right to be Forgotten”) | Right to request the erasure of your personal data in the circumstances provided for by applicable law. Please note that this right is not absolute and may be subject to certain legal exceptions. |
Right to Restriction of Processing | Right to request the restriction of the processing of your personal data in the circumstances provided for by applicable law. |
Right to Data Portability | Right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and, where technically feasible, to have that data transmitted directly to another controller, where the processing is based on your consent or on a contract and is carried out by automated means. |
Right to Object
| Right to object to the processing of your personal data where the processing is based on our legitimate interests or for direct marketing purposes. Where required by applicable law, we will cease such processing unless we demonstrate overriding legitimate grounds or the processing is necessary for the establishment, exercise or defence of legal claims. |
We do not carry out automated decision-making, including profiling, that produces legal effects concerning you.
You may submit a request to exercise your rights via email at dpo@silverbellgroup.com, in person at our premises, and/or by mail to the address of our registered seat.
We will respond to your request without undue delay and within the period prescribed by the applicable data protection legislation. Where the Serbian Law on Personal Data Protection applies, we will respond no later than 30 days from receipt of the request. This period may be extended by a further 60 days where necessary, taking into account the complexity and number of requests. Where the GDPR applies, we will respond no later than one month from receipt of the request. This period may be extended by a further two months where necessary, taking into account the complexity and number of requests. We will inform you of any extension and the reasons for it within the initial 30-day or one-month period, as applicable. The exercise of your rights is generally free of charge.
At the same time, you have the right to lodge a complaint at any time with the Commissioner for Information of Public Importance and Personal Data Protection of the Republic of Serbia or with a Supervisory Authority within the European Union, if you believe that the processing of your Personal Data is not carried out in accordance with the applicable Law.
The contact details of the Serbian Commissioner are: Bulevar kralja Aleksandra no. 15, Belgrade, Republic of Serbia, Email: office@poverenik.rs, Telephone: +381 11 3408 900
Contact details of all competent data protection authorities within the European Union are available at the following website: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en
The competent data protection authority in the United Kingdom is the Information Commissioner’s Office (“ICO”), whose contact details are available at: https://ico.org.uk/global/contact-us/
Lodging a complaint with the Commissioner or with a competent data protection authority does not affect your right to seek protection of your rights through appropriate judicial or administrative proceedings.
XI. AMENDMENTS TO THE PRIVACY POLICY
We may update this Privacy Notice from time to time to reflect changes in our processing activities, applicable legal requirements, or our business operations.
The most recent version of this Privacy Notice will always be available on our Website. Where required by applicable law, or where the changes are material, we will provide appropriate notice before such changes take effect.
Effective as of: 01.09.2026
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