The company processes only personal data necessarily necessary for performing the registered activity – consulting in connection with the operation and other management, from its own:
- clients;
- business partners;
- website visitors and social media profiles;
- employees.
The company processes personal data through the following processes:
- collection/recording of personal data in electronic and paper form;
- recording/memorizing personal data in electronic and paper form;
- organizing/structuring/keeping personal data in electronic and paper form;
- inspection of personal data in electronic and paper form;
- use of personal data in electronic and paper form;
- disclosure through transfer of personal data in electronic and paper form;
- copying and duplication of personal data in electronic and paper form;
- analysis of personal data in electronic and paper form;
- archiving of personal data in electronic and paper form;
- destruction of unnecessary personal data in electronic and paper form;
based on:
- written consent of the subject of personal data, which states the purposes of data processing and the volume of data for processing;
- conclusive action (signing of an invoice, power of attorney, contract…) of the subject of personal data, which unequivocally shows a connection with the processing of personal data to which the action refers in the sense of Article 4 paragraph 1 point 11 of the Protection Act personal data (Official Gazette of the Republic of North Macedonia number 42/2020);
- fulfillment of contractual obligations;
The purposes for which personal data are processed are:
- consulting regarding the operation and other management of related entities;
- consulting regarding operations and other management for business associates.
The purposes for which personal data are processed are defined in Article 10 paragraph 1, point 2 and 6 of the Act on the Protection of Personal Data (Official Gazette of the Republic of North Macedonia number 42/2020) as:
- fulfillment of a contract where “the Subject of personal data” is a contracting party, i.e. as:
- fulfillment of legitimate interests of the Controller or of a third party, except when such do not prevail over the interests or fundamental rights and freedoms of the subject of personal data that require the protection of personal data, especially when the subject of personal data is a child.
The subject of personal data has the right to withdraw consent at any time in the same way as originally given or in a simplified form with a written request (including e-mail).
Withdrawal of consent does not affect the lawfulness of the processing, based on the given consent before its withdrawal.
Personal data intended for the collections of related legal entities or business associates are transferred by the Company to them on the basis of an appropriate written agreement in accordance with the law of which the “Personal data subject” is personally informed when providing personal data in a way that clearly results from the consent for this type of personal data processing.
The Company processes personal data received directly from the “Personal Data Subject” or from a person authorized by law to provide personal data to the “Personal Data Subject”.
The company as a “Controller” processes only the necessary personal data of its employees in accordance with the law and this policy for the purpose of exercising their employment rights.
The Company in terms of this policy as a “User” processes personal data of visitors to the Company’s business premises as necessary through the procurement of video surveillance organization services from a third party who is the organizer and administrator of the video surveillance and throughout the performance of the work fulfills the legal assumptions that refer to the “Controller” of personal data, i.e. video surveillance.
The Company does not have access to any of the components of the video surveillance and the corresponding recordings are obtained for the purpose of conducting judicial or disciplinary proceedings in the event of a security or similar incident.
The “subjects of personal data” are informed about the exercise of video surveillance by The “controller” enjoys all rights to protect its personal data in accordance with The Law on Protection of Personal Data and the relevant by-laws.
The procurement and use of video surveillance organization service in terms of this paragraph The company and the third party regulate it with a separate agreement in accordance with the relevant regulations on Personal Data Protection.
Employees and external Associates of the Company are obliged to handle the personal data they process in accordance with their category in the sense of this article.
The company processes personal data in electronic and paper form.
The company for the needs of its registered activity, respecting the positive legal regulations for the protection of personal data processed by:
- Name and surname;
- Personal identification number of the citizen;
- Personal health number of the citizen;
- Address;
- Telephone number;
- ID number;
- Passport number;
- Bank account number;
- Credit history and status;
- Traffic license number;
The company through its website processes personal data for the purpose of enabling direct marketing for itself, related legal entities or business associates, improving the user experience with the prior written and unambiguous consent of the site visitor.
The processing of personal data is carried out in accordance with the provisions for processing, protection and storage of personal data from the positive legal regulations.
The Company obligatorily enables every potential Subject of personal data, before giving his personal data for processing to the Company, to be familiar with the extent, legal basis and purposes of processing his personal data, with data on the competent “Controller”, “Processor” and “Personal Data Protection Officer” through:
- signing a written consent for the processing of personal data; or
- signing an agreement, authorization, consent or invoice from which it clearly and unequivocally follows that the Company processes his personal data for purposes to the extent necessary for the realization of that act.
The company, on the basis of a business-technical cooperation agreement and in accordance with the Personal Data Protection Act (Official Gazette of Republic of North Macedonia number 42/2020) is the author and administrator of a customer loyalty program system intended for serving legal entities with registered activity in the Republic of North Macedonia – Marketing Contractors “MINT Bonus” available online, through which it offers loyalty benefits for customers and potential customers of the Marketing Contractors.
The company ensures full compliance of the processing of personal data through the program with the relevant positive legal regulations of the Republic of North Macedonia, in which users have the right to continuous and immediate insight through its ICT Sector and OZLP.
The personal data that are processed on the basis of these provisions are formed, processed and stored as a separate collection of personal data exclusively on the basis of personal and unambiguous consent of the subjects of personal data.
MINT Bonus Terms of Use and Privacy Policy are governed by this policy and Mint Bonus General Terms and Conditions.
The company, on the basis of a business-technical cooperation agreement and in accordance with the Personal Data Protection Act (Official Gazette of Republic of North Macedonia number 42/2020) is the author and administrator of the internet application “MINT Application” available for installation through the Google Play Store and App Store, through which it offers an application, monitoring and servicing of products and services for customers and potential customers of the users of the application, the legal entities that are members of the MINT GROUP.
An external collaborator for the internet application is creator of the same, while on his own behalf and at the expense of the users, he ensures full compliance of the processing of personal data through the application with the relevant positive legal regulations of the Republic of North Macedonia, in which the users have the right to continuous and immediate insight through its ICT Sector and DPO.
The personal data processed on the basis of these provisions are formed, processed and stored as a separate collection of personal data exclusively on the basis of personal and unambiguous consent of the subjects of personal data.
The terms of use and the privacy policy of the MINT application are regulated by the General terms, this policy and Appendix 1 and 2.
The Company obligatorily enables each potential Subject of personal data, before giving his personal data for processing to the Company, to be familiar in detail with the possibility of withdrawing the given consent from paragraph 1 of this article by written request (including e-mail) regardless in which way he gave it or to submit a request for correction or destruction of the given data.
The subject of personal data has the right to request and receive from the Company within 15 days from the day of submission of the request, correction of his incorrect personal data by written request (including e-mail).
Taking into account the purposes of the processing, the subject of the personal data has the right to supplement the incomplete personal data, by providing an additional statement.
The subject of the personal data has the right to ask the Company to delete the personal data, whereby the Company has the obligation to delete personal data within 3 days from the day of submission of the request for deletion with a written request (including e-mail), if one of the following conditions is met:
- the personal data are no longer needed for the purposes for which they were collected or processed in another way;
- the subject of the personal data withdraws his consent on which the data processing is based and if there is no other legal basis for processing;
- the subject of the personal data submitted an objection to the processing, after which it was decided positively that personal data were illegally processed.
Date: September 2, 2024
General Director,
Nikola Joshevski
