Privacy Policy

1. Who we are

This Privacy Policy explains how Selection processes personal data when you request access to, use, create Content with or interact with the Selection platform and websites powered by Selection.

Selection is operated by:

IVAN KNEŽEVIĆ PR PRIVATNI SMEŠTAJ SELECTION BEOGRAD (STARI GRAD) Dobračina 9 11000 Belgrade (Stari Grad) Serbia

PIB: 107065001 MB: 62473835

Contact: office@selection.rs Website: https://selection.rs

For processing for which Selection determines the purposes and means, Selection acts as controller.

Where a Creator uses Selection to collect information from Visitors through features such as Sign Up, the respective data-protection roles of Selection and the Creator may depend on the circumstances and applicable law.

2. Scope

This Privacy Policy applies to personal data processed through Selection, including:

• onboarding and access requests;
• Selection Studio;
• Selection-powered public Experiences;
• Sign Up and similar interactive features;
• communications relating to Selection accounts and services;
• security and abuse-prevention systems.

This Policy does not govern the independent privacy practices of third-party services that may be embedded in, linked from or used to communicate through Selection.

3. Onboarding and account information

When you request access to Selection, we may process information such as:

• your name or business/display name;
• email address;
• telephone number;
• requested Selection workspace or subdomain;
• information you voluntarily provide in your request;
• request status and related timestamps.

We use this information to evaluate and administer onboarding requests, provision and operate Selection accounts and workspaces, communicate service-related information, maintain platform security and keep appropriate operational records.

Selection does not collect an applicant's Telegram identity as part of the active onboarding process.

4. Account and authentication information

For authorized Studio Users, Selection processes information necessary to identify the account and control access to the platform, including account identifiers, email address, display name, role, tenant/workspace association and account/session status.

Selection uses authentication and session mechanisms to maintain authenticated access to Studio.

Authentication credentials and session information are separate from ordinary onboarding communications.

Selection does not use WhatsApp or ordinary onboarding email communications to transmit passwords, session tokens, authentication cookies or similar authentication secrets.

5. Creator Content

Creators may upload, enter, embed, publish and manage information through Selection, including text, images, video references, links, locations, event information and other Content.

Some Creator Content may itself contain personal data.

Creators are responsible for ensuring that they have an appropriate legal basis and any permissions required to upload, publish or otherwise process personal data contained in their Content.

Additional rules concerning Creator Content are contained in the Terms of Service, Acceptable Use Policy and Content Rights & Takedown Policy.

6. Sign Up and Visitor submissions

Selection Experiences may contain Sign Up or similar interactive features.

Depending on how a Creator configures such a feature, a Visitor may provide:

• name;
• an answer or selection;
• email address, telephone number or Instagram contact information;
• consent relating to public display of certain submitted information;
• submission time and related technical identifiers.

Selection may also generate a random browser-scoped identifier used to recognize subsequent submissions from the same browser to the same Sign Up feature.

This identifier does not establish or verify the real-world identity of the Visitor.

Sign Up submissions therefore must not be treated as verified human identity merely because the same browser identifier is present.

Where public-display consent is provided, selected submission information such as a name and answer may be displayed publicly as part of the relevant Experience.

7. Technical and security information

Selection may process technical information necessary to operate, secure and protect the service, including:

• browser and request information;
• security and authentication assertions;
• session information;
• IP-address-related information used for security, rate limiting and abuse prevention;
• security verification tokens;
• operational identifiers and audit records.

Selection uses Cloudflare Turnstile on relevant public submission surfaces for protection against automated abuse.

IP-address-related information may be used for rate limiting and security verification. The active Selection application does not use IP address as the identity of a Sign Up respondent.

8. Cookies and browser storage

Selection uses cookies and browser storage necessary for platform functionality.

This includes or may include:

Session cookie: Selection uses a secure session cookie to maintain authenticated Studio sessions.

Sign Up respondent identifier: A random identifier may be stored in browser local storage so that a subsequent submission from the same browser to the same Sign Up feature can update an earlier submission rather than automatically create another one.

Interface preferences: Local browser storage may be used for preferences such as language or recently used Studio functionality.

Temporary onboarding state: Session storage may be used to maintain the state of an onboarding request while the relevant browser session remains active.

Selection does not currently operate its own advertising or behavioural profiling system through these storage mechanisms.

Third-party embedded services may use their own cookies or similar technologies under their respective policies.

9. Purposes of processing

Depending on the context, Selection processes personal data to:

• provide and operate Selection;
• process onboarding requests;
• create and administer accounts and workspaces;
• authenticate authorized Studio Users;
• save and publish Creator Content;
• process Visitor Sign Up submissions;
• provide requested platform functionality;
• communicate account and service information;
• protect Selection against fraud, spam, abuse and unauthorized access;
• diagnose technical problems and maintain platform reliability;
• enforce the Terms and platform policies;
• respond to legal claims, rights requests and lawful requests from competent authorities;
• comply with applicable legal obligations.

10. Legal bases

Where applicable data-protection law requires a legal basis, Selection may process personal data on one or more of the following bases.

Contract and steps requested before entering into a contract: for onboarding, account administration and provision of Selection services.

Legitimate interests: where necessary to operate, secure and protect Selection, prevent abuse, maintain appropriate records and protect the rights and security of Selection, its Users, Creators and Visitors, provided those interests are not overridden by applicable rights and interests of the individual.

Legal obligation: where processing is required to comply with applicable law or a legally binding request.

Consent: where Selection or a Creator specifically requests consent for a particular processing activity and consent is the appropriate legal basis.

Where processing relies on consent, consent may be withdrawn subject to applicable law.

11. Communications

When you provide an email address or telephone number during onboarding, Selection may use that information to communicate with you about:

• your onboarding request;
• account or workspace status;
• availability of Studio access;
• actions required from you;
• other service-related matters.

An authorized Selection operator may initiate such communication by email or, where a telephone number has been provided, through a messaging service such as WhatsApp.

A communication may, for example, inform you that your Selection Studio is ready and direct you to Studio.

These communications are not authentication channels.

Selection does not use these messages to transmit passwords, session tokens or other authentication secrets.

If communication occurs through a third-party messaging service, that provider may process the telephone number and communication according to its own terms and privacy practices.

12. Service providers and third-party services

Selection uses service providers and infrastructure necessary to operate the platform.

Cloudflare

Selection uses Cloudflare infrastructure and security services and, depending on the relevant Selection surface, technologies including Workers, Pages, D1, R2, KV, Access, Images and Turnstile.

Cloudflare may process information necessary to provide these services.

YouTube

Creators may include YouTube videos in Selection Experiences.

When a Selection page containing an active YouTube embed loads, the Visitor's browser may communicate directly with Google/YouTube.

Information such as the requested video, page/referrer context, IP address, browser/device information and other information handled by Google's services may therefore be processed by Google/YouTube according to their own privacy practices.

Google Maps

Creators may include Google Maps content in Selection Experiences.

When such content is rendered, the Visitor's browser may communicate directly with Google. Information associated with the map request and browser/network context may therefore be processed by Google according to its own privacy practices.

Messaging providers

Where an authorized Selection operator communicates with an applicant through a third-party messaging service such as WhatsApp, the provider may process the telephone number and communication according to its own terms and privacy practices.

Other delivery resources

Certain Selection-operated surfaces may load technical presentation resources from third-party content-delivery or font providers. When such resources are loaded, the Visitor's browser may communicate with the relevant provider.

Selection does not list a provider in this Policy merely because the operator independently uses that provider for unrelated purposes.

13. Creator-selected third-party Content

Selection provides tools that allow Creators to create and publish their own Experiences.

A Creator's choice to include a third-party video, map, link or similar resource may cause Visitors' browsers to communicate with that third-party provider.

Selection does not control the independent processing performed by those providers.

Creators should consider the privacy implications of third-party Content they choose to publish.

14. International processing

Selection is operated from Serbia, while some infrastructure and service providers operate internationally.

Personal data may therefore be processed in Serbia, the European Economic Area, the United States and other countries in which relevant service providers operate.

Where applicable data-protection law requires safeguards for an international transfer, Selection will use an applicable lawful transfer mechanism or other legally recognized safeguard.

15. Data retention

Selection retains personal data for as long as reasonably necessary for the purposes for which it is processed, including providing the service, maintaining security and operational integrity, resolving disputes, enforcing agreements and complying with legal obligations.

Different categories of data may be retained for different periods.

Selection does not claim a fixed automatic deletion period for every category of personal data.

Some operational or historical records may remain after associated presentation Content is archived or deleted.

In particular, deletion or removal of a Page, Experience or other presentation element does not necessarily cause automatic deletion of associated historical Sign Up submissions, audit records or other records maintained separately from presentation Content.

Where applicable law requires deletion or gives an individual a right to request deletion, Selection will assess and act on a valid request in accordance with applicable law.

16. Privacy rights

Depending on applicable law and the circumstances of processing, an individual may have rights including:

• access to personal data concerning them;
• correction of inaccurate or incomplete data;
• deletion of personal data where applicable;
• restriction of processing;
• objection to certain processing;
• data portability where applicable;
• withdrawal of consent where processing is based on consent;
• information concerning applicable international-transfer safeguards;
• the right to lodge a complaint with a competent data-protection authority.

These rights are subject to conditions, limitations and exceptions under applicable law.

Requests concerning personal data processed by Selection may be sent to:

office@selection.rs

Selection may request information reasonably necessary to verify the identity of the person making a request before disclosing, changing or deleting personal data.

Individuals may also have the right to lodge a complaint with the Commissioner for Information of Public Importance and Personal Data Protection of the Republic of Serbia or another competent supervisory authority where applicable.

17. Creator-controlled data

Where personal data was submitted through an Experience created by a Selection Creator, the Creator may also have responsibilities concerning that processing.

Depending on the circumstances, Selection may need to coordinate a privacy request with the relevant Creator.

Nothing in this Policy removes rights that an individual has against a controller under applicable law.

18. Security

Selection uses technical and organizational measures intended to protect personal data against unauthorized access, disclosure, alteration, loss and misuse appropriate to the nature of the service and information involved.

No Internet-based service or storage system can guarantee absolute security.

Users are responsible for protecting access to their devices and authentication mechanisms and must not knowingly provide authenticated Studio access to unauthorized persons.

19. Children and Studio access

Selection Studio is intended only for account holders aged 18 or older who have legal capacity to accept the applicable agreement.

A person accepting the Selection Terms represents that they satisfy this requirement.

Selection cannot guarantee that an authorized User's device, browser session or access mechanism will never be used by another person.

Public Selection Experiences may be accessed or shared beyond the Studio account holder.

The Studio 18+ requirement does not by itself establish the age of every Visitor to a publicly shared Experience.

20. Sensitive information

Selection is not designed as a service for intentionally collecting highly sensitive personal information through ordinary Content or Sign Up features.

Creators should not use ordinary Selection features to solicit passwords, authentication credentials, financial-account credentials, government identification credentials, health information or other highly sensitive information unless a particular Selection feature expressly supports that processing, appropriate safeguards have been established and the processing is lawful.

21. Automated decision-making

Selection does not represent ordinary browser-scoped respondent matching, rate limiting or security verification as verified human identity.

Selection does not currently identify any ordinary Selection product feature as a solely automated decision-making process intended to produce legal or similarly significant effects on an individual.

If Selection introduces such processing, this Policy will be reviewed and updated where required by applicable law.

22. Changes to this Privacy Policy

Selection may update this Privacy Policy as the platform, applicable law or processing practices change.

Each version will identify its version number and effective date.

Where a change materially affects Studio Users, Selection may require Users to review or acknowledge an updated Privacy Policy and, where applicable, accept updated contractual terms before continuing to use Studio.

A Privacy Policy update does not by itself mean that consent is the legal basis for the processing described in that update.

Where consent is legally required for a particular processing activity, Selection will request it separately where appropriate.

23. Language

These documents may be made available in multiple languages. In the event of an inconsistency between translations, the English version will prevail, except where applicable law requires otherwise.

24. Contact

Questions, privacy requests or concerns may be sent to:

office@selection.rs

IVAN KNEŽEVIĆ PR PRIVATNI SMEŠTAJ SELECTION BEOGRAD (STARI GRAD) Dobračina 9 11000 Belgrade (Stari Grad) Serbia

PIB: 107065001 MB: 62473835

https://selection.rs