Comtrade Recruitment Privacy policy

1. Introduction

This privacy policy (Privacy Policy) sets out the ways in which Comtrade Group may collect and process your personal data.

By interacting with us regarding employment/recruitment opportunities or other purposes or by visiting our website we may collect and process personal data about you. We are strongly committed to protect and keep private any information so collected and to always comply with applicable legislation, including the EU General Data Protection Regulation (“GDPR”).

2. Single contact point:

Address: Comtrade Group, Savski nasip 7, 11000 Belgrade, Serbia
Phone: +381 11 201 56 00

3. How we may collect data

We may collect and process your personal data that you have provided to, personal data that we have obtained from third parties we work closely with or from publicly accessible sources.

4. Purposes of processing and information we process

We may collect and process your personal data for the following purposes:

  • to fulfill our contractual obligations towards you. This information may include your name, address, email address, phone number, title, workplace, company, type of cooperation with us;
  • for recruiting of new employees, either for specific employment vacancies or for general future employment possibilites; this information may include your name, address, email address, phone number, date of birth, information regarding your education and experiences, CV, photo and other relevant information;
  • to provide you with information or services that you have requested from us. This information may include your name, address, email address, phone number, and other relevant information;
  • to improve our websites. This information may include your IP address, geographical location, device information, browser type, referral source, length of visit, operating system, number of page views, which pages you viewed and similar information. For more information on cookies please refer to paragraph 11 below;
  • to comply with or abide by legal obligations or requirements.

5. Legal basis for processing of personal data under GDPR

We will process such personal data on the following legal bases:

  • the performance of a contract with you in compliance with Article 6(1)(b) GDPR;
  • our legitimate interest in compliance with Article 6(1)(f), when you communicate with us regarding employment opportunities or in our desire to improve the website;
  • your consent in compliance with Article 6(1)(a) GDPR where needed;
  • to comply with a legal obligation to which we are subject in compliance with Article 6(1)(c)

6. Disclosure of personal data

We may disclose your personal data to:

  • our affiliated companies;
  • data processors, who will process personal data in our name in accordance with our written instructions and for the purposes as stated above;
  • to other recipients if obliged to do so subject to a court order or order issued by other government authority or valid law.

7. Transfer of personal data to outside the EU/EEA

We may transfer such personal data to recipients who are located outside the EU/EEA (”third countries”), that is to their affiliated companies and data processors (such as the System provider). Such transfers take place under the following safeguard measures:

– the EU Commission has decided that the third country in question ensures an adequate level of protection;

– recipient from the USA is bound by the EU-US Privacy Shield;

– the EU Commission has not decided, due to the local legislation of such country or international obligations it has concluded, that such a country in question ensures an adequate level of protection.

In such cases, We will do everything to ensure that your personal data will receive an appropriate level of protection, which includes the use of Standard contractual clauses approved by the European Commission for transfer to countries that are not designated as countries that provide an adequate level of protection. Standard contractual clauses are available in various languages ​​available on this link: For more information regarding the use of the Standard contractual clauses you can contact us through

– In other cases, We may transfer your personal data to third countries based on your explicit consent in compliance with Article 49(1)(a) GDPR after you have been informed of the possible risks for you in regard with transfers of your personal data to third countries due to the absence of an adequacy decision and appropriate safeguards.

8. Storage period

We will process your personal data which we process for employment opportunities for as long as reasonably necessary for the purpose for which it was collected, but in no event longer than 24 months or for as long as reasonably necessary in order to comply with any applicable legal requirements.

We will process your other personal data only for as long as reasonably necessary for the purposes for which it was collected or received or to comply with any applicable legal requirements. Where your consent is the legal basis for the processing of personal data we will stop processing such data upon your withdrawal of your consent.

9. Protection and Security

We take precautions to protect your personal data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We have taken appropriate technical and organizational measures to protect the information systems on which your personal data is stored and we require our data processors to protect your personal data by contractual means.

10. Your rights

Subject to certain exceptions and restrictions set out in applicable legislation, you enjoy the right to request access to your personal data, to have your personal data rectified, deleted, or processing thereof restricted, to object to the processing and to data portability. You also have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or affects you significantly.

Where our processing of your personal data is based on your consent you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

If you want to exercise any of your rights as described above or have any question to that, please contact us by sending an email to

You also have the right to lodge a complaint with the competent supervisory authority as provided by applicable legislation.

11. Cookies

We use cookies and similar technologies to ensure that you get the most out of our website, to collect information on how you use our website and to track your online behaviour. The type of information gathered may include origin of the website visitor or email recipient, type of browser, operating system and search engine used, and length of visit on the webpage or email message. For more information about how we use cookies and similar technologies and how you can control them, please refer to our cookie policy published at the bottom of the website.

For more information on how to disable email tracking, please refer here (;;; ), or to the documentation of your e-mail application (if you use one), or your email service provider (if you use web browser to read email).

12. Links to other websites

The website may contain links to third party websites. We disclaim any control over, relationship with, or endorsement of these sites and shall not be liable for any damages arising from the content of such websites. Links to other websites are provided only as a convenience and we encourage that you read these third-party websites’ Terms of Use and Privacy Statements.

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. Updated privacy policies will be updated on the relevant website or provided to you at your request.