Privacy Policy

Effective: February 16, 2026

Please read the following Privacy Policy carefully to understand our policy, procedures and practices regarding your Personal Data and how we collect, use, store and disclose it. We will use your Personal Data in accordance with this Privacy Policy and applicable data protection laws.

Definitions of Terms used in this Privacy Policy

The following terms shall have the meaning set forth below:

Account means a unique Account created for you to access Services or parts of our Services.

Anti–money laundering (AML) means a set of laws, regulations and institutional practices designed to help regulated entities prevent, detect, and report money laundering and related financial crime; in certain jurisdictions it can be paired with combating the financing of terrorism (AML/CFT).

Applicable law has the meaning given to it in our User Agreement.

Browser means a software application (such as Chrome, Safari, Firefox, or Edge) that accesses, retrieves, and displays Websites and other web content on a User’s device by requesting content from web servers.

Cookies mean small text files that are placed on your computer or mobile device by Websites that you visit. Cookies are used to make Websites function or function more efficiently, and to provide information to the Website’s operator.

Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of Personal Data relating to him or her.

Controller or Data Controller means a natural person, legal entity or public authority responsible for data processing.

Data Subject or Subject means an identified or identifiable natural person from whom or about whom information is collected.

Device means any device that can access the Website such as a computer, a mobile phone or a digital tablet.

Geolocation or Geolocation data or Location data means any data processed in an electronic communications network or by an electronic communications Service indicating the geographical position of the terminal equipment of a User of a public electronic communications Service.

Internet Protocol Address or IP Adress’ means an identifying number that is associated with a specific computer or computer network.

KYC (Know Your Customer) means a set of identity verification and due‑diligence procedures that organizations use to confirm a customer’s identity and, where required, assess risk (i.e. fraud, money laundering, sanctions exposure) before or during providing Services.

Marketing Communications mean the communication of advertising or marketing material directed at individuals.

Newsletter means a regular email sent to provide information or updates about a product or Service, received by subscribers.

Personal Data or Personal Information means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. For the purposes of this Privacy Policy, there is no distinction between the terms Personal Data and Personal Information.

Processing or Data Processing means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission or dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Processor or Data Processor means any natural person, legal entity or public authority to whom/which a controller delegates certain processing-related duties under the law or on the basis of a contract.

Social Media Account means Accounts, profiles, pages or registrations on Social Media or social networking Services.

Third Party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process Personal Data.

Restriction of Processing means the marking of stored Personal Data with the aim of limiting their processing in the future.

Web Beacon (also known as a tracking pixel, pixel tag or web bug) means a small resource embedded in a webpage or email that enables the operator to detect when the content is viewed and collect basic interaction and technical data.

1. Privacy Notice

1.1. We at ZajamNajam (‘we’, ‘us’, ‘our’ or ‘ZajamNajam’) value your privacy and we are committed to taking care of your Personal Data. Safeguarding your Personal Data and compliance with relevant data protection laws and regulations are responsibilities we take very seriously.

1.2. This Privacy Policy describes how the operator of the Website ZajamNajam - Puls Invest doo, with headquarters in Niš, Republic of Serbia, company registration number: 21376221, tax number 110688215 - and its subsidiaries collect, use, process and share Personal Information.

1.3. The operator of the Website is the Data Controller of the Services provided through the Website.

1.4. This Privacy Policy applies to Users and Visitors (individually ‘you’) of the ZajamNajam Website, applications, Social Media Accounts and other Services (our ‘Services’). This Privacy Policy explains how we comply with EU legislation related to data protection (EU General Data Protection Regulation 2016/679 – GDPR) and the Law on Personal Data Protection of the Republic of Serbia (Official Gazette of the Republic of Serbia no. 87/2018).

1.5. When using our Services, you can choose to interact with Features or Services from Third Parties that operate independently from us (i.e. links to Third Party Websites). Please note that this Privacy Policy does not cover the use of Personal Data by Third Parties or their Services, and we do not take any Accountability for their practices in the area of Personal Data protection. We recommend that you review the privacy policies and practices of Third Parties.

1.6. Individuals with disabilities who are unable to access our Privacy Policy online may contact us to inquire how they can obtain a copy of our policy in another, more easily readable format.

1.7. Please note that your use of our Services provided on the ZajamNajam Website is subject to our User Agreement.

2. Personal Data We Collect

2.1. Personal Data refers to any information relating to an identified or identifiable living natural person, as defined in the Definitions of Terms section above. This means any information relating to you which allows us to identify you, relates to you, describes you, can be used to contact you, or could reasonably be connected directly or indirectly with you.

2.2. When you visit our Website, register an Account with us and use our Services provided on the Website, subscribe to our Marketing Communications or interact with us in relation to our Services, you may provide us with your Personal Data or we may obtain Personal Data about you.

2.3. We may collect the following categories of Personal Data directly from you:

(a) Personal identifiers and contact details (such as your name, age, date of birth, gender, address, e-mail address, phone number);

(b) Personal identifiers for the purpose of the KYC procedure (such as proof of identity, proof of address);

(c) Account information (such as login credentials, including e-mail address and password, and Account settings);

(d) Social Media data (if you choose to link your ZajamNajam Account with your Social Media Account, we may collect Personal Information such as name, age, photograph, and other Personal Data linked to your Social Media Account);

(e) Billing information;

(f) Your published content and photos (such as any Personal Information you decide to publish via your Account and/or include about yourself or others);

(g) Your contacts and/or reservations (such as contact information of the people you add to or notify of your reservations or listing through the use of our Services);

(h) Submitted reviews (reviews you submit by any name or in connection with any Personal Information you publish by yourself or others);

(i) Correspondence data (such as conversations, questions, complaints or any other Personal Information that you submit to us);

(j) Marketing Communications and preferences (such as your e-mail address or phone number; you can always stop receiving our Marketing Communications at any time through any methods displayed as part of any communication between us or by unsubscribing the link in our e-mails to you);

(k) Internet and Website information (such as your use of our Website, the date and time of your visit and use of our Website, personal identification numbers, IP addresses, geolocation, usernames, device information, browser information, platform, operating system, search engine used and other system identifying pieces of information).

(l) Other Personal Information you may provide (any other information you provide about yourself or others through the use of our Services or through Third Party platforms).

2.4. Some of the Personal Data mentioned above, such as your identity proof or address proof, may be considered a special category of data under applicable law or in your local jurisdiction. Please be aware that this information may be required for the Account registration procedure in order for us to comply with KYC and AML regulations and standards.

2.5. Certain Features of our Services may prompt your browser or device to request access to your geolocation information. We do not process geolocation information without you giving us permission through your browser or device.

2.6. Copies of proof-of-identity documents and proof-of address documents are Personal Data and must be treated with a high level of protection. Please note that they are not automatically special categories of Personal Data. If, and only if, we must carry out specific technical processing of facial images (i.e. ID photo) for the purpose of uniquely identifying you, such Personal Data may be treated as special category of Personal Data. In such cases we shall apply additional safeguards and rely on an appropriate legal basis required by applicable law.

2.7. Where you have willingly and transparently consented to our processing of Personal Data and/or sensitive or special category of Personal Data, you have the right to revoke such consent at any time contacting our support team.

2.8. You have the right not to provide some of the Personal Data described above. Please note that the use of our Services requires particular information to operate. If you choose not to provide the Personal Information which is necessary to operate and provide you with a certain Service or Feature of that Service, you may not be able to use it.

3. Why do we collect your Personal Data?

3.1. The table below describes the main purposes for which we process your Personal Information, the categories of your Personal Data used and our lawful basis for being able to do this.

3.2. Please note that some of your Personal Information is required by applicable law, by contract requirements, or for other essential reasons in line with applicable legislation. If you don’t provide this information with us, we might not be able to fulfill our contract with you, meet compliance obligations or our legitimate interests, as well as provide our Services or the full range of our Services as well as provide a personalized experience to you.

3.3. Marketing Communications and newsletters are entirely optional – If you decide not to share this information for such purposes, there are no consequences at all, except that we won’t be able to send you personalized offers, insights or other types of promotional messages. If you have given your consent for Marketing Communications and/or newsletter, you can withdraw it at any time by unsubscribing the link in the e-mail or by contacting us directly at: support@zajamnajam.com

4. Who We Share Your Personal Data With?

4.1. For our Website to function properly and provide related Services, we may need to share your Personal Information with trusted Third Parties. This involves sharing information with Third Parties that support Service delivery.

4.2. We share Personal Information with our affiliates and subsidiaries to ensure smooth business operations, legal and regulatory compliance, customer support and proper Service delivery. We work with vendors who perform essential Services on our behalf such as web hosting, data analytics, e-mail marketing, customer relationship management, infrastructure management and payment processing. All these vendors/Service providers are contractually obliged to process your Personal Information only as necessary to provide these Services.

4.3. We may share your information with customers/guests and listing partners, such as property managers or agents, when you interact with them or when they request more information. If you, as a customer/guest, inquire a accommodation rental through our Website, your contact details may be shared with the host. If you utilize Features that enable messaging or sharing content, your Personal Information may be disclosed.

4.4. We may also cooperate with analytics and/or advertising partners to deliver relevant marketing ideas and strategies, measure performance, and improve User experience. This may include sharing information such as location and User activity.

4.5. Please be aware that your Personal Information may be disclosed when you interact with Third Party integrations, such as logging in through Social Media Accounts. We are not responsible for privacy notices, policies or privacy practices of Third Parties.

4.6. We may disclose Personal Information to law enforcement, courts, regulators, or other authorities when required by applicable law and to comply will all relevant legal and regulatory requirements as well as protect our rights, ensure safety or enforce agreements.

4.7. If our company undergoes a merger, restructuring or acquisition, your Personal Information may be shared with relevant parties during the process. We may also disclose your Personal Data with auditors, legal counsel, and professional advisors to comply with legal, financial and operational requirements.

4.8. We may share your Personal Information when you direct us to do so or share content through integrated Features and tools.

4.9. We do not disclose your Personal Data to anyone else unless you have given your explicit consent or we are legally required to do so.

5. How Do You Obtain Consent?

5.1. By using our Website, subscribing to our newsletter, contacting us through forms or contact details provided, explicitly accepting the use of Cookies on our Website, or sharing Personal Data so we can communicate with you or registering an Account on our platform, you agree to the collection, storage and the use of your Personal Information as described in this Privacy Policy.

5.2. Please note that you can withdraw your consent at any time. To do so, send us a request through the contact information provided below.

6. How Long Do We Store Your Personal Data?

6.1. We may store your Personal Data for as long as your Account is active.

6.2. We may also retain your Personal Data as necessary to maintain logs and business records for the purpose of analysis, audit and/or security purposes; maintain compliance with record retention requirements under applicable law; deal with complaints regarding the provision of our Services and comply with all legal and regulatory obligations and enforce our contracts.

7. Technical, Administrative and Security Measures We Implement

7.1. We maintain all reasonable technical, administrative and security measures designed to safeguard your Personal Information from loss, misuse, unauthorized access, alteration, disclosure, and destruction.

7.2. We shall take all commercially-reasonable steps to ensure that appropriate technical, administrative, organizational and security measures are carried out in order to safeguard the Personal Data we collect from you against any unlawful access and/or accidental loss and/or damage. To prevent unauthorized access or data disclosure, we have put in place suitable physical, technical and administrative procedures to protect Personal Information we collect.

7.3. We shall ensure that all our employees, affiliates and partners are aware of privacy and security obligations under this Privacy Policy. We shall take all reasonable steps to ensure that Third Parties working on our behalf are aware of their privacy and security obligations.

7.4. The transmission of Personal Information on the Internet is not entirely secure, and you play a significant role in keeping your Personal Data secure. You should not share your username, password, or any other security information for your Account with anyone. If you have any reason to believe that your interaction with us is no longer safe and/or feel that the security of your Account has been compromised, please contact us immediately.

7.5. Except to the extent that liability cannot be excluded or limited due to applicable law, we assume no responsibility or liability for disclosure of your Personal Information due to errors in transmission, unauthorized Third Party access or any other causes that are beyond our control.

8. International Transfers

8.1. Your Personal Information is processed at our operating offices and in any other places where the parties involved in the processing are located. This means that information may be transferred to recipients outside of your state, province, country or governmental jurisdiction. These transfers may be to our partners or Service providers who are in regions with divergent data protection laws.

8.2. Please note that data can be transferred from the Republic of Serbia to a state party to the Council of Europe Convention for the Protection of Individuals with regard to automatic processing of Personal Data. Data may be transferred from the Republic of Serbia to a state that is not party to the above-mentioned Convention or an international organization if such state or international organization has a regulation or data transfer agreement in force which provides a level of data protection equivalent to that envisaged by the Convention.

8.3. When transferring your Personal Data intentionally, we implement appropriate safeguards to ensure the confidentiality and security of your data, as proposed by applicable data protection laws and regulations. These safeguards may include, for example, Standard Contractual Clauses (SCCs) approved by the European Commission and the Commissioner for Personal Data Protection of the Republic of Serbia.

8.4. Any transfer of Personal Data to another country or international organization (whether the data is already being processed or intended for further processing after the transfer) is permitted only if the Data Controller and the Data Processor comply with the conditions prescribed by applicable law. The main objective is to ensure an adequate level of protection for natural persons, equivalent to the level guaranteed by applicable law.

8.5. Your consent to this Privacy Policy means that you agree to the potential transfer, storing and processing of your information to the extent permitted by applicable data protection laws and the EU GDPR.

8.6. We shall take all steps reasonably necessary to ensure that your Personal Data is treated securely all the time, and in accordance with this Privacy Policy and applicable law. No transfer of your information will take place to a country or international organization unless there are adequate controls in place including the security of your Personal Information and all other related information.

9. Children

9.1. Our Services are not directed at or intended for use by children. We do not knowingly collect Personal Information from children under the age of 16 (sixteen). If you are under the age of 16 (sixteen), you are not allowed to use or submit information to our Website.

9.2. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us using our official contact details.

10. Your Rights as a Data Subject

10.1. You have certain rights regarding your Personal Data. This section explains these rights on the basis of applicable legal provisions.

10.2. Right to Notification of Data Processing: As a data subject, you have the right to be accurately and fully informed by the controller on the processing of your data, the source of data, type of data being processed, purposes for which the data is being processed, the legal grounds for data processing, the use of data, the period of data retention and other matters as prescribed by the Serbian Law on Data Protection and the EU GDPR.

10.3. Right to Withdraw Consent: You may withdraw your consent for data collection, processing, or transfer at any time, in whole or in part. Once you do, we shall stop processing your Personal Data for purposes that relied on your consent as a legal basis – unless there is another valid legal basis. Withdrawal does not affect the legality of any processing performed prior to the withdrawal.

10.4. Right of Access: You have the right to request confirmation of whether we process your Personal Information. You are also entitled to a copy of the data with related details such as processing purposes, third-party recipients, retention of data, your rights, sources of data collection, and security measures in case of any international transfer.

10.5. Right to Rectification: You can always ask us to correct inaccurate Personal Information or complete any incomplete data, without undue delay.

10.6. Right to Erasure (‘Right to be Forgotten’): You have the right to request deletion of your Personal Data if the information is no longer necessary, if the consent is withdrawn (without an alternative legal basis for processing), you object to processing, deletion is legally required, data were unlawfully processed, or data were collected from minors under 16 (sixteen). Please note that this right is not absolute – data may be retained if necessary for compliance with applicable laws and regulations.

10.7. Right to Restrict Processing: In certain cases (i.e. disputed accuracy of data, unnecessary processing, unlawful processing and similar situations) you can ask us to limit how we use your Personal Information. While restricted, we may only store Personal Data or process them with your consent or for compliance with applicable laws and regulations or public interest.

10.8. Right to Data Portability: If your Personal Information was provided to us directly or processed through automated means based on your consent or for the fulfilment of a contract with us, you have the right to receive data in a structured, commonly used and machine-readable format. When technically feasible, you can request transfer to another Data Controller.

10.9. Right to Object: You can object to our processing of your Personal Data based on public or legitimate interest. We must then stop processing unless we have compelling legal reasons. You have an unconditional right to object to data use for direct marketing.

10.10. Right to Lodge a Complaint: If you believe that we somehow mishandled your Personal Data, you can contact us at support@zajamnajam.com. We will respond to your complaint within 30 (thirty) days. You also have the right to file a complaint with the Commissioner for Personal Data Protection, address: Bulevar kralja Aleksandra 15, 11120 Belgrade (Republic of Serbia) or via office@poverenik.rs.

11. Links to Other Websites and Applications

11.1. Our Website may contain links to other Websites, applications or Services that are not owned or controlled by us, including links to Social Media platforms, or may redirect you off our Website.

11.2. This Privacy Policy only applies to information collected by our Website and our Services. We are not responsible for the privacy and security practices of Third Parties or the information they may collect and/or process.

11.3. You should contact these Third Parties directly to determine their privacy policies and privacy practices. Links to any other Websites, Services, applications or content do not constitute or imply, either directly or indirectly, a recommendation or an endorsement by us of the linked Website, Service, application and/or content.

12. Cookies and Tracking Technologies

12.1. We use Cookies and similar tracking technologies to track the activity of our Services and store certain information. Tracking technologies used may be web beacons, tags and scripts to collect and track information for the purpose of analyzing and improving our Services. You can find more information about Cookies and how to manage them in the information below.

12.2. Essential cookies are required and cannot be disabled, as they enable core features of the Platform. For non‑essential cookies. We will ask for your explicit consent. Please note that declining non‑essential cookies may limit certain features

12.3. There are several types of Cookies:

(a) Session Cookies: temporary Cookie files which are erased when you close your browser and exist only while your browser is open.

(b) Persistent Cookies: files stored on the User’s device that remembers information, settings, preferences or sign-in credentials that the User has previously used.

(c) First-Party Cookies: Cookies that are created and stored directly by the Website you are visiting; these Cookies belong to the provider of the Website and are placed on your browser to enable functionality, improve User experience, and remember your preferences during your visit.

(d) Third-Party Cookies: Cookies that are stored under a divergent domain than the one you are currently visiting.

12.4. Technologies similar to Cookies refer to technologies that store or access information on a User’s device. Our Cookies, web beacons and similar technologies are intended for various purposes, but they are generally essential for the functioning of our Website and Services and help us improve the Website’s performance or provide more functionality.

12.5. We use Cookies and similar tracking technologies to acquire a better understanding of how Users use our Services and all Features on our Website. Cookies help us tailor the Services to your personal needs, improve User experience and functionality. We use Cookies in a variety of ways to improve your experience on our Website.

12.6. Some Cookies are applied when you enter our Website. We keep all the information collected via Cookies in a non-personally identifiable format. Our First-Party Cookies do not store personally identifiable information such as your name or full IP address. They may contain anonymous identifiers used solely to improve our Website’s functionality.

13. Amendments to this Privacy Policy

13.1. We may update this Privacy Policy from time to time, to reflect changes in our practices, legal requirements or influenced by other reasonable factors, by posting notice of the update on our Website. Changes to this document shall be effective when posted and the novel effective data shall be identified.

13.2. If we conduct any changes to the Privacy Policy that may materially impact previously collected Personal Data about you, we shall make reasonable efforts to provide notice and obtain consent to any such changes as may be required by applicable law.

13.3. If you want to require a copy of this document or a copy of the Privacy Policy which was effective at the time you registered an Account, please use the details below to contact us.

14. How to Contact Us?

If you would like to contact us with questions about our Privacy Policy and privacy practices or with any other complaint or request, you can do so via the following e-mail address: support@zajamnajam.com