This Privacy Policy aims to inform in a clear and transparent way about the collection, use, storage, and processing of personal data of visitors to our website, users of services and employees of EAST GATE MALL Import-Export Skopje (EAST GATE MALL).

WHAT IS PERSONAL DATA?

Personal data is any information that relates to you as a natural person, for example: name and surname, unique social security number, telephone number, location data, internet identifier, data of a financial nature such as a credit card for the purchase of certain products or services, i.e. personal data is any information through which a certain natural person can be identified directly or indirectly.

WHO IS RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA?

EAST GATE MALL DOOEL import-export Skopje , with headquarters at str. Belasica no. 2, Gazi Baba Municipality, Skopje, Republic of North Macedonia, is the controller for the processing of personal data, to which your personal data may be submitted, in order to realize the relationship with you and respond to your requests.

The submission of any information or content by you as a subject of personal data (hereinafter referred to as the User) is voluntary and is subject to the Terms of Use which are an integral part of this Privacy Policy (hereinafter referred to as the “Policy”).

The Policy governs the right to privacy and security of personal data that is subject to processing. Please read the Policy and check it from time to time as we reserve the right to change it according to our activities and changes.

If you have questions regarding the points covered by this Policy, you are free to contact our Personal Data Protection Officer, Filip Kopanovski at the following email: filip.kopanovski@seg.mk .

By registering and logging in to our website, you declare that you are familiar with and agree to the content of our Privacy Policy.

WHOSE PERSONAL DATA DO WE COLLECT?

We may collect data related to the following categories of persons:

• Visitors to our website : https://eastgatemall.mk/ , users of EAST GATE MALL applications and potential consumers,

• Visitors to EAST GATE MALL, consumers, users of services and products.

WHAT PERSONAL DATA DO WE COLLECT?

Identification data: first name, last name, telephone number, e-mail, address.

User profile data: username and password, questions asked, requests, preferences.

Website visit data: information about web pages of the website visited by the User, web pages that redirected the User to the eastgate website, web pages that the User visited through links presented on the eastgatemall website the page, date and time of those visits, IP address of the user/IP address of the device-computer/tablet/phone from which access is made, question is asked, type of internet browser used by the User, keywords used by the User during search of the eastgate directory, the number of users who saw the internet advertisement (banner) on the eastgatemall website, the number of clicks on the internet advertisement (banner) on the eastgatemall website.

Data of a financial nature: We may have access to billing information when using our application for Loyalty Program: such as the date and time of the transaction, the amount of the transaction, the name of the merchant where the transaction was made.

This data will also be collected and processed by our trusted suppliers as third parties, in accordance with the terms and conditions of their privacy policies and terms of use.

We process your personal data in accordance with the positive legal regulations in the Republic of North Macedonia.

Data voluntarily submitted independent of the business relationship: The personal data that we collect when you visit our website, or when you send us an electronic mail (e-mail), or contact us by phone, are those that you voluntarily decide to you submit them to us, and for purposes established by law, how they would enable us to realize and fulfill the service we offer you (for example: name and surname, residential address, contact phone number, electronic mail (e-mail), data about your social networks, if you have accessed EAST GATE MALL information through a social network (Facebook, LinkedIn , Instagram, Youtube), data on potential employment candidates.

Data related to questions, requests, compliments, complaints, unethical or other impermissible conduct: The personal data that you share with us when you contact us in order to praise us, ask a question, submit a request, complaint or to report an action that in your opinion is unethical or impermissible, and in relation to you and/or the identity of the person to whom the address refers (for example: name and surname, contact data, content of the request/letter/report which may contain personal data of the person to whom the address refers, with evidence and attachments, etc.).

Video data from the video surveillance system.

WHERE IS PERSONAL DATA COLLECTED FROM?

Personal data is collected directly from you, when you register as a User, when you ask questions, requests, submit a complaint or praise, when you agree to receive marketing offers (newsletter), through your use of our website, through our email: complaints @seg.mk or when you communicate with us in another way.

FOR WHAT PURPOSE DO WE USE PERSONAL DATA?

• To answer questions about our activities, services, requests, suggestions, complaints.
• Delivery of direct marketing offers, discount information, via email and text messages, phone or mail.
• Completing or using EAST GATE MALL applications (for example for employment purposes, or for the services we offer according to the scope of our operations).
• To optimize the online user experience, personalized marketing messages and promotions that are the result of algorithmic analysis and prediction of preferences, interests and behaviors.
• To research and monitor the behavior of the User, his habits and interests, to analyze the effectiveness of advertising, for statistical purposes and for the purpose of improving the services offered. We may use Google Analytics for this purpose. EAST GATE MALL may process this information in a personalized form together with other information about the User that he provided during registration.
• To receive discounts and benefits through your participation in our Loyalty Program, sweepstakes, promotions, surveys or research, educations.

LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

Whenever we process your personal data, we have a legal basis for that processing. The legal basis for the processing of your personal data can be:

• Your consent – This applies when you provide your personal data and agree to us processing it in order to provide you with a specific service, for example:

1. You may receive marketing communications from us. We may use your identification, contact, preferences and user profile data to find out which products, services and marketing promotions would be of interest to you, only with your consent. You have the right to withdraw your consent at any time through an opt-out option whenever you receive marketing offers via email. Additionally, to withdraw consent for marketing offers, you can contact our Personal Data Protection Officer, Filip Kopanovski at the following email: filip.kopanovski@seg.mk.
2. We may store certain cookies on your device. Cookies are small text files that are placed on your device by the websites you visit. We may place analytical cookies (these are also known as performance cookies and measure/record your interaction with our site so we can make improvements) on your device. Please see our Cookie Policy on our website for more information about the different types of cookies we use and their purpose.

• Fulfillment of a contract – This applies when you provide us with your personal data for the realization and conclusion of a contract.
• Our legitimate interests – This applies when you provide us with your personal data and we use it to:
• We may use your personal information to ensure that our websites/applications function properly and are safe and secure.
• To answer your questions, requests, complaints and praises.
• Fulfillment of any legal requirements or for statistical purposes.
• Video surveillance to protect the property and assets of the Shopping Center, employees, visitors and users of our services from criminal activities, as well as providing evidence in proceedings in case of theft, fraud, damage to the property/assets of the Shopping Center, etc.

• To comply with a specific legal obligation – This applies when you provide us with your personal data which we need to keep for our legal reasons (for example, we need to keep your transaction information to comply with our tax obligations and financial reporting).

WHO CAN ACCESS THE DATA?

We want to clearly emphasize that we do not sell your personal data.

Access will always be controlled on a need-to-know basis, and will only be provided where necessary to provide you with the requested services or to allow us to perform any necessary or legitimate functions. Where permitted, we may also share some of your personal data, including data collected through cookies, to match and update the information you share with us, perform statistics based on your characteristics, and customize our communications to you.

Your personal data may be processed on our behalf by our trusted suppliers (third parties).

We rely on trusted third parties to carry out a range of business operations on our behalf. We only provide them with the necessary information to perform the service and request that they do not use your personal data for any other purpose. We always make our best efforts to ensure that all third parties we work with will keep your personal data secure. For example, we may entrust services that require the processing of your personal data to:

• Advertising, marketing, digital and social media agencies to help us run advertising, marketing and campaigns, analyze their effectiveness and manage your contacts, inquiries and our relationship.
• Third parties who assist us in providing IT services, such as platform providers, hosting services, maintenance and support of our databases and our software and applications.
• Payment service providers such as banks and payment financial institutions that perform services for us, related to the realization of the payment.
• Independent third parties, telecommunications operators, postal service companies, marketing partners, insurance companies, as well as competent institutions that have legal authority may use personal data for their own purposes.

Our relationship with third parties is regulated on the basis of a legally binding agreement which regulates that the appropriate measures of safety and security of your personal data are taken.

TRANSFER OF PERSONAL DATA

Personal data will not be transferred to third countries outside the European Union (EU) or the European Economic Area (EEA).

In the event that EAST GATE MALL needs to transfer personal data to third countries outside the borders of the EU or the EEA, we will take appropriate measures to ensure that an appropriate level of personal data protection is applied during the transfer, by concluding agreements for the processing of personal data (the standard contractual clauses issued by the European Commission or the Agency for the protection of personal data, other contractual clauses or protective mechanisms).

HOW LONG WILL THE DATA BE KEPT?

We will keep your personal data for as long as necessary to provide you with the requested service/s or to satisfy commercial and legal obligations. To determine the retention period of your personal data, we take into account several criteria to ensure that we do not keep your personal data longer than necessary. Those criteria are the following:

• The purpose for which we hold your personal data.
• Our legal and regulatory obligations related to that personal data, for example obligations arising from financial operations and submission of financial statements.
• If our relationship with you is current, i.e. active, for example if you have an active user profile on our website, if you continue to receive marketing communications or if you regularly search through our website.
• If you no longer wish to receive our emails, if you do not visit our website.
• Any specific request on your part regarding the deletion of your personal data and
• Our legitimate business interests in connection with the management of our own rights, for example, the defense of any legal claims or for statistical purposes.

In particular, we retain certain personal data for the following periods:

• When you purchase certain services, we store your personal data for the duration of our contractual relationship.
• When you have consented to receive marketing communications, we retain your personal data until you: (i) request that we delete your personal data or until you withdraw your consent to receive marketing communications; or (ii) after a certain period of inactivity (ie when you have not communicated with us for a period of time).
• When cookies are placed on your computer, they are kept for as long as necessary to achieve their purposes (for example, for the duration of a session for shopping cart cookies or session identification cookies).

When we no longer need to use your personal data, it will be removed from our system and records, or it will be anonymized so that you can no longer be identified through it.

HOW WE PROTECT YOUR PERSONAL INFORMATION

 

Users aged 16 and under

If you are 16 years of age or younger, ask your parent or guardian for permission before providing us with personal information. Users may not provide us with personal data without such consent.

 

Links to other websites, applications and services

The EAST GATE MALL website may provide links to third-party websites or include third-party sites and services. EAST GATE MALL is not responsible for the protection of privacy or personal data by third parties, application providers, operating system providers, wireless service providers, device manufacturers, etc.

 

In the event you choose to visit such a link, we are not responsible for the availability of the selected site, mobile applications or other third-party services. We also do not check the websites of third parties, their mobile applications or services and are not directly or indirectly responsible for their use and content, collection and processing of any data by the websites, mobile applications or services of these people. In view of the above, we recommend that before using the services or mobile applications of third parties, or before entering any personal data into them, that you inform yourself about their privacy policies or privacy statements, which are available on or on their websites -pages or when accessing (registration) in such a mobile application .

 

Security of Collected Data

We use strict physical, electronic and administrative security measures to protect your data from access by unauthorized persons and against unlawful processing, accidental loss, destruction and damage both online and offline. Personal data is retained in an identifiable format only for the period necessary, identified by the purposes of the processing for which the data is collected.

 

RIGHTS OF PERSONAL DATA SUBJECTS

You as subjects of personal data have the following rights:

• The right to be informed about the processing of your personal data .
• Right of access to personal data and their copy.
• Right to rectification and deletion of personal data if they are incomplete and inaccurate, processed in an illegal manner and the purpose of their processing is fulfilled.
• The right to restrict the processing of personal data, if you dispute their accuracy for the time it takes us to check their accuracy, the processing is unlawful, but you object to their deletion and request the restriction of their use, they do not need to be stored any longer by us party, but are necessary for the fulfillment of your legal requirements, you object to their processing based on our legitimate interests until it is confirmed that they prevail over your interests as a subject of personal data;
• The right to object to the processing of personal data when it is processed on the basis of our legitimate interest. You have the right to object at any time to processing for direct marketing and profiling related to direct marketing.
• The right to data portability, that is, to receive your personal data in a structured machine-readable format or to be transferred to another company, which is provided in an automated way, based on a contract or your consent.

For additional information and/or exercise of your rights for personal data protection, you can contact our Personal Data Protection Officer Filip Kopanovski at the following e-mail: filip.kopanovski@seg.mk .

Requirements for exercising the rights to personal data:

• Form No. 1 – Request for access to personal data
• Form No. 2 – Request for correction of personal data
• Form No. 3 – Request for deletion of personal data processing
• Form No. 4 – Request to limit the processing of personal data
• Form No. 5 – Request for transfer of personal data
• Form No. 6 – Request for withdrawal of consent for personal data processing
• Form No. 7 – Objection to the processing of personal data

WHICH DATA ARE MANDATORY AND WHICH ARE OPTIONAL?

The data necessary for the realization of transactions and payment operations are mandatory for the Loyalty Program, otherwise the Loyalty Program will not be able to be implemented.

AUTOMATED DECISION-MAKING PROCESS, PROFILING

We may use an automated decision-making process, including profiling in the process of processing your personal data based on previously given consent for marketing activities. We may analyze your personal data based on demographic data, search data, purchase history. Based on this analysis, we can give you a specific offer for certain products.

If you have any questions regarding automated decision-making, you are free to contact us via the contact details of the Personal Data Protection Officer listed above.

RIGHT OF OBJECTION TO THE PERSONAL DATA PROTECTION AGENCY

You have the right to submit an objection to the Personal Data Protection Agency (AZLP) against the processing of your personal data if you believe that your right to personal data protection has been violated. You can exercise this right by submitting a Request to AZLP, through the following contact email: info@privacy.mk or by visiting their website: https://dzlp.mk/prizlnlp .

PRIVACY POLICY CHANGE

The Privacy Policy will be regularly changed and supplemented according to the changes and our activities.

February, 2024