This Privacy Policy explains how BlackBee Agency collects, uses, shares and protects personal data when you visit www.blackbeeagency.com (the “Website”), submit one of our forms, or otherwise contact us. It is written to meet the requirements of the Serbian Law on Personal Data Protection (Official Gazette of RS, No. 87/2018, the “ZZPL”) and, where it applies to you, the EU General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the UK GDPR.
1Who we are (data controller)
The controller of your personal data is:
- Controller
- BRANKO VOJNOVIĆ PR ODŽACI, trading as BlackBee Agency
- Registered address
- Somborska 61, 25250 Odžaci, Republic of Serbia
- Company registration number (MB)
- 68726387
- Tax identification number (PIB)
- 115894466
- Registered with
- The Serbian Business Registers Agency (APR)
In this policy, “BlackBee”, “we”, “us” and “our” mean this entity. We have not appointed a Data Protection Officer because the law does not require one for our activities. All privacy requests are handled by the founder and can be sent to info@blackbeeagency.com.
2Scope
This policy covers personal data of:
- visitors to the Website;
- people who submit the Free Marketing Audit, Get a Quote or Partner Application forms;
- people who contact us by email;
- representatives of prospective clients and partners.
It does not cover personal data we process on behalf of our clients during a paid engagement (for example, data inside a client’s ad accounts or customer lists). In those cases the client is the controller, we act as a processor, and the processing is governed by our service agreement and data processing terms with that client.
Our services are intended for businesses. The Website is not directed at children, and we do not knowingly collect data from anyone under 16.
3What data we collect
a) Data you give us through our forms
| Form | Data collected |
|---|---|
| Free Marketing Audit | Store or website URL, work email, phone number (optional), monthly ad spend range, advertising channels you use, and any notes you write |
| Get a Quote | Store or website URL, work email, phone number (optional), monthly ad spend range, advertising channels you use, and any notes you write |
| Partner Application | Agency or company name, your name, work email, website, partnership track, and any notes you write |
Please do not include sensitive personal data (such as health, political or religious information) or passwords in the free-text fields.
b) Data you give us by email or during our communication
Such as your name, job title, company, phone number, and the content of our correspondence.
c) Account access data
If you choose to grant us read-only access to your advertising or analytics accounts for an audit or quote, we will see the business data in those accounts and the names or emails of users connected to them. We use this access only to prepare your audit or quote. We never ask for your passwords; access is granted through each platform’s own user-permission tools, and you can revoke it at any time.
d) Technical data collected automatically
When you visit the Website our hosting provider processes your IP address, browser type, device information, requested pages, date and time, and referring URL in server logs, for security and to deliver the Website. Our forms also record the time taken to fill them in and contain a hidden anti-spam field; these are used only to block automated submissions.
e) Cookies and similar technologies
See Section 9.
4Why we use your data and our legal basis
| Purpose | Legal basis (ZZPL Art. 12 / GDPR Art. 6) |
|---|---|
| Responding to your audit, quote or partnership request and preparing the audit, quote or proposal | Taking steps at your request before entering into a contract; our legitimate interest in responding to business enquiries |
| Communicating with you about your request and any follow-up you ask for | Pre-contractual steps; legitimate interest |
| Entering into and performing a contract with your company | Performance of a contract; legitimate interest (where you are an employee or representative of the contracting company) |
| Operating, securing and improving the Website, and preventing spam and abuse | Legitimate interest |
| Analytics and advertising measurement with cookies (GA4, Meta Pixel) | Your consent, which you can withdraw at any time |
| Keeping accounting and tax records | Legal obligation |
| Establishing, exercising or defending legal claims | Legitimate interest |
Where we rely on legitimate interest, we have balanced our interest against your rights. You can object at any time (Section 8).
We do not add you to newsletters or automated email sequences. If we ever wish to send you marketing emails, we will ask for your consent first or rely on an existing business relationship where the law allows, and every message will include a way to opt out.
We do not make decisions about you based solely on automated processing, including profiling, that produce legal or similarly significant effects.
5Who we share your data with
We do not sell your personal data. We share it only with:
| Recipient | Role | Location |
|---|---|---|
| Vercel Inc. | Website hosting and form processing | USA; Website served from EU (Frankfurt) region |
| Resend (Plus Five Five, Inc.) | Delivery of form submissions by email | USA |
| Google LLC / Google Ireland Ltd (Gmail, Google Workspace) | Email inbox and storage of form submissions and correspondence | USA / EU |
| Google LLC (Google Analytics 4) | Website analytics, only with your consent | USA / EU |
| Meta Platforms Ireland Ltd / Meta Platforms, Inc. (Meta Pixel) | Ad measurement and audiences, only with your consent | EU / USA |
| Zenith Digital | Our fulfilment partner for Web Design & CRO and SEO & GEO; receives your data only if your request concerns those services and only as needed | Serbia |
| Accountants, lawyers and professional advisers | Bound by confidentiality | Serbia |
| Public authorities | Only where required by law or a binding order | Serbia |
Our service providers act on our instructions and are bound by confidentiality and data protection obligations.
6International transfers
We are based in Serbia, and some providers above are based in or access data from the United States and other countries. When data leaves Serbia or the EEA/UK, we transfer it only where the recipient country has been recognised as providing adequate protection, the recipient is certified under the EU-U.S. Data Privacy Framework (for transfers subject to GDPR), or appropriate safeguards are in place, such as standard contractual clauses adopted by the Serbian Commissioner for Information of Public Importance and Personal Data Protection or by the European Commission. You can ask us for information about these safeguards.
7How long we keep your data
| Data | Retention |
|---|---|
| Form submissions and emails that do not lead to a contract | Up to 24 months after our last contact, then deleted |
| Data about clients and partners | For the duration of the relationship and up to 5 years afterwards, to handle claims |
| Invoices and accounting records | As long as Serbian accounting and tax law requires (currently up to 10 years) |
| Read-only access to your ad and analytics accounts | Until the audit or quote is delivered; we ask you to revoke it, and we remove ourselves if you have not done so within 30 days |
| Audit notes and screenshots of your accounts | Up to 12 months after delivery, unless you become a client |
| Server logs | According to the hosting provider’s standard log retention (typically days to weeks) |
| Cookies | See Section 9 |
8Your rights
Subject to the conditions set by law, you have the right to:
- access the personal data we hold about you and receive a copy;
- rectify inaccurate or incomplete data;
- erase your data (“right to be forgotten”);
- restrict processing;
- data portability, where processing is based on consent or a contract and is carried out by automated means;
- object to processing based on legitimate interest, and to direct marketing at any time;
- withdraw consent at any time, without affecting processing carried out before withdrawal (for cookies, use the cookie settings link in the Website footer).
To exercise these rights, email info@blackbeeagency.com. We may need to verify your identity. We respond within 30 days; this can be extended by 60 days for complex requests, and we will tell you if it is.
You also have the right to lodge a complaint with a supervisory authority:
- in Serbia: the Commissioner for Information of Public Importance and Personal Data Protection (Poverenik), Bulevar kralja Aleksandra 15, 11000 Belgrade, www.poverenik.rs;
- if you are in the EU/EEA or the UK: the data protection authority in your country of residence, place of work, or place of the alleged infringement.
We would appreciate the chance to address your concern first, so please contact us before going to an authority.
9Cookies and similar technologies
We use strictly necessary cookies and local storage to operate the Website and remember your cookie choices. These do not require consent.
With your consent only, we use:
| Tool | Provider | Purpose | Typical cookies and lifetime |
|---|---|---|---|
| Google Analytics 4 | Measuring visits, traffic sources, and how pages are used | _ga, _ga_*: up to 2 years | |
| Meta Pixel | Meta | Measuring ad performance and building advertising audiences | _fbp: 90 days; _fbc: 90 days |
These tools are not loaded until you accept them in our cookie banner. You can change or withdraw your choice at any time through the “Cookie settings” link in the footer, and you can delete cookies in your browser settings. If you decline, the Website still works fully.
When the Meta Pixel is active, Meta and BlackBee are joint controllers for collecting and transmitting the data to Meta. Meta is responsible for its further processing. See Meta’s Privacy Policy at facebook.com/privacy/policy and Google’s at policies.google.com/privacy.
10Security
We use appropriate technical and organisational measures: encrypted connections (HTTPS/TLS), two-factor authentication on the accounts that store your data, access limited to the people who need it, read only permissions for client accounts, and anti-spam controls on our forms. No method of transmission or storage is completely secure. If a personal data breach is likely to put your rights at risk, we will notify the competent authority and, where required, you, within the time limits set by law.
11Third-party links
The Website links to third-party sites, such as our partner Zenith Digital and review platforms. We are not responsible for their privacy practices. Please read their policies.
12Changes to this policy
We may update this policy from time to time. The “Last updated” date shows when it last changed. Material changes will be highlighted on the Website.
13Contact
Questions or requests: info@blackbeeagency.com, or by post to BRANKO VOJNOVIĆ PR ODŽACI, Somborska 61, 25250 Odžaci, Republic of Serbia.