Privacy Policy

Apatinska pivara Apatin d.o.o.


Personal Data Protection Policy


Latest update effective as of: 22 May 2018




Apatinska pivara Apatin d.o.o. (Apatin Brewery) (hereinafter referred to as: APA) values and respects the privacy of each individual. We wish you are informed on the manner we collect, use and store your data.


This Privacy Policy described our procedures related to Data (defined in Section 3) collected on our web pages, social network pages and promotional sites we control, widgets, mobile locations and applications, our prize programs, blogs, interactive applications, by e-mail or text messages (SMS and MMS) we send you and other interactive functions (individually “Location” and jointly “Locations”), through our online ads on third party web pages or through suppliers/sources from which we receive data.


In the context of current law on data protection and privacy, APA legal entity to which you submit your Data, and/or which manages Locations by which you communicate with us shall be the Personal Data handler (defined below) for data collected from you on the Location.


We recommend reading the entire Privacy Policy in order to get familiar with our procedures.




  1. This Privacy Policy applies to data received from individuals in communication with us or our Locations, products or services. It does not refer to data received in the capacity of the employer. During the interaction with our Locations you are not obligated to submit any data, however, if you choose to do so, you may not have access to certain functions of Locations and other services.

    APA locations and access to all advertising or marketing data are intended only to persons older than the legal minimum allowing alcohol consumption in accordance with the legal system where such content is accessed or viewed. You will be obligated to confirm your date of birth before access or interaction with the location. Confirmation windows may also be included within the Location.

    We do not collect data from persons that are under the legal minimum allowing alcohol consumption intentionally and we do not ask such persons to deliver any data (defined below) and access our locations. If you are younger than the legal minimum allowing alcohol consumption and you have assessed our location providing inaccurate date of birth, you must leave the location without delay. If you believe that someone younger than the legal minimum allowing alcohol consumption delivered data by accessing in violation of location access limitations, please contact us without delay and such data will be removed immediately.

  1. Data types: APA collects two types of data (jointly “Data):
    1. “Personal Data” includes data on a person whose identity can be determined in accordance with current laws. This data is usually collected when you open an account, order goods, join the promotion, have interaction over social networks, contact customer services or place an inquiry at the Location. Examples of Personal Data include:
      • Contact data (for example, first and family name, home or physical address, e-mail address, telephone and mobile phone number);
      • Data regarding sending bills and letters (for example, credit/debit card number, expiration date, CCV number, billing address and shipping address and contact data);
      • Username and password used for Location access, including verification through social network platforms;
      • Data related to social network accounts (for example, usernames and passwords, profile images and other images available as content set by the user) and
      • Other Personal Data considered necessary or delivered voluntarily.
    2. “Other Data” includes data collected on Locations, online or from third party sources in which the individual is not specifically identified. Examples of Other Data usually include:
      • Data on web app usage,
      • Data collected through cookies, labels, pixels, transparent pixels, web beacons and other similar technologies,
      • Geographic location data such as precise or approximate location,
      • Landing web pages or existing web pages/URLs (including URLs that forward by click or pixel-plates),
      • Brower and device data (including platform and version)
      • Other group or anonymous data.
  2. How do we collect data: APA may collect data in the following manner:
  • Offline (for example, inquiries to the customer service, prize games)
  • Online monitoring technologies, including cross-monitoring of devices (for example, service log files, IP addresses, labels, pixels, transparent pixels, gifs, bugs, web beacons and other similar technologies, some of which enable APA company or our service providers to identify you and collect data on you using devices and Locations),
  • Using mobile devices (that is, data received from your mobile apps, such as latitude and elevation of your device (for example, GPS, Wi-Fi, Bluetooth signal, web beacons, LED chips or other similar technologies) or payment apps or services from third parties.
  • Through browser or device (for example, certain data, including computer type, operating system name, IP address, media access control address (MAC), language, type and version of the internet browser and service provider that are often automatically collected on most of browsers),
  • Through web page analytics and ad functions (for example, Google Analytics, Google Analytics Demographics, Interest Reporting, Adobe Flash technologies, including, but not limited to locally saved objects Adobe Flash, Quantcast)
  • Other sources (for example, public data bases, mutual marketing partners, social media platforms, from people you are linked to on social networks, public forums and other third parties).
    1. How can we use data: To the extent allowed by current laws APA company may use your data in order to:
  • Send you administrative data such as, for example, data on Locations and conditions, terms and polices amendments
    • Because this data may be important for your use of Locations, you may decide whether you wish to receive these messages;
  • Manage your account on any or our locations, including subsequent programs, prize games and competitions for which you apply, including notification on results
    • We must note that some promotions include additional rules containing additional data on usage and disclosure of your personal data
  • Send you marketing messages and latest information on the APA company for which you applied for, including data on new products, events and promotions (for example, e-mails, push notifications, SMS and MMS),
  • Deliver customized or dedicated ads based on Data we collected from your use of our Locations and ads, Data received from third parties or combination of these sources, including previous purchases and interests,
  • Send you e-mails on transactions referring to purchases on our Locations, including order confirmations and e-mails on forgotten items in shopping carts;
  • Execute your orders and process your transactions/payments;
  • Provide support to customers and respond to your inquiries and meet your demands;
  • Allow interaction or posting on our pages on social networks and blogs, and all similar platforms which you decide to join, with us and other customers. We must note that all data posted or disclosed on these platforms become public data and available to Location visitors and public in general;
  • Enable sending messages to friends (only older than the legal minimum allowing alcohol consumption) through Locations. By using this function, you are telling us that you have the right to use and submit contact data of your friends.
  • Perform marketing research and analysis and for other business purposes to which you consented including but not limited to audit, new product development, communication improvement with you and on our locations, estimated of efficiency of our media purchase, determination of trends and forms related to traffic/downloading and issue detection;
  • Personalize your experience on our Locations, including presenting content based on your location, previous purchase, interests and Data collected from devices and locations, only when you ask for it;
  • Act in accordance with and apply regulated legal provisions;
  • Respond to requests of competent authorities and
  • In another manner regulated by law.


  1. Cookies and tracking technologies. APA company uses “cookies”, “labels”, “pixels”, “transparent pixels” and other similar technologies for tracking on our Locations. Cookie is a textual file installed on your computer or other mobile device when you access Locations or the Internet. These technologies enable APA to collect data on your interaction with our Locations and ads. Examples of such data may include, but are not limited to: demographic data, browser type, IP address, viewed pages, activities performed and time of visit. At any time, you have the option to log out from certain tracking mechanisms through browser settings. However, disabling these functions may prevent you from using certain functions or completely benefiting from our offers on Locations.

    Different forms of cookies are used for different purposes on our Locations, and they are known as: strictly required cookies, performance cookies and functionality cookies. Some cookies may be set by third parties in order to add new function on our Locations and they are described below.




    Strictly required cookies

    These cookies are necessary for actions you required, such as logging confirmation. If you prevent these cookies by setting your browser, we cannot guarantee the performance of our Locations during your visit.

    Performance cookies

    These cookies are used to improve our Locations, for example, for analytics purposes that enables us to see how our Location is used and where can we improve. These cookies are used to collect data on how the visitors use our Locations. Data is collected in anonymous format and include the number of visitors, where do they access the Location from and pages visited.

    Functionality cookies

    These cookies improve operation and functionality of our Locations, often as the result of something you as a user do. For example, we can personalize our content for you or remember your preferences.

    APA company, our reliable suppliers/service providers and approved third parties may also advertise our products on third party web pages. Third party web pages may also include cookies or other tracking means. APA company, our reliable suppliers/service providers and approved third parties shall have no control over the tracking technologies use don third party web pages. Because of this, read carefully privacy policies of these third parties in order to understand their tracking activities, if any.

  2. Request not to track. We will automatically collect cookies and other data when you visit the Location. Due to this automatic collection we are currently not accepting browsers with requests not to track. Currently we are participating in advertising networks of third parties and we use third party cookies in a manner explained above in order to track your visits on different web locations.

    For details on how to log out in order to prevent collection of your data by tracking means see section “Selection/Sign out” below.

  3. Disabling cookies on your browser. On our Locations you may reject or erase cookies. See help manual on your browser in order to learn more about cookies and other tracking means and how to manage them. If you select to reject or erase cookies some of the functions of our Locations will be impaired. If you use another computer or change the browser, you will have to repeat the procedure of cookie rejection or erasure. More information on cookies, including setting your internet browsers in order to reject cookies may be found at:
  4. Tracking ads. Certain tools may enable limiting tracking ads. See settings on your computer or device for more information on how to turn off ad tracking.




    In some cases, we may use a third-party payment service for shopping processing on Locations, including, but not limited to, reservation sites and e-shops, on which you shall be notified. In such cases, your Data may be collected by such third party and not us, and such Data will be handled in accordance with privacy policy of such third party, not this Privacy Policy. We do not have control or liability for the manner such third party uses or discloses your Data.




In some cases, APA company may make certain Data available to third parties.

For example, APA may share information collected on you:

  • In accordance with the law, in case of an investigation or similar legal proceedings




    APA may collect information on physical location of your device using, for example, satellite, GPS, mobile telephony transmitters, towers or Wi-Fi signal. Once you provide consent we can use the physical location of your device in order to enable services and content customized to your location, including ads. We can also share the physical location of your device in combination with data on which ads you viewed or other data we collect, with our marketing partners in order to enable delivery of personalized content, including ads and ad campaign efficiency analysis. In some situations, you may be allowed to accept or deny this type of use and/or sharing location of your device, but if you decide to reject such use and/or sharing or the location of your device, we and/or our marketing partners may not be able to send you appropriate personalized services and content. If you withhold your consent, this location is collected anonymously in the form that does not identify you personally. For example, when you download APA Location (including mobile app) on your device, you may have the option to state whether you would like to share your location.

    Information on logging out from services based on location may be found in Settings on your device.




    Security, integrity and confidentiality of your data is extremely important to us. APA applies measures of administrative, technical and physical protection of Data we have on you in order to use them in accordance with this Privacy Policy. However, please be aware that despite our best effort there are no perfect or impenetrable security measures. If you have any reason to believe your Personal Data is not secured, please contact us in accordance with Section 15 below.


    When you post content on social networks or other public platforms, Data you share is visible to other users and they can read, collect and use them. APA is not responsible for Data you share voluntarily or post on such platforms. For example, if you post your first and family name on a social network location, or your age and address, such Data is public.


    We will store your Personal Data as long as it is reasonably necessary for the purpose for which it was collected and, in a manner described in this notification. In some circumstances we may store your Personal Data for a longer period of time, for example, when necessary in pursuant to legal and regulatory obligations.




    Data you post, or data collected may be transferred in accordance with the law.

    More information on the manner we transfer Personal Data in accordance with relevant EU data protection laws may be found in “Additional Data for EU Residents” section.




    On certain Locations we may enable online access to communities for sharing Data in the form of messages, photos and videos. This Data may be shared only with persons older than the minimum limit for alcohol consumption in accordance with regulations in the legal system from which such Location is accessed. We may also enable posting content from some Locations on your social network profile. We must note that all content posted or shared on such Location will be subject to privacy policy of that social network. Also, when you post or share content or communication from our Locations with any third-party social network, in this manner you enable us to share Data with this third-party social network.


    We cannot control policy or terms of such third-party social network. For example, sharing such Data with Facebook may lead to us having to use cookies and/or APIs to enable communication between our Locations and Facebook. Such Data shared by cookies and/or APIs then become subject to Privacy Policy of Facebook that can be found at As a result of that, we cannot be responsible for any misuse of your Data or content on the third-party social network, you use at own risk.




    Our Locations may contain links to third-party web pages or apps not controlled by APA which are not subject to this Privacy Policy. If you submit Data on any of these web pages, your Data shall be subject to their Privacy Policy. We encourage you to carefully read privacy policies of all web pages or apps you visit. We do not have control or the authority over third-party locations and we are not responsible for any Data submitted on such locations.


    We must note that if you submit Data to us by social media or you are active on social network locations that are linked to our Locations, in this manner you consent to us using your Data for any reason and in the same manner as if you submitted it directly through the Location.




    Our Locations may include interactive programs enabling certain services of other companies, such as “liking” or sharing content often called widgets. You may have the option to submit Data such as our e-mail address for widget collection. Widget may also use cookies and/or collect usage data. Data collected by widgets are subject to privacy policies of companies that created such widgets.




  1. Privacy Inquiries


    If you have any questions or comments regarding this Privacy Policy, or if you would like to review, update, correct or remove any Personal Data from our records, please contact us using information below. Once we have received your removal request, we will remove your personal data from our records if we do not have certain legal obligations to store your personal data.


    Apatinska pivara Apatin d.o.o.

    5 Trg Oslobodjenja Street

    25260 Apatin, Serbia



    E-mail communication is not always secure; thus, we advise against sending sensitive data, including credit card data in e-mails.


    We will use our best effort to respond to your requests in the shortest possible term in accordance with the law.


  2. Updating e-mail addresses


    If you wish to remove your e-mail address from our records, please follow the sign out instructions from e-mail messages you receive from us and follow the procedure described in sub-section A above.


  3. Updating information related to mobile marketing (SMS and MMS)


    If you choose to be on the mobile marketing list, be aware that there usually are costs of messages and data transfer related to reception of SMS (text) and MMS (multimedia). They shall differ depending on the mobile operator and rate plans. You should check the costs with your operator before you apply for mobile device updating system. If you wish to stop receiving messages from us on your mobile phone, respond to a message with STOP (or other type of message if necessary). You may also contact your mobile operator for additional data on reception or termination of receiving messages on your mobile device.


  4. Location services


    If you previously selected that your computer or mobile device may send data location, you may have the option to sign out and prevent us from acting on such data by changing the settings on your computer or mobile device or by erasing the application.


  5. Push notifications


    If you wish to disable push notifications on your mobile device see settings on your mobile device.


  6. Third-party analytics
  1. Google Analytics: For more information on how to sign out in order to prevent the use of Google Analytics or its advertising functions visit and,
  2. Quantcast: More information and instructions on how to sign out from Quantcast may be found on their web site
  3. DAA sign out page: Users may sign out from the option of additional monitoring and target marketing. Including Google Analytics and Quantcast, using the sign out page of the Digital Advertising Alliance (DAA) and Network Advertising Initiative (NAI) at or


Your use of Locations and continued use of Locations after the amendments of this Privacy Policy implies that you agree with provisions and terms of this Privacy Policy. If you disagree with the terms of this Privacy Policy, please do not use Locations or submit Data to us.


We may update this Privacy Policy periodically by publishing amendments on this page, therefore, we encourage you to periodically review this Privacy Policy.


We shall take two steps to keep you updated with amendments: (i) at the heading we shall state the date when Privacy Policy was updated last, (ii) when we perform significant amendments of the Privacy Policy we will place a visible announcement on such amendments on the first page of the Location next to the link to this Privacy Policy or we shall send an e-mail to all users whose Personal Data are held by the APA company (or appropriate business unit). Your use of the Location after the publication of amended Privacy Policy shall be considered the acceptance of such amended policy hence we recommend periodical review of the Privacy Policy.