Privacy Policy — Dopuni Se
Dopuni Se DOPUNI SE

Privacy Policy

Effective from 02.09.2026.

This document was originally drafted in Serbian. In the event of any discrepancy between language versions, the Serbian version shall prevail and is considered legally binding. The mobile information and SMS provisions in Sections 4, 5, and 5.1 are aligned between the Serbian and English versions.

1. Introduction

This Privacy Policy aims to explain how and why DOPUNI SE DOO Belgrade ("DOPUNI SE"), as the data controller, processes your personal data and the measures taken to keep your data safe and protected. Personal data processing is carried out in accordance with the Law on Personal Data Protection of the Republic of Serbia. By accepting this Privacy Policy, you consent to the use of your personal data under the conditions set forth in this Policy. DOPUNI SE processes information about you for the purpose of normal application functioning. The information we hold and process will be used only for our management and administrative purposes. We will retain and use it to enable us to manage our business and our business relationship with you efficiently, lawfully, and appropriately.

2. Data Controller

  • Registered business name: DOPUNI SE DOO Belgrade (DOPUNI SE)
  • Address: Nikolaja Gogolja 94, 11000 Belgrade
  • Registration number: 21942804
  • Tax ID: 113905911
  • Contact: info@dopuni.se

3. Legal Basis for Processing

Personal data is processed exclusively when there is a legal basis: legal obligation, contractual relationship, user consent, protection of the user's vital interests, legitimate interest, and exercise of legally prescribed powers.

We process your personal data when such processing is necessary to conclude and execute a contract with you (Terms of Use). We may process your personal data if required by law. We may also process your personal data if processing is necessary to protect your vital interests. If we process your personal data based on our legal obligations or to protect your vital interests, we will inform you accordingly. We may also process your personal data to pursue our legitimate business interest. We use only personal data necessary for a specific purpose and always strive to limit processing to what is necessary for that purpose. The purpose of processing your personal data is registration on the Dopuni.se Application and use of all its benefits. By accepting the Terms of Use, you enter into a contract with us. We process your personal data for the purpose of concluding and executing that contract.

In addition, we may process your personal data to send you newsletters with information about special offers. When sending newsletters, we will do so either based on your consent or relying on our legitimate interest.

Legitimate Interest of the Controller

To achieve our business purpose, we process your personal data based on legitimate interest. Of course, we only do this if your interest or your fundamental rights and freedoms do not outweigh our legitimate interest. We use legitimate interest to:

  • Maintain your user account, respond to your requests and possible complaints;
  • Promote and market our products and services;
  • Protect the rights, property, or safety of our members or other persons;
  • Protect our business and support our partners and colleagues;
  • Identify and prevent fraud and other illegal activities;
  • Test and develop new services and products or improve existing ones.

At any time, you can object to such processing of your personal data based on our legitimate interest by sending an email to: info@dopuni.se.

4. What Personal Data Do We Process About You?

Personal data you provide to us:

1. Registration

  • Username, Full name, Email, Phone number, Gender, Date of birth

We process your personal data for registration purposes in order to provide you with the Services of the Dopuni.se Application.

2. Use of the Dopuni.se Application

If you choose to use paid Services that require a payment method, payment details may be requested and processed by our payment service provider, including the card number, cardholder name, issuing company name, card expiry date, and CVC/CVV code.

3. Information About Your Transactions

We process data about transactions you make through the Dopuni.se Application, including the time of your transaction and the usage fee.

4. Messaging Information

For SMS OTP communications, we process your mobile phone number, records of OTP requests and verification attempts, SMS opt-in or opt-out status and messaging consent information where applicable, and technical message delivery information. We use this information only to send requested OTPs for account registration, sign-in, and phone-number verification, secure accounts, maintain consent and opt-out records, provide support, prevent fraud, and monitor message delivery. We do not use SMS opt-in information or messaging consent data for marketing or promotional purposes.

5. Recipients of Personal Data

Your personal data may be shared internally where necessary for the operation and maintenance of the Dopuni Se Application. DOPUNI SE DOO Belgrade ("DOPUNI SE") may also disclose personal data, where necessary and permitted by applicable law, to service providers and professional advisers acting on our behalf, including subcontractors, external consultants, lawyers, accountants, commercial banks, payment service providers, hosting and technology providers, and communications providers.

We may also disclose personal data where required by law, pursuant to a court or governmental order, or where reasonably necessary to protect the life, safety, rights, or property of DOPUNI SE, our users, or other persons.

Notwithstanding the above, mobile phone numbers, SMS opt-in information, and messaging consent data are not shared, sold, rented, or otherwise provided to third parties or affiliates for their marketing or promotional purposes.

Where mobile information is provided to contracted service providers acting as processors on behalf of DOPUNI SE for SMS delivery, authentication, security, hosting, or technical operation of the service, those providers may process such information solely to provide the contracted services to DOPUNI SE and not for their own purposes or for marketing or promotional purposes.

Recipients processing personal data on our behalf are required to implement appropriate technical, organizational, and personnel measures to protect personal data and users’ rights, and appropriate data processing agreements are entered into where required.

5.1. Mobile Information and SMS Communications

We use your mobile phone number only to send user-requested one-time passcodes (OTPs) for account registration, sign-in, and phone-number verification, including resends you request. We do not use this SMS program for rental, payment, account-notification, promotional, or marketing messages.

Messages are sent only after you request a code. Message frequency varies based on your requests; generally, one SMS is sent per successful request and per resend you request. Message and data rates may apply.

You may opt out of SMS communications, where applicable, by replying STOP to an SMS message. You may request assistance by replying HELP or by contacting us at info@dopuni.se.

We do not share, sell, rent, or provide your mobile phone number, SMS opt-in information, or messaging consent data to third parties or affiliates for their marketing or promotional purposes.

We may disclose mobile information to contracted telecommunications, messaging, authentication, security, hosting, and technical service providers acting as processors on our behalf only where necessary to deliver and protect the requested OTP service. Such providers may process this information solely to provide the contracted services to DOPUNI SE and may not use it for their own purposes or for marketing or promotional purposes.

Consent to receive SMS messages is not a condition of purchase. However, completing a phone-based registration, sign-in, or phone-verification flow requires receiving and entering the requested OTP. Other authentication methods may be available where offered in the Application.

6. We Do Not Knowingly Collect Data from Minors Under 15

The Dopuni.se Application is not intended for minors under fifteen (15) years of age. We do not knowingly collect personal data from minors below this age and will delete any data subsequently found to belong to a minor under 15, unless we have obtained consent from the parent or guardian of such minor. If a parent or guardian believes their child has provided information through the Dopuni.se Application and wishes to have that data removed or corrected, please contact DOPUNI SE at: info@dopuni.se.

7. Retention Period

We retain your personal data for as long as you have an account on the Dopuni.se Application and for a certain period thereafter to allow members to recover their accounts.

8. Accuracy and Security

We will take reasonable steps to ensure that the personal data we process is reliable for its intended use, accurate, complete, and up to date. You are responsible for the accuracy of all personal data you provide to us. We will make reasonable efforts to maintain the accuracy and integrity of the personal data obtained and to update it as needed. DOPUNI SE prioritizes personal integrity and therefore actively works to ensure your personal data is processed with the utmost care. DOPUNI SE takes appropriate security measures to protect your personal data from unauthorized access and disclosure. We implement appropriate physical, procedural, technical, organizational, and personnel measures to achieve an adequate level of protection for the personal data we process. Protection covers loss, misuse, unauthorized access and disclosure, alteration, and destruction of such personal data.

9. User Rights

You may exercise certain rights against DOPUNI SE in relation to the personal data we process about you. You can submit a request to exercise these rights at any time.

  • Information: the right to be informed about how we process your personal data;
  • Access: the right to request access to all your personal data we process. If you submit the request electronically, the information is provided in a commonly used electronic format, unless you request otherwise;
  • Rectification: the right to request that inaccurate or incomplete personal data about you be corrected without delay. Please inform us if you change your personal data or if you learn that any personal data we hold is inaccurate or incomplete;
  • Erasure: the right to request that your personal data be deleted without delay (subject to limitations imposed by law);
  • Restriction: the right to request restriction of processing of your personal data in certain situations;
  • Objection: the right to object to specific personal data processing. This includes direct marketing, processing for scientific or historical research purposes, or for statistical purposes;
  • Portability: the right to request that we transfer this data to another company, if processing is based on consent or on a contract and processing is carried out by automated means.

If you believe that any of the above rights has been denied to you, or that we are processing your personal data in violation of the law, please contact us at: info@dopuni.se. At any time, you may file a complaint with the Commissioner for Information of Public Importance and Personal Data Protection.

10. Consent and Withdrawal of Consent

You may withdraw your consent to the processing of your personal data that you have given us at any time. We will immediately respond and stop processing those personal data. This right is free of charge. You can send your consent withdrawal request to: info@dopuni.se.

11. Contact

For questions, personal data matters, or additional information about the handling of personal data, please contact: info@dopuni.se.

Effective from 02.09.2026.