Privacy policy

The protection of the privacy and confidentiality of the data of customers and employees is of the greatest importance for the Gold and Silver Trading Company INVEST METAL DOOEL Skopje (hereinafter: INVEST METAL), taking into account the nature of the company's operations as well as the data that we collect them in the current operation.

The privacy policy of INVEST METAL DOOEL Skopje aims to explain the process of collection, use, processing, disclosure, protection and destruction (the "life cycle") of the personal data it processes.

INVEST METAL DOOEL Skopje carries out any activity related to personal data in accordance with the provisions of the Law on the Protection of Personal Data and the by-laws adopted on the basis of this Law, as a legal framework that implements the general Regulation of the European Union on data protection (English: "EU General Data Protection Regulation (GDPR)").

For the purposes of personal data protection, INVEST METAL DOOEL Skopje has appointed a Personal Data Protection Officer (whose contact details can be found below in this Policy), whom subjects can contact for issues related to the processing of their personal data and for the exercise of their legal rights. In addition, protection of the privacy and confidentiality of the data of INVEST METAL DOOEL Skopje customers is part of the Privacy Policy, the provisions of which are mandatory for all employees of INVEST METAL DOOEL Skopje.

1. THE ROLE OF INVEST METAL DOOEL SKOPJE ACCORDING TO THE LAW ON THE PROTECTION OF PERSONAL DATA

INVEST METAL DOOEL Skopje, in accordance with the provisions of the Law on the Protection of Personal Data, is the Controller of Personal Data, i.e. a legal entity that determines the purposes and method of processing the personal data of the subjects of personal data.

2. BASIC PRINCIPLES

As a controller, INVEST METAL DOOEL Skopje ensures the protection and processing of personal data in accordance with the applicable legal framework, which it follows on a regular basis and for this purpose ensures that the subjects' personal data is processed in accordance with the following principles:

- Legality, fairness and transparency – personal data are processed in accordance with the law, to a sufficient extent and in a transparent manner in relation to the subject of the personal data;

- Limitation of purposes – personal data is collected for specific, clear and legitimate purposes determined by law and will not be processed in a way that is inconsistent with those purposes;

- Minimum amount of data – the personal data that are processed are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. This principle is also relevant in relation to access to the personal data being processed;

- Accuracy – personal data are accurate and, where necessary, updated, taking all appropriate measures to promptly delete or correct data that is incorrect or incomplete;

- Limitation of the storage period – personal data is stored in a format that allows the identification of the subjects of the personal data, no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored longer than their storage period if they are processed only for the purposes of archiving in the public interest, for scientific or historical research or for statistical purposes in accordance with the law, and by applying appropriate technical and organizational measures for the protection of rights and the freedoms of the subject of personal data;

- Integrity and confidentiality - personal data are processed in a way that ensures an adequate level of personal data security, including protection against unauthorized or illegal processing as well as their accidental destruction or damage, by applying appropriate technical or organizational measures; and

- Principle of accountability - INVEST METAL DOOEL Skopje is responsible for compliance with the above principles and can demonstrate compliance at any time, especially at the request of external verifiers, the Personal Data Protection Officer or the Personal Data Protection Agency .

The above principles of processing are applied cumulatively, all together during the overall cycle of personal data processing.

3. CATEGORIES OF PERSONAL DATA PROCESSED BY INVEST METAL DOOEL Skopje

INVEST METAL DOOEL Skopje processes personal data of users when selling precious metals, our associates and employees of INVEST METAL DOOEL Skopje as subjects of personal data.

The main source of personal data of INVEST METAL DOOEL Skopje is the personal data that the subjects of personal data submit to us when purchasing the precious metals.

We note that INVEST METAL DOOEL Skopje processes personal data only to the extent necessary for the purposes of processing.

In particular, INVEST METAL DOOEL Skopje can process the following personal data:

Personal data submitted by subjects when purchasing precious metals (gold, silver), i.e.: identification data (name and surname, EMBG), residential address and contact data (email and phone)

Personal data submitted by our associates during the performance of contractual or pre-contractual activities, i.e.: name and surname of manager, tax and identification number of a legal entity, contact data and other data required for the performance of contractual or pre-contractual activities in accordance with the Law on Bonds relationships.

Subjects of personal data are obliged to immediately notify INVEST METAL DOOEL Skopje of any change in the above data.

Personal data collected by INVEST METAL DOOEL Skopje are for different purposes:

- personal data for fulfilling legal obligations

- personal data related to business cooperation;

- personal data required for communication during business cooperation

- personal data to answer your request, question or complaint

- personal data for using our services

- in accordance with the applicable legal framework for providing data to state authorities;

- when performing marketing activities or direct marketing

- in the context of general customer communication with INVEST METAL DOOEL Skopje via e-mail/telephone

- "cookies" and associated technologies that enable access and use of our website;

- data that concern customers and that are publicly available via the Internet or in another way;

- data on employees in INVEST METAL DOOEL Skopje, persons who do internship or volunteer work in INVEST METAL DOOEL Skopje in accordance with the valid legal framework in this area (Law on Records in the Field of Labor, Law on Labor Relations and others) explained in more detail in Annex 1 of this Policy;

- data on candidates for employment in INVEST METAL DOOEL Skopje explained in more detail in Annex 2 of this Policy;

- the personal data collected when using the website of INVEST METAL DOOEL Skopje, explained in more detail in Annex 3 of this Policy.

Personal data processed by INVEST METAL DOOEL Skopje are stored in paper and electronic form.

4. PURPOSES OF PERSONAL DATA PROCESSING

INVEST METAL DOOEL Skopje processes the personal data of the subjects that are collected during the establishment / extension of the business relationship with INVEST METAL DOOEL Skopje, for the following purposes:

A. Before buying precious metals:

1. to fulfill a legal obligation

2. to confirm the identity of the client;

3. to communicate with customers when taking pre-contractual actions or for issues related to the business relationship with INVEST METAL DOOEL Skopje.

4. to prepare, conclude and manage the Agreement concluded with INVEST METAL DOOEL Skopje and to take actions for the fulfillment of obligations to customers as well as for the purpose of execution, management, monitoring and processing of customer transactions, i.e. to ensure that the required service or product from INVEST METAL DOOEL Skopje;

5. to evaluate the suitability for offering a service.

B. In the context of the legal and current operation of INVEST METAL DOOEL Skopje and the protection of its rights and legal interests, in particular:

1. to develop and/or improve the advertising and marketing services offered by INVEST METAL DOOEL Skopje in relation to customer preferences;

2. to respond to requests, questions or complaints from customers;

3. to assess and manage the risks related to the operation of INVEST METAL DOOEL Skopje;

4. to pursue his legal claims before judicial authorities or other bodies for out-of-court/alternative dispute resolution,

5. to evaluate and optimize security procedures, IT systems, etc.

G. Based on consent given:

1. to send information about the products sold by INVEST METAL DOOEL Skopje that correspond to the interests and preferences of customers through several channels:

i. directly to INVEST METAL DOOEL Skopje

ii. over the phone

iii. via email

2. to keep the CV of a candidate for employment for longer than 12 months

Regarding the above, we note that consent is not required in the following cases:

• for recording/using identification data such as the identification number in accordance with the legal obligations of INVEST METAL DOOEL Skopje

• for the execution of a contract concluded with INVEST METAL DOOEL Skopje or for the purpose of undertaking the necessary activities in connection with the Request submitted by the client before entering into the contract;

• to fulfill the legal obligation of INVEST METAL DOOEL Skopje as a controller;

• to protect the essential interests of clients or another person;

• for the execution of works of public interest; and

• when the processing is necessary for the purposes of the legitimate interests of INVEST METAL DOOEL Skopje or of a third party, except when such interests do not prevail over the interests or fundamental rights and freedoms of the subjects that require the protection of personal data.

INVEST METAL DOOEL Skopje applies appropriate measures to protect the rights and freedoms and legitimate interests of the subjects of personal data, and at least the right to ensure human intervention by INVEST METAL DOOEL Skopje, the right to express a personal opinion and the right to contest such a decision. Such type of Decisions are not based on special categories of personal data, except in the cases allowed by the Law on Protection of Personal Data.

5. USERS TO WHOM INVEST METAL DOOEL SKOPJE MAY DISCLOSE THE PERSONAL DATA OF THE SUBJECTS

INVEST METAL DOOEL Skopje discloses personal data to public authorities in accordance with their legal powers.

More specifically, INVEST METAL DOOEL Skopje can disclose the personal data of the subject of the personal data only if it is obliged according to the law, a decision of a competent authority or to third parties, i.e. to the following category of users of personal data: state authorities or legal entities established by the state for the exercise of public powers, agency or other bodies as well as third parties (natural or legal persons) who act by order or on behalf of INVEST METAL DOOEL Skopje, such as:

1. third parties (natural or legal persons) who cooperate with INVEST METAL DOOEL Skopje in any form, acting on behalf and on behalf of INVEST METAL DOOEL Skopje, in order to achieve the purpose of processing the contract, including the following categories:

2. Companies - suppliers of information technology equipment;

3. Agencies for securing persons and property with access to video surveillance or access to our client's address for safe transportation of products;

4. Consulting companies, including financial advisors and auditors;

5. Companies - data providers;

6. Social security authorities, public institutions and public companies;

7. State institutions and inspections such as the Labor Inspectorate and the State Market Inspectorate;

8. Financial institutions, Public Revenue Administration and other state institutions

9. Lawyers, bailiffs and notaries

10. Banks

11. Supervisory, judicial, independent and other authorities at the national and European level for the purpose of fulfilling the legal obligations of INVEST METAL DOOEL Skopje ordered according to the current regulation or by a court decision;

12. Authorized auditing companies.

INVEST METAL DOOEL Skopje cooperates only with third parties who can implement appropriate technical and organizational measures in accordance with the regulations and standards of INVEST METAL DOOEL Skopje, thereby enabling adequate protection of personal data. In such cases, third parties (processors of personal data) are bound by a specific Personal Data Processing Agreement which ensures that personal data is processed only in accordance with the instructions given by INVEST METAL DOOEL Skopje and in compliance with protective technical and organizational measures with which ensures the security of personal data.

6. THE RULES APPLICABLE TO THE TRANSFER OF PERSONAL DATA OF SUBJECTS TO OTHER COUNTRIES (CROSS-BORDER TRANSFER)

INVEST METAL DOOEL Skopje may transfer the personal data it processes in accordance with the provisions of the Law on Personal Data Protection.

INVEST METAL DOOEL Skopje, if necessary, for example for the purpose of implementing an Agreement for the use of services by external persons when the service provider is an external person from abroad, may carry out the transfer of personal data to other countries that are members of the EU or the EEA and informs the Personal Data Protection Agency about it in accordance with the Law on the Protection of Personal Data and the legal rules for the transfer of personal data in the European Union. INVEST METAL DOOEL Skopje also has the right to transfer personal data to other countries that are not members of the EU or the EEA, after prior approval for the transfer of personal data from the Agency for the Protection of Personal Data, i.e. after receiving a decision on suitability from by the Agency if it has assessed that the third country provides an adequate level of personal data protection.

INVEST METAL DOOEL Skopje does not carry out transmission outside the borders of the Republic of North Macedonia.

7. THE TIME PERIOD OF STORAGE OF THE PERSONAL DATA OF THE SUBJECTS AND THE STATUS OF THE PERSONAL DATA AFTER THE EXPIRY OF THE TIME PERIOD

The basic principle regarding the storage of personal data is that INVEST METAL DOOEL Skopje keeps them no longer than is necessary for the purposes for which they are processed. The retention period is often related to the basis for which the personal data is processed. For example, if the processing of personal data is required to fulfill a legal obligation, the storage period is often determined in the specific law.

After the expiration of the data storage period, INVEST METAL DOOEL Skopje destroys the data in accordance with the appropriate Document Destruction Procedure, observing the provisions of the applicable regulation on document archiving and destruction. It also ensures that such a process is observed by third parties who provide services on behalf and on behalf of INVEST METAL DOOEL Skopje and other business associates.

8. RIGHTS OF PERSONAL DATA SUBJECTS

Subjects of personal data have a certain set of rights determined by the Law on Protection of Personal Data, which are explained below.

- Right to information (Articles 16, 17 and 18 of the Law)

INVEST METAL DOOEL Skopje informs the subjects of personal data about the data processing process, the purposes of the processing, the categories of personal data that are processed, the users/categories of users if there are any, the intention to through – border transfer (if transferred, information on the appropriate protective measures with the possibility of obtaining a copy or information where available), the period of storage of personal data/criteria used to determine that period, the legitimate interests of INVEST METAL DOOEL Skopje if the processing is carried out in accordance with this basis for the processing of personal data, the existence of an automated decision-making process, including profiling, as well as information on the rights of the subjects of personal data. In accordance with the principle of transparency, INVEST METAL DOOEL Skopje informs the subjects of personal data about matters related to personal data through the document "Information about the subject of personal data".

We note that INVEST METAL DOOEL Skopje is not obliged to provide this information in the cases provided for by the Law on the Protection of Personal Data (Article 18 paragraph 5).

- Right of access (Article 19 of the Law)

The subjects of personal data have the right to receive a confirmation from INVEST METAL DOOEL Skopje whether their personal data is being processed and if it is being processed, they have the right to receive information in accordance with the right to information.

- Right to correction or addition (Articles 20 and 23 of the Law)

Personal data subjects have the right to correct their inaccurate personal data.

- Right to deletion of data (Article 21 of the Law)

Subjects of personal data have the right to ask INVEST METAL DOOEL Skopje to delete their personal data, if the conditions according to the Law on the Protection of Personal Data are met. Basically, at the request of the subject of the personal data, INVEST METAL DOOEL Skopje will delete the same only if the personal data are no longer needed for the purposes for which they were collected or, where relevant, the subject of the personal data has withdrawn his consent, and personal data were processed based on the consent given (in the case of direct marketing).

When deleting personal data, INVEST METAL DOOEL Skopje takes care that the same is deleted also by the third parties with whom INVEST METAL DOOEL Skopje cooperates and who process that data.

- Right to restriction of processing (Article 22 of the Law)

Subjects of personal data have the right to request from INVEST METAL DOOEL Skopje to limit the processing of their personal data, if the conditions are met according to the Law on the Protection of Personal Data including and under the condition that the processing is no longer necessary to comply with a legal obligation that requires processing according to the law applicable to INVEST METAL DOOEL Skopje.

- Right to object (Article 25 of the Law)

Subjects of personal data have the right to submit an objection to INVEST METAL DOOEL Skopje at any time, based on a specific situation related to them, when the processing of their personal data is based on the legitimate interest of INVEST METAL DOOEL Skopje or a third party or the public interest including profiling based on these grounds. If personal data is processed for direct marketing purposes, subjects have the right at any time to submit an objection to the processing of personal data and to request that INVEST METAL DOOEL Skopje stop the further processing of personal data for those purposes.

- The right to regulate any automatic decision-making and profiling (Article 26 of the Law)

Subjects of personal data have the right not to be subject to a decision based solely on the automated processing of their personal data, including profiling that causes legal consequences or similarly significantly affects the customer, except in the cases provided for by the Law on the Protection of Personal Data .

- Right to portability (Article 24 of the Law)

Subjects of personal data have the right to receive their personal data, which they have given to INVEST METAL DOOEL Skopje, in a structured, commonly used, machine-readable format, and they have the right to transfer it to another controller, without interference from INVEST METAL DOOEL Skopje, if the conditions are met according to the Law on Protection of Personal Data.

We note that the Request for the exercise of the rights is available by submitting to the email address: contact@investmetal.mk and you can submit the same to the address "Louis Pasteur no. 1 Skopje - Center" with the indication "for the Personal Data Protection Officer".

NOTE: Before submitting a Request for the exercise of rights, all subjects of personal data are encouraged and asked to read the relevant legal provisions cited above, which contain conditions and limitations when and how the rights are exercised, in order to avoid unnecessary and unfounded requests to INVEST METAL DOOEL Skopje.

We also note that INVEST METAL DOOEL Skopje will provide the requested information without compensation, except in cases where the Requests are clearly unfounded or excessive, especially if the same requests are repeated. In these cases INVEST METAL DOOEL Skopje will either refuse to act on the Request or will charge a fee taking into account the volume, complexity and time required to provide the information or act on the Request, for which you will be notified accordingly.

We also note that if more than one copy of the personal data being processed is requested, INVEST METAL DOOEL Skopje decides whether to charge a fee, taking into account the volume, complexity and time required to provide the copies.

9. SECURITY OF PERSONAL DATA PROCESSING

The confidentiality of the personal data of the clients of INVEST METAL DOOEL Skopje has a special focus on the part of all employees of INVEST METAL DOOEL Skopje.

INVEST METAL DOOEL Skopje takes the necessary technical and organizational measures in order to ensure that personal data are protected from accidental loss or disclosure, destruction or misuse. For this purpose, a large set of technical and organizational measures are applied by which INVEST METAL DOOEL Skopje guarantees that personal data are processed strictly in accordance with the Law on the Protection of Personal Data and the Regulation on Security of Personal Data Processing.

Each employee is responsible for respecting the internal policies for the protection of personal data of INVEST METAL DOOEL Skopje and INVEST METAL DOOEL Skopje has zero tolerance for cases that may question the trust and privacy of customers and the general public.

A breach of personal data security may occur in the event of accidental or intentional destruction, loss, alteration, disclosure or access to personal data.

In such a situation, INVEST METAL DOOEL Skopje immediately after learning about the breach of security, and within 72 hours at the latest, informs the Personal Data Protection Agency. If it considers that it is a situation where it is likely to cause a high risk for the rights and freedoms of customers, and the legal requirements of the Law on the Protection of Personal Data are met, it also informs all concerned natural persons.

INVEST METAL DOOEL Skopje has adopted an appropriate procedure for the manner in which an incident should be reported to the Personal Data Protection Agency in the event of a security incident related to leakage or violation of personal data.

10. MODIFICATION / SUPPLEMENT TO THIS PRIVACY POLICY

The Privacy Policy was adopted in 2023

INVEST METAL DOOEL Skopje has the right to update or amend or supplement this Privacy Policy of INVEST METAL DOOEL Skopje in order to comply with the applicable legal framework or the company's standards, if they are higher than those provided by national legislation.

In such a case, INVEST METAL DOOEL Skopje will publish a notice on its website indicating the date of amendment and the changes in the Policy.

11. CONTACT INFORMATION FOR INVEST METAL DOOEL SKOPJE AND THE OFFICER FOR THE PROTECTION OF PERSONAL DATA

For any questions regarding this Privacy Policy of INVEST METAL DOOEL Skopje as well as regarding the Policies from the Annexes attached to this Policy, please contact the Personal Data Protection Officer in one of the following ways:

- through a written letter that you can submit to INVEST METAL DOOEL Skopje at the address "Louis Pasteur no. 1 Skopje - Center" with the indication "for the Officer for the protection of personal data";

- electronically, at the email address: contact@investmetal.mk

ANNEX number 1: Policy for privacy of personal data of employees of INVEST METAL DOOEL Skopje This Policy applies to the employees of INVEST METAL DOOEL Skopje, interns and volunteers at INVEST METAL DOOEL Skopje, contract employees and hired persons (hereinafter: "employees"). This Policy determines the types of data processed by INVEST METAL DOOEL Skopje for the employees of INVEST METAL DOOEL Skopje, the purposes of processing their personal data, the time of their storage, protection, etc...

Categories of personal data of employees that INVEST METAL DOOEL Skopje processes

Based on the Law on records in the field of labor, the Law on labor relations, the Law on internships, the Law on volunteering and other legal and by-laws in this area, as well as for the purpose of fulfilling the contractual obligations with the employees of INVEST METAL DOOEL Skopje, INVEST METAL DOOEL Skopje can process the following personal data:

· name, surname and father's name of the employee;

· unique identification number of the citizen (EMBG);

· day, month and year of birth;

· place of birth (municipality, town and country);

· gender (male-female);

· residence and address (municipality, settlement, street and number and country);

· belonging to communities;

· religious affiliation;

· participation in a trade union;

· place of work (municipality, town, street and number, country);

· degree and type of completed education (no education, primary school, secondary school, higher education, faculty, masters and doctors of science);

· degree of professional preparation,

- completed professional training programs (training, further qualification and retraining) and

- special knowledge and abilities (computer skills, knowledge of foreign languages and other skills);

· occupation code and description;

· working hours of the employee (full-time or part-time);

· insurance experience until starting work with the employer;

· duration of employment:

- for an indefinite period of time and

- for a certain period of time;

· transaction account number;

· salary amount;

· data on disciplinary procedures and imposed fines;

· whether he is disabled for work (health data);

· date of establishment of the employment relationship;

· date of termination of employment;

· grounds for termination of employment.

Purposes of processing the personal data of the employees of INVEST METAL DOOEL Skopje

In addition, INVEST METAL DOOEL Skopje processes the personal data of the employees of INVEST METAL DOOEL Skopje and for the needs of the legitimate interest of INVEST METAL DOOEL Skopje, in the following situations:

· Making decisions about internal deployment by sector, promotions, etc...;

· Making decisions about salary and other benefits;

· Provision of contractual benefits for employees;

· Maintaining comprehensive, up-to-date records for the employees of INVEST METAL DOOEL Skopje, in order to ensure, among other things, the establishment of efficient correspondence and maintenance of appropriate points of contact in case of an emergency;

· Efficient monitoring of operations and efficiency and taking appropriate actions, if such a need arises;

· Assessment of training needs;

· Effective management of employees' sick days and vacations;

· Management of the system for legal leave from work and pay, such as maternity leave, unpaid leave, etc.;

· Business planning and restructuring;

· Dealing with legal proceedings against INVEST METAL DOOEL Skopje;

· Prevention of fraud;

Based on the legal regulations for the protection of personal data, INVEST METAL DOOEL Skopje is not obliged to provide special consent for the processing of special categories of personal data in order to implement its legal obligations arising from the regulations on labor relations, social and health insurance. Depending on the purpose of the processing, it is possible in certain situations to request consent for the processing of special categories of personal data. In that case, the employees are fully aware of the reasons for the processing.

Security of personal data processing INVEST METAL DOOEL Skopje takes the necessary technical and organizational measures in order to ensure that the personal data of employees are protected from accidental loss or disclosure, destruction or abuse.

Time of storage of personal data

In accordance with the principles of personal data protection, INVEST METAL DOOEL Skopje processes personal data only as much as is necessary to fulfill the purposes of the processing. During the duration of the employment, the personal data of the employees are kept in the employee records, and after the termination of the employment relationship, in accordance with the Law on archival material, the Policy for the storage and destruction of documents and electronic records and the Law on records in the field of labor is kept for at least 45 years.

All data related to employees are stored in accordance with the requirements of the Law on Labor Relations and the Law on Archival Operations, that is, within a time limit of 45 years.

All employee reports such as disciplinary and investigations are kept for 3 years after termination of employment.

Customer data is stored for 10 years.

Complaints made by users are kept for 3 years.

The data obtained from consumers or other customers by signing a contract are processed for the duration until the obligations of that contract are fulfilled and are deleted no later than 1 year after the fulfillment of all rights and obligations arising from that contract.

Automatic making of individual decisions

INVEST METAL DOOEL Skopje does not process the personal data of INVEST METAL DOOEL Skopje employees for making automatic decisions related to employees.

ANNEX number 2: Privacy policy for the personal data of candidates for employment in INVEST METAL DOOEL Skopje

This Policy applies to candidates for employment in INVEST METAL DOOEL Skopje (hereinafter: "candidates"). This Policy determines the types of data kept by INVEST METAL DOOEL Skopje for employment candidates, the purposes of processing their personal data, the time they are kept, etc.

Categories of personal data of candidates for employment in INVEST METAL DOOEL Skopje that INVEST METAL DOOEL Skopje processes INVEST METAL DOOEL Skopje can process the following personal data of job candidates:

• Name and surname, address, date of birth, telephone number;

• A picture and only with the express consent of the candidate, given in accordance with the Law on the Protection of Personal Data;

• gender; • information included in the CV, including education level and employment history;

• documentation confirming the candidate's right to work in the Republic of North Macedonia;

• driver's license (for certain job positions).

Purposes of processing the personal data of candidates for employment in INVEST METAL DOOEL Skopje

INVEST METAL DOOEL Skopje has a legitimate interest in processing the personal data of employment candidates for the following purposes:

• Making a decision to whom to offer employment from the candidates registered for the position, internal allocation by sectors, promotions, etc.;

• Making decisions about salary and other benefits;

• Assessment of training needs.

If the application is not successful and the candidate is not offered the job, the personal data will not be used for any other reason. They will be destroyed from the database of INVEST METAL DOOEL Skopje. In the above case, INVEST METAL DOOEL Skopje may request the consent of the candidate to save his personal data in the database of potential candidates for employment, in case suitable vacancies appear in the organization for which he thinks they would like to apply. within 1 year maximum.

Users and transfer of your personal data

As a candidate for employment at INVEST METAL DOOEL Skopje, INVEST METAL DOOEL Skopje discloses the personal data of the head of the Department at INVEST METAL DOOEL Skopje for the position for which the candidate applied, as well as to other employees of INVEST METAL DOOEL Skopje responsible for interviewing and selection of candidates. Regarding the other possible users of the candidate's personal data as well as the transfer of personal data, the provisions for the transfer of personal data from the Privacy Policy of INVEST METAL DOOEL Skopje apply.

Security of personal data processing

INVEST METAL DOOEL Skopje takes the necessary technical and organizational measures in order to ensure that personal data are protected from accidental loss or disclosure, destruction or misuse.

Personal data retention time

If the application is unsuccessful, and at the same time INVEST METAL DOOEL Skopje does not have the consent of the candidate to keep his personal data for future open job positions in INVEST METAL DOOEL Skopje will keep personal data for a maximum of 60 days from the day of completion of the selection for the job position.

If INVEST METAL DOOEL Skopje requested and received consent to store personal data for future open job positions in INVEST METAL DOOEL Skopje, it will keep the data for a period of 1 year.

After the end of this period, INVEST METAL DOOEL Skopje will destroy the personal data, except in the case if the candidate withdrew the consent earlier.

If the application is successful, the personal data will be transferred to the records of employees of INVEST METAL DOOEL Skopje.

ANNEX number 3: Personal data privacy policy on the website and online services of INVEST METAL DOOEL Skopje

INVEST METAL DOOEL Skopje collects data about visitors to its website available at the following link: https://www.investmetal.mk/

The website may include links to other websites that are under the responsibility of third parties (individuals or legal entities). In no case is INVEST METAL DOOEL Skopje responsible for the measures for the protection and management of personal data in relation to the above-mentioned websites of third parties.

The personal data collected through the website of INVEST METAL DOOEL Skopje is required at the moment when the user requests the service or visits the site. INVEST METAL DOOEL Skopje may process all or part of the personal data provided by the users in order to provide the service as well as for statistical/analytical purposes in order to improve the services and the user experience.

More specifically, INVEST METAL DOOEL Skopje collects the following data:

Personal identification data

INVEST METAL DOOEL Skopje may collect personal identification data from users in various ways, in connection with the activities, services, features or available resources on the website and online services of INVEST METAL DOOEL Skopje.

Users can also visit the site anonymously through "incognito mode" of the Internet browser.

Personal data that INVEST METAL DOOEL Skopje can collect and process when you visit the website or other online services, is the data obtained by cookies.

Non-Personally Identifiable Information

INVEST METAL DOOEL SKOPJE can also collect identification data for users that are not personal, whenever they visit the website or online services of INVEST METAL DOOEL Skopje. Non-personally identifiable information may include:

- Data tracking, i.e. the name of the internet search engine, the type of computer, as well as technical information about the connection used by the user when visiting the web – site, such as operating system and internet service provider and similar information,

- Duration of visit as well as duration of a certain problem that occurred when using the website or online services,

- A pseudo-identified ID (unique identification number) stored in order to identify the user when he revisits the website,

- Marketing data, i.e. data indicating INVEST METAL DOOEL Skopje which advertisements and promotions the user viewed, etc.,

- Location information, i.e. data about the location from where the website was opened or the online services were accessed.

All this information is collected in order to create a pseudo-anonymized user profile. In this way, the user's personal data is protected.

"Cookies"

The website of INVEST METAL DOOEL Skopje may use "cookies" in order to improve the user experience, to improve access to certain services of INVEST METAL DOOEL Skopje, to identify the most frequently visited areas as well as to assess the effectiveness of the website – the page, but the user's personal data is not processed. "Cookies" are small text files that are sent to the user's computer in order to ensure the technical functionality of the website and to personalize the user experience (e.g. a "cookie" that remembers the user's preferences during the next visit to the website).

INVEST METAL DOOEL Skopje can use "cookies" that fall into four categories:

- Strictly necessary cookies. These cookies are always active for the functionality of the website.

- Analytical cookies. The data processed by these cookies are related to the way the website is used by users (where the visitor comes from, which pages they visit, etc.). This data is not used for marketing or other purposes other than to improve the user experience of the visitor.

- Marketing cookies. INVEST METAL DOOEL Skopje does not use "cookies" that collect data that are then processed for marketing purposes. At the same time, a cookie is set by Google AdSense (a third party) for their marketing purposes (targeting visitors as they visit different websites). They are used in accordance with Google's Privacy Policy.

- Cookies from third parties. Third-party cookies enable various functionalities on our site such as (advertising, social media functions, analytics). These cookies are not owned by INVEST METAL DOOEL Skopje and INVEST METAL DOOEL Skopje has no control over them and how they will be used. For full transparency, please read our Cookie Policy available on our website. During the first visit to the website of INVEST METAL DOOEL Skopje, the visitor receives information about the "cookies" policy of INVEST METAL DOOEL Skopje and gives consent to their use. In that direction, we note that the "cookies" that are necessary from a technical point of view in order for users to use the website of INVEST METAL DOOEL Skopje cannot be turned off. Regarding other types of "cookies", which are not necessary for the general functionality of the website, it is possible to reject them or agree to accept them. Users can change their preferences at any time.

In addition, the use of the website of INVEST METAL DOOEL Skopje is not conditional on the acceptance of cookies, even though certain processes may not be technically optimized for the visitor's user experience.

PURPOSES OF PERSONAL DATA PROCESSING

• To improve the functionality of the website and online services

INVEST METAL DOOEL Skopje constantly strives to improve the offer of its website and online services based on the feedback we receive from users.

• To improve the services of INVEST METAL DOOEL Skopje to customers

Personal data helps us more effectively respond to users' requests for services or support they need (eg, transaction processing, identity verification, fraud prevention, analytics, etc.).

SECURITY OF PERSONAL DATA

INVEST METAL DOOEL Skopje applies security measures during the collection, storage and processing of information for the purpose of protection against unauthorized access, change, disclosure or destruction of personal data, as well as non-personal data stored on the website or online services of INVEST METAL DOOEL Skopje.

THIRD PARTY WEBSITES

Users may find advertisements or other content on the website of INVEST METAL DOOEL Skopje, which lead to other pages and services of our partners, suppliers, advertising companies, sponsors, and other third parties. INVEST METAL DOOEL Skopje does not control the content or links that are present on those pages and is not responsible for the actions of the employees of the pages that are linked to or from the website of INVEST METAL DOOEL Skopje. In addition, the sites or services referred to, including the content and links, may change from time to time. These sites or services may have their own Personal Data Privacy Policy on their websites and a separate Customer Relations Policy. The search and interaction with any other site, including the sites that have links to the website of INVEST METAL DOOEL Skopje, is subject to the specific rules and policies of the respective sites.

CHANGES IN THE PRIVACY POLICY OF PERSONAL DATA

INVEST METAL DOOEL Skopje has established an additional Cookie Policy that explains the details of the cookies used on the site. You can find the policy on our website. Information on the privacy of the subject of personal data

With this document, we as the Controller of Personal Data Gold and Silver Trading Company INVEST METAL DOOEL Skopje (hereinafter INVEST METAL), with registered office: Luj Pasteur No. 1 Skopje - Centar, with e-mail contact@investmetal.mk - we provide information about the processing of personal data and your rights related to this processing.

Our vision for personal data protection:

INVEST METAL pays great attention to the protection of personal data in all its business processes, implementing the standards set by the regulations for privacy and protection of personal data in the Republic of North Macedonia, which are elaborated in more detail in the internal Policies and procedures that make up the system of protection of personal data of INVEST METAL.

Our privacy policy is attached to the website of INVEST METAL and you can get it in an electronic version at your request

Purpose, description and categories of personal data subject to processing:

INVEST METAL processes personal data of users when selling precious metals, our associates and INVEST METAL employees as subjects of personal data.

The main source of personal data of INVEST METAL is the personal data that the subjects of personal data submit to us during the purchase of precious metals.

We note that INVEST METAL processes personal data only to the extent necessary for the purposes of the processing.

In particular, INVEST METAL can process the following personal data:

Personal data submitted by subjects when purchasing precious metals (gold, silver), i.e.: identification data (name and surname, EMBG), residential address and contact data (email and phone)

Subjects of personal data are obliged to immediately notify INVEST METAL of any change in the above data.

Personal data collected by INVEST METAL DOOEL Skopje are for different purposes:

- personal data for fulfilling legal obligations

- personal data related to business cooperation;

- personal data required for communication during business cooperation

- personal data to answer your request, question or complaint

- personal data for using our services

- in accordance with the applicable legal framework for providing data to state authorities;

- when performing marketing activities or direct marketing

- in the context of general customer communication with INVEST METAL via e-mail/telephone

- "cookies" and associated technologies that enable access and use of our website;

- data that concern customers and that are publicly available via the Internet or in another way;

- data on employed persons in INVEST METAL, persons who perform internship or volunteer work in INVEST METAL in accordance with the valid legal framework in this area (Law on records in the field of labor, Law on labor relations and others) explained in more detail in Annex 1 of INVEST METAL's privacy policy;

- data on candidates for employment at INVEST METAL explained in more detail in Annex 2 of INVEST METAL's Privacy Policy

- the personal data that are collected when using the website of INVEST METAL DOOEL Skopje are explained in more detail in Annex 3 of the Privacy Policy of INVEST METAL.

Personal data processed by INVEST METAL DOOEL Skopje are stored in paper and electronic form.

Legal basis for processing your personal data:

· Fulfillment of a legal obligation - We process your personal data for the purposes of legal obligations (for example, the obligation to keep the personal file of employees, keep an employee book, collect customer identification data).

· Fulfillment of a contractual obligation - We process your personal data for the purpose of fulfilling the contractual obligations arising from the Employment Agreement and for the fulfillment of other contractual obligations arising from an Agreement, but within the framework of the regulations established in the Law on the Protection of Personal Data and its by-laws or other relevant laws.

· Legitimate interest of the company – Legitimate interests are the interests of the company. These may include commercial interests, individual interests or wider societal benefits, but such processing should always explain the purpose of that processing.

· Statement of consent - We can process your data, if it is not based on a legal basis, only on the basis of your express consent. In that case, we will take appropriate measures, in a timely manner, in a transparent, understandable and easily accessible way to inform you about the purpose of the processing for which we need your consent so that you can make an informed decision about whether you want to give us your consent. Additionally, you will be notified of your legal rights, the possibility of withdrawing consent at any time, as well as the method of withdrawing the given consent based on the Personal Data Protection Law.

What is electronic notification: Electronic notification is any legally binding notification resulting from the binding relationship between the user and our company, for which the user has given consent to be forwarded electronically, as a substitute for notification by mail.

What is direct marketing:

Any type of communication made in any way for the purpose of sending advertising, marketing or propaganda material that is directed directly to an identified user.

Rights of Users - subjects of personal data

Subjects of personal data have a certain set of rights determined by the Law on Protection of Personal Data, which are explained below.

- Right to information (Articles 16, 17 and 18 of the Law)

INVEST METAL informs the subjects of personal data about the data processing process, the purposes of the processing, the categories of personal data that are processed, the users/categories of users if any, the intention of cross-border transfer (if transferred, information about the respective protective measures with the possibility of obtaining a copy or information where available), the time period of personal data storage/the criteria used to determine that period, the legitimate interests of INVEST METAL if the processing is carried out in accordance with this basis for the processing of personal data , the existence of an automated decision-making process, including profiling, as well as information on the rights of the subjects of personal data. In accordance with the principle of transparency, INVEST METAL informs the subjects of personal data about matters related to personal data through the Privacy Policy.

We note that INVEST METAL is not obliged to provide this information in the cases provided by the Law on Personal Data Protection (Article 18 paragraph 5).

If you want to know more information about the right to information, see the following link: https://azlp.mk/vashite-prava/%d0%bf%d1%80%d0%b0%d0%b2%d0%be-%d0 %bd%d0%b0-%d0%b8%d0%bd%d1%84%d0%be%d1%80%d0%bc%d0%b8%d1%80%d0%b0%d1%9a%d0% b5/

- Right of access (Article 19 of the Law)

Subjects of personal data have the right to receive confirmation from INVEST METAL if their personal data is being processed and if it is being processed they have the right to receive information in accordance with the right to information.

If you want to know more information about the right of access, see the following link: https://azlp.mk/vashite-prava/%d0%bf%d1%80%d0%b0%d0%b2%d0%be-%d0 %bd%d0%b0-%d0%bf%d1%80%d0%b8%d1%81%d1%82%d0%b0%d0%bf/

- Right to correction or addition (Articles 20 and 23 of the Law)

Personal data subjects have the right to correct their inaccurate personal data.

If you want to know more information about the right to correction or addition, see the following link: https://azlp.mk/vashiteprava/%d0%bf%d1%80%d0%b0%d0%b2%d0%be-%d0%bd%d0%b0-%d0%b8%d1%81%d0 %bf%d1%80%d0%b0%d0%b2%d0%ba%d0%b0/

- Right to deletion of data (Article 21 of the Law)

Subjects of personal data have the right to ask INVEST METAL to delete their personal data, if the conditions according to the Law on Personal Data Protection are met. Basically, at the request of the subject of the personal data, INVEST METAL will only delete the same if the personal data is no longer needed for the purposes for which it was collected or, where relevant, the subject of the personal data has withdrawn his consent, and the personal data data were processed based on the consent given (in the case of direct marketing).

When deleting personal data, INVEST METAL takes care that it is also deleted by the third parties with whom INVEST METAL cooperates and who process that data.

If you want to know more information about the right to delete data, see the following link: https://azlp.mk/vashite-prava/%d0%bf%d1%80%d0%b0%d0%b2%d0%be- %d0%bd%d0%b0-%d0%b1%d1%80%d0%b8%d1%88%d0%b5%d1%9a%d0%b5-%d0%bf%d1%80%d0%b0 %d0%b2%d0%be-%d0%b4%d0%b0-%d1%81%d0%b5-%d0%b1%d0%b8%d0%b4%d0%b5-%d0%b7%d0 %b0%d0%b1/

- Right to restriction of processing (Article 22 of the Law)

Subjects of personal data have the right to ask INVEST METAL to limit the processing of their personal data, if the conditions according to the Law on the Protection of Personal Data are met, including on the condition that the processing is no longer necessary to comply with a legal obligation that requires processing according to law applicable to INVEST METAL.

If you want to know more information about the right to restrict processing, see the following link: https://azlp.mk/vashite-prava/%d0%bf%d1%80%d0%b0%d0%b2%d0%be- %d0%bd%d0%b0-%d0%be%d0%b3%d1%80%d0%b0%d0%bd%d0%b8%d1%87%d1%83%d0%b2%d0%b0% d1%9a%d0%b5-%d0%bd%d0%b0-%d0%be%d0%b1%d1%80%d0%b0%d0%b1%d0%be%d1%82%d0%ba% d0%b0%d1%82%d0%b0/

- Right to object (Article 25 of the Law)

Subjects of personal data have the right to submit an objection to INVEST METAL at any time, based on a specific situation related to them, when the processing of their personal data is based on the legitimate interest of INVEST METAL or a third party or the public interest including profiling based on these foundations. If personal data is processed for direct marketing purposes, subjects have the right at any time to submit an objection to the processing of personal data and request that INVEST METAL stop further processing of personal data for those purposes.

If you want to know more information about the right to object, see the following link: https://azlp.mk/vashite-prava/%d0%bf%d1%80%d0%b0%d0%b2%d0%be-%d0 %bd%d0%b0-%d0%bf%d1%80%d0%b8%d0%b3%d0%be%d0%b2%d0%be%d1%80/

- The right to regulate any automatic decision-making and profiling (Article 26 of the Law)

INVEST METAL DOOEL Skopje does not perform profiling or automatic decision-making

If you want to find out more information about the right to regulate any automatic decision-making and profiling, see the following link: https://azlp.mk/vashite-prava/%d0%bf%d1%80%d0%b0%d0 %b2%d0%be-%d0%b4%d0%b0-%d0%bd%d0%b5-%d1%81%d0%b5-%d0%b1%d0%b8%d0%b4%d0%b5 -%d0%bf%d1%80%d0%b5%d0%b4%d0%bc%d0%b5%d1%82-%d0%bd%d0%b0-%d0%be%d0%b4%d0% bb%d1%83%d0%ba%d0%b0-%d0%ba%d0%be/

- Right to portability (Article 24 of the Law)

Subjects of personal data have the right to receive their personal data, which they have provided to INVEST METAL in a structured, commonly used, machine-readable format, while they have the right to transfer it to another controller, without interference from METAL INVEST, if the conditions according to the Law on Personal Data Protection have been met.

If you want to know more information about the right to portability, see the following link: https://azlp.mk/vashite-prava/%d0%bf%d1%80%d0%b0%d0%b2%d0%be-%d0 %bd%d0%b0-%d0%bf%d1%80%d0%b5%d0%bd%d0%be%d1%81%d0%bb%d0%b8%d0%b2%d0%be%d1% 81%d1%82-%d0%bd%d0%b0-%d0%bf%d0%be%d0%b4%d0%b0%d1%82%d0%be%d1%86%d0%b8%d1% 82%d0%b5/

INVEST METAL is obliged to respond to the user within 15 days from the date of receipt of the request, and is not obliged to respond to the same or similar request again, if there are no changes in his personal data in the meantime, unless six months have passed since the day of submission of the previous request to the new request.

If the customer does not receive a response to the request for access to personal data, he can submit a request to determine the violation of the right to the protection of personal data to the Agency for the Protection of Personal Data at their email address: info@privacy.mk or by sending a mail to their address: Bul. "Goce Delchev" no. 18, (the Macedonian Radio Television MRTV building - floor 14).

Term of keeping your personal data:

The length of time we keep your information depends on what kind of information it is.

Customer identification data is stored for 10 years.

The consents given by the subject are kept for 6 years or until the consent is withdrawn by the subject.

All data related to employees are stored in accordance with the requirements of the Law on Labor Relations and the Law on Archival Operations, that is, within a time limit of 45 years.

All employee reports such as disciplinary and investigations are kept for 3 years after termination of employment.

We keep our records for at least the minimum specified required retention period.

Categories of processors to whom we may transfer personal data:

INVEST METAL Skopje discloses personal data to public authorities in accordance with their legal powers.

More specifically, INVEST METAL Skopje can disclose the personal data of the subject of the personal data only if it is obliged according to the law, a decision of a competent authority or to third parties, i.e. to the following category of users of personal data: state authorities or legal entities established by the state for exercise of public powers, agency or other bodies as well as third parties (natural or legal persons) who act by order or on behalf of INVEST METAL Skopje, such as:

third parties (natural or legal persons) who cooperate with INVEST METAL Skopje in any form, acting on behalf and on behalf of INVEST METAL Skopje, in order to achieve the purpose of processing the contract, including the following categories:

2. Companies - suppliers of information technology equipment;

3. Agencies for securing persons and property with access to video surveillance or access to our client's address for safe transportation of products;

4. Consulting companies, including financial advisors and auditors;

5. Companies - data providers;

6. Social security authorities, public institutions and public companies;

7. State institutions and inspections such as the Labor Inspectorate and the State Market Inspectorate;

8. Financial institutions, Public Revenue Administration and other state institutions

9. Lawyers, bailiffs and notaries

10. Banks

12. Authorized auditing companies.

INVEST METAL Skopje cooperates only with third parties who can implement appropriate technical and organizational measures in accordance with INVEST METAL Skopje's regulations and standards, thereby enabling adequate protection of personal data. In such cases, third parties (processors of personal data) are bound by a specific Agreement for the processing of personal data or another legal act in accordance with Article 32 which ensures that personal data are processed only in accordance with the instructions given by INVEST METAL Skopje and in compliance with protective technical and organizational measures that ensure the security of personal data.

Sources of personal data:

We receive personal data directly from you through the initiation of a business relationship, or through the provision of an express statement of consent.

Automatic decision-making based on personal data:

No automatic decision-making takes place during the processing of personal data.

What are your rights?

In order to exercise your rights arising from the Personal Data Protection Law (right of access, correction, deletion, limitation of the processing of your personal data, objection and transferability), send a request to the electronic address of the personal data protection officer : contact@investmetal.mk

If you believe that any of your rights to the protection of personal data have been violated, you have the right to submit a request for the determination of a violation of the regulations on the protection of personal data to the Agency for the Protection of Personal Data as the competent authority for supervising the legality of the activities undertaken during the processing of personal data in the territory of the Republic of North Macedonia.