TOOBI Privacy Policy

Last updated: October 2025

TOBI MEDIA d.o.o. (“TOBI”, “we”, “us”, or “our”) respects your privacy and is committed to
protecting your personal information. This Privacy Policy explains how we collect, use, store,
and protect your information when you use the TOOBI platform (the “App” or “Service”). By
accessing or using the Service, you agree to this Privacy Policy.

1. Information We Collect

When you use the TOOBI App, we may collect the following categories of information:
• Account Information: Name, email address, phone number, billing details, and other
data you provide when registering an account.
• Payment Information: Processed via authorized payment processors (Visa, MasterCard,
banks). We do not store your full card details.
• Usage Data: IP address, device type, operating system, login information, app usage
history, and viewing history.
• Customer Support Data: Information you provide when contacting us (emails,
messages, phone calls).
• Optional Content: If you upload or share content through the Service, you are
responsible for such content.

2. How We Use Your Information

We process your data only for legitimate purposes, including:
• To provide and manage your subscription and access to the App.
• To process payments and deliver invoices.
• To personalize your user experience and recommend content.
• To send service-related communications and, if you consent, marketing messages.
• To ensure technical security and prevent fraud or abuse.
• To provide customer support and handle complaints.
• To comply with legal obligations (e.g., tax, accounting, regulatory).

3. Legal Basis

We process your personal data based on:
• Your consent (e.g., marketing messages, cookies),
• Performance of our contract (providing the Service),
• Legal obligations (e.g., tax and accounting), and
• Our legitimate interests (security, fraud prevention, improving the App).

4. Data Sharing and Third Parties

We do not sell or rent your data. We may share your data only with:
• Payment processors and financial institutions (to handle transactions),
• IT and cloud service providers (for hosting and security),
• Authorities when required by law or court order.
All third parties are bound by confidentiality and data protection agreements.

5. Data Retention

• Account and usage data: stored as long as you maintain an active account.
• Payment and billing data: stored for at least 5 years as required by Serbian accounting
law.
• Technical logs: retained for a limited time to ensure system security.
After retention periods, your data will be securely deleted or anonymized.

6. Cookies and Tracking Technologies

We may use cookies, tracking pixels, and similar technologies to:
• Enable proper functioning of the App and website,
• Analyze usage patterns and improve our Service,
• Provide personalized content and recommendations,
• Deliver marketing and advertising (only with your consent).
You can control cookies through your browser settings and withdraw consent at any time.

7. Your Rights

You have the following rights under applicable law (EU GDPR and Serbian Law on Personal
Data Protection):
• Access your personal data,
• Request correction or deletion,
• Request restriction of processing,
• Object to processing,
• Data portability,
• Withdraw consent at any time (without affecting prior lawful processing).
To exercise these rights, contact us at: [email protected].

8. Security

We apply technical and organizational measures to protect your information against
unauthorized access, loss, misuse, or disclosure. Sensitive data such as payment details are
handled only through secure, encrypted channels.

9. Children’s Privacy

The Service is not intended for children under 18. We do not knowingly collect personal data
from minors without parental consent. If you believe a minor has provided us with personal data,
please contact us to remove it.

10. International Data Transfers

If you access the Service from outside Serbia, your information may be processed in Serbia, the
EU, and potentially other countries where our cloud service providers operate (such as the
United States). In such cases, we rely on recognized legal mechanisms (e.g., Standard
Contractual Clauses – SCC) to ensure your data remains adequately protected.

11. Marketing Communications

With your consent, we may send you marketing emails, newsletters, or push notifications. You
may opt out of receiving marketing communications at any time by:
• Clicking the “unsubscribe” link in our emails, or
• Contacting us directly at [email protected].
Service-related messages (e.g., payment confirmations, security alerts) are not considered
marketing and cannot be opted out of.

12. Changes to This Policy

We may update this Privacy Policy to reflect changes in law, our services, or other factors. If we
make material changes, we will notify you via email or in-app notice before the new policy takes
effect.

13. Contact Us

If you have questions or concerns about this Privacy Policy, please contact us:
TOBI MEDIA d.o.o.
Desanke Maksimović 17, 11000 Belgrade, Serbia
Email: [email protected]
__________________________
Nikola Radivojević, DIRECTOR TOBI MEDIA d.o.o.