Last updated: 22 September 2026

1. Who we are

CodeBase is the trading name of DARKO MILOVANOVIC PR ZENTRU NOVI SAD, a sole proprietorship registered in the Republic of Serbia (“CodeBase”, “we”, “us”). We operate the website codebaseoutsourcing.com and provide software development and IT staffing services.

We are the data controller for the personal data described in this policy.

How to contact us about your data:
Email: office@codebaseoutsourcing.com
Phone: +381 60 322 8292

Our full registered particulars are recorded with the Serbian Business Registers Agency (APR) and are available on request.

2. Which law applies

We process personal data in accordance with the Serbian Law on Personal Data Protection (Zakon o zaštiti podataka o ličnosti).

Where we offer services to, or monitor the behaviour of, individuals located in the European Economic Area, we also process personal data in accordance with the EU General Data Protection Regulation (GDPR).

3. What we collect, why, and on what legal basis

We collect only what you actively give us. We do not build profiles, and we do not track you across other websites.

3.1 Contact form enquiries

What: the name, email address and message content you submit through the contact form, plus any other details you choose to include.

Why: to read, understand and reply to your enquiry.

Legal basis: our legitimate interest in responding to people who contact us (GDPR Art. 6(1)(f)); where your enquiry is a step toward a contract, the performance of pre-contractual measures (Art. 6(1)(b)).

Retention: 24 months from our last contact with you, after which it is deleted.

3.2 Meeting bookings

What: when you book an introductory call, we collect your name, email address, company, website and a short description of your project need, and optionally your phone number and preferred delivery model. We also record the meeting time you selected.

Why: to schedule, confirm, remind you about and hold the meeting you requested.

Legal basis: performance of pre-contractual measures at your request (GDPR Art. 6(1)(b)).

Retention: 24 months from the meeting date.

Processor: bookings are handled by Zoho Corporation using its European data centre. See section 5.

3.3 Job applications

What: if you apply for a role with us, we collect your name, contact details, CV, work history and anything else you include in your application.

Why: to assess your application and communicate with you about the role.

Legal basis: pre-contractual measures at your request (GDPR Art. 6(1)(b)); and, where we keep your details for future openings, your consent (Art. 6(1)(a)), which you may withdraw at any time.

Retention: for the duration of the recruitment process, plus 12 months only if you consent to be considered for future roles.

3.4 Email correspondence

What: the content of emails you send us and our replies, including your email address.

Why: to communicate with you and keep a record of what was agreed.

Legal basis: legitimate interest in conducting business correspondence (Art. 6(1)(f)), or performance of a contract (Art. 6(1)(b)) where applicable.

Retention: 36 months, or longer where required by accounting or other statutory obligations.

Processor: our business email is provided by Zoho Corporation, European data centre.

3.5 Server and security logs

What: our hosting provider records standard technical information when your browser requests a page, including IP address, browser type, requested URL and timestamp.

Why: to operate the site securely, diagnose faults and prevent abuse.

Legal basis: legitimate interest in the security and availability of our website (Art. 6(1)(f)).

Retention: as determined by our hosting provider, typically no more than 30 days.

4. Cookies and tracking

We do not use analytics cookies, advertising cookies, or third-party tracking pixels on this website. We do not use Google Analytics, advertising networks, social media tracking pixels, or cross-site profiling of any kind.

Our website and its security plugin may set strictly necessary cookies required for the site to function and to protect administrator logins. These are not used to track you and are not shared with third parties.

If we introduce analytics or any other non-essential cookies in future, we will ask for your consent before any such cookie is set, and we will update this policy first.

5. Who we share data with, and international transfers

We do not sell your personal data. We do not share it for advertising.

We share personal data only with service providers who process it on our behalf, under contract, and only as needed to provide the service. These currently are:

• Zoho Corporation — business email and meeting bookings. European Union data centre.
• Our website hosting provider — website hosting and backups.

We may also disclose personal data where we are legally required to do so, or to establish, exercise or defend legal claims.

Transfers outside Serbia and the EEA: where a provider processes data outside Serbia or the EEA, we rely on an adequacy decision or on Standard Contractual Clauses together with appropriate supplementary measures.

6. Your rights

Under Serbian data protection law and, where applicable, the GDPR, you have the right to:

• access the personal data we hold about you, and receive a copy;
• rectify data that is inaccurate or incomplete;
• erase your data, where the conditions are met;
• restrict processing in certain circumstances;
• object to processing based on legitimate interests;
• data portability — receive your data in a structured, machine-readable format;
• withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing before withdrawal.

To exercise any of these rights, email office@codebaseoutsourcing.com. We will respond within 30 days.

If you believe we have handled your personal data unlawfully, you may lodge a complaint with the Serbian Commissioner for Information of Public Importance and Personal Data Protection (Poverenik za informacije od javnog značaja i zaštitu podataka o ličnosti), Bulevar kralja Aleksandra 15, 11000 Belgrade — or, if you are in the EEA, with your local supervisory authority.

7. How we protect your data

Our website is served over HTTPS. Administrator access requires two-factor authentication. We keep encrypted backups, restrict access to personal data to people who need it, and use reputable providers who contractually commit to appropriate security measures.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

8. Children

Our website and services are directed at businesses, not children. We do not knowingly collect personal data from anyone under 15. If you believe a child has provided us with personal data, please contact us and we will delete it.

9. Changes to this policy

We may update this policy from time to time. The “Last updated” date at the top reflects the most recent revision. Material changes will be highlighted on this page.

10. Contact

Email: office@codebaseoutsourcing.com
Phone: +381 60 322 8292