1. Introduction and purpose of this document

This Privacy Policy (“Policy”) describes how Rakić Advisory d.o.o. Banja Luka (“Rakić Advisory”, “we”) collects and processes personal data of natural persons (e.g., website visitors, contact persons of clients and suppliers, job applicants, and other individuals we communicate with). The purpose of this Policy is to provide clear information about which data we process, for what purposes, on what legal basis, how long we retain it, to whom we disclose it, and what rights you have.

We apply the applicable regulations of Bosnia and Herzegovina on personal data protection and, where applicable, standards from the General Data Protection Regulation (GDPR), especially in the areas of transparency and informing data subjects.


2. Who is the data controller and how to contact us

Controller: Rakić Advisory d.o.o. Banja Luka.

Data protection contact: info@rakicadvisory.com (please indicate “Data Protection” in the subject line).


3. Categories of data subjects

This Policy applies in particular to:

  • clients – natural persons (if any) and contact persons at legal entities (directors, employees, attorneys-in-fact);
  • website visitors and individuals contacting us via email/phone/contact form;
  • business partners and suppliers (contact persons and representatives);
  • job applicants and interns;
  • participants in trainings, events, and professional courses we organize or attend.

4. Categories of personal data we process

Depending on the specific relationship, we may process:

  • identification and contact data (first and last name, employer/company name, position, email, phone, address);
  • communication data (content of inquiries, email correspondence, meeting minutes, call notes);
  • data necessary for an offer/contract and service delivery (e.g., data in powers of attorney, contracts, invoicing, project records);
  • financial/accounting data to the extent necessary for providing the contracted service;
  • data related to compliance, preventing misuse and protecting legitimate interests (e.g., access records, security logs);
  • job application data (CV, cover letter, references, education and work experience) – submitted by email;
  • technical data about website use (e.g., IP address, technical logs, essential cookies), to the extent and in the manner described in the cookies section.
Important note: In the context of tax and legal services, Rakić Advisory may act as a controller or as a processor (depending on the engagement model). When we process data on behalf of a client and according to the client’s instructions, we act as a processor and the client is the controller; details are regulated by a contract/data processing agreement where required.

5. Sources of data

We most often obtain data:

  • directly from you (when you contact us or enter into a contract);
  • from our client/business partner (when you are their contact person or authorized representative);
  • from publicly available sources (e.g., official registers), to the extent necessary for verifying data and conducting lawful business;
  • automatically via the website (essential cookies and technical logs), in accordance with your settings.

6. Purposes of processing and legal basis

We process your data only when we have an appropriate legal basis, in particular for the following purposes:

6.1. Service delivery, entering into and performance of contracts

Purpose: handling inquiries, preparing offers, negotiations, performance of contracts for tax advisory, accounting and related services, and communication during engagement.

Legal basis: necessity for the performance of a contract or for taking steps at your request prior to entering into a contract.

6.2. Compliance with legal obligations

Purpose: compliance with obligations arising from tax, accounting, contract and other regulations (e.g., records, document retention, responding to requests from competent authorities).

Legal basis: legal obligation.

6.3. Legitimate interest – protection of business and security

Purpose: protecting IT systems and the network, preventing misuse, keeping communication records to protect legal interests, internal quality control, risk management and claims management.

Legal basis: legitimate interest, with a balancing test where applicable.

6.4. Marketing and notifications (professional updates)

Purpose: sending professional updates, event invitations, and similar information about our work and services.

Legal basis: consent (where required) or legitimate interest for business (B2B) communication, in accordance with applicable regulations. You can request to stop receiving such communications at any time.

6.5. Recruitment and hiring

Purpose: processing applicants’ submissions, assessing qualifications, scheduling interviews, and making hiring decisions. We receive applications (CV and supporting documents) by email.

Legal basis: taking steps prior to entering into a contract; after the selection process ends, we retain documentation only for a reasonable period for record-keeping and protection against potential legal claims, and longer only with your explicit consent.


7. Recipients of data and processing by third parties

We may make your data available only to persons who need it to achieve the processing purposes, including:

  • our employees and engaged associates subject to confidentiality obligations;
  • IT service providers (hosting, email, maintenance, backups) – acting as processors;
  • accounting and administrative service providers (when necessary);
  • lawyers/partner firms or other professionals (when necessary for service delivery or protection of rights);
  • competent authorities – where there is a legal obligation or a justified request.

Where applicable, we enter into appropriate data processing/confidentiality agreements with processors.


8. International data transfers

As a rule, we process data in Bosnia and Herzegovina. However, certain IT services (e.g., email/hosting) may involve processing or storage outside Bosnia and Herzegovina/EEA. In such cases, we take measures to ensure transfers are lawful and protected (e.g., contractual clauses, risk assessments and appropriate technical measures), in line with applicable regulations.


9. Data retention periods

We retain data only as long as necessary for the processing purpose, unless regulations require longer retention. Typically:

  • contract and project documentation: for the duration of the contract and after termination for a reasonable period to protect legal interests and in line with limitation periods;
  • accounting and financial documentation: for the periods prescribed by tax and accounting regulations;
  • communications (inquiries, email): for the period needed to handle the inquiry and a reasonable time thereafter for record-keeping;
  • job applications (CV via email): until the selection process ends and then up to 6 months for record-keeping and protection against possible legal claims; longer retention only with your explicit consent.

If we cannot specify an exact retention period in advance, we apply the following criteria: the nature and purpose of the data, legal obligations, limitation periods and dispute risks, and the principle of minimization (we keep only what is necessary).


10. Data security

We apply appropriate technical and organizational security measures (access control, authorization restrictions, passwords and authentication, encryption where justified, backups, antivirus/antimalware, confidentiality training, physical security of premises). However, no system is absolutely secure; if an incident occurs that may result in a risk to your rights and freedoms, we will take measures in accordance with regulations, including notifying competent authorities and/or individuals, where required.


11. Cookies and technical logs

We use only essential (technical) cookies on our website to enable basic site functionality and protect session security. We do not use analytics or marketing cookies (e.g., Google Analytics, Meta Pixel, etc.).

You can configure your web browser to refuse or delete cookies. Please note that disabling essential cookies may affect the functionality of certain parts of the website.

In addition to cookies, our servers may automatically record technical logs (e.g., IP address, access time, browser type) solely for system maintenance and security and for troubleshooting.


12. Your rights

In accordance with applicable regulations, you have the right to:

  • request access to your data;
  • request rectification of inaccurate data or completion of incomplete data;
  • in certain cases, request erasure (“right to be forgotten”) or restriction of processing;
  • object to processing based on legitimate interest;
  • where processing is based on consent – withdraw consent at any time (withdrawal does not affect the lawfulness of processing prior to withdrawal);
  • in relevant cases, exercise the right to data portability.

To exercise your rights, contact us at info@rakicadvisory.com with “Data Protection” in the subject line. For protection purposes, we may request additional identity verification.


13. Right to lodge a complaint with the supervisory authority

If you believe your data is being processed contrary to regulations, you have the right to lodge a complaint with the Personal Data Protection Agency in Bosnia and Herzegovina (AZLP).


14. Children and minors

Our services are primarily intended for business entities. We do not knowingly target the collection of children’s data. If you believe we have collected a minor’s data by mistake, please contact us so we can delete it or align the processing accordingly.


15. Changes to this Policy

We may update this Policy from time to time to ensure compliance with regulations or changes in our processes. We will publish the updated version on our website with the date of the last update.


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