Privacy Policy
Last updated: 12 September 2026
Sandic Photo Media respects your privacy and is committed to protecting your personal data.
This Privacy Policy explains how we collect, use, store and protect personal information when you visit www.spmedia.rs, contact us, purchase or request photographs or other services, communicate with us, or otherwise use our website and services.
We process personal data in accordance with applicable data protection legislation, including, where applicable, the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and applicable Serbian data protection legislation.
1. Data Controller
The controller responsible for the processing of personal data through this website and our services is:
Sandic Photo Media – Photo & Video Agency
Belgrade, Serbia
Responsible person: Slobodan Sandić
Website: www.spmedia.rs
Email: info@spmedia.rs
Telephone: +381 63 367 486
For any questions concerning this Privacy Policy, the processing of your personal data, or the exercise of your data protection rights, please contact us using the details above.
2. Personal Data We May Collect
Depending on how you use our website and services, we may collect and process the following categories of personal data:
- first and last name;
- email address;
- telephone number;
- billing or delivery information where required;
- information provided when contacting us;
- information submitted through contact, enquiry or application forms;
- information relating to orders and purchases;
- photographs selected, ordered or purchased;
- communication preferences and selected communication channels;
- correspondence conducted by email, WhatsApp, Viber or other available communication channels;
- transaction and payment-related information, where applicable;
- IP address and basic technical information about your device and browser;
- website usage and cookie information, where applicable;
- any other information that you voluntarily provide to us.
We aim to collect only personal data that is adequate, relevant and necessary for the purposes described in this Privacy Policy.
3. Photographs and Event Photography
Sandic Photo Media provides professional photography and video services, including photography at sporting, cultural, entertainment, public and other events.
Photographs may contain identifiable individuals and may therefore constitute personal data under applicable data protection legislation.
Depending on the circumstances, photographs may be processed for purposes including:
- documenting an event;
- providing photography and video services;
- organising photographs into galleries;
- allowing customers to locate and select photographs;
- processing requests and orders;
- delivering purchased photographs;
- maintaining an archive where appropriate;
- protecting copyright and other legitimate business interests;
- publication or promotional use where an appropriate legal basis exists.
Where consent is legally required for a particular use of a photograph, we will seek the appropriate consent.
Where processing is based on legitimate interests, we will consider the rights, interests and reasonable expectations of the individuals concerned.
If you believe that a photograph published or processed by us infringes your privacy or data protection rights, please contact us at info@spmedia.rs and provide sufficient information to identify the photograph concerned.
4. Purposes of Processing
We may process personal data for the following purposes:
- operating and maintaining www.spmedia.rs;
- providing photography and video services;
- displaying and managing photo galleries;
- responding to enquiries and messages;
- processing customer requests and orders;
- providing purchased digital photographs or arranging other forms of delivery;
- communicating with customers regarding their orders;
- communicating through email, WhatsApp, Viber or another communication method selected by the customer;
- maintaining business and accounting records;
- preventing fraud, abuse and security incidents;
- maintaining the security and technical functionality of our website;
- complying with applicable laws and legal obligations;
- establishing, exercising or defending legal claims;
- improving our website and services;
- sending marketing communications where permitted by law.
We will not use your personal data for purposes incompatible with those for which it was originally collected unless such further processing is permitted by applicable law.
5. Legal Bases for Processing
Where the GDPR applies, we process personal data only where an appropriate legal basis exists.
Depending on the circumstances, processing may be based on:
Performance of a contract – where processing is necessary to provide a service, process an order or take steps at your request before entering into a contract.
Legal obligation – where we are required to process or retain information under applicable accounting, tax or other laws.
Legitimate interests – where processing is necessary for our legitimate business interests, provided that those interests do not override your fundamental rights and freedoms.
Such interests may include operating our photography business, providing and protecting our services, preventing fraud, securing our systems, communicating with customers and protecting our legal and intellectual property rights.
Consent – where you have expressly agreed to a particular processing activity. Where processing is based on consent, you may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.
6. Orders and Customer Communications
When you request or purchase photographs or other services, we may process information necessary to:
- identify your order;
- identify the photographs or services requested;
- calculate prices and applicable discounts;
- communicate with you;
- arrange payment;
- prepare purchased photographs;
- deliver the requested content;
- maintain appropriate business records.
If you choose to communicate with us through third-party communication services such as WhatsApp or Viber, your information may also be processed by the provider of that service in accordance with its own privacy policy.
We recommend reviewing the privacy information provided by any third-party communication service you choose to use.
7. Payment Information
Where payment options are available through third-party payment providers, banks or other financial institutions, payment information may be processed directly by those providers.
Sandic Photo Media does not necessarily receive or store complete payment-card information where transactions are handled by an independent payment service provider.
Payment providers process personal data according to their own terms and privacy policies.
8. Cookies and Similar Technologies
Our website may use cookies and similar technologies that are necessary for the website to function properly.
Depending on the services enabled on the website, cookies may also be used for:
- remembering user preferences;
- maintaining shopping cart functionality;
- website security;
- measuring website performance;
- analytics;
- embedded third-party services;
- marketing, where applicable.
Where required by law, non-essential cookies will only be activated after obtaining the visitor's consent.
Visitors should be able to withdraw or modify their cookie consent where applicable.
More detailed information about the cookies used on the website may be provided in a separate Cookie Policy or cookie consent interface.
9. Sharing Personal Data
We do not sell personal data.
We may disclose personal data only where necessary and legally permitted, including to:
- hosting and IT service providers;
- website and infrastructure providers;
- cloud storage providers;
- payment service providers and financial institutions;
- professional advisers, accountants or legal advisers;
- delivery or communication service providers;
- photographers or authorised collaborators where necessary to provide the requested service;
- competent courts, authorities or public bodies where disclosure is required by law.
Where a service provider processes personal data on our behalf, we seek to use providers offering appropriate safeguards for the protection of personal data.
10. International Data Transfers
Some service providers used in connection with our website or business may process or store information outside Serbia or outside the European Economic Area (“EEA”).
Where the GDPR applies and personal data is transferred internationally, we will seek to ensure that an appropriate transfer mechanism or safeguard is in place where required by law.
Depending on the recipient and destination, such safeguards may include an adequacy decision, appropriate contractual safeguards, Standard Contractual Clauses or another legally recognised transfer mechanism.
11. Data Retention
We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including providing our services and satisfying legal, accounting, tax, contractual and security requirements.
Retention periods may vary depending on the type of information and the purpose of processing.
Order and transaction information may be retained for the period required by applicable accounting, tax and commercial laws.
Communications may be retained for as long as necessary to resolve an enquiry, provide a service, maintain appropriate business records or establish, exercise or defend legal claims.
Photographs and original media may be retained for longer periods where necessary for professional archives, customer re-orders, copyright protection, contractual requirements or other legitimate purposes, subject to applicable law.
When personal data is no longer required, we will delete, anonymise or otherwise securely dispose of it where reasonably possible and legally appropriate.
12. Data Security
We take reasonable technical and organisational measures designed to protect personal data against:
- unauthorised access;
- unlawful processing;
- accidental loss;
- alteration;
- disclosure;
- destruction.
These measures may include access controls, authentication, secure hosting, backups, restricted administrative access and other appropriate technical safeguards.
However, no method of transmission or storage on the Internet can guarantee absolute security.
13. Your Data Protection Rights
Where the GDPR or other applicable data protection legislation provides these rights, you may have the right to:
- obtain information about how your personal data is processed;
- request access to your personal data;
- request correction of inaccurate or incomplete information;
- request deletion of your personal data;
- request restriction of processing;
- object to certain processing based on legitimate interests;
- object to direct marketing;
- receive certain personal data in a structured, commonly used and machine-readable format;
- request transmission of eligible data to another controller where technically feasible;
- withdraw consent where processing is based on consent;
- lodge a complaint with a competent data protection supervisory authority.
These rights are subject to the conditions and limitations established by applicable law. For example, the right to erasure does not require deletion where information must be retained to comply with a legal obligation or for the establishment, exercise or defence of legal claims.
14. Exercising Your Rights
To exercise a data protection right or ask a privacy-related question, please contact:
Email: info@spmedia.rs
Please clearly describe your request and provide sufficient information for us to identify the relevant data.
Where reasonably necessary, we may request additional information to verify your identity before acting on a request.
Where the GDPR applies, we will respond without undue delay and generally within one month of receiving a valid request, subject to any extensions permitted by law.
15. Right to Lodge a Complaint
If you believe that your personal data has been processed unlawfully, you have the right, where applicable, to lodge a complaint with a competent data protection authority.
As Sandic Photo Media is based in Serbia, you may also contact the Serbian authority responsible for personal data protection:
Commissioner for Information of Public Importance and Personal Data Protection of the Republic of Serbia
Where the GDPR applies, you may also have the right to lodge a complaint with the competent supervisory authority in the EU/EEA Member State of your habitual residence, place of work or the place of the alleged infringement.
We encourage you to contact us first at info@spmedia.rs so that we have an opportunity to address your concerns.
16. Children's Privacy
Our services are not intended to collect personal data from children unnecessarily.
Because our photography services may involve public, sporting, school, cultural or other events at which minors may be present, photographs may in certain circumstances include minors.
Where processing involving children requires consent or another specific legal basis, we will apply the requirements of applicable data protection legislation.
Parents or legal guardians who have questions or concerns regarding a photograph or personal data relating to a child may contact us at info@spmedia.rs.
17. Automated Decision-Making
We do not intend to make decisions producing legal or similarly significant effects on individuals solely through automated processing unless specifically disclosed and permitted by applicable law.
We may use automated technical tools for purposes such as website security, image processing, image organisation, search functionality or service optimisation. Such technical processing does not necessarily constitute automated decision-making within the meaning of the GDPR.
18. Third-Party Websites and Services
Our website may contain links to external websites or use third-party services.
Sandic Photo Media is not responsible for the privacy practices of independent third-party websites or services. We recommend reviewing their privacy policies before providing personal information.
19. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our services, technology, business practices or applicable legal requirements.
The current version will be published on www.spmedia.rs with the date of the latest revision displayed at the top of this page.
20. Contact
For questions, requests or concerns regarding privacy and personal data, please contact:
Sandic Photo Media – Photo & Video Agency
Belgrade, Serbia
Responsible person: Slobodan Sandić
Website: www.spmedia.rs
Email: info@spmedia.rs
Telephone: +381 63 367 486
© 2026 Sandic Photo Media. All rights reserved.