Who We Are

Qrilyonda Komietos operates an educational platform focused on advanced AR and VR game development techniques. Our registered address is Dimitrija Tucovića 57, Užice, Serbia. We process personal data as part of delivering online courses, webinars, and educational content to students across Serbia and beyond.

You can reach our data protection team at support@qrilyondakomietos.com or by calling +38162416900 during business hours. We respond to all privacy inquiries within 72 hours.

What Data We Collect

We collect different types of information depending on how you use our platform. Here's what we gather and why:

Account Information

When you register for courses, we need your name, email address, phone number, and sometimes your postal address for certificate delivery. We also store your password in encrypted format and any profile details you choose to add.

Learning Activity Data

To track your progress and provide personalized recommendations, we record which courses you view, lessons you complete, quiz scores, forum posts, and time spent on different modules. This helps us improve your learning experience and show you relevant content.

Payment Information

For paid courses, we collect billing details and transaction records. However, we don't store complete credit card numbers on our servers. Payment processing happens through certified third-party processors who handle sensitive financial data securely.

Technical Data

Our servers automatically log IP addresses, browser types, device information, operating systems, and browsing patterns. This technical data helps us fix bugs, improve performance, and keep our platform secure.

Communications

We keep records of emails you send us, support tickets, feedback forms, and any other correspondence. This helps us provide better customer service and resolve issues faster.

How We Use Your Information

We process your data for specific purposes, and we're transparent about what those are:

• Delivering course content and educational materials you've enrolled in
• Processing payments and maintaining accurate financial records
• Sending important updates about courses, schedule changes, or platform maintenance
• Responding to your questions and providing technical support
• Analyzing learning patterns to improve our curriculum and teaching methods
• Preventing fraud and maintaining platform security
• Complying with legal obligations under Serbian and EU law

Legal Basis for Processing

Under GDPR, we need a lawful reason to process your personal data. Here's what applies to different situations:

Who We Share Data With

We don't sell your personal information to anyone. But we do share data with certain third parties who help us run the platform:

Service Providers

Cloud hosting companies store our data on secure servers. Email service providers send course updates and notifications. Payment processors handle financial transactions. Video hosting platforms deliver course content. Analytics tools help us understand how students use the platform.

All these providers are bound by strict confidentiality agreements and only process data according to our instructions.

Legal Requirements

Sometimes we're legally required to share information with Serbian government agencies, tax authorities, or law enforcement. This only happens when mandated by valid legal processes.

Business Transfers

If Qrilyonda Komietos merges with another company or gets acquired, your data might transfer to the new entity. We'd notify you beforehand and ensure the new owner respects this privacy policy.

International Data Transfers

Some of our service providers operate servers outside Serbia and the European Economic Area. When we transfer data internationally, we use approved mechanisms like Standard Contractual Clauses to ensure your information stays protected according to GDPR standards.

For students based in Serbia, we try to keep most data within EU-based data centers whenever possible. Your learning records and course progress are primarily stored on European servers.

How Long We Keep Your Data

We don't keep personal information longer than necessary. Here's our retention schedule:

• Active student accounts – data retained while your account is active plus three years after your last login
• Course completion records – kept for seven years to provide proof of training if you need it
• Financial records – retained for ten years as required by Serbian tax law
• Marketing consent records – maintained until you withdraw consent, then deleted within 30 days
• Support tickets and communications – deleted two years after case closure
• Anonymous analytics data – kept indefinitely since it can't identify you

After these periods expire, we securely delete or anonymize your data so it can't be linked back to you.

Your Rights Under GDPR

Serbian residents have strong data protection rights under GDPR. Here's what you can do:

Access Your Data

Request a copy of all personal information we hold about you. We'll provide this in a readable format within 30 days, usually as a downloadable file.

Correct Inaccurate Information

Update outdated or wrong details in your account settings yourself, or contact us to make changes to data you can't edit directly.

Delete Your Data

Ask us to erase your personal information. We'll comply unless we have legal reasons to keep certain records, like financial data required for tax purposes.

Restrict Processing

Request that we temporarily limit how we use your data while you challenge its accuracy or object to processing.

Data Portability

Get your data in a machine-readable format to transfer to another service. We'll provide course completion records, learning progress, and profile information.

Object to Processing

Stop us from using your data for direct marketing immediately, or object to processing based on legitimate interests if you have specific reasons.

Withdraw Consent

Remove consent for any processing that relies on it. This doesn't affect the lawfulness of processing before you withdrew consent.

Security Measures

Protecting your data is a priority. We use multiple security layers to prevent unauthorized access, data breaches, and cyber attacks.

All data transmitted between your browser and our servers uses TLS encryption. Passwords are hashed with industry-standard algorithms and never stored in plain text. Our databases are protected by firewalls and access controls that limit which staff members can view sensitive information.

We conduct regular security audits and penetration testing to identify vulnerabilities. Our team receives ongoing training about data protection best practices and security protocols.

In the unlikely event of a data breach affecting your personal information, we'll notify you within 72 hours as required by GDPR and Serbian law. We'll explain what happened, what data was affected, and what steps we're taking.

Cookies and Tracking

Our website uses cookies to remember your preferences, keep you logged in, and analyze how students use the platform. Some cookies are essential for basic functionality, while others help us improve the user experience.

You can control cookie settings through your browser preferences. Blocking essential cookies might affect your ability to access certain features. We provide a detailed cookie policy on our website that lists every cookie we use and its purpose.

We don't use advertising cookies or share browsing data with ad networks. Our analytics cookies collect anonymous usage statistics that help us understand which course topics are most popular and where students struggle.

Children's Privacy

Our courses are designed for adults interested in professional game development skills. We don't knowingly collect data from anyone under 16 years old without parental consent.

If we discover that someone under 16 has registered without proper consent, we'll delete their account and all associated data immediately. Parents who believe their child has provided information to us should contact support@qrilyondakomietos.com right away.

Third-Party Links

Course materials sometimes include links to external websites, game development tools, or resource libraries. We're not responsible for the privacy practices of these third-party sites. When you leave our platform, you should review the privacy policy of any site you visit.

We carefully vet educational resources before linking to them, but we can't control how external sites handle your data once you click through.

Changes to This Policy

We update this privacy policy occasionally to reflect changes in our practices, legal requirements, or platform features. The "Last Updated" date at the top shows when the most recent revision happened.

For minor changes like clarifying existing practices, we'll simply update the document. For significant changes that affect how we process your data, we'll notify you by email at least 30 days before the new policy takes effect. This gives you time to review changes and exercise your rights if needed.

Complaints and Regulatory Authority

If you're unhappy with how we've handled your personal data, please contact us first so we can try to resolve the issue. We take complaints seriously and investigate every concern thoroughly.

You also have the right to file a complaint with Serbia's data protection authority, the Commissioner for Information of Public Importance and Personal Data Protection. You can reach them at:

Commissioner for Information of Public Importance and Personal Data Protection
Bulevar kralja Aleksandra 15
11000 Belgrade, Serbia
Phone: +381 11 3408 900
Email: office@poverenik.rs