Privacy Policy

Agreement on the Protection of Personal Data of Users of the Internet Portal “leadder.net”

This Privacy Policy applies to all information that the Internet Portal located at the domain name https://leadder.net (hereinafter, the “Portal” or “Site”) may receive about the User during the use of the Internet Portal, and is based on the Law on the Protection of Personal Data of the Republic of Serbia (No. 87/2018).

DEFINITIONS

1.1. The following terms are used in this Privacy Policy:

1.1.1. “Site Administration” – authorized employees managing the website on behalf of Sole Proprietor “Milana Fedotova,” who organize and/or perform the processing of personal data, determine the purposes of processing, the composition of the data to be processed, and actions (operations) performed with the personal data.

1.1.2. “Personal data” – any information directly or indirectly related to an identified or identifiable individual (data subject).

1.1.3. “Processing of personal data” – any action or set of actions performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, usage, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction.

1.1.4. “Confidentiality of personal data” – a mandatory requirement for the Operator or other persons who have access to personal data not to allow its dissemination without the consent of the data subject or the presence of another legal basis.

1.1.5. “User” – a person who accesses the Site via the Internet and uses it.

1.1.6. “Cookies” – small data fragments sent by a web server and stored on the user's device, which the web client or browser sends to the web server each time in an HTTP request when trying to open a page.

1.1.7. “IP address” – a unique network address of a node in a computer network based on the IP protocol.

1.1.8. “User Account” – a personalized section of the site accessible after user authorization where they can manage their data and interaction with the services of the Internet Portal.

1.1.9. “Messenger” – an application or web service intended for real-time communication between users via the Internet (e.g., Telegram, WhatsApp, Facebook Messenger).

1.1.10. “Bot” – an automated program used to interact with users in messengers, including for technical support and handling requests.

2. General Provisions

2.1. Use of the Site https://leadder.net by the User implies full and unconditional acceptance of this Privacy Policy and the terms of processing the User’s personal data.

2.2. If the User disagrees with the terms of the Privacy Policy, they must stop using the Site.

2.3. This Privacy Policy applies only to https://leadder.net and its subdomains. Milana Fedotova is not responsible for third-party websites or external data sources.

2.4. Legal Basis for Processing: Processing of Personal Data is carried out on the basis of User consent (for registration data) and the legitimate interest of the Operator (for providing the service).

2.5. The Site Administration does not verify the accuracy of personal data provided by Users, but relies on the User’s obligation to provide accurate information.

3. Subject of the Privacy Policy: Data Categories

3.1. This Policy addresses the processing and protection of two categories of data:
A) User Registration Data
B) Aggregated Open Data (Leads)

A) User Registration Data (Provided by User)

3.2. Personal data provided by the User for registration and use of the Service includes (but is not limited to):

• Full name or company name (if applicable);
• Phone number (for authentication/contact);
• Email address;
• Telegram or Google account data (e.g., user ID, name);
• Interaction history with bots and support forms (messages, timestamps, actions);
• Transaction data (excluding full payment card details, which are processed by third-party payment systems).

Identification data of third-party services: Identifiers (ID) and/or authorisation tokens (e.g., Telegram Bot API token) provided by the User with their explicit consent to ensure the functionality of the Service.

3.3. Metadata (Automatically Collected):
Data automatically collected by scripts (pixels) and server logs may include:

• IP address;
• Cookies;
• Browser or viewer software data;
• Access time;
• Page address where the ad block is located;
• Referrer (previous page address).

3.4. Disabling cookies may affect access to authorized sections of the website.

B) Aggregated Open Data (Leads)

3.5. Nature of Aggregated Data.
The Portal's primary function is the aggregation, structuring, and display of publicly available information (client inquiries/leads) from open online sources (e.g., public Telegram channels, forums).

3.6. Responsibility for Open Data.
The Site Administration processes this Aggregated Open Data for the User's benefit. Since this data is publicly available and collected using open standards (HTTP requests to public endpoints), the Administration treats it as information that has been made public by the original source. The Administration does not collect sensitive personal data from these sources.

4. Purposes of Collecting User Data

4.1. Personal data is used for:

• Identifying the User and providing Service access (Account);
• Fulfillment of contractual obligations under the Public Offer Agreement;
• Feedback and support, including via Messenger/Bot;
• Security, integrity, and fraud prevention;
• Order and payment status notifications;
• Marketing communications (only with explicit consent);
• Partner integrations and improving Service functionality.

5. Methods and Periods of Processing

5.1. Processing is carried out for the duration of the contractual relationship with the User and for a reasonable period thereafter as required by law (e.g., tax documentation).

5.2. Cross-Border Transfer:
User data may be transferred to third parties (e.g., hosting providers, cloud services, payment systems) located outside the Republic of Serbia, provided such transfer is necessary for fulfilling the Service and complies with the level of protection guaranteed by the Law on the Protection of Personal Data of the Republic of Serbia (including adequate safeguards for countries outside the EEA).

5.3. Personal data may be transferred to authorized bodies of the Republic of Serbia only in accordance with Serbian law (e.g., court order).

5.4. In case of a data breach, the Site Administration will inform the User and the competent supervisory authority (Poverenik za informacije od javnog značaja i zaštitu podataka o ličnosti) without undue delay, as required by law.

5.5. Third-Party Data Processors. The Service uses the following third-party services that may process User data in accordance with their respective privacy policies:

• Dodo Payments (https://dodopayments.com) — payment processing provider. All payment transactions are processed by Dodo Payments. The Service does not store or have access to full payment card details.
• Telegram (https://telegram.org) — used for user authentication, bot interactions, and lead data aggregation from public channels.
• Google (https://google.com) — used for user authentication and account management.

Each third-party processor operates under its own privacy policy and data protection standards. By using the Service, the User acknowledges and consents to the transfer of relevant data to these processors as necessary for the operation of the Service.

6. User Rights (Data Subject Rights)

6.1. The User has the right to exercise the following rights with respect to their registration data (Personal Data Category A) provided directly to the Platform:

• Access their personal data;
• Request Rectification of inaccurate data;
• Request Erasure (Right to be Forgotten) of their data, provided there are no legal obligations to retain it;
• Request Restriction of processing;
• Object to processing (if processing is based on the Operator's legitimate interest, excluding processing required for contract fulfillment).

6.2. Scope of Rights.
The rights listed in 6.1 apply exclusively to the data provided by the User for registration and use of the Service. The Administration reserves the right to deny requests for the erasure or restriction of Aggregated Open Data (Personal Data Category B), as this data is publicly available, indexed by the Service in the User’s legitimate interest, and its processing is necessary for Service functionality.

To exercise these rights, the User must send a written request to info@leadder.net.

7. User and Admin Obligations

7.1. The User must:

• Provide accurate and complete personal data during registration;
• Promptly update data in case of changes.

7.2. The Site Administration must:

• Use data only for specified purposes;
• Not disclose or sell data without User’s consent (except as legally required);
• Take necessary technical and organizational measures to protect data;
• Block or delete data upon valid request from the User.

LIABILITY

7.1. The Site Administration is liable for damages caused by unlawful use of personal data, except for cases:

• Data became public before disclosure;
• Data was received from third parties;
• Disclosure was permitted by the User.

7.2. The Site Administration must:

• Use data only for specified purposes;
• NEVER request, store, or have access to User passwords for any third-party services (including Telegram or Google);
• Not disclose or sell data without User’s consent (except as legally required);
• Take necessary technical and organizational measures to protect data;
• Block or delete data upon valid request from the User.

7.3. The Site is not liable for data loss resulting from unauthorized access to messenger accounts due to weak password protection.

DISPUTE RESOLUTION

8.1. Before going to court, parties must try to settle disputes via a written claim.

8.2. The claim must be reviewed within 30 calendar days.

8.3. If unresolved, disputes are submitted to court under the laws of the Republic of Serbia.

ADDITIONAL TERMS

9.1. The Site Administration may update the Privacy Policy without User consent.

9.2. The updated policy becomes effective upon publication unless otherwise stated.

9.3. Questions about the policy may be sent to: info@leadder.net

9.4. The current policy is available at: https://leadder.net/docs/privacy-policy

OPERATOR DETAILS

MILANA FEDOTOVA PR
Preduzetnik, Serbia
PIB: 114956391
Registration No: 67981804
Address: Tikveška 19, Voždovac, Belgrade, 11050