Osnovna škola „Junior“ Novi Sad & Gimnazija Clever School Novi Sad

Last updated: 23/01/26

1. Introduction

Osnovna škola „Junior“ Novi Sad and Gimnazija Clever School Novi Sad (hereinafter jointly referred to as the Schools, we, us) are committed to protecting the privacy and personal data of all individuals whose data we process. Special care is applied when processing personal data of children and students, whose data enjoy enhanced legal protection under the laws of the Republic of Serbia.

This Privacy Policy explains what personal data we collect, how and why we process them, how they are protected, and what rights data subjects and their legal representatives have.

2. Data Controllers

2.1 Osnovna škola „Junior“ Novi Sad

• Address: Cara Dušana 5, 21000 Novi Sad, Republic of Serbia
• Phone: +381 69 701 258
• Email: info@cleveris.org
• Registration number (MB): 08892008
• Tax ID (PIB): 105723723
• Founder: Sergey Shishov
• Principal (Director): Olga Suslova

2.2 Gimnazija Clever School Novi Sad

• Address: Cara Dušana 5, 21000 Novi Sad, Republic of Serbia
• Email: info@cleveris.org
• Founder: Sergey Shishov
• Principal (Director): Olga Suslova

Each school acts as an independent data controller, while certain administrative, educational, and technical processes may be jointly organised in full compliance with applicable law.

2A. Legal Status and Accreditation

Osnovna škola „Junior“ Novi Sad

Osnovna škola „Junior“ Novi Sad is a private primary education institution founded and operating in accordance with the laws of the Republic of Serbia. The School is duly registered as a legal entity and entered into the official register of educational institutions. The School has been verified and accredited by the competent authority acting on behalf of the Ministry of Education of the Republic of Serbia, confirming that it fulfills all legally prescribed conditions relating to: – educational facilities and equipment, – teaching aids and resources, – qualified teaching and professional staff, – implementation of the approved primary education curriculum. 

The accreditation authorizes the School to perform primary education (grades I–VIII) at its registered address in Novi Sad. The School is subject to continuous supervision and inspection in accordance with applicable education laws.

Gimnazija Clever School Novi Sad

Gimnazija Clever School Novi Sad is a private secondary education institution (gymnasium) established and operating in accordance with Serbian law. The Gymnasium holds verified status issued by the competent education authorities, authorising it to perform general secondary education. The Gymnasium operates under an approved curriculum and school program and is subject to supervision by the Ministry of Education and other competent inspection bodies.

3. Legal Basis for Processing Personal Data

The Schools process personal data lawfully and transparently, based on one or more of the following legal grounds:

• compliance with legal obligations in the field of education,
• performance of enrolment and education contracts,
• consent of parents, legal guardians, or adult students,
• protection of vital interests of students,
• execution of tasks carried out in the public interest,
• legitimate interests of the Schools, provided such interests do not override the fundamental rights and freedoms of data subjects.

4. Categories of Personal Data

4.1 Students

We may process: – personal identification data (name, date and place of birth, citizenship), – student identifiers and education records, – address and contact details, – parent or legal guardian data, – grades, attendance records, assessments, certificates, and diplomas, – data related to final and graduation exams, – individual education plans (IOP), – health-related data strictly necessary for education or student safety, – photographs and video recordings from school activities (with consent), –disciplinary, behavioral, and safety-related records.

4.2 Parents and Legal Guardians

We may process: – name and surname, – contact details, – relationship to the student, – contractual and payment-related data, – correspondence with the Schools.

4.3 Adult Students (Gymnasium)

For students who have reached legal adulthood, personal data are processed based on their own legal capacity, consent, or contractual relationship with the School.

4.4 Employees and Associates

We may process: – identification and employment data, – professional qualifications and licenses, – payroll, tax, and social security data, – attendance, performance, and access-control data.

4.5 Website Visitors

When visiting our website, we may collect: – IP address, – browser and device information, – basic usage statistics, – cookies and similar technologies.

5. Purpose of Data Processing

Personal data are processed exclusively for purposes including:

• enrolment and education of students,
• organisation and implementation of teaching, exams, and graduation, ensuring student safety, wellbeing, and protection,
• compliance with education, administrative, and financial regulations,
• communication with parents, guardians, and students,
• issuance of certificates, diplomas, and official school documents,
• operation, security, and improvement of the Schools’ websites.

5A. Educational Programs

Primary Education Program – Osnovna škola „Junior”

The School implements the official primary education curriculum of the Republic of Serbia for grades I–VIII. The program includes compulsory subjects, elective programs, extracurricular activities, individualised education plans where applicable, continuous assessment, and final certification. Personal data are processed only to the extent necessary for the lawful implementation of this educational program.

Secondary Education Program – Gimnazija Clever School

The Gymnasium implements a general secondary (gymnasium) education program in accordance with national standards. The program prepares students for higher education and academic development. Processing of personal data is limited strictly to purposes related to education, assessment, graduation, and communication.

6. Protection of Minors’ Data

The Schools apply enhanced safeguards when processing personal data of minors. Data relating to children are collected only when legally required, accessed only by authorised personnel, and never used for commercial profiling.

Consent for optional data processing activities (such as publication of photographs or videos) is obtained exclusively from parents or legal guardians, except where students are legally adults.

7. Data Sharing and Disclosure

Personal data may be disclosed only when required or permitted by law, including to:

• Ministry of Education and competent authorities,
• health, social welfare, and child-protection institutions,
• courts, inspection bodies, and law enforcement agencies,
• contracted service providers acting under data-processing agreements.

The Schools do not sell or commercially exploit personal data.

8. Data Retention

Personal data are retained for periods prescribed by education, archival, and financial regulations, or for the duration of contractual relationships. After expiration of retention periods, data are securely deleted or anonymised.

9. Data Security Measures

The Schools implement appropriate technical and organisational measures, including:

• controlled and role-based access to data,
• physical protection of documentation,
• secure IT systems and authentication,
• confidentiality obligations for all employees and associates,
• regular internal compliance checks.

9A. Constitutional Protection of Personal Data (Articles 41 and 42)

In accordance with Article 41 of the Constitution of the Republic of Serbia, which guarantees the confidentiality of correspondence and communications, and Article 42, which guarantees the protection of personal data, the Schools ensure that:

• personal data are collected and processed lawfully and transparently,
• data are used exclusively for legally defined purposes,
• unauthorised access, disclosure, or misuse is strictly prohibited,
• all data subjects are informed about data processing activities,
• constitutional and statutory rights may be exercised freely and without obstruction.

Any processing contrary to Articles 41 and 42 of the Constitution is considered a serious violation and subject to legal consequences.

10. Cookies and Website Technologies

The Schools’ websites use essential and functional cookies to ensure proper operation and basic analytics. Users may manage cookie settings through their browser. No invasive tracking or third-party advertising cookies are used.

11. Rights of Data Subjects

Data subjects, or their parents or legal guardians where applicable, have the right to:

• access personal data,
• request correction or completion,
• request deletion where legally permitted,
• restrict or object to certain processing,
• withdraw consent at any time,
• lodge a complaint with the Commissioner for Information of Public Importance and Personal Data Protection of the Republic of Serbia.

Requests may be submitted via email to: info@cleveris.org

12. Amendments to This Policy

This Privacy Policy may be updated to reflect legal or operational changes. The most recent version will always be available on the Schools’ official website(s).