This Privacy Policy explains how TUNNEL TECH DOO (hereinafter 'TUNNEL TECH'), with registered office in Serbia (Crkvena 11, Požega, Company Reg. No.: 22078097), collects, uses, protects, and processes your personal data when using the TUNNEL application and/or website (hereinafter: 'Service').

This Policy applies to all users, regardless of whether they access the service from Serbia, the EU, or other jurisdictions.

We may process the following categories of personal data:

• Identification data: Email address, full name, username, address, phone number, password (hashed)
• Technical data: IP address, device type, operating system, browser information
• Usage data: In-application activities, access times, frequency of use
• Billing data: Transaction history, license type, subscription status
• Cookie data: Anonymized identifiers, language settings, analytics

We process data based on:

• Contract performance: – for providing service after registration.
• Legitimate interest: – improving functionality and system security.
• User consent: – for cookie use or marketing messages.
• Legal obligations: – retaining accounting and tax data.

Processing data for copyright protection is based on:

• Legal obligations (GDPR Art. 6(1)(c)).
• Legitimate interest (GDPR Art. 6(1)(f)) for preventing unlawful use.

We use data for:

• Enabling registration and service access
• Managing subscriptions and invoices
• Detecting abuse and security threats
• Sending critical notices (e.g., terms changes)
• Internal analytics and system improvement
• Responding to inquiries and user support
• Preventing copyright infringement
• Verifying license validity upon authorities' request
• Enforcing repeat offender policy
• Cooperating with collective management organizations (SOKOJ, GEMA, ASCAP)

We implement the following security measures:

• Data is stored on secure servers within the EU.
• We employ SSL/TLS encryption, firewalls, and anti-DDoS protection.
• Only authorized personnel and external processors (under DPA agreements) access data.
• Data is retained while accounts are active or per legal requirements (e.g., 5 years for accounting purposes).

Your data will not be sold or shared with third parties except when:

• Required for payment processing (e.g., Stripe, PayPal)
• Necessary for technical infrastructure (e.g., hosting providers)
• Legally required by competent authorities
• Based on your explicit consent

We may share your data with:

• Collective management organizations (e.g., GEMA, ASCAP, SOKOJ)
• Competent courts and state authorities during infringement investigations
• Authorized representatives of rights holders

All external partners are contractually obligated to protect data per GDPR.

TUNNEL TECH uses infrastructure located within the European Union. Should data be transferred outside EU/EEA, we only use countries with adequate data protection levels (Article 45 GDPR) or implement standard contractual clauses (Article 46 GDPR).

All users have the following rights under Articles 15–22 GDPR:

• Right to access data
• Right to rectify inaccurate data
• Right to erasure ('right to be forgotten')
• Right to restrict processing
• Right to data portability
• Right to object
• Right to withdraw consent (where applicable)

Requests may be submitted via email: tunnel-sales@smarty.rs

We will respond within 30 days per GDPR and Serbian Personal Data Protection Law requirements.

We use cookies to enhance functionality, perform analytics, and remember your preferences. For details, see our dedicated Cookie Policy.

You may disable them in your browser, but this may impair application functionality.

We do not engage in user profiling or make automated decisions with legal effects.

The Service is not intended for children under 16 without parental/guardian consent. If we discover processing of a child's data without authorization, such data will be immediately deleted.

TUNNEL TECH reserves the right to modify this Policy. All users will be notified via email or in-app at least 30 days in advance. Updated versions will be available on our website.

TUNNEL TECH DOO

Address: Crkvena 11, 31210 Požega, Srbija

Company Reg. No.: 22078097

Email: tunnel-sales@smarty.rs

For complaints, you may also contact:
Commissioner for Information of Public Importance and Personal Data Protection,
Bulevar kralja Aleksandra 15, 11000 Belgrade
https://www.poverenik.rs

EU users may contact their local Data Protection Authority (DPA).