Privacy policy

This Privacy Policy explains how Larko Digital DOOEL Berovo (hereinafter: "we", "us", or "the Service Provider"), as the operator of the web application eBiblioteka, collects, uses, stores, and protects the personal data of users and individuals whose data is processed through the Application.

This Policy applies to the website ebiblioteka.mk, all subdomains (subdomain.ebiblioteka.mk), the registration form (registracija.ebiblioteka.mk), and all services related to eBiblioteka.

By using our services, you agree to the processing of data described in this Policy. If you do not agree, please do not use our services.

The entity responsible for processing personal data is:

Roles in data processing

In accordance with the Law on Personal Data Protection, regarding data entered into the Application:

• The School (the User) is the Controller of personal data - it decides which data will be entered and for what purpose.
• Larko Digital DOOEL (the Service Provider) is the Processor - it processes the data technically through the Application, on behalf of and according to the instructions of the Controller.

This means that the school bears the primary responsibility for the lawfulness of the entered data, while we are responsible for their technical protection and security.

A) Data during school registration

During school registration through the registration form, we collect:

• Name of the school
• Address and location
• Tax Identification Number (TIN) and Registration Number
• Full name of the school principal
• Contact phone number
• Email address

Note: The TIN and Registration Number are publicly available data of legal entities (schools) and do not constitute personal data of natural persons.

B) Data entered by the school into the Application

After registration, the school independently enters data necessary for the operation of the library:

• Students: first name, last name, class/grade, email (optional)
• Teachers: first name, last name, subject, contact
• Books: title, author, ISBN, quantity, condition
• Textbooks: title, publisher, subject, grade, records per student
• Loans: issue date and return date, responsible persons

This data is entered by the User (the school) and the User is responsible for its accuracy and lawfulness.

C) Technical data (automatic)

When visiting our website, the following data is automatically collected:

• IP address
• Browser type and version
• Operating system
• Date and time of the visit
• Pages visited

This data is used exclusively for analytics and service improvement, and is not linked to specific individuals.

D) Data from the contact form

When you contact us through the website form, we collect: your name, email address, and the content of the message.

We collect and process personal data for the following purposes:

• Service provision: Creating and maintaining user accounts, enabling the features of the Application (records of books, textbooks, loans).
• Communication: Responding to inquiries, sending technical notifications, introductory information, and usage guides.
• Service improvement: Usage analysis to improve functionality and user experience.
• Legal obligations: Fulfilling legal requirements, including maintaining records in accordance with tax regulations.
• Security: Protecting the system from misuse, unauthorized access, and cyber attacks.

Important: We never use data entered by schools for marketing, sale to third parties, profiling, or any other purpose other than providing the service.

In accordance with the Law on Personal Data Protection of the Republic of Macedonia, we process data on the basis of:

• Contractual obligation (Art. 10, Para. 1, Item 2): Processing is necessary for the performance of the contract for using the Application.
• Consent (Art. 10, Para. 1, Item 1): For processing data during registration and for sending communications.
• Legitimate interest (Art. 10, Para. 1, Item 6): For system security, prevention of misuse, and service improvement.
• Legal obligation (Art. 10, Para. 1, Item 3): For maintaining tax records and other documentation required by law.

The school, as the Controller, is responsible for ensuring an appropriate legal basis for the entry of student and teacher data (e.g., parental consent, legal obligation for record-keeping).

Access to data entered in the Application is granted to:

• Authorized personnel from the school: Administrators, librarians, teachers, and students - each with an appropriate level of access defined by the school administrator.
• Our technical team: A limited number of employees and associates who have access exclusively for purposes of maintenance, technical support, and problem resolution. All are bound by a confidentiality agreement.

We DO NOT share your data with:

• Third-party companies for marketing or advertising
• Other schools or organizations
• Government institutions (unless required by a legal order)
• Any other entity without your explicit consent

If it is necessary to engage a sub-processor (e.g., for hosting or backups), this will only be done with the prior consent of the User and with ensuring the same level of protection.

We implement appropriate technical and organizational measures to protect your data:

Technical measures

• SSL/TLS encryption: All communications between your device and our servers are encrypted.
• Secured infrastructure: Servers are located in professional data centers with physical and network protection.
• Regular backups: Automatic saving of all data for protection against loss.
• Firewall and monitoring: Continuous protection against unauthorized access and cyber attacks.
• Cryptographically protected passwords: User passwords are stored in a cryptographically protected (unreadable) form.

Organizational measures

• Access to data is restricted on a need-to-know basis.
• All employees and associates with access to data are bound by a confidentiality agreement.
• Regular review and updating of security measures.
• Procedure for notification in case of security incidents (within 72 hours).

We retain personal data only for as long as necessary for the purposes for which it was collected:

• Data in the Application: For the duration of the Usage Agreement. After termination of the Agreement, the User has 30 days to download their data, after which it is deleted from our systems.
• Registration data: For the duration of the service usage, plus an additional period for potential legal needs (maximum 3 years after termination).
• Invoices and financial data: In accordance with tax regulations (10 years).
• Technical logs: Maximum 90 days.
• Contact form: Maximum 12 months from receipt of the message.

After the expiration of these periods, data is permanently deleted or anonymized.

Under the Law on Personal Data Protection, you have the right to:

• Access: Request information about what personal data we hold about you and obtain a copy.
• Rectification: Request correction of inaccurate or incomplete personal data.
• Erasure: Request deletion of your personal data when it is no longer necessary for the purpose for which it was collected.
• Restriction: Request restriction of the processing of your personal data in certain situations.
• Portability: Receive your personal data in a structured, commonly used format.
• Objection: Lodge an objection against the processing of your personal data.
• Withdrawal of consent: If processing is based on consent, you may withdraw it at any time.

To exercise your rights, contact us at info@ebiblioteka.mk. We will respond to your request within 30 days.

Note regarding student data: If a parent/guardian requests access, correction, or deletion of a student's data, the request should be submitted to the school (the Controller), which will then contact us for technical implementation.

If you believe that your personal data protection rights have been violated, you have the right to submit a request to the Personal Data Protection Agency of the Republic of Macedonia (www.dzlp.mk).

Our website uses cookies to improve the user experience:

Essential cookies

These cookies are necessary for the basic functioning of the website and cannot be disabled. They include session cookies and security cookies.

Analytics cookies

We use Google Analytics to understand how visitors use our website. These cookies collect anonymous statistical data. You can disable them in your browser settings.

Managing cookies

You can control and delete cookies through your web browser settings. Please note that disabling essential cookies may affect the functionality of the Application.

Your data is stored on servers located in Europe. We do not transfer personal data outside the European Economic Area (EEA) unless it is necessary for providing the service (e.g., for email service), in which case we ensure appropriate protective measures in accordance with the Law on Personal Data Protection.

Google Analytics may transfer anonymized analytics data to servers outside the EEA. This data does not contain personal information and is subject to Google's privacy policy.

In the event of a security incident involving personal data (e.g., unauthorized access, loss, or destruction of data), we commit to:

• Notifying the affected school (the User) without unnecessary delay, and no later than within 72 hours from becoming aware of the incident.
• Taking all necessary measures to mitigate the damage.
• Cooperating with the User and the competent authorities (Personal Data Protection Agency) if necessary.
• Providing a detailed report on the nature of the incident, the affected data, and the measures taken.

This Privacy Policy may be updated from time to time. For significant changes, we will notify users through:

• Notification via email
• A visible notice on our website
• Notification within the Application itself

We recommend periodically checking this page for any updates. The date of the last amendment is indicated at the beginning of the document.

For questions, requests, or complaints regarding the protection of your personal data, contact us:

Competent authority for personal data protection: