Privacy Policy — Klub čitalaca (Readers' Club)
Effective date: 18 July 2026
This privacy policy explains how Društvo sa ograničenom odgovornošću Nova knjiga (Nova knjiga LLC), with its registered office at Ludvika Kube, Gorica C — zgrada Razvršja bb, Podgorica, Montenegro, tax ID (PIB) 02290006 ("we" or "Nova knjiga"), collects, uses, shares, and protects the data of users of the Klub čitalaca mobile application (the "app").
Who we are and how to contact us
- Company: Društvo sa ograničenom odgovornošću Nova knjiga
- Address: Ludvika Kube, Gorica C — zgrada Razvršja bb, Podgorica, Montenegro
- Tax ID (PIB): 02290006
- Privacy and user request email: nknjiga@gmail.com
Who this policy applies to
This policy applies to users of the Klub čitalaca app. The app does not allow creating a new membership or account. It only allows users whose membership already exists in the PANTHEON business system to sign in via a one-time email link, access their existing membership data, view member benefits and purchase history, and, if they choose, receive notifications.
What data we collect
Data you provide
- Email address — for one-time-link sign-in, account communication, and exercising your rights.
- First and last name — if you enter them or if they are already linked to your Readers' Club membership.
- Date of birth — if you voluntarily enter it for a birthday greeting and birthday benefit.
- Communication and feedback content — if you contact support, report a problem, or send feedback through the app.
Membership and service usage data
- Account and membership card identifiers.
- Membership status, tier, points, discounts, and other benefits linked to the account. Points and the membership tier are determined automatically from recorded purchases, and the calculation resets at the start of each calendar year.
- Purchase history, including purchased items, purchase date, and value, to the extent linked to the membership.
- Notification history, including notifications we sent and whether they were marked as read.
- Membership and purchase data originates from the PANTHEON business information system, provided to Nova knjiga by Datalab MN d.o.o.
PANTHEON may hold a wider set of member data, including username, email, national ID number (JMBG), date of birth, registration date, last sign-in, profile photo, name, card number, and loyalty category. The app uses only the name, card number, loyalty category, email, and date of birth from that set. The app does not retrieve or use the JMBG, registration date, last sign-in, or profile photo from PANTHEON.
Device, analytics, and diagnostics data
Depending on app settings and your choices, the app and its embedded services may process:
- Device push token and data needed to technically deliver notifications.
- App, installation, session, account, or device identifiers used by our technical services.
- Device and app data, such as device model and manufacturer, operating system and version, app version, screen size and characteristics, language, country or approximate region derived from technical data, and network data such as IP address.
- App usage data, such as screens opened, features used, taps and gestures, session duration and flow, and interactions with the app.
- Diagnostics and performance data, such as app crashes, errors, stack traces, startup time, freezes, network requests, and other technical events.
- Sentry Session Replay is not used, and the app does not send Sentry any recordings or reconstructions of user sessions.
We link Sentry diagnostics only to a pseudonymous user identifier, without sending the email address. Microsoft Clarity is not used in the app.
We do not access your contacts, photos, videos, microphone, or precise device location, unless app functionality changes in the future and we notify you in advance.
How we use data
| Purpose | Data used |
|---|---|
| Sign-in and access to an existing membership account | Email, account identifiers, first and last name |
| Displaying membership, purchases, points, discounts, and benefits | Membership, membership card, and purchase data |
| Service messages, including the sign-in link | Email, account data, and technical delivery data |
| Push notifications, including the birthday benefit — only with your permission | Push token, user identifier, date of birth, and notification history |
| Usage analytics and app improvement (Firebase Analytics) | Pseudonymous identifiers and device, app, session, and interaction data |
| Detecting and fixing errors and monitoring performance (Sentry) | Pseudonymous identifier, diagnostics, and performance data |
| Support and responding to user requests | Contact data, request content, and technical data related to the report |
| Meeting legal obligations | Data we must retain or disclose under law |
An email address is required to sign in. The date of birth and push notifications are voluntary — all core account features work without them; you simply will not receive the related benefit or notifications.
Who we share data with
We do not sell data or share it with third parties for advertising. We provide data to the following service providers only to the extent needed to run the app:
- Hetzner Online GmbH — hosting of application servers and the database in Nuremberg, Germany.
- Mailgun / Sinch — technical email delivery, including one-time sign-in links, via infrastructure in the European Union.
- Expo / 650 Industries, Inc. — technical delivery of push notifications.
- Google LLC and affiliates (Firebase) — Firebase Analytics, technical Firebase services, and, where applicable, push notification delivery.
- Functional Software, Inc. (Sentry) — error reporting, diagnostics, and performance monitoring, without session replay.
- Data Design d.o.o., Branimir Bukilić — owner and administrator of the Mailgun account used for technical email delivery for the Nova knjiga, Gradska knjižara, Kosmos, and Klub čitalaca brands.
- Datalab MN d.o.o. — provider of the PANTHEON business information system from which existing membership and purchase data originates.
- Public authorities, courts, or other recipients where disclosure is required by law or needed to protect our rights.
We require service providers to use data only to provide the contracted service and to apply appropriate safeguards. Some providers use infrastructure outside Montenegro and the European Economic Area; such transfers rely on safeguards provided for by data protection regulations.
Data security
Communication between the app and our servers uses HTTPS/TLS encryption, and access to data is limited on a need-to-know basis. Sign-in uses time-limited one-time links instead of passwords. No security measure can remove risk entirely, but we review our measures regularly in line with the nature of the processing.
How long we keep data
We keep data only as long as needed for the purposes it was collected for, unless the law requires a longer period:
- Account and profile data in the application system is kept while the membership is active. When a membership is fully deleted or anonymized in PANTHEON, the related data in the application system is deleted.
- The push token is kept while notifications are enabled and the token is valid. A previous token is removed or replaced when the app receives a new token, when the user signs out, or when the membership is deactivated.
- Individual notification history is kept for up to 12 months, and automated system notification history for up to three months.
- Technical access logs are kept for up to 30 days.
- Firebase Analytics user-level and event-level data is kept for the default period of two months.
- Sentry events and diagnostics are kept for up to 90 days.
- Backups are deleted or overwritten within two weeks.
After the applicable period expires, we delete the data or irreversibly anonymize it.
Account and data deletion
It is not possible to create a new membership or delete an existing membership in the app. Membership and related data are managed in the PANTHEON business information system, while the app provides access to an existing membership.
You can request deletion of your data or termination of your membership at nknjiga@gmail.com. Nova knjiga will process the request and, where needed, coordinate its execution with the PANTHEON provider. After receiving a request, we may ask for reasonable identity verification to prevent unauthorized deletion. Under normal circumstances we complete the request within 15 days.
When a membership is fully deleted or anonymized, data that exists only in the application system is also deleted. Historical business records that must be retained by law are kept in a form that can no longer be linked to the user.
Deleting the app from your device does not by itself delete your account.
Your controls and rights
- You can turn push notifications off in the app (Profile > Settings > Notifications) or in your device's system settings; turning them off in the app removes the push token from our server.
- You can request access to your data, correction of inaccurate data, deletion of data, or object to analytics and diagnostics — write to nknjiga@gmail.com. We respond without undue delay, at the latest within one month.
- If you believe your rights have been violated, you can contact the Montenegrin Agency for Personal Data Protection and Free Access to Information (azlp.me).
Children
The app is intended exclusively for adult users, i.e. persons at least 18 years old. We do not knowingly collect data of persons under 18. Membership is opened in person at a Nova knjiga store with an identity document check. If we learn that a person under 18 is using the app, we will take reasonable steps to disable access and delete data collected contrary to these rules.
Changes to this policy
We may update this policy from time to time to reflect changes to the app, service providers, or regulations. The effective date of the latest version is shown at the top of the document. We will notify you of significant changes through the app or by email.
The current version of this policy is available at legal.kc.novaknjiga.com, and in English at legal.kc.novaknjiga.com/en.