Dávid Gyetván (1104 Budapest, Alkér street 70.) (further on: Service-provider, Data processor) subdues itself under the following policy:
REGULATION (EEC) No 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (27 April 2016) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Regulation (EC) No 95/46, the following information is provided.
„personal data”: any data that can be related to the Customer – especially the name, username of the customer and any knowledge characteristic for one or more physical, physiological, mental, economic, cultural, or social identity of the Customer – and any conclusion related to the Customer drawn from the data;
„data management”: the totality of any operation or operations carried out in an automated or non-automated manner on personal data or data files, such as collecting, recording, organizing, tagging, storing, modifying or modifying, querying, inspecting, using, communicating, distributing or otherwise making available, aligning or linking, limiting, deleting or destroying;
„data manager”: means any natural or legal person, public authority, agency or any other body that determines the purposes and means of handling personal data individually or with others, where the purposes and means of data management are defined by Union or national law, the data controller or the particular aspects of the designation of the data controller may also be defined by Union or national law;
„data processor”: means any natural or legal person, public authority, agency or any other body that manages personal data on behalf of the data controller;
„recipient”: is a natural or legal person, a public authority, agency or any other body with whom or with which personal data is communicated, whether or not it is a third party. Public authorities who have access to personal data in an individual investigation in accordance with Union or national law shall not be considered recipients; the management of those data by those public authorities must comply with the applicable data protection rules in accordance with the purposes of data management;
„the contributor concerned”: a voluntary, specific and appropriate informed and explicit statement of the will of the person concerned by which he or she expresses the statement or confirmation by means of an inadvertent act of affirmation that he or she has consented to the processing of personal data concerning him or her;
„data protection incident”: a security breach resulting in accidental or unlawful destruction, loss, alteration, unauthorized disclosure or unauthorized access to personal data transmitted, stored or otherwise treated.
3. THE PRINCIPLES OF PERSONAL DATA MANAGEMENT
The personal data:
must be legally and fairly handled and transparent to the person concerned ("lawfulness, fairness and transparency");
are collected for specified, clear and legitimate purposes and are not treated in a manner incompatible with these purposes; in accordance with Article 89 (1), no further data handling ("end-use") for purposes of public interest archiving for scientific and historical research purposes or for statistical purposes shall not be considered incompatible with the original purpose;
must be appropriate and relevant to the purposes of data management and should be limited to the need ("saving of the data");
must be accurate and, if necessary, up-to-date; all reasonable measures must be taken to correct or correct inaccurate personal data for the purposes of data management ("accuracy");
must be stored in a form which permits the identification of the data subjects only for the time needed to manage the personal data; the retention of personal data may only take place if the personal data are processed in accordance with Article 89 (1) for public interest archiving, for scientific and historical research purposes or for statistical purposes, in accordance with the rights and subject to appropriate technical and organizational measures for the protection of their freedoms ("limited storage");
shall be managed in such a way as to ensure adequate security of personal data, including the protection against unauthorized, unlawful, unintentional, loss or destruction of data ("integrity and confidentiality") by means of appropriate technical or organizational measures.
The data processor is responsible for the above and must be able to demonstrate compliance ("accountability").
The data controller declares that its data management is carried out in accordance with the principles set out in this section.
4. DATA MANAGEMENTS
4.1. Registration (creation of user account)
The fact of data collection, the range of managed data, and the aim of data management:
Aim of data management
It is necessary for identification and secure access to the user account.
Article 6 (1) (a) and (b).
To keep in touch, send system messages, and log in to a user account.
Article 6 (1) (a) and (b).
Provides secure access to the user account.
Article 6 (1) (a) and (b).
Compliance with data protection rules.
Article 6 (1) (a) and (b).
Date of registration
The fulfillment of technical operation.
Article 6 (1) (a) and (b).
IP address at the time of registration
The fulfillment of technical operation.
Article 6 (1) (a) and (b).
Range of Customers: Everybody registered on the website.
Time of data handling, the deadline for data deletion: If one of the conditions set out in Article 17 (1) of the GDPR is met, it lasts until the person concerned requests cancellation. Deleting the registration will immediately delete the personal data. The controller shall inform the data subject electronically in accordance with Article 19 of the GDPR of the deletion of any personal data provided by the data subject. If the data subject's request for cancellation also covers the e-mail address provided by the data subject, the data controller will also delete the e-mail address after the notification.
Possible data managers entitled to know the data, the recipients of personal data: Personal data may be handled by authorized personnel of the Data Controller in accordance with this Prospectus.
Describe the rights of data subjects involved in data management:
The data subject may apply to the data controller for access to, correction, deletion, or limitation of the personal data concerning him, and
the data subject has the right to data storage and to withdraw the consent at any time.
It is possible to initiate, delete, modify, or restrict access to personal data, transferability of data, and objection to data processing in the following ways:
By post at the address: Hungary, 1104 Budapest, Alkér street 70.
Legal basis for data processing: Article 6 (1) ( a) and (b ).
We inform you that:
Data management is necessary for your consent or to take action at your request prior to the conclusion of the contract.
You are obliged to provide personal information to register.
Failure to provide the data has the consequence that the user account cannot be created.
5. ADDRESSES WITH WHOM PERSONAL DATA IS COMMUNICATED WITH
„Recipient”: any natural or legal person, public authority, agency, or any other body with which personal data are disclosed, whether or not a third party is involved.
5.1. Data processors (who perform data management on behalf of the data controller)
The Data Controller uses data processors to facilitate its own data management activities and to fulfill its obligations under contract or legislation.
The Data Controller places great emphasis on using only data processors who either provide adequate guarantees to implement data management in compliance with GDPR requirements and ensure adequate technical and organizational measures to protect the rights of stakeholders.
The data processor and any person acting under the control of the controller or the data processor who has access to personal data shall treat the personal data contained in these regulations only in accordance with the instructions of the data controller.
The controller is responsible for the data processing activities. The data processor is only liable for damages caused by data management if he or she has not complied with the obligations specified in the GDPR specifically for processors, or if the data controller has ignored or acted contrary to the lawful instructions of the data controller.
There is no substantive decision-making on data processing by the data processor.
If you have questions during using some of the services of the data processor, or the customer has some problem you can get in contact with the data processer on the website (on the phone, e-mail, community sites, etc.).
The data processor deletes the incoming e-mails, messages, on phone, on any community site, etc. that contain the name and e-mail address or any other given personal information of the customer, after 2 years from the start of the service.
For exceptional magisterial requests, or in case of law accumulation the service provider is bound for guidance, the information providing, transferring, or making documents available for these organizations.
In these cases, the service provider only gives personal information for the request (if they pointed out the exact aim and the necessary information) what are essentials for the aim of the request.
8. CUSTOMER RIGHTS
The right of access
You are entitled to receive feedback from the data controller about whether your personal data is being processed and, if such processing is in progress, you have the right to have access to your personal information and the information listed in the decree.
The right of rectification
You are entitled to request the data controller to rectify any inaccurate personal information that he or she is required to do without undue delay. Taking into account the purpose of data management, you are entitled to request the supplementation of incomplete personal data, including by means of a supplementary statement.
The right to cancel
You are entitled to request that the data controller, without undue delay, disclose personal information about you, and that the data controller is obliged to delete personal information about you, without undue delay, under certain conditions.
The right to be forgiven
If the data controller has disclosed the personal data and is required to cancel it, taking reasonable steps, including technical measures, to take into account the cost of available technology and implementation, in order to inform the data controller handling the data that you have applied for the personal data in question pointing links or deleting a duplicate or duplicate of these personal data.
The right to restrict data management
You are entitled to request that your data controller restricts your data handling if one of the following conditions is met:
You dispute the accuracy of your personal data; in this case, the restriction applies to the period of time that the data controller can check the accuracy of personal data;
Data handling is illegal and you are opposed to the deletion of data and instead asks you to restrict them;
The data controller no longer needs personal data for data processing, but you require them to submit, enforce, or protect legal claims;
You have objected to data manipulation; in this case, the restriction applies to the period when it is established that the legitimate reasons for the data controller have priority over your legitimate reasons.
The right to data storage
You are entitled to receive personal data that is made available to you by a data controller in a fragmented, widely used machine-readable format and is entitled to transfer this data to another data controller without this being obstructed by the data controller whose provided personal information to you (...)
The right to protest
You are entitled to object to the handling of your personal information (...), including profiling based on these provisions, for any reason relating to your own situation.
Protest in case of direct business acquisition
If your personal data is handled for direct business, you are entitled to protest at any time against the handling of personal data relating to it, including profiling if it is related to a direct business acquisition. If you object to personal data being handled for direct business purposes, your personal information can no longer be handled for that purpose.
Automated decision-making in individual cases, including profiling
You are entitled to exclude the scope of any decision based solely on automated data handling, including profiling, which would have a bearing on it or affect it significantly. The preceding paragraph shall not apply if the decision is:
You are required to conclude or complete a contract between you and the data controller;
the granting of the right to a data controller is subject to the law of the Union or of the Member States which also lays down appropriate measures to protect your rights and freedoms and legitimate interests; or
you are based on your explicit consent.
9. DEADLINE FOR ACTION
The data controller informs you of any measures taken in response to these requests without undue delay but in any way within 1 month of receipt of the request.
If necessary, it may be extended by 2 months. The controller will inform you about the extension of the deadline by indicating the cause of the delay within 1 month of receipt of the request.
If the data controller fails to take action upon your request, he or she will notify you without delay and at the latest within one month of the receipt of the request for reasons of non-action and whether you may file a complaint with a supervisory authority and exercise its right of appeal.
10. SECURITY OF DATA MANAGEMENT
The data controller and the data processor shall take appropriate technical and organizational measures to take into account the state of science and technology and the costs of implementation, the nature, scope, circumstances and objectives of data management and the risk of varying probability and severity of natural persons' rights and freedoms to guarantee an adequate level of data security, including, inter alia, where appropriate:
(a) the pseudonymization and encryption of personal data;
(b) ensuring, maintaining, integrity, availability and resilience of the continuing confidentiality of systems and services used to manage personal data;
(c) in the case of a physical or technical incident, the ability to restore access to personal data and the availability of data in good time;
(d) the procedure for systematic testing, assessment and evaluation of the effectiveness of technical and organizational measures taken to ensure the security of data processing.
(e) The data processed must be stored in such a way as to prevent unauthorized access. In the case of paper-based data carriers, by establishing the order of physical storage, filing, and using the central authorization system for data processed in electronic form.
(f) The method of storing the data using the IT method must be chosen so that it can be deleted at the end of the period for deletion of data, or if it is necessary for other reasons, subject to a different cancellation deadline. The deletion must be irreversible.
(g) Paper-based media shall be deprived of personal data by means of a document shredder or by an external document destruction organization. In the case of electronic data carriers, physical destruction shall be ensured in accordance with the rules on the disposal of electronic media, and, where necessary, the safe and irrevocable deletion of data shall be made in advance.
(h) The data controller will take the following specific data security measures:
In order to ensure the security of personal data handled on paper, the Service Provider applies the following measures (physical protection):
i. Place documents in a secure, lockable dry room.
ii. The Service Provider's building and premises are equipped with fire protection and property protection equipment.
iii. Personal data can only be accessed by authorized persons, third parties cannot access it.
iv. During the course of his work, the employee of the Service Provider performing data management may only leave the room where data management is taking place by blocking the data carriers entrusted to him or by closing the given room.
v. If personal data managed on paper is digitized, the rules governing digitally stored documents must be applied.
b. IT protection
i. Computers and mobile devices (other media) used in data management are the property of the Service Provider.
ii. Data on computers can only be accessed with a username and password.
iii. Access to the central server machine is only granted with the appropriate authority and only by designated persons.
iv. For the security of digitally stored data, the Service Provider uses data backups and archives.
v. A computer system containing personal data that is useful to the Service Provider is provided with virus protection.
11. INFORMING THE PERSON CONCERNED ABOUT THE PRIVACY INCIDENT
If the privacy incident is likely to pose a high risk to the rights and freedoms of natural persons, the data controller shall inform the data subject of the privacy incident without undue delay.
Information given to the data subject should be clearly and easily understood and the nature of the privacy incident must be disclosed and the name and contact details of the Data Protection Officer or other contact person providing additional information should be disclosed; the likely consequences of a data protection incident should be described; describe measures taken or planned by the data controller to remedy a data protection incident, including, where appropriate, measures to mitigate any adverse consequences of a data protection incident.
The person concerned shall not be informed if any of the following conditions are met:
the data controller has implemented appropriate technical and organizational protection measures and applied these measures to the data covered by the data protection incident, in particular the measures, such as the use of encryption, which make it impossible for persons who are unauthorized to access personal data the data;
after the data protection incident, the data controller has taken further measures to ensure that high risk for the rights and freedoms of the person concerned is no longer likely to be realized;
Informing would require disproportionate efforts. In such cases, the data subject shall be informed by means of publicly disclosed information or a similar measure shall be taken to ensure that such information is equally effective.
If the data controller has not yet notified the data subject of the data protection incident, the supervisory authority may, after considering whether the privacy incident is likely to pose a high risk, may inform the data subject.
12. REPORTING A PRIVACY INCIDENT TO THE AUTHORITY
The data protection incident shall be reported to the supervisory authority under Article 55 without undue delay and, if possible, no later than 72 hours after the data protection incident becomes known, unless the data protection incident is unlikely to pose a risk to the rights of natural persons and freedom. If the notification is not filed within 72 hours, the reasons for proving the delay must also be enclosed.
13. REVIEW FOR MANDATORY DATA MANAGEMENT
If the period of mandatory data management or the periodic review of its necessity is not specified by law, local government regulation, or a binding act of the European Union, the controller shall review at least every three years from the commencement of the data processing that it or the processor acting on its behalf or on its instructions and if the personal data management is necessary for the purpose of data management.
The circumstances and results of this review shall be documented by the Data Controller, and shall be retained for a period of ten years after the review has been conducted and made available to the Authority at the request of the National Authority for Data Protection and Freedom of Information (hereinafter referred to as the Authority).
14. COMPLAINT OPPORTUNITY
Complaint regarding the possible breaching of the law by the data manager can be made to the Hungarian National Authority for Data Protection and Freedom of Information:
Hungarian National Authority for Data Protection and Freedom of Information
1055 Budapest, Falk Miksa street 9-11.
Mailing address: 1374 Budapest, Post office box: 603. Telephone: +36 -1-391-1400
15. CLOSING REMARKS
The following regulations were accounted in the course of composing the guide:
REGULATION (EEC) No 2016/67 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (27 April 2016) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Regulation (EC) No 95/46
2011 CXII. Law on information self-determination and freedom of information (hereinafter: Infotv.)
Act CVIII of 2001 - Act on Electronic Commerce and Information Society Services (especially Section 13 / A)
Act XLVII of 2008 - Act on the Prohibition of Unfair Commercial Practices against Consumers;
Act XLVIII. Of 2008 – the basic conditions and certain limitations of economic advertising activity (in particular Article 6)
XC. Law of 2005 on Eletronic Freedom of Information
Act C of 2003 on Electronic Communications (specifically Article 155)
No. 16/2011. an opinion on the EASA / IAB Recommendation on Best Practice in Behavioral Online Advertising
Recommendation of the National Data Protection and Information Authority on the data protection requirements for prior information