Privacy notice

To manage the data of newsletter subscribers

 

 

I.            Name of data controller

 

 

II.            Legislation on which the processing is based

 

The following laws apply to the processing of subscribers' data:

·        Regulation (EC) 2016/679 of the European Parliament and of the Council of 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/EC, in its current version:

https://eur-lex.europa.eu/legal-content/HU/TXT/PDF/?uri=CELEX:32016R0679&from=HU

·        Act CXII of 2011 on the Right of Informational Self-Determination and Freedom of Information (hereinafter: Info tv.), in its current text: https://net.jogtar.hu/jogszabaly?docid=A1100112.TV

·        Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions on Economic Advertising Activities, in its current text: https://net.jogtar.hu/jogszabaly?docid=A0800048.TV

·        Act CLV of 1997 on consumer protection, in force: https://net.jogtar.hu/jogszabaly?docid=99700155.TV

 

 

III.            Information on the data processed

 

Scope of data processed and purpose of data processing

 

The scope and purpose of the data processed, the duration, the legal basis and the method of processing are set out in the appendix to this notice.

 

IV.            Access to data and data security measures

 

IV.1.                    Access to and transfer of data

 

The personal data you have provided may be accessed by the Data Controller's employees in order to perform their tasks.

The Data Controller shall transfer the personal data processed to its subcontractors as set out in the Annex to this Policy.

 

The Data Controller will only exceptionally transfer your personal data to other Data Controllers, public bodies not listed in the Annex.

 

For example, if

 

·        a judicial proceeding concerning you is pending and the court in the case requires the transfer of documents containing your personal data,

·        the police contact the Data Controller and request the transfer of documents containing your personal data for the purposes of the investigation.

 

IV.2.                    Data security measures

 

The Data Controller stores the personal data you have provided on the Data Controller's servers or, where applicable, in paper files.  The Controller does not use the services of any other company to store the personal data.

The controller shall take appropriate measures to protect personal data against, inter alia, unauthorised access or unauthorised alteration. For example, access to personal data stored on the server is logged by the Data Controller, which means that it is always possible to check who has accessed what personal data, when and to what extent.

 

V.            Rights of the data subject in relation to data processing

 

1.      Your access rights

 

You, as the right holder, have access to your personal data.

 

If you request feedback from the Data Controller on whether the Data Controller is processing your personal data, the Data Controller is obliged to provide you with information on:

 

(a)              what personal data,

(b)              on what legal basis,

(c)              for what purpose,

(d)              from what source,

(e)              how long it will treat.

 

Your right to receive feedback on whether (or not) your personal data is being processed by the Data Controller,

 

(a)              covers personal data relating to you;

(b)              does not cover anonymous data;

(c)              does not include personal data not relating to you; and

(d)              includes pseudonymised data that can be clearly linked to you.

 

The Data Controller will provide access to and a copy of your personal data upon your request. If you request an additional/repeat copy of your personal data, the Data Controller may charge a reasonable fee to cover the administrative costs incurred in connection with fulfilling the request, which will be borne by you.

 

2.      Your right to rectification

 

You have the right to have your personal data rectified.

 

E yoga

(a)              does not cover anonymous data;

(b)              covers personal data relating to you;

(c)              does not include personal data not relating to you; and

(d)              includes pseudonymised data that can be clearly linked to you.

 

The Data Controller will correct or complete your personal data accordingly upon your request. The Data Controller will inform the recipients of your personal data (if any) of the rectification of your personal data. However, the Data Controller will not inform the recipients of the rectification of personal data if it proves impossible or would involve a disproportionate effort to inform the recipients.

 

3.      Right to erasure

 

You have the right to have your personal data deleted under certain conditions.

 

The Controller shall delete your personal data without undue delay if.

(a)              the Controller processes those personal data, and

(b)              you request the erasure of your personal data, and

(c)              the personal data are not necessary for the purposes for which the Controller processes the personal data.

 

The Controller shall delete your personal data without undue delay if.

(a)              the Controller processes your personal data, and

(b)              you request the erasure of your personal data, and

(c)              you withdraw the consent on which the processing of your data is based, and

(d)              there is no other legal basis for the further processing of your data.

 

The Controller shall delete your personal data without undue delay if.

(a)              processing is necessary for the purposes of the legitimate interests pursued by the Controller or a third party, and

(b)              You object to the Controller processing your personal data, and

(c)              the legitimate ground for processing such personal data does not override your objection.

 

The Controller shall delete your personal data without undue delay if.

(a)              you request the erasure of your personal data, and

(b)              the processing of such data by the Controller is not unlawful; or

(c)              cancellation is mandatory under the applicable law, or

(d)              your data is collected in relation to information society services.

 

The Data Controller will inform the recipients of your personal data (if any) of the erasure of your personal data. However, the Data Controller will not inform the recipients of the erasure of personal data if it would be impossible or would require a disproportionate effort to inform the recipients.

 

4.      Your right to restrict processing

 

You may request the restriction of the processing of your personal data.

Your right to request restriction of the processing of your personal data

(a)        does not cover anonymous data

(b)       covers personal data relating to you;

(c)        does not includepersonal data that does notrelate to you; and

(d)       includespseudonymised data that can be clearlylinked to you.

 

The Controller will restrict the processing of your personal data for the period during which it verifies the accuracy of such data if you request the restriction of the processing of your personal data and you contest the accuracy of such data.

The Data Controller will restrict the processing of your personal data if you request the restriction of the processing of data whose processing is unlawful and you object to the erasure of such data.

 

The Controller will restrict the processing of your personal data if.

(a)        you request the restriction of the processing of your personal data, and

(b         the Controller no longer needs thosedata for the purposes of its processing; and

(c)        You are requesting your data in order to lodge, exercise or defend a legal claim

 

The Controller will restrict the processing of your personal data if.

(a)              You object to the processing of your personal data that is necessary for the purposes of the legitimate interests of the Controller, and

(b)              You are waiting for confirmation that the Controller has a legitimate ground for processing your personal data which does not override your objection.

 

The Data Controller will inform the recipients of such personal data (if any) of the restriction of the processing of your personal data. However, the Data Controller will not inform the recipients of such restriction if it would be impossible or would require a disproportionate effort to inform the recipients.

 

If the Controller restricts the processing of your personal data, it may.

(a)        may store such personal data

(b)       may process such personal data with your consent

(c)        may process personal data for the establishment, exercise or defence of legal claimsor the protection of the rights of individuals.

5.      Your right to data portability

 

You have the right to receive personal data concerning you that you have provided to a controller in a structured, commonly used, machine-readable format and the right to have those data transferred to another controller without hindrance (where technically possible) to the controller to whom you have provided the personal data, where the processing is based on consent or is necessary for the performance of a contract and the processing is automated.

 

Your right to data portability

(a)        does not cover anonymous data

(b)       covers personal data about you

(c)        does not include personal data that does not relate to you; and

(d)       does not cover clearly pseudonymous data

 

6.      Deadline for processing your application as a data subject

 

The Data Controller shall respond to requests for the rights to which you are entitled under the above without undue delay and at the latest within one month.

 

7.      Right to lodge a complaint

 

If you believe that your rights have been infringed, the Data Controller recommends that you seek a conciliation with the Data Controller by contacting the Data Controller directly. If such conciliation is not successful or if you do not wish to engage in such activities, you may take the matter to court or to the NAIH. In the event of legal proceedings, you may decide to bring such proceedings before the competent court in your place of residence or domicile.

 

The contact details of the NAIH are as follows: 1125 Budapest, Szilágyi Erzsébet fasor 22/C.; telephone: +36 1 391 1400; fax: +36 1 391 1410; e-mail: ugyfelszolgalat@naih.hu; website: www.naih.hu

 

8.      Amendments to this information notice

 

The Data Controller reserves the right to amend this information at any time. The Data Controller will inform customers of such changes by letter or e-mail, as appropriate, and in any case in accordance with applicable law.

 

Data processing related to newsletter subscriptions
S.sz.	Personal data	Purpose of data processing	Legal basis for processing	Who has access to the data	Storage method: paper and/or electronic	Storage location	Duration of storage
1.	Name	Sale of the Service, billing	Necessary for the performance of a contract or for the steps preceding the conclusion of a contract	Administration, Sales staff, Invoicing	E	Electronic archives	As defined in the Act on the Rules of Taxation
2.	E-mail address	Sale of the Service, billing	Necessary for the performance of a contract or for the steps preceding the conclusion of a contract	Administration, Sales staff, Invoicing	E	Electronic archives	As defined in the Act on the Rules of Taxation
3.	Phone number	Service sales, invoicing	Necessary for the performance of a contract or for the steps preceding the conclusion of a contract	Administration, Sales staff, Invoicing	E	Electronic archives	As defined in the Act on the Rules of Taxation

 

1. Annex No.

Recording of data transfers

 

Serial number	Date	Addressee	Scope of personal data	Other data	Comment