- This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
- We take the protection of your privacy and confidentiality seriously. We understand that all our customers and visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
- We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
- Our policy complies with Hungarian law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
- The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org and https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en.
- Except as set out below, we do not share, or sell, or disclose any information collected through our face to face data exchange or our website to a third party.
The bases on which we process information about you
The law requires us to determine under what defined bases we process different categories of your personal information, and to notify you of the basis for any category. If a basis on which we process your personal information is no longer relevant, then we shall immediately stop processing your data. If the basis changes, then, if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
- Information we process because we have a contractual obligation with you.
When you create an account with us or visit our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between us. In order to carry out our obligations under that contract, we must process the information you give us. Some of this information may be personal information. We may use it in order to:
- verify your identity for security purposes
- sell products to you
- provide you with our services
- provide you with suggestions and advice on products, services and how to obtain the most from using our website. We process this information on the basis that there is a contract between us, or that you have requested that we use the information before we enter into a legal contract. Additionally, we may aggregate this information in a general way and use it to provide class information, for example, to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable. We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
- Information we process with your consent
- Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation. For example, we may be required to give information to legal authorities if they so request or if they have the proper authorization such as a search warrant or court order. This may include your personal information.
Specific uses of information you provide to us
- Information provided on the understanding that it will be shared with a third party
Our website, or in particular third party feeds to our website, allows you to post information with a view to that information being read, copied, downloaded, or used by other people. Examples include:
- posting a message on any of our social network pages
- tagging an image
- clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks. In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it. We do not specifically use this information except to allow it to be displayed or shared. We do store it, and we reserve a right to use it in the future in any way we decide. Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time. Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at email@example.com.
- Complaints regarding content on our website
Our website is a publishing medium just as our social pages. Anyone may register and then publish information about himself, herself or some other person. We attempt to moderate user generated content, but we are not always able to do so as soon as that content is published. In particular our website may contain feeds from YouTube, Facebook and Twitter, and these mediums are moderated. If you complain about any of the content on our website, we shall investigate your complaint. If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate. Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you. If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
- Information relating to your method of payment
We store your bank account details when you first provide them to us. We store this payment information at your request in order to make repeat purchasing of goods and services easier next time there is a payment becoming due for an agreed service under a direct debit agreement. We also store it to help us prevent fraud. We take the following measures to protect your payment information:
- We keep your bank detail information on our secure servers. This in itself is not considered a risk as you’re account could not be accessed just with bank details.
- We use 3rd party direct debit companies who comply with the GDPR.
- We do not retain any of your card details. If we take your card details remotely, we use 3rd party software to avoid the possibility of fraud. The 3rd party company complies with the GDPR.
- Access to your payment information is restricted to authorized staff only.
- If we ask you questions about your payment information it will be on the telephone generally in order to request that the bank account details that we hold are still valid. We will ask you for the bank account number and sort code.
- Job application and employment
If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date. If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for the period according to the applicable labor laws and regulations before destroying or deleting it.
- Sending a message to our support team
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our business. We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is. We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
- Affiliate and business partner information
This is information given to us by you in your capacity as an affiliate of us or as a business partner. It allows us to recognise visitors that you have referred to us, and to credit to you commission due for such referrals. It also includes information that allows us to transfer commission to you. The information is not used for any other purpose. We undertake to preserve the confidentiality of the information and of the terms of our relationship. We expect any affiliate or partner to agree to reciprocate this policy.
Use of information we collect through automated systems when you visit our website
- to track how you use our website
- to record whether you have seen specific messages we display on our website
- to keep you signed in our site
- to record your answers to surveys and questionnaires on our site while you complete them
- to record the conversation thread during a live chat with our support team
- Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded. We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution. We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you. If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
- Our use of re-marketing
Disclosure and sharing of your information
- Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use. No such information is personally identifiable to you.
- Third party softwares, plugins on our website
- Credit reference
To assist in combating fraud, we sometimes share information with company information services, law offices and/or credit reference agencies according to the applicable law.
- Data may be processed or stored outside the European Union
Our websites are hosted in the EU. We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business. Accordingly data obtained within the EU or any other country could be processed or stored outside the European Union. We use the following safeguards with respect to data transferred outside the European Union:
- Data backed up by third party suppliers are encrypted.
Access to your own information
- Access to your personal information
- At any time you may review or update personally identifiable information that we hold about you by contacting us.
- To obtain a copy of any information that is not provided on our website you may send us a request at firstname.lastname@example.org.
- After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
- Removal of your information
If you wish us to remove personally identifiable information from our website or our data storage vaults, you may contact us at email@example.com. This may limit the service we can provide to you.
- Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
- Use of site by children
- We do not sell products or provide services for purchase by children, nor do we market to children.
- If you are under 18, you may use our website only with consent from a parent or guardian.
- Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us. Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar. Personal data, such as tax returns, where we require your approval, will be held on secure applications where you will be able to access the data using a username and password. When you access the account you will be forced to change your password to one of your choosing.
- How you can complain
- If a dispute is not settled, we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
- If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the regulatory authority.
- Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
- to provide you with the services you have requested;
- to comply with other law, including for the period demanded by our tax and statistical authorities;
- to support a claim or defense in court.
- with regard to your personal accounting records, these should be collected after your job has been finished. If you are not local, you agree for us to courier your records back to you using a Courier firm or signed for postage. If you do not collect your records within 12 months of your job being completed, we reserve the right to destroy your records securely.
- Compliance with the law