Data Privacy

Privacy Statement

We are pleased to welcome you to our website and thank you for your interest in our company.

This privacy statement describes, among other things, how EDAG HUNGARY KFT. processes your personal data and your rights as a data subject in accordance with the general data protection regulation (GDPR).

Please do not hesitate to contact us if you have any questions regarding our personal data processing. Our contact information is set out in Section I and II below.

I.    The Data Controller’s Name and Contact Information

EDAG HUNGARY KFT.
Management: László Várallyai
Zrínyi Str. 11
9024 Györ
Hungary

Phone: +36 96 401-800
Fax:       +36 96 401-809
E-mail: laszlo.varallyai@edag.com
Website: hu.edag.com

II.    General Data Processing Information

1.    Extent to which personal data is processed

We only ever collect and use personal data of our users to the extent to which this is necessary to provide a fully functional website and our contents and services. The regular collection and use of personal data of our users is only ever made with the user's consent. One exception to this rule applies in cases in which, for factual reasons, it is not possible to obtain the user's prior consent or in which, according to applicable data protection legislation, the processing of this data is permitted on other legal grounds.

2.    Legal basis for the processing of personal data

Insofar as we obtain the consent of the data subject to process his or her personal data, Art. 6 para. 1 p. 1 point a of the EU General Data Protection Regulation (GDPR) and the analogous provisions pursuant to applicable data protection legislation shall serve as the legal basis for the processing of personal data.

Art. 6 para. 1 p. 1 point b of the GDPR and the analogous provisions pursuant to applicable data protection legislation shall serve as the legal basis for the processing of personal data necessary for the performance of a contract to which the data subject is party. This shall also apply to processing necessary for the performance of pre-contractual measures.


Insofar as the processing of personal data is necessary for compliance with a legal obligation to which our company is subject, Art. 6 para. 1 p. 1 point c of the GDPR and the analogous provisions pursuant to applicable data protection legislation shall serve as the legal basis.

Should it be necessary to process personal data in order to protect the vital interests of the data subject or another natural person, Art. 6 para. 1 p. 1 point d of the GDPR and the analogous provisions pursuant to applicable data protection legislation shall serve as the legal basis.

Should processing be necessary to protect the legitimate interests of our company or a third party and such interests are not overridden by the interests, fundamental rights and freedoms of the data subject, then Art. 6 para. 1 p. 1 point f of the GDPR and the analogous provisions pursuant to applicable data protection legislation shall serve as the legal basis for processing.  In this case we specify our interest and conduct a balance of interests to determine whether our interests are overridden by your interests or fundamental rights and freedoms or not.

3.    Data erasure and storage period

The personal data of the data subject will be deleted as soon as the purpose for which it has been saved ceases to apply. Further, data may also be stored if provided for by European or national legislators in Union directives, laws or other regulations, to which the data controller is subject. The data will also be deleted at such time as the storage period prescribed by the designated standards expires, unless it is necessary for the data to be stored for a further period for the conclusion or performance of a contract.

4. Requirement to provide personal data
The data subject's provision of personal data is often necessary for us to fulfill our contractual obligations. Failure to provide such data may cause us not to be able to fulfil our contractual obligations.

III.    Provision of the Website and Creation of Log Files

1.    Description and extent of data processing
Every time our website is accessed, our system automatically acquires data and information from the computer system of the calling computer. 

The following data is collected:

(1)    The user's IP address

(2)    Date and time of access

(3)    Website visited

(4)    Quantity of data sent in bytes

(5)    Source/link from which you accessed the website

(6)    Browser used

(7)    Operating system used

The data is also stored in the log files of our system. This data is not stored with other personal data of the user.

2.    Legal basis for data processing
Art. 6 para. 1 p. 1 point f of the GDPR and the analogous provisions pursuant to applicable data protection legislation are the legal basis for the temporary storage of the data and the log files. We have balanced our interest against your rights and freedoms and we have found that our interests are not overridden by your interests or fundamental rights and freedoms.

3.    Purpose of data processing

The temporary storage of the IP address by the system is necessary in order to be able to deliver the website to the user's computer. To this end, the user’s IP address must be stored for the duration of the session. The data that has been acquired is used for statistical analyses and to improve the website. Your personal data (IP address) is first anonymised.

Data is stored in log files to ensure that the website functions properly. In addition, the data serves to optimise the website and to guarantee the security of our IT systems. No data evaluation is carried out for marketing purposes in this context. 

These purposes are also in our legitimate interests in data processing under Art. 6 para. 1 p. 1 point f of the GDPR and the analogous provisions pursuant to applicable data protection legislation.

4.    Storage duration
Data is deleted as soon as it is no longer needed for the purpose for which it was collected. In the case of data being collected in order to make the website available, this is the case when the session is terminated. 

In the case of data stored in log files, this is the case after a maximum of seven days. Storage beyond this point in time is possible. In this case, the user's IP address will be deleted or distorted, so that it can no longer be attributed to the accessing client.

5.    Right to object and right of erasure
Data acquisition is essential for the provision of the website and the storage of data in log files is essential for operating the website. We deem this as a compelling legitimate ground for the processing which override your interests, rights and freedoms and therefore we shall not comply your objections, unless you provide us with additional information to the contrary.

6.    Additional information

The processing is not required by law, and it is not a requirement necessary to enter into any contract, and you are not obliged to provide your personal data to us.

In case you do not provide us with your personal data, you will not be able to use our website.

The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

IV.    Use of Cookies

1. Description and extent of data processing

Our website makes use of cookies. Cookies are text files stored on the user's computer system in or by the Internet browser. If a user accesses a website, a cookie can be stored on the user's operating system. This cookie contains a characteristic character string that enables the browser to be clearly identified the next time the website is accessed. 

We use cookies to make our website more user-friendly. Some elements of our website require the accessing browser to be identified if the user changes from one page to another. 

The following data is stored and transmitted in the cookies:

(1)    The user's IP address
(2)    Date and time of access
(3)    Login information
(4)    Amount of data transferred
(5)    Enquiring domain

On our website, we also use cookies which make it possible to analyse the user's surfing habits. 

The following data can be transmitted in this way:

(1)    Equipment type, model, brand, screen resolution
(2)    Operating system, versions, families
(3)    Browser, version, configuration, engines, plugins, language, language code
(4)    Location data
(5)    Provider details
(6)    Pages per visit, number of visits, repeat visits, time of visit, date of visit
(7)    Entry pages, exit pages, page URL, title of page, search items, downloads
(8)    Search engines, search item, websites, social networks
(9)    Campaigns, campaign key word

When accessing our website, the user is informed that functional cookies are used, as are cookies for analysis and marketing purposes, and a Cookie Consent Manager is used to obtain his or her consent to the processing of the personal data used in this respect. Information regarding this data privacy statement is also issued in this context. 

Detailed information on how the individual cookies work, information on how long they function and details of whether third parties have access to these cookies can also be found in the Cookie Consent Manager. You can access the Cookie Consent Manager any time by clicking the corresponding button in the footer of our website.

2.     Legal basis for data processing

The legal basis for the processing of personal data using technically necessary cookies is Art. 6 para. 1 p. 1 point f of the GDPR.
The legal basis for the processing of personal data using functional cookies and cookies for analysis and marketing purposes is Art. 6 para. 1 p. 1 point a of the GDPR along with the analogous provisions in accordance with the applicable data protection legislation.

3.     Purpose of data processing

Depending on their intended use and function, we divide cookies into the following categories:

a)      Technically  necessary cookies
Technically necessary cookies guarantee functions without which our website cannot be be put to its intended use. These cookies are used exclusively by us, i.e. they are first party cookies. This means that all information stored in the cookies is returned to our website. Technically necessary cookies are used, for example, to ensure that users who have logged in always remain logged in when accessing various sub-pages of our website, and so do not have to re-enter login data every time they access a new page.

It is possible and permissible to use technically necessary cookies on our website without first obtaining consent. For this reason, individual technically necessary cookies cannot be activated or deactivated. These purposes are also in our legitimate interests in the processing of personal data under Art. 6 para. 1 p. 1 point f of the GDPR. Our interest in ensuring the unobstructed provision of our website and the services it offers prevails.

b)      Functional cookies
Functional cookies enable our website to store information that has already been input (such as registered name, language selection or a user's location) and, on the basis of this information, offer improved and more personalised functions. The way in which these cookies collect and store data ensures that user behaviour on other websites cannot be tracked.

c)      Performance cookies
In order to improve the website's attractiveness, content and functionality, performance cookies collect aggregated information about how it is used. These cookies help us to determine whether, how often and how long which website subpages are visited and what content is of particular interest to users.

These cookies do not store any information that would allow the user to be identified. The information collected is aggregated, and does not allow us to directly identify the individual. The only purpose it serves is to compile statistics in order to better tailor the content of our website to the needs of our users, to improve user experience, and to optimise our range of services.

d)      Marketing cookies
Marketing cookies come from external advertising companies (third party cookies) and are used to collect information about the websites visited by the user, to create targeted advertising for the user, and to display advertisements based on the user's interests. They are also used to limit the frequency with which an advertisement appears, and to measure the effectiveness of advertising campaigns. This information may be shared with third parties, advertisers for instance.

4.     Storage duration, right to object and right of elimination
Cookies are stored on the user's computer, from which they are transmitted to our website. As the user, you therefore have complete control over the use of cookies.

Even if you have consented to the use of cookies, you can revoke your consent at any time, with future effect. Please use one of the following options to do this:

  • You can inform us that you wish to withdraw your consent or change your settings in our Cookie Consent Manager, which can be accessed at any time via the website.
  • You can prevent cookies from being stored by adjusting your browser software accordingly; we would, however, like to draw your attention to the fact that if you do so, this might possibly result in your not being able to use all the functions offered on this website to the full.
  • Cookies which have already been stored can be removed from your settings at any time. This can also be done automatically.
  • Further, you can prevent the collection of data generated by the cookie and relating to your use of our websites (including your IP address) to Google and the processing of this data by downloading and installing the plug-in available for your browser.
  • You can also use the tools developed as part of self-regulation programs in many countries, e.g. www.aboutads.info/choices/ (USA) or www.youronlinechoices.com/uk/your-ad-choices (EU), to manage marketing cookies.

V. Job applications via e-mail

1.    Description and extent of data processing
Applications are received via email. We process the personal data you provide to us through your job application, including but not limited to, name, telephone number, address,  E-mail address, date of birth etc. There is no disclosure of data to third parties without your written consent in advance.

2.    Legal basis for data processing
The legal basis for the processing of data, provided the user's consent has been obtained, is Art. 6 para. 1 p. 1 point b of the GDPR.

3.    Purpose of data processing
The sole reason for processing the personal data is to enable us to handle the application, in order to conclude an employment contract.

4.    Storage duration
Data is deleted as soon as it is no longer needed for the purpose for which it was collected. For the data collected during the application procedure, this is the case when the application process is closed. 

5.    Right to object and right of erasure
As the applicant, you can contact us at any time if you wish us to delete the information. 

6.    Additional information
The processing is not required by law, but it is a requirement necessary to enter into an employment contract, however, you are not obliged to provide your personal data to us.

In case you do not provide us with your personal data we will not conclude an employment contract with you.

The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

VI.    E-Mail Contact

1.    Description and extent of data processing
The e-mail address is provided to enable contact to be established with us. In this case, the personal data of the user transmitted with the e-mail is stored. 

In this respect, there is no disclosure of data to third parties. Such data is used solely to process the communication.

2.    Legal basis for data processing
The legal basis for the processing of data collected when an e-mail is being sent is Art. 6 para. 1 p. 1 point f of the GDPR due to our legitimate interest of answering and administering the e-mail. We have balanced our interest against your rights and freedoms and we have found that our interests are not overridden by your interests or fundamental rights and freedoms.

If the point of the e-mail contact is to enter into a contract, then Art. 6 para. 1 p. 1 point b of the GDPR will serve as an additional legal basis for processing.

3.    Purpose of data processing
The sole reason for processing personal data is to enable us to handle the e-mail enquiry, which also establishes a legitimate interest in processing the data.

4.    Storage duration
Data is deleted as soon as it is no longer needed for the purpose for which it was collected. For personal data transmitted by e-mail, this is the case when a particular communication with the user is finished. Communication is finished when circumstances indicate that the matter concerned has been fully resolved. 

5.    Right to object and right of erasure
If the user contacts us by e-mail, he or she can object to the storage of his or her personal data at any time. If this is the case, then the communication cannot be continued.

In this case, all personal data collected as a result of contact being made will then be erased.

6.    Additional information

The processing is not required by law, and – unless you specifically contact the Controller in order to conclude a contract – it is not a requirement necessary to enter into any contract, and you are not obliged to provide your personal data to us.

In case you do not provide us with your personal data we will not be able to answer your messages.

The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

VII. Online Presence in Social Media

We maintain online presences within social networks in order to communicate with any customers, interested parties and users active there, and to inform them about our services. In this context, only simple links are used, or only social media plug-ins that do not establish any connection to the network in question when the page is loaded. This is the difference between the social media plug-ins used here and the the widespread Like buttons, which transmit data to the social networks as soon as the page is loaded, without the button having to be clicked. Additional information on the processing of data can be found in the following social media data privacy statement.

VIII.    Web Tracking

1. Description and extent to which personal data is processed

This website uses Google Analytics, a web analytics service of Google Inc. ("Google"). This makes it possible for data, sessions and interaction across multiple devices to be assigned to a pseudonymised user-ID, permitting the cross-device analysis of the activities of a user.

Google Analytics makes use of cookies which are stored on your computer and enable the use of the website to be analysed. As a rule, the information relating to your use of this website generated by the cookie is transferred to a Google server in the USA, where it is saved. If IP address anonymisation has been activated on this website, Google will truncate your IP address within member states of the European Union or other states party to the Agreement on the European Economic Area. On behalf of the owner of this website, Google will use this information to evaluate your usage of the website, to compile reports on the website activities, and to perform further services relating to the use of the website and Internet for the website owner.

To do this, the following data concerning you is processed:

(1)      The user's IP address

(2)      Date and time of access

(3)      Login information

(4)      Amount of data transferred

(5)      Enquiring domain

(6)      Equipment type, model, brand, screen resolution

(7)      Operating system, versions, families

(8)      Browser, version, configuration, engines, plugins, language, language code

(9)      Location data

(10)   Provider details

(11)   Pages per visit, number of visits, repeat visits, time of visit, date of visit

(12)   Entry pages, exit pages, page URL, title of page, search items, downloads

(13)   Search engines, search item, websites, social networks

(14)   Campaigns, campaign key word

The IP address sent by your browser via Google Analytics is not merged with other data by Google.

2. Legal basis for the processing of personal data

The legal basis for the use of Google Analytics is Art. 6 para. 1 p. 1 point a of the GDPR and the analogous provisions in accordance with the applicable data protection legislation.

3. Purpose of data processing

The purpose behind the use of the web analytics service is to analyse and make regular improvements to the use of our website. The statistics obtained enable us to improve our services and make them more interesting to you, our users. For any exceptional cases in which personal data is transferred to the USA, standard contractual clauses have been agreed with Google under the terms of the contractual arrangements.

These purposes are also in our legitimate interests in data processing under Art. 6 para. 1p. of the GDPR and the analogous provisions pursuant to applicable data protection legislation as the legal basis.

4. Storage duration, right to object and right of erasure

Any data that is sent by Google and linked with cookies, user authentication (e.g. user ID) or advertising IDs is automatically deleted after 14 months. According to Google, data which has come to the end of its storage period is automatically deleted once a month. We draw your attention to the fact that we have no influence over how long data is stored by Google.

You can prevent cookies from being stored by adjusting your browser software accordingly; we would, however, like to draw your attention to the fact that if you do so, this might possibly result in your not being able to use all the functions offered on this website to the full. Further, you can prevent the acquisition of the data generated by the cookie and relating to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plug-in available on the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

Opt-out cookies prevent the future acquisition of your data when visiting this website. To prevent acquisition across multiple devices by Universal Analytics, you will have to activate the opt-out for all systems in use. Click here to set the opt-out cookie: tools.google.com/dlpage/gaoptout

This website uses Google Analytics with the "_anonymizeIp()" function. This ensures that IP addresses are processed in truncated form, making it impossible to trace them to a specific user. Should the data about you that has been collected produce a direct personal link, this is immediately blocked, so the personal data is instantly deleted.

Information on the third-party provider

Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001.

The conditions of use can be found on: https://marketingplatform.google.com/about/analytics/terms/us/.

A data privacy summary can be found at:  https://policies.google.com/?hl=en-US , and a data privacy statement at: https://policies.google.com/privacy?hl=en-US .

To this purpose, we have also entered into a data processing contract with Google. 

5. Use of Google Tag Manager

We use Google Tag Manager. Google Tag Manager is a solution that enables marketers to manage website tags via one interface. The Tool Tag Manager itself, which implements the tags, is a cookie-free domain and does not collect any personal data. The tool triggers other tags that under certain circumstances may themselves collect data. Google Tag Manager does not access this data. If deactivation has been effected at domain or cookie level, it will remain in force for all tracking tags implemented with Google Tag Manager. More information can be found here: http://www.google.de/tagmanager/use-policy.html

Click here for exclusion from data collection by the Google Tag Manager.

The webtracking on this page is activated/deactivated. Deactivate Now/Activate Now

IX.    Integration of Google Maps

1.    Description and extent of data processing
We use the Google Maps service on this website. This enables us to display interactive maps directly on the website, making it easy and convenient for you to use the map function.

Should you visit the website, Google receives the information that you have activated the corresponding subpage of our website. In addition, the following data is transmitted:

(1)    IP address of the accessing computer
(2)    Date and time of enquiry

This happens regardless of whether or not Google has provided a user account by means of which you have logged on. If you have logged on to Google, your data is assigned directly to your account. If you do not wish the data to be assigned to your profile with Google, you must log out before clicking on the link. 

Further, depending on what settings the user has made, it is even possible for Google to collect location data. However, your consent to such data being used is always necessary, and you can refuse to let Google have this in your response to the query. 

Further information concerning the purpose and scope of data acquisition and its processing by the plugin provider can be found in the provider's data privacy statements, where you will also find additional information on your rights in this respect and setting options to protect your private sphere:

https://policies.google.com/privacy?hl=en&gl=en
Google also processes your personal data in the USA, and for this reason, the conclusion of standard contractual clauses has been agreed with Google.

2.    Legal basis for data processing
The legal basis for processing is Art. 6 para. 1 p. 1 point f of the GDPR and the analogous provisions in accordance with the applicable data protection legislation. We have balanced our interest against your rights and freedoms and we have found that our interests are not overridden by your interests or fundamental rights and freedoms.

3.    Purpose of data processing
Google stores your data as usage profiles, which it then uses for advertising or market research purposes, and/or the needs-based design of its website. An analysis of this type is carried out (even for users who have not logged on) in particular to provide needs-based advertising, and to inform other people using the social network of your activities on our website.

4.    Storage duration
We do not store your data in connection with this processing. The privacy policy used by Google is available at https://policies.google.com/privacy?hl=se&gl=de.

5.    Right to object and right of erasure
To prevent data from being assigned to an existing profile with Google, log out before activating the link. You have the right to object to the creation of these user profiles, and to exercise this right, or your other rights (including the right of erasure), you must contact Google (https://policies.google.com/privacy?hl=se&gl=de).

6. Additional information

The processing is not required by law, and it is not a requirement necessary to enter into any contract, and you are not obliged to provide your personal data to us.

The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

X. Use of Google Web Fonts

1.    Description and extent of data processing

We use the web fonts provided by Google to ensure that font types are shown consistently. When you call up a page, your browser loads the required web fonts into its browser cache so that texts and fonts are displayed correctly. If your browser does not support web fonts, a default font from your computer is used.

No cookies are set when you call up the page. Data transmitted in connection with the page view is sent to resource-specific domains such as fonts.googleapis.com or fonts.gstatic.com. It is not brought into contact with data that might be collected or used in connection with the parallel use of authenticated Google services such as Gmail.

2.    Legal basis for data processing

The legal basis for processing is Art. 6 para. 1 p. 1 point f of the GDPR and the analogous provisions in accordance with the applicable data protection legislation. We have balanced our interest against your rights and freedoms and we have found that our interests are not overridden by your interests or fundamental rights and freedoms.

3.    Purpose of data processing

Google Fonts is a freely available library of over 800 fonts. Google Fonts allows us to present our website to the user in an attractive design and in the same quality across all devices. This is the only way of making it technically possible for all visitors to our homepage to have a consistent and pleasant user experience. This purpose is also in our legitimate interests in the processing of personal data under Art. 6 para. 1 point f of the GDPR.

4.   Storage duration, right to object and right of erasure

We do not store your data in connection wth this processing.

For more information on Google Web Fonts and your right in conncetion with the processing of Google, see https://developers.google.com/fonts/faq and Google's data privacy statement: https://www.google.com/policies/privacy/

5. Additional information

The processing is not required by law, and it is not a requirement necessary to enter into any contract, and you are not obliged to provide your personal data to us.

The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

XI. INTEGRATION OF YOUTUBE VIDEOS (VIA PLUGIN)

1. Description and extent of data processing
We have integrated YouTube videos into our online service; these are stored at www.YouTube.com and can be played directly from our website. [These are all embedded in "enhanced privacy mode," which means that no data about you as a user is transferred to YouTube unless you play the videos. The data mentioned below will not be transmitted until you play the videos. We have no influence on this data transmission.]

Should you visit the website, YouTube receives the information that you have activated the corresponding subpage of our website. In addition, the following data is transmitted:

This happens regardless of whether or not YouTube has provided a user account by means of which you have logged on. If you have logged on to Google, your data is assigned directly to your account.

2. Legal basis for data processing
The legal basis for processing is Art. 6 para. 1 p. 1 point f of the GDPR.

3. Purpose of data processing
YouTube stores your data as usage profiles, which it then uses for advertising or market research purposes, and/or the needs-based design of its website. An analysis of this type is carried out (even for users who have not logged on) in particular to provide needs-based advertising, and to inform other people using the social network of your activities on our website.

4. Storage duration, right to object and right of elimination
If you do not wish the data to be assigned to your profile with YouTube, you must log out before activating the button. You have the right to object to the creation of these user profiles, and to exercise this right, you must contact YouTube.

Further information concerning the purpose and scope of data acquisition and its processing by YouTube can be found in the data privacy statement. where you will also find additional information on your rights and setting options to protect your private sphere: www.google.de/intl/de/policies/privacy. Google also processes your personal data in the USA, and for this reason, the conclusion of standard contractual clauses has been agreed with Google.

XII.  Rights of Data Subject

If personal data concerning you is processed, you are the data subject as defined in the GDPR, and the analogous provisions pursuant to applicable data protection legislation and have the following rights against the data controller:

1.    Right to information
You can ask the controller to provide you with confirmation as to whether or not personal data concerning you is processed by us. 

If such processing is being undertaken, you can ask the controller to provide you with information concerning the following:

(1)    The purposes for which the personal data is processed;
(2)    The personal data categories which are processed;
(3)    The recipients or categories of recipients to whom the personal data concerning you has been or will be disclosed;
(4)    The planned storage duration of the personal data concerning you or, if it is not possible to provide concrete information on this point, criteria for defining the storage duration;
(5)    The existence of a right to correct or delete the personal data concerning you, a right to limit processing by the controller, or a right to object to such processing; 
(6)    The existence of a right to lodge a complaint with a supervisory authority;
(7)    All available information concerning the origin of the data, if the personal data was not acquired from the data subject him or herself;
(8)    The existence of automated decision-making and profiling in accordance with Art. 22 para. 1 and 4 of the GDPR and – at least in these cases – meaningful information on the logic involved and the implications and intended impact of such processing for the data subject.

You have the right to request information on whether or not the personal data concerning you is transmitted to a third country or international organisation. In this context, you may ask for information on appropriate guarantees in accordance with Art. 46 of the GDPR and the analogous provisions pursuant to applicable data protection legislation relating to the transmission of data.

2.    Right to rectification
You have a right to have the controller correct or complete any personal data concerning you which, having been processed, is either incorrect or incomplete. The data controller must carry out any corrections without undue delay.

3.    Right to restrict processing
Subject to the following conditions, you can request that processing of the personal data concerning you be restricted:

(1)    If you dispute the accuracy of the personal data concerning you for a period which allows the controller to check the accuracy of the personal data;
(2)    the processing is unlawful and you refuse deletion of the personal data, instead requesting that use of the personal data be restricted;
(3)    the controller no longer needs the personal data for processing purposes, but you need it in order to establish, exercise or defend legal claims, or
(4)    if you have filed an objection to the processing of the data in accordance with Art. 21 para. 1 of the GDPR and the analogous provisions pursuant to applicable data protection legislation, and it is not yet clear whether the legitimate reasons of the controller outweigh your reasons.

If the processing of the personal data concerning you has been restricted, then, storage aside, this data may only be processed with your consent (insofar as legally required), or to establish, exercise or defend legal claims, or to protect the rights of another natural or legal person, or for reasons of substantial public interest on the basis of Union or Member State law.

If restriction of the processing has been restricted under the above-mentioned conditions, you will be informed by the controller before the restriction is lifted.

4.    Right to deletion
a)    Obligation to delete
You can ask the controller to delete the personal data concerning you without undue delay, and the controller is obliged to delete this data without delay if one of the following reasons applies:
(1)    The personal data concerning you is no longer needed for the purposes for which it was collected or otherwise processed.
(2)    You revoke your consent, which served as the basis for processing in accordance with Art. 6 para. 1 lit. a or Art. 9 para. 2 point a of the GDPR, and there is no other legal basis for the processing. 
(3)    You file an objection to processing in accordance with Art. 21 para. 1 of the GDPR, and there are no overriding legitimate reasons for the processing, or you file an objection to processing in accordance with Art. 21 para. 2 of the GDPR and the analogous provisions pursuant to applicable data protection legislation. 
(4)    The personal data concerning you has been unlawfully processed. 
(5)    Deletion of the personal data concerning you is necessary in order to ensure compliance with a legal obligation under Union or Member State law to which the data controller is subject. 
(6)        The personal data concerning you has been acquired in relation to the offer of information society services in accordance with Art. 8 para. 1 of the GDPR and the analogous provisions pursuant to applicable data protection legislation.

We reiterate and highlight that you have the right to fully or partly (i.e. in connection with only certain processings or data) withdraw your consent at any time in every case where  the legal base of the processing is your consent (Art. 6 para. 1 lit. a or Art. 9 para. 2 point a of the GDPR).

b)    Information to third parties
If the controller has made the personal data concerning you public, and is obliged to delete such data in accordance with Art. 17 para. 1 of the GDPR, then, taking into account the technologies available and implementation costs, he - the controller - applies appropriate measures, which may also be of a technical nature, to inform the people responsible for processing personal data that, as a data subject, you have requested that they should delete all links to this personal data as well as all copies or replications of this personal data. 

c)    Exceptions
The data subject does not have the right to have his or her data deleted if processing is necessary

(1)    to exercise the rights to freedom of expression and freedom of information;
(2)    to comply with a legal obligation calling for processing on the basis of Union or Member State law to which the controller is subject, or to perform a task carried out in the public interest or in the exercise of official authority vested in the controller;
(3)    for reasons of public interest in the field of public health in accordance with Art. 9 para. 2 points h and i and Art. 9 para. 3 of the GDPR;
(4)    for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89 para. 1 of the GDPR, and the analogous provisions pursuant to applicable data protection legislation insofar as the right set out in section a) is likely to render impossible or seriously impair the achievement of the purposes of this processing, or
(5)    to establish, exercise or defend legal claims.

5.    Right to information
If you have exercised your right to have the controller correct, delete or restrict the processing of your data, then the controller is obliged to inform all recipients to whom the personal data concerning you has been disclosed of such correction or deletion of the data or restriction of the processing, unless it proves impossible to do so or would involve unreasonable expense and effort.

You are entitled to have the controller inform you of these recipients.

6.    Right to data portability
You have the right to receive the personal data concerning you with which you have provided the controller in a structured, commonly used and machine-readable format. Further, you have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was provided, providing that

(1)    the processing is based on consent in accordance with Art. 6 para. 1 p. 1 point a of the GDPR or Art. 9 para. 2 point a of GDPR or on a contract in accordance with Art. 6 para. 1 p. 1 point b of the GDPR, and the analogous provisions pursuant to applicable data protection legislation, or on a contract in accordance with Art. 6 para. 1 p. 1 point b of the GDPR and the analogous provisions pursuant to applicable data protection legislation, and
(2)    the processing is carried out by automated means.

In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another, where technically feasible. This shall not adversely affect the rights and freedoms of others.

The right to data portability does not apply to processing of personal data for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7.    Right to object
You have the right, on grounds relating to your particular situation, to object at any time to the processing of personal data concerning you which is based on Art. 6 para. 1 p. 1 point e or f of the GDPR and the analogous provisions pursuant to applicable data protection legislation; this also applies to profiling based on these provisions. 

The controller will no longer process the personal data concerning you unless the controller can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or the processing serves to establish, exercise or defend legal claims.

If personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing purposes; this also applies to profiling, insofar as it is related to such direct marketing.

Should you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for such purposes.

In the context of the use of information society services – notwithstanding Directive 2002/58/EG and the analogous provisions pursuant to applicable data protection legislation – you are entitled to exercise your right to object by automated means using technical specifications.

We reiterate and highlight that you have the right to object to any processing at any time, where our processing is based on Art. 6 para. 1 p. 1 point e or f of the GDPR, or your data is processed for direct marketing purposes.

8.    Right to withdraw declaration of consent under data protection law
You have the right to withdraw your declaration of consent to the processing of personal data at any time. The withdrawal of consent shall not affect the lawfulness of processing based on your consent before its withdrawal.

9.    Automated individual decision-making, including profiling
You have the right not to be subject to a decision based solely on automated processing - including profiling - which produces legal effects that concern you or significantly affects in a similar way.

This does not apply if the decision

(1)    is necessary for entering into or the performance of a contract between you and the data controller,
(2)    is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and your legitimate interests, or
(3)    is made with your explicit consent.

These decisions must not, however, be based on special categories of personal data referred to in Art. 9 para. 1 of the GDPR and the analogous provisions pursuant to applicable data protection legislation, unless Art. 9 para. 2 point a or g and the analogous provisions pursuant to applicable data protection legislation apply, and suitable measures have been undertaken to safeguard your rights and freedoms and your legitimate interests.

With regard to the cases described in points (1) and (3), data controller will implement suitable measures to safeguard your rights and freedoms and your legitimate interests, including at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.

10.    Right to lodge a complaint with a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data concerning you infringes the GDPR and the analogous provisions pursuant to applicable data protection legislation.

The supervisory authority with which the complaint has been lodged will inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy in accordance with Art. 78 of the GDPR and the analogous provisions pursuant to applicable data protection legislation.

 

Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH) – National Authority for Data Protection and Freedom of Information

Address: 1125 Budapest, Szilágyi Erzsébet fasor 22/C

Phone: +36 (1) 391-1400

Fax: +36 (1) 391-1410

E-mail: ugyfelszolgalat(at)naih.hu 

Online: www.naih.hu

The competent Regional Court

Győr Regional Court based on the registered office of the Controllers

The competent Court based on your permanent residence

The competent Court based on your habitual residence

Version: Juli 2020

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