Privacy Notice

• Regulation (EU) 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 Directive 95/46/EC (General Data Protection Regulation, “GDPR”);
• The Hungarian Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information;
• The Hungarian Act C of 2003 on Electronic Communications, and
• The Hungarian Act XLVIII of 2008 on the Basic Requirements and Certain Restrictions of Commercial Advertising Activities.

1.       Basic concepts

2.      Why and when do we process your Personal data?

3.      What are the principles of our Data processing?

• We process your Personal data lawfully, fairly and in a transparent manner. This means that you will always be provided with all the relevant information that relates to how and why your Personal data is processed and what privacy-related rights you may exercise during the course of the Data processing. It also means that the Data processing will always have a valid, real and lawful purpose. We will never process your Personal data for non-disclosed or not sufficiently specific purposes.
• We do not collect or store any data that is not necessary for the purposes described in Section 4. Apart from the data specified there, we do not collect or use any Personal data, nor do we collect Personal data that we plan to use only in the future for a purpose yet to be determined.
• We process your data only for as long as necessary given the underlying purpose. We do not store your data indefinitely, the applicable retention periods are communicated to you in a transparent manner and once the given period is over, your data will be erased without the possibility to restore them. 
• We shall do our best to ensure that your Personal data is kept accurate and up to date. For this purpose, we kindly ask you to inform us of any change in your Personal data that we process.
• We always take appropriate steps to ensure the safety of your Personal data and minimize the risk of unauthorized access, disclosure or any other event or data breach that could compromise the confidentiality, integrity or availability of your data.
• We know that first and foremost, you are the one who has the right to decide what happens to your Personal data. We examine and address any queries, requests or complaints you have in relation to the processing of your Personal data and respond to those within the statutory deadline. The same is true when you wish to exercise your rights detailed in Section 8.

4.      How do we process your Personal data?

• registering the organization, thereby allowing access to the Platform, 
• providing support in the context of using the Platform;
• communicating with your organization regarding the use of the Platform and in relation to our contractual arrangements with your organization, 
• preparation, execution, and fulfilling of contractual arrangements with your organization in accordance with our Terms and Conditions.

• until your organisation informs us that another contact person has taken your place, but in no case after the expiry of the civil law statutory limitation period (5 years), which starts when the contractual arrangement is terminated between your organisation and us for any reason; or
• until you, as Data subject object to the Data processing, and our assessment finds no compelling cause that overrides your objection.

• register you as an individual entrepreneur, thereby allowing access to the Platform; 
• provide support in the context of using the Platform;
• communicate with you regarding the use of the Platform and in relation to our contractual arrangements; 
• prepare, execute and fulfill contractual arrangements with you in accordance with our Terms and Conditions;
• meet our mandatory accounting and tax payment obligations.

• until the expiry of the civil law statutory limitation period (5 years), which starts when the contractual arrangement is terminated between your organisation and us for any reason; or 
• until you, as Data subject object to the Data processing, and our assessment finds no compelling cause that overrides your objection.

• until the end of the civil law statutory limitation period (5 years), which starts from the conclusion of handling the complaint or responding to the query or Data subject request; or
• until you, as Data subject object to the Data processing, and our assessment finds no compelling cause that overrides your objection.

• the IP address and type of the device you use when visiting the Platform;
• the browser and operating system you use when visiting the Platform;
• certain parameters relating to your activity on the Platform, such as where you clicked, how long you stayed at a given site of the Platform and in which order you browsed the various sites of the Platform.

• Category 1: These Cookies are used in order to provide you with personalized content relating to our activities and services based on the analysis of your activity on the Platform. Some tracking codes also fall into this category.
• Category 2: These Cookies carry out statistical, aggregate analysis, which is important to us as this is how we learn certain preferences of our user. Based on this information we can improve the various functionalities of the Platform. Some tracking codes also fall into this category.
• Category 3: These Cookies are used for the purposes of load-balancing the Platform as a website, ensuring its security, remembering certain user settings, displaying content and optimizing its efficiency in various ways. Without these Cookies, certain functions of the Platform would not work properly or at all. These Cookies are automatically deployed to your computer when you visit the Platform and acknowledge the use of Cookies. Note that in this category, there are no tracking codes used.

• Categories 1 and 2: on the basis of your voluntary, explicit and informed consent, which you can withdraw at any time (note that you can also manage your cookie settings in your browser);
• Category 3: on the basis of our legitimate interest related to ensuring the proper technical functionality of the Platform as a website.

• until the withdrawal of your consent; or
• if we erase your contact details for the reason specified in Section 4.1 of this Notice (i.e. because your objected to the use of your contact details).

5.      How do we store your Personal data?

6.      To whom do we disclose your Personal data?

• in the case of exercising legal claims or defending against the legal claims of others, we might need to transfer your Personal data to our legal advisors, who will, at all times, be bound by confidentiality obligations as well as the professional secrecy rules applicable to attorneys at law;
• if a court procedure is initiated in relation to the contractual arrangements between you or your organisation and us, your Personal data might be disclosed to the court and other participants of such procedure;
• upon the request of authorities or courts, we are obliged to provide the information requested, which may contain your Personal data. We cannot be held responsible for such data transfers and their consequences. You will be notified if such a transfer takes place, to the extent permitted by the applicable laws. 

7.       What are your rights with respect to Data processing?

• what data we process about you,
• what is the purpose of our Data processing, 
• to which recipients we disclose your Personal data, 
• how long does the retention period take (how long we keep your Personal data), 
• what rights you have in relation to the Data processing, and
• whether we transfer your Personal data to any third countries or organisations and if we do, what additional guarantees we put in place to ensure the safety of your Personal data.

• we no longer need the data for any of the purposes specified in Section 4 above;
• we were processing your data on the basis of your explicit consent (e.g. for marketing purposes or for certain Cookie types) and you withdraw such consent;
• we were processing your data based on our legitimate interest and you object to such processing, provided that based on our assessment, there are no legitimate grounds that override your objection;
• despite our best efforts, for some reason the data is has been processed unlawfully;
• we must erase the data in compliance with a mandatory provision in the laws either of the European Union or Hungary;

• you contest the accuracy of the data – in this case, the restriction extends to the period while we check the accuracy of the data;
• despite our best efforts the Data processing was unlawful, however, instead of erasing your data, you request that its processing be restricted;
• we no longer need your Personal data for any of the purposes specified above, but the data is needed for the establishment, exercise or defence of our legal claims;
• you objected to the processing – in this case, the restriction extends to the period until which we assess whether there are any legitimate grounds that override your objection.

• our Data processing is justified by legitimate and compelling causes that override your objection, or
• the Data processing is required for the establishment, enforcement or defence of our legal claims.

• this allows us to draw certain conclusions about your preferences which we can later use to provide you with personalized content in the form of advertisements. This is what you’ve likely already experienced with webshops or online marketplaces where, based on your previous searches, certain goods are advertised to you on dynamic surfaces integrated into websites;
• note that we will use the results of this analysis to send you custom-tailored newsletters and other information directly, only if you also consented to receiving newsletters as per Section 4.7.