Privacy Policy / GDPR
Communication concerning data processing
SUMMARY
Updated: 01/01/2024
This simplified communication was prepared based on the principle of clarity and adequate information on data processing. Documents that are available and accessible on the website before registration: General Terms and Conditions, Privacy Policy / GDPR and Regulations regarding „Cookies”.
The contents of the Communication on Data Protection took into account the guidelines related to clarity included in the Guidelines on Transparency, thus comprehensive information was provided with additional annexes.
Privacy Contact: If you wish to enforce your rights related to your data, please email [email protected] and we will handle your request. For information about our data processors, see the communication.
By providing your personal data or information, you declare that you have fully understood and explicitly accept the version of the Communication on Data processing valid at the time when the data or information was made available.
The legal basis for the communication is Regulation (EU) No 2016/679 of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing REGULATION OF THE EUROPEAN PARLIAMENT AND THE COUNCIL (EU) 2016/679 (EC) No 95/46 (hereinafter referred to as Regulation).
The purpose of this website is to make it possible for the Provider to place advertisements related to erotic massage, dating partner search ads, reviews and reports for users. This service makes it possible for registered adult members to have access to the data sheet of other registered private persons or to contact them.
We pay special attention to children’s personal data protection. Content and information on https://massage.dating may be adult, so the site is for adult visitors and users only. Uploaded pictures and content may be offensive to some. If the User has not completed the age of 18 (21 years in some countries) or if the use of the site is illegal, please do not access the site
Our website have the SSL security certification
Our principles concerning the management of personal data: We handle the personal data lawfully and fairly and in a transparent way for those concerned, collection of such data can only take place with a specific, unambiguous and legitimate purpose, limited to the required amount of data, stored safely and with limited duration.
For what purposes are data processed?
- On the grounds of fulfilling its contractual obligations, the Company manages the data of the natural person with whom the contract is concluded for the purpose of concluding, executing, terminating the contract, advertising and hosting the service
- For the purpose of fulfilling the contract with the legal partner, for business contacts.
- In order to increase the service’s efficiency, user experience, to make the use of the webpage more comfortable we use cookies on our webpage.
- In order to create a Contact Account in order to distinguish users from each other and to build contacts, including webpage and space services (such as advertisement profiles).
- Creating advertisement profile accounts in order to distinguish users from each other and to present services;
- For the purpose of sending newsletters, advertisements and establishing advertisement contacts;
- On the grounds of fulfilling legal obligations, for the purpose of complying with tax and accounting regulations stipulated by law (bookkeeping, taxation) manages data (defined by law) of clients, partners and suppliers related to natural persons.
The detailed communication contains the list of data processed belonging to that purpose, the legal ground, the duration of the data processing, the data subjects and who might have access to the data.
We ensure the following rights related to your personal data, these are the following:
- Right of access
- Right to rectification
- Right to deletion
- Right to erasure
- Right to limit data processing
- Right to data portability
- Right to object
- Right to object in case of unsolicited marketing
- Informing the data subject about a data protection incident
- Right to lodge a complaint at the Supervisory authority
- Right to effective judicial review at the Supervisory authority
- Right to effective judicial review against the data processor
You have the right to take an action for damages against the data processor and to lodge a complaint with the competent supervisory authorities of the domicile in case if you consider that your personal data are treated illegally.
Data protection availability: in case if you would like to validate your rights related to data protection, send an e-mail to [email protected] and we will manage your request.
We would like to draw your attention to the fact that concerning the data processing carried out by Massage.Dating on https://massage.dating and on subdomains for the specific countries only the full version of the communication on data processing can be regarded as comprehensive information.
Information on data processing
INTRODUCTION
This information ensures in line with the stipulations of the data protection regulation of the EU 2016/679 (with English abbreviation GDPR/General Data Protection Regulation) that the natural persons shall be aware of our data processing principles and rules before using the services of our website https://massage.dating (hereinafter referred to as: Massage.Dating, Data Controller, Company, Service Provider, data processor).
The webpage https://massage.dating is an international service with multilingual adaptations.
The objective of the webpage is to provide an opportunity for placing erotic massage, dating partner search advertisements and accounts for users. The service makes it possible for registered members to have access to other persons’ data sheets and get in touch with them. For this, the advertisers and the registered members using the webpage have to provide personal data.
By providing personal data or information, you declare that you are aware of the contents of the information on data processing at the time when you got and explicitly accepted the information.
Massage.Dating is committed to protect the personal data of their clients and partners, we consider the right of informational self-determination very important, we treat all sorts of personal data as confidential and make all sorts of security, technical and organizational arrangements that guarantee data safety.
At the time of registration you as a user have to tick the box or signal your consent in any other written form to accept the legal use and management of personal data or data made available on the advertisement profile, or subject to special protection. You can unsubscribe from our newsletters at any time.
The information and data security of our webpages is important for us: our webpages are SSL certified.
For us the protection of the personal data of children are of utmost importance. The content and information available at https://massage.dating can be of adult nature. The webpage was made exclusively for adult visitors and users. The uploaded photos and content might be offensive to some people. In case if the user has not completed 18 years of age (21 years in some countries) or if you consider that the use of the webpage is against the rules, please do not enter the website.
Documents available at the website that you can read before registration: Terms and Conditions, Information on Data processing and „Cookie” regulations.
DESIGNATION OF THE DATA PROCESSOR
Massage.Dating as data processor has consented to be bound by the content of the present legal notice. The company assumes responsibility for its activities that will comply with all the requirements stated in the valid national regulations and with the expectations of the legal acts of the European Union.
The wording of the Communication on Data Protection has taken into account the guidelines of the Guidelines on Transparency, thus the comprehensive information was realized with annexes.
Privacy Contact: If you wish to enforce your rights related to your data, please email [email protected] and we will handle your request.
DATA PROCESSORS
Data processor: natural or legal person, public authority, agency or other body which manages personal data on behalf of the data processor; (Regulation 4, article 8.) Recourse to the data processor does not require the preliminary consent of those concerned but informing them is necessary. Accordingly, we provide the following information:
- IT service provider of our company
- Our company maintains and manages its website within the company group.
- The accounting service provider of our company
- Our company manages the accounting and bookkeeping tasks related to taxation obligations within the company group.
- Online payment and hosting provider
DEFINITIONS USED IN THE INFORMATION DOCUMENT
„The definition of handling personal data”: Any kind of operation or sum of operations using either automatised or non-automatised ways on personal data including the collection, recording, organizing, dissection, storage, transformation or change, query, inspection, usage, publication, forwarding, spreading or making available by other kind of methods, synchronisation, connection, limitation, deletion and destruction.
„personal data”: Any kind of information concerning an identified or identifiable natural person; a natural person is a person who can be identified directly or indirectly based on some kind of identification such as name, number, location data, online identifier, or based on one or more identical factors such as the person’s physical, physiological, genetical, spiritual, economical, cultural or social identity.
„specifial data”: personal data concerning racial origin, nationality, political affiliation, religious or other belief, business federation organizational membership, sexual life, state of health, harmful habits and personal criminal records;
„data processing”: any kind of operation or sum of operations by either automatised or non-automatised way on personal data including collection, recording, organizing, dissection, storage, transformation or change, query, inspection, usage, publication, forwarding, spreading or making available by other kind of methods, synchronisation, connection, limitation, deletion and destruction.
„controller”: natural person, legal entity, executive power, agency or any other organ that defines the aims and implements of data processing individually or in cooperation with others; if the aims and implements of data processing is defined by UN or member state law, the controller or the special aspects of determining the person of the controller can be either defined by UN or member state law;
„data processor”: natural person, legal entity, executive power, agency or any other organ that is processing personal data in the name of the controller.
„addressee”: natural person, legal entity, executive power, agency or any other organ that the personal data is shared with, independently from third party status. The executive powers that are capable of accessing personal data in accordance with UN or member state law in sphere of individual investigation are not qualified as addressees; the processing of the mentioned personal data by executive powers must meet the purpose of data protection laws to be applicable according to data protection objectives.
„the contribution of the data subject”: the voluntary, exact and properly understandable pronouncing of the data subject’s will based on sufficient instructions, with which the data subject announces the acceptance of processing the personal data concerns her/him through a declaration or deed which expresses the confirmation in an unmistakable way;
„data protection incident”: a breach causing the accidental or illegal destruction, loss, change, illegal publication or unathorised access of the personal data that is forwarded, stored or handled in any other way.
Additional definitions and information: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rules-business-and-organisations_en
PRINCIPLES OF DATA PROCESSING
Protecting your personal data is especially important for us. We handle your personal data in a transparent, decent and lawful procedure. Data collection can serve a certain, clear and lawful purpose that is limited to the necessary amount of data, stored in a safe and limited manner.
„lawfulness, decent procedure and trasparency”: Personal data must be handled lawfully and decently in a clear and transparent manner for the data subject.
„purpose limitation”: The collection of personal data shall only take place for a clear and lawful purpose and must not be handled irreconcilably to these purposes; according to article 89 indent (1), the data collected with the purpose of general archiving, scientific and historical research or further processing for statistical purposes are not considered irreconcilabe to these aims.
„data minimisation”: Personal data must be relevant and proper in terms of the aims of data processing purposes, and must be confined to the necessary amount.
„reliability”: Personal data must be reliable and up-to-date if necessary: all the reasonable measures must be taken so that unreliable data in terms of the aims of data processing shall be deleted or corrected without delay.
„limited storage”: Personal data must be stored in a way so that the subjected persons can only be identified for the amount of time necessary to access the data in order to fulfill the requirements of data processing aims. This time limit can only be exceeded in correspondence with article no. 89. indent (1), stating that handling of personal data will be carried out with the purpose of general archiving, science and historical research or further processing for statistical purposes, with regards to applying the proper technical and organizational measures to protect the rights and liberty of the subjected persons included in this decree.
„integrity and confidential quality”: Personal data must be handled in a way that proper security of the personal data can be assured with the applied proper technical and organizational measures, including protecting data against illegal or onlawful data processing, accidental loss, destruction or damage.
„accountability”: The Controller is responsible for complying with the terms mentioned above and also must be capable to justify accountability.
DIRECTIONS FOR DATA SECURITY
Our websites are secured with SSL security certificates. SSL certificates serve the purpose of creating a secure and encrypted channel between the client and the server. Certain information, such as credit card data, account authorization data and other confidential information must be transferred through an encrypted channel to exclude the possibility of data leakage. Using SSL certificates, our data becomes encrypted before being transferred through the internet. The encrypted data can only be translated by the destination server. This ensures that the personal data entered on the website cannot be stolen. Transactions take place using PIN codes and other methods of encyption.
The data gathered by us are stored at different places within our infrastructure, including system logs, backend databases and analytical systems. In case of data transfers from EEA to the United States and other countries we follow the directions of the European Commission and rely on the compliance provisions for the individual countries defined by the European Commission.
Some of our services may provide links to other websites such as commercial banners or Facebook. Since the data protection principles and practices of these third party websites are not controlled by us, please read the data protection principles defined there to get information about their methods of collecting and using personal data. Part of our products and services can also be paid by credit cards or e-vouchers. In both cases you are redirected to third parties that completely fulfilled their part of security measures.
Data transfer through the internet by email or text message is not completely safe. Although we are doing our best to protect your personal data, we cannot guarantee the safety of your data transferred by our services or email; every data transfer is the subject of the owner’s responsibility. After your personal data is entered, we implement proper technical and organizational measures in order to protect your data against loss, theft, unathorised usage, access or modifications. Please protect your data using strong passwords.
HANDLING PERSONAL DATA
DATA PROCESSING BASED ON LEGAL OBLIGATIONS
DATA PROCESSING RELATED TO CONTRACTS, GENERAL TERMS AND CONDITIONS, WEBSITE
1. Management and register of the data related to the contracting persons, advertisers
Objective of personal data processing: The company manages the data of clients and suppliers by virtue of concluding, fulfilling, termination of a contract, and of providing advertisement and internet storage space.
- Processed personal data: name, birth name, date of birth, address, seat, address of the seat, telephone number, e-mail address, website address, bank account number, client ID (client number, order number), online ID number
- Legal basis for managing personal data: basis of the right of contract fulfilment. This data processing is considered lawful even if the data processing was required at the client’s request to take the necessary actions prior to the conclusion of the contract
- The addressees of personal data and the categories of addressees: the Company’s employees dealing with customer service, accounting, bookeeping and taxation related tasks and data processors.
- Duration of personal data storage: Until the data subject withdraws his consent, in case if this does not take place, the Company deletes the data 5 years after the termination of the Company’s account. In case if the Company is obliged to keep the data on the basis of the Accounting Act, the Company is going to delete the data only after 8 years following the termination of the account, regardless of the termination of the account. In practice this means that if the data are part of the documents supporting the accounting, for example if the data are specified on documents related to contracts between the Company and the Client (e.g. in orders) or on the invoices issued.
- Stakeholders concerned: website customers, clients, suppliers, advertisers
2. Legal person clients, customers, suppliers, data related to representatives
Objective of managing personal data: Fulfilment of contracts concluded with companies as legal partners, business contacts.
- Processed personal data: name, phone number, e-mail address, online ID
- Legal basis for managing personal data: fulfillment of contract
- The addressees of personal data and the categories of addressees: the Company’s employees dealing with customer service, accounting, bookeeping and taxation related tasks and data processors.
- Duration of storing personal data: for a period of 5 years following the business relation and following the existence of the representation
- Data subjects: business representatives of advertisers that are not natural persons, clients and customers
3. Data processing related to visitors (cookies) on the Company’s website
In accordance with the general practice our Company also uses cookies at its website. The cookie is a little file that contains a series of characters which is downloaded to the user’s computer when the user visits a webpage. The cookies generally make the use of the webpage easier, they create a real user experience and contribute to make it an efficient source of information, moreover they ensure that the webpage’s operator is able to control the operation of the webpage, help prevent frauds and foster the smooth operation of the services provided at the website at an appropriate level.
The cookies alone are not suitable for identifying the user’s identity.
Data subjects: all the natural persons who visit the page.
Addressees of the personal data and the categories of the addressees: The IT provider of the Company and the employees taking part in the service
Types of cookies
Technically indispensible work process (session) cookies
They help users browse the webpage without problems, contribute to the smooth operation of the webpage and comprehensive use of all of their functions, the services available through the website, thus – among other things – the memorization of operations carried out on the website by the user.The user’s contribution is not required for these types of cookies.
Use related cookies and cookies ensuring performance
These cookies make it possible for the Company to memorize the user’s choices related to the webpage. The user is able to ban this data processing prior to using the service and during the use of the service as well. These data cannot be assigned to the webpage user’s data and without the user’s consent they cannot be handed over to a third person. For these types of cookies the user’s consent is needed.
Management of cookies on the webpage
Our Company’s webpage registers and handles the following data related to the user and the browsing tool: password, IP address, language, date of registration, most recent activity, automatic entry cookie, operation system, type of browser and other information. The system automatically keeps track of these data and does not link it to the data provided during the registration or during use. The Users do not have access to these data, only the Service Provider.
The Service Provider is entitled to register the data of internet pages from where the User reached the webpage, including those that were visited through the webpage and the date and duration of the visit. The person and identity of the user cannot be traced and disclosed with the help of these data.
Process (session) cookies
They help users browse the webpage.
- PHPSESSID: technical cookie containing work process ID
The legal basis for data processing: The appropriate work process related to the webpage is ensured in accordance with the stipulations of Act 13/A § (3) on certain issues related to ICT services and in line with the relevant directives of the European Commission.
The objective of data managment: ensuring appropriate operation of the webpage.
Duration: The data processing duration of these cookies only concerns the actual visit of the user, when the work process is finished or when the browser is closed the cookies are automatically deleted from your computer.
2. Cookies fostering use:
These cookies make it possible for our webpage to track the operational mode (e.g. whether the webpage uses the Hungarian or English version, accessible version, how many findings appear in the browser’s result list so that you do not need to enter these once again on your second visit. Without the information stored in the cookies our webpage can function, though less smoothly.
The webpage uses the following cookies:
- cookieconsent_dismissed: cookie required for the operation of the cookie regulation which stores the information whether the visitor accepts the cookie regulation
- fixlanguage: cookie containing the ID of the actually used language
The legal basis for the data processing: the visitor’s consent.
The objective of the data processing: to increase the efficiency of the service, to increase the user experience, to make the use of the webpage more comfortable.
Duration of the data processing: 12 months.
3. Cookies ensuring performance:
The cookies ensuring performance make it possible for us to collect infromation concerning how visitors are using our webpage (such as which pages the visitors have viewed, how many pages they have visited, which part of the page they have clicked, how long each of the work processes were, what sort of error messages appeared, etc).
This is done in order that we can further develop our webpage (available services, functions, etc) in line with our visitors’ needs and to provide a high quality, user friendly experience for them.
4. Third party cookies
In order to measure performance, our webpage uses third party cookies in case of each visit. By way of using the cookies we can track how many visitors are landing on the webpage and what content they are interested in. We store each piece of information anonymously so that we can guarantee high quality experience for our users.
The webpage uses the analytical cookies of the following provider:
- Cloudflare – the detailed information concerning the service is available at the following link: https://www.cloudflare.com/terms/
- Google Analytics – the detailed information concerning the service is available at the following link:https://www.google.com/analytics/terms/us.html
The legal basis for the processing of data: the visitor’s consent.
The purpose of data processing: to increase the efficiency of the service and the user experience, to make the use of the webpage more comfortable.
The duration of the data processing: 12 months.
For further information on third party cookies: https://www.google.com/policies/technologies/types/, on data protection: https://www.google.com/analytics/learn/privacy.html?hl=en
Cookie information and deletion
Prior to entering our webpage the user visiting our webpage is informed about the management of cookies.
It is not obligatory to accept and authorize the use of cookies. You can reset your browser settings in such a way that all of the cookies are disabled or the user is alerted when the system sends a cookie. Although most of the browsers automatically accept cookies in default setting, however, these can be changed in general in order to prevent automatic acceptance the system always offer this choice.
For further information about the settings of the most popular browsers:
We would like to draw your attention to the fact that certain webpage functions or services are not going to operate appropriately without cookies. Further information in the cookie regulation.
4. Registration of an advertiser profile on the Company’s webpage
The objective of managing personal data: Creating a contact account in order to distinguish between users and to establish new contacts, including the use of services offered by the webpage and storage space (e.g. advertisement profile), contacts, electronic contact and Information about the Company’s services, contractual conditions, promotions.
- Data subjects: natural persons advertising erotic massage services and natural persons provided by erotic massage parlors
- Processed personal data: e-mail address, user type, login, IP address, date of registration, IP address, most recent activity, automatik entry cookie and data for the advertisement profile
- Legal basis for managing personal data: The registering natural persons can enter their data by ticking the appropriate boksz and consenting to the management of their data.
- The addressees of personal data and the categories of addressees: the Company’s employees dealing with customer service, marketing activity, employees dealing with data processing and storage activities for the IT service provider.
- Duration of personal data storage: until the existence of registration / service or until the data subjects have withdrawn their consent (request for deletion). Until the data subjects have withdrawn their consent, otherwise the Company is going to delete the data 5 years following the deletion of the account.
5. Personalized advertisement profile account on the company’s webpage
Objective of the data processing: creating an advertisement profile in order to distinguish between users and to present the advertised services
- Data subjects: natural persons advertising erotic massage services and natural persons provided by erotic massage parlors
- Legal basis for data processing: the consent of the data subject that is provided when the advertisement account is created.
- Processed personal data: nickname, age, nationality, advertisement country, advertisement town, types of massages, sexual orientation, target group, about me, height, weight, bust, hip, waist size, hair colour, eye colour, spoken languages, uploaded photo and video, validation photo.
- The addressees of personal data and the categories of addressees: the Company’s employees dealing with customer service, marketing activity, employees dealing with data processing and storage activities for the IT service provider.
- Duration of personal data storage: until the withdrawal of the consent of the data subject, for 6 months following the deletion of the account.
The company informs its users that a part of these data is of special personal nature (e.g. sexual orientation), providing such data is voluntary and completing the profile is considered as a written consent. If you decide to provide these pieces of information in your profile and advertisement, we are going to share it on the webpage and use it to customize functions and services. All the users who have an authorized access to your account can view the personal data stored in the account, including the phone number, accounts about the services, ratings, comments.
6. Data processing related to the newsletter services
The users registering for the newsletter consent to the management of their personal data by ticking the relevant square. The user wishing to unsubscribe from the newsletter can do so by using the „Unsubscribe” function or in writing, or by sending a declaration in an e-mail at any time, this means the withdrawal of the consent. In this case all of the user’s data has to be deleted immediately.
Objective of managing personal data: Sending a newsletter, marketing material related to the Company’s products, services, sending personal data to the chosen advertisers in order to contact them
- Data subjects by personal data: all the natural persons that registered for the newspaper service by accepting the objective, the data processing and the General Terms and Conditions
- Processed personal data: name of the natural person, e-mail address, spoken language, interests for services which is identified based on the advertisement services selected by the user.
- Legal basis for data processing: the consent of the data subject.
- The addressees of personal data and the categories of addressees: the Company’s employees dealing with customer service, marketing activity, employees dealing with data processing and storage activities for the IT service provider.
- Duration of personal data storage: until the newsletter service is provided or until the withdrawal of consent by the data subject (request for deletion).
With registration the user acknowledges that the data collected – based on preferences, user habits and interests related to marketing content – can be used for making partly automated decisions as a result of which the company group is going to identify potential business opportunities on the „https://massage.dating website through subdomain platforms classified by countries.
By accepting the Communication on Data Protection, the users acknowledge and accept that with the help of the „https://massage.dating” platform Massage.Dating continuously keeps track of and registers if the users opened the newsletters or deleted them without opening and how many times they clicked on the references contained therein. Accordingly, the company identifies the contents that may be of interest for the company which was contacted through the e-mail address.
Data processing for the purpose of taxation and accounting obligations
The Company manages the data of natural persons (clients, suppliers) defined by legislation as part of its contractual obligation in order to comply with the necessary taxation and accounting obligations stipulated by law (accounting, taxation). The data processed by the Company are defined by the Accounting Act: tax number, name, address, tax status, name, address, the designation of the person or organization ordering economic transaction, the signature of the authorising officer and the person certifying the execution of the action, the signature of the auditor; the recipient’s signature on the receipts of stock movements and on cash handling receipts, the signature of the contributor on the receipts, the number of the business license, number of the primary producer’s card, tax ID number. Duration is 8 years following the termination of the legal relation. The addressees of the personal data: the employees and data processors of the Company dealing with taxation, accounting, payroll and social security tasks.
SHARING DATA WITH PARTNERS
The Company manages the website all over the world – through the webpage adapted for the specific countries – shares the information within the company and with outside partners and with those that you contact as an advertiser or registered member in line with the present regulation and the General Terms and Conditions.
For the purposes specified in this regulation, the information and personal data processed by Massage.Dating are forwarded to the United Kingdom, the United States of America or other, not the countries of residence or stored and processed there by our contractual data processors. Forwarding the daa is required in order to ensure the services described in the General Terms and Conditions and to be able to operate our storage and contact services all around the world and to make it accessible for all our users.
In case if the personal rights are transferred within Massage.Dating, this sort of transfer belongs to the model contracts of the Committee in accordance with the stipulations of 2004/915 / EC and 2010/87 / EU decisions on the transfer of personal data (that is, on the basis of standard contract clauses). In case if the data is transferred to third persons, these transfers are either (i) the Commission’s transfer contract model contracts (that is, standard contract clauses) in accordance with 2004/915 / EK and 2010/87 / EU; or (ii) can rely upon the EU-USA Privacy Shield framework system. You can contact the data protection officer by obtaining one copy of the data transfer contract or regarding further information related to the relevant guarantees. Further information concerning the EU-USA data protection framework system can be obtained at the website of the Commercial Ministry of the United States.
If we share personal information with partners related to certain third persons, including marketing and advertisement partners, too, this information include your name, e-mail address and other information that make it possible for the partners:
- they provide help in using our products and services,
- they contact you with offers, services and products that might interest you,
- ensure your products or services.
- If in line with your privacy regulations your preliminary consent is required for such sharing of information, we only share information with your consent. We would like to draw your attention to the fact that we will not grant permission if a request for service comes through a tool whose exact place of origin is hidden, for example through a virtual private network because we can not identify the legal status of that tool.
Furthermore, it is strictly forbidden for our partners to use the contact data beyond the above mentioned purposes without preliminary notice. We are not going to provide credit card details for our partners.
In case if we collect data from you related to an offer collectively presented by us and a partner, we are going to inform you about who is collecting the information, whose data protection regulations shall be considered valid in case of your information.
It can occur that we conclude a contract with a carefully chosen third partner for providing a service for us (such as customer service, fraud detection and deterrence or access on the advertising tool and providing information technology and storage services) or to help us in our own marketing and advertising activity (including the analytical information and search optimization services). These sorts of model contracts prohibit for us the use of your personal data for any purposes beyond the original purpose of why it was shared. If you buy a product or service from a third party through one of the brands, we hand over your personal data to such third party so that they can fulfil their order.
We do not share personal data with third parties, including media, industrial observers, marketing and advertisement partners, salespersons, clients, potential clients or partners. For example we present our mobile search trends, the open fee of e-mails, the best practices of the industry and the campaign or the number of users who visited our webpages or who clicked on our webpage and who rated our products and services.
COMMUNICATION ABOUT THE RIGHTS OF THE DATA SUBJECT
The data subjects are entitled to request information about the handling of personal data, they can request the correction of their personal data and – except for obligatory data processing – deletion, withdrawal of data, they can use their right of data transfer and the right to object in the way specified at the data registration and at the contact details of the Data processor specified above.
| Right for preliminary information | (Regulation article 13-14) |
| Access rights of the data subjects | (Regulation article 15). |
| Right for correction | (Regulation article 16) |
| Right for deletion („right to erasure”) | (Regulation article 17) |
| Right for the limitation of data processing. | (Regulation article 18) |
| Right for the correction or deletion of personal data and notification obligation related to the limitation of data processing | (Regulation article 19 |
| Right to data portability | (Regulation article 20) |
| Right to object | (Regulation article 6 (1) e) or f) and Regulation article 21 |
| Automated decision making processes in individual cases, including profile creation | (Regulation article 22 |
| Limitations | in line with the rights and obligations contained in articles 12–22 and in article 34, and articles 12–22 (Regulation article 23) |
| Information for the data subjects about data protection incidents | (Regulation article 34 |
| Right for making complaints at the supervisory authority (right of appeal to a judicial authority) | (Regulation article 77 |
| Right of appeal to a supervisory authority | (Regulation article 78) |
| Right of appeal to a judicial authority against the data processor or data processor | (Regulation article 79) |
Right for information
The data processor takes the necessary actions to provide all the relevant information specified in articles 13 and 14 of the GDPR regarding personal data processing for the data subjects, and in accordance with articles 15–22 and 34 in a clear, short, understandable and easily accessible way.
Right of access: The data subjects are entitled to get feedback from the Data processor regarding whether the management of their personal data is in progress and if such data processing is in progress, they have the right to be granted free access to the data and pieces of information:
- objectives of data processing;
- categories of the personal data concerned;
- addressees and categories of addressees who were informed about the personal data or with whom the data will be shared, including especially the addressees from third countries and international organisations
- planned duration of storage concerning personal data;
- correction, deletion or data processing limitation and the right to object;
- right to submit appeals and claims to the supervisory authority;
- information concerning data resources;
- the fact of automated decision making, including profile creation and the applied logics and understandable information regarding that, and the foreseeable consequences for the data subjects.
The data processor is going to provide the necessary information within a month from the submission of the request.
Right for data correction: The data subjects are entitled to request the correction of the incorrect personal data processed by the Data processor concerning them, this also applies to data where some information is missing. In the user profile, purchasing and in case of some saved data the registered persons can also do the immediately required modifications themselves.
Right of deletion: The data subjects are entitled to request the immediate deletion of their personal data in the following cases:
- the personal data that were collected or otherwise processed are no longer required;
- the data subjects withdraw their consent to data processing, there is no other legal basis for data processing;
- the data subjects objects to the data processing and there is no legal reason for data processing;
- personal data were processed illegally;
- in accordance with European Union or national legislation the personal data concerning the data processor have to be deleted;
- the personal data are collected since ICT related services are being offered.
The deletion of the data cannot be initiated if data processing is required:
- in order to practice rights related to the freedom of expression and rights related to the information;
- for the purpose of complying with EU or national legislation that stipulates the management of personal rights with regard to the data processor, or for the purpose of fulfilling an obligation as part of exercising public powers;
- in cases related to public health, archiving, scientific and historical research, for statistical purposes or for public benefit;
- or the purpose of the establishment, exercise or defence of legal claims.
Right to limit and withdraw data processing: At the request of the data subjects the Data processor limits data processing if one of the following conditions is fulfilled:
- the data subjects disputes the exactitude of the personal data, in this case the limitation only concerns the period that makes it possible to check the correctness of personal data;
- the data processing is against the law and the data subject objects to the deletion of the data, instead requesting the limitation of their use;
- the data processor no longer needs the data for data processing, but the data subject requires them the purpose of the establishment, exercise or defence of legal claims; or
- the data subject objected to the data processing; in this case the limitation concerns the period of time, until it is decided whether the data processor’s justified reasons have priority over the justified reasons of the data subject.
In case if the data processing is subject to limitations, with the exception of storage personal data can only be handled and processed with the preliminary consent and approval of the data subject, or for the purpose of the establishment, exercise or defence of legal claims, or for defending the rights of other natural or legal persons, or for the public benefit and interest of the European Union or any of the member states.
Right to data portability: The data subjects are entitled to receive a printed, comprehensively used, clearly legible, typewritten document specifying their rights that they provided for the data processor and to forward these data to another data processor.
Right to object: The data subjects are entitled to object to the public use of their personal data for any reason or to the data processing required for the task executed as part of exercising the public powers transferred to the data processor or to the data processing required for the validation of the data processor’s or a third party’s justified interests, including the creation of profiles based on the above mentioned regulations.
In case of objection the data processor is not authorized to continue with the data processing, except if compelling legitimate grounds justify their further use which have priority over the concerned party’s interests, rights and freedom or which are related to the establishment, exercise or defence of legal claims.
Objection in case of direct marketing: In case if personal data is processed for direct marketing purposes, you are entitled to object to the processing of your data for these purposes, including profile creation if it is related to direct marketing. If you object to the processing of your personal data for the purposes of direct marketing, personal data cannot be processed for this objective any longer.
Automated decision making in individual cases, including profile creation: You are entitled to opt for evading the scope of decisions that are based on automated data processing – including profile creation as well – which would have a legal or any kind of significant impact on you.
The previous chapter cannot be employed in case if:
- the decision is needed for the conclusion or the fulfilment of the contract between you and the data processor;
- the decision making is made possible by the European Union’s or member state’s legislation which also specifies measures defending your legitimate interests, rights and freedom; or contributed to it.
Right to make a complaint at the supervisory authority:
- Without prejudice to any other administrative or non-judicial remedy, each data subject shall have the right to an effective judicial remedy where the supervisory authority which is competent – especially in the member state where the data subjects have the country of residence, place of work or the suspected infringement took place -, in case if they consider that the processing of their data violates the regulation.
- The supervisory authority where the complaint was submitted, is obliged to inform the client concerning the progress of the procedure related to the complaint and its result, including that in accordance with article 78 of the Regulation, the client is entitled to resort to using legal remedy. (Article 77 of the Regulation)
Right to effective judictial review at the Supervisory Authority
- Without prejudice to any other administrative or non-judicial remedy, each natural or legal person shall have the right to an effective judicial remedy against the binding decision made by the supervisory authority.
- Without prejudice to any other administrative or non-judicial remedy, each data subject shall have the right to an effective judicial remedy if the supervisory authority that is competent according to Article 55 and 56 does not deal with the complaint submitted pursuant to Article 77 or if the data subejct is not informed about the progress of the procedure or the results.
- Proceedings against a supervisory authority should be brought before the courts of the Member State where the supervisory authority is established.
- Where proceedings are brought against a decision of a supervisory authority which was preceded by an opinion or a decision of the Board in the consistency mechanism, the supervisory authority shall forward that opinion or decision to the court. (Article 78 of the Regulation)
Effective judicial remedy against the controller or the data processor
- Without prejudice to the available administrative or non-judicial remedy – including the right to make a complaint at the Supervisory Authority pursuant to Article 77 – each natural or legal person shall have the right to an effective judicial remedy if they consider that their rights were violated due to the inappropriate processing of their personal data pursuant to this Regulation.
- Proceedings against a controller or a processor shall be brought before the courts of the Member State where the controller or processor has an establishment. Alternatively, such proceedings may be brought before the courts of the Member State where the data subject has his or her habitual residence, unless the controller or processor is a public authority of a Member State acting in the exercise of its public powers. (Article 79 of the Regulation)
Communication of a personal data breach to the data subject
When the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, the controller shall communicate the personal data breach to the data subject without undue delay.
SUBMISSION OF THE DATA SUBJECT’S REQUEST, MEASURES TAKEN BY THE CONTROLLER
- The Controller shall inform the data subject about the actions taken as a result of the request for exercising his or her rights without any reasonable delay but within one months of receiving the request at the latest.
- That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. The controller shall inform the data subject of any such extension within one month of receipt of the request, together with the reasons for the delay.
- Where the data subject makes the request by electronic form means, the information shall be provided by electronic means where possible, unless otherwise requested by the data subject.
- If the controller does not take action on the request of the data subject, the controller shall inform the data subject without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.
- The Data Processor shall ensure the information pursuant to Articles 13 and 14 of the Regulation and the communication concerning the rights of the data subject (Articles 15-22 and 34 of the Regulation) and the action free of charge. In case if the data subject’s request is evidently ungrounded or – in particular because of their repetitive character – exaggerated, with regard to the administrative costs related to the requested information or the action taken the Data Processor may refuse to act on the request.
- Where the controller has reasonable doubts concerning the identity of the natural person making the request, the controller may request the provision of additional information necessary to confirm the identity of the data subject.
- We refuse to fulfill the request in the event when we can prove that the data processing is justified by compelling legitimate grounds which take precedence over your interests, rights and freedoms, or which are related to the presentation, exercise or defense of legal claims.
- In case if you do not agree with our decision or if we fail to keep the deadline, you are entitled to bring the case before the court within 30 days of the communication of the decision or the last day of the deadline.
OTHER DISPOSITIONS AND INFORMATION
1. Enforcement proceedings
The fact that the data processing complies with the law, has to be proven by the data controller. The legitimacy of data transmission has to be proven by the data importer. The court is in charge of making a decision at the end of the proceedings. The legal proceedings – based on the choice of the data subject – can be brought to the competent court according to the place of residence or place of stay of the data subject.
2. Communication of a personal data breach to the data subject
When the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, the controller shall communicate the personal data breach to the data subject without undue delay.
The data subject does not need to be informed, if any of the following conditions are met:
- the controller has implemented appropriate technical and organisational protection measures, and those measures were applied to the personal data affected by the personal data breach, in particular those that render the personal data unintelligible to any person who is not authorised to access it, such as encryption;
- the controller has taken subsequent measures after the incident which ensure that the high risk to the rights and freedoms of data subjects is no longer likely to materialise;
- the information would require a disproportionate effort. In such cases the data subjects concerned should be informed by way of published information or similar measures should be taken to ensure stakeholders in an equally efficient way.
In the case of a personal data breach, the controller shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the supervisory authority competent in accordance with Article 55, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. Where the notification to the supervisory authority is not made within 72 hours, it shall be accompanied by reasons for the delay.
3. Compensation and grievance fees
If the controller causes harm by the unlawful processing of data related to the data subject or by breaching the data security regulations, the controller is liable to compensate this breach. If the controller causes harm by the unlawful processing of data related to the data subject or by violating the civil rights of the data subject, the data subject is entitled for a grievance fee from the data controller.
You do not have to compensate for the damage and the grievance fees if the impairment caused by civil rights violation was due to deliberate or seriously obvious negligence of the party concerned.
4. Legal remedies
Privacy Contact: If you wish to enforce your rights related to your data, please email to [email protected] and we will handle your request.
The data subject is entitled to initiate a legal procedure by the National Authority for Data Protection and Freedom of Information that is competent at the place of residence in case if legal remedy needs to be sought related to the processing of personal data or if there is a direct danger concerning that.
Any data subjects are entitled to turn to the court in case if they wish to seek legal remedy related to their personal data. The judgement at the end of the legal proceedings belongs to the competence of the court. The legal action – according to the choice of the data subject – can be brought to the court that is competent in the place of residence.
5. Modification of the Communication on Data processing
The Data Processor reserves the right to modify the present communication on data processing. After the webpage’s modification has entered into force, the modified communication on data processing shall be accepted.
Valid as of January 01, 2024
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