Information on data management
The Véleménybázis Alapítvány/Véleménybázis Foundation (hereinafter referred to as: service provider, data controller) is subject to the following information.
The following information is provided pursuant to 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 Regulation (EC) No 95/46/EC (General Data Protection Regulation).
This privacy statement governs the processing of data on the following sites: fishermans.io
The privacy statement is available on this page.
Any changes to this notice will take effect upon publication at the address above.
THE DATA CONTROLLER AND ITS CONTACT DETAILS:
Name: Véleménybázis Alapítvány
Address: 1122 Budapest, Városmajor utca 48/B.
E-mail: [email protected]
DEFINITION OF TERMS
(1) “personal data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
(2) ‘processing’ means any operation or set of operations which is performed upon personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
(3) “controller” means a natural or legal person, public authority, agency or any other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of the processing are determined by EU or national law, the controller or specific criteria for the designation of the controller may also be determined by EU or national law;
(4) “processor” means a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller;
(5) “recipient” means a natural or legal person, public authority, agency or any other body to whom or with which personal data is disclosed, whether or not a third party. Public authorities which may have access to personal data in the context of an individual investigation in accordance with EU or national law are not recipients; the processing of those data by those public authorities must comply with the applicable data protection rules in accordance with the purposes of the processing;
(6) “data subject’s consent” means a freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she signifies, by a statement or by an act expressing his or her unambiguous consent, that he or she signifies his or her agreement to the processing of personal data concerning him or her;
(7) “data breach” means a breach of security that results in the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
PRINCIPLES GOVERNING THE PROCESSING OF PERSONAL DATA
(a) be carried out lawfully and fairly and in a transparent manner for the data subject (“lawfulness, fairness and transparency”);
(b) be collected only for specified, explicit and legitimate purposes and not processed in a way incompatible with those purposes; further processing for archiving purposes in the public interest, scientific and historical research purposes or statistical purposes shall not be considered incompatible with the original purpose in accordance with Article 89(1) (‘purpose limitation’);
(c) be adequate, relevant and limited to what is necessary for the purposes for which the data are processed (“data minimisation”);
(d) be accurate and, where necessary, kept up to date; all reasonable steps must be taken to ensure that personal data which are inaccurate for the purposes for which they are processed are erased or rectified without undue delay (“accuracy”);
(e) be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be kept for longer periods only if the personal data will be processed for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1), subject to the implementation of appropriate technical and organisational measures to safeguard the rights and freedoms of data subjects as provided for in this Regulation (‘limited storage’);
(f) be carried out in such a way as to ensure adequate security of personal data, including protection against unauthorised or unlawful processing, accidental loss, destruction or damage (“integrity and confidentiality”), by implementing appropriate technical or organisational measures.
The controller is responsible for compliance with the above and must be able to demonstrate such compliance (“accountability”).
PROCESSING OF DATA RELATED TO THE OPERATION OF THE SITE
- The fact of data collection, the scope of data processed and the purpose of data processing:
Managed data: first and last name
Purpose of the processing: Contact
Data processed: e-mail address
Purpose of processing: Contact
Data processed: telephone number
Purpose of data processing: Contact
Managed data: date of registration
Purpose of data processing
Processed data: IP address at the time of registration
Purpose of processing
Execution of a technical operation.
- Data subjects: all data subjects registered on the website.
- Duration of data processing, deadline for deletion of data: immediately upon cancellation of registration. Deletion of any personal data provided by the data subject. If the data subject’s request for erasure also includes the e-mail address provided by the data subject, the controller will also erase the e-mail address following the notification. Except in the case of accounting records, since pursuant to Article 169 (2) of Act C of 2000 on Accounting, these data must be kept for 8 years.
Accounting documents (including general ledger accounts, analytical or detailed records) directly and indirectly supporting the accounting accounts must be kept for at least 8 years in a legible form, retrievable by reference to the accounting records.
- Identity of potential data controllers, recipients of personal data: personal data may be processed by the controller’s staff, in compliance with the principles set out above.
- Description of data subjects’ rights in relation to data processing:
- The data subject may request the controller to access, rectify, erase or restrict the processing of personal data relating to him or her, and
- object to the processing of such personal data; and
- the right to data portability and the right to withdraw consent at any time.
- The data subject may initiate access to, erasure, modification or restriction of processing of personal data, data portability and objection to processing in the following ways:
– by post at the registered office of the controller,
– by e-mail at [email protected]
- Legal basis for processing:
7.1 Article 6(1)(b) GDPR,
The service provider may process personal data which are technically indispensable for the provision of the service. The service provider must, other conditions being equal, choose and in any case operate the means used in the provision of the information society service in such a way that personal data are processed only if absolutely necessary for the provision of the service and for the fulfilment of the other purposes specified in this Act, but in this case only to the extent and for the duration necessary.
7.3 When issuing an invoice in accordance with accounting legislation, Article 6(1)(c).
7.4 In the event of enforcement of claims arising from the contract, 5 years pursuant to § 6:21 of Act V of 2013 on the Civil Code.
- 6:22 [Limitation period]
(1) Unless otherwise provided by this Act, claims shall be time-barred after five years.
(2) The limitation period shall begin to run when the claim becomes due.
(3) An agreement to change the limitation period shall be in writing.
(4) An agreement excluding the limitation period is void.
- Please be informed that
– the processing is necessary for the performance of a contract.
– You are required to provide personal data in order for us to fulfil your order.
– failure to provide the data will result in our inability to process your order.
THE DATA PROCESSORS USED
- Activity performed by the data processor: Hosting
- Name and contact details of the data processor:
Name: DigitalOcean, LLC.
Address: 101 Avenue of the Americas, 10th Floor, New York, NY 10013
E-mail: [email protected]
Physical location of data processing: Frankfurt, Germany
- Fact of processing, scope of data processed: all personal data provided by the data subject.
- Data subjects: all data subjects using the website
- Purpose of data processing: to make the website available and to ensure its proper operation.
6.Duration of data processing, deadline for deletion of data: data processing lasts until the termination of the agreement between the data controller and the hosting provider or until the data subject’s request for deletion to the hosting provider.
- The legal basis for the processing of the data is Article 6(1)(c) and (f) and Article 13/A(3) of Act CVIII of 2001 on certain aspects of electronic commerce services and information society services.űű
CRM system operation
- Activity performed by the data processor: provision of database services
- Name and contact details of the data processor:
- Fact of processing, scope of data processed: name, e-mail address
- Data subjects: all data subjects who register on the website.
- Purpose of processing: responding to enquiries about the service, contacting the registrant
- Duration of processing, deadline for deletion of data: until consent is withdrawn.
- Legal basis for processing: article 6(1)(b) GDPR. The processing is necessary for the purposes of online payment at the request of the data subject.
- Rights of the data subject:
- You may be informed of the circumstances of the processing,
- You have the right to receive feedback from the controller on the processing of your personal data and to access all information relating to the processing.
- You have the right to receive your personal data in a structured, commonly used, machine-readable format.
- You have the right to have inaccurate personal data corrected by the controller without undue delay at your request.
COOKIE MANAGEMENT (COOKIES)
- Website-specific cookies are so-called “password-protected session cookies”, “shopping cart cookies” and “security cookies”, the use of which does not require prior consent from the data subject.
- Fact of processing, scope of data processed: unique identifier, dates, times
- Data subjects: all data subjects visiting the website.
- Purpose of data processing: to identify users, to register the “shopping cart” and to track visitors.
- 5. Duration of data processing, deadline for deletion of data:
Cookie type: session cookies
Legal basis for data processing:Section 13/A (3) of Act CVIII of 2001 on certain aspects of electronic commerce services and information society services (Elkertv.)
Duration of processing: until the end of the relevant visitor session
Managed data body: connect.sid
- Description of data subjects’ rights in relation to data processing: data subjects have the possibility to delete cookies in the Tools/Preferences menu of their browsers, usually under the Privacy settings.
USE OF GOOGLE ADWORDS CONVERSION TRACKING
- The data controller uses the online advertising program “Google AdWords” and makes use of Google’s conversion tracking service within its framework. Google Conversion Tracking is an analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).
- When you reach a website through a Google ad, a cookie is placed on your computer to track conversions. These cookies have a limited validity and do not contain any personal data, so they do not identify the User.
- When the User browses certain pages of the website and the cookie has not yet expired, Google and the data controller can see that the User has clicked on the advertisement.
- Each Google AdWords client receives a different cookie, so they cannot be tracked through AdWords clients’ websites.
- The information, which is obtained through the use of conversion tracking cookies, is used to provide conversion statistics to AdWords customers who choose to track conversions. Clients are then informed of the number of users who click on their ad and are referred to a page with a conversion tracking tag. However, they do not have access to information that would allow them to identify any user.
- If you do not want to participate in conversion tracking, you can opt-out by disabling the option to set cookies in your browser. You will then not be included in the conversion tracking statistics.
- Further information and Google’s privacy statement can be found at: www.google.de/policies/privacy/
THE APPLICATION OF GOOGLE ANALYTICS
- This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site you have visited.
- The information generated by the cookies on the website used by the User is usually transmitted to and stored on a Google server in the USA. By activating the IP anonymisation on the website, Google will previously shorten the User’s IP address within the Member States of the European Union or in other states party to the Agreement on the European Economic Area.
- Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity for the website operator and to provide other services relating to website activity and internet usage.
SOCIAL NETWORKING SITES
- Fact of data collection, scope of data processed: name registered on Facebook and Instagram social networking sites and public profile picture of the user.
- Data subjects: all data subjects who have registered on Facebook and Instagram and have “liked” the website.
- Purpose of data collection: to share, “like” or promote certain content, products, promotions or the website itself on social networking sites.
- Duration of data processing, time limit for deletion of data, the identity of the possible controllers entitled to access the data and the rights of the data subjects in relation to data processing: the data subject can find out about the source of the data, the processing of the data and the method and legal basis of the transfer on the relevant Community site. The data are processed on the social networking sites, so the duration of the processing, the way in which the data are processed and the possibilities for deleting and modifying the data are governed by the rules of the social networking site concerned.
- Legal basis for processing: the data subject’s voluntary consent to the processing of their personal data on social networking sites.
CUSTOMER RELATIONS AND OTHER DATA MANAGEMENT
- Should the data controller have any questions or problems when using our services, the data subject may contact the data controller using the methods provided on the website (telephone, e-mail, social networking sites, etc.).
- The Data Controller shall delete the data provided in e-mails, messages, telephone, Facebook, etc., together with the name and e-mail address of the interested party and other personal data voluntarily provided by the interested party, after a maximum of 2 years from the date of the communication.
- Information on data processing not listed in this notice is provided at the time of collection.
- The Service Provider shall be obliged to provide information, disclose data, hand over data or make documents available in response to exceptional requests from public authorities or other bodies authorised by law.
- In such cases, the Service Provider shall disclose personal data to the requesting party only to the extent and to the extent strictly necessary for the purpose of the request, provided that the requesting party has indicated the exact purpose and scope of the data.
THE RIGHTS OF DATA SUBJECTS
The controller and the processor shall implement appropriate technical and organisational measures, taking into account the state of the art and the cost of implementation, the nature, scope, context and purposes of the processing and the varying degrees of probability and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of data security appropriate to the level of risk, including, where appropriate:
- a) the pseudonymisation and encryption of personal data;
- b) the continued confidentiality, integrity, availability and resilience of the systems and services used to process personal data;
- c) in the event of a physical or technical incident, the ability to restore access to and availability of personal data in a timely manner;
- d) a procedure to regularly test, assess and evaluate the effectiveness of the technical and organisational measures taken to ensure the security of processing.
INFORMING THE DATA SUBJECT OF THE PERSONAL DATA BREACH
Where a personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, the controller shall inform the data subject of the personal data breach without undue delay.
The information given to the data subject shall clearly and prominently describe the nature of the personal data breach and provide the name and contact details of the data protection officer or other contact person who can provide further information; describe the likely consequences of the personal data breach; describe the measures taken or envisaged by the controller to remedy the personal data breach, including, where appropriate, measures to mitigate any adverse consequences of the personal data breach.
The data subject need not be informed if any of the following conditions are met:
- the controller has implemented appropriate technical and organisational protection measures and those measures have been applied to the data affected by the personal data breach, in particular measures, such as the use of encryption, which render the data unintelligible to persons not authorised to access the personal data;
- the controller has taken additional measures following the personal data breach to ensure that the high risk to the rights and freedoms of the data subject is no longer likely to materialise;
- information would require a disproportionate effort. In such cases, the data subjects should be informed by means of publicly disclosed information or by a similar measure which ensures that the data subjects are informed in an equally effective manner.
- If the controller has not yet notified the data subject of the personal data breach, the supervisory authority may, after having considered whether the personal data breach is likely to present a high risk, order the data subject to be informed.
REPORTING A PERSONAL DATA BREACH TO THE AUTHORITY
The data protection incident shall be notified by the controller to the supervisory authority competent under Article 55 without undue delay and, if possible, no later than 72 hours after the data protection incident has come to its attention, unless the data protection incident is unlikely to pose a risk to the rights and freedoms of natural persons. If the notification is not made within 72 hours, it shall be accompanied by the reasons justifying the delay.
REVIEW IN CASE OF MANDATORY PROCESSING
If the duration of the mandatory processing or the periodic review of its necessity is not specified by law, local government regulation or a binding legal act of the European Union, the controller shall review, at least every three years from the start of processing, whether the processing of personal data processed by the controller or by a processor acting on its behalf or under its instructions is necessary for the purposes of the processing.
The data controller shall document the circumstances and the result of this review, keep this documentation for ten years after the review and make it available to the National Authority for Data Protection and Freedom of Information (hereinafter referred to as “the Authority”) upon request.
POSSIBILITY TO COMPLAIN
A complaint against a possible infringement by the data controller can be lodged with the National Authority for Data Protection and Freedom of Information:
National Authority for Data Protection and Freedom of Information
1125 Budapest, Szilágyi Erzsébet fasor 22/C.
Postal address: 1530 Budapest, P.O. Box 5.
Phone: +36 -1-391-1400
E-mail: [email protected]