DATA MANAGEMENT STATEMENT

In the activity of the Data Controller (hereinafter “Data Controller”), he is paying particular attention to the protection of personal data, compliance with mandatory legal provisions, safe and fair data management.

Data Manager Data:

Company Name: Right Communication Kft.
Business Registration Number: 01 09 877354
Headquarters: 1025 Budapest, Cseppkő u. 46 / C.
Tax number: 13866958-2-41

In any case, the Data Controller manages the personal data provided to him in compliance with the applicable Hungarian and European legislation and ethical requirements, in any case he or she shall take the technical and organizational measures necessary for the proper safe handling of data.

This Policy is based on the following applicable laws:

• 1995 CXIX. TV. addressing address and home address data for search and direct business purposes
• CVIII of 2001. TV. e-commerce services and information society services
• Act XLVIII of 2008. TV. the basic conditions and some limitations of economic advertising activity
• Act CXII of 2011 on Information Freedom of Information and Freedom of Information
• Regulation (EU) No 2016/679 / EU of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and Directive 95/46 /

Repeal of the Order The Data Controller undertakes to unilaterally comply with the present Policy and requests, that its Customers also accept the provisions of the Code. The Data Controller reserves the right to change the privacy policy, in which case the amended policy is publicly disclosed.

2. INTERPRETATIVE PROVISIONS In our policy, data protection terms have the following meanings:

Personal data: Any natural person (identified or identifiable) identified (identified as identifying or identifiable), as referred to herein, may be deduced from the data for the person concerned. Personal data preserves this quality while handling it, as long as its connection can be restored with the individual. In particular, a person may be identified, if it can be identified, directly or indirectly, by a name, identifier, or one or more physical, physiological, mental, economic, cultural or social identity.

Contribution: voluntary and decisive disclosure of the will of the person concerned, based on appropriate information, and giving him an unmistakable consent to the handling of his or her personal data, whether complete or inclusive.

Protest: the statement of the person with whom he or she is objecting to the handling of his / her personal data and requesting the termination of the data processing or the cancellation of the processed data.

Data Administrator: a natural or legal person, or an entity, that does not have legal personality, who either independently or with others determines the purpose of data management, makes and executes decisions on data management (including the used device) or performs it with the Data Processor.

Data Management: irrespective of the method used, any operation or aggregation of operations, such as collecting, capturing, recording, systematizing, storing, modifying, utilizing, retrieving, transmitting, publishing, aligning, linking, blocking, deleting and destroying any of the operations, or to prevent further use of the data, to take photographs, sound or images, and to record physical features that can be identified by the person.

Date Transmission: To make the data available to a specific third party. Disclosure: making the data available to anyone.

Data wiping: Making data unrecognizable in such a way, that its recovery is no longer possible.

Data designation: Providing the data identifying mark to distinguish it.

Data encryption: for the purpose of limiting the continued handling of the data with an identifying indication for a definite or fixed time period.

Data Destruction: Complete Physical Destruction of Data-Carrier Media.

Data processing: performs technical tasks related to data management operations, irrespective of the method and device used to perform the operations and the location of the application, provided that the technical task is performed on the data record.

“Data processor” means a natural or legal person or an organization without legal personality who, on the basis of a contract, including a contract under a provision of the law, processes data.

Data Records: the sum of data processed in one register. Third party: a natural or legal person or a non-legal entity that is not the same as the data subject, the data controller or the data processor.

EEA State: a Member State of the European Union and a State party to the Agreement on the European Economic Area, as well as a State which is a national under an international agreement between the European Union and its Member States and a non-member State not party to the Agreement on the European Economic Area, Shall enjoy the same status as a national of a State Party to the Agreement on the Area.

Third country: any State other than an EEA State. Privacy Incident: Illegal processing or processing of personal data, including unauthorized access, alteration, transmission, disclosure, deletion or destruction, and incidental destruction or damage.

3. DATA HANDLING POLICY
Personal data may be handled, if the party concerned agrees to it, or it is governed by a local government decree or a law or, under the authority of the law, within the scope specified therein. Personal data can only be handled for a specific purpose, in order to exercise the right and to fulfill obligations. At all stages of the data handling, it must meet this goal. Only personal data that is essential for achieving the purpose of data management can only be used to reach the goal, only to the extent and for the time necessary to achieve it. Personal data can be transmitted, and different data manipulations can be linked when the party concerned has consented to it or if the law allows it and if the terms of the data are met for each personal data. Personal data from the country, irrespective of the data carrier or the mode of transmission, may be transmitted to a data controller or data processor in a third country if the data subject is explicitly consented to or permitted by law and in the third country for handling or processing the data transferred an adequate level of protection of personal data is ensured. In the case of mandatory data handling, the purpose and conditions of the data management, the scope and knowledge of the data to be handled, the length of the data management and the data controller are determined by the law on data management or the self-governing decree. A law may order the disclosure of personal data in the public interest, with the explicit indication of the scope of the data. In all other cases, disclosure is required by the consent of the person concerned, and in case of special data, written consent. In case of doubt, it must be presumed that the party concerned has not given his consent. The consent of the person concerned shall be deemed to be given in respect of the data, which he has communicated or made available for disclosure during the public service of the person concerned. The consent of the person concerned to the treatment of his or her data needs to be presumed. For this fact, the attention of the person concerned should be invoked. You may also grant your consent to a contract with the Data Handler in writing to complete the contract. In this case, the contract must contain all information that the data subject needs to know for the purposes of personal data management, in particular the definition of the data to be processed, the duration of the data handling, the purpose of use, the transmission of data and the use of data processing. The contract must, in an unambiguous manner, contain the signature of the signatory to manage its data as specified in the contract. The right to privacy and the privacy of the person concerned, except where otherwise provided by law, cannot be infringed by other interests, including the publicity of data of public interest.

Data of website visitors
The Data Handler does not record any user’s IP address or other personal data when visiting the web pages it hosts. The html code of the web pages operated by the Data Controller may contain, for web analytical measurements, references to external servers and external servers. The measurement also includes tracking conversions. The web analytics provider does not only handle personal data, it only treats browsing data that is not suitable for identifying individual individuals.

Currently, web analytics are performed by Google Inc. (1600 Amphitheater Parkway, Mountain View, CA 94043), under Google Analytics.

Through the Facebook and Google AdWords advertising systems, you run remarketing ads. These providers may collect or receive data from the Data Management Web site and other Internet sites using cookies, web signers, and similar technologies. Use these data to provide measurement services or target ads. Targeted ads may appear on additional websites in Facebook and Google’s partner network (such as Instagram).

Remarketing lists do not include the visitor’s personal information and are not personally identifiable.

You can delete cookies from the user’s own computer or block them from being used in your browser. Depending on the browser, these options are typically set in Settings / Privacy. For more information about Google and Facebook privacy policies, visit the following link: http://www.google.com/privacy.html and https://www.facebook.com/about/privacy/ Newsletter

The Data Manager submits newsletters (also known as VIP members) to the newsletters of websites operated by it, usually newsletters containing news, news and offers on a monthly basis, but once daily, and delivering direct marketing messages via e-mail or postal mail. To subscribe to the newsletter, the name and e-mail address are mandatory, which is essential for the delivery of the messages. The data will be processed until the deletion of the data is requested by the data subject. The possibility of unsubscribing is provided in every newsletter by a direct link. The user is responsible for the authenticity of the personal data provided. Data management related to the newsletter has been announced to the National Data Protection and Freedom Authority, data protection registration identification number of data management: “announcement in process” Quiz game

The data handler may announce quiz games on the websites it runs. One person can take part in a quiz game. To check this, ask the player’s name, e-mail address, and phone number. Emails to all players on their emails if they have won the quiz. On the given phone number, the winner will notify you or request further details of the winner that are required to deliver any potential prize. The data of the quiz players will be kept until the last day of the current year.

5. SECURITY OF DATA MANAGEMENT

This site is owned by: Right Communication Kft.

Newsletter Distribution

The Data Controller protects the data in particular against unauthorized access, alteration, transmission, disclosure, deletion or destruction, and against accidental destruction and damage. The Data Manager, together with the server’s operators, provides the technical, organizational and organizational measures for the security of the data, which provides a level of protection that corresponds to the risks associated with data management.

RIGHTS OF THE INTERESTED PARTIES

You may request the information concerned to handle your personal data and may request the rectification of your personal information or, with the exception of statutory data handling, in the link in the footer of the newsletters or at any contact of the Data Controller. At the request of the data subject, the Data Controller shall provide information on the data he or she handles, the purpose, legal basis, duration of the data processing, the data processor’s name, address (domicile) and data management related activities, and the data for and for what purpose. The Data Controller shall provide the information in writing, in a readable form, within the shortest possible time, not later than 25 days after the submission of the request. The Data Controller must correct the personal data that is not true. The Personal Data is deleted by the Data Manager if its handling is unlawful, the person concerned requests it, is incomplete or incorrect – and this status can not be legally corrected – provided that the deletion is not excluded if the purpose of data management is terminated, the statutory deadline for storing the data expired or ordered by the court or the Data Protection Commissioner. Correction and deletion will be notified to the affected person, as well as those who previously forwarded the data for data processing. Notification may be omitted if it does not prejudice the legitimate interest of the data concerned for the purpose of data handling. The person concerned may object to the handling of his or her personal data if the processing of personal data is only necessary to enforce the right or legitimate interest of the data controller or the data exporter, unless data management is prescribed by law, the use or transmission of personal data is direct business acquisition, or for scientific research, the exercise of the right of protest is otherwise permitted by law. The Data Controller shall simultaneously suspend the processing of data to examine the protest within the shortest possible time but not later than 15 days from the submission of the application and inform the applicant in writing thereof. If the protest is warranted, the data controller shall also discontinue data processing, including further data collection and transmission, and lock the data, and inform the protest and any action taken against any person who has previously transferred the personal data involved in the protest and who are obliged to take action in order to enforce the right to protest. In case of violation of his or her rights, the data subject may turn to the court or the data protection authority.