2019. marcius 27.    [CONFERENCE.SCIO-EDUCTOR.COM- PRIVACY POLICY]

Conference.scio-eductor.com

Privacy Policy

Bevezetés

MANDELAY Magyarország Limited Liability Commercial Company (company number: 13-09-151464, tax number: 23586310-2-13, registered office: 2310 Szigetszentmiklós, Gyártelep), (further on: Service-provider, Data processor) subdues itself under the following policy.

REGULATION (EEC) No 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (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, the following information is provided.

The present privacy policy guide regulates privacy of the following websites: https://conference.scio-eductor.com/https://rendezveny.scio-eductor.com/

The present privacy policy guide can be found on: https://conference.scio-eductor.com/privacy

Modifications to the data become effective when they appear on the webpage above.

The data manager and contact information:

Name: MANDELAY Magyarország Limited Liability Commercial Company Seat: 2310 Szigetszentmiklós, Gyártelep 12001/33 hrsz.

E-mail: This email address is being protected from spambots. You need JavaScript enabled to view it.This email address is being protected from spambots. You need JavaScript enabled to view it. Telephone: +36 (20) 250-7190 Skype telephone: +1 206 201 2394

Explanatory terms

1. ״personal data": any data that can be related to the Customer - especially the name, username of the customer and any knowledge characteristic for one or more physical, physiological, mental, economic, cultural, or social identity of the Customer - and any conclusion related to the Customer drawn from the data;

2. ״data management”: the totality of any operation or operations carried out in an automated or non-automated manner on personal data or data files, such as collecting, recording, organizing, tagging, storing, modifying or modifying, querying, inspecting, using, communicating, distributing or otherwise making available, aligning or linking, limiting, deleting or destroying;

3. ״data manager”: means any natural or legal person, public authority, agency or any other body that determines the purposes and means of handling personal data individually or with others, where the purposes and means of data management are defined by Union or national law, the data controller or the particular aspects of the designation of the data controller may also be defined by Union or national law;

4. ״data processor”: means any natural or legal person, public authority, agency or any other body that manages personal data on behalf of the data controller;

5. ״recipient”: is a natural or legal person, a public authority, agency or any other body with whom or with which personal data is communicated, whether or not it is a third party. Public authorities which have access to personal data in an individual investigation in accordance with Union or national law shall not be considered recipients; the management of those data by those public authorities must comply with the applicable data protection rules in accordance with the purposes of data management;

6. ״the contributor concerned”: a voluntary, specific and appropriate informed and explicit statement of the will of the person concerned by which he or she expresses the statement or confirmation by means of an inadvertent act of affirmation that he or she has consented to the processing of personal data concerning him or her;

7. ״dataprotection incident”: a security breach resulting in accidental or unlawful destruction, loss, alteration, unauthorized disclosure or unauthorized access to personal data transmitted, stored or otherwise treated.

The principles of personal data management

The personal data:

a) must be legally and fairly handled and transparent to the person concerned ("lawfulness, fairness and transparency");

b) are collected for specified, clear and legitimate purposes and are not treated in a manner incompatible with these purposes; in accordance with Article 89 (1), no further data handling ("end-use") for purposes of public interest archiving for scientific and historical research purposes or for statistical purposes shall not be considered incompatible with the original purpose;

c) must be appropriate and relevant to the purposes of data management and should be limited to the need ("saving of the data");

d) must be accurate and, if necessary, up-to-date; all reasonable measures must be taken to correct or correct inaccurate personal data for the purposes of data management ("accuracy");

e) must be stored in a form which permits the identification of the data subjects only for the time needed to manage the personal data; the retention of personal data may only take place if the personal data are processed in accordance with Article 89 (1) for public interest archiving, for scientific and historical research purposes or for statistical purposes, in accordance with the rights and subject to appropriate technical and organizational measures for the protection of their freedoms ("limited storage");

f) shall be managed in such a way as to ensure adequate security of personal data, including the protection against unauthorized, unlawful, unintentional, loss or destruction of data ("integrity and confidentiality") by means of appropriate technical or organizational measures.

The data processor is responsible for the above, and must be able to demonstrate compliance ("accountability").

The Data Controller declares that data management is carried out in accordance with the principles set out in this section.

Data managementsContact

1. Fact of data collection, the range of managed data and the aim of data management:

Personal data

The purpose of data management

Legal basis

Name

Identification.

Article 6 (1) (a) (b) and (c).

Email address

Necessary to keep in touch.

Telephone

Required for contact, purchase, and billing.

Content of the message

It is neccessary for answering.

Date of contact

The fulfillment of techincal operation.

IP address at the time of contact

The fulfillment of techincal operation.

Neither the username nor the email address is required to be personal contain data.

2. Range of Customers: All those who send message using the contact form on the website.

3. Time of data handling, deadline for data deletion: If any of the conditions set out in Article 17 (1) of the GDPR exists, it shall continue until the request for cancellation by the data subject.

4. Possible data managers entitled to know the data, the recipients of personal data: Personal data may be handled by authorized personnel of the Data Controller in accordance with this Prospectus.

5. Describe the rights of data subjects involved in data management:

• The data subject may request from the controller access, rectification, erasure or restriction of the personal data relating to him or her, and

• the data subject has the right to data storage and the withdrawal of consent at any time.

6. It is possible to initiate, delete, modify or restrict access to personal data, transferability of data, and objection to data processing in the following ways:

- By post at the address: 2310 Szigetszentmiklós, Gyártelep 12001/33 hrsz

- Via e-mail: This email address is being protected from spambots. You need JavaScript enabled to view it. and This email address is being protected from spambots. You need JavaScript enabled to view it.

- On telephone: +36 (20) 250-7190

7. Legal basis for data processing: the consent of the data subject, Article 6 (1) (a),

(b) and (c). If you contact us, you agree that we will treat your personal information (name, phone number, email address) as provided in this Policy.

8. We inform you that:

This data management is based on your consentor is based on a legal obligation(co-operation) required for the submission of a contractor a

contractual relationship.

• Data management is necessaryfor you to get in contact with us

• Failure to provide data has the consequencesthat you can not get in contact with the Service Provider

• Withdrawal of consent does not affect the legality of the consent-based prerevocation data management.

CUSTOMER RELATIONSHIPS

1. The fact of data collection, the range of data processed and the purpose of data management:

Personal data

The purpose of data management

Legal basis

Name, email address, phone number.

Contact, identification, fulfillment of contracts, business purpose.

6 (1) (b) and (c), in the case of enforcement of claims arising from the contract, Act V of 2013 on the Civil Code 6:21. § cent

2. Range of affecteds: All those involved in contact with the data controller by phone / e-mail / personally or in a contractual relationship.

3. Duration of data management, deadline for deletion of data: The letters containing the requests will last until the request for cancellation of the data subject, but for a maximum of 2 years.

4. Persons authorized to access the data and the recipients of the personal data: The personal data may be handled by authorized personnel of the data controller, while respecting the above principles.

5. Describe the rights of data subjects involved in data management:

• The data subject may request from the controller access, rectification, erasure or restriction of the personal data relating to him or her, and

• the data subject has the right to data storage and the withdrawal of consent at any time.

6. It is possible to initiate, delete, modify or restrict access to personal data, transferability of data, and objection to data processing in the following

ways:

- By post at the address: 2310 Szigetszentmiklós, Gyártelep 12001/33 hrsz

- Via e-mail: This email address is being protected from spambots. You need JavaScript enabled to view it. and This email address is being protected from spambots. You need JavaScript enabled to view it.

- On telephone: +36 (20) 250-7190

7. Legal basis for data processing:

8. We inform you that:

Data management is necessary for the performance of the contract and forgiving offers.

• You mustprovide personal information so we are able to fulfill the contract and the vendor is able to send an offer

• Failure to provide data has the consequencesthat the selected vendor is not going to be able to send You personalized offer and we can not fulfill the contract

Newsletter, DM activity

1. According to § 6 of Act XLVIII of 2008 on the fundamental conditions of economic advertising activity the Customer may give consent in advance to the Service Provider for sending him/her advertisement and other consignment via the addresses given at registration.

2. Furthermore, the Customer may give consent to the Service Provider for managing the personal data for sending advertisements bearing in mind the regulations of the present guide.

3. Service Provider sends no unwanted advertisement and the Customer has the option to unsubscribe the sending of advertisements without any limitations and justification. In such case the Service Provider deletes every information - required for sending the messages - from the register and sends no further offers. Customer can unsubscribe the sending of advertisement by clicking on the link in the message.

4. The fact of data collection, range of managed data and the aim of datamanagement:

Personal data

Aim of data management

Claim

Name, e-mail address.

Identification, admit of subscription on the newsletter.

The consent of the data subject,

Article 6 (1) (a). XLVIII. Section 6 (5) of the Act on the basic conditions and certain limitations of the economic advertising activity.

Date of subscription

The fulfillment of technical operation.

IP address at the time of subscription

The fulfillment of technical operation.

5. The range of customers: All Customers subscribing for the newsletter.

6. The aim of data collection: sending electronic messages (e-mail, sms, push notification) containing advertisements to the Customer giving information on actual products, discounts, new functions, etc.

7. The time period of data management and the deadline of deletion of data: until the withdrawal of the consent, i.e. unsubscribing from the newsletter.

8. The potential data managers entitled to know the data, the recipients of personal data: Personal data can be managed by the sales and marketing staff of the data manager in respect for the above principles.

9. Describe the rights of data subjects involved in data management:

• The data subject may apply to the data controller for access to, correction, deletion or limitation of the personal data concerning him or her, and

• may object to the handling of such personal data as well

• the data subject has the right to data storage and to withdraw the consent at any time.

10. It is possible to initiate, delete, modify or restrict access to personal data, transferability of data, and objection to data processing in the following ways:

- By post at the address: 2310 Szigetszentmiklós, Gyártelep 12001/33 hrsz

- Via e-mail: This email address is being protected from spambots. You need JavaScript enabled to view it. and This email address is being protected from spambots. You need JavaScript enabled to view it.

- On telephone: +36 (20) 250-7190

11. The users are free to unsubscribe from the newsletters at any time, with no cost.

12. We inform you that:

Data management is based on your consent and the legitimate interest ofthe service provider.

•    You mustprovide personal information so that we can send you newsletter.

•    Failure to provide data has the consequencesof not being able to send you newsletter.

• We will inform you that you can withdraw your consent at any time by clicking on unsubscribe.

• Withdrawal of consent does not affect the legality of the prerevocation data management based on consent.

Application for events and other data managements related to events

1. The fact of data collection, the range of data processed and the purpose of data management:

Personal data

The purpose of data management

Common goal

Legal basis

Name

Identification.

Registration of candidates, participants, differentiation, fulfillment of orders, provision of discounts, documentation of purchase and payment, fulfillment of accounting obligations, keeping contact, analyzing customer habits, more targeted service.

6 (1) (b) of the GDPR

Telephone

Contacts, consultation

6 (1) (b) of the GDPR

E-mail address

Keeping in touch to send the information.

6 (1) (b) of the GDPR

Billing name and address

Issuing a regular invoice, creating a contract, defining its content, modifying it, monitoring its performance, billing the fees, and enforcing related claims.

Article 6 (1) (c) and Article 169 (2) of Act C of 2000 on Accounting.

Audio and video recordings of participants at events

Provision of reference material.

Article 6 (1) (a) of the GDPR by giving its consent to the event by entering the event.

Date of application

The fulfillment of technical operation.

6 (1) (b) of the GDPR

IP address at the time of application

The fulfillment of technical operation.

6 (1) (b) of the GDPR

The e-mail address does not need to contain any personal information.

2. Range of affecteds: All those applying for the event.

3. Duration of data management, deadline for deletion of data:

3.1. Data management lasts until the end of the event.

3.2. If any of the conditions set out in Article 17 (1) of the GDPR exists, it shall continue until the request for cancellation by the data subject.

3.3. The controller shall inform the data subject electronically of the deletion of any personal data provided by the data subject pursuant to Article 19 of the GDPR. If the data subject's cancellation request also covers the e-mail address given by him / her, the data manager will also delete the e-mail address after the notification.

4. Persons authorized to access the data and the recipients of the personal data:

4.1. The personal data may be handled by authorized personnel of the data controller, while respecting the above principles.

4.2. In the event of disclosure, the recordings made at the events may appear on the websites of the data controller, on social sites, in the copyright works published by him.

5. Describe the rights of data subjects involved in data management:

• The data subject may request from the controller access, rectification, erasure or restriction of the personal data relating to him or her, and

• the data subject has the right to data storage and the withdrawal of consent at any time.

6. It is possible to initiate, delete, modify or restrict access to personal data, transferability of data, and objection to data processing in the following ways:

- By post at the address: 2310 Szigetszentmiklós, Gyártelep 12001/33 hrsz

- Via e-mail: This email address is being protected from spambots. You need JavaScript enabled to view it. and This email address is being protected from spambots. You need JavaScript enabled to view it.

- On telephone: +36 (20) 250-7190

7. We inform you that:

Data management is necessary for the performance of the contract and for applications.

• You mustprovide personal information to apply for an event

• Failure to provide data has the consequencesthat you can not apply for an event

Addresses with whom personal data is communicated with

״Recipient": any natural or legal person, public authority, agency or any other body with which personal data are disclosed, whether or not a third party is involved.

Data processors (who perform data management on behalf of the data controller)

The Data Controller uses data processors to facilitate its own data management activities and to fulfill its obligations under contract or legislation.

The Data Controller places great emphasis on using only data processors who either provide adequate guarantees to implement data management in compliance with GDPR requirements and to ensure adequate technical and organizational measures to protect the rights of stakeholders.

The data processor and any person acting under the control of the controller or the data processor who has access to personal data shall treat the personal data contained in these regulations only in accordance with the instructions of the data controller.

The controller is responsible for the data processing activities. The data processor is only liable for damages caused by data management if he or she has not complied with the obligations specified in the GDPR specifically for processors, or if the data controller has ignored or acted contrary to the lawful instructions of the data controller.

There is no substantive decision-making on data processing by the data processor.

Each data processors

Data processing activities

Name

Addresscontact

Accountant

Joshua Accounting Kft.

2310 Szigetszentmiklós, Gyártelep hrsz. 12001/33.

Marketing

Dr. Császi András István EV

1221 Budapest, Arany János utca 7.

IT

Natur-IT Kft.

1211 Budapest, Kossuth Lajos utca 26. földszint 1.

Use of Cookies

1. The fact of data handling, the range of data processed: Unique identification number, times, dates.

2. The range of customers: Everybody who visits the website.

3. Aim of data management: Identify users and track visitors.

4. Term of data management, deadline for deletion of data:

Type of cookie

Legal basis of data management

Time of data management

Managed data

Session cookies

CVIII of 2001 on Certain Issues of Electronic Commerce Services and Information Society Services (Elkertv.) 13 / A. (3)

Until the end of the relevant visitor session

connect.sid

Permanent or saved cookies

CVIII of 2001 on Certain Issues of Electronic Commerce Services and Information Society Services (Elkertv.) 13 / A. (3)

Until the deletion of the affected person

 

Statistics cookies

CVIII of 2001 on Certain Issues of Electronic Commerce Services and Information Society Services (Elkertv.) 13 / A. (3)

1 month - 2 years

 

5. The potential data managers entitled to know the data: With the use of cookies the service provider does not manage personal data.

6. Giving information on the rights of the Customers related to data management: Customers can delete cookies in the Tools/Settings menu of the browser generally at the menu item Data protection.

7. Legal basis of data management: No consent is required if the sole purpose of the use of cookies is the communication service provided through the electronic communications network or the provision of information society services expressly requested by the subscriber or user.

8. Most browsers that our users use allow you to set which cookies to save and allow (specified) cookies to be deleted again. If you restrict or save third-party cookies on specific websites, this may in some circumstances result in our website not being fully usable. Here is information on how to customize cookie settings for standard browsers:

Google Chrome (https://support.google.com/chrome/answer/95647?hl=hu)

Internet Explorer (https://support.microsoft.com/hu-hu/help/17442/windows-internet-explorer-delete-manage-cookies)

Firefox (https://support.mozilla.org/hu/kb/sutik-engedelyezese-es-tiltasa-amit-weboldak-haszn

Safari (https://support.apple.com/kb/PH21411?locale=hu_HU)

The use of google and facebook services

Using the google ads conversion tracking

1. The online advertising program called "Google AdWords" is used by the data handler and uses the Google conversion tracking feature within its framework. Google conversion tracking is Google Inc.'s analytics service (1600 Amphitheater Parkway, Mountain View, CA 94043, USA; "Google").

2. When a User accesses a web site through a Google Ad, a conversion tracking cookie is placed on your computer. These cookies have limited validity and do not contain any personal information, so the User can not be identified by them.

3. When the User browses on certain pages of the website and the cookie has not expired, Google and the Data Manager will also see that the User clicked on the ad.

4. Each Google AdWords customer receives a different cookie so that they can not be tracked through AdWords clients' websites.

5. The information you receive through conversion tracking cookies is intended to make conversion statistics for your AdWords conversion tracking customers. Customers will then be informed about the number of users who have been submitted to their ad and click on a conversion tracking tag. However, they do not have access to information that could identify any user.

6. If you do not want to participate in conversion tracking, you can disable this by blocking cookies from being installed on your browser. Then you will not be included in conversion tracking statistics.

7. For more information and Google Privacy Statement, visit: www.google.de/policies/privacy/

The service of Google Analytics

1. This website uses the service of Google Analytics, which is the webanalyser service of the Google Inc. (״Google”). The Google Analytics uses so called ״cookies”, textiles, which are saved on your computer, and they help the analysis of the website usage of the Users.

2. The cookies of the websites which were visited by the User and their connecting informations are sent and stored on one of the Google’s servers in the USA. With the activation of the IP-anonymisation on the websites the Google can shorten the time of the IP-anonymisation of the Users in the European Union or in the member states of the European Economic Region.

3. Only in unique cases the full IP-addresses are sent to the servers of Google in the USA and they get shorten there. Operators of these websites commit the Google to use these informations for interpretations about the usage of the website, furthermore to create reports about the activity of the website, and to do their website and internet usage related duties.

4. In the Google Analytics, the forwarded IP-address of the Users will not be matched with others data by the Google. The store of the cookies can be prevented in the settings of the web browsers, but in this way it can happen, if some features of the websites will not work. You can prevent Google from collecting datas about the website usage habits of the users (including IP-addresses too), if you download and setup this web browser plugin. https://tools.google.com/dlpage/gaoptout?hl=hu

Facebook pixel

1. The Facebook Pixel is a code that is used to report on conversions on the website, to set up target audiences, and to provide the site owner with detailed analysis of the use of the website. With Facebook remarketing pixel tracking code, visitors can display customized offers and ads on the Facebook interface. The Facebook remarketing list is not suitable for personal identification. For more information about Facebook Pixel / Facebook pixels, please visit: https://www.facebook.com/business/help/651294705016616

Social websites

1. The fact of data collection, range of managed data: name and public profile image of the    Customer    registered    at

Facebook/Google+/Twitter/Pinterest/YouTube/Instagram etc.

2. The range of customers:    All Customers registered at Facebook/Google+/Twitter/Pinterest/YouTube/Instagram etc. and gave like to the website.

3. Purpose of the data collection: To share, or "like”, promote certain content elements, products, actions of the web site or the website itself on social networking sites.

4. Duration of data processing, deadline for deletion of data, person of possible data controllers who are able to know the data and details of the data management rights of the data subjects: Information about the source, their handling, the method of transfer and the legal basis of the data can be consulted on the given social networking site. Data management takes place on social networking sites, so the duration of the data handling, the ways of deleting and modifying the data are governed by the rules of the respective community site.

5. Legal base of data management: voluntary consent of the Customer for the management of personal data at community sites.

Customer services and other data management

1. If you have question during using some of the services of the data processor, or the customer has some problem you can get in contact with the data processer on the website (on phone, e-mail, community sites, etc.).

2. The data processer deletes the incoming e-mails, messages, on phone, on any community site, etc. what contains the name and e-mail address or any other given personal information of the customer, after 2 years from the start of the service.

3. We give information about the privacy policy which is not in this guide at the start of the service.

4. For exceptional magisterial request, or in case of law accumulation the service provider is bound for guidance, information providing, transferring, or making documents available for these organisation.

5. In these cases the service provider only gives personal informations for the request (if they pointed out the exact aim and the necessary informations) what are essentials for the aim of the request.

Customer rights

1. The right of access

You are entitled to receive feedback from the data controller about whether your personal data is being processed and, if such processing is in progress, you have the right to have access to your personal information and the information listed in the decree.

2. The right of rectification

You are entitled to request the data controller to rectify any inaccurate personal information that he or she is required to do without undue delay. Taking into account the purpose of data management, you are entitled to request the supplementation of incomplete personal data, including by means of a supplementary statement.

3. The right to cancel

You are entitled to request that the data controller, without undue delay, disclose personal information about you, and that the data controller is obliged to delete personal information about you, without undue delay, under certain conditions.

4. The right to be forgiven

If the data controller has disclosed the personal data and is required to cancel it, taking reasonable steps, including technical measures, to take into account the cost of available technology and implementation, in order to inform the data controllers handling the data that you have applied for the personal data in question pointing links or deleting a duplicate or duplicate of these personal data.

5.    The right to restrict data management

You are entitled to request that your data controller restricts your data handling if one of the following conditions is met:

•    You dispute the accuracy of your personal data; in this case, the restriction applies to the period of time that the data controller can check the accuracy of personal data;

•    Data handling is illegal and you are opposed to the deletion of data and instead asks you to restrict them;

•    The data controller no longer needs personal data for data processing, but you require them to submit, enforce, or protect legal claims;

•    You have objected to data manipulation; in this case, the restriction applies to the period when it is established that the legitimate reasons for the data controller have priority over your legitimate reasons.

6. The right to data storage

You are entitled to receive personal data that is made available to you by a data controller in a fragmented, widely used machine-readable format and is entitled to transfer this data to another data controller without this being obstructed by the data controller whose provided personal information to you (... )

7. The right ro protest

You are entitled to object to the handling of your personal information (...), including profiling based on these provisions, for any reason relating to your own situation.

8. Protest in case of direct business acquisition

If your personal data is handled for direct business, you are entitled to protest at any time against the handling of personal data relating to it, including profiling, if it is related to direct business acquisition. If you object to personal data being handled for direct business purposes, your personal information can no longer be handled for that purpose.

9. Automated decision-making in individual cases, including profiling

You are entitled to exclude the scope of any decision based solely on automated data handling, including profiling, which would have a bearing on it or affect it significantly. The preceding paragraph shall not apply if the decision is:

• You are required to conclude or complete a contract between you and the data controller;

• the granting of the right to a data controller is subject to the law of the Union or of the Member States which also lays down appropriate measures to protect your rights and freedoms and legitimate interests; or

• you are based on your explicit consent.

Deadline for action

The data controller informs you of any measures taken in response to these requests without undue delay but in any way within 1 month of receipt of the request.

If necessary, it may be extended by 2 months. The controller will inform you about the extension of the deadline by indicating the cause of the delay within 1 month of receipt of the request.

If the data controller fails to take action upon your request, he or she will notify you without delay and at the latest within one month of the receipt of the request for

reasons of non-action and whether you may file a complaint with a supervisory authority and exercise its right of appeal.

Security of data management

The data controller and the data processor shall take appropriate technical and organizational measures to take into account the state of science and technology and the costs of implementation, the nature, scope, circumstances and objectives of data management and the risk of varying probability and severity of natural persons' rights and freedoms to guarantee an adequate level of data security, including, inter alia, where appropriate:

a) the pseudonymization and encryption of personal data;

(b) ensuring, maintaining, integrity, availability and resilience of the continuing confidentiality of systems and services used to manage personal data;

(c) in the case of a physical or technical incident, the ability to restore access to personal data and the availability of data in good time;

(d) the procedure for systematic testing, assessment and evaluation of the effectiveness of technical and organizational measures taken to ensure the security of data processing.

e) The data processed must be stored in such a way as to prevent unauthorized access. In the case of paper-based data carriers, by establishing the order of physical storage, filing, and using the central authorization system for data processed in electronic form.

f) The method of storing the data using the IT method must be chosen so that it can be deleted at the end of the period for deletion of data, or if it is necessary for other reasons, subject to a different cancellation deadline. The deletion must be irreversible.

(g) Paper-based media shall be deprived of personal data by means of a document shredder or by an external document destruction organization. In the case of electronic data carriers, physical destruction shall be ensured in accordance with the rules on the disposal of electronic media and, where necessary, the safe and irrevocable deletion of data shall be made in advance.

h) The data controller will take the following specific data security measures:

a. In order to ensure the security of personal data handled on paper, the Service Provider applies the following measures (physical protection):

i. Place documents in a secure, lockable dry room.

ii. The Service Provider's building and premises are equipped with fire protection and property protection equipment.

iii. Personal data may only be accessed by authorized persons and not accessible to third parties.

iv. In the course of his work, the Service Provider's employee may only leave the room where data is being processed, to block the media entrusted to him or to close the room.

v. If digitization of paper-based personal data is done, the rules governing digitally stored documents should apply.

b. IT protection

i.    Computers and mobile devices (other media) used in data management are the property of the Service Provider.

ii.    Data on computers can only be accessed with a username and password.

iii.    Access to the central server machine is only granted with the appropriate authority and only by designated persons.

iv.    For security of digitally stored data, the Service Provider uses data backups and archives.

v.    A computer system containing personal data that is useful to the Service Provider is provided with virus protection.

vi.    SSL encryption.

INFORMING THE PERSON CONCERNED ABOUT THE PRIVACY INCIDENT

If the privacy incident is likely to pose a high risk to the rights and freedoms of natural persons, the data controller shall inform the data subject of the privacy incident without undue delay.

Information given to the data subject should be clearly and easily understood and the nature of the privacy incident must be disclosed and the name and contact details of the Data Protection Officer or other contact person providing additional information should be disclosed; the likely consequences of a data protection incident should be described; describe measures taken or planned by the data controller to remedy a data protection incident, including, where appropriate, measures to mitigate any adverse consequences of a data protection incident.

The person concerned shall not be informed if any of the following conditions are met:

• the data controller has implemented appropriate technical and organizational protection measures and applied these measures to the data covered by the data protection incident, in particular the measures, such as the use of encryption, which make it impossible for persons who are unauthorized to access personal data the data;

• after the data protection incident, the data controller has taken further measures to ensure that high risk for the rights and freedoms of the person concerned is no longer likely to be realized;

• Informing would require disproportionate efforts. In such cases, the data subject shall be informed by means of publicly disclosed information or a similar measure shall be taken to ensure that such information is equally effective.

If the data controller has not yet notified the data subject of the data protection incident, the supervisory authority may, after considering whether the privacy incident is likely to pose a high risk, may inform the data subject.

REPORTING A PRIVACY INCIDENT TO THE AUTHORITY

The data protection incident shall be reported to the supervisory authority under Article 55 without undue delay and, if possible, no later than 72 hours after the data protection incident becomes known, unless the data protection incident is unlikely to pose a risk to the rights of natural persons and freedom. If the notification is not filed within 72 hours, the reasons for proving the delay must also be enclosed.

REVIEW FOR MANDATORY DATA MANAGEMENT

If the period of mandatory data management or the periodic review of its necessity is not specified by law, local government regulation or a binding act of the European Union, the controller shall review at least every three years from the commencement of the data processing that it or the processor acting on its behalf or on its instructions and if the personal data management is necessary for the purpose of data management.

The circumstances and results of this review shall be documented by the Data Controller, and shall be retained for a period of ten years after the review has been conducted and made available to the Authority at the request of the National Authority for Data Protection and Freedom of Information (hereinafter referred to as the Authority).

Complaint opportunity

Complaint regarding the possible breaching of the law by the data manager can be made to the Hungarian National Authority for Data Protection and Freedom of Information:

Hungarian National Authority for Data Protection and Freedom of Information

1125 Budapest, Szilágyi Erzsébet fasor 22/C.

Mailing address: 1530 Budapest, P.O.Box: 5.

Telephone: +36 -1-391-1400 Fax: +36-1-391-1410 E-mail: This email address is being protected from spambots. You need JavaScript enabled to view it.

Closing remarks

The following regulations were accounted in the course of composing the guide:

-    REGULATION (EEC) No 2016/67 OF THE EUROPEAN PARLIAMENT AND OF THE

COUNCIL (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

-    2011 CXII. Law on information self-determination and freedom of information (hereinafter: Infotv.)

- Act CVIII of 2001 - Act on Electronic Commerce and Information Society Services (especially Section 13 / A)

- Act XLVII of 2008 - Act on the Prohibition of Unfair Commercial Practices against Consumers;

- Act XLVIII. Of 2008 - the basic conditions and certain limitations of economic advertising activity (in particular Article 6)

- XC. Law of 2005 on Eletronic Freedom of Information

- Act C of 2003 on Electronic Communications (specifically Article 155)

- No. 16/2011. an opinion on the EASA / IAB Recommendation on Best Practice in Behavioral Online Advertising

- Recommendation of the National Data Protection and Information Authority on the data protection requirements for prior information

23

Personal data The purpose of data
management
Common goal Legal basis
Name Identification. Registration of
candidates,
participants,
differentiation,
fulfillment of
orders,
provision of
discounts,
documentation
of purchase and
payment,
fulfillment of
accounting
obligations,
keeping
contact,
analyzing
customer
habits, more
targeted
service.
6 (1) (b) of the
GDPR
Telephone Contacts, consultation 6 (1) (b) of the
GDPR
E-mail address Keeping in touch to
send the information.
6 (1) (b) of the
GDPR
Billing name and
address
Issuing a regular
invoice, creating a
contract, defining its
content, modifying it,
monitoring its
performance, billing the
fees, and enforcing
related claims.
Article 6 (1) (c)
and Article 169 (2)
of Act C of 2000 on
Accounting.
Audio and video
recordings of
participants at events
Provision of reference
material.
Article 6 (1) (a) of
the GDPR by giving
its consent to the
event by entering
the event.
Date of application The fulfillment of
technical operation.
6 (1) (b) of the
GDPR
IP address at the
time of application
The fulfillment of
technical operation.
6 (1) (b) of the
GDPR