DATA PROTECTION POLICY
Effective from [May] 2020
This purpose of this data protection policy (“Policy”) is to provide prior and understandable information with respect to the processing of personal data carried out on the website called (“Website”) operated by Q&C Magyarország Korlátolt Felelősségű Társaság (registered seat: 2100 Gödöllő, Köztársaság u. 30.), as data controller (“Data Controller”).
Data Controller and its contact details
Name of the Data Controller: Q&C Magyarország Korlátolt Felelősségű Társaság
Registered office: 2100 Gödöllő, Köztársaság u. 30.
Postal address: 2100 Gödöllő, Köztársaság u. 30.
Registration number: 13-09-060340
Phone number: +36203555355
data control: shall mean any operation or set of operations that are performed upon data, whether or not by automatic means, such as in particular collection, recording, organization, separation, storage, adaptation or alteration, query, inspection, use, retrieval, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction;
data processor: shall mean a natural or legal person that is engaged in the processing of personal data in the name of the Data Controller or on the basis of engagement by the Data Controller;
personal data: shall mean any information relating to an identified or identifiable 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, online identification number or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
the data subject’s consent shall mean any freely and expressly given specific and informed indication of his/her wishes by which he or she, by a statement or by clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
restriction of data control shall mean the marking of stored personal data with the aim of limiting their control in the future;
a filing system shall mean any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis;
personal data breach shall mean a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed
3. Principles relating to the processing of personal data
The Data Controller shall be responsible for, and be able to demonstrate the compliance with the following principles.
(1) Lawfulness, fairness and transparency
The personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject;
(2) Purpose limitation
The personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes;
(3) Data minimisation
The personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed
The personal data shall be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay
(5) Storage limitation
The personal data shall 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 stored for longer periods insofar as the personal data will be processed solely 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 the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject.
(6) Integrity and confidentiality
The personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
5. Data processing, use of hosting provider
Data Controller uses the following hosting provider at the moment:
Name of the hosting provider: Amazon Web Services, Inc
Postal address of the hosting provider: 410 Terry Avenue North, Seattle, WA 98109-5210
Telephone number: +1-206-266-4064
E-mail address of the hosting provider: http://aws.amazon.com
6. Rights of the data subjects
A. THE DATA SUBJECT’S RIGHT TO INFORMATION
The Data Controller shall provide the data subject with the following information concerning the main characteristics of data processing which is the identity and the contact details of the Data Controller and of the Data Controller's representative; the purposes of the data control activities as well as the legal basis for the data control; the period for which the personal data will be stored; where the data control is based on balance of interest, the legitimate interests pursued by the Data Controller; the rights of the data subject in relation to the data processing, the right to lodge a complaint with the National Media and Infocommunications Authority and where the personal data are not collected from the data subject, any available information as to their source and to the categories of personal data concerned.
B. RIGHT OF ACCESS BY THE DATA SUBJECT
The data subject shall have the right to obtain from the Data Controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
the purposes of the data control;
categories of personal data concerned;
the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
the existence of the right to request from the Data Controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such data control;
the right to lodge a complaint with a supervisory authority;
where the personal data are not collected from the data subject, any available information as to their source;
the existence of automated decision-making, including profiling, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
C. RIGHT TO RECTIFICATION AND TO ERASURE
The data subject shall have the right to obtain from the Data Controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
The Data Controller shall have the obligation to erase personal data without undue delay upon the request of the data subject:
the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise controlled;
the data subject withdraws consent on which the data control is based and where there is no other legal ground for the data control;
the data subject objects to the data control and there are no overriding legitimate grounds for the processing or the data subject objects to the processing for direct marketing purposes;
the personal data have been unlawfully processed;
the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
the personal data have been collected in relation to the offer of information society services provided to children.
The Data Controller shall communicate any rectification or erasure of data control to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The Data Controller shall inform the data subject about those recipients if the data subject requests it.
D. RIGHT TO RESTRICTION OF DATA CONTROL
The Data Controller shall restrict the data control upon request of the data subject if:
the accuracy of the personal data is contested by the data subject, for a period enabling the Data Controller to verify the accuracy of the personal data;
the data control is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
the Data Controller no longer needs the personal data for the purposes of the data control, but they are required by the data subject for the establishment, exercise or defence of legal claims;
the data subject has objected to data control carried out on the basis of legitimate interest or public interest, the verification whether the legitimate grounds of the controller override those of the data subject.
The Data Controller shall communicate any restriction of data control to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The Data Controller shall inform the data subject about those recipients if the data subject requests it.
E. RIGHT TO DATA PORTABILITY
The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a Data Controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
the data control is based on consent or on a contract pursuant to the General Data Protection Regulation; and
the data control is carried out by automated means.
F. RIGHT TO OBJECT
The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to data control of personal data concerning him or her which is carried on the basis of legitimate interest or the public interest, including profiling based on those provisions. The Data Controller shall no longer process the personal data unless the Data Controller demonstrates compelling legitimate grounds for the data control which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
At the latest at the time of the first communication with the data subject, the right referred to above shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.
G. AUTOMATED DECISION MAKING IN INDIVIDUAL CASES, INCLUDING PROFILING
The Date subject shall have the right not to be affected by automated data collecting and decision making – including profiling- that would have a significant effect on the data subject, in such cases, the data controller must take necessary actions in order to defend the rights of te data subject.
The foregoing shall not apply where the decision:
Necessary for the conclusion or performance of a contract between you and the data controller;
If the data controller is allowed by EU or State laws, which also lays down appropriate measures to protect your rights and freedoms and legitimate interests; or
Is based on your explicit consent
Automated decision making and profiling are not done through the Website by the Data Controller.
7. Framework for the exercise of rights
The Data Controller, without any unjustified lateness, shall inform the data subject within a month about the legal actions carried out that he or she requested that are listed in Paragraph 6 hereof. If needed, considering the number and complexity of requests, the deadline can be extended by two months. In the case of the deadline extension, the data controller will inform the data subject within a month from the requests made. In case the requests were made electronically, the information will be conveyed in the same manner unless the date subject requires.
If the Data Controller does not take the necessary actions upon the data subject’s requests however informs the data subject, within a month, about the reason why the legal actions were not carried out or that the data subject can complain at the National Media and Infocommunications Authority.
8. Judicial remedies of the data subject
A. Right to lodge a complaint with a supervisory authority
Without prejudice to any other administrative or judicial remedy, you shall have the right to lodge a complaint with a supervisory authority, if you consider that the processing of your personal data infringes the provisions of GDPR.
Supervisory authority and its contact details:
National Media and Infocommunications Authority
1125 Budapest, Szilágyi Erzsébet fasor 22/C.
Tel: +36 1 391 1400
B. Right to an effective judicial remedy against a supervisory authority
Without prejudice to any other administrative or non-judicial remedy, you shall have the right to an effective judicial remedy against a legally binding decision of a supervisory authority concerning you. You shall have the right to an effective judicial remedy where the supervisory authority which is competent does not handle a complaint or does not inform the data subject within three months on the progress or outcome of the complaint lodged.
C. Right to an effective judicial remedy
Without prejudice to the right to lodge a complaint with a supervisory authority, you shall have the right to an effective judicial remedy where you consider that your rights under the GDPR have been infringed.
Proceedings against shall be brought before the courts of the Member State where the Data Controller has an establishment. If you do not have habitual residence in Hungary, you may bring the case before the courts of the Member State where you have your habitual residence.
The legal basis of the data control: Your consent based on Point a) Paragraph 1) of Article 6 of GDPR.
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10. Modification of the Policy
The Data Controller reserves the right to unilaterally modify this Policy. The modifications become effective when publishing them on the Website.