This document contains all relevant data privacy information regarding the operation of the www.refactoring.hu website, pursuant to the Regulation 2016/679 EC on the General Data Protection Regulation (hereinafter: Regulation. GDPR) and Act CXII of 2011. (hereinafter: Infotv.)
You may contact us using the www.eutek.hu website. The contact initiated by You, as well as the data and information provided by You are governed by the GDPR as follows.
Name of Data Controller: Refactoring Fejlesztő, Innovációs és Szolgáltató Kft.
Registered seat: 1011 Budapest, Jégverem utca 2. 2/1.
Postal address: 1011 Budapest, Jégverem utca 2. 2/1.
HOSTING PROVIDER AND DATA PROCESSING
Name: Magyar Hosting Zrt.
Postal address: Budapest, Victor Hugo u. 18-22, 1132
E-mail address: firstname.lastname@example.org
Phone No.: +36 1 700 2323
What is Cookie?
Data Controller uses so-called cookies when visiting the website. Cookie is an information package consisting of letters and digits, that is sent by our website to your browser to save certain settings, support the use of our website and to contribute in the collection some relevant, statistical information on our visitors.
Some cookies do not contain personal information and are not suitable for the identification of individual users, however, some of them include such an individual ID (a secret, randomly generated sequence) on your device, which also ensures your identification. The operational duration of certain cookies are included in the respective description.
Legal background and basis of cookies:
The legal basis of the data processing is your consent pursuant to the Regulation Art. 6. (1) a).
Main features of the cookies used by the website:
- Internet Explorer: http://windows.microsoft.com/en-us/internet-explorer/delete-managecookies#ie=ie-11
- Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-yourcomputer
- Mozilla: https://support.mozilla.org/hu/kb/weboldalak-altal-elhelyezett-sutik-torlese-szamito
- Safari: https://support.apple.com/kb/ph21411?locale=en_US
- Chrome: https://support.google.com/chrome/answer/95647
Further Data Processing
If Data Controller wishes to perform additional data processing, then it shall provide prior notification on the substantial circumstances of the data processing (legal background and basis of data processing, purpose of data processing, period of data processing).
We inform You, that the written data requests from the authorities based on the law, shall be fulfilled by Data Controller. Data Controller manages record on the data transfers pursuant to Infotv. Section 15 (2)-(3). (for which authority, on what legal basis, when and what kind of personal data was transferred), and Data Controller shall provide information in this regard on request, except if the notification is prohibited by the law.
YOUR RIGHTS DURING DATA PROCESSING
Within the period of the data processing, You have the following rights:
- the right to withdraw the consent
- the right to personal data and information regarding data processing
- right to rectification
- right to restrict data processing, right to erasure
- right to object
- right to portability.
If You wish to exercise any of your rights, it includes your identification, and the Data Controller shall communicate with You. Therefore, in order to ensure the identification, provision of personal data will become necessary (however, the identification shall be based only on such data, that Data Controller processes on You anyway), and your complaint regarding the data processing will be available in the Data Controller’s e-mail account within the period determined on complaints in this information.
Data Controller shall reply on complaints regarding data processing latest within 30 days.
Right to Withdraw the Consent
You are entitled to withdraw your consent to data processing anytime, in such case we erase the provided data from our systems.
Access to Personal Data
You are entitled to receive feedback from the Data Controller in regards whether your data processing is in progress or not, and if the data processing is in progress, You are entitled to:
- get access to the processed personal data and get informed by the Data Controller on the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipient to whom the personal data have been or will be disclosed;
- proposed period of storing personal data, or if it is 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 You or to object to such processing;
- the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from You, 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 You.
The purpose of exercising the right may aim to determine and check the lawfulness of data processing, therefore, for any further copies requested by You, the Data Controller may charge a reasonable fee based on administrative costs
Data Controller ensures the access to personal data so, that following your identification, it sends You the processed personal data and information. If You have registration, then we provide access so, that by logging into your user account, You can view and check the personal data processed regarding You.
Please indicate in your request, whether You request access to your personal data, or information regarding data processing.
Right to Rectification
You have the right to obtain from the Data Controller without undue delay the rectification of inaccurate personal data concerning You.
Right to Restriction
You have the right to obtain from the Data Controller restriction of processing where one of the following applies:
- You contest the accuracy of the personal data, for a period enabling the Data Controller to verify the accuracy of the personal data, if the accurate data can be promptly determined, then no restriction is applied;
- the processing is unlawful and You oppose the erasure of the personal data for any reason (eg. because the data are important for You to enforce legal claims), therefore You do not request the erasure of the data, but the restriction of their use instead;
- Data Controller no longer needs the personal data for the purposes of the processing, but they are required by You for the establishment, exercise or defence of legal claims; or
- You have objected to processing, but data processing may be grounded by Data Controller’s legitimate interests, in this case, pending the verification whether the legitimate grounds of the controller override those of You, the data processing shall be restricted.
Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
Data Controller previously informs You on releasing the restriction (at least 3 business days prior to the release of the restriction).
Right to Erasure – ‘Right to be Forgotten’
You have the right to obtain from the Data Controller the erasure of personal data concerning You without undue delay, where one of the following grounds applies:
- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed by Data Controller;
- You withdraw your consent, and the data processing has no more legal basis;
- You object to the data processing based on legitimate interest, and there is no prevailing legitimate purpose (or legitimate interest) for data processing,
- the personal data have been unlawfully processed by Data Controller, and upon the complaint, it has been determined, that the personal data shall be erased to fulfil legal obligation provided by the Union or Member State laws applicable on the Data Controller.
Where the Data Controller has made the personal data public and is obliged to erase the personal data, the Data Controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that You have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
The erasure shall not be applied, if the data processing is necessary:
- for exercising the right of freedom of expression and information;
- for compliance with a legal obligation which requires processing by Union or Member State law, to which the Data Controller is subject (eg. data processing within invoicing, since the preservation of the invoice is required by the law), or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- for the establishment, exercise or defence of legal claims (eg. if Data Controller has claims against You, and it has not been fulfilled, or consumer, data processing claim is in progress).
Right to Object
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning You. In this event, Data Controller shall no longer process the personal data unless the Data Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of You or for the establishment, exercise or defence of legal claims.
Where personal data are processed for direct marketing purposes, You shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where You object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
Right to Portability
Where the data processing is achieved in an automated manner, or where the data processing is based on your voluntary consent, You have the right to request the Data Controller to receive the data provided by You to the Data Controller, which Data Controller provides You in sml, JSON or csv format, if it is technically possible, to request Data Controller to forward the data to another Data Controller in this form.
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning You or similarly significantly affects You. In these cases, Data Controller shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the Data Controller, to express your point of view and to contest the decision.
The above shall not be applied in the event if the decision:
- Is necessary to arrange and fulfil the Agreement between You and the Data Controller;
- it is enabled by such Union or Member State law applicable on the Data Controller, which also determines measures to protect your rights or freedom, and legitimate interest;
- or is based on your express consent.
Report into Data Privacy Records
Pursuant to the provisions of the Infotv., Data Controller shall report certain data processings to the Data Processing Register. This reporting obligation ceased on 25th May 2018.
Data Security Measures
Data Controller declares, that it has made appropriate security measures to protect personal data against unauthorized access, alteration, transfer, disclosure, erasure or destruction, and accidental destruction or damage, and becoming inaccessible due to the change of the applied technology.
Data Controller shall make its best efforts according to its organizational and technical opportunities to make their Data Processors appropriate data security measures, when processing your personal data.
If You suppose that the Data Controller infringed any legal provision of law, or failed to fulfil your request, then, in order to cease the unlawful data processing, may initiate the procedure of Nemzeti Adatvédelmi és Információszabadság Hatóság (National Data Protection and Information Freedom Authority) (postal address: 1530 Budapest, Pf.: 5., email: email@example.com).
We also inform You that in the event of infringing the provisions of law regarding data processing, or if Data Controller failed to fulfil any of its requests, then You may initiate a Court proceeding against Data Controller.
Where Data Controller intends to further process the personal data for a purpose other than that for which the personal data were collected, Data Controller shall provide You prior to that further processing with information on that other purpose and with any relevant further information:
- the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period;
- the existence of the right to request from the Data Controller access to and rectification or erasure of personal data or restriction of processing concerning You or to object to processing of personal data, and in the event of data processing on the basis of consent or contractual relationship, may request to ensure the right to data portability;
- where the processing is based on consent, the existence of the right to withdraw consent at any time,
- the right to lodge a complaint with a supervisory authority;
- whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether You are obliged to provide the personal data and of the possible consequences of failure to provide such data;
- 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 You.
Data Processing may begin only following your consent, provided that the legal grounds for data processing is consent, You also have to consent to the data processing in addition to being informed.