Data privacy

1. Name of Data Processor

Name of Data Processor: Wirecorner Informatikai Kft.

Company registration number of Data Processor: 01-09-979732

Registered seat of Data Processor: 1117 Budapest, Nádorliget utca 7/C, 5. em. 515.

Contact details of Data Processor:

Representative of Data Processor: Sándor Gintli, Managing director

2. Data protection regulations

This data protection policy shall be valid from 1 November 2014, until withdrawal.

Wirecorner Informatikai Kft. (hereinafter referred to as “Company”) processes personal data in relation to this interface on the basis of its Data Protection and Data Security Policy. The scope of the Policy covers all processes in all organisational units of the Company, during which personal data, as defined in point 2 of Section 3 of the Info Act, are processed.

The terms in the Policy are the same as the interpretative definitions in Section 3 of the Info Act.

Personal data may only be processed in order to exercise rights or fulfil obligations. The personal data processed by the Company must not be used for any private purpose. Data processing shall comply at all times with the principle of purpose limitation.

The Company processes personal data only for specific purposes in order to exercise rights and fulfil obligations, and to the minimum extent and for the period of time necessary for that purpose. Data processing shall in all stages conform to the purpose, and the data will be deleted if the purpose of the data processing has ceased or the processing of the data otherwise becomes unlawful.

The Company processes personal data only on the basis of the prior consent of the data subject or the authorisation of the law.

Before recording any data, the Company informs the data subject about the purpose of the data processing and the legal basis of the data processing in all cases.

The employees engaged in data processing at the Company’s organisational units and the employees of organisations involved in data processing under the Company’s assignment or performing any operation thereof shall keep as a business secret any personal information they come to know. The persons processing and authorised to access personal data shall make a privacy statement.

If any person subject to this policy becomes aware that any personal data processed by the Company is incorrect, incomplete or untimely, he/she is obliged to correct it or initiate the correction thereof at the staff member responsible for recording the data.

The data protection obligations applicable to national or legal persons or organisations lacking legal personality, who/which carry out data processing activities under the Company’s assignment are enforced in the assignment contract made with the data processor.

The Company’s managing director from time to time defines the organisation of data protection and the tasks and competences concerning data protection and the related activities, taking into account the specificities of the Company, and assigns the person overseeing data processing.

In carrying out their work, the Company’s staff ensures that no unauthorised persons access personal data, also that the personal data storage and placement of personal data are arranged in a manner to prevent access, insight, modification or destruction by any unauthorised persons.

The Company’s data protection system is supervised by the managing director via a person assigned or mandated by him, who is responsible for data protection.

3. Enforcing the rights of data subjects

The data subject may request information on or the correction of the processing of his/her personal data, and may request, except for cases when required to do so by legal provisions, the deletion of his/her personal data using the Company’s contact details above.

The Company will forward all applications and objections received to the head of the organisational unit competent for the purposes of data processing within three working days of receipt.

The head of the competent organisational unit will respond to the application of the data subject regarding the processing of his/her personal data in an easily understandable form in writing within 30 days or, in case the right to object is exercised, 15 days of receipt.

The response will cover the information under section 15(1) of the Info Act, provided that the information to the data subject may not be refused on the basis of the law.

As a rule, the information is free, and the Company will charge a fee only in the cases defined in Section 15(5) of the Info Act.

The Company refuses an application only for the reasons stated in Section 9(1) or Section 19 of the Info Act and stating the reasons thereof in writing, providing the information specified in Section 16(2) of the Info Act.

The head of the organisational unit processing the data will rectify any incorrect data if the correct data and the public documents supporting them are available or, in the cases foreseen in Section 17(2) of the Info Act, take action to delete the processed personal data.

The head of the organisational unit processing the data will suspend processing of the data for the period of judging the objection of the data subject against processing his/her personal data, but for no more than 5 days, examine the merits of the objection and take a decision, of which he/she informs the applicant in the manner set out in Section 21(2) of the Info Act.

If the objection is justified, the head of the organisational unit processing the data will act in accordance with Section 21(3) of the Info Act.

If, in exercising the rights of the data subject, the assessment of the case is not clear, the head of the organisational unit processing the data may send the documents of the case and his/her opinion to the internal data protection officer and seek his/her opinion, who shall respond within three days.

The Company is liable for any damage caused to a data subject as a result of unlawful processing or by any breach of data security requirements and will pay compensation to the data subject for the violation of any privacy rights by the Company or any data processor employed by it. The data processor may be exempted from liability for the damage caused and the obligation to pay the compensation if it is able to prove that the damage or the violation of privacy of the relevant personal data was brought about by an unavoidable cause outside the scope of data processing. Similarly, no compensation will be paid where the damage was caused by intentional or negligent conduct on the part of the data subject.

Data subjects may submit a complaint concerning the Company’s data processing procedures to the NAIH:

Name:                    Nemzeti Adatvédelmi és Információszabadság Hatóság (National Authority for Data Protection and Freedom of Information)

Registered seat:       1024 Budapest, Szilágyi Erzsébet fasor 22/C.


4. Data processing in relation to using the Company’s website

Location of data processing:

1134 Budapest, Róbert Károly krt. 64-66.

4.1. Data processing on the website

Anyone can access the Company’s website without disclosing his/her identity and personal data and obtain information from the website and the pages linked to it freely and without restriction. However, the website collects non-personalised information about the visitors indefinitely and automatically. Personal data cannot be obtained from these data, so it does not constitute data processing within the meaning of the Info Act.

The website uses the Web analytics service Google Analytics. Google Analytics uses “cookies”, that is, text files placed on the visitor’s computer, which are designed to assist in analysing the use of the website. The information concerning the use of the website generated by the cookies (IP address of the visitor of the website) is forwarded to and stored on the Google servers located in the United States of America. Google does not associate the information generated by the cookies with other information, therefore, it does not constitute processing of personal data under the current data protection legislation. The use of cookies can be refused by selecting the appropriate settings on the browser of the website visitor. By using this website, the visitor consents to processing his/her data in the manner and for the purposes set out above.

The above information is used by Google to evaluate and analyse your use of the website, compile reports about the activities carried out on the website and provide other services related to the activities carried out on the website and the use of the Internet.

4.2. Contact-related data processing

While visiting the website, the visitors have the possibility to contact us. When contacting us, the visitor discloses his/her name and e-mail address, on the basis of which the Company becomes aware of the incoming inquiries at the e-mail address.

The Company operates its own servers for storing the e-mail received to the Company’s addresses. The Company processes any personal data included in the emails only until the relevant purpose is achieved.

Data processing registration number: NAIH-81530/2014.

Purpose of data processing: Communication and contact with the Company

Scope of processed data: e-mail address, content and subject of the message, name and other personal data contained in the message

Legal basis of data processing: consent of the data subject under Section 5(1) of the Info Act

Time limit for data storage: until the purpose of the communication is achieved

Method of data storage: electronic

5. Matters not covered in this information

Matters not covered in this information are governed by the Info Act and the Company’s Data Protection and Data Security Policy.



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