Privacy Policy
Introduction
Privacy Policy and Information Notice
As the data controller, Sämling Vállalatfejlesztés Kft. acknowledges the contents of this legal notice as binding on itself. Sämling Vállalatfejlesztés Kft. is committed to protecting the personal data of visitors to its website and attaches great importance to respecting the users' right to information self-determination.
Sämling Vállalatfejlesztés Kft.
(Tax Nr. 10595624243, Reg.Nr. 01 09 078837,
Address: Hungary - 1124 Budapest, Németvölgyi Str. 64.), hereinafter referred to as the Data Controller Service Provider, acknowledges the contents of this policy and information as binding upon itself.
The person responsible for the contents of the DATA MANAGEMENT RULES AND INFORMATION SHEET is István Ecsédi, Managing Director.
Scope of the
Privacy Policy and Information Notice
The scope of this Policy and Information Notice covers the processing of data on the website operated by the Service Provider and the processing of data that comes to its knowledge in the course of providing training and consultancy services.
Effective date: 25th May 2018.
The Service Provider undertakes to ensure that the processing of data related to its services complies with the provisions set out in this Policy and the applicable legislation, and that the provisions of the Policy and the Information Notice are in compliance with the applicable Hungarian and European legislation, including, in particular, the Hungarian Act on the Right to Information Self-Determination and Freedom of Information of 2011. CXII of 2013 (hereinafter: Info tv.), Act V of 2013 on the Civil Code (hereinafter: Ptk.), and the data management provisions take into account the provisions of the General Data Protection Regulation of the European Union (hereinafter: Regulation)
The Service Provider may unilaterally modify this Privacy Policy and this Privacy Notice. The Service Provider shall inform the data subjects of any amendment to the Policy by means of a written notice.
DATA PROCESSING POLICY
Principles and legal basis
of data processing
The data processing principles of the Service Provider are in accordance with the applicable legislation on data protection:
- REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 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/EC (General Data Protection Regulation).
- Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information.
- Act CVIII of 2001 on certain aspects of electronic commerce services and information society services.
- Act C of 2003 on Electronic Communications.
- Act XLVIII of 2008 - on the basic conditions and certain restrictions of economic advertising activities.
- Act LXVI of 1992 on the Registration of Personal Data and Addresses of Citizens (hereinafter Nytv.),
- Act CXIX of 1995 on the processing of name and address data for the purposes of research and direct marketing.
- Act LXXVII of 2013 on Adult Education
- Act V of 2013 on the Civil Code
- and any other legislation containing mandatory applicable data processing provisions.
Data security:
- The Service Provider shall take all organizational and technical measures to ensure the highest level of security of personal data, with particular attention to the prevention of unauthorized alteration, destruction and use of data.
- The Service Provider shall take all necessary measures to ensure data integrity and the accuracy, completeness and up-to-date status of the personal data it handles and/or processes.
- The Service Provider shall take appropriate measures to protect the data, in particular against unauthorised access, alteration, disclosure, disclosure, erasure or destruction.
Data management:
Personal data may be processed if
- a) with the consent of the data subject; or
- (b) it is required by law or by an ordinance of a local authority, empowered by law within the scope specified therein. Special categories of data may be processed if the data subject consents in writing or if the processing is ordered by law.
Personal data may be processed only for specified purposes, for the exercise of a right or the performance of an obligation. The processing must comply with this purpose at all stages.
Only personal data which is necessary for the purpose of the processing, which is adequate for the purpose, to the extent and for the duration necessary for the purposes of the processing, may be processed. Personal data may only be processed with informed consent. The data subject shall be informed in a clear, plain and detailed manner of all the facts relating to the processing of his or her data, in particular the purposes and legal basis of the processing, the identity of the controller and processor, the duration of the processing and the persons who may access the data. The information shall also cover the rights and remedies of the data subject with regard to the processing. The personal data processed must comply with the following requirements:
- (a) their collection and processing must be fair and lawful;
- (b) accurate, complete and, where necessary, kept up to date;
- (c) they are stored in a manner which ensures that the data subject can be identified only for the time necessary for the purposes for which they are stored.
The personal data of the data subjects (i.e. data that can be associated with the person of the customer) may be processed by the Service Provider in four ways:
- automatically, in the context of maintaining the Internet connection, the computer, browser program, Internet address, technical data relating to the pages visited, used by the user who visits the website,
- the user can also provide his/her name, contact details or other data if he/she wishes to contact the Service Provider personally when using our website, so that they can be made available to him/her,
- the user may also provide his/her name, contact details and other data in person if he/she wishes to attend or participate in one of our external or open training courses
- by the user's employer in connection with participation in one of our external or open training courses.
The data subject consents to the processing of the data provided by the Service Provider in accordance with the applicable data protection legislation. The Service Provider undertakes to store and process the personal data that comes to its knowledge in accordance with the applicable legal provisions.
The personal data shall retain this quality during the processing for as long as the relationship with the Data Subject can be re-established. The connection with the Data Subject may be restored if the Service Provider has the technical conditions necessary for restoration.
The Service Provider is not entitled to transfer the data to third parties or to make them available in any form.
The legal basis for the processing of data by the Service Provider as described above is, on the one hand, the Info tv. 5.§ (1) a) of the Data Subjects' explicit and voluntary consent to the processing, on the other hand, and the statutory data processing permit for the provision of specific services.
By accepting this Policy, the Data Subject accepts the provisions of this Privacy Policy and Information Notice and consents to the processing of his or her personal data for the purposes, to the extent, in the manner, to the extent and for the duration set out in this Policy.
Information on data processing:
- The User may request information about the processing of his/her personal data by telephone or in writing, and may request the rectification or erasure of his/her personal data in the manner indicated when he/she provided the information or by using the contact details indicated on the contact page.
- At the User's request, the Service Provider shall provide information about the data processed by the Service Provider, the source of the data, the purpose, legal basis and duration of the data processing, however, the Service Provider shall provide the information in writing in an intelligible form within 30 days at the latest.
- The Service Provider shall block the personal data if the User so requests or if, on the basis of the information at its disposal, it can be assumed that the deletion would harm the legitimate interests of the User. Blocked personal data may be processed only for as long as the processing purpose that precluded the deletion of the personal data persists.
- The Service Provider shall delete the personal data,
- if its processing is unlawful,
- the User requests it,
- the processed data is incomplete or inaccurate - and this situation cannot be lawfully remedied - provided that the deletion is not excluded by law, the purpose of the processing has ceased,
- or the statutory time limit for the storage of the data has expired or has been ordered by a court or the National Authority for Data Protection and Freedom of Information.
- The controller has 30 days to delete, block or rectify the personal data. If the Service Provider fails to comply with the User's request for rectification, blocking or erasure, it shall inform the User in writing within 30 days of the reasons for the refusal.
- The Service Provider shall notify the Customer of the rectification, blocking and erasure.
Definitions
GDPR: (General Data Protection Regulation) the new European Union Data Protection Regulation
Data Processing: The performance of technical tasks related to data processing operations, irrespective of the method and means used to perform the operations and the place of application, provided that the technical task is performed on the data;
Data processing: Any operation or set of operations which is performed upon data, whatever the method used, in particular any collection, recording, recording, organisation, storage, alteration, use, retrieval, disclosure, transmission, alignment or combination, blocking, erasure or destruction of data, prevention of their further use, taking of photographs, sound recordings or images and physical features which can be used to identify a person (e.g. fingerprints, palm prints, DNA samples, iris scans);
Data subject: any natural person identified or identifiable, directly or indirectly, by reference to specific personal data, who subscribes to the site's mailing or contact system or who receives training or consultancy services, either personally or through an employer;
Consent of the data subject: a voluntary, specific, informed and unambiguous indication of the data subject's wishes by which he or she signifies, by a statement or by an act expressing his or her unambiguous consent, that he or she gives his or her consent to the processing of personal data concerning him or her;
Controller: a natural or legal person or unincorporated body which, alone or jointly with others, determines the purposes for which the data are to be processed, takes and executes decisions regarding the processing (including the means used) or has them executed by a processor on its behalf
Data destruction: the total physical destruction of a data medium containing data;
Transfer of data: making data available to a specified third party;
Data erasure: rendering data unrecognisable in such a way that it is no longer possible to recover them;
Data breach: unlawful processing or handling of personal data, in particular unauthorised access, alteration, disclosure, transmission, disclosure, erasure or destruction, accidental destruction or accidental damage;
User means any natural person, legal entity, unincorporated business or other entity that accesses the Portal and uses its functionalities;
Third Party: a natural or legal person other than the Data Subject, the Controller or the Processor;
Newsletter: a free service provided by the Service Provider through the Portal, whereby the Service Provider sends to the Users who have given their consent, a message on a specific subject, which is also considered as electronic direct marketing and advertising, to the User's e-mail address provided on the Portal;
Consent: a voluntary and explicit expression of the Data Subject's wishes, based on appropriate information, by which he/she gives his/her unambiguous consent to the processing of personal data concerning him/her, either in full or for specific operations;
Special Data: data revealing racial or ethnic origin, membership of a national or ethnic minority, political opinions or political parties, religious or philosophical beliefs, membership of an interest group, health, pathological or sex life, or data concerning a criminal offence.
Disclosure: making data available to anyone;
Portal: the website operated by the Service Provider under the URL;
Personal Data: data that can be associated with the data subject by the processing - in particular the name, email address of the Data Subject.
Service: the services provided by the Service Provider and available to Users, the scope of which the Service Provider, acting at its discretion, is free to define, modify, discontinue certain services, introduce new services, modify existing services at any time. Services include, but are not limited to, the Service Provider's gaming, online administration, newsletter sending services and functions, as well as all other services provided by the Service Provider, whether on a temporary or permanent basis;
Service provider: Sämling Vállalatfejlesztés Kft. 1124 Budapest, Németvölgyi út 64. Tax number: 10595624-2-43, Company registration number: 0109078837
Objection: a statement by the Data Subject objecting to the processing of his/her personal data and requesting the cessation of the processing or the erasure of the processed data.
ACCEPTANCE, MODIFICATION
Rights in Relation to Data Processing
This policy and information notice - in compliance with the provisions of Article 20 of the Info Act - provides information on what data the Service Provider keeps, for what purpose, on what basis, how and for how long it processes them, to whom it transfers them and who may have access to them. From this statement - and from the provisions of the aforementioned legislation - you can find out how you can request clarification of the data processed, how you can request their blocking or deletion from the records of the Service Provider, and what legal remedies you have in the event of a breach of your rights in relation to data processing.
The identity of the controller:
The data processing is carried out by the Service Provider itself. The Service Provider itself is the data controller. No personal data of the data provider may be reproduced from the data thus transmitted by any means whatsoever.
Data collection from external service providers.
RIGHTS RELATING TO DATA MANAGEMENT:
Right to request information: Any person may request, through the contact details provided, information on what data the organisation processes, on what legal basis, for what purpose, from what source and for how long. The request will be answered promptly, but within 30 days at the latest, by sending information to the contact details provided.
Right to rectification. Any person who wishes to exercise his or her right to rectify his or her personal data may request the rectification of his or her personal data without undue delay and within 30 days at the latest.
Right to erasure: Any person may request the erasure of his or her data by contacting the contact details provided. Any person who wishes to have his or her data deleted may have the right to have it deleted.
Right to blocking, restriction: Any person may request the blocking of his or her data by contacting the contact details provided. The blocking lasts as long as the reason indicated makes it necessary to store the data. Upon request, this must be done promptly and within a maximum of 30 days and information must be sent to the contact details provided.
Right to object. The objection shall be examined and a decision shall be taken on its merits within the shortest possible time from the date of the request, but not later than 15 days, and the decision shall be communicated to the contact details provided.
Amendments to the ADMINISTRATIVE RULES AND SUPPORT:
The Service Provider may unilaterally amend this Policy at any time.
The Service Provider is obliged to publish the Policy, as well as any amendments thereto and the Consolidated Data Management Policy and the Information Notice, which is consolidated by the amendments, in a prominent place on the Portal, on the Portal's home page or directly accessible from there, in a way that can be stored, displayed and printed free of charge.
Remedies for Data Subjects:
1. Court
In case of violation of his/her rights, the Data Subject may, within 30 (thirty) days from the date of the communication of the decision or, if the Service Provider fails to comply with the time limit provided for in the Info Act, the last day of the time limit, take the Data Controller to court, to the competent court of law, or, in the capital, to the Metropolitan Court of Budapest. The lawsuit may also be brought before the court of the place of residence or domicile of the data subject, at his or her choice. The court shall decide the case out of turn. It is for the controller to prove that the processing is in compliance with the law.
2. Data protection authority procedure
The Data Subject may lodge a complaint with the National Authority for Data Protection and Freedom of Information (President: Dr. Attila Péterfalvi, registered office: 1024 Budapest, Szilágyi Erzsébet fasor 22/C, postal address: 1530 Budapest, PO Box 5; telephone: +36-1-391-1400, fax: +36-1-391-1410; website: www.naih.hu).
Personal data of participants in adult education programmes
(1) Sämling Vállalatfejlesztés Kft. as a Service Provider conducts adult education activities in accordance with the conditions set out in Act LXXVII of 2013 on Adult Education. Accordingly, it processes the data related to these activities, for which it uses Sämling Solution Consulting Kft. as a data processor.
(2) For the performance of the contract, it is necessary to process personal data of the employees or authorised representatives, subcontractors of the contracting party (company, other organisation) or, in the case of open training, the data of the natural person of the contracting party for the purpose of the performance of the contract.
(3) The Company obtains the personal data from the employer (principal) or directly from the data subject.
(4) The purpose of the processing is the fulfilment of a legal obligation, the performance of a contract between a legal person or a natural person and a legal person, or the fulfilment of the data reporting obligation set out in Act LXXVII of 2013 on Adult Education.
(5) Categories of personal data processed: Name, birth name, mother's name, place and date of birth, gender, nationality, address of residence and place of stay, telephone number, title of residence in Hungary of a non-Hungarian citizen and the name and number of the document or document entitling to residence, social security number of the participant, data relating to the training relationship, concerning the educational and vocational qualifications of the trainee, his/her language skills, his/her enrolment in the training, the assessment and qualification of his/her studies, the name of the qualification or other competence acquired through the training, the place, date and result of the examination.
(6) The duration of data processing is 5 years after the training, as defined in the Adult Education Act. For more information on other data processing for tax and accounting purposes, see the next chapter.
(7) The recipients of the data are the employees and agents of the company involved in adult education and the data controllers collecting data on training courses as defined by law.
Attendance and attendance certificate forms
(1) In the performance of certain contracts concluded between the Company and other legal or natural persons (training courses, training sessions), the Company shall draw up attendance and, where appropriate, certificate acceptance forms.
(2) The purpose of the processing is to certify the performance of the activity to the client or to the relevant Tax and Adult Education Authority and, in the case of a certificate transfer form, to certify the delivery of the certificates.
(3) The legal basis for the processing of data is Act V of 2013 on the Civil Code; Act CL of 2017 on the Rules of Taxation and the implementing legislation; Act C of 2000 on Accounting and the implementing legislation; and Act LXXVII of 2013 on Adult Education.
(4) The data shall be stored for a period of 5 years after the tax liability for the performance.
(5) The recipients of the data are the Company's customer service and its employees and agents performing tasks related to the performance of the contract, the representative of the principal and, in the event of an audit, the audit authority.
Profile data of legal persons or participants in the performance of contracts between a natural person and a legal person
(1) In the performance of certain contracts concluded between the Company and another legal person (e.g. 360 degree evaluation), the Company processes personal data of employees or authorised representatives, subcontractors of the contracting party (company, other organisation). The profile data is obtained by the Company directly from the data subject or, in the case of evaluation procedures, from external evaluators.
(2) The purpose of the processing is the performance of a contract between a legal person or a natural person and a legal person.
(3) Legal basis for processing: consent of the data subject.
(4) The duration of the processing is the end of the purpose of the processing, i.e. 12 months after the performance of the contract or the withdrawal of the data subject's consent.
(5) The recipients of the data are the employees and agents of the Company involved in the performance of the contract.
Contact
Legal Remedies
The owner: Sämling Vállalatfejlesztés Kft. as a member of the ImproversGroup , www.improversgroup.hu
Registered office: Hungary - 1124 Budapest, Németvölgyi Str. 64.
Tel: +36 1 2124412
10:00-16:00 on working days
E-mail address: fejlesztes@samling.hu
Represented by István Ecsédi, Managing Director
Contact:
Data protection related notification can be made (contact details of the data controller):
Address for correspondence: Hungary - 1124 Budapest Németvölgyi Str. 64.
Telephone number: +36 1 2124412
Reception: 10:00-16:00 on working days
E-mail: fejlesztes@samling.hu