PRIVACY POLICY
Privacy Notice of ZONE Klaszter Nonprofit Kft., effective from 01.05.2020 until revoked.
ZONE Klaszter Nonprofit Kft. is committed to respecting the data processing rights of its partners. The Cluster carries out the data processing activities set out in this notice during its operations. The terms used in this notice shall be interpreted in accordance with the definitions set out in Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter: GDPR) and in Act CXII of 2011 on Informational Self-Determination and Freedom of Information (hereinafter: Info Act).
Table of Contents
I. Rights of data subjects and conditions for their exercise
I./1. Who processes your personal data?
I./2. What principles does the Cluster consider important when processing your personal data?
I./3. Categories of data subjects
I./4. To whom is personal data transferred?
I./5. What are your rights regarding your personal data processed by the Cluster?
I./6. What are your legal remedies in connection with your personal data processed by the Cluster?
II. Specific cases of data processing
II./1. Information regarding applications for professional training courses and programs organized by ZONE Klaszter Nonprofit Kft., and the forwarding of professional materials
II./2. Information regarding contact and marketing inquiries
III. Cookie data processing
I. Rights of data subjects and conditions for their exercise
1. Who processes your personal data?
Your personal data is processed by (hereinafter: Cluster) as data controller, or on its behalf and in accordance with its instructions by data processors engaged by it.
Name of the data controller:
ZONE Klaszter Nonprofit Kft.
Registered office: 1016 Budapest, Mihály utca 4/a.
Tax number: 26278184-2-41
Company registration number: 01 09 321638
Contact details:
Represented by: Roland Nemes
Email address: dialogue.zone@
2. What principles does the Cluster consider important when processing your personal data?
The Cluster guarantees the enforcement of the provisions of the General Data Protection Regulation, the Info Act, and sectoral legislation concerning specific data processing. During its data processing activities, the Cluster respects the personal rights of data subjects and processes the personal data of its partners in compliance with the applicable legal provisions. For the purpose of providing the service, only personal data relevant to the purposes of data processing, as predefined, will be processed for the time necessary to achieve the purposes of the service. The Cluster is responsible for the accurate processing of the personal data provided by its partners with the same content after the personal data has been provided.
3. Categories of data subjects
The data subjects in this data processing activity are persons using the services specified below.
4. To whom is personal data transferred?
For the purpose of disclosing, accessing, and transferring the personal data it processes, the Cluster may be contacted by an authority (in particular, a misdemeanor authority, investigating authority, prosecutor's office, court, other administrative authority, the National Authority for Data Protection and Freedom of Information) or another data controller, based on legal authorization. If the requesting body precisely indicates the scope of the requested data, the purpose and legal basis of the request, and the fulfillment of the request does not conflict with the law, the personal data strictly necessary for the realization of the purpose of the request will be made available. Apart from the above cases and without your consent, personal data will not be transferred to another data controller.
Legal bases for data processing
Personal data may be processed if:
a) the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which the controller is subject;
d) processing is necessary in order to protect the vital interests of the data subject or of another natural person;
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
The data subject shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Prior to giving consent, the data subject shall be informed thereof. The withdrawal of consent shall be made as easy as giving consent.
If personal data was collected on the basis of the data subject's consent, the Cluster may process the collected data – in the absence of a contrary provision of law:
a) for the purpose of fulfilling a legal obligation to which it is subject, or
b) for the purpose of pursuing its own or a third party's legitimate interest, if the pursuit of this interest is proportionate to the restriction of the right to the protection of personal data, without further special consent, and also after the withdrawal of the data subject's consent.
5. What are your rights regarding your personal data processed by the Cluster?
According to the GDPR regulation, the data subject has the following rights in relation to data processing; the deadline for fulfillment is a maximum of one month from the receipt of the request:
Right to information and access, whereby the data subject is entitled to obtain confirmation from the controller 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 categories of personal data concerned, the purposes of the processing, the recipients or categories of recipient to whom the personal data have been or will be disclosed, where applicable, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period, and the data subject's right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing, as well as the right to lodge a complaint with a supervisory authority.
Right to rectification, whereby the data subject is entitled to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her, and, taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Right to erasure, whereby the data subject is entitled to obtain from the controller the erasure of personal data concerning him or her processed on the basis of consent without undue delay.
Right to restriction of processing, whereby the data subject is entitled to obtain from the controller restriction of processing where the data subject contests the accuracy of the personal data, or the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead, or the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims, or where the data subject has objected to processing, in which case the restriction shall apply for a period enabling the controller to verify whether the legitimate grounds of the controller override those of the data subject.
Right to object, whereby the data subject is entitled to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on the necessity for the purposes of the legitimate interests pursued by the controller or by a third party. The Cluster shall no longer process the personal data on the basis of the objection unless the processing is justified by compelling legitimate grounds which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.
6. What are your legal remedies in connection with your personal data processed by the Cluster?
Right to lodge a complaint with a supervisory authority
Without prejudice to any other administrative or judicial remedy, every data subject shall have the right to lodge a complaint with the National Authority for Data Protection and Freedom of Information (hereinafter: Supervisory Authority) if the data subject considers that the Controller service provider or the Data Processor engaged by it has committed an infringement or created a risk thereof through its activity or omission.
Contact details of the National Authority for Data Protection and Freedom of Information:
1530 Budapest, Pf.:5.
1125 Budapest, Szilágyi Erzsébet fasor 22/c
Tel.: +36 1/391-1400
Right to an effective judicial remedy against a controller or processor.
Without prejudice to any available administrative or non-judicial remedy, including the right to lodge a complaint with a supervisory authority, each data subject shall have the right to an effective judicial remedy where he or she considers that his or her rights in relation to the processing of his or her personal data have been infringed. The trial falls within the competence of the regional court. You may decide to bring the action before the regional court of your place of residence or stay.
The list of regional courts can be found at the web address http://birosag.hu/torvenyszekek.
II. Specific cases of data processing
1. Information regarding applications for professional training courses and programs organized by ZONE Klaszter Nonprofit Kft., and the forwarding of professional materials
Purpose of data processing
Processing of Data Subjects' data for the purpose of application for webinars and sending related professional materials.
Duration of data processing
Until the registration / service exists, or until the data subject withdraws consent (request for erasure).
Legal basis for data processing
The data subject's voluntary consent pursuant to Section 5 (1) (a) of the Info Act and Article 6 (1) (a) of the GDPR.
Scope of data processed
The data subjects' name, email address, IP address, and, if they wish to provide it separately, telephone number.
2. Information regarding contact and marketing inquiries
Purpose of data processing
Information and marketing inquiries related to the services of ZONE Klaszter Nonprofit Kft., thus information about marketing campaigns and participation in them.
Duration of data processing
Until the newsletter service exists, or until the data subject withdraws consent (request for erasure).
Legal basis for data processing
The data subject's voluntary consent pursuant to Section 5 (1) (a) of the Info Act and Article 6 (1) (a) of the GDPR.
Scope of data processed
The data subjects' name, email address, IP address.
We inform you that the external server of Google Analytics helps with the independent measurement and auditing of the visitor traffic and other web analytics data of these registration websites. The data controller can provide detailed information on the processing of measurement data at www.google-analytics.com.
Which persons participate as data processors in the processing of personal data, how is data processing carried out?
The Data Controller is also considered a data processor, i.e., it performs technical operations related to data processing. Data processing is carried out via an information system. During data processing, the Data Controller also uses the services of other data processors:
Tárhely.Eu Szolgáltató Kft. Hosting provider (1097 Budapest, Könyves Kálmán körút 12-14.)
Google Ireland Limited (Gordon House, Barrow Street, Dublin 4.Dublin, D04 E5W5)
BPD Group Kft. web development (2200 Monor, Dózsa György utca 3.)
The Rocket Science Group, LLC mailing system, newsletter sending (675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA)
Data Processors may access all personal data of the Data Subject made available to the Data Controller.