INFORMATION ON DATA PROTECTION

We hereby inform you that the personal data provided by you are processed by

FoReGo Magyarország Kft

seat: Kagyló u. 1-3., Budapest 2092, Hungary;

company registration number: 13-09-102819;

VAT number: 13468251-2-13;

registering authority: Company Registry Court of Budapest-Capital Regional Court Miklós Kalocsa Managing Director; hereinafter referred to as “Data Controller”) in a confidential manner, in accordance with the applicable statutory provisions on data protection.

1. By providing your personal data, you explicitly authorize the Data Controller to process the personal data provided by you in accordance with the applicable statutory provisions on data protection, to register them in the database of the Data Controller, and to process them for the duration prescribed hereby following the provision of the data (or until any declaration on restriction of you), unless you request the erasure of your data, in other words, you have explicitly authorized the Data Controller to process your data for a further designated duration.

Scope of processed data:

Name / email

Purpose of data processing: Recommending the products or services of the Data Controller; sending its advertisements; providing information on actual news, products, reductions or new functions by the means of an electronic newsletter.

Legal basis of data processing: consent of the Data Subject

Duration of data processing: until the cancellation of the subscription for the newsletter

Scope of persons authorized to learn the data: Only the employees or agents of the Data Controller required to learn the data for the sake of the completion of their tasks are authorized to access the personal data provided by you.

2. For the above purposes, the Data Controller uses the following data processor:

RackForest Kft

Sáfrány utca 6., Budapest 1116, Hungary

VAT number: 14671858-2-43

Phone: +36 70 398 1166, / email: info@rackforest.hu, / web: www.rackforest.hu

MiniCRM Zrt

Madách Imre út 13-14., Budapest 1075, Hungary

VAT number: 23982273-2-42

Phone: +36 1 999-0402 / email: help@minicrm.hu / web: www.minicrm.hu

LBS ECONET Informatikai és Gazdasági Szolg. Kft

Kossuth L. u. 3-5, Szigetszentmiklós 2310, Hungary

VAT number: 13045403-2-13

Phone: +36 24 441-471 / email: info@lbseconet.hu / web: www.lbseconet.hu

Facebook Inc.

1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

Phone: +1 650-543-4800

Email: N/I/ Website: https://www.facebook.com/

Google LLC

1 Hacker Way, Menlo Park, California 94025

Phone: N/I Email: N/I

Website: https://www.google.com/

3. The Data Controller and the data protector(s) will process the personal data provided by you in a confidential manner and in compliance with the applicable provisions on data protection, especially including the provisions of Act CXII of 2011 on Informational Self-Determination and Freedom of Information, Act VI of 1998 on the Ratification of Strasbourg Convention of 28 January 1981 for the Protection of Individuals with regard to Automatic Processing of Personal Data, and 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 (General Data Protection Regulation).

For the purpose of safe data processing, the Data Controller takes all the IT measures and other measures promoting safe data processing related to data storing, data processing or data forwarding, and also ensures such measures. By the reasonable means, the Data Controller ensures the protection of the personal data processed by it against unauthorized access, modification, disclosure, erasure, damage or destruction, and also ensures the technical conditions necessary for the above.

4. Your rights

The purpose of this document is to provide information on the facts and information related to the data processing to the Data Subjects subscribing for the newsletter (hereinafter referred to as “Data Subject”), before the start of data processing.

You are entitled to receive feedback anytime on whether your personal data is currently processed or not; and whether your are entitled to gain access to the personal data and the following information or not, if your personal data is currently processed:

1. a) purpose of data processing;
2. b) categories of the concerned personal data;
3. c) recipients or categories of recipients who were provided or will be provided with the personal data, including in particular recipients of third countries and international organizations;
4. d) estimated duration of the storage of personal data in certain case; or if it is not possible, the factors of the determination of such duration;
5. e) right for requesting the Data Controller to rectify, erase, or restrict the procession of the personal data concerning him or her, and the right to object against the procession of such personal data;
6. f) right for making a claim at any of the supervisory authorities;
7. g) any available information on the source of the information if it was not collected from the Data Subject;
8. h) fact of automatized decision-making, including profiling; or at least in such cases, easily understandable information on the applied logics, and on significance of such data processing and its estimated consequences concerning the Data Subject.

Upon your request, the Data Controller will provide you with a copy of the personal data subject to the data processing. For further copies, the Data Controller may charge a reasonable price based on the administrative costs.

You are entitled to request the rectification or completion of the incorrect personal data anytime, and the Data Controller is obliged to fulfil your request without undue delay.

You are also entitled to withdraw your consent anytime. You are withdrawing your consent by cancelling your subscription for the newsletter by using the proper link, or by sending your request to withdraw your consent to the Data Controller in accordance with the provisions of this Point.

If you cancel your subscription for the newsletter, the Data Controller erases your personal data from its database within 10 days after your withdrawal.

Upon the request of the Data Subject, the Data Controller shall be obliged to delete the personal data concerning the Data Subject without undue delay if

– the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

– the data subject withdraws consent on which the processing is based, and where there is no other legal ground for the processing;

– the personal data is processed for direct marketing purposes, the data subject objects to the processing, and there are no overriding legitimate grounds for the processing;

– 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.

Where the Data Controller has made the personal data public and is obliged pursuant to this Point to erase the personal data, the 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 the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

The above provision or erasure shall not apply to the extent that processing is necessary:

1. a) for exercising the right of freedom of expression and information;
2. b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
3. c) for reasons of public interest in the area of public health;
4. d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in so far as the right for erasure is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
5. e) for the establishment, exercise or defence of legal claims.

Upon the request of the Data Subject, the Data Controller shall be obliged to restrict the data processing if

– the accuracy of the personal data is contested by the Data Subject, for a period enabling the controller to verify the accuracy of the personal data;

– the processing 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 processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; or

– the personal data is processed for direct marketing purposes, the data subject objects to the processing; in this case pending the verification whether the legitimate grounds of the Data Controller override the legitimate grounds of the Data Subject.

Where processing has been restricted on the basis of the above, such personal data shall, with the exception of storage, only be processed with the Data Subject’s 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. A data subject who has obtained restriction of processing shall be informed by the controller before the restriction of processing is lifted.

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 Data Controller to which the personal data have been provided, and to have the personal data transmitted directly from one controller to another, where technically feasible.

The request may be issued at the following addresses: Kagyló u. 1-3, Budakeszi 2092, Hungary (post mail), info@forego.hu (email).

For identification purposes, it is required to provide correct personal data each time.

The Data Controller provider the Data Subject with information on the measures taken based on the request of the Data Subject for exercising rights without undue delay, but no later than 30 days after receiving the request.

If the Data Subject has submitted the request electronically, the information shall also be provided electronically if possible, unless otherwise demanded by the Data Subject.

The Data Controller shall notify the Data Subject, and each party who received the information for data processing, on any rectification, restriction or erasure.

If the Data Controller does not take any measure upon the request of the Data Subject, the Data Subject shall be notified on the reasons of the lack of measures, and on the fact that the Data Subject is entitled to make a complaint at a supervisory authority or to exercise his or her rights at a court. Such notifications shall be made without undue delay, but no later than 30 days after receiving the request.

Where requests from a Data Subject are manifestly unfounded or excessive, in particular because of their repetitive character, the Data Controller may either:

1. a) charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or
2. b) refuse to act on the request.

The Data Controller shall bear the burden of demonstrating the manifestly unfounded or excessive character of the request.

5. In case of any violation of its rights detailed above, the User may turn to a court or the National Authority for Data Protection and Freedom of Information.

National Authority for Data Protection and Freedom of Information

Address: Szilágyi Erzsébet fasor 22/c, Budapest 1125, Hungary

Phone: +36 (1) 391-1400

Fax: +36 (1) 391-1410

website: http://www.naih.hu

email: ugyfelszolgalat@naih.hu

6. The Data Controller has registered the data processing at the National Authority for Data Protection and Freedom of Information, registration number of data processing: NAIH- 116711/2017

Done in Budapest on 13 June 2018

FoReGo Magyarország Kft.