I. General. Besides other general information, this chapter contains the data of the Controller.
II. Ways of processing. In this chapter you may find specific information (the purpose, grounds and period of processing, the scope of data subjects and the data processed) per each purpose of the processing:
II/1. Contacting us
II/2. Career, job application
II/3. Contact persons of partners
III. The rights of data subjects. Here you may find a detailed description of your rights regarding the processing and the related procedure.
IV. Remedies. In this chapter you may find the detailed description of the remedies you can have if our rights related to your personal data are violated.
‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
‘Controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
‘processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
(2) The data of the Controller in respect of the processing specified herein:
Company name/ Name: Advocate Strategic Consulting Kft.
Registered and postal address: H-1103 Budapest, Gyömrői út 115.
E-mail: info @ asconsult.hu
Tax No: 26267366242
Registration No: 01 09 321058
(6) Governing law: The Controller provides its services protecting the personality rights of the visitors of the Website and its clients, in accordance with the Hungarian law, especially:
(8) The Controller may forward personal data to pursue its activities, to the extent required thereto, to data processors as recipients.
(9) Any personal data processed by us through the Website are stored at our storage provider as a data processor:
MAXER Hosting Kft.
Contact: 9024 Győr, Répce utca 24. 1. em. 3./p>
Activities: web storage, in case no data is provided, the Controller cannot fulfill its activities.
II/1. Contacting us:
(10) When contacted (e.g. in e-mail or on the phone or through the website) for the first time without any previous processing, the Controller processes the personal data of the natural person contacting us.
(11) The purpose of the processing is keeping contact.
(12) The ground for processing is the voluntary consent of the data subject (the visitor) in accordance with point (a) of subparagraph 1 of Article 6 of the GDPR.
(13) Period of processing: until the communication lasts or the ground changes (e.g. for entering into an agreement).
(14) Providing the personal data is not a condition to entering into an agreement but without it keeping contact may not be ensured.
(15) The scope of the processed data: the personal data provided by the data subject in the course of making contact, especially his or her name, e-mail address, phone number, job or title.
(16) The recipients of the data are our employees dealing with client care or the addressees of the message sent by the data subject or our employee handling the respective matter concerned.
II/2. Career, job application
(17) The Controller process the personal data of candidates applying for jobs at the Controller either through the ‘Career’ menu item on the Website or in other form.
(18) The purpose of processing is the assessment of the application for filling a position.
(19) The ground for processing is the voluntary consent of the data subject (the visitor) in accordance with point (a) of subparagraph 1 of Article 6 of the GDPR.
(20) Processed personal data: name, address, place and date of birth, qualification, professional training, e-mail address, phone number, portrait.
(21) The data subjects are the candidates.
(22) Period of processing: Until the candidate is hired or until the consent is withdrawn by the candidate or, in case of an unsuccessful application, for 30 days from filling the position. Personal data may also be stored for one (1) year in case the candidate provides his/her explicit consent to it allowing the Controller to store the personal data for the purpose of filling any vacancies within this period.
(23) The recipients of the data are the person exercising the employer’s rights, employees responsible for HR matters, employees involved in the selection process (e.g. office manager, head of department etc.)
II/3. Contact persons of partners
(24) The Controller processes the personal data (names, e-mail addresses, phone numbers, email addresses, titles, position the contact persons) of the natural person contact persons of the partners not being natural persons (e.g. clients and suppliers) as data subjects.
(25) The purpose of processing is keeping contact with our partners.
(26) The ground for processing is the legitimate interests of the Controller and the partner that their agreement be fulfilled [point (f) of subparagraph 1 of Article 6 of the GDPR].
(27) Period of processing: the civil law expiry period of 5 years.
(28) The recipients of the data are account managers and other employees (only to the extent required for performance of their jobs), accountant (especially if contact data are included to the invoice or to the invoice accompanying documents).
(29) In this aspect, the accountant of the Controller is considered a data processor. Activities: accountancy, in case no data is provided, the Controller cannot fulfill its activities. Forwarded personal data: personal data required for invoices, name and address.
(31) In order to monitor the Website, the Controller uses an analytical tool (cookie) which prepares a data string and tracks how the visitors use the internet pages. When a page is viewed, the system generates a cookie in order to record the information related to the visit (pages visited, time spent on the Controller’s pages, browsing data, exits, etc) and installs it on the computer of the visitor but these data cannot be linked to the visitor’s person. This tool is instrumental in improving the ergonomic design of the website, creating and improving a user-friendly website, enhancing the online experience for visitors and preventing data loss. Cookies recognize the computer of the visitor and manage its IP address. Most internet browsers accept cookies, but visitors have the option of deleting or automatically rejecting or allowing them. The visitor has the option to decline the installation of cookies. Since all browsers are different, visitors can set their cookie preferences individually with the help of the browser toolbar. Users might not be able to use certain features on the Website if they decide not to accept cookies. Using cookies, the websites seen by the visitor and the internet use customs of the visitor may be monitored. Only upon revisiting the Website and exclusively the respective service provider can link such data to the person of the visitor. The duration of the storing of such data depends on the type of the cookies. Session cookies erase the data upon closing the Website, Flash-cookies, however may store the data up to one year of inactivity.
(32) The ground for processing is the voluntary consent of the data subject (the visitor) in accordance with point (a) of subparagraph 1 of Article 6 of the GDPR.
(33) Processed data: browser history, identification No, date, time of visit.
(34) The purpose of processing: improvement of the user experience, storing of the data of the respective session, prevention of data loss, identification and tracking of the data subjects, web analytics .
(35) In the Menu of most of the browsers, there is a “Help” function providing information for the data subject, in his or her browser
(36) The Controller uses the session cookies which shall be deleted upon closing your browser.
(37) People may subscribe to our newsletters with their expressed, voluntary and active declarations.
(38) The purpose of processing is informing the data subjects on the services, products, news and events of the Controller and any changes thereto.
(39) The ground for processing is the voluntary consent of the data subject in accordance with point (a) of subparagraph 1 of Article 6 of the GDPR.
(40) Processed personal data: name (surname and first name); e-mail address
(41) Period of processing: lasts until the data subject requests to unsubscribe from the newsletters.
(42) The data subject may exercise his or her following rights via the contacts of the Controller listed above:
III/1. Right for information and access:
(43) The Controller shall take appropriate measures to provide any information referred to in Articles 13 and 14 of the GDPR relating to processing to the data subject in a concise, transparent, intelligible and easily accessible form, using clear and plain language.
(44) Information may be requested in writing through the contact data of the Controller specified above. When requested by the data subject, the information may be provided orally, provided that the identity of the data subject is proven by other means.
(45) The data subject shall have the right to obtain from the controller confirmation 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 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, in particular recipients in third countries or international organisations; the envisaged period for which the personal data will be stored; the existence of the 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; the right to lodge a complaint with a supervisory authority; 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 the data subject. Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
(46) The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
(47) The Controller shall be obliged to respond to requests from the data subject at the latest within one month.
III/2. Right to rectification:
(48) The data subject shall have the right to obtain from the Controller without undue delay the rectification of inaccurate personal data and the completion of incomplete personal data concerning him or her.
III/3. Right to erasure (‘right to be forgotten’):
(49) The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
(50) Erasure may not be requested to the extent that 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 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; for reasons of public interest in the area of public health; for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes; or for the establishment, exercise or defence of legal claims.
III/4. Right to restriction of processing:
(51) The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
(52) Where processing has been restricted, 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 European Union or of a Member State.
(53) A data subject who has obtained restriction of processing shall be informed by the controller before the restriction of processing is lifted.
III/5. Right to data portability:
(54) The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a 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 controller to which the personal data have been provided.
III/6. Right to object:
(55) The data subject shall have the right 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 necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller or processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, including profiling based on those provisions. The Controller shall no longer process the personal data unless the Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
(56) Where personal data are processed for direct marketing purposes, the data subject 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 the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
III/7. Right to object against automated individual decision-making:
(57) The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her. This right may not be exercised if the processing is necessary for entering into, or performance of, a contract between the data subject and a data controller; is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or is based on the data subject’s explicit consent.
III/8. Right of withdrawal:
(58) The data subject shall have the right to withdraw his or her consent anytime. The withdraw of the consent shall not affect affecting the lawfulness of processing based on consent before its withdrawal.
III/9. Rules on the procedure of the enforcement of rights:
(59) Deadline: The Controller shall provide information on actions taken on a request under Chapter III hereof to the data subject without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. The Controller shall inform the data subject of any such extension within one month of receipt of the request, together with the reasons for the delay. Where the data subject makes the request by electronic form means, the information shall be provided by electronic means where possible, unless otherwise requested by the data subject.
(60) If the controller does not take action on the request of the data subject, the controller shall inform the data subject without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.
(61) Information shall be provided free of charge. Where requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character, the controller may either charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or refuse to act on the request.
(62) The Controller shall communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort.
(63) Any person shall have the right to notify the Hungarian National Authority for Data Protection and Freedom of Information (in Hungarian: Nemzeti Adatvédelmi és Információszabadság Hatóság; http://www.naih.hu/; registered seat: 1125 Budapest Szilágyi Erzsébet fasor 22/c, post address: 1530 Budapest, Pf.: 5., telephone: +36 (1) 391-1400) and request an investigation alleging an infringement relating to his or her personal data or concerning the exercise of the rights of access to public information or information of public interest, or if there is imminent danger of such infringement. The Authority shall carry out the investigation free of charge; the costs thereof shall be advanced and borne by the Authority.
(64) In the event of any infringement of his rights, the data subject may turn to court action against the controller. The court shall hear such cases in priority proceedings. The action shall be heard by the competent tribunal. If so requested by the data subject, the action may be brought before the tribunal in whose jurisdiction the data subject’s home address or temporary residence is located. Data controllers shall be liable for any damage caused to a data subject as a result of unlawful processing or by any breach of data security requirements. The data controller shall also be liable for any damage caused by data processors acting on its behalf. The data controller may be exempted from liability if it proves that the damage was caused by reasons beyond his control. No compensation shall be paid where the damage was caused by intentional or serious negligent conduct on the part of the aggrieved party. Should the data controller infringe the personality rights of the data subject with the illegal control of the data subject’s data or with the breach of data security requirements, the data subject may claim restitution from the data controller.