Privacy Policy

1. Purpose of the data protection information

Effekt Marketing Ltd (thereafter Data Controller) is committed to protect the personal data of its customers and partners, and considers it of utmost importance to respect its customers’ right to self-determination of information. The Data Controller treats personal data confidentially and takes all security, technical and organizational measures that guarantee data security. The Data Controller recognizes the content of this legal notice as binding on itself. All data processing related to its activity complies with the requirements set out in these regulations and in the applicable national legislation, as well as in the legal acts of the European Union. The data controller’s data protection guidelines are continuously available at www.promarketing.hu/adatvedelem. The date manager may update the Privacy Policy from time to time by posting a new version online. You should check this page occasionally to review any changes. If there is any changes you will be notified by posting the revised Privacy Policy on the website. If you have any questions related to this announcement, please write to us and our colleague will answer your question. The data controller describes its data management practices below.

Basic data management concepts:
– data processing: performing technical tasks related to data management operations, regardless of the method and tool used to perform the operations, as well as the place of application, provided that the technical task is performed on the data;
– data processor: the natural or legal person, or an organization without legal personality who processes data on the basis of the contract concluded with the data controller – including the conclusion of a contract based on the provisions of the law;
– data management: regardless of the procedure used, any operation performed on the data or the set of operations, including in particular the collection, recording, recording, organization, storage, change, use, query, transmission, disclosure, coordination or connection, locking, deletion and destruction, as well as preventing further use of the data, taking photographs, audio or video recordings, as well as physical characteristics suitable for identifying the person (e.g. fingerprints or recording of a palm print, DNA sample, iris image);
– data controller: the natural or legal person, or an organization without legal personality who, independently or together with others, determines the purpose of data management, makes and implements decisions regarding data management (including the device used), or implements them with the data processor commissioned by it;
– data destruction: complete physical destruction of the paper-based data carrier containing the data;
– data transfer: making the data available to a specific third party; disclosure: making the data available to anyone;
– data erasure: rendering the data unrecognizable in such a way that their recovery is no longer possible;
– data blocking: providing the data with an identification mark for the purpose of limiting its further processing permanently or for a specified period of time;
– concerned (you or User): any specific natural person identified or – directly or indirectly – identifiable on the basis of their personal data; –
 third party: a natural or legal person, or an organization without legal personality, who is not the same as the data subject, data controller or data processor;
– consent: the voluntary and decisive declaration of the data subject’s will, which is based on adequate information, and with which he gives his unequivocal consent to the processing of his personal data – in full or covering certain operations;
– personal data: data that can be associated with the data subject – in particular the data subject’s name, identification mark, and one or more pieces of information characteristic of his or her physical, physiological, mental, economic, cultural or social identity – as well as the conclusion about the data subject that can be drawn from the data;
– objection: the statement of the data subject objecting to the processing of his personal data and requesting the termination of the data processing or the deletion of the processed data;

2. Data of the Data Controller

Name: Effekt Marketing Ltd.

Headquarters: 203 Rákos str, Budapest 1155 Hungary

Company registration number: 01-09-904490

Name of the registering court: Company Court of the Capital Court

Tax number: 14453401-2-42

Phone number: +36 20 9389 211

E-mail: info@promarketing.hu

The Data Controller accepts complaints and comments related to its data management exclusively to the e-mail address indicated above, and you can request information about the management of your personal data at this address.

Hosting provider: Kismester Bt.

3. The scope of personal data managed by the Data Controller, the purpose, title and duration of data management

The data management of the Data Controller is based on voluntary consent. In some cases, the management, storage and transmission of a range of the provided data is made mandatory by law, of which we notify our customers separately. We draw the attention of informants to the Data Controller that if they do not provide their own personal data, the informant must obtain the consent of the data subject. Its basic data management principles are in line with the applicable data protection legislation, in particular with the following: – Regulation 2016/679 of the European Parliament and of the Council of 2016 (“General Data Protection Regulation” or “GDPR”) – Act V of 2013 on the Civil Code ( “Ptk.”) – LXXVII of 2013 Act on adult education – CXII of 2011 Act (“Infotv”) on the right to self-determination of information and freedom of information – XLVIII of 2008. Act (“Grtv”) on the basic conditions and certain limitations of economic advertising activity – CVIII of 2001. Act on certain issues of electronic commercial services and services related to the information society

3.1 Data of visitors of the website operated by the Data Controller

Website operated by the Data Controller: www.promarketing.hu Purpose of data management: the Data Controller records visitor data during visits to the www.promarketing.hu website in order to perform the service, check its operation and prevent abuse. (It is not necessary to provide personal data to visit the website.) The legal basis for data management: the consent of the data subject, and CVIII of 2001 on certain issues of electronic commerce services and services related to the information society. Act 13/A. (3) of § The scope of the managed data: date and time of the visit, address of the page visited and previously viewed, operating system and browser type, IP address. Duration of data management: 1 year from the date of viewing the website. The html codes of the portals available at https://www.promarketing.hu contain links to and from an external server independent of the Data Controller. The providers of these links are able to collect user data due to the direct connection to their server.

3.2 Technical data

The Data Controller selects and operates the IT tools used for the management of personal data during the provision of the service in such a way that the managed data: – is accessible to those authorized to do so (availability); – its authenticity and authentication are ensured (authenticity of data management); – its immutability can be verified (data integrity); – be protected against unauthorized access (data confidentiality). The Data Controller uses appropriate measures to protect the data against unauthorized access, alteration, transmission, disclosure, deletion or destruction, as well as against accidental destruction. The Data Controller ensures the protection of the security of data management with technical, organizational and organizational measures that provide a level of protection corresponding to the risks associated with data management. During data management, the Data Controller preserves – confidentiality: protects the information so that only those who are authorized to do so can access it; – integrity: protects the accuracy and completeness of the information and the method of processing; – availability: it ensures that when the authorized user needs it, he can really access the desired information and that the related tools are available.

3.3 Cookies

In order to provide customized service the browser plases a small data package, so-called cookie on the computer of the visitor and reads it back during the next visit. If a previously saved cookie is returned during a visit, the cookie management service provider has the opportunity to link the user’s current visit with previous ones, but only with regard to its own content. The purpose of cookies is to: – collect information about visitors and their devices; – the individual settings of the visitors are noted, which will be used, e.g. when using online transactions, so you don’t have to type them in again; – facilitate the use of the website; – provide a quality user experience.

4. Data transmission, data processing, the circle of those familiar with the data

The Data Controller and its internal employees are primarily entitled to know the data, which are not forwarded to third parties, are not published, and are used and can only be used for the purposes specified in the Data Protection Information. The Data Controller does not use external data processors for online data. The Data Controller may use a system operator for the operation of the underlying IT system. The Data Controller is not responsible for the data management practices of such external actors. Given the relevant provisions of the GDPR, the Data Controller is not obliged to appoint a Data Protection Officer.

5. Affected rights and legal enforcement options

The data subject can request information about the management of their personal data, and can request the correction of their personal data, or – with the exception of mandatory data management – deletion or withdrawal, they can exercise their right to data portability and protest as indicated when the data was collected, or at the above contact details of the data controller.

5.1 Right to information

The Data Controller takes appropriate measures in order to provide the data subjects with all information regarding the processing of personal data referred to in Articles 13 and 14 of the GDPR and Articles 15-22. and provide each piece of information according to Article 34 in a concise, transparent, comprehensible and easily accessible form, clearly and comprehensibly worded.

5.2 Data subject’s right of access

The data subject has the right to receive feedback from the data controller as to whether their personal data is being processed, and if such data processing is in progress, they entitled to access the personal data and the following information: the purposes of the data processing; categories of personal data concerned; the recipients or categories of recipients to whom or to whom the personal data has been or will be communicated, including in particular recipients in third countries and international organizations; the planned period of storage of personal data; the right to rectification, deletion or limitation of data processing and the right to protest; the right to submit a complaint to the supervisory authority; information about data sources; the fact of automated decision-making, including profiling, as well as comprehensible information about the applied logic and the significance of such data management and the expected consequences for the data subject. The data controller shall provide the information within a maximum of one month from the date of submission of the request.

5.3 Right of rectification

The data subject may request the correction of inaccurate personal data concerning him/her managed by the Data Controller and the addition of incomplete data.

5.4 Right to erasure

If one of the following reasons exists, the data subject has the right to have the Data Controller delete their personal data without undue delay at their request: – personal data are no longer needed for the purpose for which they were collected or otherwise processed; – the data subject withdraws the consent that forms the basis of the data management, and there is no other legal basis for the data management; – the data subject objects to data processing and there is no overriding legal reason for data processing; – the personal data were handled illegally; – personal data must be deleted to fulfill the legal obligation prescribed by EU or Member State law applicable to the data controller; – the collection of personal data took place in connection with the offering of services related to the information society. Data deletion cannot be initiated if data management is necessary: ​​for the purpose of exercising the right to freedom of expression and information; for the purpose of fulfilling the obligation under the EU or Member State law applicable to the data controller requiring the processing of personal data, or for the execution of a task carried out in the public interest or in the context of the exercise of a public authority vested in the data controller; affecting the field of public health, or for archival, scientific and historical research purposes or for statistical purposes, on the basis of public interest; or to submit, assert or defend legal claims.

5.5 Right to restriction of data processing

At the request of the data subject, the Data Controller restricts data processing if one of the following conditions is met: – the data subject disputes the accuracy of the personal data, in which case the restriction applies to the period that allows checking the accuracy of the personal data; – the data management is illegal and the data subject opposes the deletion of the data and instead requests the restriction of their use; – the data controller no longer needs the personal data for the purpose of data management, but the data subject requires them to present, enforce or defend legal claims; or – the data subject objected to data processing; in this case, the restriction applies to the period until it is established whether the legitimate reasons of the data controller take precedence over the legitimate reasons of the data subject. If data management is subject to restrictions, personal data may only be processed with the consent of the data subject, with the exception of storage, or to submit, enforce or defend legal claims, or to protect the rights of another natural or legal person, or in the important public interest of the EU and member state

5.6 Right to data portability

The data subject has the right to receive the personal data concerning him/her provided to the data controller in a segmented, widely used, machine-readable format, and to forward this data to another data controller.

5.7 Right to protest

The data subject has the right to object at any time for reasons related to their own situation to the processing of their personal data necessary for the performance of a task carried out in the public interest, or within the framework of the exercise of public authority conferred on the data controller, or the processing necessary to enforce the legitimate interests of the data controller or a third party, including profiling based on the aforementioned provisions too. In the event of a protest, the data controller may no longer process the personal data, unless it is justified by compelling legitimate reasons that take precedence over the interests, rights and freedoms of the data subject, or that are related to the submission, enforcement or defence of legal claims.

5.8 Automated decision-making in individual cases, including profiling

The data subject has the right not to be covered by the scope of a decision based solely on automated data management, including profiling, which would have legal effects on them or affect   them to a similar extent.

5.9 Right of Withdrawal

The data subject has the right to withdraw their consent at any time.

5.10 Right to Court

In the event of a violation of their rights, the data subject may apply to the court against the data controller. The court acts out of sequence in the case.

5.11 Data protection official procedure

You can file a complaint with the National Data Protection and Freedom of Information Authority: Name: National Data Protection and Freedom of Information Authority Headquarters: 1125 Budapest, Szilágyi Erzsébet fasor 22/C. Mailing address: 1530 Budapest, PO Box.: 5. Phone: +36 1 3911400 Fax: +36 1 3911410 E-mail: ugyfelszolgalat@naih.hu Website: http://www.naih.hu

6. Other provisions

We provide information on data management not listed in this information when the data is collected. We inform our customers that the court, the prosecutor, the investigative authority, the infringement authority, the public administrative authority, the National Data Protection and Freedom of Information Authority, the Hungarian National Bank, or other bodies based on the authorization of the law, provide information, communicate data, transfer documents, or they can contact the data controller to make it available. The Data Controller will only release personal data to the authorities – if the authority has indicated the exact purpose and the scope of the data – to the extent and to the extent that is absolutely necessary to fulfil the purpose of the request.