Data Protection Notice
Search Consulting – Keresőmarketing Szolgáltató és Tanácsadó Korlátolt Felelősségű Társaság
1. General provisions and contact details
This policy (“Policy”) applies to the handling of any information (personal data) concerning identified or identifiable natural persons (data subjects) by Search Consulting – Keresőmarketing Szolgáltató és Tanácsadó Korlátolt Felelősségű Társaság (“Search Consulting”).
Search Consulting is required to comply with the provisions of GDPR from 25 May 2018.
Search Consulting address: 1053 Budapest, Kecskeméti utca 13. 2. em. 2/b.
Search Consulting company registration number: Cg. 01-09-188489
Search Consulting webpage: https://secon.hu/
Search Consulting phone number: +36/70/6327604
Search Consulting e-mail address: firstname.lastname@example.org
Search Consulting representative and contact information: Pacsa Attila, see contact information above
If you have any questions or remarks concerning this Policy, please contact Search Consulting at one of above contact details prior to using the https://secon.hu/ website and prior to providing any information or data in accordance with this Policy.
2. Updates and access to the Policy
Search Consulting reserves the right to unilaterally modify the Policy, following any prior modifications, after which such modification shall come into effect. With this in mind, it is recommended to regularly visit the https://secon.hu/ website to carefully follow any changes. Upon your request, we will be happy to provide you with an up-to-date hard copy of the Policy.
3. Understanding and accepting the Policy
By providing your personal information, you agree that you understood and explicitly accepted the valid version of the Policy at the time of doing so. Certain data protection conditions may be applicable during the provision of using certain services, of which you may be notified prior to using such services.
4. The scope of handled data and the purpose of data handling
The scope of personal data processed by Search Consulting, the purposes of data handling, the duration of the data handling and those authorised to access the data is presented in the table.
5. Transfer of personal data to our contracted partners
Search Consulting uses the below contracted partners for the completion of tasks related to data handling activities. The contracted partner acts as a so-called “data processor”: rights and responsibilities regarding the use of data are determined by Search Consulting and these partners are not authorised to make decisions related to data handling. They shall not process the data for their own purposes, furthermore, the personal data must be stored and kept in accordance with Search Consulting’s provisions.
6. Cookies used on the https://secon.hu/ website
Cookies are used in certain areas of the https://secon.hu/ website. The cookies are files that store information on your hard disk or web browser.
Cookies, for example, make it possible for the website to recognise if you have visited previously, or, by allowing us to see which sites you visit and how much time you spend there, help us understand what part of the website is most popular. By studying this, we can better adjust the site to your needs and offer a more varied user experience. With the help of cookies, we can assure that the information displayed on your next visit to the site will meet your expectations.
When you visit one of our websites, technical information may be gathered that does not allow you to be personally identified. For example, the name of another website that directed you here, the location from where you accessed the website, and search quiries completed on the website. Collecting this information helps us identify the preferred search habits of our website users without using their personal data. Such information is used strictly for internal purposes. Anonymous or general data from which your person cannot be identified does not qualify as personal data and thus does not fall within the scope of this Policy.
Links for the handling of cookies in the case of most frequently used browsers:
Mozilla Firefox: https://support.mozilla.org/t5/Cookies-and-cache/Enable-and-disable-cookies-that-websites-use-to-track-your/ta-p/2784
Google Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en
Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
Google Analytics provides a further option of unsubscribing from the Google Analytics service: http://tools.google.com/dlpage/gaoptout?hl=en-GB
7. Personal data relating to children and third parties
With the exception of when parental consent is provided, persons under 16 years of age are not permitted to provide any personal data.
By providing personal data, you declare and affirm that you have considered the above and that your legal capacity related to providing personal data is not limited.
If you do not have the right to independently provide personal data, you must acquire the permission of the appropriate third party (i.e. legal representative, guardian, other persons you are representing), or provide another form of a legal basis to do so. In relation to this, you must be able to consider whether the personal data to be provided requires the consent of a third party. To this point, you are responsible for meeting all the necessary requirements, as Search Consulting may not otherwise come into contact with the data subject and Search Consulting shall not be liable or bear any responsibility in this regard. Nevertheless, Search Consulting has the right to check and verify whether the proper legal basis has been provided with relation to the handling of data at all times. For example, if you are representing a third party, we reserve the right to request the proper authorisation and/or consent of the party being represented with relation to the matter at hand.
We will do everything in our power to remove all unauthorised information provided and ensure that such information is not forwarded to any third party, or used for our own purposes (advertising or any other activity). We request that you inform us immediately should you become aware that a child or any other third party has provided any personal data of yours that you have not properly authorised them to do so.
8. Data security
Data processed by Search Consulting is protected by the restrictions applied to the access of information. For example, only those who require it, in the interests of and for the purposes listed previously, have access to the data.
9. Your data protection rights and legal options for remediation
You may request from us: (a) information on the handling of your personal data, (b) updates to your personal data, and (c) the deletion or blocking of your personal data, with the exception of the mandatory handling of data. Search Consulting is obligated to provide you with your requested information, in writing and in an easily comprehensible form, within the shortest amount of time from receipt of the request, but no later than within 25 days.
Should we not implement the update, block or deletion as you request, we shall provide you with the factual and legal reasons for the denial of such request within 25 days of having been handed the request, either in writing or, with the consent of the data subject, via electronic means.
You may object to the handling of your data under those circumstances determined and laid out in section 21 of Act CXII of 2011 on the right of informational self-determination and freedom of information. Search Consulting will assess the objection within the shortest amount of time from receipt of the request, but within no more than 15 days.
You may turn to the courts in the event you feel your rights have been violated. The proceedings may be initiated – according to your preference – at the relevant courts of either your place of residence, or domicile.
By notifying the National Authority for Data Protection and Freedom of Information (http://naih.hu/; 1530 Budapest, Pf.: 5.; Tel.: +36 1 391 1400; fax: +36 1 391 1410; e-mail: email@example.com), anyone may initiate an investigation with reference to a violation of rights regarding personal data handling, or that there is an imminent risk of such a violation.
The subsections of Infotv. 13-17 and 30 contain detailed rights and options for judicial remediation relating to data handling.
It may be in your best interests to send your complaints to Search Consulting prior to initiating any proceedings.
10. Data protection rights and judicial remediation
After 25 May 2018, your data protection rights and options for judicial remediation, and the GDPR’s provisions and restrictions in relation to this, are contained in detail in the GDPR (specifically GDPR articles 15, 16, 17, 18, 19, 20, 21, 22, 77, 78, 79 and 82). Below is a summary of the most important provisions.
10.1 Access rights
(1) You are entitled to receive a notification from us to indicate that the handling of your personal data is in progress. If data processing is in progress, you are entitled to be provided with access to your personal data and the following information:
a) purpose of the data handling;
b) categories of the data subject’s personal data;
c) recipients or categories of recipients, who have been or will be informed of personal data, particularly third party national recipients and international organisations;
d) where appropriate, the planned period of personal data storage, or it is not possible to provide this, the criteria for determining such a timeframe.
e) it is your right to request an update, deletion or processing restriction of personal data related to you, as well as to object to such personal data handling;
f) the right to lodge a complaint to the supervisory authority; and
g) if the data was not provided by you, all available information as to the source of such data;
h) automated decisions, including profiling, and at least in these cases, the applied logic and related information, the degree of relevance and expected consequences that these types of data handlings have for you.
(2) If personal data is transferred to a third country, you are entitled to receive notification of such associated applicable guarantees.
(3) A copy of the personal data subject to the data handling shall be made available to you. If your request was made electronically, the information shall be made available in the most commonly used electronic format, unless requested otherwise.
10.2 Right to update
You are entitled to have your information updated without delay or reason at your request. You are entitled to request that any missing or incomplete personal data is updated by making, inter alia, a supplementary declaration.
10.3 Right to deletion (“right to be forgotten”)
(1) You are entitled to have your information deleted without delay or reason, at your request, if any of the following conditions are met:
a) there is no longer a need for the personal data for the purposes it was gathered for or handled otherwise;
b) you revoke your consent on which the handling is based and there is no other legal basis for the data handling;
c) you object to the data handling, and in the given case there is no overriding legitimate reason for the data handling;
d) the personal data was processed unlawfully;
e) the personal data must be deleted in order to fulfil our obligations under European Union or Member State law; or
f) the collection of personal data was associated with the offering of information society services.
(2) If Search Consulting disclosed any personal data and is obligated to delete such data based on paragraph (1), Search Consulting shall, with consideration to available technology and costs associated with carrying them out, take the necessary and expected steps – including technical measures – in the interest of informing those handling the data that the data subject has requested the deletion of links to the personal data in question or copies thereof, as well as further duplication of such personal data.
(3) Paragraphs (1) and (2) are not applicable in so much as the data handling is necessary, among others:
a) for the purposes of exercising the right to freedom of expression and information;
b) for the purposes of fulfilling our obligations relating to personal data handling under European Union or Member State law, as defined therein;
c) for the purposes of archiving in the public interest, scientific and historical research or statistical purposes, in so much as the rights contained in paragraph (1) would seriously threaten such data handling or most likely make it impossible; or
d) for the submission, validation and protection of legal proceedings.
10.4 Right to restrict data handling
(1) You are entitled to request that we restrict data handling if any of the following conditions are met:
a) you argue the accuracy of the personal data, in which case the restriction is applied for the timeframe that allows for the inspection of the personal data’s accuracy;
b) the data handling is unlawful and you object to the deletion of the data, and instead request its restricted use;
c) we have no further use for the data for the purposes of data handling, but you request them for the submission, validation and defence of your legal claims; or
d) You objected to the data handling; in which case, the restriction applies to the time period required to determine whether Search Consulting’s legitimate reasons take precedence over those of the data subject.
(2) If data handling is subject to a restriction based on paragraph (1), such personal data, with the exception of storage, can only be processed with your consent, or for the submission, validation and defence of your legal claims, or in the interests of protecting the rights of other natural or legal persons, or in the important public interest of the European Union or a Member State.
(3) We shall inform you prior to the lifting of the data handling restriction.
10.5 Notification obligation related to the updating, deleting and data handling restriction of personal data
Search Consulting shall communicate any updates, deletion or data handling restriction to those recipients to whom the data have been disclosed, unless this proves to be impossible or requires excessive resources. We shall inform you of the recipients upon your request.
10.6 Right to data portability
(1) You are entitled to receive personal data applicable to you and made available to us, in an articulate, commonly used, machine-readable format, furthermore, you are entitled to forward these data to another data processor without obstruction from Search Consulting, if:
a) ata handling is based on consent or a contractual agreement; and
b) data handling takes place through automated means.
(2) In exercising the right of data portability according to paragraph (1), you are entitled to – if technically possible – request the direct transmission of personal data between data controllers.
10.7 Right to object
(1) You have the right to object, on grounds relating to your own situation, to the handling of personal data based on a legitimate interest, including profiling. In such a case, we shall not further process your personal data, unless we demonstrate compelling legitimate grounds for handling that takes precedence over your interests, rights and freedoms or relates to the submission, validation and defence of legal claims.
(2) If the personal data is processed for the purposes of direct marketing, you have the right to object, at any time, to the handling of personal data relating to you in the interest of such, which also includes profiling in so much as it relates to direct marketing.
(3) If you object to the handling of personal data for the purposes of direct marketing, the personal data can no longer be processed for this purpose.
(4) You may also exercise your right to object through automated means, based on technical specifications, relating to the use of information society services and notwithstanding Directive 2002/58/EC of the European Parliament.
(5) If the handling of personal data is for the purpose of scientific or historical research or for statistical purposes, you have the right to object, on grounds relating to your own situation, to the handling of personal data, unless the handling of data is necessary for the performance of tasks carried out in the public interest.
10.8 Right to lodge a complaint to the supervisory authority
You are entitled to lodge a complaint to a supervisory authority – particularly in your habitual residence, place of work or the Member State of the alleged infringement – if, according to your assessment, the handling of personal data related to you infringes your rights under the GDPR. The competent supervisory authority in Hungary is: National Authority on Data Protection and Freedom of Data (http://naih.hu/; 1530 Budapest, Pf.: 5.; Tel.: +36 1 391 1400; fax: +36 1 391 1410; e-mail: firstname.lastname@example.org).
10.9 Right to an effective judicial remedy against a supervisory authority
(1) You are entitled to an effective judicial remedy against the supervisory authority’s legally binding decision applicable to you.
(2) You are entitled to an effective judicial remedy if the competent supervisory authority does not respond to the complaint, or does not inform you within three months on the progress or outcome of the proceedings related to the lodged complaint.
(3) Proceedings against a supervisory authority shall be brought before the courts of the Member State where the supervisory authority is established.
10.10 Right to effective judicial remedy against the data controller or processor
(1) You are entitled to an effective judicial remedy if, according to your assessment, the handling of personal data was improperly processed as per the GDPR and, as a result, infringes your rights under the GDPR.
(2) The proceeding must be initiated against the data controller or the data processor before the courts of the Member State where the data controller or data processor has its principal place of business. Such proceedings may be initiated before the courts of the Member State of the data subject’s usual place of residence.