Privacy policy :: fittbaby.com

Privacy and Data Protection Policy

- effective from 2023.01.01. -

Information about the Data Manager and the Hosting provider

Information of the Data Manager

name: Edit Dankuliné Gazsovics, sole proprietor
location, business headquarters and address for complaints: 1223 Budapest, Rózsakert u. 41.
contact: phone: +36 1 3625969, +36 30 4133843

e-mail: dankuliedit@gmail.com

entrepreneur’s card number: EV-665252
data protection registration number: NAIH- 144068/2018.

(hereinafter: Data Manager)

Information of the Hosting provider

name: ATEDIN Bt.
headquarters: 1126 Budapest, Kiss János altábornagy u. 11.
court of registration, company registration number: Company Registry Court of Budapest-Capital Regional Court, Cg. 01-06-761918
contact: phone: +36 70 3662073

e-mail: info@atedin.hu

(hereinafter: Hosting provider)

1.3. Information of the payment service provider

name: Barion Payment Zrt.
headquarters: 1117 Budapest, Infopark sétány 1. I. building 5. floor 5.
court of registration, company registration number: Company Registry Court of Budapest-Capital Regional Court, Cg. 01-10-048552
contact: phone: +36 1 4647070

(hereinafter: Payment Service Provider)

Subject, adoption and scope of the Policy

2.1. Subject of the Policy

This Privacy and Data Protection Policy (hereinafter referred to as the „Policy”) governs the use of the website www.babamozgato.hu and its English website version www.fittbaby.com (hereinafter referred to as the “Website”), including free services and services subject to the payment of a subscription fee (hereinafter referred to as “Services”), and the rules governing the processing of the data provided by You, the user (hereinafter referred to as the “User”) on the website of the Data Manager as service provider in relation to the use of the services, the viewing of educational articles or the availability of audiovisual content for individual downloading via the Internet, and in connection with the contract between the Data Manager as service provider and the User in this respect (hereinafter referred to as the “Contract”), and contains information on the User’s rights in relation to data management and data protection, in particular the rights under Article 13. of Regulation (EU) 2016/679 of the EUROPEAN PARLIAMENT AND OF THE COUNCIL (27 April, 2016, General Data Protection Regulation, GDPR) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data repealing Regulation (EC) No 95/46/EC., and in Article 13/A(9) of Act CVIII of 2001 on certain aspects of electronic commerce services and information society services.

2.2. Adoption of the Policy

By accepting the Terms and Conditions electronically before clicking on the “Confirm Registration” icon during the registration process, the User expressly declares that s/he has read and accepts present Privacy Policy and agrees to be bound by it and to the processing of his/her data under the conditions set out in this Policy, in particular for the purposes and for the period of time specified herein.

By accepting the General Terms and Conditions electronically before clicking on the “OK, I subscribe” icon during the subscription process, the User expressly declares that s/he has read and accepts present Privacy Policy and agrees to be bound by it and to the processing of his/her data under the conditions set out in this Policy, in particular for the purposes and for the period of time specified herein.

In the absence of registration, by browsing the website, the User accepts present Privacy and Data Protection Policy as binding on him or her, and consents to the processing of his/her data under the conditions set out in this Policy, in particular for the purposes and for the period of time specified herein.

2.3. Amendment of the Policy

User acknowledges that Service Provider is entitled to unilaterally modify the provisions of this Policy in a manner that does not affect the purpose and legal basis of the processing. In case of amendments to these Terms and Conditions, Service Provider shall notify the registered Users of such amendments by e-mail 8 (eight) days prior to the date of entry into force of the amendment. Following the entry into force of the amendment to the Policy, by continuing to use the Website or the Service, the User accepts the changed data processing rules as an implicit conduct, the express consent of the User is not required for the amendment of the Policy.

Service Provider informs the User that the current version of the Policy is available on the Website, where it can be viewed and printed from.

2.4. Scope of the Policy

Present Privacy and Data Protection Policy is in force indefinitely.

3. Key legislation and concepts

3.1. Key legislation

The main legislation governing the Data Manager’s data processing activities are:

REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (27 April 2016) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and of repealing Regulation (EC) No 95/46/EC (general data protection regulation, hereinafter “the Regulation”);
Act CXII 2011 on the right of informational self-determination and freedom of information (hereinafter referred to as the “InfoAct”);
Act CVIII of 2001 on certain issues of electronic commerce services and information society services (hereinafter referred to as the “EcAct”);
Act CXXVII of 2007 on value added tax (hereinafter referred to as “VAT Act”);
Act CL of 2017 on the rules of taxation (hereinafter referred to as the “TaxAct”);
Act V of 2013 on the civil code (hereinafter referred to as the “Civil Code”);
Act CLV of 1997 on consumer protection (hereinafter referred to as the “Consumer Protection Act”);

3.2. Definitions of concepts

a) Policy: the present Privacy and Data Protection Policy, which contains the rules for processing data provided by the User, and contains information on User’s rights in relation to data processing and data protection;

b) GTC: the General Terms and Conditions – in addition to the provisions of the applicable mandatory legislation – define the content of the Contract between You and the Service Provider, in particular the rights and obligations of the Parties, the conditions of the Contract, the deadlines of performance, the delivery and payment terms, the liability rules, and the conditions for exercising the right of withdrawal and termination;

c) Data Manager, Service Provider: the person providing the services specified in the GTC, as defined in point 1.1;

d) User, You: a natural person either identified by the data provided during registration or browsing the Website without registration;

e) Website: the Hungarian website www.babamozgato.hu and its English version fittbaby.com;

f) Services: services provided on the Website for the viewing of educational articles or for making audiovisual content available on the Internet for individual download, including free services and services subject to the payment of a subscription fee;

g) Contract: the contract concluded between You and the Service Provider for the use of the Services of the Website upon acceptance of the GTC;

h) Donor: the User who wishes to give the subscription as a gift;

i) Recipient: the User to whom the Subscription has been donated by the Donor.

4. Description of data processing in the operation of the Website

4.1. Information about the use of cookies

4.1.1. What is a cookie?

The Data Manager uses so-called cookies when you visit the Website. A cookie is a set of letters and numbers that our website sends to your browser to save certain settings, facilitate the use of our Website and help us collect some relevant statistical information about our visitors.

Some of the cookies do not contain any personal information and cannot be used to identify the individual user, but some of them contain a unique identifier – a secret, randomly generated sequence of numbers – that is stored on your device, thus ensuring your identification. The duration of activity of each cookie is described in the relevant description of each cookie.

4.1.2 What happens if I do not consent to the use of Cookies?

If you do not agree to the use of cookies than certain features will not be available to you.

4.1.3 Legal basis for the processing of cookies

The legal basis for processing is your consent pursuant to Article 6(1)(a) of the Regulation.

4.1.4 Main characteristics of the cookies used be the Website

Google Adwords cookie: when someone visits our site, the visitor’s cookie ID is added to our remarketing list. Google uses cookies – such as NID and SID cookies – to personalize the ads you see in Google products, such as Google search. It uses such cookies for example to remember to remember your recent searches, your previous interactions with advertisements from individual advertisers or search results, and your visits to the advertisers’ websites. The AdWords conversion tracking feature also uses cookies. To track ad sales and other conversions, cookies are saved on a user’s computer when they click on an ad. Some common use of cookies include: selecting ads based on what is relevant for a particular user, improving campaign performance reporting, and avoiding displaying ads that the user has already viewed.

Google Analytics cookie: Google Analytics is Google’s analytics tool that helps website and app owners to get a more accurate picture of their visitors’ activities. The Service may use cookies to collect information and report statistics about the use of the Website without individually identifying visitors to Google. The main cookie used by Google Analytics is the “__ga” cookie. In addition to generating reports from site usage statistics, Google Analytics – together with some of the advertising cookie described above – may also be used to display more relevant advertising on Google products (such as Google Search) and across the web.

Remarketing cookies: They may appear to previous visitors or users when browsing other sites on the Google Display Network or when searching for terms related to its products or services.

Cookies strictly necessary for the operation of the Website: these cookies are essential for the use of the Website and allow you to use its essential functions. Without them, many of the Website’s features will not be available to you. The lifetime of these types of cookies is limited to the duration of the session only.

Cookies to improve user experience: these cookies collect information about your way of using the Website, such as which pages you visit most often or what error messages you receive from the Website. These cookies do not collect any information that identifies the visitor, i.e. they are completely generic and anonymous. We use the data we obtain from these cookies to improve the performance of the Website. The lifetime of these types of cookies is limited to the duration of the session only.

Session cookies: these cookies store the location of the User, the language of the browser, the currency of the payment, and their lifetime is until the browser is closed or for a maximum of 2 hours.

Last viewed product cookie: these cookies record the products last visited by the User. They have a lifetime of 60 days.

Last visited category cookie: these cookies record the last visited categories. They have a lifetime of 60 days.

Recommended products cookie: the “recommend to a friend” function records a list of products you wish to recommend. They have a lifetime of 60 days.

Mobile version, design cookie: detects the device used by the User and switches to full view on mobile. Lifetime of 365 days.

Cookie acceptance cookie: it accepts the cookie statement in the warning window when you visit the website. Lifetime of 365 days.

Shopping cart cookie: this cookie records the products placed in your shopping cart. Lifetime of 365 days.

Smart offer cookie: records the conditions under which smart offers are displayed (e.g. whether the visitor has visited the website before, or whether s/he has placed an order). Lifetime of 30 days.

Exit #2 cookie: according to option #2, the system will exit the User after 90 days. Lifetime of 90 days.

Backend ID cookie: it is the ID of the backend server serving the Website. Its lifetime lasts until the browser is closed.

Facebook pixel (Facebook cookie): Facebook pixel is a code that allows the Website to report conversions, create audiences and provide the owner with detailed analytics on how visitors use the Website. It is used to display personalized offers and ads to visitors of the Website on the Facebook interface. You can read Facebook’s privacy policy here:

https://www.facebook.com/privacy/explanation

4.1.5. Deleting cookies

For more information on how to delete cookies please see:

Internet Explorer: http://windows.microsoft.com/en-us/internet-explorer/delete-manage-cookies#ie=ie-11
Mozilla Firefox: https://support.mozilla.org/hu/kb/weboldalak-altal-elhelyezett-sutik-torlese-szamito
Safari: https://support.apple.com/hu-hu/HT201265
Chrome: https://support.google.com/chrome/answer/95647

4.2. Data processed for or in connection with the conclusion and performance of contractual duties

There may be more than one data processing operation for the purposes of conclusion and performance of contacts. Please note that data processing in relation to complaint handling and warranty management will only take place if you exercise one of these rights.

If you do not place an order in the webshop, but are only a visitor there, the processing for marketing purposes may apply to you if you give us your consent for marketing purposes.

4.2.1. Contact

When, for example, you get in touch with us by email, contact form or telephone with a question about a Service.

Contacting us in advance is not mandatory, you can subscribe on the Website without this at any point of time.

Data processed, purpose of processing, legal basis:

Data processed:

Purpos(es) of data processing:

Legal basis for processing:

Data provided by you during contact.

Contact

Your voluntary consent given to the Data Manager when contacting us [processing pursuant to Article 6.(1) a) of the Regulation]

Duration of data processing:

We will only process the data until the contact is completed.

4.2.2. Registration on the Website

Upon a successful registration, you will receive your own user account, which will be used by the Data Manager to provide the Service. If, following registration, you place a(n) subscription order(s), the Data Manager will also process the data provided during the order(s) in the user account, in accordance with the terms and conditions set out in sections 4.2.3. – 4.2.4.

Data processed, purpose of processing, legal basis:

In order to use the free services, the User is required to provide the following information during registration: name, e-mail address.

The mandatory fields are marked with a * symbol. The User’s country is automatically identified by the system.

The Data Manager processes the following data, for the following purposes and on the following legal basis:

	Data processed:	Purpos(es) of data processing:	Legal basis for processing:
1.	name:	establishing, defining the content of, amending and monitoring the fulfillment of the contract regarding the Services, enforcing claims in relation to the Services, the provision of the Service, contact	Your voluntary consent given to the Data Manager when contacting us [processing pursuant to Article 6.(1) a) of the Regulation]
2.	e-mail address:	the provision of the Service, contact	Your voluntary consent given to the Data Manager when contacting us [processing pursuant to Article 6.(1) a) of the Regulation]
3.	User’s country	the provision of the Service, contact, enforcing claims in relation to the Services	Your voluntary consent given to the Data Manager when contacting us [processing pursuant to Article 6.(1) a) of the Regulation]

The User may provide his/her telephone number during registration in order to facilitate contact, but this information is optional.

The Data Manager shall inform the User of the purposes of data processing under this point prior to the registration of the optional data provided for the purposes of this point. Data Manager may process the following data only for the purposes and the period specified below, subject to the consent of the User given electronically during registration.

Data processed:

Purpos(es) of data processing:

Legal basis for processing:

phone number

contact

Your voluntary consent given to the Data Manager when contacting us [processing pursuant to Article 6.(1) a) of the Regulation]

Duration of processing:

Processing of the mandatory data will continue until your consent to registration is withdrawn. The withdrawal of the consent will result in the termination of your user account and the deletion of the data processed in your user account, however, the data related to the subscription order(s) already placed will continue to be processed by the Data Manager, as described in sections 4.2.3.- 4.2.5.

The User may prohibit the processing of optional data at any time during the registration and subsequently during the provision of the Service. To this end, the Service Provider shall ensure the possibility of deleting, in particular the data concerned, from the user account and prohibiting their use for the purposes set out in this clause, as well as the possibility to unsubscribe from electronic advertisements and newsletters.

4.2.3 Subscriber data, billing data

Data processing is carried out for the purposes of creating and fulfilling the contract for the Services to which the subscription relates, and for the purposes of issuing and sending invoices in accordance with the law, and for the purposes of keeping accounting records. Pursuant to Section 159(1) of the VAT Act, the Data Manager must issue an invoice for the provision of the Service and keep it at least until the right to assess the tax has expired.

Data processed, purpose of processing, legal basis:

In order to use the services subject to the payment of a subscription fee, in addition to the information already provided during subscription the User is required to provide the following billing information: billing name, billing address.

The mandatory fields are marked with a * symbol or and in the event that mandatory fields are not filled in, the system issues a warning and marks the incompletely filled field(s) in red. The User’s country is automatically identified by the system.

The Data Manager processes the following data, for the following purposes and on the following legal basis:

	Data processed:			Purpos(es) of data processing:	Legal basis for processing:
1.	name:			establishing, defining the content of, amending and monitoring the fulfillment of the contract regarding the Services, enforcing claims in relation to the Services, the provision of the Service, contact	Performance of the contract. [processing of data pursuant to Article 6.(1)(b) of the Regulation] The legitimate interest of the Data Manager [processing pursuant to Article 6.(1)(f) of the Regulation]
2.	e-mail address:			the provision of the Service, billing the charges for the Services, contact, enforcing claims in relation to the Services contact	Performance of the contract. [processing of data pursuant to Article 6.(1)(b) of the Regulation]
3.	billing name:			billing the charges for the Services, contact, enforcing claims in relation to the Services	Performance of the contract. [processing of data pursuant to Article 6.(1)(b) of the Regulation] The legitimate interest of the Data Manager [processing pursuant to Article 6.(1)(f) of the Regulation]
4.		billing address:	billing the charges for the Services, contact, enforcing claims in relation to the Services		Performance of the contract. [processing of data pursuant to Article 6.(1)(b) of the Regulation] The legitimate interest of the Data Manager [processing pursuant to Article 6.(1)(f) of the Regulation]
5.		User’s country:	provision of the Service, billing the charges for the Services, contact, enforcing claims in relation to the Services		Performance of the contract. [processing of data pursuant to Article 6.(1)(b) of the Regulation] The legitimate interest of the Data Manager [processing pursuant to Article 6.(1)(f) of the Regulation]

If you have placed a subscription order, the provision of the above data and their processing is essential for the performance of the contract and for the issuing, sending and storage of the invoice as an accounting document.

Duration of processing:

The name, e-mail address and country of the User are processed pursuant to Civil Code § 6:22, paragraph(1) of the Civil Law Statute of Limitations, for 5 years.

With regard to billing name and address data, invoices issued must be kept at least until the statute of limitations for the right to tax assessment has expired pursuant to Section 179 (1) of the VAT Act. Pursuant to Article 202 (1), the right to tax assessment expires five years after the last day of the calendar year in which the tax should have been declared, reported or notified, or in the absence of declaration, reporting or notification, the tax should have been paid. The limitation period for the right to assess tax may be extended in cases provided for in Article 203.

4.2.4. Gifting a subscription

In case of gifting a subscription, data processing is carried out in order to establish and perform the contract for the Services to which the subscription relates, and to issue and send the invoice in accordance with the law, and to fulfil the obligation to keep accounting records. Pursuant to Section 159 (1) of the VAT Act, the Data Manager must issue an invoice for the provision of the Services and keep it at least until the right to assess the tax has expired.

During the data management process, the Donor will provide his/her own data.

To use the Service, the Recipient must register herself, and in doing so registers his/her own personal data. This data is subject to processing described in 4.2.2.

Data processed, purpose of processing, legal basis:

In order to gift a subscription, the Giver is required to provide the following information: name of Donor, e-mail address of Donor, billing address, phone number.

In the event that mandatory fields are not filled in, the system issues a warning and marks the incompletely filled field(s) in red. The User’s country is automatically identified by the system.

The Data Manager processes the following data, for the following purposes and on the following legal basis:

	Data processed:			Purpos(es) of data processing:	Legal basis for processing:
1.	name of Donor:			establishing, defining the content of, amending and monitoring the fulfillment of the contract regarding the Services, enforcing claims in relation to the Services, the provision of the Service, contact	Performance of the contract. [processing of data pursuant to Article 6.(1)(b) of the Regulation] The legitimate interest of the Data Manager [processing pursuant to Article 6.(1)(f) of the Regulation]
2.	e-mail address of Donor:			the provision of the Service, billing the charges for the Services, contact, enforcing claims in relation to the Services contact	Performance of the contract. [processing of data pursuant to Article 6.(1)(b) of the Regulation]
3.	country of Donor:			the provision of the Service, billing the charges for the Services, contact, enforcing claims in relation to the Services	Performance of the contract. [processing of data pursuant to Article 6.(1)(b) of the Regulation] The legitimate interest of the Data Manager [processing pursuant to Article 6.(1)(f) of the Regulation]
4.		billing address:	billing the charges for the Services, contact, enforcing claims in relation to the Services		Performance of the contract. [processing of data pursuant to Article 6.(1)(b) of the Regulation] The legitimate interest of the Data Manager [processing pursuant to Article 6.(1)(f) of the Regulation]
5.		phone number:	contact		Performance of the contract. [processing of data pursuant to Article 6.(1)(b) of the Regulation]

If you have placed a subscription order as a gift, the provision of the above personal data and their processing is essential for the performance of the contract and for the issuing, sending and storage of the invoice as an accounting document.

Duration of processing:

The name of the Donor, the e-mail address of the Donor, the country of the Donor and the telephone number of the Donor are data processed for 5 years, as per the Civil Law Statute of Limitations specified in Civil Code 6:22 (1).

With regard to the name of the Donor as the billing name and billing address data, invoices issued must be kept at least until the statute of limitations for the right to tax assessment has expired pursuant to Section 179 (1) of the VAT Act. Pursuant to Article 202 (1), the right to tax assessment expires five years after the last day of the calendar year in which the tax should have been declared, reported or notified, or in the absence of declaration, reporting or notification, the tax should have been paid. The limitation period for the right to assess tax may be extended in cases provided for in Article 203.

4.2.5. Further data processed during the performance of the contract

Once Data Manager has confirmed your subscription order and a contract for the subscription Services has been concluded, the Data Manager will process the following data for the purposes and on the legal basis set out below in order to fulfil the contract:

	Data processed:			Purpos(es) of data processing:	Legal basis for processing:
1.	order number(s):			establishing, defining the content of, amending and monitoring the performance of the Contract, enforcing claims in relation to it, the provision of the Service	Performance of the contract. [processing of data pursuant to Article 6.(1)(b) of the Regulation] The legitimate interest of the Data Manager [processing pursuant to Article 6.(1)(f) of the Regulation]
2.	details of the videos included in the subscription			defining the content of, amending and monitoring the performance of the Contract, enforcing claims in relation to it, the provision of the Service	Performance of the contract. [processing of data pursuant to Article 6.(1)(b) of the Regulation] The legitimate interest of the Data Manager [processing pursuant to Article 6.(1)(f) of the Regulation]
3.	the amount of the subscription fee			monitoring the performance of the Contract, enforcing claims in relation to it	Performance of the contract. [processing of data pursuant to Article 6.(1)(b) of the Regulation] The legitimate interest of the Data Manager [processing pursuant to Article 6.(1)(f) of the Regulation]
4.		start and end date of subscription:	defining the content of, amending and monitoring the performance of the Contract, enforcing claims in relation to it, the provision of the Service		Performance of the contract. [processing of data pursuant to Article 6.(1)(b) of the Regulation] The legitimate interest of the Data Manager [processing pursuant to Article 6.(1)(f) of the Regulation]
5.		date and amount of payment made	monitoring the performance of the Contract, enforcing claims in relation to it		Performance of the contract. [processing of data pursuant to Article 6.(1)(b) of the Regulation] The legitimate interest of the Data Manager [processing pursuant to Article 6.(1)(f) of the Regulation]

Duration of processing:

The data are processed for 5 years, as per the Civil Law Statute of Limitations specified in Civil Code 6:22 (1).

4.2.6. Warranty management and the handling of other customer complaints

The data management process is carried out in order to deal with warranty complaints.

Providing the following data is mandatory during warranty management and other customer complaints, and Data Manager processes data for the following purposes and on the following legal basis:

	Data processed:	Purpos(es) of data processing:	Legal basis for processing:
1.	name:	enforcing claims in relation to the Contract	Performance of the contract. [processing of data pursuant to Article 6.(1)(b) of the Regulation] To comply with the legal obligation to which the Data Manager is subject [processing pursuant to Article 6.(1)(c) of the Regulation]
2.	address:	enforcing claims in relation to the Contract, contact	Performance of the contract. [processing of data pursuant to Article 6.(1)(b) of the Regulation] To comply with the legal obligation to which the Data Manager is subject [processing pursuant to Article 6.(1)(c) of the Regulation]
3.	e-mail address and/or phone number:	enforcing claims in relation to the Contract, contact	Performance of the contract. [processing of data pursuant to Article 6.(1)(b) of the Regulation] To comply with the legal obligation to which the Data Manager is subject [processing pursuant to Article 6.(1)(c) of the Regulation]

If you have requested warranty management or have other customer complaints, the provision and processing of the data are essential.

Duration of processing:

If you are a consumer, we are obliged to keep your warranty claims and other costumer complaints, as well as the data provided in the course of these, for 5 years, pursuant to Section 17/A (7) of the Consumer Protection Act.

If you are not a consumer, warranty claims and other customer complaints, as well as the data provided in the course of such complaints, are subject to the provisions of the Civil Code 6:22 (1) of the Civil Law Statue of Limitations, and are processed for 5 years.

4.2.7. Data processed in relation to the justification of consent

During registration, placing a subscription order and newsletter subscription, the IT system stores consent related IT data for later evidence.

The Data Manager processes the following data, for the following purposes and on the following legal basis:

Data processed:

Purpos(es) of data processing:

Legal basis for processing:

date of consent

establishing, defining the content of, amending and monitoring the performance of the Contract, enforcing claims in relation to it

Performance of the contract. [processing of data pursuant to Article 6.(1)(b) of the Regulation]

To comply with the legal obligation to which the Data Manager is subject [processing pursuant to Article 6.(1)(c) of the Regulation]

The legitimate interest of the Data Manager [processing pursuant to Article 6.(1)(f) of the Regulation]

IP address of the data subject

establishing, defining the content of, amending and monitoring the performance of the Contract, enforcing claims in relation to it

Performance of the contract. [processing of data pursuant to Article 6.(1)(b) of the Regulation]

To comply with the legal obligation to which the Data Manager is subject [processing pursuant to Article 6.(1)(c) of the Regulation]

The legitimate interest of the Data Manager [processing pursuant to Article 6.(1)(f) of the Regulation]

Duration of processing:

Pursuant to Civil Code 6:78, the Data Manager must be able to verify your consent at a later stage, therefore the data are subject to the provisions of Civil Code 6:22(1) of the Civil Law Statute of Limitations, and will be processed for a period of 5 years.

4.3. Data processing for marketing purposes

4.3.1. Remarketing

Data management for remarketing purposes is carried out using cookies.

Data processed

Data processed by cookies as defined in the cookie notice.

Duration of processing

More information is available on the retention period of a given cookie here:

Google general cookie information:

https://www.google.com/policies/technologies/types/

Google Analytics information:

https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage?hl=hu

Facebook information:

https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen

Legal basis for data processing

Your voluntary consent given to the Data Manager by using the Website [processing pursuant to Article 6.(1) a) of the Regulation].

4.4. Other data processing

If Data Manager intends to carry out further processing, s/he shall provide prior information on relevant circumstances of the processing (legal background and legal basis of the processing, purpose of the processing, scope of the data processed, duration of the processing).

Please be informed that the Data Manager must comply with written requests for data from public authorities based on a legal mandate. In accordance with Article 25/E(1) of the Data Protection Act, Data Manager shall keep records of data transfers, in particular to which authority, which personal data, on what legal basis and when Data Manager has transferred the data – and Data Manager shall provide information on the content of such records upon requests, unless the provision of such information is excluded by law.

4.5. Data management on Social Networking sites

Data Manager hereby informs the User that some of the educational articles and audiovisual content of the Website is also displayed on Instagram/Babamozgato, Facebook/Babamozgato and YouTube/Babamozgato, and that by clicking on the icons provided on the Website the User can access the Data Manager’s Instagram, Facebook and YouTube pages.

If the User visits Data Manager’s Instagram, Facebook or YouTube pages, the processing of any data collected in the course of such visits shall be subject to Instagram’s, Facebook’s or YouTube’s own data usage and data processing policies.

5. Information on the use of data processors and their activities related to data processing

5.1. Processing with the purpose of storing personal data

The hosting service for the Data Manager is provided by the following partner:

name of data processor: ATEDIN Bt.
headquarters of data processor: 1126 Budapest, Kiss János altábornagy u. 11.
court of registration of data processor: Company Registry Court of Budapest-Capital Regional Court
registration number of data processor: Cg. 01-06-761918
contact details of data processor: phone: +36 70 3662073

e-mail: info@atedin.hu

(herein after: Hosting Provider)

5.2. Processing of data related to online payments

Payment service for Data Manager is provided by the following partner:

name of data processor: Barion Payment Zrt.
headquarters of data processor: 1117 Budapest, Infopark sétány 1. I. building 5. floor 5.
court of registration for data processor: Company Registry Court of Budapest-Capital Regional Court
company registration number of data processor: Cg. 01-10-048552
contact of data processor: phone: +36 1 4647070

e-mail sending page: https://www.barion.com/hu/ugyfelszolgalat/barionnal-fizettem/

(hereinafter: Payment Service Provider)

5.3. Processing of data related to billing

The billing system service for the Data Manager is provided by the following partner:

name of data processor: KBOSS.hu Kft. (Számlázz.hu)
headquarters of data processor: 1031 Budapest, Záhony utca 7.
court of registration of data processor: Company Registry Court of Budapest-Capital Regional Court
registration number of data processor: Cg. 01-09-303201
contact details of data processor: phone: not available

e-mail: info@szamlazz.hu

(hereinafter: Billing Service Provider)

The Billing Service Provider, as a data processor, contributes to the registration of accounting documents on the basis of a contract with the Data Manager. In the course of this, the Billing Service Provider as data processor shall process the provided invoicing data (name, address/registered office, tax number in the case of an organization) to the extent necessary for accounting records, and for the period of time pursuant to Section 179 (1) of the VAT Act, and shall delete them thereafter.

5.4. Processing of data related to accounting service

The accounting service for the Data Manager is provided by the following partner:

name of data processor: DIKSER Kereskedelmi és Szolgáltató Korlátolt Felelősségű Társaság (Vezér Könyvelő és Gazdasági Tanácsadó Iroda)
headquarters of data processor: 2440 Százhalombatta, Ifjúság útja 7.
court of registration of data processor: Company Registry Court of Budapest Environs Court
registration number of data processor: Cg. 13-09-067721
contact details of data processor: phone: +36-23-550-076; +36-20-4371811

e-mail: info@vezeriroda.hu

(hereinafter: Accountant)

The Accountant, as a data processor, contributes to the registration of accounting documents on the basis of a contract with the Data Manager. In the course of this, the Accountant as data processor shall process the provided invoicing data (name, address/registered office, tax number in the case of an organization) to the extent necessary for accounting records, and for the period of time pursuant to Section 179 (1) of the VAT Act, and shall delete them thereafter.

5.5 Limitation of liability for the activities of data processors

The Data Manager shall not be liable for the activities of data processors specified in this Section 5, and the Service Provider hereby excludes its liability - to the extent and in cases permitted by applicable law - for any infringement, breach of contract, non-contractual tort caused by any data processor, or otherwise due to technical or other failure in the interest of any data processor.

6. Your rights during data processing

Under the Policy you have the following rights during the period of processing:

the right to withdraw consent,
access to personal data and information relating to data processing,
the right of rectification,
restriction of processing,
the right to erasure,
the right to object,
the right to portability.

If you wish to exercise your rights, this will involve your identification and the Data Manager will need to communicate with you. You will therefore be required to provide personal data for identification purposes (but identification will only be based on data that the Data Manager already holds about you) and, if you send your complaint by email, your complaint about the processing will be available in the Data Manager’s email account within the time period specified in this Policy in relation to complaints.

If you have been a subscriber and would like to be identified for complaint or warranty purposes, please include your subscription order number. This will also allow us to identify you as a subscriber.

The Data Manager will respond to complaints about data processing within no more than 30 days.

6.1. The right to withdraw consent

You have the right to withdraw your consent at any time, provided that the legal basis for the processing is your voluntary consent. In such cases, your data will be deleted from our systems.

However, please note that cancellation of an outstanding subscription order may result in our inability to provide you with the Service. In addition, if the subscription has already expired, we cannot delete billing data from our systems due to accounting regulations, and if you have a debt to us, we may process your data following your withdrawal of consent on the basis of our legitimate interest in the recovery of the debt.

6.2. The right of access to personal data

You have the right to receive feedback from the Data Manager as to whether or not your personal data is being processed and, if it is being processed, you have the right to:

have access to the personal data processed, and
receive from the Data Manager the following information:

the purpose(es) of data processing;
the categories of your personal data being processed;
information about the recipients or categories of recipients to whom or with which the personal data have been or will be disclosed by the Data Manager, including in particular recipients in third countries or international organisations;
the envisaged period of storage of the personal data or, where this is not possible, the criteria for determining that period;
your right to obtain from the Data Manager the rectification, erasure or restriction of the processing of personal data concerning you and, in the case of processing based on legitimate interest, the right to object to the processing of such personal data;
the right to lodge a complaint with a supervisory authority;
if the data were not provided by You, any available information regarding their source;
the fact of automated decision-making (where such a process is used), including profiling and, at least in these cases, clear information on the logic used and the significance and likely consequences for you of such processing.

The purpose of exercising this right may be to ascertain and verify the lawfulness of the processing, and therefore, in the event of repeated requests for information, the Data Manager may charge reasonable fees for the provision of information.

Data Manager provides you access to personal data by sending you the personal data and information processed by email after you have identified yourself. If you are a registered user, we will provide access by you logging into your account, where you can view and verify the personal data we process about you.

In your request, please indicate whether you want access to your personal data or information on data management.

6.3 The right of rectification

You have the right to, upon request, have inaccurate personal data relating to you be corrected by the Data Manager without delay.

6.4. The right to restriction of processing

You have the right to have the Data Manager restrict processing at your request if one of the following conditions is met:

you contest the accuracy of the personal data, in which case the restriction shall apply for the period of time necessary to allow Data Manager to verify the accuracy of the personal data; if the accuracy of the data can be established immediately, no restriction shall apply;
the data processing in unlawful, but you object to the deletion of the data for any reason (for example because the data are important to you for the purposes of pursuing a legal claim) and you do not request the deletion of the data but instead request the restriction of their use;
the Data Manager no longer needs the personal data for the purposes for which they are processed, but you require them for the establishment, exercise or defence of legal claims; or
you have objected to the processing, but the Data Manager may have a legitimate interest in the processing, in which case the processing shall be restricted until it is established whether the Data Manager’s legitimate grounds prevail over your legitimate grounds.

If data processing is restricted, such personal data may be processed - with the exception of storage – only with the consent of the person the data is related to, or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person or of an important public interest of the Union or of a Member State.

The Data Manager will inform you at least 3 working days in advance prior to the lifting of the restrictions.

6.5. The right to erasure – the right to be forgotten

You have the right to have the Data Manager delete personal data concerning you without undue delay if one of the following grounds applies:

the personal data are no longer necessary for the purposes for which they were collected or otherwise processed by the Data Manager;
you withdraw your consent and there is no other legal basis for the processing;
you object to the processing based on legitimate interest, and there is no overriding legitimate ground (i.e. legitimate interest) for the processing;
the personal data have been unlawfully processed by the Data Manager and this has been established on the basis of the complaint;
the personal data must be erased in order to comply with a legal obligation under Union or Member State law to which the Data Manager is subject.

If the Data Manager has disclosed personal data about you for any lawful reason and is required to delete it for any of the reasons set out above, Data Manager shall take the reasonable steps, including technical measures, and taking into account the available technology and the cost of implementation, to inform the other data processors that you have requested the deletion of the links to, or copies or duplicates of the personal data in question.

Erasure does not apply where the procession is necessary:

for the exercise of the right to freedom of expression and information;
to comply with an obligation under Union or Member State law to which the Data Manager is subject to and which requires the processing of personal data (such as processing in the context of billing where the storage of invoices is required by law) or for the performance of a task carried out in the interest of the public or the exercise of the power of public authority vested in the Data Manager;
on grounds of public interest relating to public health;
for archiving purposes in the public interest, scientific and historical research purposes or statistical purposes, where your right to erasure would be likely to render such data processing impossible or would seriously jeopardize it.
for the presentation, exercise and defence of legal claims (e.g. if the Data Manager has a claim against you and you have not yet satisfied it, or if a consumer or data management complaint is pending).

6.6. The right to portability

Where the processing is based on your voluntary consent or is necessary for the performance of Contract, or where the processing is carried out by automated means, you have the right to request from the Data Manager the data you have provided, for the purpose of transferring them to another data controller. The Data Manager will provide the data to you in JSON and html format.

If it is technically feasible, you may request that the Data Manager transfer the data – in JSON, html format – directly to another Data Manager.

6.7. The right to object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data based on Article 6(1)(e) (performance of a task carried out in the interest of the public or the exercise of the power of public authority) or (f) (legitimate interests of the Data Manager) of the GDPR. In such cases, the Data Manager may no longer process the personal data unless Data Manager demonstrates compelling legitimate grounds for the processing, which override your interests, rights and freedoms, or are related to the presentation, exercise and defence of legal claims.

Where personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purposes, including profiling where it is related to direct marketing. If you object to the processing of your personal data for direct marketing purposes, your personal data may no longer be processed for those purposes.

6.8. Automated decision-making

You have the right not to be subject to a decision based solely on automated processing (including profiling) that would have legal effects concerning you or would similarly significantly affect you.

The above does not apply if the decision:

is necessary for the conclusion or performance of a contract between you and the Data Manager
is permitted by Union or Member State law applicable to the Data Manager which also lays down appropriate measures to protect your rights and freedoms and legitimate interests; or
is based on your explicit consent.

In cases under (a) and (c), the Data Manager shall take appropriate measures to safeguard the rights, freedoms and legitimate interests of the person(s) the data concerns, including at least the right to obtain human intervention by Data Manager, to express his or her point of view and to object to the decision.

7. Data security measures

The Data Manager declares that s/he has implemented appropriate security measures – taking into account the state and science of technology and the cost of implementation, the nature, scope, context and purposes of processing, and the varying degrees of probability ad severity of the risk to the rights and freedoms of natural persons – to protect personal data against unauthorized access, alteration, disclosure and against inaccessibility resulting from changes in the technology used.

The Data Manager will make every effort to ensure that its data processors also take appropriate data security measures when working with your personal data, as far as organizational and technical possibilities allow.

8. Legal remedies

In order to assert your rights, you may, in accordance with Article 22 and Chapter VI. of the InfoAct

request the National Authority for Data Protection and Freedom of Information (postal address: 1363 Budapest, PO Box 9, e-mail: ugyfelszolgalat@naih.hu) to examine the lawfulness of the Data Manager’s action if you believe that the Data Manager is restricting the exercise of your rights under Section 6 of these Rules or refusing your request to exercise those rights, or
request the National Authority for Data Protection and Freedom of Information to initiate proceedings of data protection if in your opinion during the processing of your personal data the Data Manager or a data processor acting on his/her behalf or at his/her instructions is in breach of the provisions on the processing of personal data laid down by law or by a binding legal Act of the European Union.

If in your opinion

the Data Manager or a data processor acting on his/her behalf or at his/her instructions processes your personal data in breach of the requirements for the processing of personal data laid down by law or by a legally binding Act of the European Union;
the Data Manager or a data processor acting on his/her behalf or at his/her instructions infringes the provisions on the processing of personal data laid down by law or by a legally binding Act of the European Union and thereby causes damage to you;
the Data Manager or a data processor acting on his/her behalf or at his/her instructions infringes the provisions on the processing of personal data laid down by law or by a legally binding Act of the European Union and thereby violates your right to privacy,

you may take the Data Manager or this data processor to court in accordance with the provisions of Articles 23-24 of the InfoAct and pursue the claims set out therein.

9. Processing for purposes other than those set out in this Policy

If the Data Manager wishes to carry out further processing of data under this Policy for purposes other than those for which they were collected, Data Manager will inform you of the purposes of the intended processing and will provide the following information prior to further processing:

the envisaged period of storage of the personal data or, where this is not possible, the criteria for determining that period;
your right to obtain from the Data Manager access to the personal data concerning you, their rectification, erasure or restriction of the processing, and in the case of processing based on consent or contractual agreement, the right to portability;
in the case of processing based on consent, the right to withdraw your consent at any time;
the right to lodge a complaint with a supervisory authority;
whether the provision of personal data is based on contractual obligation or is a prerequisite for the conclusion of a contract, whether you are under an obligation to provide the personal data and the possible consequences of not providing the data;
the fact of automated decision-making (where such a process is used), including profiling and, at least in these cases, clear information on the logic used and the significance and likely consequences for you of such processing.

Processing for any other purpose may only start following the above steps. Where the legal basis for processing is consent, you must give your consent to the processing in addition to the provided information.

10. Further provisions

10.1.

Present Policy contains all relevant information on data processing in relation to the operation of the Website in accordance with REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data repealing Regulation (EC) No 95/46/EC, and in accordance with Act CXII of 2011 (InfoAct).

10.2.

Unless otherwise specified, the statements and notifications required under this Policy shall be made in writing and delivered personally, by registered letter with acknowledgement of receipt, by courier or by e-mail to the address of the Data Manager as set out in point 1., or to the address provided by the User during registration. Statements and notices under this Policy shall be deemed to have been served on the following dates:

in the case of personal delivery or delivery by courier service, on the date of signature or refusal of signature of the acknowledgement of receipt (courier service record) by the addresse;
in the case of a postal item sent by registered mail with acknowledgement of receipt, on the date of receipt indicated on the acknowledgement of receipt or, in the absence of a receipt, on the fifth working day after the attempted delivery of the item;
in the case of delivery via e-mail, when the reading of the e-mail has been confirmed by the recipient by means of an automatic confirmation or a separate confirmation e-mail.

10.3.

If any part or provision of these Terms and Conditions becomes invalid, this shall not affect the validity of the remaining provisions of these Terms and Conditions, unless the parties would not have accepted the Terms and Conditions without the invalid provision.

10.4.

To matters not regulated in this Policy the provisions of Hungarian law shall apply, in particular Act V. of 2013 on the Civil Code, Act CXII of 2011 on the Right of Informational Self-Determination and Freedom of Information, and Act CVIII of 2001 on e-commerce services and certain aspects of information society services.

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Privacy and Data Protection Policy

We consider data protection important