Privacy Policy
1. Purpose, scope and applicable law of the Privacy Policy

The purpose of this Privacy Policy is to set out the data protection and data management principles applied by VÖRÖS MARCELL MARKETING KFT., the organization’s data protection and data management policy, which the organization as data controller acknowledges as binding.

In drafting the provisions of the Privacy Policy, the organization has taken particular account of the requirements of Regulation 2016/679 of the European Parliament and of the Council ("General Data Protection Regulation" or "GDPR"), the 2011 EU Regulation on the Right to Information Self-Determination and Freedom of Information. CXII of 2013 ("Information Act"), Act V of 2013 on the Civil Code ("Civil Code") and Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Commercial Advertising Activities ("Act XLVIII of 2008").

This Privacy Policy covers the processing of data related to the website available at https://www.smart-leadgeneration.com (hereinafter referred to as the "Website"). This Privacy Policy is valid until revoked.

The purpose of the Privacy Policy is to harmonize the provisions of the other internal rules of the organization with regard to data management activities in order to protect the fundamental rights and freedoms of natural persons and to ensure the adequate processing of personal data.

Another important purpose of issuing a Privacy Policy is to ensure that by knowing and complying with it, the organization is able to process the data of natural persons lawfully.

2. Identity of the data controller

Name: VÖRÖS MARCELL MARKETING KFT.

Seat: HUNGARY, 7623 PÉCS MADÁCH IMRE UTCA 9. A lcsh. 1 em. 6 ajtó

Tax number: 28959917-1-02

Registration number: 02 09 085508

Telephone: + 3630/9277884

E-mail: lead.generator.info@gmail.com

Data Protection Officer: Marcell Voros

The Data Controller is an organization registered in Hungary.

3. Key concepts, definitions

The GDPR (General Data Protection Regulation) is the European Union's new Data Protection Regulation.

Data Controller: a natural or legal person, public authority, agency or any 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 the processing are determined by Union or Member State law, the controller or the specific criteria for the designation of the controller may also be determined by Union or Member State law.

Data Processing: any operation or set of operations which is performed upon personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Processor: a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller.

Personal data: 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, 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.

Third party: any natural or legal person, public authority, agency or any other body other than the data subject, the controller, the processor or the persons who are the controllers or processors, are authorized to process personal data under the direct control of a data processor.

Consent of the Data Subject: A voluntary, specific, informed and unambiguous indication of the data subject's wishes by which he or she signifies his or her agreement to the processing of personal data concerning him or her by means of a statement or an unambiguous act of affirmation.

Restriction of processing: the marking of stored personal data for the purpose of restricting their future processing.

Data Erasure: rendering data unrecognizable in such a way that it is no longer possible to recover it.

Data Breach: a breach of security that results in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.

4. Principles of Data Management

Personal data:

● processing must be lawful, fair and transparent for the data subject ("lawfulness, fairness and transparency")

● collected only for specified, explicit and legitimate purposes and not processed in a way incompatible with those purposes; further processing for archiving purposes in the public interest, scientific and historical research purposes or statistical purposes shall not be considered incompatible with the original purpose in accordance with Article 89(1) ("purpose limitation")

● be adequate, relevant and limited to what is necessary for the purposes for which the data are processed ("data minimization")

● be accurate and, where necessary, kept up to date; all reasonable steps must be taken to ensure that personal data which are inaccurate for the purposes of the processing are erased or rectified without undue delay ("accuracy")

● be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be kept for longer periods only if the personal data will be processed for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1), subject to the implementation of appropriate technical and organizational measures to safeguard the rights and freedoms of data subjects as provided for in this Regulation ('limited storage')

● be carried out in such a way as to ensure adequate security of personal data, including protection against unauthorized or unlawful processing, accidental loss, destruction or damage ("integrity and confidentiality"), by implementing appropriate technical or organizational measures.

The controller is responsible for compliance with the above and must be able to demonstrate such compliance ("accountability").

5. Purpose of Data Processing

The Data Controller processes personal data only for specific purposes. The data is collected and processed fairly and lawfully.

The Data Controller shall process only personal data that is necessary for the purpose of the processing and is suitable for achieving that purpose. Personal data shall be processed only to the extent and for the duration necessary to achieve the purpose.


6. Scope of the Data Processed

CONTACT

Purpose of processing: contacting, maintaining contact, providing information, requesting information.

Legal basis for processing: voluntary consent of the data subject, Article 6(1) GDPR point a).

Data processed: name (identification), e-mail address (contact), telephone number (contact).

Deadline for deletion: 2 years from the last contact.

Anyone can visit the website of the controller without having to provide any personal data beyond the technically automatic processing.

You can request the deletion or modification of your personal data by:

● by post: HUNGARY, 7623 PÉCS MADÁCH IMRE UTCA 9. A lcsh. 1 em. 6 ajtó
● by e-mail: lead.generator.info@gmail.com

7. How the Data is Processed

The Data Controller shall store the data of the data subject on its own servers and temporarily on the computers of the Data Controller. Only the Data Controller is able to process the personal data of the data subjects.

In all cases, the provision of data is voluntary, i.e. the data subject is free to decide whether or not to provide the personal data requested. If the data subject consents, the Data Controller will process the data in accordance with the applicable law and within the limits of the data subject's consent.

In order to prevent unauthorized use and misuse of the personal data processed, the Data Controller applies extensive technical and operational security measures. Our security procedures are regularly reviewed and improved in line with technological developments.

8. Technical Data and Cookie Management

Because natural persons can be associated with online identifiers, such as IP addresses and cookie identifiers, provided by the devices, applications, tools and protocols they use, this data, when combined with other information, can and may be used to create a profile of a natural person and identify that person.

Cookies are also able to remember preferences so that the user does not have to re-enter them when visiting a new page, remember previously entered data so that it does not have to be re-entered, analyze the use of the website in order to make improvements to the website as much as possible as a result of the information obtained, work according to the user's expectations, the user can easily find the information they are looking for and the effectiveness of our advertising is monitored.

If the Data Controller displays various content on the Website through external web services, this may result in the storage of some cookies that are not under the control of the Data Controller, and therefore it has no control over the data collected by these websites or external domains.

Information about these cookies is provided in the policies for the specific service. The user can set their web browser to accept all cookies, reject all cookies or notify the user when a cookie is received. The setting options can usually be found in the "Options" or "Settings" menu of the browser. The detailed information on the English website www.aboutcookies.org also helps you with the settings in different browsers.

Cookies used by the website:

Session Cookies: these are essential for navigating our website, for the operation of key features of our website and for accessing protected content. These cookies store the information you need to fill in the forms and sometimes the language you choose, and do not collect any information about you that could identify you, be used for marketing purposes or remember what other websites you have visited. Once the website is closed, these cookies are automatically deleted and the session is terminated.

Functional Cookies: these cookies detect which device you use to access our website to improve your user experience, remember your previous usage choices (such as your username, password, language, region, whether you logged in during a previous session, changes you made to text size, font or other customizable elements of the website) so that we can offer you better and more personalized features. These cookies do not track your activity on other websites and we do not use them to send you advertising through other sites.

Google Analytics Cookies: Google Analytics is Google's analytics tool that helps website and application owners to get a more accurate picture of their visitors' activities. The service may use cookies to collect information and report statistics about website usage without individually identifying visitors to Google.

9. Data Transmission

The Data Controller shall only transfer personal data to third parties if the data subject has given his or her unambiguous consent, knowing the scope of the data transferred and the recipient of the data transfer, or if the transfer is authorized by law. 

The Data Controller shall in all cases document the transfers and shall keeps records of data transfers.

10. Data Processing

The Data Controller is entitled to use a data processor for the performance of its activities. Processors do not take independent decisions and are only entitled to act in accordance with the contract concluded with the Data Controller and the instructions received. The Controller shall monitor the work of the processors. Processors shall be entitled to engage an additional processor only with the consent of the Controller.

The data processors used by the Data Controller:

DATA PROCESSING ACTIVITIES RELATED TO MARKETING, SOCIAL COMMUNICATION
The data processor: Facebook Ireland Ltd.

The data processor’s seat: 4 Grand Canal Square, Dublin Ireland The data processor's e-mail address: support@facebook.com

On the Website, plug-ins are disabled by default. They are only enabled if the user clicks on the appropriate button (Marketing cookies). By enabling the plug-in, the data subject establishes a connection with the social networking site and consents to the transfer of his or her data to Facebook.

- –

GOOGLE ANALYTICS AGGREGATED DATA ANALYTICS DATA PROCESSING ACTIVITIES
Name of data processor: Google, Mountain View, California, United States

The data processor’s seat: 4 Barrow Street, Dublin, Ireland The data processor's e-mail address: -
The Processor, under contract with the Controller, uses the Processor's Google Analytics service, which helps both the Controller and the Processor to get a more accurate picture of their visitors' activities. 

11. External service providers

In operating the Website, the Data Controller uses external service providers, with which the Data Controller cooperates.

Personal data processed in the systems of External Service Providers is governed by the respective privacy policies of the External Service Providers. The Data Controller
will use its best efforts to ensure that the personal data transmitted to it are processed by the external service provider in accordance with the law and used only for the purposes specified by the User or set out in this notice.

The Data Controller shall inform Users about the data transfers to external service providers in the context of this Notice.

External service providers:

Facebook Limited., 4 Grand Canal Square, Dublin Ireland (marketing, social media, Facebook)
Google, Mountain View, California, United States (Google Analytics aggregated data analysis)

12. Data Security, Access to Data

The Data Controller shall ensure the security of the data, take the technical and organizational measures and establish the procedural rules necessary to enforce the applicable laws, data protection and confidentiality rules. The Data Controller shall take appropriate measures to protect the data against unauthorized access, alteration, disclosure, erasure or destruction, accidental destruction or damage and against inaccessibility resulting from changes in the technology used.

The Data Controller shall keep records of the data it processes in accordance with the applicable laws, ensuring that the data are only accessible to employees and other persons acting in the interest of the Data Controller (data processors), who need to do so in order to carry out their job or duties. The data can only be accessed within the employee's organization by keeping a log. The employees of the data controller perform individual searches, individual operations on the data only at the request of the User or when necessary for the provision of the service.

13. Duration of Processing

The Controller shall delete personal data if.

Unlawful processing: if it is found that the data are being processed unlawfully, the Data Controller will delete them without delay.

At the request of the data subject (except for processing based on law): the data subject may request the erasure of data processed on the basis of his or her voluntary consent. In this case, the Data Controller will delete the data.

The data is incomplete or inaccurate - a situation that cannot be lawfully remedied - provided that deletion is not precluded by law.

The purpose of the processing has ceased or the statutory time limit for storing the data has expired. As the Data Controller provides a continuous service to the data subject, the relationship between the parties is not time-limited.

On this basis, the Controller shall process the data for as long as the relationship between the Controller and the data subject exists and for as long as the Controller is able to provide the data subject with services. All other data shall be deleted by the Controller if it is evident that the data will no longer be used, i.e. the purpose of the processing has ceased to exist.

It has been ordered by a court or the National Authority for Data Protection and Freedom of Information: where a court or the National Authority for Data Protection and Freedom of Information has issued a final order for the deletion of the data, the deletion shall be carried out by the The Data Controller. Instead of deletion, the Controller shall, after informing the data subject, block the personal data if the data subject so requests or if, on the basis of the information available to him or her, it is likely that deletion would harm the data subject's legitimate interests. Personal data blocked in this way may be processed only for as long as the processing purpose which precluded the deletion of the personal data persists.

The Data Controller shall mark the personal data it processes if the data subject contests the accuracy or correctness of the personal data, but the inaccuracy or incorrectness of the contested personal data cannot be clearly established. In the case of processing required by law, the deletion of data shall be governed by the provision of the law. In case of erasure, the Controller shall render the data unidentifiable. Where required by law, the Controller shall destroy the storage medium containing the personal data.

14. Customer relations

If the data subject has any questions or problems when using our services, he or she can contact the data controller by the means indicated on the website (telephone, e-mail, social networking sites, etc.).

The Data Controller deletes the data provided in e-mails, messages, telephone, Facebook, etc., together with the name and e-mail address of the interested party and other personal data voluntarily provided by the interested party, after a maximum of 2 years from the date of the communication.

Information about data processing not listed in this notice is provided at the time of collection.

In exceptional cases, the Service Provider shall be obliged to provide information, disclose data, hand over data or make documents available upon request of a public authority or other bodies authorized by law.

In such cases, the Service Provider shall disclose to the requester - provided that the requester has indicated the precise purpose and scope of the data - personal data only to the extent and to the extent necessary to achieve the purpose of the request is essential.

15. Rights in Relation to Data Processing

The right to request information: any person may request, through the contact details provided, information on what data the organization processes, on what legal basis, for what purpose, from what source and for how long. The request will be answered promptly, but within 30 days at the latest, by sending information to the contact details provided.

Right to rectification: any person may request the rectification of any of their data through the contact details provided. Any person who wishes to make a request may have his or her personal data corrected.

Right to erasure: Any person may request the erasure of their data by using the contact details provided. Anyone who wishes to have his or her data deleted may request this without undue delay, but within 30 days at the latest, and will be informed by means of a message sent to the contact details provided. Data that we are required to retain for legal, statutory or contractual obligations to maintain commercial records will be blocked instead of erased to prevent their use for other purposes.

Right to blocking, restriction: any person may request the blocking of their data by using the contact details provided. The blocking lasts as long as the reason stated makes it necessary to store the data. Upon request, this must be done promptly and within a maximum of 30 days and information must be sent to the contact details provided.

The right to object: any person may object to the processing of their personal data using the contact details provided. The objection must be examined within the shortest possible time from the date of the request, but not later than 15 days, a decision must be taken on the merits and information on the decision must be sent to the contact details provided.

16. Enforcement Possibilities in Relation to Data Processing

National Authority for Data Protection and Freedom of Information

Postal address: 1530 Budapest, Pf.: 5.

Address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c

Phone: +36 (1) 391-1400

Fax: +36 (1) 391-1410

E-mail: ugyfelszolgalat@naih.hu

Web: https://naih.hu

Date: December 30, 2020

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