Privacy Policy
1. Purpose and content of information
This data management information sheet (hereinafter: Data Management Information Sheet) summarizes how the Data Manager manages, uses and protects the personal data of the Contact Persons responsible for maintaining contact (hereinafter: Contact Person or You) of the legal entities that have an economic relationship with the Data Controller.
REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (April 27, 2016) on the protection of natural persons with regard to the processing of personal data and on the free flow of such data, as well as Regulation 95/46/EC (hereinafter: General Data Protection Regulation or GDPR) and CXII of 2011 on the right to self-determination of information and freedom of information. Act (hereinafter: Infotv.) is governing.
This information is provided on the basis of Article 13 of the General Data Protection Regulation.
2. Data controller
Reaction Agency Kft. (headquarters: 2821 Gyermely, Szőlőhegy dűlő 2496/2.; tax number: 27838437-2-11, company registration number: 11-09-029577, email address: hello@reactionagencyhungary.com)
3. Purpose of data management
1. Data management for the purpose of economic contact
1.1. Data subject: the contact person responsible for maintaining relations of a business company
Range of processed data: the range of minimum data required for contact, such as: your name, position, telephone number, e-mail address
Legal basis for data management:
Article 6 (1) point f) of the General Data Protection Regulation: The Data Controller processes the data of the Contact persons obtained in order to establish an economic relationship with the Company or to initiate cooperation for legitimate (economic) interests. Considering the right to freely dispose of the personal data of the Contacts, the Data Controller determines that it is necessary to manage your specific personal data in order to be able to contact the relevant business companies with inquiries, stating that an alternative solution is not possible. The Data Controller treats the data obtained in this way as confidential, so that only dedicated persons within its organization have access to this data, solely for the purpose of delivering offers related to economic activity to the Contact Person.
Duration of data management:
In the case of active contact, for an unlimited period of time, but no more than 3 years from the last contact.
1.2. In the absence of data communication: In the absence of data provision / data storage of the Contact Person, an economic relationship cannot be established between the parties, so the minimum data necessary for maintaining contact is required.
1.3. Deletion of data: As detailed above, personal data must be kept for an unlimited period of time in case of active contact. Personal data will be deleted three years after the inactive period.
1.4. Right to object: The Contact Person has the right to object to the processing of their personal data for economic purposes by means of a written message to the Data Controller.
4. Contact rights
In relation to personal data managed by the data controller, the rights of the contact person are as follows:
Contact person's right of access: The Contact Person can request information from the Data Controller on whether their data is being processed. If so, you are entitled to access your personal data and in particular the following information:
Categories of managed data, purpose of data management, transfer of data to third parties, if this has already taken place or if it is expected that this will take place in the future, planned duration of storage of personal data,
Rights and remedies related to other personal data of the contact person.
Contact person's right to correction: In case of inaccurate or incomplete personal data, you have the right to request correction of the Contact person's data.
Contact person's right to erasure: The Contact Person may request the erasure of his personal data if the purpose of data management has been fulfilled, or he objects to data management for legitimate interests, or illegal data management has taken place, or there is a reason to delete personal data based on legislation.
Contact person's right to restrict data processing: The Contact Person has the right to ask the Data Controller to limit the processing of his personal data if the data processing is inaccurate, illegal, unnecessary, exceeds the purpose of data recording, or in the event of an objection to data processing. In the case of limited data management, the Data Controller is entitled to store personal data, unless the data management was carried out with consent, or is necessary for the presentation or enforcement of legal claims, or is justified by the public interest.
Contact person's right to data portability: The Contact Person has the right to receive the personal data concerning him/her in a segmented, machine-readable format upon request, and to transmit this data to another data controller.
Contact person's right to protest: The Contact Person has the right to object at any time to the processing of his personal data on the legal basis of legitimate interest or public interest, for the reason indicated by him, in which case the Data Controller may no longer process the personal data, unless the Data Controller proves that the data processing is justified by compelling legitimate reasons that take priority over the interests, rights, and freedom of the Contact, or that are related to the presentation, enforcement, or defense of legal claims.
Automated decision-making in individual cases: The Contact Person has the right to request that the scope of the decision based on automated data management, including profiling, does not extend to him, unless it is necessary for the conclusion or fulfillment of the contract between the Contact Person and the Data Controller, or if he expressly consents to this , or legislation Page 3 of 3 enables the decision while protecting your rights and interests. In this context, you have the right to request human intervention from the Data Controller, to express your point of view, and to submit objections to the decision.
Right to compensation: If you have suffered material or non-material damage as a result of a violation of the General Data Protection Regulation, you are entitled to compensation from the Data Controller (or the data processor) for the damage suffered.
6. Evaluation of the request by the data controller
The Data Controller examines the request submitted in connection with the enforcement of the above rights without undue delay, but in any case within one month from the receipt of the request, and informs about the measures taken as a result of the request, or the reasons for the failure to take measures. If the application is complex or a large number of applications are received, the deadline can be extended by another two months. Information and measures are free of charge, except for requests that are clearly unfounded or, especially due to their repetitive nature, that are excessive. In these cases, the Data Controller will charge a reasonable fee or refuse the requested measure. Copies of your personal data managed by the Data Controller are also free of charge in the first case, for further copies we charge a fee equal to the administrative costs.
7. Complaint
You can file a complaint against the Data Controller with the supervisory authority (National Data Protection and Freedom of Information Authority, headquartered at: Szilágyi Erzsébet fasor 22/C., 1024 Budapest, website: www.naih.hu, phone number: +36 (1) 391-1400.) , and you can exercise your right to legal remedies. He is entitled to a judicial remedy against the decision of the supervisory authority or the lack thereof.
8. Built-in and default data protection
The Data Controller does everything to ensure the security of your data, and therefore applies the following security measures. Data stored electronically can only be accessed after identification and with a personal password, data stored on paper is placed in a lockable place, to which the person in charge with access rights has the key. When transmitting data, we use pseudonyms to the extent necessary. We would like to inform you that the following person within the Data Controller's organization has access to your personal data: András Mencsik, the managing director of the company.
9. Protection of business secrets
The Data Controller draws your attention to the fact that the contents of this Data Management Information Form constitute a business secret. As a contact person, you are obliged to maintain business confidentiality. In addition, you may not disclose to an unauthorized person any data that you have become aware of during contact with the Data Controller, the disclosure of which may have adverse consequences for the Data Controller or another person. The confidentiality obligation exists without time limit after the termination of the contract.
10. Other information
The Data Controller draws your attention to the fact that personal data not included in this Data Management Information Sheet should not be entered or recorded in the Data Controller's systems. If it is necessary to provide other personal data, the Data Controller will provide information on a case-by-case basis. If you have any questions to which this Data Management Notice does not provide a clear answer, please contact the Data Controller athello@reactionagencyhungary.com at e-mail address.
Budapest, October 1, 2023.