Privacy & Cookies Policy

This Privacy & Cookies Policy describes how Absolvo Consulting Kft. (“Absolvo” or the “Data Controller”) collects, uses, shares, and otherwise processes Personal and Other Data (defined below) about Visitors to our website https://absolvo.hu/en/

By visiting our website You (the “User”) accept all the conditions described in our Privacy & Cookies Policy, please read our Policy carefully before you visit and use our website and its services.

1. Overview

Absolvo is the Data Controller of the Data we process, and is therefore responsible for ensuring that the systems and processes we use are compliant with data protection laws, to the extent applicable to us. Absolvo personnel are also required to comply with this Privacy & Cookies Policy when dealing with Data.

About the Data Controller:

Company name: Absolvo Consulting Kft.

Registered seat: H-1115 Budapest, Bartók Béla út 105-113.

Represented by: Tamás Horgos, General Manager

E-mail: [email protected]

Phone: + 36 1 279 1979

2. Data provided by the website Users

Website Users can provide Data and other information to Data Controller:

  • By proactively and expressly using website’s built-in forms such as contact form, newsletter subscription (if applicable) and event registration and providing Data Controller with their consent (see part I)
  • Data related to their visit and usage of the website and its services (cookies – see part II)

 

I. Data provided by Users proactively and expressly

1. Collected range of Data, Purpose of Data Collection

Users can contact Data Controller directly via the website’s contact form placed on the bottom of the landing page and under the menu “Contact”. Users are expected to use this form with the aim of requesting information about the services introduced on the website, asking specific questions, sharing comments with regards to the website and / or services or enquiring for Data Controller’s business operation and services. The Data Controller’s purpose of collecting and storing Data given and submitted by contact form is to provide appropriate information to Users, provide answers and keep contact with Users interested in Data Controller’s services and handle / manage comments and observations addressed / shared by the Users.

Users can subscribe to Data Controller’s newsletter to regularly get business-related contents, information about latest market trends, relevant publications, surveys of the Data Controller or get informed about upcoming professional events or workshops.

Users can register to Data Controller’s actual events, published on the website with the aim of participation in person and get first-hand information about the topic of the event from the invited speakers.

1.a. To submit the contact form, the following Data are requested to be given by Users (data indicated by * are obligatory):

Full name*
Company name*
Direct e-mail address*
Message text*
Consent to data controlling* (see below)

1.b: To subscribe to Absolvo’s newsletter, the following Data are requested to given by Users (data indicated by * are obligatory):

Full name*
Company name*
Direct e-mail address*
Consent to data controlling* (see below)

1.c: To register to an actual event, published on the website, the following Data are reqested to given by Users in order to enable Absolvo to record and follow-up User’s registration, share instructions about participation fee payment and provide Users with all the necessary information about the event to ensure User’s participation.

Full name*
Company name*
Position*
E-mail address*
Phone number*
Invoice name and address*
Preliminary questions to the event agenda

1.d. To register to an event where tickets are sold online and required immediate ticket purchase to secure registration, the following Data are requested to given by Users (data indicated by * are obligatory):

Full name*
Company name
Direct e-mail address*
Invoice name and address*
VAT number (if applicable)

The following Data are recorded automatically to secure and track transactions:

IP address*
Date, time and amount of transaction*

2. Legal Basis and Duration of Data Controlling

The data controlling activity of Data Controller is based on Users expressed consent. Data Controller does not audit the genuineness of Data provided by the Users, ensure appropriateness of Data is responsibility of Users solely. Data Controller does not take any responsibility derived from wrong, invalid or 3rd parties’ data provision.

If in the context of events, fee payment / ticket purchase is applicable and transaction is made, the data controlling activity of Data Controller is based on the necessity of controlling for the performance of a contract.

Contacting Absolvo by Users via contact form, invalid event registration with unpaid fees: during the existence of the original data controlling purpose, Data Controller controls Users’ data max. 180 days after the definite closing the bilateral communications between the Data Controller and User unless User asks for deletion of his / her Data or withdraws his / her consent to data controlling.

Newsletter subscription: expressed consent of Users is valid until the expressed withdrawal of consent given by Users.

Event registration with fee payment / ticket purchase: Data given by users or collected in order to secure the contract performance are controlled until the time necessary for the purpose of the data controlling and required to be retained in-line with applicable laws.

Data Controller deletes immediately all the Data controlled from Users if the original purpose of data controlling ends or the given deadline expires or if User declares so, except in case of the purpose of contract performance.

3. Sharing of Data, Data Processing

Data Controller may share Data with the purpose of Data Processing with suppliers and service providers to enable such parties to perform functions on our behalf and under our instructions in order to carry out the purpose identified above. We require such parties by contract to provide reasonable security for Personal Data and to use and process such Personal Data on our behalf only.

Entitled Data Processors on behalf of the Data Controller:

  • Webhosting: DotRoll Kft. (H-1148 Budapest, Fogarasi út 3-5.)
  • Server operation, IT system administration: Puzzle-Trade Kft. (2167 – Vácduka, Deák utca 11.)
  • CRM system maintenance: Harmati Róbert ev.
  • Newsletter: Mailchimp – The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA https://mailchimp.com/legal/privacy/
  • Website visit analytics: Google Analytics – Google LLC (“Google”), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. https://policies.google.com/privacy?hl=en-GB
  • Platform, application, software and system integrations for online event organization and ticket purchase: Ticketninja: Szintézis-Net Kft. (9024 Győr, Vasvári Pál út 1/c)
  • Secure bank service background and payment solution for online event ticket purchase: Simple Pay: OTP Mobil Kft. (1093 Budapest, Közraktár u. 30-32.)

Data Controller keeps the right to involve additional service providers in data processing with the condition of immediate update of the list of Data Processors’ as part of this Privacy & Cookies Policy.

4. Data Subject Rights

If you are in the European Economic Area (EEA) you have the following rights:

  • Access. Subject to certain exceptions, you have the right to request a copy of the Personal Data we are processing about you, which we will provide to you in electronic form. At our discretion we may require you to prove your identity before providing the requested information.
  • Rectification. You have the right to require that any incomplete or inaccurate Personal Data that we process about you is amended.
  • Deletion. You have the right to request that we delete Personal Data that we process about you, unless we are required to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
  • Restriction. You have the right to request that we restrict our processing of your Personal Data where:
    • you believe such data to be inaccurate;
    • our processing is unlawful; or
    • we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not want us to delete it.
  • Portability. You have the right to request that we transmit the Personal Data we hold in respect of you to another data controller, where this is:
    • personal information which you have provided to us; and
    • we are processing that data on the basis of your consent or in order to perform our obligations under contract to you
  • Objection. Where the legal justification for our processing of your Personal Data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation.  We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.
  • Withdrawing Consent.  If you have consented to our processing of your Personal Data, you have the right to withdraw your consent at any time, free of charge.

If you have questions or comments regarding this Privacy & Cookies Policy, our privacy practices or you have questions or doubts if Data Controller’s practices meet the legal requirement you have the opportunity to contact us and ask for more information or clarification via emailing to [email protected] or posting  to Absolvo Consulting Kft., H-1115 Budapest, Bartók Béla út 105-113.

If you are in the EEA you also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws.  Access a list of local data protection authorities in EEA countries

5. Notification and Management of Personal Data Breaches

Based on the GDPR a personal data breach is defined as a breach of security that leads to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.

In the case of a personal data breach, the Data Controller shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the Supervisory Authority competent (in Hungary: NAIH), unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. Where the notification to the Supervisory Authority is not made within 72 hours, it shall be accompanied by reasons for the delay. Where, and in so far as, it is not possible to provide the information at the same time, the information may be provided in phases without undue further delay.

The notification to the Supervisory Authority shall at least:

  • describe the nature of the personal data breach including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned;
  • communicate the name and contact details of the Data Controller
  • describe the likely consequences of the personal data breach;
  • describe the measures taken or proposed to be taken by the Data Controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.

Data Controller shall document any personal data breaches, comprising the facts relating to the personal data breach, its effects and the remedial action taken. Data in the document will be stored for 5 years from the date of the observation of data breach incident.

6. Data Security

We have implemented technical and organisational measures in an effort to safeguard the Personal Data in our custody and control.

While we endeavour to always protect our systems, sites, operations and information against unauthorized access, use, modification and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others.

You also have an important role in protecting Personal Data. You should not share any username, password or other authentication data provided to you with anyone, and we recommend that you do not re-use passwords across more than one website or application.

II. Data collected from Users in relation with their website visit and usage (cookies)

We use cookies and similar tracking technologies (collectively, “cookies“) on our website.

1. What are cookies?

Cookies are small amounts of data that are stored on your browser, device, or the page you are viewing. Some cookies are deleted once you close your browser, while other cookies are retained even after you close your browser so that you can be recognized when you return to a websites. More information about cookies and how they work is available at All About Cookies.

2. How do we use cookies?

We use cookies to provide the website and services, gather information about your usage patterns when you navigate this website in order to enhance your personalized experience, and to understand usage patterns to improve our website, products, and services.

Cookies on our website are generally divided into the following categories:

  • Strictly Necessary Cookies: These are required for the operation of our website. They include also, for example, cookies that enable you to log into secure areas if applicable. These cookies are session cookies that are erased when you close your browser.
  • Analytical/Performance Cookies: These allow us to recognize and count the number of users of our website and understand how such users navigate through our site. This helps to improve how our website works, for example, by ensuring that users can find what they are looking for easily. These cookies are session cookies which are erased when you close your browser.  We use Google Analytics, and you can see below for how to control the use of cookies by Google Analytics.
  • Functional Cookies: These improve the functional performance of our website and make it easier for you to use. For example, cookies are used to remember that you have previously visited the website. These cookies qualify as persistent cookies, because they remain on your device for us to use during a next visit to our website. You can delete these cookies via your browser settings.

3. What are your options if you do not want cookies on your computer?

You can review your Internet browser settings, typically under the sections “Help” or “Internet Options,” to exercise choices you have for certain Cookies. If you disable or delete certain Cookies in your Internet browser settings, you might not be able to access or use important functions or features of this website, and you may be required to re-enter your log-in details.

To learn more about the use of Cookies for Google analytics and to exercise choice regarding such cookies, please visit the Google Analytics Opt-out Browser Add-on

III. Outbound links, third party websites

The Site may contain links and references to other websites administered by unaffiliated third parties. This Privacy & Cookies Policy does not apply to such third party sites.  When you click a link to visit a third party website, you will be subject to that website’s privacy practices.  We encourage you to familiarize yourself with the privacy and security practices of any linked third party websites before providing any Personal Data on that website.

IV. Changes to Privacy & Cookies Policy

We may update this Privacy & Cookies Policy from time to time as our services and privacy practices change, or as required by law.  The effective date of our Privacy & Cookies Policy is posted below, and we encourage you to visit our Site periodically to stay informed about our privacy practices.  We will post the updated version of the Privacy & Cookies Policy on our website, and ask for your consent to the changes if legally required.

 

Effective date: 25 May 2018

Absolvo Consulting Kft.
Data Controller