Privacy Policy

Version 1.0

1. Data Manager

Name: DUAX Kft.

Contact: [email protected]

Representative: Peter Freed

Official mailing address: H-1034 Budapest, Bécsi út 60.

Company Registration Number: 0109465162

2. Contact details of the Privacy Officer

We do not engage in any activity that would justify the employment of a Privacy Officer.

3. How and why do we manage your personal data?

a. If you order Diplomacy&Trade in print format

By filling out the 'Order the print version' form, you will enter into a contractual relationship with us, under which you will be a subscriber to our monthly newspaper, in which case we treat your data according to the Contractual Legal Basis and store it for the legally required period of time (8 years). We also invoice you based on these data.

Processed data: name, name featured on invoice, address featured on invoice, delivery address, e-mail address, phone number. If you pay by bank transfer, we will also store your bank account number.

b. On our Facebook page: https://www.facebook.com/Diplomacy-Trade-426866201439437

If you choose to like or follow us on Facebook, it will allow us to see your name, your public profile, your posts, shares and you may see our ads – all based on your consent. However, these data are not handled by us but by Facebook. You can withdraw your consent by clicking the "Unfollow the page" button.

c. Cookies

A cookie is a small data file that is stored by your computer when you visit a website. Cookies have many functions. Among other things, they collect information, note the customized settings of the visitor, and generally facilitate the use of the website for users. We use the following cookies:

• Essential cookies

Essential cookies are indispensable for the operation of the website, e.g. you do not need to sign in on each page separately (if you are a registered user) and allow us to store your decision on what other cookies you enable or disable. Therefore, you cannot disable these cookies here. If you really want to for some reason, you can disable them in your browser's cookie settings. Here is a description for the most popular browsers: Google Chrome | Firefox | Microsoft Internet Explorer | Safari

• Statistical cookies

These cookies help us find out how many visitors visited the site, where they came from, how much time they spent reading, and which pages they visited. These statistics help us identify the most popular articles, what visitors are interested in, and ultimately, by enabling these cookies, you help us produce better and more relevant content. On this website, we use statistics produced by Google Analytics, therefore, cookies from these providers will be stored on your computer. More info about Google Analytics cookies.

• Facebook cookies

In order for you to be able to send us a quick and direct message, like or share our content in a simple manner, log on to our website with the click of a button, and for us to deliver relevant information to you, even in the form of an ad, you may want to consider installing Facebook cookies. Further information on Facebook cookies

4. Who has access to your personal information besides our colleagues?

Contributors and employees involved in data management and / or data processing at our company are entitled to access your personal data to a predetermined extent - subject to a clause of confidentiality. Our data processors are:

Our hosting provider: Hosting.eu Szolgáltató Kft. (H-1144 Budapest, Ormánság u. 4.), https://tarhely.eu

Our Web Designer: AdCodeDesign Ltd. (Akaziengasse 34/3 1230 Wien, Austria) https://adcodedesign.com

The company responsible for distributing the newspaper: (H-1097 Budapest, Táblás u. 32.)

5. Data transfer to a third country or international organization

We do not send data directly to third (non-EU) countries or other organizations.

You can read about the data management of our partners, Google, Facebook and Salesautopilot, on their respective websites.

6. Your rights to manage your data

• Right to access

You can request information on whether your personal data is being processed. If the answer is yes, we will inform you about why we manage them, what type of data we manage, to whom we transfer them, for what period we store them, what other rights we provide for you, where you can complain, etc.

Send your request for information to us by e-mail and we will provide you with the information within 30 days of receiving your request.

• Right to rectify

If there is a mistake in your name, phone number or e-mail address or any other personal information, we will correct or supplement them upon your request.

You can send us your request for correction by e-mail and we will make the requested changes within 30 days of receiving it.

• Right to delete personal data

Naturally, we will delete your personal data provided on a voluntary basis if you withdraw your consent or upon expiry of the time limit for each data processing.

• Right to restrict and withdraw data management

We restrict the processing of your data at your request if one of the following conditions is met:

• • you dispute the accuracy of your personal information, in which case the limitation applies to the period during which we verify the accuracy of these data;
  • the data management is illegal, but you are against deleting the data and instead request the restriction of their use;
  • although we no longer need personal data for data management, you still require them for the purpose of submitting, validating or defending legal claims;
  • you object to the data management: in this case, the limitation applies to the period until it is determined whether our legitimate reasons take precedence over your legitimate reasons.

We can record the withdrawal of your consent with a 30-day deadline, but it is possible that certain data may be managed by us after the withdrawal of the consent in order to fulfill our legal obligations or enforce our legitimate interests.

• Object to the management of personal data

You may object to the management of your personal data if our data management is based on our legitimate interest. This may only occur in the case of business partners' contact information, but for other activities this is not the legal ground of our data management.

You can send your objection to us by e-mail and we will implement the requested changes within 30 days of receipt.

• Right to data transfer

You may request that we provide your data stored in automated form in a structured, widely used, machine-readable format or that we send them to another data controller. You can only request this if the legal basis for our data management is your consent or a contract.

You can send us your request for the transfer of your data by e-mail and we will send the requested information within 30 days of receipt.

7. If you have a complaint

If you feel that we manage your personal data incorrectly, our customer service will be happy to assist you and discuss the problem without delay. Send your message here: [email protected]

You may choose to enforce your rights in court in a civil trial. Judicial review is within the jurisdiction of the Tribunal. You must file a claim with the court of your place of residence (see the list and contact details of the courts on this link: http://birosag.hu/torvenyszekek).

You can also contact the National Authority for Data Protection and Freedom of Information with any personal data complaint or question (H-1125 Budapest, Szilágyi Erzsébet fasor 22 / C; mailing address: H-1530 Budapest, Pf. 5).

8. Data security

We protect your personal data by using the appropriate technical and other means, and ensure the security, availability of your data, and protect them from unauthorized access, alteration, damage or disclosure, and any other unauthorized use. As part of our organizational measures, we monitor physical access to the data, train our employees continuously, and keep the paper-based documents locked up with adequate protection. When managing your data, we use encryption, password protection, and antivirus software tailored to the nature of data management. Nevertheless, please note that data transmission over the Internet cannot be considered fully secure data transmission. Our website communicates via encrypted channels (https protocol) in all cases, so that the data you send or receive are not accessible to third parties.

9. Other data management issues

We may only transfer your data in line with statutory regulations and in the case of our data processors, we apply contractual terms and conditions to ensure that your personal data is not used for purposes other than to what you granted your consent for.

The court, the prosecutor's office and other authorities (e.g. police, tax office, National Authority for Data Protection and Freedom of Information) can contact us for information, disclosure or access to documents. In these cases, we need to fulfill our reporting obligations, but we do so only to the extent strictly necessary to achieve the purpose of the request.

10. Miscellaneous provisions

This privacy policy enters into force on 10 July 2019, and as soon as new guidelines, resolutions, and detailed rules become available that require us to amend it, we will review the content thereof. If the scope of our business changes or we introduce new marketing tools, we will rewrite or supplement this policy.

11. Legal references

Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information;

Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Regulation (EC) No 95/46 ( General Data Protection Regulation, GDPR);

Act V of 2013 - on the Civil Code;

Act C of 2000 on Accounting;

Act LIII of 2017 on the Prevention and Combating of Money Laundering and Terrorist Financing;

Act CCXXXVII of 2013 on Credit Institutions and Financial Enterprises.

Act CVIII of 2001 on certain aspects of electronic commerce services and information society services;

Act C of 2003 on Electronic Communications;

Act CLV of 1997 on Consumer Protection Act;

Act CLXV of 2013 on Complaints and Notifications of Public Interest;

Act XLVIII of 2008 on the Essential Conditions of and Certain Limitations to Business Advertising Activity.

This policy is effective from 16 July 2019 until revocation or modification.

The Company reserves the right to change this Policy.

Budapest, 16/07/2019