Florida Investment Marketing, INC adheres to the Privacy Shield Principles

As a Real Estate Brokerage and Marketing firm, we have always protected your rights to privacy. Like all providers of brokerage services, we are required by law to inform our clients of our policies regarding privacy of client information.

 

Types of Nonpublic Personal Information We Collect

We collect nonpublic personal information about you that is provided to us by you or obtained by us with your authorization.

 

Parties to Whom I Disclose Information

For current and former clients, we do not disclose any nonpublic personal information obtained in the course of our practice except as required or permitted by law. Permitted disclosures include, for instance, providing information to our employees, and in limited situations, to unrelated third-party service providers who need to know that information to assist us in providing services to our customers including: other brokers/realtors to perform a contract with you, closing agents and attorneys at title companies and law offices preparing closing documents, reviewing property ownership and payment check; mortgage companies/loan providers providing loan; accountants, tax professional preparing and filing income tax, obtaining ITIN number; property management companies for providing management). In all such situations, we stress the confidential nature of information being shared, for example name, e-mail, address, telephone number.

 

Protecting the Confidentiality and Security of Current and Former Clients’ Information

We retain records relating to professional services that we provide, so that we are better able to assist you with your professional needs, and in some cases, to comply with professional guidelines. In order to guard your nonpublic personal information, we maintain physical, electronic, and procedural safeguards that comply with our professional standards. Please call if you have any questions, because your privacy, our professional ethics, and the ability to provide you with quality financial services are very important to us.

 

EU-US Privacy Shield Policy

Introduction

Florida Investment Marketing, Inc. (hereinafter referred to as “Florida Investment Marketing,” “we,” “us,” or “our”) complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Florida Investment Marketing has certified that it adheres to the Privacy Shield Principles. To learn more about the Privacy Shield program, and to view our certification page, please visit www.privacyshield.gov

This Privacy Policy outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use it, and the notice and choice affected individuals have regarding our use of and their ability to correct that information. This Privacy Policy applies to all personal information, whether in electronic, paper, or verbal format, received by Florida Investment Marketing directly from individuals in the EU.

 

Definitions

“Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of personal data. “Personal Information” or “Information” means information that (1) is transferred from the EU to the US; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.

“Processing” of personal information means any operation or set of operations which is performed upon personal data, whether or not by automated means, such as collection, recording, organization, storage, adaption or alteration, retrieval, consultation, use, disclosure or dissemination, and erasure or destruction. “Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership, or that concerns an individual’s health.

 

Provisions

NOTICE

Florida Investment Marketing processes Personal Information that comes into our possession through electronic methods (website form, e-mail, FTP sites, secure portals), by accessing the Personal Information internally on source repositories such as our software, document databases, billing platforms, or via other technology. For current and former clients, we do not disclose any nonpublic personal information obtained in the course of our practice except as required or permitted by law. Permitted disclosures include, for instance, providing information to our employees and, in limited situations, to unrelated third-parties who need to know that information to assist us in providing services to our customers. In all such situations, we stress the confidential nature of information being shared.

 

Types of Data Collected

Florida Investment Marketing is a Real Estate Broker and Marketing service provider with confidential contact with our consumers, therefore, we will collect and process a highly sensitive personal data for the purposes stated in the ‘Purpose of Data Use’ section below. Concerning our existing and prospective customers, vendors and suppliers we will collect all information necessary to conduct our work described above in a legally prescribed manner and extent. With regards to employees, contractors and temporary workers, only personal data required to manage and administer their employment with us will be collected and processed.

 

Personal Data Collected Via Technology

To make web-based software products and related services more useful to our clients, our servers (usually hosted by a third party service provider) collect Personal Information, including browser type, Internet Protocol (IP) address (a number that is automatically assigned to a computer when it uses the Internet, which may vary from session to session), domain name, and/or a date/time stamp for use by those web-based software products. We also use navigational data like Uniform Resource Locators (URL) to gather information regarding the date and time of the visit, as well as the solutions and information for which our clients search and view. We automatically gather this Personal Information and store it in log files each time a person visits our website or accesses his or her account on our network.

 

Purpose of Data Use

Florida Investment Marketing processes Personal Information of our customers to provide Real Estate Investment opportunities and Real Estate purchase or sale support services. We also use Personal Information of our employees and vendors for our internal use only that enable us to manage vendors and employees.

 

Feedback

If you provide us with feedback on any of our services, we may use such feedback for any purpose, however, we will not associate such feedback with your Personal Information (i.e. we will anonymous the data where possible). Florida Investment Marketing will collect any information contained in such communication and will treat the Personal Information therein in accordance with this Privacy Policy.

 

CHOICE

Florida Investment Marketing is mandated by the law to obtain a written consent to disclose information which provides an opportunity to (opt out) whether Personal Information is (1) to be disclosed to a third-party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual or entity. The Company will not disclose Personal or Sensitive Personal Information for a purpose other than the purpose for which it was originally collected or subsequently authorized.

 

ACCOUNTABILITY FOR ONWARD TRANSFERS

Except as otherwise stated in this policy, we do not generally share the Personal Information collected from our services with other entities. We are Real Estate Brokerage Provider, therefore, we share Personal Information with Real Estate Closing Attorneys, State or Local Real Estate Tax Authorities as required by law. However, we may be required to share Personal Information if we believe in good faith that such disclosure is necessary; (a)(i) to comply with relevant laws or to respond to subpoenas or warrants served on Florida Investment Marketing; (a)(ii) in response to a lawful request by public authorities, including to meet national security or law enforcement requirements; or (b) to support our business objectives described in the ‘Purpose of Data Use section’ above.

Florida Investment Marketing has liability in cases of onward transfers to third-parties as regulated by the law. When transferring personal data to third party contractors or service providers (i.e. ‘agents’) that may be selected to support the business objectives described in the Purpose of Data Use section of this policy, Florida Investment Marketing will (1) transfer such data only for limited and specified purposes; (2) obligate the agent to provide at least the same level of privacy protection as is required by the Principals; (3) take reasonable and appropriate steps to ensure that the agent effectively processes the personal information transferred in a manner consistent with our obligations under the Principles; (4) require the agent to notify us if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Principles; (5) upon notice; including under point (4), take reasonable and appropriate steps to stop and remediate unauthorized processing; and (6) provide a summary or a representative copy of the relevant privacy provisions of our contract with our agent to the Department of Commerce upon request.

 

SECURITY

Florida Investment Marketing is committed to protecting the security of our data subject’s Personal Information. Therefore, we have implemented reasonable and appropriate measures to protect it from loss, misuse and unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing and the nature of the personal data. Such measures include a variety of industry-standard security technologies and procedures, such as policies restricting access to Information to authorized personnel, mechanisms to protect Information from interception during transmission, physical safeguards to protect Information stored in electronic or hard copy form, and training, reviews and audits of our security and operational procedures.

 

DATA INTEGRITY AND PURPOSE LIMITATION

Florida Investment Marketing shall only process Personal Information in a way that is compatible with and relevant to the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, we shall take reasonable steps to ensure that Personal Information is reliable for its intended use, accurate, complete and current. Florida Investment Marketing will take reasonable and appropriate measures to only retain personal information in a form identifying or making identifiable the individual only for as long as it serves a purpose of processing within the meaning of the previous paragraph.

 

ACCESS

Individuals have the right to access and change any of their Personal Information, and may do so by contacting Florida Investment Marketing. Individuals may correct, amend, or delete inaccurate Information or information processed in violation of these Principles, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated. Individuals may request deletion of their Personal Information by us, but please note that we may be required (by law or otherwise) to keep this Information and not delete it (or to keep this Information for a certain time, in which case we will comply with the deletion request only after we have fulfilled such requirements). When we delete any Information, it will be deleted from the active database and from our archives.

 

RECOURSE, ENFORCEMENT & LIABILITY

Florida Investment Marketing uses a self-assessment approach to assure compliance with this Privacy Policy and periodically verifies that the Privacy Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible, and in conformity with the Principles. Accordingly, Florida Investment Marketing is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

We encourage interested persons to raise any concerns using the contact information provided. We will investigate and attempt to resolve any complaints and disputes regarding collection, use, or disclosure of Personal Information in accordance with the Principles. European Union individuals with inquiries, comments, or complaints regarding this Privacy Policy or data collection and processing practices should first contact Florida Investment Marketing using the following details:

In compliance with the Privacy Shield Principles, Florida Investment Marketing commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Florida Investment Marketing at:

E-mail: laszlok@sprynet.com

Attention: Data Privacy Officer

Subject: Privacy Shield

Florida Investment Marketing has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to EU Data Protection Authorities (DPAs) as our independent recourse mechanism. Florida Investment Marketing uses International Centre for Dispute Resolution-American Arbitration Association, ICDR-AAA, as an Independent Resource Mechanism. You can resolve any applicable disputes you have with us concerning our certification through AAA. You can contact AAA through their website. http://go.adr.org/privacyshield.html

If your complaint is not satisfactorily addressed, and your inquiry or complaint involves human resource data, you may have your complaint considered by an independent recourse mechanism: for EU/EEA Data Subjects, a panel established by the EU data protection authorities (“DPA Panel”). To do so, you should contact the state or national data protection or labor authority in the jurisdiction where you work. Florida Investment Marketing agrees to cooperate with the relevant national DPAs and to comply with the decisions of the DPA Panel.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

 

Other Information

Florida Investment Marketing does not disclose any personal information with any private entity or private third parties. We disclose personal information only with Federal, State or Local government authorities, closing attorneys, accountants, tax professionals for the purpose of purchase or sale of real estate. Any other disclosure can be processed only after a written consent signed by the information owner as required by law.

 

Amendments

This privacy policy may be amended from time to time consistent with the requirements of the Privacy Shield Frameworks. We will post any revisions to this policy on our website. Information Subject to Other Policies Florida Investment Marketing is committed to following the Principles for all Personal Information within the scope of the Privacy Shield Frameworks. However, certain information is subject to policies that may differ from the general policies set forth in this privacy policy.

INTRODUCTION

FLORIDA INVESTMENT MARKETING, INC (Document Number: P01000031178, FEI/EIN Number: 59-3703736, Principal Address: 8304 MANOR CLUB CIRCLE., #1, TAMPA, FL 33647), (further on: Service-provider, Data processor) subdues itself under the following policy.

REGULATION (EEC) No 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 repealing Regulation (EC) No 95/46, the following information is provided.

The present privacy policy guide regulates privacy of the following websites: https://floridainc.us

The present privacy policy guide can be found on: https://floridainc.us/privacy-policy Modifications to the data become effective when they appear on the webpage above.

THE DATA MANAGER AND CONTACT INFORMATION:

Name: FLORIDA INVESTMENT MARKETING, INC.

Seat: 8304 MANOR CLUB CIRCLE., #1, TAMPA, FL 33647

E-mail: laszlo@floridainc.us and laszlok@sprynet.com

Viber and telephone number in Florida: 1-813-503-0301 és 1-813-465-8796

EXPLANATORY TERMS

1. „personal data”: any data that can be related to the Customer – especially the name, username of the customer and any knowledge characteristic for one or more physical, physiological, mental, economic, cultural, or social identity of the Customer – and any conclusion related to the Customer drawn from the data;

2. „data management”: the totality of any operation or operations carried out in an automated or non-automated manner on personal data or data files, such as collecting, recording, organizing, tagging, storing, modifying or modifying, querying, inspecting, using, communicating, distributing or otherwise making available, aligning or linking, limiting, deleting or destroying;

3. „data manager”: means any natural or legal person, public authority, agency or any other body that determines the purposes and means of handling personal data individually or with others, where the purposes and means of data management are defined by Union or national law, the data controller or the particular aspects of the designation of the data controller may also be defined by Union or national law;

4. „data processor”: means any natural or legal person, public authority, agency or any other body that manages personal data on behalf of the data controller;

5. „recipient”: is a natural or legal person, a public authority, agency or any other body with whom or with which personal data is communicated, whether or not it is a third party. Public authorities which have access to personal data in an individual investigation in accordance with Union or national law shall not be considered recipients; the management of those data by those public authorities must comply with the applicable data protection rules in accordance with the purposes of data management;

6. „the contributor concerned”: a voluntary, specific and appropriate informed and explicit statement of the will of the person concerned by which he or she expresses the statement or confirmation by means of an inadvertent act of affirmation that he or she has consented to the processing of personal data concerning him or her;

7. „dataprotection incident”: a security breach resulting in accidental or unlawful destruction, loss, alteration, unauthorized disclosure or unauthorized access to personal data transmitted, stored or otherwise treated.

THE PRINCIPLES OF PERSONAL DATA MANAGEMENT

The personal data:

a) must be legally and fairly handled and transparent to the person concerned (“lawfulness, fairness and transparency”);

b) are collected for specified, clear and legitimate purposes and are not treated in a manner incompatible with these purposes; in accordance with Article 89 (1), no further data handling (“end-use”) for purposes of public interest archiving for scientific and historical research purposes or for statistical purposes shall not be considered incompatible with the original purpose;

c) must be appropriate and relevant to the purposes of data management and should be limited to the need (“saving of the data”);

d) must be accurate and, if necessary, up-to-date; all reasonable measures must be taken to correct or correct inaccurate personal data for the purposes of data management (“accuracy”);

e) must be stored in a form which permits the identification of the data subjects only for the time needed to manage the personal data; the retention of personal data may only take place if the personal data are processed in accordance with Article 89 (1) for public interest archiving, for scientific and historical research purposes or for statistical purposes, in accordance with the rights and subject to appropriate technical and organizational measures for the protection of their freedoms (“limited storage”);

f) shall be managed in such a way as to ensure adequate security of personal data, including the protection against unauthorized, unlawful, unintentional, loss or destruction of data (“integrity and confidentiality”) by means of appropriate technical or organizational measures.

The data processor is responsible for the above, and must be able to demonstrate compliance (“accountability”).

The Data Controller declares that data management is carried out in accordance with the principles set out in this section.

DATA MANAGEMENTS

1. Fact of data collection, the range of managed data and the aim of data management:

The e-mail address does not have to contain any personal data.

2. Range of Customers: Everybody semding a message through the contact form.

3. Time of data handling, deadline for data deletion: If any of the conditions set out in Article 17 (1) of the GDPR exists, it shall continue until the request for cancellation by the data subject.

4. Possible data managers entitled to know the data, the recipients of personal data: Personal data may be handled by authorized personnel of the Data Controller in accordance with this Prospectus.

5. Describe the rights of data subjects involved in data management:

• The data subject may apply to the data controller for access to, correction, deletion or limitation of the personal data concerning him, and
• the data subject has the right to data storage and to withdraw the consent at any time.

6. It is possible to initiate, delete, modify or restrict access to personal data, transferability of data, and objection to data processing in the following ways:

• By post at the address: 8304 MANOR CLUB CIRCLE., # 1, TAMPA, FL 33647
• Via e-mail: laszlo@floridainc.us or laszlok@sprynet.com
• Viber and Florida Mobile Phone Numbers : 1-813-503-0301 and 1-813-465- 8796

7. Legal basis for data processing : consent of the data subject , Article 6 (1) (a), (b) and (c). If you contact us, we agree that we will treat your personal information (name, phone number, email address) as provided in this Policy.

8. We inform you that:

• This data management is based on your consent or is based on a legal obligation (co-operation) required for the submission of a contract or, in the case of a contractual relationship.
• You are obliged to provide personal information to contact us.
• Failure to provide data has the effect of not being able to contact the Service Provider.
• the withdrawal of consent does not affect the legality of the consent-based prerevocation data management.

CUSTOMER RELATIONSHIP

1. Fact of data collection, the range of managed data and the aim of data management:

2. Range of Customers: All those involved in contact with the data controller by phone / email / personally or in a contractual relationship.

3. Time of data handling, deadline for data deletion: The letters containing the requests will last until the request for cancellation of the data subject, but for a maximum of 2 years.

4. Possible data managers entitled to know the data, the recipients of personal data: Personal data may be handled by authorized personnel of the Data Controller in accordance with this Prospectus.

5. Describe the rights of data subjects involved in data management:

• The data subject may apply to the data controller for access to, correction, deletion or limitation of the personal data concerning him, and
• the data subject has the right to data storage and to withdraw the consent at any time.

6. It is possible to initiate, delete, modify or restrict access to personal data, transferability of data, and objection to data processing in the following ways:

• By post at the address: 8304 MANOR CLUB CIRCLE., # 1, TAMPA, FL 33647
• Via e-mail: laszlo@floridainc.us or laszlok@sprynet.com
• Viber and Florida Mobile Phone Numbers: 1-813-503-0301 and 1-813-465- 8796

7. Legal basis for data processing:

8. We inform you that:

• Data management is necessary for the performance of the contract and the offer.
• You are obliged to provide personal information so that we can fulfill the contract / fulfill your other request.
• Failure to provide the data has the consequence that we are unable to execute / process the contract.

NEWSLETTER, DM ACTIVITY

1. According to § 6 of Act XLVIII of 2008 on the fundamental conditions of economic advertising activity the Customer may give consent in advance to the Service Provider for sending him/her advertisement and other consignment via the addresses given at registration.

2. Furthermore, the Customer may give consent to the Service Provider for managing the personal data for sending advertisements bearing in mind the regulations of the present guide.

3. Service Provider sends no unwanted advertisement and the Customer has the option to unsubscribe the sending of advertisements without any limitations and justification. In such case the Service Provider deletes every information – required for sending the messages – from the register and sends no further offers. Customer can unsubscribe the sending of advertisement by clicking on the link in the message. 4. The fact of data collection, range of managed data and the aim of data management:

5. The range of customers: All Customers subscribing for the newsletter.

6. The aim of data collection: sending electronic messages (e-mail, sms, push notification) containing advertisements to the Customer giving information on actual products, discounts, new functions, etc.

7. The time period of data management and the deadline of deletion of data: until the withdrawal of the consent, i.e. unsubscribing from the newsletter.

8. The potential data managers entitled to know the data, the recipients of personal data: Personal data can be managed by the sales and marketing staff of the data manager in respect for the above principles.

9. Describe the rights of data subjects involved in data management:

• The data subject may apply to the data controller for access to, correction, deletion or limitation of the personal data concerning him or her, and
• may object to the handling of such personal data as well
• the data subject has the right to data storage and to withdraw the consent at any time.

10. It is possible to initiate, delete, modify or restrict access to personal data, transferability of data, and objection to data processing in the following ways:

• By post at the address: 8304 MANOR CLUB CIRCLE., # 1, TAMPA, FL 33647
• Via e-mail: laszlo@floridainc.us or laszlok@sprynet.com
• Viber and Florida Mobile Phone Numbers : 1-813-503-0301 and 1-813-465- 8796

11. The users are free to unsubscribe from the newsletters at any time, with no cost.

12. We inform you that:

• Data management is based on your consent and the legitimate interest of the service provider.
• You must provide personal information so that we can send you newsletter.
• Failure to provide data has the consequences of not being able to send you newsletter.
• We will inform you that you can withdraw your consent at any time by clicking on unsubscribe.
• Withdrawal of consent does not affect the legality of the pre-revocation data management based on consent.

ADDRESSES WHOM PERSONAL INFORMATION IS COMMUNICATED WITH

„Recipient”: any natural or legal person, public authority, agency or any other body with which personal data are disclosed, whether or not a third party is involved.

DATA PROCESSORS (WHO PERFORM DATA MANAGEMENT ON BEHALF OF THE DATA CONTROLLER)

The Data Controller uses data processors to facilitate its own data management activities and to fulfill its obligations under contract or legislation.

The Data Controller places great emphasis on using only data processors who either provide adequate guarantees to implement data management in compliance with GDPR requirements and to ensure adequate technical and organizational measures to protect the rights of stakeholders.

The data processor and any person acting under the control of the controller or the data processor who has access to personal data shall treat the personal data contained in these regulations only in accordance with the instructions of the data controller.

The controller is responsible for the data processing activities. The data processor is only liable for damages caused by data management if he or she has not complied with the obligations specified in the GDPR specifically for processors, or if the data controller has ignored or acted contrary to the lawful instructions of the data controller. There is no substantive decision-making on data processing by the data processor.

The data controller can use a hosting provider to provide the back office, and a courier service as a data processor for delivering the ordered products.

EACH DATA PROCESSORS

USE OF COOKIES

1. The fact of data handling, the range of data processed: Unique identification number, times, dates.

2. The range of customers: Everybody who visits the website.

3. Aim of data management: Identify users and track visitors.

4. Term of data management, deadline for deletion of data:

5. The potential data managers entitled to know the data: With the use of cookies the service provider does not manage personal data.

6. Giving information on the rights of the Customers related to data management: Customers can delete cookies in the Tools/Settings menu of the browser generally at the menu item Data protection.

7. Legal basis of data management: No consent is required if the sole purpose of the use of cookies is the communication service provided through the electronic communications network or the provision of information society services expressly requested by the subscriber or user.

8. Most browsers that our users use allow you to set which cookies to save and allow (specified) cookies to be deleted again. If you restrict or save third-party cookies on specific websites, this may in some circumstances result in our website not being fully usable. Here is information on how to customize cookie settings for standard browsers:

Google Chrome (https://support.google.com/chrome/answer/95647?hl=hu)

Internet Explorer (https://support.microsoft.com/hu- hu/help/17442/windows-internet-explorer-delete-manage-cookies)

Firefox (https://support.mozilla.org/hu/kb/sutik-engedelyezese-es-tiltasa- amit-weboldak-haszn

Safari (https://support.apple.com/kb/PH21411?locale=hu_HU)

9. Further informations about cookies:

Like most companies, floridainc.us uses cookies and other similar technologies (“cookies”) on your sites to support and enhance the online experience of users.

The use of cookies

Cookies contain a small amount of information that are downloaded on your computer when you visit the site. Cookies are then sent back to our website, which allows us to recognize your device but in not a personally identifiable manner. Thesse essential Recognizing cookies allow the site to assist you efficiently navigate, allowing you to easily find the necessary information and services.

The analytical and customization cookies allow websites to remember your personal settings, such as the selected language, and help viewing the most relevant information in relation to your interests. In addition, these cookies help maintain and improve your site: providing information on how visitors find and use the site, and how websites perform.

In certain cases adcookies can be used so the ads can be relevant to users.

What kind of features you can use cookies on your website for

• User account registration
• User Login Features
• Sign up for newsletter
• Submitting orders
• Questionnaire answers
• Submit Forms
• Site Settings

What kind of “third parties” of this type may access the content of cookies on this website or place their own cookies

• Google Analytics
• Other analytical service providers
• Google AdSense
• Behavioral advertising
• Website Optimization
• Conversion Tracking
• Customize content
• Affiliate Tracking
• Social media tools

What kind of cookies may be included on the page to help user contact

• Cookies that include Email address
• Visit a link on our website typeof
• Ones that include phone number

By enabling the use of cookies on the site, you consent to the use of cookies by using the website.

The additional options for cookies

If you want to look at one by one floridainc.us and the cookies used by the selected partners on the site, and you would like to make decisions about the use of cookies based on the knowledge of the system and the technical expertise of most browsers. Please note that if you decide to disable cookies on your website, you may not be able to take full advantage of the features of the site afterwards.

Sharing tools

Occasionally, content and sharing tools from other sites (third-party sites) can be embedded to enhance the experience on the site, such as the “like” button on social networks. Third-party sites are also eligible to place and access cookies on this site.

The floridainc.us does not check the placement and access of third- party cookies. Check the relevant third-party sites for more information about these cookies and the options available to them.

THE USE OF GOOGLE AND FACEBOOK SERVICES

USING THE GOOGLE ADS CONVERSION TRACKING

1. The online advertising program called “Google Ads” is used by the data handler and uses the Google conversion tracking feature within its framework. Google conversion tracking is Google Inc.’s analytics service (1600 Amphitheater Parkway, Mountain View, CA 94043, USA; “Google”).

2. When a User accesses a web site through a Google Ad, a conversion tracking cookie is placed on your computer. These cookies have limited validity and do not contain any personal information, so the User can not be identified by them.

3. When the User browses on certain pages of the website and the cookie has not expired, Google and the Data Manager will also see that the User clicked on the ad.

4. Each Google Ads customer receives a different cookie so that they can not be tracked through Ads clients’ websites.

5. The information you receive through conversion tracking cookies is intended to make conversion statistics for your Ads conversion tracking customers. Customers will then be informed about the number of users who have been submitted to their ad and click on a conversion tracking tag. However, they do not have access to information that could identify any user.

6. If you do not want to participate in conversion tracking, you can disable this by blocking cookies from being installed on your browser. Then you will not be included in conversion tracking statistics.

7. For more information and Google Privacy Statement, visit: www.google.de/policies/privacy/

THE SERVICE OF GOOGLE ANALYTICS

1. This website uses the service of Google Analytics, which is the webanalyser service of the Google Inc. („Google”). The Google Analytics uses so called „cookies”, textiles, which are saved on your computer, and they help the analysis of the website usage of the Users.

2. The cookies of the websites which were visited by the User and their connecting informations are sent and stored on one of the Google’s servers in the USA. With the activation of the IP-anonymisation on the websites the Google can shorten the time of the IP-anonymisation of the Users in the European Union or in the member states of the European Economic Region.

3. Only in unique cases the full IP-addresses are sent to the servers of Google in the USA and they get shorten there. Operators of these websites commit the Google to use these informations for interpretations about the usage of the website, furthermore to create reports about the activity of the website, and to do their website and internet usage related duties.

4. In the Google Analytics, the forwarded IP-address of the Users will not be matched with others data by the Google. The store of the cookies can be prevented in the settings of the web browsers, but in this way it can happen, if some features of the websites will not work. You can prevent Google from collecting datas about the website usage habits of the users (including IP-addresses too), if you download and setup this web browser plugin. https://tools.google.com/dlpage/gaoptout?hl=hu

FACEBOOK PIXEL

1. The Facebook Pixel is a code that is used to report on conversions on the website, set up audiences, and the owner of the page receives detailed analysis data about the use of the website. With Facebook remarketing pixel tracking code, visitors can display customized offers and ads on the Facebook interface. The Facebook remarketing list is not suitable for personal identification. For more information about Facebook Pixel / Facebook pixels, see: https://www.facebook.com/business/help/651294705016616

SOCIAL WEBSITES

1. The fact of data collection, range of managed data: name and public profile image of the Customer registered at Facebook/Google+/Twitter/Pinterest/YouTube/Instagram etc.

2. The range of customers: All Customers registered at Facebook/Google+/Twitter/Pinterest/YouTube/Instagram etc. and gave like to the website.

3. Purpose of the data collection: To share, or “like”, promote certain content elements, products, actions of the web site or the website itself on social networking sites.

4. Duration of data processing, deadline for deletion of data, person of possible data controllers who are able to know the data and details of the data management rights of the data subjects: Information about the source, their handling, the method of transfer and the legal basis of the data can be consulted on the given social networking site. Data management takes place on social networking sites, so the duration of the data handling, the ways of deleting and modifying the data are governed by the rules of the respective community site.

5. Legal base of data management: voluntary consent of the Customer for the management of personal data at community sites.

CUSTOMER SERVICES AND OTHER DATA MANAGEMENT

1. If you have question during using some of the services of the data processor, or the customer has some problem you can get in contact with the data processer on the website (on phone, e-mail, community sites, etc.).

2. The data processer deletes the incoming e-mails, messages, on phone, on any community site, etc. what contains the name and e-mail address or any other given personal information of the customer, after 2 years from the start of the service.

3. We give information about the privacy policy which is not in this guide at the start of the service.

4. For exceptional magisterial request, or in case of law accumulation the service provider is bound for guidance, information providing, transferring, or making documents available for these organisation.

5. In these cases the service provider only gives personal informations for the request (if they pointed out the exact aim and the necessary informations) what are essentials for the aim of the request.

CUSTOMER RIGHTS

1. The right of access

You are entitled to receive feedback from the data controller about whether your personal data is being processed and, if such processing is in progress, you have the right to have access to your personal information and the information listed in the decree.

2. The right of rectification

You are entitled to request the data controller to rectify any inaccurate personal information that he or she is required to do without undue delay. Taking into account the purpose of data management, you are entitled to request the supplementation of incomplete personal data, including by means of a supplementary statement.

3. The right to cancel

You are entitled to request that the data controller, without undue delay, disclose personal information about you, and that the data controller is obliged to delete personal information about you, without undue delay, under certain conditions.

4. The right to be forgiven

If the data controller has disclosed the personal data and is required to cancel it, taking reasonable steps, including technical measures, to take into account the cost of available technology and implementation, in order to inform the data controllers handling the data that you have applied for the personal data in question pointing links or deleting a duplicate or duplicate of these personal data.

5. The right to restrict data management

You are entitled to request that your data controller restricts your data handling if one of the following conditions is met:

• You dispute the accuracy of your personal data; in this case, the restriction applies to the period of time that the data controller can check the accuracy of personal data;
• Data handling is illegal and you are opposed to the deletion of data and instead asks you to restrict them;
• The data controller no longer needs personal data for data processing, but you require them to submit, enforce, or protect legal claims;
• You have objected to data manipulation; in this case, the restriction applies to the period when it is established that the legitimate reasons for the data controller have priority over your legitimate reasons.

6. The right to data storage

You are entitled to receive personal data that is made available to you by a data controller in a fragmented, widely used machine-readable format and is entitled to transfer this data to another data controller without this being obstructed by the data controller whose provided personal information to you (…)

7. The right ro protest

You are entitled to object to the handling of your personal information (…), including profiling based on these provisions, for any reason relating to your own situation.

8. Protest in case of direct business acquisition

If your personal data is handled for direct business, you are entitled to protest at any time against the handling of personal data relating to it, including profiling, if it is related to direct business acquisition. If you object to personal data being handled for direct business purposes, your personal information can no longer be handled for that purpose.

9. Automated decision-making in individual cases, including profiling

You are entitled to exclude the scope of any decision based solely on automated data handling, including profiling, which would have a bearing on it or affect it significantly. The preceding paragraph shall not apply if the decision is:

• You are required to conclude or complete a contract between you and the data controller;
• the granting of the right to a data controller is subject to the law of the Union or of the Member States which also lays down appropriate measures to protect your rights and freedoms and legitimate interests; or
• you are based on your explicit consent.

DEADLINE FOR ACTION

The data controller informs you of any measures taken in response to these requests without undue delay but in any way within 1 month of receipt of the request.

If necessary, it may be extended by 2 months. The controller will inform you about the extension of the deadline by indicating the cause of the delay within 1 month of receipt of the request.

If the data controller fails to take action upon your request, he or she will notify you without delay and at the latest within one month of the receipt of the request for reasons of non-action and whether you may file a complaint with a supervisory authority and exercise its right of appeal.

SECURITY OF DATA MANAGEMENT

The data controller and the data processor shall take appropriate technical and organizational measures to take into account the state of science and technology and the costs of implementation, the nature, scope, circumstances and objectives of data management and the risk of varying probability and severity of natural persons’ rights and freedoms to guarantee an adequate level of data security, including, inter alia, where appropriate:

(a) the pseudonymization and encryption of personal data;

(b) ensuring, maintaining, integrity, availability and resilience of the continuing confidentiality of systems and services used to manage personal data;

(c) in the case of a physical or technical incident, the ability to restore access to personal data and the availability of data in good time;

(d) the procedure for systematic testing, assessment and evaluation of the effectiveness of technical and organizational measures taken to ensure the security of data processing.

(e) The data processed must be stored in such a way as to prevent unauthorized access. In the case of paper-based data carriers, by establishing the order of physical storage, filing, and using the central authorization system for data processed in electronic form.

(f) The method of storing the data using the IT method must be chosen so that it can be deleted at the end of the period for deletion of data, or if it is necessary for other reasons, subject to a different cancellation deadline. The deletion must be irreversible.

(g) Paper-based media shall be deprived of personal data by means of a document shredder or by an external document destruction organization. In the case of electronic data carriers, physical destruction shall be ensured in accordance with the rules on the disposal of electronic media and, where necessary, the safe and irrevocable deletion of data shall be made in advance.

(h) The data controller will take the following specific data security measures:

a. In order to ensure the security of personal data handled on paper, the Service Provider applies the following measures (physical protection):

i. Place documents in a secure, lockable dry room.

ii. The Service Provider’s building and premises are equipped with fire protection and property protection equipment.

iii. Personal data may only be accessed by authorized persons and not accessible to third parties.

iv. In the course of his work, the Service Provider’s employee may only leave the room where data is being processed, to block the media entrusted to him or to close the room.

v. If digitization of paper-based personal data is done, the rules governing digitally stored documents should apply.

b. IT protection

i. Computers and mobile devices (other media) used in data management are the property of the Service Provider.

ii. Data on computers can only be accessed with a username and password.

iii. Access to the central server machine is only granted with the appropriate authority and only by designated persons.

iv. For security of digitally stored data, the Service Provider uses data backups and archives.

v. A computer system containing personal data that is useful to the Service Provider is provided with virus protection.

vi. The service provider encrypts the passwords.

INFORMING THE PERSON CONCERNED ABOUT THE PRIVACY INCIDENT

If the privacy incident is likely to pose a high risk to the rights and freedoms of natural persons, the data controller shall inform the data subject of the privacy incident without undue delay.

Information given to the data subject should be clearly and easily understood and the nature of the privacy incident must be disclosed and the name and contact details of the Data Protection Officer or other contact person providing additional information should be disclosed; the likely consequences of a data protection incident should be described; describe measures taken or planned by the data controller to remedy a data protection incident, including, where appropriate, measures to mitigate any adverse consequences of a data protection incident.

The person concerned shall not be informed if any of the following conditions are met:

• the data controller has implemented appropriate technical and organizational protection measures and applied these measures to the data covered by the data protection incident, in particular the measures, such as the use of encryption, which make it impossible for persons who are unauthorized to access personal data the data;
• after the data protection incident, the data controller has taken further measures to ensure that high risk for the rights and freedoms of the person concerned is no longer likely to be realized;
• Informing would require disproportionate efforts. In such cases, the data subject shall be informed by means of publicly disclosed information or a similar measure shall be taken to ensure that such information is equally effective.

If the data controller has not yet notified the data subject of the data protection incident, the supervisory authority may, after considering whether the privacy incident is likely to pose a high risk, may inform the data subject.

REPORTING A PRIVACY INCIDENT TO THE AUTHORITY

The data protection incident shall be reported to the supervisory authority under Article 55 without undue delay and, if possible, no later than 72 hours after the data protection incident becomes known, unless the data protection incident is unlikely to pose a risk to the rights of natural persons and freedom. If the notification is not filed within 72 hours, the reasons for proving the delay must also be enclosed..

REVIEW FOR MANDATORY DATA MANAGEMENT

If the period of mandatory data management or the periodic review of its necessity is not specified by law, local government regulation or a binding act of the European Union, the controller shall review at least every three years from the commencement of the data processing that it or the processor acting on its behalf or on its instructions and if the personal data management is necessary for the purpose of data management.

The circumstances and results of this review shall be documented by the Data Controller, and shall be retained for a period of ten years after the review has been conducted and made available to the Authority at the request of the National Authority for Data Protection and Freedom of Information (hereinafter referred to as the Authority).

COMPLAINT OPPORTUNITY

Complaint regarding the possible breaching of the law by the data manager can be made to the Hungarian National Authority for Data Protection and Freedom of Information:

Hungarian National Authority for Data Protection and Freedom of Information

1125 Budapest, Szilágyi Erzsébet fasor 22/C.

Mailing address: 1530 Budapest, P.O.Box: 5.

Telephone: +36 -1-391-1400

Fax: +36-1-391-1410

E-mail: ugyfelszolgalat@naih.hu

CLOSING REMARKS

The following regulations were accounted in the course of composing the guide:

• REGULATION (EEC) No 2016/67 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 repealing Regulation (EC) No 95/46
• 2011 CXII. Law on information self-determination and freedom of information (hereinafter: Infotv.)
• Act CVIII of 2001 – Act on Electronic Commerce and Information Society Services (especially Section 13 / A)
• Act XLVII of 2008 – Act on the Prohibition of Unfair Commercial Practices against Consumers;
• Act XLVIII. Of 2008 – the basic conditions and certain limitations of economic advertising activity (in particular Article 6)
• XC. Law of 2005 on Eletronic Freedom of Information
• Act C of 2003 on Electronic Communications (specifically Article 155)
• No. 16/2011. an opinion on the EASA / IAB Recommendation on Best Practice in Behavioral Online Advertising
• Recommendation of the National Data Protection and Information Authority on the data protection requirements for prior information