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Privacy

1. INTRODUCTION

Hírek Média és Internet Technológiai Kft. (Embankment Estate E3 Business Center
1036 Budapest, Lajos u. 103. I. emelet, mentioned as Hírek Kft. in the followings, provider, data controller), as a data controller is bound by the content of this legal notice. Commits itself that all data management related to ResearchCenter's services meet the requirements specified in these rules. The privacy policy of ResearchCenter's services concerning data management is constantly available at http://www.kutatocentrum.hu/privacy.

The owner and operator of ResearchCenter, Hírek Kft. reserves the right to change this information at any time. The audience will be informed of these changes in due time. Should you have any questions about this notice, please contact us and our colleagues will answer. Hírek Kft. although committed to maintain the highest quality of service, is not responsible for the damage arising from the use of the service.

Hírek Kft. is committed to protect the personal data of its users and partners, highlights the importance of respecting the informational autonomy rights of its customers. Hírek Kft. manages the personal data confidentially, and takes every security, technical and organizational measures to guarantee the safety of these data.

Hírek Kft. regarding that confidential information of business customers are just as important as natural persons, applies its provisions not only to natural persons but also to the customers of legal persons in addition of the requirements of the Data Protection Act.

Hírek Kft. describes its privacy policy below, presents the expectations that it expresses towards itself and satisfies as data controller. Its privacy principles corresponds to the existing laws on data protection, in particular with the following:

• Law No. LXIII./1992 - the protection of personal data and the publicity of public-benefit data
• Law No. CXIX./1995 - the name and address data management for the purpose of research and direct marketing
• Law No. CVIII./2001 - certain aspects of the e-commerce services and services related to the information society
• Law No. C./2003 - electronic communications
• Law No. XLVIII./2008 - the basic conditions and limits of economic advertising

2. DEFINITIONS

2.1. personal data: any defined (identified or identifiable) data in connection with a natural person , or from which conclusions can be drawn to the person. The personal data keeps its form until the connection between the data and its owner can be restored. A person could be regarded as identifiable, if one could be identified (indirectly or directly) by name, ID, or by one or more physical, physiological, mental, economic, cultural or social factors specific to the identity.
2.2 consent: the voluntary and determined expression of the respondents wish, which is based on appropriate information, and with which one unambiguously consent to the management - whole or partial - of one’s personal data.
2.3. objection: the statement of the respondent in which one criticizes the management of one’s personal data and requests its elimination and deletion.
2.4. data manager: that natural or legal person or organization without legal rights which defines the purpose of data management, makes and implements decisions on the data management (including the used tools) or makes it implemented by the contracted data processor.
2.5. data management: regardless of the used method, any operation or set of operations carried out on the data, such as collection, recording, organization, storage, alteration, use, transmission, disclosure, unification or combination, distraint, deletion or destruction, and the prevention of its further use. Taking pictures, recording sounds and videos are also data management, as well as recording personal physical characteristics (e.g.: finger or palm print, DNS sample, picture of the iris).
2.6. data transmission: if the data is made available for third parties
2.7. disclosure: if the data is accessible to anyone
2.8. data deletion: making the data unrecognizable so that it is impossible to restore it
2.9. data distraint: making impossible the transmission, the cognition, the disclosure, the conversion, the alteration, the destruction, the deletion, the unification or combination and the use of data permanently or for a certain period.
2.10. data distraint: making impossible the transmission, the cognition, the disclosure, the conversion, the alteration, the destruction, the deletion, the unification or combination and the use of data permanently or for a certain period.
2.11. data distraint: making impossible the transmission, the cognition, the disclosure, the conversion, the alteration, the destruction, the deletion, the unification or combination and the use of data permanently or for a certain period.
2.12. data processor: that natural or legal person or organization without legal rights, which processes the personal data on the order of the data manager.
2.13. third party: that natural or legal person or organization without legal rights, which is not the same person as the respondent, the data manager or the data processor.
2.14. third country: every state that is not an EEA state

3. BASIC PRINCIPLES OF HÍREK KFT. DURING DATA MANAGEMENT

Personal data can be managed if:
a) the respondent gives its permission,
b) it is ordered by law or by - the authority of law - a local government decree.

To have the statement of an incapable minor or minors having restrained capacity the consent of its legal guardian is needed, except in the case of those parts ot the services, where statement is concerning the registration massively occuring in everyday life, and does not require special consideration.

Personal data shall be managed only for special purposes, in order to exercise rights and obligations. Each stage of data management must meet this goal.

Only that personal data can be managed, which is essential for the realization of the goal of data management, is proper for reaching this goal, but only to the necessary extent and time.

Personal data can only be managed by the consent of the respondent based on appropriate information.

The respondent must be informed - clearly, understandably and in detail - about all the facts concerning the management of his/her data, in particular the purpose and legal basis of the data management, the person authorized for data management and processing, the duration of data management, and about who can get the information. The information should include the respondent's rights and legal remedies related to data management.

The managed personal data must meet the following requirements:
a) their collection and management are fair and legal
b) they are accurate, complete, and if necessary current
c) the method of their storage is proper for identifying the respondent only until the necessary time of the purpose of storage.

The usage of general and uniform identification code that could be used without restriction is prohibited.

Personal data may be transmitted and various data management may be connected, if the respondent gave its consent, or it is permitted by law, and if the conditions of data management are met for each personal data.

Personal data (including special data) from the country - regardless of the medium of transmission and method - could only be transmitted to a third country data manager or processor, if the respondent gave its consent or is permitted by law, and if the management and processing of these data in the third country meets the protection requirements of personal data. Data transmission to EEA states should be regarded as a data transfer within the territory of Hungary.

4. SCOPE OF PERSONAL DATA, THE PURPOSE OF DATA PROCESSING, ITS TITLE AND DURATION

Within the service of ResearchCenter any kind of data management of the respondents’ data is based on their voluntary contribution.
However, in some cases the management, storage and transmission of a range of these data is made compulsory by law, which we inform our respondents about.
We would like to draw the attention of our respondents that if they don't give their own personal data then it's their responsibility to get the consent of the data owner.

4.1. THE DATA OF THE VISITORS OF WWW.KUTATOCENTRUM.HU

The purpose of data management: the service provider collects data during its site's visit in order to provide the service, control its operation and to prevent any abuse.
Legal basis of data management: the consent of the respondents, and 13/A. § (3) of Law No. CVIII./2001 concerning certain aspects of the e-commerce services and services related to the information society.
The scope of managed data: date, time, the user's IP address, the address of the page viewed, and generally accepted other data for measuring attendance during the usage of the internet.
Duration of data management: 3 months from the visit of the site.

Data encountered during the log file analysis will not be connected by Hírek Kft. to other information, we do not attempt to identify the user.

Data management of external service providers:
The html code of the portal is independent of Hírek Kft., contains a link from an external server to an external server. The provider of this link can collect users' data, because of the direct connection through its server.

The website is monitored (visits and web analytics) by www.google-analytics.com, which uses cookies and web beacons. If the browser sends back a previously saved cookie, then the service provider can connect the users' current visit with the previous ones, but only regarding its own content.

The user can delete the cookie from its own pc, or disable their application in the browser. The option for managing the cookies can be found in the browser's Tools/Options menu under Privacy settings under the Cookies label. Detailed information is provided for the management of these data by the above mentioned data manager.

4.2. REGISTRATION TO RESEARCHCENTER’S ONLINE PANEL

The purpose of data management: identifying the users, participating in ResearchCenter’s prize draw and online panel, conducting scientific, public opinion and market research.
Legal basis of data management: the consent of the respondent, Law No. CXIX./1995 on the name and address data management for the purpose of research and direct marketing, and the 13/A. § (3) of Law No. CVIII./2001 on certain aspects of the e-commerce services and services related to the information society.
The scope of managed data: ID number, name, e-mail address, telephone and mobile number, birth date, gender, household data, first child's year of birth, internet, mobile phone, data regarding car usage habits, highest level of education, occupation, net monthly income, bank where they have an account, technical equipment of the household, breadwinner and purchase decision maker, net income of the household, interest of the user, smoking habit, desired type of sweepstakes and gifts.
Time of data management: until the cancellation request of the respondent, 7 days in case of unconfirmed registrations.

Source of data: online form.

Respondents can indicate their intention to opt-out at any of the following contacts:
- by mail at 1036 Budapest, Lajos u. 103.
- by e-mail at info@kutatocentrum.hu
- by phone at 06.1.373.0953


Record number of data management: 00634-000X.

4.3. NEWSLETTER OF RESEARCHCENTER

The purpose of data management: sending e-mail newsletters including marketing advertisements, news and current offers for those who are interested.
Legal basis of data management: 6. § (5) of Law No. XLVIII./2008 on the basic conditions and limits of economic advertising.
The scope of managed data: ID number, name, e-mail address, company name, date, time, consent for receiving direct marketing messages.
Deadline for data cancellation: until the withdrawal of the consent.

Source of data: online form.

Respondents can prohibit the transmission of newsletters and direct marketing messages and ask for the deletion or modification of their personal data at any of the following contacts:
- by mail at 1036 Budapest, Lajos u. 103.
- by e-mail at info@kutatocentrum.hu
- by phone at 06.1.373.0953


Record number of data management: 00634-000X.

4.4. CONTACTS AND CUSTOMER LETTERS OF RESEARCHCENTER

The purpose of data management: operation of customer service, contacts, validation of consumer and service rights, targeted service.
Legal basis of data management: the consent of the respondent, and the 13/A. § (3) of Law No. CVIII./2001 on certain aspects of the e-commerce services and services related to the information society.
The scope of managed data: ID number, name, e-mail address, company name, date, time, and personal data given in the e-mail.
Deadline for data cancellation: 5 years.

4.5. MANAGEMENT OF DATA GIVEN DURING RESEARCH

We inform our respondents, that we store their responses given during research separately and anonimously from their personal data, with such technical procedures, that makes their later identification impossible. Research data thus can not be regarded as personal data, their anonymous use therefore is unlimited.
Exceptions are those researches, where the respondent gave its written consent to Hírek Kft. for processing these responses with their personal data, for the purpose of the research.
The user participating in the research contributes to the managing of its special data for the processing and evaluation of the responses by Hírek Média Kft.

4.6. OTHER DATA MANAGEMENT

We give information on those data management issues not listed in this guide at the data recording.

We inform our clients, that by the authority of the court, the prosecutor, the investigating authority, the authority of infringement, the administrative authority, the privacy commissioner and the law they can contact the data controller to inform other administrative bodies, to communicate data, to transfer data and to make the documents available. Hírek Kft. gives as much personal data and only to that extent for the authorities - if the authority gave its exact purpose and scope of the data -, which is essential for the purpose of the request.

5. METHOD OF STORING PERSONAL DATA, SECURITY OF DATA PROCESSING

The computing system and other data storage places of Hírek Kft. can be found at its headquarter, and at the server room of Invitel Távközlési Zrt. at 1143 Budapest, Ilka u. 31. B fsz.

Hírek Kft. chooses and runs the IT resources used during its services for managing personal data, that the managed data:
a) is accessible for the authorized persons (availability); b) its credibility and validation is ensured (data authenticity); c) its unchangingness is verifiable (data integrity); d) is protected against unathorized access (data confidentiality).

Hírek Kft. takes technical, organizational and structural measures to ensure the security of data management, which provides the appropriate level of protection against the risks arising from data management.

Hírek Kft. keeps during the data management:
a) the secrecy: protects the information that only those can access it who are authorized;
b) the integrity: protects the accuracy and completeness of the processing method and the information;
c) the availability: ensures that when the authorized user needs it, it can access the desired information and that the related assets are also available.

The information system and network of Hírek Kft. and its partners are protected against computer-assisted fraud, espionage, sabotage, vandalism, fire and flood as well as against computer viruses, computer intrusions and intrusions leading to denial of the service. The operator ensures the security by applying server and application security methods.

We inform the users, that electronic messages transmitted through the Internet are vulnerable to network threaths regardless of protocol (e-mail, web, ftp, etc.), which are leading to unfair practice, contract dispute or the disclosure or change of information. The service provider shall take all reasonable precautions against such threats. It observes the systems in order to record any security deviation and to provide proof of all security events. Monitoring the system also allows to control the efficiency of applied precautionary measures.

6. DATA AND CONTACTS OF THE DATA MANAGER

Name: Hírek Média és Internet Technológiai Kft.
Short name: Hírek Kft.
Headquarter: Embankment Estate E3 Business Center
1036 Budapest, Lajos u. 103. I. emelet
Telephone: 06.1.373.0953 (on workdays between 10-16)
Fax: 06.1.373.0954
E-mail: media@hirek.hu
Customer service: on workdays between 10-16
Company registration number: 01-09-565272
VAT number: 12206715-2-42
Representative: Tamás Trentin

Responsible for data protection: Tamás Tóth
Post of the responsible for data protection: development director
Contacts of the responsible for data protection: 06-1-373-0953, toth.tamas@hirekmedia.hu

Record numbers of data management: 00634-000X, 00634-000X.

7. LEGAL REMEDY POSSIBILITIES

The user can request information about the management of its personal data, and can request the correction of its personal data, and its deletion by the one responsible for data protection of Hírek Kft -except for the data processing ordered by law.

For the request of the user Hírekt Kft. provides information about the data it manages, and about the data processed by the responsible data processor, the purpose of the data management, the legal basis of the data management, the time, the name of the data processor, the address (headquarter), and the activities related to data management, as well as about who received the data and for what purpose. The data manager gives the requested information in writing in a comprehensible form, within the shortest period of time from the submission of the request, but not later than 30 days. This information is free, unless the person requesting the information has not already submitted other requests to the data controller relating to the same field in the same year. In other cases Hírek Kft. estabilishes a compensation.

Hírek Kft. deletes the personal information when its handling is illegal, the user requests it, the purpose of data management ceases, the statutory deadline of storing the data expired, it was ordered by the court or the privacy commissioner.

Hírek Kft. notifies the user and those for whom it forwarded the data for processing about its correction or deletion. This notice can be omitted, if it does not offend the legitimate interest of the concerned party regarding the purpose of data management.

The user can protest against its personal data handling if
a) the management of its personal data (transmission) is necessary only for the validation of the rights or legitimate interests of the data manager or the person who receives the data, unless the data processing was ordered by law;
b) the use or transmission of the personal data is for direct marketing, public opinion or scientific research;
c) to protest is permitted by law.

Hírek Kft. - with the simultaneous suspension of the data processing - examines the protest within the shortest period of time from the submission of the protest, but not later than 15 days, and notifies the applicant in writing. If the objection is justified the data controller eliminates the data management - including the further data recording and transmission -, blocks the data, and informs those who have received the personal data concerned in the protest and those who are obliged to take actions for enforcing the protesting rights about the protest and the taken actions.
If the concerned party does not agree with the decision of the data controller, it can go to court - within 30 days of the notification.

Hírek Kft. can not delete the personal data of the user, if the data management is ordered by law. The data, however, may not be transferred if the data controller agrees with the objection and the court justified the objection.
The concerned party can go to court in case of the infringements of its rights. The court decides out of turn about the case.
Hírekt Kft. reimburses the damage caused by the illegal handling of data of the concerned party or by the breach of the technical requirements of data protection. The controller is exempted from the liability if the damage was made by unavoidable causes outside the scope of data management.
It does not compensate the damage if it was caused by the victim's intentional or negligent behaviour.

If you have any problem with the data management of Hírek Kft. contact our data protection auditor: www.ppos.hu/audit.

For legal remedy contact the privacy commissioner:

Name: Adatvédelmi Biztos Hivatala
Headquarter: 1051 Budapest, Nádor u. 22.
Mailing address: 1387 Budapest, Pf.: 40.
Telephon: 06-1-475-7186, 475-7100
Fax: 06-1-269-3541
E-mail: adatved@obh.hu

Supervisor bodies:
Name: Budapest Főváros Közigazgatási Hivatal
Fogyasztóvédelmi Felügyelőség
Headquarter: 1088 Budapest, József krt. 6
Mailing address: 1364 Budapest, Pf.: 234.

Name: Budapest II. Kerület Polgármesteri Hivatal
Headquarter: 1024 Budapest, Mechwart liget 1.