Data protection

1.General legal notice

Domján Enikő Mária ev. (PwG Communication) – (refer to her as the “Data Controller” or “Controller”) acknowledges the content of this legal notice as binding.

The Data Controller processes the personal data of registered users in connection with service activities, solely for the purpose of providing services and in order to fulfil obligations in connection with the provision of services (e.g. billing) and to ensure the provision of the service. The Data Controller will only process personal data that is necessary for the purposes of the processing and is adequate to achieve the purposes for which it is processed. Process personal data only to the extent and for the duration necessary to achieve the purpose.

The Data Controller will only use personal data for marketing and promotional purposes, if concerned people have given their specific consent.

The Data Controller is committed to protecting the personal data of customers and partners, and attaches great importance to respecting the right to information self-determination of customers. The Data Controller treats personal data confidentially and takes all security, technical and organizational measures to ensure the security of the data.

The Data Controller reserves the right to change this information.

2. Data controller’s data

Legal name: Domján Enikő Mária ev. (in English: Eniko Maria Domjan sole proprietorship)

Registration number: 54125571

Representative: Enikő Mária Domján

Tax number: 55447386-1-38

Email address: eniko.domjan@pwgcommunication.com

 3.Privacy Policy

The data processing of the Data Controller’s activities is based on voluntary consent and legal authorization. In the case of processing based on voluntary consent, data subjects may withdraw their consent at any time during the processing.

In certain cases, the processing, storage and transmission of some of the data provided may be required by law.

Data subjects are reminded that if they do not provide their own personal data, it is their obligation to obtain the data subject’s consent.

The legal representative may give consent on behalf of a User who is under the age of 16 or otherwise incapacitated.

Data management principles are in accordance with the applicable data protection legislation, in particular the following:

• Act CXII of 2011 – on the Right to Informational Self-Determination and Freedom of Information (Infotv.); Regulation (EU) 2016/679 of the European Parliament and of the Council of 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/EC (General Data Protection Regulation, GDPR); Act V of 2013 – on the Civil Code (Civil Code);
• Act C of 2000 – on Accounting (Accounting Act);
• Act LIII of 2017 – on the Prevention and Combating of Money Laundering and Terrorist Financing (PMT);
• Act CCXXXVII of 2013 – on Credit Institutions and Financial Undertakings (Hpt.).

4.Scope of data processed

No data is required to visit the site, but personal data is required to subscribe to the newsletter and to order the service.

Personal data to be provided when subscribing to the newsletter: name, email address

Personal data to be provided when ordering a service: name, email address, billing name, billing address

When you visit the site, our system records the IP address of the user, which in some cases can be used to identify the concerned person, the operating system and browser type used, the page visited and the referrer of the page visited. The purpose of this recording is to guarantee the security of the system, to identify possible hacker attacks, to disable IP addresses from which unwanted traffic (e.g. overload attack or attempted intrusion) is coming.

The Data Controller performs backups at regular intervals. The purpose of backups is primarily of a technical nature, which is essential for the continued operation of our sites’ systems.

5.Purpose of data processing

To inform the user about changes, news and information related to the service.

To compile statistics on visits and visitors for own usage.

6.Duration of data processing

Data provided during registration and generated during the use of the service will be stored until the user requests their deletion. The deletion can be initiated by the user at any time using the delete profile function on the profile page. Technical data related to the number of visits (IP address, operating system, browser type, etc.) are stored for 3 years, after which the Operator will only keep them in aggregate form, as statistics on visits.

7.Data subjects and data processors

The Data Controller’s designated employees are entitled to access the processed data.

7.1. Server and hosting services

Name: DotRoll Kft.

Location: 1148 Budapest, Fogarasi Street 3-5., Hungary

Email address: support@dotroll.com

Website: https://dotroll.com/

Data transmitted: name, email address, IP address

Purpose of transmission: to provide server and hosting services, including for data storage purposes

7.2. Billing

Name: Billingo

Registered address: 1133 Budapest, Árbóc utca 6. 3. em.

Email address: hello@billingo.hu

Website: www.billingo.hu 

Data transmitted: family name, first name, email address, billing name, billing address, purchase details

Purpose of transmission: to issue a fee request and invoice

7.3. Subscription to the newsletter

Name: MailerLite Limited

Address: Ground Floor, 71 Lower Baggot Street, Dublin 2, D02 P593

Email address: info@mailerlite.com  

Website: www.mailerlite.com  

Data transmitted: email address, name

Purpose of transmission: sending digital material by email

8. Data subject’s rights and means of enforcement

The data subject may request information about the processing of his or her personal data, may request the rectification, erasure or withdrawal of his or her personal data, with the exception of mandatory data processing, and may exercise the right to data portability and objection rights in the manner indicated when the data were collected or at the above contact details of the controller.

8.1 Right to information

The Data Controller shall take appropriate measures to provide data subjects with all the information referred to in Articles 13 and 14 of the GDPR and each of the notifications referred to in Articles 15 to 22 and 34 of the GDPR concerning the processing of personal data in a concise, transparent, intelligible and easily accessible form, in clear and plain language.

8.2. The data subject’s right of access

The data subject has the right to obtain from the controller feedback as to whether or not his or her personal data are being processed and, if such processing is ongoing, the right to access the personal data and the following information:

• the purposes of the processing;
• the categories of personal data concerned;
• the recipients or categories of recipients to whom or with whom the personal data have been or will be disclosed, including in particular recipients in third countries or international organizations;
• the envisaged period of storage of the personal data;
• the right to rectification, erasure or restriction of processing and the right to object;
• the right to lodge a complaint with a supervisory authority;
• information on the data sources;
• the fact of automated decision-making, including profiling, and the logic used and clear information on the significance of such processing and its implications for the data subject

likely consequences for the data subject.

The controller shall provide the information within a maximum of one month from the date of the request.

8.3. Right of rectification

The data subject may request the rectification of inaccurate personal data concerning him or her processed by the Controller and the completion of incomplete data.

8.4. Right to erasure

The data subject shall have the right to obtain from the Data Controller, upon his or her request, the erasure of personal data relating to him or her without undue delay where one of the following grounds applies:

• the personal data is no longer necessary for the purposes for which they were collected or otherwise processed; the data subject withdraws the consent on the basis of which the processing was carried out and there is no longer any need for the processing
• the data subject objects to the processing and there are no overriding legitimate grounds for the processing;
• the personal data has been unlawfully processed;
• the personal data must be erased in order to comply with a legal obligation under Union or Member State law to which the controller is subject;
• the personal data has been collected in connection with the provision of information society services.

The erasure of the data cannot be initiated if the processing is necessary:

• to exercise the right to freedom of expression and information;
• to comply with an obligation under Union or Member State law to which the controller is subject to which the processing of personal data is subject, or in the public interest or in the exercise of official authority vested in the controller
• the performance of a task carried out in the exercise of a public authority;
• for archiving purposes, scientific and historical research purposes or statistical purposes in the public interest in the field of public health;
• or for the establishment, exercise or defense of legal claims.

8.5. Right to restriction of processing

At the request of the data subject, the Controller shall restrict processing if one of the following conditions is met:

• the data subject contests the accuracy of the personal data, in which case the restriction shall apply for a period of time which allows the accuracy of the personal data to be verified;
• the processing is unlawful and the data subject opposes the erasure of the data and requests instead the restriction of their use;
• the controller no longer needs the personal data for the purposes of the processing but the data subject requires them for the establishment, exercise or defense of legal claims; or
• the data subject has objected to the processing; in this case, the restriction shall apply for a period of time until it is established whether the legitimate grounds of the controller override the legitimate grounds of the data subject.

If the processing is subject to restriction, the personal data shall, except for storage, only be processed with the consent of the data subject or for the establishment, exercise or defense of legal claims or interests of another natural or legal person or for important public interests of the Union or of a Member State.

8.6. Right to data retention

The data subject has the right to obtain the personal data concerning him or her that he or she has provided to the controller in a structured, commonly used, machine-readable format and to transmit these data to another controller.

8.7 Right to object

The data subject shall have the right to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her which are processed for a task carried out in the public interest or in the exercise of official authority vested in the controller. Processing necessary for the performance of a task carried out in the exercise of official authority vested in the controller, or processing necessary for the purposes of the legitimate interests pursued by the controller or by a third party, including profiling based on those provisions. In the event of an objection, the controller may no longer process the personal data, except on compelling legitimate grounds which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.

8.8 Automated decision-making in individual cases, including profiling

The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

8.9 Right of withdrawal

The data subject has the right to withdraw his or her consent at any time.

9. Contact, Remedies

The user who feels that the Data Controller has violated his/her right to the protection of personal data may lodge a complaint with the National Authority for Data Protection and Freedom of Information (registered office: 1125 Budapest, Szilágyi Erzsébet fasor 22/C), and may enforce his/her claim before a civil court. Detailed legal provisions on this and on the obligations of the data controller are set out in the following laws:

• Act CXII of 2011 – on the Right to Informational Self-Determination and Freedom of Information (Info Act, Data Protection Act)
• Act CVIII of 2001 – on certain aspects of electronic commerce services and information society services (Eker. tv.)
• Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions on Commercial Advertising (Act XLVIII of 2008)

The Data Controller will, however, endeavor to clarify any problems that may arise and will be happy to consult you on any data protection issues that may arise.

10. Placing an anonymous visitor identifier (“cookie”)

An anonymous visitor identifier (“cookie”) is a unique set of signals that is placed on a visitor’s computer by a web server to identify the visitor and store profile information. Such a sequence of signals is not in itself capable of identifying the visitor in any way, but only of recognizing the visitor’s computer. It does not contain a name, e-mail address or any other personal information. Accepting cookies is not required to browse the Website. Not only the website sends a cookie to the visitor’s browser, but also an external, independent auditing service (Google Analytics) measures the site’s visit by such means. Details of how this measurement data is handled can be found at http://www.google.com/intl/hu/analytics.

The Site contains so-called remarketing tags for the purpose of building remarketing lists, so that after your visit, third-party service providers, including Google, may display advertisements on Internet sites, so-called interest-based advertisements. Remarketing lists are not personally identifiable, they do not contain any personal data of the visitor, they only identify the browser software. Google uses cookies for remarketing tags. The Website uses so-called conversion tracking to measure the effectiveness of Google Ads ads. The conversion tracking cookie is for a limited time only, is optional, does not record or use any personal information.

Visitors can disable Google’s usage of cookies by visiting the Google Ads settings at http://www.google.com/settings/ads. You can also opt-out of cookies from other third-party providers by visiting the Network Advertising Initiative opt-out page (http://www.networkadvertising.org/managing/opt_out.asp). Facebook like buttons are available on the Website. These buttons also place cookies on the visitor’s browser. For more information about Facebook’s privacy policy, please visit http://www.facebook.com/about/privacy/. The Website uses Facebook’s so-called conversion tracking pixel to measure the effectiveness of Facebook ads. No personal data of the visitor is recorded during conversion tracking. Disabling Google and Facebook cookies does not affect the purchase.

01.01.2023 Budapest                                               Domján Enikő Mária ev.