|Purpose of data processing
||Subscription to newsletters
||Subscription to the blog
|Scope of processed data
|Duration of data processing
1. Purpose of this document
2. Availability and updating of this document
NNG reserves the right to amend this document unilaterally in the future. We suggest visiting the webpage www.nng.com (hereinafter referred to as “Site”) in order to follow such amendments.
3. Data controller
The data provided on this Site is processed by NNG Software Developing and Commercial Limited Liability Company (hereinafter referred to as “NNG”) as data controller.
Registered office of NNG: H-1037 Budapest, Szépvölgyi rd. 35-37, Hungary
Court of registration: Capital Regional Court (in Hungarian: Fővárosi Törvényszék)
Company registration number: Cg.01-09-891838
Tax number: 13357845-2-44
E-mail address: email@example.com
The provided data is accessible to the following persons:
- NNG’s employees and managers involved in the execution of the purpose of the data collection;
- IT specialists performing a variety of IT tasks related to the operation and maintenance of NNG’s computer system and
- the data processor of NNG (see section 12) regarding the sending of newsletters.
4. Purpose of the data processing and scope of the processed data
4.1. Any personal information which you supply to NNG must be true, complete and accurate in all respects.
4.2. Personal data provided by User is processed for the following purposes:
4.2.1. Sending newsletters
NNG can send newsletters to Users who subscribe according to the terms described in section 11. In relation to sending newsletters NNG may evaluate and measure the effectiveness of its campaigns as described in section 12.2 by involving a data processor. In order to send newsletters NNG processes the following personal data of the User:
- first and last name;
- e-mail address.
4.2.2. Notification of Users about the entries on NNG’s blog
Users can subscribe to NNG’s blog on this Site. By ticking the appropriate checkbox Users will receive notifications about the latest entries on the blog. In order to send such notifications NNG processes the following personal data of the User:
- first and last name;
- e-mail address.
5. Legal basis of data processing
5.1. Data processing activities are carried out in compliance with Act CXII of 2011 on the right of informational self-determination and on freedom of information (“Privacy Act”) and Act XLVIII of 2008 on the Basic Requirements and Certain Restrictions of Commercial Advertising Activities (“Advertising Act”).
The legal basis of data processing is
- the consent of the User given pursuant to point a) of section 5 (1) of the Privacy Act and
- the consent of the User given pursuant to section 6 (1) and (2) of the Advertising Act.
5.2. As of 25th May 2018, the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th 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 Directive 95/46/EC (“General Data Protection Regulation” or “GDPR”) shall apply. As of this date, the legal basis of data processing will be the consent of the data subject, as set forth in point a) in Article 6(1) of the GDPR.
6. Consent to the provisions of this Policy
By subscribing to NNG’s newsletter or NNG’s blog by ticking the appropriate checkbox(es), you expressly and voluntarily give your consent to NNG to process your personal data according to the provisions of this Policy and in line with the data protection rules of the law.
|Types of cookie||Purpose of the cookies||Cookie retention period|
|Google Analytics||The Site uses Google analytics tool to carry out access measurements and to collect information about how Users use the Site. We use the information to compile reports and to help us improve the Site. The data is collected in an anonymized form, including the number of Users to the Site, where Users have come to the Site from and the pages they visited within the Site. The collected data cannot be tracked back to a User. For further information on Google’s privacy click here.
||Google Analytics Cookies are created as soon as User visits a website on which a valid Google Analytics tracking code is installed. Cookies will be held on the User’s device for a maximum period of 2 years from the above date. For further information please click here.|
|Session||Session Cookies allow Users to be recognized within the Site so User will not be asked for the same information he/she has already given to the Site.||The information is saved until the end of a session. Sessions means the time period while User visits the Site. After that, the collected information will no longer be available.|
|Persistent||Persistent Cookies remember the language settings applied by the User.||The cookie will be deleted automatically after 1 year.|
|Facebook pixel||Facebook pixel is a code that helps to track behavior and conversions of Users. It enables Facebook to both report back on the number of actions Facebook ads drive as well as allow Facebook to learn which people that see our ads are more likely to result in doing a certain action on our Site, such as a purchase, and optimize the delivery of ads to result in more of these actions.||The cookie will be held in the User’s browser for a maximum period of 180 days.|
Please note that there are links on the Site that lead to other web sites. To the usage of such external web sites their respective data protection rules shall apply, therefore after you click on their link or the provided button, NNG will no longer have any influence over the collection, storage, or processing of any personal data transmitted by clicking.
9. Duration of data processing
9.1. The retention period of your personal data uploaded to this Site depends on your activity. Your personal data shall be deleted 2 years after your last activity (e.g. opening a newsletter, visiting NNG’s blog) should NNG notice that you have not been active on the Site for at least 2 years.
9.2. Notwithstanding the above, NNG deletes the personal data immediately in case you specifically request the deletion thereof.
10. Data security
NNG observes all applicable regulations regarding the security of personal data, therefore both NNG and its authorized data processor implement appropriate technical and organizational measures to protect personal data, and adequate procedural rules to enforce the provisions of the Privacy Act concerning confidentiality and the security of data processing.
11.1. Users can subscribe on the newsletter and the blog of NNG on this Site. By ticking the appropriate checkbox Users voluntarily give their consent that NNG may send them newsletters from time to time.
11.2. User has the right to withdraw such consent any time by sending an email to firstname.lastname@example.org or by sending mail to NNG’s address (H-1037 Budapest, Szépvölgyi rd. 35-37.). You may also unsubscribe (opt-out) any time by following the instructions within the mailing.
11.3. Please note that NNG may decide anytime to stop sending newsletters without any notice, further liability or obligation of any kind.
11.4. Registration number of such data controlling: NAIH-118610/2017.
12. Data processor
12.1. Data processing is carried out on behalf of NNG by a data processor which provides e-mail marketing services. The data processor provides NNG with an online system (hereinafter referred to as the “System”), through which NNG can manage the sending of newsletter to the Users.
12.2. In order to improve marketing activities, the System is used for the following purposes:
- storing the User’s personal data;
- sending e-mails to the User;
- observing whether the addressees have received the e-mail;
- observing the bounce rate (e.g. cases when the e-mail address is invalid or the e-mail is listed as spam);
- analyzing the behavior of the addressees (in particular whether the mails were opened, how many times did the addressees click on them, whether the addressee read the entire e-mail).
12.3. The User data listed in section 1 is stored both in the System and on NNG’s servers.
12.4. NNG reserves the right to change the data processor at any time.
Name of the data processor: The Rocket Science Group LLC d/b/a MailChimp
Address of the data processor: 675 Ponce De Leon Ave NE, Suite 5000 Atlanta, Georgia 30308 USA
13. Rights and enforcement
13.1. User may request the following from NNG as data controller:
- information on the processing of his/her personal data;
- rectification of the personal data and
- deletion or blocking of personal data (unless processing of the personal data is mandatory).
13.2. You are entitled to request information on the data processing carried out by NNG, especially information as to what personal data is stored relating to you, the sources from which they were obtained, the purpose, grounds and duration of processing, if your personal data is made available to others, the legal basis and the recipients, and any data protection incident in relation to your personal data by sending an email to email@example.com or a mail to NNG’s address (H-1037 Budapest, Szépvölgyi rd. 35-37.). NNG provides information on personal data processing within 25 days upon submission of the respective request, in writing. You may also can request the correction or blocking of your personal data.
13.3. In case the personal data is inaccurate, you may request NNG to rectify such data provided that the correct data is at NNG’s disposal.
13.4. Your data may be deleted upon your request. Request for data deletion may be submitted to NNG by using the email or postal address specified below. NNG also deletes all stored personal data of which knowledge is no longer necessary for the performance of the purpose or if the storage of the personal data is inadmissible due to legal reasons. Personal data that is subject to legal obligation to preserve is not affected.
13.5. Personal data shall be blocked instead of being deleted if so requested by User as data subject, or if there are reasonable grounds to believe that deletion could affect the legitimate interest of the User.
13.6. Please be informed that your data will not be deleted if the processing thereof is required by law.
13.7. You may lodge a complaint about the processing of your personal data to the National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság, hereinafter referred to as “NAIH”; address: H-1125 Budapest, Szilágyi Erzsébet fasor 22/C.; postal address: 1530 Budapest, Pf. 5.; 5 phone: +36-1-391-1400; facsimile: +36-1-391-1410; email: firstname.lastname@example.org).
13.8. Independently from lodging a complaint to NAIH, in the event of the infringement of your rights You may turn to court pursuant to the provisions set forth in the Privacy Act. Upon your decision the procedure might be launched before the tribunal in whose jurisdiction you are domiciled or you have a temporary address. Prior to initiating a legal procedure, it might be useful to discuss the complaint with NNG.
13.9. Your detailed rights and remedies are set out in the subsections 14-18 and 21-23 of the Privacy Act.
14. Limited applicability of this Policy
15. Contact NNG
We value your opinion. If you have any comments or questions or wish to obtain more information regarding the data processing at NNG, please let us know via this Site using the Contact us menu item or write to NNG’s official address. We will treat the submitted information confidentially. Our representative will contact you within a reasonable time.
This Policy has been posted and is effective as of 1st June 2017.