Privacy Policy

Privacy Policy

 

1. Purpose of this document

This Privacy Policy (hereinafter referred to as the “Policy”) sets the terms and conditions on how the data subject’s (hereinafter referred to as the “User” or “you”) personal or anonymous information is processed. Please read these terms and conditions carefully!

2. Definitions

General Data Protection Regulation or GDPR means 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.

NNG means NNG Software Developing and Commercial Limited Liability Company.

  • Registered office: H-1037 Budapest, Szépvölgyi út 35-37, Hungary
  • Court of registration: Budapest-Capital Regional Court (Fővárosi Törvényszék)
  • Company registration number: Cg.01-09-891838
  • Tax number: 13357845-2-44
  • Email address: privacy@nng.com
  • Website: www.nng.com

Site means www.nng.com and its subdomains

User or “you” means a registered or not registered visitor of the Site.

3. Availability and updating of this document

The Data Controller reserves the right to amend this document unilaterally at any time. We suggest visiting the Site from time to time for the latest information.

4. Data controller(s)

The data provided on the Site is processed by NNG (hereinafter referred to as “Data Controller”).

The provided data is accessible to the following persons:

  • NNG’s employees involved in the data processing (including IT specialists performing a variety of IT tasks related to the operation and maintenance of NNG’s computer system) as part of their role within NNG in connection with performing their duties associated with the purpose of this Policy.

5. Data processing activities 

5.1 Sending newsletters or other promotion related e-mails

The User can subscribe to newsletters on the Site. By ticking the appropriate checkbox, the User gives his/her voluntary consent that the Data Controller may send him/her a newsletter from time to time.

5.1.2. Purpose of the data processing

The Data Controller may send newsletters to the User who subscribes under the terms set forth in this section to inform the User about new products, promotions, blog entries or other marketing activities. The Data Controller may also inform Users in such newsletters about business offers and opportunities. In order to provide You with personalized newsletters relevant for You and increase your user experience and satisfaction and to evaluate and measure the effectiveness of its newsletter campaigns, NNG uses profiling techniques with the involvement of the data processor described in section 9.

  • Scope of User’s processed personal data:
  • First and last name;
  • Email address,
  • Company name (optional),
  • Job Role (optional).

Data processed for Profiling purposes:

  • User’s interaction with the delivered email (i.e. whether the email was opened, how many times the addressee clicked on it, whether the addressee read the entire email);
  • Bounce rate of the newsletters sent to the User.

5.1.3. Legal basis of the data processing

The data is processed in compliance with GDPR, and all relevant local laws.

The legal basis of data processing is

  • the User’s express consent given pursuant to point a) in Article 6(1) of the GDPR and
  • sections 6(1) and (2) of Act XLVIII of 2008 of Hungary on the basic requirements of and certain restrictions on commercial advertising activities.

5.1.4. Duration of the data processing and subscription to the newsletter

Your personal data will be is retained for the 2 years after the User’s last activity (e.g. opening a newsletter), should the Data Controller notice that the User has not been active on the Site for at least 2 years, or until You unsubscribe from the newsletter or specifically request the deletion of your personal data and there is no valid legal ground for data processing.

The User may withdraw his/her consent at any time as follows:

  • By following the instructions in the newsletter. Click on the unsubscribe link at the bottom of the newsletter.
  • By sending an email to privacy@nng.com or press@nng.com.
  • By sending a mail to NNG’s address defined in section 2.

Please note that unsubscribing from the newsletter does not affect the lawfulness of data processing based on your consent and conducted before

such withdrawal.

Please note that the Data Controller may at any time decide to stop sending newsletters without prior notice, or further liability or obligation of any kind.

Please note that the newsletters are sent with the cooperation of a data processor defined in section 9.

5.2 Communication with the User on the Site

5.2.1. Purpose of the data processing

The User can send messages to the Data Controller on the Site in order to receive more information on the products offered by NNG by providing certain personal data listed in section 5.2.2.

5.2.2. Scope of User’s processed personal data:

  • First and last name;
  • Email address;
  • telephone (optional);
  • country;
  • company (optional);
  • subject of the message;
  • text of the message;
  • attachment to the message (optional).

5.2.3. Legal basis of the data processing

The data is processed in compliance with GDPR and all relevant local laws. The legal basis of data processing is the User’s express consent given pursuant to point a) of Article 6(1) of the GDPR.

5.2.4. Duration of the data processing

Your personal data will be retained for the 2 years after the User’s last activity, should the Data Controller notice that the User has not been active on the Site for at least 2 years.

Notwithstanding the above, NNG shall immediately delete your personal data if You specifically request the deletion thereof and there is no valid legal ground for data processing.

5.3. Communication with Users related to any contents available for download on the Site

5.3.1. Purpose of the data processing

The Data Controller may wish to provide access to Users to educational or any other materials (e.g. white papers, reports, webinars) in connection with the activity of NNG (hereinafter referred to as “Content”).

5.3.2. Scope of User’s processed personal data:

In order to keep contact with those Users who downloaded the Contents and inform them when there is new available content on the Site or sending newsletters or other promotion related e-mails according to section 5.1, the Data Controller collects and processes the following data of the Users:

  • First and last name;
  • Email address;
  • Company name (optional)
  • Job Role (optional)

Data processed for Profiling purposes:

  • User’s interaction with the delivered email (i.e. whether the email was opened, how many times the addressee clicked on it, whether the addressee read the entire email);
  • Bounce rate of the newsletters sent to the User.

Please note that contacting Users belongs to the Data Controller’s sole discretion and that they may decide anytime to stop informing Users without any notice, further liability or obligation of any kind.

5.3.3. Legal basis of the data processing

The data is processed in compliance with GDPR and all relevant local laws.

The legal basis of data processing is

  • the User’s express consent given pursuant to point a) in Article 6(1) of the GDPR and
  • sections 6(1) and (2) of Act XLVIII of 2008 of Hungary on the basic requirements of and certain restrictions on commercial advertising activities.

5.3.4. Duration of the data processing

The same conditions apply as set forth in section 5.1.4  of this Policy.

5.3.5. Cooperation with third parties

NNG may from time to time cooperate with carefully selected third party organizations (“Third Parties”) in the creation and publication of the Content.

We will get your express consent before we share your personal data collected in relation to this section 5.3 with any Third Party for marketing purposes. If you have opted-in, we may share your personal data with the Third Parties explicitly marked by the given Content and they may contact you directly (unless you have asked them not to do so) by email about products, services, promotions and special offers they offer that may be of interest to you.

Please note that these Third Parties qualify as data controller in respect of personal data shared with them and such data is processed by the Third Parties in accordance with the provisions of their privacy policy.

Data processing conducted by Partner, i.e. further transfer of personal data within its company group is not covered by this Policy.

Following the transfer of the personal data described in this section, the Third Party is directly liable for the processing of such data. Should any claim occur related to the data processing, as from this date, the User shall address such claim directly to the Third Party.

5.4. Notification of the User of entries in NNG’s blog

5.4.1. Purpose of the data processing

The User can subscribe to NNG’s blog on this Site. By ticking the appropriate checkbox, the User will receive notifications of the latest entries in the blog (“Blog Notification”).

5.4.2. Scope of User’s processed personal data:

To send Blog Notifications, NNG processes the following personal data of the User:

  • First and last name;
  • Email address.

5.4.3. Legal basis of the data processing

The data is processed in compliance with GDPR and all relevant local laws. The legal basis of data processing is the User’s express consent given pursuant to point a) of Article 6(1) of the GDPR.

5.4.4. Duration of the data processing and subscription to the newsletter

Your personal data will be is retained for the 2 years after the User’s last activity (e.g. visiting NNG’s blog), should the Data Controller notice that the User has not been active on the Site for at least 2 years, or until You unsubscribe from the Blog Notification or specifically request the deletion of your personal data and there is no valid legal ground for data processing.

The User may withdraw his/her consent at any time as follows:

  • By following the instructions in the Blog Notification. Click on the unsubscribe link at the bottom of the Blog Notification.
  • By sending an email to privacy@nng.com or press@nng.com.
  • By sending a mail to NNG’s address defined in section 2.

Please note that unsubscribing from the Blog Notifications does not affect the lawfulness of data processing based on your consent and conducted before

such withdrawal.

Please note that the Data Controller may at any time decide to stop sending Blog Notifications without prior notice, or further liability or obligation of any kind.

Please note that the Blog Notifications are sent with the cooperation of a data processor defined in section 9.

6. Consent to the provisions of this Policy

6.1. By subscribing to the newsletter or to the blog, sending communication via the Site or downloading Contents by way of ticking the appropriate checkbox(es), you expressly and voluntarily give your consent to the Data Controller to process your personal data in compliance with the provisions of this Policy and rules of law on data protection.

6.2. Any personal information that you supply to the Data Controller must be true, complete, and accurate in all respects.

7. Links

Please note that there are links on the Site that lead to other websites. Their respective data protection rules apply to the use of such external websites, therefore after you click on their link or the provided button, the Data Controller will no longer have any influence over the collection, storage, or processing of any personal data transmitted by your click.

8. Data security

The Data Controller observes all applicable regulations regarding the security of personal data, therefore both the Data Controller and its authorized data processor(s) implement appropriate technical and organizational measures to protect personal data and establish adequate procedural rules to enforce the provisions of all applicable laws concerning confidentiality and the security of data processing.

9. Data processor(s)

9.1. For making Contents available to the Users and/or for provisioning e-mail marketing services, NNG cooperates with data processors. The data processor provides NNG with an online system (hereinafter referred to as the “System”), through which Data Controller can manage the provisioning of the Contents and/or sending newsletters to the Users.

9.2. To improve user experience or marketing activities, the System is used for the following purposes:

  • Storing the User’s personal data;
  • Sending emails to the User;
  • Checking whether the addressee has received the email;
  • Analyzing the bounce rate (e.g. cases when the email address is invalid or the email is listed as spam);
  • Analyzing the addressee’s behavior (in particular whether the email was opened, how many times the addressee clicked on it, whether the addressee read the entire email);
  • Allowing for the User the download of the Content;
  • Analyzing the User’s interaction with the downloaded Content.

9.3 The User data listed in section collected and processed under this Policy is stored both in the System and on the NNG’s servers.

9.4. NNG reserves the right to change the data processor at any time.

9.5. List data processors related to this purpose:

Name: salesforce.com EMEA Limited
Address: Floor 26 Salesforce Tower, 110 Bishopsgate EC2N 4AY London, UK
Website: https://www.salesforce.com
Contact information: https://www.salesforce.com/form/contact/contact-privacy.jsp

 

Name: The Rocket Science Group LLC d/b/a MailChimp
Address: 675 Ponce De Leon Ave NE, Suite 5000 Atlanta, Georgia 30308 USA
Website: https://mailchimp.com/
Contact information: https://mailchimp.com/contact/

 

10. Rights and enforcement

10.1. You may exercise your rights in respect of and against the Data Controller.

10.2. You may exercise the following rights in relation to the Data Controller’s data processing activities:

  • Request information on the processing of your personal data;
  • Request data portability;
  • Request the rectification of your personal data;
  • Request the deletion of your personal data or restriction of the processing of your personal data;
  • Object to NNG’s data processing.

10.3. You are entitled to request information on data related to you and processing carried out by the Data Controller thereof, especially information as to what personal data relating to you is stored; 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 or mail to the email or postal address (registered office) specified in section 2. The Data Controller shall provide written information on the processing of your personal data within 1 months after receipt of the request. You may also request the correction of your personal data.

10.4. You are also entitled to request a structured, commonly used and machine-readable formatted copy of your personal data that the Data Controller is processing subject to conditions set out in Article 20 of the GDPR.

You have the right to transmit your personal data to another controller or, where it is technically feasible, you can request the Data Controller to transfer your personal data directly to another controller as specified in Article 20 of the GDPR.

10.5. If your personal data is inaccurate, you may request the Data Controller to rectify such data, provided that the correct data is at the Data Controller’s disposal.

10.6. Your personal data shall be deleted upon your request in accordance with applicable laws. Your request for data deletion may be submitted to the Data Controller by using the email or postal addresses (registered office) specified in section 2. The Data Controller shall delete all stored personal data in compliance with this Policy by obfuscating your personal data, by making it anonym in a permanent and non-reversible manner. Please be informed that your data will not be deleted if the processing thereof is required by law or other exceptions apply under applicable law.

10.7. You have the right to obtain restriction of processing from the Data Controller in the following cases:

  • you think that your processed personal data is not accurate, for a period enabling the Data Controller to verify the accuracy of your personal data;
  • the processing is unlawful and you oppose the erasure of your personal data, you are entitled to request restriction of their use instead;
  • the Data Controller no longer needs your personal data for the purposes of processing, but you require the Data Controller to continue the processing for the establishment, exercise or defence of your legal claims;
  • you have objected to processing, for a period pending the verification whether the legitimate grounds of the Data Controller override those of yours.

10.8. At any time, you have the right to object to processing your personal data subject to certain conditions under applicable laws, you may separately object against processing your personal data for direct marketing purposes, including profiling. In this case, the Data Controller will no longer process your personal data unless the Data Controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and data protection related freedoms or if the processing is necessary for the establishment, exercise or defence of legal claims.

10.9. 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 – NAIH; address: H-1055 Budapest, Falk Miksa utca 9-11.; postal address: 1363 Budapest, Pf. 9; phone: +36-1-391-1400; facsimile: +36-1-391-1410; email: ugyfelszolgalat@naih.hu) or to the data protection authority of your home country or country of your residency.

10.10. Independently from lodging a complaint to the data protection authority, you may turn to court pursuant to the provisions set forth in the GDPR if your rights are infringed. Upon your decision, the procedure may be launched before the tribunal in whose jurisdiction you are domiciled or you have a temporary address. Prior to initiating a legal procedure, it may be useful to discuss the complaint with the Data Controller.

10.11. Your detailed rights and remedies are set out in Articles 15-21 of the GDPR.

11. Limited applicability of this Policy

This Policy is not applicable to the Career Portal of the Site.

12. Contacting the Data Controller

We value your opinion. If you have any comments or questions, or wish to obtain more information on data processing from the Data Controller, please use the Contact us menu on this Site or write to any official addresses of the Data Controller. We will handle the submitted information confidentially. Our representative will contact you within a reasonable time.

The data protection officer (DPO) of the Data Controller can be contacted under DPO@nng.com email address.

This Policy was posted and is effective as of 19th October 2021.