|Purpose of data processing||Subscription to newsletters||Subscription to the blog|
|Data controller||· NNG
|Scope of processed data||· User’s first and last name;
· User’s email address.
|· User’s first and last name;
· User’s email address.
|Legal basis||· User’s consent.
|· User’s consent.|
|Duration of data processing||· Until the User’s request for deletion.
· The User’s personal data will be deleted 2 years after the User’s last activity (e.g. opening a newsletter), should NNG notice that the User has not been active on the Site for at least 2 years.
|· Until the User’s request for deletion.
· The User’s personal data will be deleted 2 years after the User’s last activity (visiting NNG’s blog), should NNG notice that the User has not been active on the Site for at least 2 years.
|Data processor||· Mail Chimp|
1. Purpose of this document
2. Availability and updating of this document
NNG reserves the right to amend this document unilaterally at any time. We suggest visiting www.nng.com (hereinafter referred to as the “Site”) from time to time for the latest information
3. Data controller
The data provided on the 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 Szépvölgyi út 35-37, Budapest, Hungary
Court of registration: Budapest-Capital Regional Court (Fővárosi Törvényszék)
Company registration number: Cg.01-09-891838
Tax number: 13357845-2-44
Email address: email@example.com
The provided data is accessible to the following persons:
- NNG’s employees and managers involved in the accomplishment of the purpose of 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 assigned by NNG (see section 12) the task of sending newsletters.
4. Purpose of data processing and scope of processed data
4.1. Any personal information that you supply to NNG must be true, complete, and accurate in all respects.
4.2. The personal data provided by the User is processed for the following purposes:
4.2.1. Sending newsletters
NNG may send newsletters to the User who subscribes under the terms set forth in section 11. NNG may evaluate and measure the effectiveness of its newsletter campaigns as described in section 12.2, by involving a data processor. To send newsletters, NNG processes the following personal data of the User
- First and last name;
- Email address.
4.2.2. Notification of the User of entries in NNG’s blog
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. To send such notifications, NNG processes the following personal data of the User:
- First and last name;
- Email address.
5. Legal basis of data processing
5.1. The data is processed in compliance with Act CXII of 2011 on the right of informational self-determination and on freedom of information (hereinafter referred to as the “Privacy Act”) and Act XLVIII of 2008 on the basic requirements and certain restrictions of commercial advertising activities (hereinafter referred to as the “Advertising Act”).
The legal basis of data processing is
- The User’s consent given pursuant to point a) of section 5(1) of the Privacy Act and
- The User’s consent given pursuant to sections 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 (hereinafter referred to as the “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) of 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 way of ticking the appropriate checkbox(es), you expressly and voluntarily give your consent to NNG to process your personal data in compliance with the provisions of this Policy and rules of law on data protection.
|Types of Cookie||Purpose of Cookies||Cookie retention period|
|Google Analytics Cookies are created as soon as the User visits a website on which a valid Google Analytics tracking code is installed. The 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 Cookies allow the User to be recognized within the Site, so the User will not be prompted to give the information he/she has already provided.||The information is saved until the end of the current session. A session means the time period during which the User is visiting the Site. After that, the collected information will no longer be available.
|Persistent Cookies remember the language settings applied by the User.
|The Cookie is automatically deleted after 1 year.
|Facebook pixel||The Facebook pixel is a code, which helps to track User’s behaviour and conversions. It enables Facebook to report the number of actions Facebook ads drive and allow Facebook to learn which of the visitors who have seen our ads are more likely to take a certain action, e.g. make a purchase, on our Site, and optimize the delivery of ads to trigger more of such actions.||The Cookie is 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 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, NNG will no longer have any influence over the collection, storage, or processing of any personal data transmitted by your click.
9. Duration of data processing
- The retention period of your personal data uploaded to this Site depends on your activity. Your personal data will 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.
- Notwithstanding the above, NNG immediately deletes your personal data if 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 establish adequate procedural rules to enforce the provisions of the Privacy Act concerning confidentiality and the security of data processing.
11.1. The User can subscribe to newsletters and NNG’s blog on this Site. By ticking the appropriate checkbox, the User gives his/her voluntary consent that NNG send him/her a newsletter from time to time.
11.2. The User may withdraw his/her consent at any time by sending an email to firstname.lastname@example.org or by sending mail to NNG’s address (H-1037 Szépvölgyi út 35-37. Budapest, Hungary). You may also unsubscribe (opt-out) at any time by following the instructions in the newsletter.
11.3. Please note that NNG may at any time decide to stop sending newsletters without prior notice, or 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 email 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 newsletters to the User.
12.2. To improve 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;
- Analysing the bounce rate (e.g. cases when the email address is invalid or the email is listed as spam);
- Analysing the addressee’s behaviour (in particular whether the email was opened, how many times the addressee clicked on it, whether the addressee read the entire email).
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. The User may request the following from NNG as data controller:
- Information on the processing of his/her personal data;
- Rectification of his/her personal data; and
- Deletion or blocking of his/her personal data (unless the 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 relating to you is stored; the sources from which they were obtained; the purpose, grounds, and duration of data 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 mail to NNG’s address (H-1037 Szépvölgyi út 35-37. Budapest, Hungary). NNG shall provide written information on the processing of your personal data within 25 days after receipt of your request. You may also request the correction or blocking of your personal data.
13.3. If your 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 shall be deleted upon your request. Your request for data deletion may be submitted to NNG by using the email or postal address specified below. NNG shall delete all stored personal data the knowledge of which is no longer necessary for the achievement of the purpose of data processing, or if the storage of the personal data is inadmissible for legal reasons. Personal data that is preserved by a rule of law shall not be affected.
13.5. The personal data shall be blocked instead of being deleted if so requested by the User as data subject, or if there are reasonable grounds to believe that the 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 Szilágyi Erzsébet fasor 22/C Budapest, Hungary; postal address: H-1530 Budapest, Pf. 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, you may turn to court pursuant to the provisions set forth in the Privacy Act 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 NNG.
13.9. Your detailed rights and remedies are set out in subsections 14–18 and 21–23 of the Privacy Act.
14. Limited applicability of this Policy
15. Contacting NNG
We value your opinion. If you have any comments or questions, or wish to obtain more information on data processing at NNG, please use the Contact us menu on this Site or write to NNG’s official address. We will handle the submitted information confidentially. Our representative will contact you within a reasonable time.
This Policy was posted and is effective as of 19 June 2017.