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Privacy Policy

DATA MANAGEMENT AND PRIVACY POLICY

Introduction

The FÜGGETLENÜL EGYMÁSSAL Közhasznú Egyesület / Independently Together Public Benefit Association (1027 Budapest, Jurányi u. 1-3., Tax number: 18498507-2-41, hereinafter referred to as FÜGE Khe.), was founded in 2006 as an officially registered organisation, with the aim of implementing cultural, especially theatre and cross-disciplinary arts projects, providing production services and an institutional background.

Our data protection registration number is: NAIH-xxxxx/2013

In connection with the processing of data, FÜGE Khe. hereby informs visitors of its website (www.juranyihaz.huwww.fugeprodukcio.hu) about the personal data it processes, its principles and practices regarding the processing of personal data, and the ways and means of exercising the rights of data subjects.

FÜGE Khe. is committed to protecting the personal data of its users and visitors and to respecting visitors’ right to information self-determination and the privacy rights of its partners, customers and visitors. The personal data recorded will be treated confidentially, in accordance with data protection legislation and international recommendations, in accordance with this Privacy Policy and will take all security, technical and organisational measures to ensure the security of the data.

Information on the data management activities of FÜGE Khe., the current version of the Privacy Policy, are available at www.fugeprodukcio.hu.

FÜGE Khe. reserves the right to change this Policy and will notify its customers and visitors of any changes in a timely manner.

Guests who become clients of FÜGE Khe. agree to the following and consent to the processing of their data as set out below.

1./ Purpose of the Privacy Policy


The purpose of this Policy is to ensure that FÜGE Khe. complies with the applicable data protection legislation, in particular:

- Act CXII of 2011 - on the Right to Informational Self-Determination and Freedom of Information
- Act CVIII of 2001 - on certain aspects of electronic commerce services and information society services;
- Act XLVII of 2008 - on the prohibition of unfair commercial practices against consumers;
- Act XLVIII of 2008 - on the basic conditions and certain restrictions on commercial advertising.


2./Scope of the Privacy Policy

2.1 Temporal scope

This Privacy Policy shall be effective from 1 January 2013 until further notice or until revoked.

2.2 Personal scope


The scope of this Privacy Policy extends to the FÜGE Khe., to the persons whose data are included in the processing covered by this Policy and to the persons whose rights or legitimate interests are affected by the processing.

2.3 Subject matter

This Policy applies to all processing of personal data carried out by all departments of the FÜGE Khe.


3./Concepts

The following terms are used in applying the Privacy Policy:
a) data subject: any natural person who is identified or can be identified, directly or indirectly, on the basis of specific personal data;
(b) personal data: data which can be associated with the data subject, in particular the name, identification, factors specific to the physical, physiological, mental, economic, cultural or social identity of the data subject, and the inference that can be drawn therefrom relating to the data subject;
(c) consent: a voluntary and explicit indication of the data subject's wishes, based on adequate information, by which he or she signifies his or her unambiguous agreement to the processing of personal data relating to him or her, whether in full or in part;
(d) objection: a statement by the data subject objecting to the processing of his or her personal data and requesting the cessation of the processing or the erasure of the data processed;
(e) data 'controller' means a natural or legal person or an unincorporated body which, alone or jointly with others, determines the purposes for which the data are processed, takes decisions regarding the processing (including the means used) and implements them or has them implemented by a processor on its behalf;
(f) 'processing' shall mean any operation or set of operations which is performed upon data, whatever the procedure used, such as collection, recording, organisation, storage, alteration, use, retrieval, disclosure, transmission, alignment or combination, blocking, erasure and destruction, as well as prevention of further use, taking of photographs, sound recordings or images and recording of physical characteristics which permit identification of individuals;
(g) 'data processor' means a natural or legal person or an unincorporated body which, under a contract with the data controller, including a contract concluded pursuant to a legal provision, carries out the processing of data;
(h) 'processing' means the performance of technical tasks related to processing operations, irrespective of the method and means used to carry out the operations and the place of application, provided that the technical task is performed on the data;
(i) 'third party' means a natural or legal person, or an unincorporated body, other than the data subject, the controller or the processor;
(j) 'transfer' means the making available of data to a specified third party;
(k) disclosure: making data available to any person;
(l) erasure: rendering data unrecognisable in such a way that it is no longer possible to retrieve them;
(m) 'data marking' means the marking of data with an identification mark in order to distinguish them;
(n) 'data blocking' means the marking of data with an identification mark for the purpose of limiting their further processing permanently or for a limited period of time;
(o) 'data destruction' means the total physical destruction of a data medium containing data;



4./ Principles of data management

Personal data may be processed if
a) the data subject consents; or
b) it is ordered by law or, on the basis of a law, by a local government decree within the scope specified by law, for a purpose in the public interest (mandatory processing).
Personal data may also be processed where obtaining the data subject's consent would be impossible or involve an disproportionate effort and the processing of the personal data is necessary for compliance with a legal obligation to which the controller is subject or is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, and the pursuit of those interests is proportionate to the restriction of the right to the protection of personal data.

The declaration of an incapacitated minor and a minor under the age of 16 with limited capacity to act requires the consent of his or her legal representative, except for those parts of the service where the declaration is for processing that occurs on a massive scale in everyday life and does not require any special consideration.

Where the data subject is unable to give his or her consent due to incapacity or for other reasons beyond his or her control, the personal data of the data subject may be processed to the extent necessary to protect his or her vital interests or those of another person or to prevent or protect against an imminent threat to the life, physical integrity or property of a person, as long as the obstacles to consent persist.

Where personal data have been collected with the consent of the data subject, the controller shall, unless otherwise provided by law

(a) for the purpose of complying with a legal obligation to which it is subject; or
(b) for the purposes of the legitimate interests pursued by the controller or by a third party, where such interests are proportionate to the restriction of the right to the protection of personal data, without further specific consent and even after the withdrawal of the data subject's consent.
Personal data may be processed only for specified purposes, for the exercise of a right and for the performance of an obligation. The processing must comply with this purpose at all stages and the collection and processing of data must be fair.

Only personal data which is necessary for the purpose of the processing, adequate for the purpose, and only to the extent and for the duration necessary for the purposes of the processing may be processed.

Personal data may only be processed with informed consent.
The data subject must be informed before the processing starts whether the processing is based on consent or whether it is mandatory. The data subject shall be informed, in a clear, plain and detailed manner, of all the facts relating to the processing of his or her data, in particular the purposes and legal basis of the processing, the identity of the controller and of the processor, the duration of the processing, whether the controller is processing the personal data of the data subject with the consent of the data subject and for the purposes of complying with a legal obligation to which the controller is subject or for the purposes of the legitimate interests pursued by a third party, and the identity of the third parties to whom the data may be disclosed. The information should also cover the rights and remedies of the data subject in relation to the processing.

The processing should ensure that the data are accurate, complete and up-to-date and that the data subject can be identified only for the time necessary for the purposes for which the data are processed.

The employees of FÜGE Khe. who are in charge of data processing in its departments are obliged to keep the personal data they receive as business secrets. Persons who process personal data and have access to them are required to sign a confidentiality declaration.



5./ Scope of personal data, purpose, legal basis and duration of processing

The data controller processes personal data solely for specified purposes, for the exercise of rights and for the performance of obligations. At all stages of processing, the purpose of the processing is fulfilled. The data are collected and processed fairly and lawfully. The data controller shall endeavour to ensure that only personal data which is necessary for the purpose of the processing and adequate for the purpose of the processing is processed. Personal data shall only be processed to the extent and for the duration necessary to achieve the purpose.
Please note that if you do not provide your own personal data but another data subject’s, you are obliged to obtain the consent of that data subject.

5.1 Data processing on the website

a) The legal basis for the processing of data on the website is the consent of the User and Article 13/A (3) of Act CVIII of 2001 on certain aspects of electronic commerce services and information society services.


b) Scope of data processed: persons registered on the website www.fugeprodukcio.huwww.juranyihaz.hu and paper subscribers (constantly changing).

c) Time limit for the deletion of data: in the case of consent to the sending of the newsletter, until the consent is withdrawn.

d) You can request the deletion or modification of your personal data by the following means:
- by post to Függetlenül Egymással Közhasznú Egyesület, 1027 Budapest, Jurányi u. 1-3., or
- by e-mail to info@fugeprodukcio.hu, or
- by following the unsubscribe option in the newsletter.

e) We inform our Users that the court, the prosecutor, the investigating authority, the administrative authority, the data protection commissioner, or other bodies authorised by law may contact the Service Provider to provide information, to disclose or transfer data, or to provide documents.

f) The FÜGE Khe. shall disclose personal data to public authorities only to the extent and to the extent strictly necessary for the purpose of the request, provided that the public authority has indicated the precise purpose and scope of the data.

g) FÜGE Khe. processes the personal data of Users for the purpose of providing the service (full use of the website, e.g. sending newsletters), only to the extent and for the duration necessary for that purpose. The processing of data shall be in compliance with this purpose at all stages.


h) In addition, FÜGE Khe. only collects information about Users (IP address, time of use, website visited, browser program and one or more cookies that allow the unique identification of the browser), which is used exclusively for the development and maintenance of the Services and for statistical purposes. The Service Provider will use the data processed for these statistical purposes only in a form that does not personally identify Users.

i) No data will be transferred to third parties.

j) The websites may contain links to external servers (not managed by FÜGE Khe.), and the sites accessible through these links may place their own cookies or other files on Users’ computers, collect data or request personal data. The FÜGE Khe. accepts no responsibility for these.



5.2 Newsletter, DM activity

a) Pursuant to Article 6 of Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Economic Advertising Activity, the User expressly consents in advance to being contacted by the Site with advertising offers and other mailings at the contact details (e.g. e-mail address) provided at the time of registration.

b) In addition, the Customer, subject to the provisions of this notice, consents to the processing by FÜGE Khe. of the personal data necessary for the sending of advertising offers.

c) FÜGE Khe. does not send unsolicited commercial messages and the User may unsubscribe from receiving such offers free of charge, without any restriction and without giving any reason. In this case, FÜGE Khe. will delete from its records all personal data necessary for sending advertising messages and will not contact the User with further advertising offers. The User may unsubscribe from advertising by clicking on the link in the message.

d) Purpose of data processing: sending electronic newsletters containing commercial advertising messages to the User, informing him/her about current information, products and events.

e) Legal basis for processing: voluntary consent of the data subject and Article 6(5) of Act XLVIII of 2008 on the Basic Conditions and Certain Limitations of Economic Advertising Activities.

f) Scope of the data processed: name, e-mail address.

g) Deadline for deletion of data: until the withdrawal of the consent, i.e. unsubscription.



6./ Data security

a) The FÜGE Khe. takes all necessary security, organisational and technical measures to ensure the highest level of security of personal data and to prevent their unauthorised alteration, destruction and use.

b) FÜGE Khe. shall take all necessary measures to ensure data integrity, i.e. the accuracy, completeness and up-to-date status of the personal data it processes and/or handles.


(c) FÜGE Khe. shall take appropriate measures to protect the data, in particular against unauthorised access, alteration, disclosure, transmission, disclosure, erasure or destruction, accidental destruction, damage and loss of accessibility resulting from changes in the technology used.

d) The FÜGE reserves the right to inform its customers and partners of any security vulnerabilities it detects in their systems and to restrict access to the Service Provider's systems, to its services or certain functions thereof until the vulnerability is remedied.

e) On the network handling personal data, the provider of the FÜGE Khe. shall continuously ensure virus protection and data security.

f) Access to the data and data files managed on the FÜGE Khe. storage is provided by means of a user name and password.



7./ Information on data management

a) The User may request information about the processing of his/her personal data, as well as request the rectification or - with the exception of data processing required by law - the deletion of his/her personal data in the manner indicated when the data was collected or at the contact details of the Service Provider.

b) FÜGE Khe. shall erase personal data if its processing is unlawful, if the User requests it, if the processed data is incomplete or inaccurate - and this situation cannot be lawfully remedied - provided that erasure is not precluded by law, the purpose of the processing has ceased, or the statutory period for storing the data has expired, or if the court or the National Authority for Data Protection and Freedom of Information has ordered it.



8./ Remedies

a) The User may object to the processing of his/her personal data if.

i. the processing or transfer of personal data is necessary solely for the performance of a legal obligation to which the Service Provider is subject or for the purposes of the legitimate interests pursued by the Service Provider, the data recipient or a third party, except when the processing is required by law;
ii. the personal data are used or transmitted for direct marketing, public opinion polling or scientific research purposes;

in other cases specified by law.

b) Within the shortest possible period of time from the date of the request, but not exceeding 15 days, the FVO shall examine the objection, decide whether it is justified and inform the applicant in writing of its decision. If the FÜGE determines that the data subject's objection is justified, it shall cease the processing, including any further collection and further transfer of data, and block the data, and notify the objection and the action taken on the basis of the objection to all those to whom the personal data covered by the objection have been disclosed and who are obliged to take measures to enforce the right to object, the objection shall be invalid.

c) If the User does not agree with the decision of the FÜGE Khe., he/she may appeal against it to a court of law within 30 days of its notification.

d) The User may take legal action against the FÜGE Khe. in the event of infringement of his rights. The court shall decide on the matter out of turn. A legal remedy or complaint may be lodged with the National Authority for Data Protection and Freedom of Information:


National Authority for Data Protection and Freedom of Information / Nemzeti Adatvédelmi és Információszabadság Hatóság
1125 Budapest, Szilágyi Erzsébet fasor 22/C.
Postal address: 1530 Budapest, P.O. Box 5.
Phone: +36 -1-391-1400
Fax: +36-1-391-1410
E-mail: ugyfelszolgalat@naih.hu