Privacy Policy


Contents

  1. Introduction 3

  2. Data processor 4

  3. Definitions 5

  4. General information in connection with data processing 7

  5. Data processing performed by the company 8

  6. Term of data processing 13

  7. Data processing 14

  8. Forwarding data to third country 17

  9. Data security 19

  10. Rights of data subjects related to the processing of their personal data 20

  11. Changes of the privacy policy 24

  12. Cookie policy 25

  13. Contact 35

  1. Introduction

    The present privacy policy contains important information about the processing of your personal data. By providing your personal data you accept the terms and conditions set forth in the present privacy policy. Please read this privacy policy regularly since the changes thereof shall be automatically applicable for processing the personal data provided by you even if a previous version of the privacy policy was in force when you provided your personal data. We shall publish the modification of the privacy policy on our websites and we shall also inform you in other forms, depending on what source we have your data available from. Please pay special attention to the provisions of the present privacy policy highlighted by italics because those may contain important provisions about the processing of your personal data.


    In case data processing takes place on our website then by using the Website you accept the terms and conditions set forth in the present privacy policy irrespectively of whether you register on the Website or not. If you do not accept the provisions set forth in the privacy policy, do not use the Website.


    The present privacy policy shall be applicable exclusively for the personal data of natural person data subjects considering that the data of legal entities or other organizations not qualified as legal entities shall not be qualified as personal data.


    By signing the Agreement with BlockBen Financial Services OÜ where the downloading location of the present privacy policy is indicated or by accepting the pop-up window related to the acceptance of the privacy policy on www.blockstock.gold website you shall agree that you have become aware of and accepted the provisions set forth in the present privacy policy.


    In addition to blockstock.gold, BlockBen Financial Services OÜ also operates the following websites from which it may receive and process personal data:




  2. Data processor

    Name: Blockben Financial Services OÜ

    Registered seat: Harju maakond, Tallinn, Kesklinna linnaosa, Harju tn 6, 10130 Estonia

    Name of representative: Peter Horvath

    Contact of representative: 1061 Budapest, Andrássy út 33. 4. emelet 3.

    Mail address: 1061 Budapest, Andrássy út 33. 4. emelet 3.

    Email address: info@blockstock.gold

    Website: www.blockstock.gold


  3. Definitions

    Private person: Any specific natural person identified or directly or indirectly identifiable on the basis of personal data.


    Personal data: Any data which can be related to the data subject or any data or information (name, identification number) on the basis of which a natural person can be identified either directly or indirectly. During the use of the Website and other software, in addition to the natural personal identification data, photos, gender, age, or any knowledge characterizing one or more physical, physiological, mental, economic, cultural or social identities shall be such in particular.


    Data subject: any natural persons whose personal data is subject of any data processing. BlockBen Financial Services OÜ shall provide the Services available on the Website exclusively to natural persons over the age of 18 therefore it developed its data processing policy in accordance with this circumstance. Considering that the consent of the legal guardian of children below the age of 16 shall be required for their declaration, BlockBen Financial Services shall obtain the consent of the legal guardian in each case when it conducts data processing addressed to such data subjects.


    Data controller: the person determining the objectives and means of processing personal data. In case of personal data processing performed via the Website the data controller BlockBen Financial Services OÜ but in certain processes where this is expressly indicated, additional data controllers other than BlockBen Financial Services OÜ also conduct data processing activity. BlockBen Financial Services OÜ shall be qualified as data controller regarding any information and shall process all data provided by the Clients to BlockBen Financial Services OÜ, uploaded to the Website while visiting or using the Website or using any Service available on the Website or which is collected by BlockBen Financial Services OÜ during the activities of the Users on the Website.


    Data processor: the natural or legal person or any other body processing personal data on behalf of the data controller or performs data processing operations in terms of personal data. BlockBen Financial Services OÜ uses several data processors for its data processing the person of which shall be indicated in relation with the individual data processing or reference shall be made to the categories of data processors.


    Data processing: Automated or non-automated operation or set of operations performed on personal data for example collecting, storing, recording, disclosing, forwarding or using personal data. Any process in which personal data is made available for BlockBen Financial Services OÜ shall be qualified as data processing.


    Title of data processing: BlockBen Financial Services OÜ shall process personal data typically for the purpose of concluding or performing agreement and legal obligations of BlockBen Financial Services OÜ and on the basis of the consent of the data subject where it is expressly indicated upon recording the personal data. BlockBen Financial Services OÜ shall provide information on the title of data processing in relation with the individual data processing operations.

    Consent: permission given by the data subject to the data controller to process their personal data for a specific purpose.

    Voluntary and definite expression of the will of the data subject based on proper information and by which the data subject gives unmistakable consent to processing their personal data comprehensively or for certain operations.


    Data processing purpose: the specifically determined purpose of processing personal data for example concluding or performing an agreement between BlockBen Financial Services OÜ and the Client.


    Scope of processed data: BlockBen Financial Services OÜ shall provide the personal data processed upon the individual data processing.


    Term of data processing: the period of time until BlockBen Financial Services OÜ is entitled to process personal data which shall be provided by BlockBen Financial Services OÜ upon the individual data processing.


    Data not suitable for personal identification: data which is recorded by BlockBen Financial Services OÜ about the users of the Website, but which is not suitable for directly or indirectly identifying a natural person.


  4. General information in

    connection with data processing

    1. The primary title of data processing by BlockBen Financial Services OÜ shall be the performance of an agreement concluded with the data subject on the basis of section b), paragraph (1), Article 6. of the GDPR.


    2. The Data subject shall be responsible for the truthfulness and accuracy of the personal data provided. BlockBen Financial Services OÜ shall not be liable for the processing of incorrect or untrue data provided by the Data subject or for the damages suffered by the Data subject or any third person due to incorrect or untrue data provision. BlockBen Financial Services OÜ shall not be responsible if BlockBen Financial Services OÜ is deceived regarding the capacity of the Data subject.


    3. In case of using the Website the title of data processing shall be consent (section a), paragraph (1), Article 6 of the GDPR). In case of data processing based on consent, the Data subject shall be entitled to withdraw such consent any time which however shall not affect the lawfulness of the data processing prior to such withdrawal. Data regarding the verification of the fact of consent shall be preserved by BlockBen Financial Services OÜ until the possibility of verifying such consent or any other legitimate interest of BlockBen Financial Services OÜ makes it necessary. Consent is given by using the website via implicit acceptance.


    4. Unless otherwise regulated by law, the personal data made available for BlockBen Financial Services OÜ shall only be processed by BlockBen Financial Services OÜ only for the purposes described in the present policy to the extent required to implement such purposes.


    5. BlockBen Financial Services OÜ performs profiling.


      Profiling: automated processing of personal data when personal data is used for the assessment of certain personal characteristics (e.g. workplace performance, economic/financial situation, health condition, personal preferences, interests, reliability, behaviour) related to a specific natural person, the analysis or prediction of place of staying or moving.


      BlockBen Financial Services OÜ performs profiling. BlockBen Financial Services OÜ groups the names and e-mail addresses of registered persons in order to provide relevant content and information and to send marketing newsletters to its users periodically. Such profiling does not consist of automated decision-making.


  5. Data processing performed by

    the company

    1. / Service provided on the basis of agreement concluded with the company


      Scope of data

      processed

      Purpose of data

      processing

      Title of data

      processing


      Data processor

      Term of data

      processing

      Name, birth name, address,

      place and date of birth,

      mother’s name of

      client


      client identification


      Section b), paragraph (1), article 6 of the GDPR - performance of agreement


      Peak Financial Services


      for 5 years following the performance of agreement


      delivery address


      delivery of card issued

      Section b), paragraph (1), article 6 of the GDPR - performance of

      agreement


      Peak Financial Services

      for 5 years following the performance of

      agreement

      number and type of identification documents (passport or ID card or driving licence depending on the choice of the data

      subject)


      application for card, client identification


      Section b), paragraph (1), article 6 of the GDPR - performance of agreement


      Peak Financial Services


      for 5 years following the performance of agreement


      photo


      for personal identification purposes


      Section b), paragraph (1), article 6 of the GDPR


      Sum & Substance

      for 5 years following the performance of

      agreement


      copy of personal documents


      Client identification and due diligence for anti-money-

      Section b), paragraph (1), article 6 of the GDPR - statutory

      obligation


      Peak Financial Services, Sum & Substance

      for 8 years following the performance of

      agreement



      laundering

      purposes





      Phone number

      Registration and verified login into Wallet (Two-factor

      authentication)

      Section c), paragraph (1), article 6 of the GDPR - statutory

      obligation


      Sum & Substance

      for 5 years following the performance of

      agreement


      Bank account number


      for the purposes of registration and application for card

      Section b), paragraph (1), article 6 of the GDPR - performance of

      agreement


      Peak Financial Services

      for 5 years following the performance of

      agreement


      Data regarding employment and citizenship


      client identification

      Section b), paragraph (1), article 6 of the GDPR - performance of

      agreement


      Sum & Substance

      for 5 years following the performance of

      agreement


      Let us call the attention of data subjects that the company shall store the data after the termination of the agreement under section f), paragraph (1), Article 6. of the GDPR for the purpose of enforcement of its legitimate interests. Let us inform you that you shall be entitled to object to such data processing based on legitimate interest any time at the representative of the company, in which case the company shall delete your personal data.

    2. / Operation and Use of the Website and Registration



      Scope of data

      processed

      Purpose of data

      processing

      Title of data

      processing


      Data processor

      Term of data

      processing


      Client name*,


      email address*, password*

      Operation of services available by the Website (from the website), creating web office registration and user

      identification


      Section a), paragraph (1), article 6 of the GDPR - consent


      Amazon Web Services (AWS)


      Until the cancellation of registration or withdrawal of consent.


      IBAN number


      (bank account number)


      Providing services related to the Wallet


      Section a), paragraph (1), article 6 of the GDPR - consent


      Amazon Web Services (AWS)

      Mongo Labs

      Until the cancellation of registration or withdrawal of

      consent.


      Client’s phone

      number


      securing wallet- based services


      Section a), paragraph (1), article 6 of the GDPR - consent


      AWS


      Mongo Labs

      Until the cancellation of registration or withdrawal of

      consent.


      Data marked with * shall be provided for registration. If you do not provide the data, you cannot register. Regarding data collected while browsing the Website, please see our cookie policy (section 12).


    3. / Information regarding the services of BlockBen Financial Services



      Scope of data

      processed

      Purpose of data

      processing

      Title of data

      processing


      Data processor

      Term of data

      processing

      Name,


      email address, phone number, country of

      residence

      Contact related to the service provided by BlockBen Financial Services and the


      Section b), paragraph (1), article 6 of the GDPR - performance of agreement


      -


      for 5 years following the performance of agreement



      performance of the

      agreement





    4. / Other communication and complaints



      Scope of data

      processed

      Purpose of data

      processing

      Title of data

      processing


      Data processor

      Term of data

      processing


      Name, email address, phone number, home address (depending on what data is provided by the Data subject or through what channel communication takes place)

      In case of contact made by the Data subject the purpose of data processing subject to the purpose of contact (e.g. reply to incoming emails, actual management of complaint and information about the measures

      taken, etc.)


      Section f), paragraph (1), article 6 of the GDPR - legitimate interest


      Description of legitimate interest: later proof of content of communication with clients, complaint management, quality assurance.


      Freshdesk Servers.com


      Depending on the nature of communication or complaint but in each case at least for 5 years following the management of the complaint


    5. / Data processing for marketing purposes



      Scope of data

      processed

      Purpose of data

      processing

      Title of data

      processing


      Data processor

      Term of data

      processing


      Name, home address, phone number, email address

      Sending newsletters related to the services of BlockBen Financial Services, direct

      marketing


      Section a), paragraph (1), article 6 of the GDPR - consent


      SendGrid


      Until the withdrawal of consent


    6. / Enforcement of claims, disputes, official proceedings


      Scope of data

      processed

      Purpose of data

      processing

      Title of data

      processing


      Data processor

      Term of data

      processing


      Name, home address, phone number, other information related to claim


      Enforcement and collection of claims of BlockBen Financial Services, proving the opinion of BlockBen Financial Services in case of enforcement of claims against BlockBen Financial Services, fulfilling official queries and notifications

      Section f), paragraph (1), article 6 of the GDPR - legitimate interest


      Designation of legitimate interest: collection of claims, enforcement of claims, protection of rights


      Section c), paragraph (1), article 6 of the GDPR - statutory obligation in specific

      case


      Freshdesk Server.com


      8 years following the enforcement of claim or the final closure of proceedings


  6. Term of data processing

    1. Data shall be deleted 5 years after the cancellation of service considering that it may be necessary to contact the client within the 5-year limitation period.


    2. The term of data processing for the purpose of client identification and due diligence under act of 2017 on the prevention of money laundering and the financing of terrorism in force in Estonia as well as for purpose of performing data supply under the same act shall be 5 years.


    3. Under act of 2002 on accounting in force in Estonia, the preservation period of receipts of financial transactions shall be 7 years.


  7. Data processing

    1. Data processor shall be the natural or legal person or any other body processing personal data on behalf of the data controller. Data processing shall not mean authorization to make decisions related to the data: the data processor shall execute the data processing decisions of the data controller.


    2. Data shall be forwarded exclusively for the purpose of performing services and fulfilling statutory obligations to accountants, shipping companies, card issuers, financial institutions and contractual partners.


    3. The data processor shall not make definitive decisions regarding the data processing and it shall process personal data obtained exclusively on the basis of the instructions of BlockBen Financial Services OÜ; it shall not perform data processing for its own purposes furthermore it shall store and preserve personal data according to the instructions of BlockBen Financial Services OÜ.


    4. Name of data processors:


      1. / PEAK Card Services Ltd.


        Address: Suites 7B & 8B, 50 Town Range, Gibraltar

        E-mail: info@peakfinancialservices.eu

        Phone: +44 20 331 83537

        Web: http://peakfinancialservices.eu/hu/fooldal/ Scope of personal data processed as data processor:

        • name,

        • email address,

        • phone number,

        • date of birth,

        • home address,

        • delivery address,

        • copy of personal identity document and the personal data indicated thereon,

        • copy of bank account statement / copy of public utility bill / copy of telephone bill.


          Task of data processor: Preparing and delivering card for client concluding agreement with BlockBen Financial Services.

      2. / Sum & Substance (KYC/AML partner)


        Address: Suite 1, 5 Percy Street, Fitzrovia, London, W1T1DG

        E-mail: info@sumsub.com

        Web: https://sumsub.com/


        Data Protection Registration Number: ZA222205.


        Personal data managed by data processor: name; place and date of birth; ID-card number, photo.


        Task of data processor: The ID-card data of the client concluding agreement with BlockBen Financial Services OÜ shall be compared by the system with a selfie taken by the user. Client inspection from different financial and criminal law aspects.


      3. / Amazon Web Services (AWS)


        Address: 1200 12th Ave S, Ste 1200, Seattle, WA 98144, United States

        Web: https://aws.amazon.com,

        GTC: https://aws.amazon.com/privacy/?nc1=f_pr


        Task of data processor: operation of website and hosting.


      4. / SendGrid


        Web: https://sendgrid.com/

        GTC: https://sendgrid.com/policies/privacy/


        Task of data processor: storing names and e-mail addresses for later use and target group segmentation for the purpose of profiling.


      5. / Freshdesk


        Address: 1250 Bayhill Drive, Suite 315, San Bruno, CA 94066

        Phone: +1 650 513 0514

        Web: https://freshdesk.com/

        GTC: https://freshdesk.com/gdpr, https://www.freshworks.com/privacy/gdpr/?_ga=2.37913379.1047924319.1533027009-1494754266.1533027009

        Task of data processor: Grouping requests, questions and complaints received by the customer service, replying those, use of personal data for such purpose within the company (name, e-mail address, other data required for the solution of the problem).


      6. / Auth0


        Address: 10900 NE 8th Street Suite 700, Bellevue, WA 98004

        Phone: +44 (0) 33-3234-1966, +1 (425) 312-6521, +1 (888) 235-2699

        Web: https://auth0.com/


        Task of data processor: identification, authentication and defence of the security of the customers’ usernames and

        passwords.


      7. / Mongo Labs (ObjectLabs Corporation)


      Address: 660 York St. Suite 101, San Francisco, CA 94110

      Phone: (415) 758-2748

      E-mail: support@mlab.com


      Task of data processor: providing database required for the BlockBen wallet interface.


  8. Forwarding data to third

    country

    1. BlockBen Financial Services shall not forward personal data to any third country.


    2. In the event that such data forwarding becomes necessary then BlockBen Financial Services shall request the personal consent of the client involved to the data forwarding, informing the client about the purpose and circumstances of such data forwarding as well as the provisions set forth in Article 13 and section a), paragraph (1), Article 49. of the GDPR.


      The list of third country data processors to whom Block Netwörk OÜ provides data:


      1. / Amazon Web Services (AWS) Inc.


        Address: 1200 12th Ave S, Ste 1200, Seattle, WA 98144, United States

        Web: https://aws.amazon.com,

        GTC: https://aws.amazon.com/privacy/?nc1=f_pr


        Task of data processor: operation of website and hosting


      2. / SendGrid


        Web: https://sendgrid.com/

        GTC: https://sendgrid.com/policies/privacy/


        Task of data processor: storing names and e-mail addresses for later use and target group segmentation for the purpose of profiling..


      3. / Freshdesk


        Address: 1250 Bayhill Drive, Suite 315, San Bruno, CA 94066

        Phone: +1 650 513 0514

        Web: https://freshdesk.com/

        GTC: https://freshdesk.com/gdpr, https://www.freshworks.com/privacy/gdpr/?_ga=2.37913379.1047924319.1533027009-1494754266.1533027009


        Task of data processor: Grouping requests, questions and complaints received by the customer service, replying those, use of personal data for such purpose within the company (name, e-mail address, other data required for the solution of the problem).


      4. / Mongo Labs (ObjectLabs Corporation)


      Address: 660 York St. Suite 101, San Francisco, CA 94110

      Phone: (415) 758-2748

      E-mail: support@mlab.com


      Task of data processor: providing database required for the BlockBen wallet interface.


  9. Data security

    1. In the scope of data security measures the company shall take in particular those technical and organizational measures and establish those procedural rules which ensure that the data processed shall be protected from unauthorized access, modification, forwarding, disclosure, deletion, destruction, accidental termination or damage, furthermore against becoming inaccessible due to the change of the technology applied.


    2. The company shall take the development of technology into consideration at all times when determining and applying the measures serving data security. In case of several possible data processing solutions, the company shall choose the one providing higher level of protection for personal data except if such solution would constitute unreasonable difficulty for the company. The company shall enforce such requirements towards the data processors as well.


    3. The company shall take obligation to call any third party to which it may forward or hand over data to observe the above commitments. In case of legitimate data forwarding by the company, the company shall not be responsible for damages caused by the recipient.


  10. Rights of data subjects

    related to the processing of their personal data

    1. Data subjects may at any time request information at the contacts indicated in the present policy about the data processing related to them, may request the correction, cancellation or restriction of use of their data and may object to the processing of such personal data.


    2. BlockBen Financial Services OÜ shall inform the Data subject without unreasonable delay but within one month of the reception of the request by all means about the measures taken as a result of the request below. If necessary, taking the complexity and the number of requests into consideration, such term may be extended by two additional months. BlockBen Financial Services OÜ shall provide information about the extension of the term, also indicating the causes for the delay within one months of the reception of the request. If the request was received electronically, the information shall also take place electronically if possible, except if the Data subject otherwise requests. If BlockBen Financial Services OÜ judges so that we do not need to take measures upon the request of the Data subject then we shall inform the Data subject without delay but within one month from the reception of the request the latest about the reasons for the omission of measures and that the Data subject may make a complaint at the data protection authority and may exercise its right to remedy in front of the court of justice.


    3. Requests shall be fulfilled free of charge, if however the request is clearly unfounded or excessive especially due to its repeated nature, the company my take the administrative costs arising from the request into consideration and charge a reasonable fee or refuse to fulfil the request.


    4. If there is founded doubt in relation with the person of the Data subject submitting the request, further information may be required to confirm identity.


    5. Upon request of the Data subjects, BlockBen Financial Services OÜ shall provide information whether their personal data is being processed and if it is, the Data subjects shall be entitled to access their data processed by

      BlockBen Financial Services OÜ as well as the information on the purpose of data processing, the categories of the data involved, the recipients or recipient categories to whom the personal data was or will be disclosed, the planned term of data processing or the factors of determining such term as well as the source of data (right of access).


    6. Upon request, BlockBen Financial Services OÜ shall provide the Data subjects with the copy of the personal data processed. For additional copies requested by the Data subjects a reasonable fee may be charged on the basis of

      administrative costs. If the Data subject submitted the request electronically, the information shall be provided in a widely used electronic format except if the Data subject requests otherwise.


    7. The Data subject may request the correction of inaccurate data and shall be entitled to request the completion of incomplete data.


    8. The Data subject may request BlockBen Financial Services OÜ to delete the personal data if:


      • such data is not needed any longer for the purpose of the data were processed;


      • the Data subject withdraws consent and there is no other title for data processing;


      • the Data subject lawfully and successfully objected to the processing of personal data and such data processing is;


      • data processing is unlawful;


      • data shall be deleted in order to fulfil a legal obligation of BlockBen Financial Services OÜ;


      • the Data subject is a minor, below the age of 16.


    9. Upon the above request, BlockBen Financial Services OÜ shall delete the data except if further data processing is required for:


      • exercising the right to freedom of opinion and expression as well as information;


      • fulfilling the legal obligation of BlockBen Financial Services OÜ requiring such data processing;


      • the purpose of presenting, enforcing or protecting legal claims.


    10. Upon request from the Data subject BlockBen Financial Services OÜ shall restrict data processing if:


      • the Data subject disputes the accuracy of personal data in which case the restriction shall apply for the period of time allowing for supervision of the accuracy of data;

      • although the data processing is unlawful, the Data subject objects to deletion and requests restriction instead;


      • BlockBen Financial Services OÜ does not need the data processing any longer but the Data subject requests it for presenting, enforcing or protecting legal claims;

      • the Data subject objected to the data processing; in which case the restriction shall apply for the period of time until it is concluded whether the legitimate reasons of the data processor have priority against the legitimate reasons of the Data subject.

    11. If the data processing is restricted according to the foregoing, such personal data shall only be processed (except for storage) with the consent of the Data subject or for the presentation, enforcement or protection of legal claims or in order to protect the rights of other persons or for the important public interest of the Union or a member state.

      BlockBen Financial Services OÜ shall inform the Data subject requesting the restriction about the resolution of the restriction in advance.


    12. BlockBen Financial Services OÜ shall notify the Data subject and anyone else to whom it had previously forwarded the data about correction, deletion or restriction. BlockBen Financial Services OÜ shall omit such notification if it is impossible or requires great effort. If BlockBen Financial Services OÜ disclosed the personal data and is obliged to delete it, it shall take the reasonable expected measures taking the available technology and the costs of implementation into consideration, including technical measures as well in order to inform the data processors processing the data that the Data subject requested them to delete the links referring to the given personal data or the copies and counterparts of such personal data.


    13. The Data subject may object to the processing of their personal data


      1. if it takes place on the basis of legitimate interest; in which case the data processing shall not be continued except if it is reasoned by forcing legitimate causes related to the presentation, enforcement or protection of lawful claims enjoying priority over the interests, rights and freedoms of the Data subject;


      2. if it takes place for or in connection with direct marketing; in which case the data processing shall not be continued in the future for this reason.


      Sections 10.2-10.4. shall be governing in case of objection as well.


    14. On the basis of data portability, the Data subject on the one hand may request BlockBen Financial Services OÜ if it is technically viable to receive its widely used data processed in a machine-readable format and to personally forward it to any data processor.


    15. If BlockBen Financial Services OÜ does not fulfil the above request of the Data subject it shall inform the Data subject about the reason thereof within one month of the reception of the request.


    16. In the event that according to the view of the Data subject, its rights related to its personal data were injured, please make a complaint to BlockBen Financial Services OÜ at the contacts provided.


    17. You may also address the authorities irrespectively of notifying BlockBen Financial Services OÜ. You can make a complaint at the competent supervisory authority, which is the National Authority for Data Protection and Freedom of Information in this case:


      Name: National Authority for Data Protection and Freedom of Information

      Mail address: 1374 Budapest, Pf. 603.

      E-mail address: ugyfelszolgalat@naih.hu

      Web: http://naih.hu


    18. In addition to the above, in case of unlawful processing of your data, you can also address the competent court of justice and initiate a civil lawsuit.


      The lawsuit shall be judged by the court of justice. The lawsuit may be filed to the court of justice with jurisdiction in your residence (you can find a list and contact of courts of justice at the link below: http://birosag.hu/torvenyszekek).


  11. Changes of the privacy policy

    1. The changes of the privacy policy shall be published on the Website. The privacy policy in force at all times shall always be applicable for processing the personal data even if a previous version of the privacy policy was in force when the Data subject registered or provided their personal data otherwise.


  12. Cookie policy

    1. Meaning of cookie


      “Cookies” are files sent by the web server with variable content consisting of letters and numbers saved and stored on the computer of the user for a pre-defined period of time. Cookies allow our web server to recognize your browser and your browsing history of the Website. With the help of cookies we can get an image about the habits and history of the user visiting our website and using the internet. Cookies do not contain any data through which the visitors to the website can be identified, those are exclusively suitable to recognize the computer of the user.


      If you need further information about these cookies and their operation, you can find detailed information at www.allaboutcookies.org or www.aboutcookies.org.


    2. Acceptance by visiting the Website


      When you visit our Website, the Website collects data with the help of the aforementioned cookies.


      When you visit our Website, with a click, you may accept the use of cookies incapable of identifying persons by the website in accordance with our privacy policy.


      You can maintain and/or delete cookies as you wish. If you need more detailed information about this, please visit www.aboutcookies.org. You can delete all the cookies stored on your computer and you can ban their installation in most browsers. In such case you might have to do certain settings manually each time you visit a given website and you may also experience that certain services and functions might not work.


    3. Cookies used on our website


      1. Functional cookies


        These cookies are needed for the us to collect information about the website using habits of the user (e.g. language, quick test filling, subscribing for newsletters). These cookies are used to provide a better user experience. This type of cookie stays in the cookie file of your browser for a longer period of time. This period of time depends on your browser settings. These cookies forward information to the web server in each case when you visit the Website.


        Cookie name

        Cookie ID, type

        Cookie Provider

        Data handled by

        Cookie

        Cookie purpose

        Duration


        _ga

        HTTP

        Google Tag Manager

        randomly generated unique ID

        The cookie is used to calculate visitor, session, camapign data and keep track of site usage for the site's analytics report. The cookies store information anonymously and assigns a randoly generated number to identify unique

        visitors.

        2 years

        _gid

        HTTP

        Google Tag Manager

        number visitors, the source where they have come from, and the pages viisted in an anonymous form.

        The cookie is used to store information of how visitors use a website and helps in creating an analytics report of how the wbsite is

        doing.

        1 day

        _gat

        HTTP

        Google Analytics

        -

        Universal Analytics to throttle the request rate to

        limit the

        1 day






        colllection of

        data on high traffic sites.


        _hjid

        HTTP

        Hotjar

        It is used to persist the random user ID, unique to that site on the browser.

        Sets a unique ID for the session. This allows the website to obtain data on visitor behaviour for statistical

        purposes.

        1 year

        _hjid

        HTML

        Hotjar

        It is used to persist the random user ID, unique to that site on the browser.

        Sets a unique ID for the session. This allows the website to obtain data on visitor behaviour for statistical

        purposes.

        Persistent

        smartlookCookie

        HTTP

        Smartlook

        number visitors, the source where they have come from, and the pages viisted in an anonymous

        form.

        Registers data on visitors' web site- behaviour.

        This is used for internal analysis and website optimization.

        Session


        collect

        Pixel

        Google

        visitor’s device and behaviour.

        Used to send data to Google Analytics about the visitor’s device and behaviour. Tracks the visitor accross devices and marketing

        channels



      2. Third-party cookies


        Third-party cookies are downloaded by the User's browser when viewing the Website, but not from the (sub) domain of the Company, but from a third party (typically an advertiser or facebook) domain, since the Website partly consists of such Third-party modules. Third-party cookies are returned to a third party when, for example, a User views an ad or visits their website. These cookies are used by a third party (such as an advertiser) to track the user's complete browsing history for websites that contain so-called "third party" modules (e.g., advertising module, ads).


        Most browsers have privacy settings that allow you to block / disable Third-party cookies.


        The Company has no control over Third-Party Cookies, so Users are requested to review these Third-Party Cookies Information. (Google Analytics, Gemius, facebook, doubleclick)


        Cookie name

        Cookie ID,

        type

        Cookie Provider

        Data handled by

        Cookie

        Cookie purpose

        Duration

        t_gid

        HTTP

        taboola.com

        user ID

        The cookie assigns a unique user ID to users and use this ID for serving relevant advertisement and

        content.

        1 year

        _fbp

        HTTP

        Google Tag Manager

        user ID

        Used by facebook to deliver advertisement when they are on Facebook or a digital platform powered by Facebook advertising after visiting this

        website

        3 months

        fr

        HTTP

        Facebook

        The cookie tracks the behavior of the user across the web on sites that have

        Facebook pixel

        to show relevant advertisments to the users and measure and improve the advertisements.

        3 months





        or Facebook

        social plugin.



        _hjIncludedInSample

        HTTP

        Hotjar

        user ID

        Determines if the user's navigation should be registered in a certain statistical

        placeholder.

        Session

        eng_mt

        HTML

        taboola.com

        advertisement impression, user interaction

        Tracks the conversion rate between the user and the advertisement banners on the website - This serves to optimise the relevance of the advertisements on

        the website.

        Persistent

        taboola global:user- id

        HTML

        taboola.com

        Unique visitor ID

        Sets a unique ID for the visitor, that allows third party advertisers to target the visitor with relevant advertisement. This pairing service is provided by third party advertisement hubs, which facilitates real-time bidding for

        advertisers.

        Persistent

        taboola_session_id

        HTTP

        taboola.com

        visitor ID string

        This cookie is used to collect information on a visitor. This information will become an ID string

        with information on a

        Session






        specific visitor – ID information strings can be used to target groups with similar preferences, or can be used by third -

        party domains or ad-

        exchanges


        trctestcookie

        HTTP

        taboola.com

        user data

        Detects whether partner data synchronization is functioning and currently running - This function sends user data between third-party advertisement companies for the purpose of targeted

        advertisements.

        Session

        SL_C_ 23361dd035530

        _KEY

        HTTP

        Smartlook

        Collects statistical data related to the user's website visits, such as the number of visits, average time spent on the website and what pages have been loaded

        The purpose is to segment the website's users according to factors such as demographics and geographical location, in order to enable media and marketing agencies to structure and understand their target groups to enable customised online advertising.

        13 months

        SL_L_ 23361dd035530

        _KEY

        HTML

        Smartlook

        Persistent

        SL_C_ 23361dd035530

        _SID

        HTTP

        Smartlook

        13 months

        SL_L_ 23361dd035530

        _SID

        HTML

        Smartlook

        Persistent

        SL_C_ 23361dd035530

        _VID

        HTTP

        Smartlook

        13 months


        SL_C_ 23361dd035530

        _VID

        HTML

        Smartlook



        Persistent


    4. Newsletters, e-mails


      You can also subscribe for our newsletter on our Website and contact us any time also regarding unsubscribing the newsletter. This latter is required to ban us collecting data on whether you opened the newsletters and e-mails we had sent you.


      Upon interpreting the present policy, the provisions of our data protection policy shall be applicable.


    5. Individual cookies used on our website


      1. Google Analytics:


        This website uses Google Analytics, a web analytics service provided by Google Inc. ("Google"). Google Analytics uses so- called "cookies", text files that are saved on your computer, to help you analyze the use of a web page that a User visits.


        The information generated by the cookies associated with the User's use of the Site is typically stored on a Google server in the US. By activating the IP anonymization web site, Google will shorten the User's IP address within the Member States of the European Union or other States party to the European Economic Area Agreement.


        The full IP address will only be forwarded to Google's server in the US and shortened there only in exceptional cases. Google will use this information on behalf of the operator of this web site to evaluate how the user has used the web site, to report web site activity to the web site operator, and to provide additional services related to the use of the web site and the Internet.


        Within Google Analytics, the IP address transmitted by the User's browser is not reconciled with other Google data. The User may prevent the storage of cookies by properly configuring his / her browser, however, please note that in this case, not all features of this website may be fully utilized. You may also prevent Google from collecting and processing your cookie-related information about your use of the Website (including your IP address) by downloading and installing the browser plug-in available at the following link. https://tools.google.com/dlpage/gaoptout?hl=hu


      2. Hojtar:

        Website optimization is performed using Hotjar cookies, which collect data on mouse movement, click data and form states. The data is stored on Hotjar.com. During data collection, all form data (with a * character) is masked, and no real data is recorded or stored. Hotjar's Privacy Policy can be found here: https://www.hotjar.com/legal/policies/privacy.


          1. Google Tag Manager


            Google Tag Manager is a tag management system that allows you to quickly and easily update your tracking codes and related code snippets (collectively, tags) on your site and in the mobile app.

          2. Smartlook


            Smartlook is a user behavior analysis tool that helps understand traffic. Smartlook records users on websites and in iOS & Android apps.


            https://help.smartlook.com/en/articles/3244452-privacy-policy


          3. Facebook Pixel


            Facebook Pixel is an analytics tool that measures the effectiveness of your advertising activity and helps you understand people's actions on your site. Facebook's privacy policy can be found here:


            https://www.facebook.com/policy.php


          4. Taboola Pixel


        The Taboola Pixel allows you understand the actions people take on your site and to optimize your marketing campaigns towards desired and valuable actions. When visitors on your site perform a certain action, the Taboola Pixel can be activated to report that action.


        https://www.taboola.com/privacy-policy


        5.7. SendGrind:


        A cloud based service used for sending Company newsletters and marketing emails.


    6. Switching off and deleting cookies


    You can switch off the use of cookies in most browsers.

    Setting this depends on the type of the browser. You can find information about switching out cookies in the “HELP”

    menu of your browser.

    You can switch of cookies in the settings menu of your browser, in different submenus depending on the given browser.


  13. Contact

If you have any questions, remarks or requests regarding the present privacy policy, or you wish to make a complaint or exercise your rights set forth in Section 10, please contact us at the contact details provided in Section 2.


The present privacy policy shall be in force from 19th October 2020.