Data protection statement

Nitro Communications Ltd. and Lead Generation Ltd. respect your right to the protection of your personal data. This page summarizes what information we may collect, how we may use it, the tools we may use, and your privacy and data protection enforcement choices.

Nitro Communications Kft. (hereinafter referred to as "Nitro"; registered office: 1036 Budapest, Lajos utca 48-66, staircase C, 4th floor) and Lead Generation Kft. (hereinafter referred to as "Lead"; registered office: 1036 Budapest, Lajos utca 48-66, staircase C, 4th floor) as joint controllers of personal data are subject to the provisions of the Hungarian Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information (hereinafter referred to as "Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information"). and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 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 Regulation (EC) No 95/46/EC (General Data Protection Regulation), i.e. the GDPR, in relation to your personal data.

1. Scope and acceptance of this privacy statement

By using the websites operated by Nitro and Lead or by providing your personal data to Nitro and Lead, you consent to the collection and use of your personal data by Nitro and Lead as joint controllers as set out in this privacy statement (the "Statement").

If your personal data is not processed by Nitro and Lead as a joint controller, you will be expressly informed of this and, if you have given your consent on the basis of this Privacy Statement, a separate processing operation will be established.

You will also be expressly informed by Nitro and Lead if they are not acting in their capacity as data controllers, but as processors acting on behalf of third party or parties, and are contacting you and carrying out the processing operation(s) required by the controller(s).

If you do not consent to the collection and use of your personal data as described in this Privacy Notice, please do not use the Nitro and Lead websites or contact and other forms, or provide any personal data to them.

This privacy statement applies to the storage and processing of data voluntarily provided by visitors to this website. Personal data will be processed by the operator in accordance with the following principles:

1. personal data may only be processed for specific purposes, for the exercise of rights and the performance of obligations. The data must be processed in accordance with the purpose of the processing at all stages, and the collection and processing of the data must be fair and lawful
2. only personal data which is necessary for the purpose of the processing and adequate for the purpose of the processing may be processed. Personal data may only be processed to the extent and for the duration necessary to achieve the purpose
3. the personal data shall retain this quality during the processing for as long as the relationship with the data subject can be re-established. The link with the data subject may be re-established if the controller has the technical conditions necessary for such re-establishment
4. the processing must ensure the accuracy, completeness and, where necessary for the purposes of the processing, the up-to-dateness of the data and that the data subject can be identified only for the time necessary for the purposes of the processing
    

2. Concepts

In this Privacy Statement, we use the following terms, including but not limited to the following data protection terms.

personal data: any specific data relating to an identified or identifiable natural person [data subject] and any inference that can be drawn from that data relating to that data subject. Personal data shall retain this quality during processing for as long as its link with the data subject can be re-established. The link with the data subject may be re-established if the controller has the technical conditions necessary for such re-establishment.

data subject/contacted person: any natural person identified or otherwise identifiable, directly or indirectly, on the basis of specific personal data. In particular, a person is identifiable if he or she can be identified, directly or indirectly, by name, an identifier or one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity.

processing: any operation which is performed on data, regardless of the procedure used, such as collection, recording, recording, organisation, storage, alteration, use, consultation, retrieval, disclosure, alignment or combination, blocking, erasure or destruction of data, prevention of their further use, taking of photographs, audio or video recordings, or recording of physical characteristics which can be used to identify a person (fingerprints, palm prints, DNA samples, iris scans, etc.).

data controller: the person or entity that determines the purposes for which the data are processed, takes and implements the decisions concerning the processing (including the means used) or has the processing carried out by a processor on its behalf.

processing: the performance of technical tasks related to data processing operations (irrespective of the method and means used to carry out the operations and the place of application).

'processor' means the person or entity that carries out the processing of data on the basis of a contract with the controller, including a contract entered into pursuant to a legal provision.

'transfer' means making data available and accessible to third parties.

joint controllers: where the purposes and means of processing are determined jointly by two or more controllers, they are considered to be joint controllers.

3. Our policy on the collection, use and transfer of personal data

Nitro and Lead will comply with applicable legal requirements, restrictions and ethical standards when collecting and processing personal data.

The data controllers undertake to:

• Inform data subjects of their data management practices in a timely manner and as required,
• collect, process, use or transfer personal data only with the consent of the data subject. The nature of the consent required depends on the sensitivity of the information, the legal basis for the processing, the applicable legal requirements, the purposes and duration of the use, third parties and technologies. Depending on the above, consent may be either explicit or implicit.
  Personal data is collected, stored and used only for specific purposes. The information collected is always adequate, relevant and appropriate for the purpose for which it is collected.
• data processing practices always serve the purposes for which the personal data were originally collected and to which the data subject consented prior to the collection or subsequently extended his or her consent.
• its data processing and management practices are always for the purposes for which the personal data were originally collected and to which the data subject consented prior to the collection or subsequently extended his or her consent.
• take reasonable steps, having regard to the purposes for which the personal data are collected, to ensure that the personal data are complete, accurate, up to date and reliable to the extent necessary for those purposes.
• use your personal data for promotional purposes only with your consent and give you the opportunity to opt-out of such communications.
• take reasonable and prudent steps to ensure the protection of the data subject's personal data, including where it is transferred to third parties. No data will be transferred to third parties without the prior explicit consent of the data subject.

4. Information collected by Nitro and Lead on the website and how it is used

Information sent automatically by your device.

On our websites, we automatically collect information about the technology you use so that we can use it for statistical purposes and to develop and improve our online services. This information includes the type of browser and operating system you use. The sending of this information depends on your system settings. If you wish to control or block the sending of this information, please consult your browser documentation.

This information is not used to identify you, but is collected to help us understand the technologies our visitors use and to help us tailor our online development.

Data packets (cookies) placed on your device

When you visit our website, small data packets called cookies are placed on your computer or smart device. This information may relate to you, your browsing preferences or the type of browser you use and is used in the vast majority of cases to ensure that the website works as intended. It is not usually possible to identify you from this information, but it is used to provide a personalised browsing experience. You can set your browser to accept cookies at any time. For detailed information, please see the "Cookie Notice".

Information you voluntarily provide to us

The data controller(s) collects information that you voluntarily and knowingly provide to us when you use our website, for example when you subscribe to our newsletter, contact us via a form, register to use a particular feature or download a file. In such cases, you may be required to provide personal information. The controller(s) will only use your personal data for the purposes for which you have given your prior consent.

The uses of the data may include the following purposes:

• promoting our products and services
• Improving our products and services
• promoting certain products and services on behalf of third parties
• statistical data analysis
• market research
• business planning
• fraud prevention
• use of personalised features

We will inform you separately about the use of your personal data when we collect it.

5. Sharing personal data

The controller(s) will not transfer your personal data to third parties or provide access to it for direct marketing purposes without your explicit consent. However, we may share your personal data with third parties in the following circumstances:

• between joint controllers
• Service providers that are subcontracted by the controller(s) to assist in the provision of the product, service or information that you request. In such cases, the service provider may access your personal data for the purpose set out in the prior consent and the data controller(s) will require in a written agreement that the service provider complies with the relevant data protection standards, ensures the security of your data and limits access to it to what is strictly necessary for the fulfilment of that purpose.

We may also share your personal information with third parties in the following specific cases: if you explicitly request it; if we are required to do so by law; in the course of official proceedings at the request of a public authority; as a result of a change in the ownership of our company; or in other compelling circumstances.

6. Retention of personal data

The controller(s) will process and store your personal data only for as long as the original purpose of the processing continues, for as long as is necessary to provide the product, service or information you have requested, for as long as you do not withdraw your consent, or for as long as we are permitted by law.

7. Amendment and deletion of personal data

You can check, delete or amend your personal data by telephone, by filling in our contact form or by sending us a letter to the following address:

Nitro Communications Ltd.
1036 Budapest
1036 Communications Communications Ltd., Lajos utca 48-66.
1036 Communications Communications Communications, Building C, 4th floor.
+36 30 627 1391
info@nitro.business

Lead Generation Kft.
1036 Budapest
Lajos Street 48-66.
Building C, 4th floor
+36 30 627 1391
info@nitro.business

8. Personal data of children

The controller(s) does not knowingly collect personal data from or about children under the age of 16. If we become aware that personal data of children under the age of 16 has been obtained, we will endeavour to remove it from our systems as soon as possible. However, the controller(s) may collect personal data of children under the age of 16 from their parents or legal guardians with their explicit consent.

If you become aware that your child has provided personal data to the controller(s), you may have it deleted by telephone, by using our contact form or by sending a letter to the addresses set out in section 7.

9. Information on data processing

In all cases, data processing is carried out using IT systems. These IT systems store the data and protect them against unauthorised access, alteration, disclosure, publication, destruction or accidental damage or destruction.

In many cases, our IT systems are operated by external service providers as data processors. In such cases, the Data Controller(s) will require the service provider(s) to provide its systems with adequate legal and technological protection in the form of a written agreement to prevent the above occurrences.

The current list of processors used by the controller(s) for the processing of your personal data will be made available by the controller(s) upon request.

10. Information on commercial email communications

The controller(s) will not send a newsletter to individuals without obtaining their prior consent. You can subscribe to our communications and give your consent to receive them as follows:

• electronically, using the subscribe function on our website
• electronically, using an offline mobile device (e.g. at an event).
• electronically, by sending us an email requesting permission (e.g. after you give us a business card)
• by email (e.g. via your card

By subscribing, you consent to the processing of your personal data (e.g. name and email address) by the data controller(s) and to the use of such data for the purposes specified.

The purpose of processing data in relation to commercial email communications is to inform our subscribers about our services, news, educational materials and to send them relevant offers.

You may unsubscribe from email communications from the controller(s) at any time by clicking on the "unsubscribe" link in the footer of the emails, by telephone, by using our contact form or by post. Within 5 business days of unsubscribing, we will place your contact details on a block list and no further communications will be sent to you until you unsubscribe voluntarily.

11. Right to information

You may amend or delete personal data by email, post or telephone. The Data Controller(s) will comply with such a request within 5 working days, including, where necessary, the transmission of the request to any third party (see cases set out in point 5).

If it is not possible to amend or delete the personal data, we will notify you in writing within 30 days and inform you of your remedies.

12. Protest

The data subject may object to the processing of his or her personal data,

1. where the processing or transfer of personal data is necessary solely for compliance with a legal obligation to which the controller(s) is subject or for the purposes of the legitimate interests pursued by the controller, the recipient or a third party, except in cases of mandatory processing
2. where the personal data are used or further processed for direct marketing, public opinion polling or scientific research purposes; and
3. in other cases provided for by law.

The controller(s) shall, within the shortest possible period of time from the date of the request, but not exceeding 25 days, examine the objection, decide whether it is justified and inform the applicant in writing of its decision.

If the controller(s) establishes that the data subject's objection is justified, it shall cease the processing, including further collection and further transmission, and block the data, and notify the objection and the action taken on it to all those to whom the personal data covered by the objection have been previously disclosed and who are obliged to take measures to enforce the right to object.

If the data subject disagrees with the decision taken by the controller(s) or if the controller fails to comply with the time limit, the data subject may, within 30 days of the notification of the decision or the last day of the time limit, have recourse to the courts.

If the data subject objects to the processing of his or her personal data or lodges a judicial remedy, or if a third party requests the disclosure of data not based on the data subject's consent, the data may be disclosed to legal representatives appointed by the Controller to the extent necessary to assess the lawfulness of the above.

13. Judicial enforcement

Please contact us if you feel that the controller(s) has violated your rights to the protection of personal data so that we can remedy the possible violation.

Please also be informed that the data subject may take the controller(s) to court in the event of a breach of his/her rights. The court will rule on the matter out of turn. The court will have jurisdiction to rule on the case. The action may be brought before the court of the place where the controller is established or, at the choice of the data subject, the court of the place where the data subject resides or is domiciled. A person who otherwise lacks legal capacity may be a party to the proceedings.

If the controller(s) causes damage to another person by unlawful processing of the data subject's data or by breaching data security requirements, the controller(s) shall compensate the damage. If the controller infringes the data subject's right to privacy by unlawfully processing his or her data or by breaching the requirements of data security, the data subject may claim damages from the controller(s). The controller(s) shall be exempted from liability for the damage caused and from the obligation to pay the damage fee if it proves that the damage or the infringement of the data subject's personality rights was caused by an unforeseeable cause outside the scope of the processing. No compensation shall be due and no damages shall be payable where the damage or injury to the personality rights of the data subject was caused by the intentional or grossly negligent conduct of the data subject.

14. Competent authority

You may also seek the assistance of the National Authority for Data Protection and Freedom of Information (NAIH) in data protection matters:

1530 Budapest, PO Box 5.
15153, Budapest, 1125 Budapest, Szilágyi Erzsébet fasor 22/c.
Phone: +36 (1) 391-1400
Fax: +36 (1) 391-1410
Web: naih.hu
E-mail: ugyfelszolgalat@naih.hu

15. Sweepstakes

The data controller(s) may also collect data during promotional games, activities, contests that do not constitute a game of chance (collectively, contests), either for themselves or as a data processor for the data controller(s) acting on their behalf. Information on the processing of data in prize draws will always be provided in the prize draw rules, which will be governed by the provisions of this privacy statement in respect of any matters not covered by them.

16. Changes to this Statement

The controller(s) reserves the right to modify or update this privacy statement at any time without prior notice and to publish the updated version on its website. Any modification shall apply only to personal data collected after the publication of the modified version.

Please check our Privacy Statement regularly to monitor changes and to be informed of how changes affect you.

Last updated 22.05.2020.