Privacy policy

The Színes Erzsébetváros Association (hereinafter: service provider, data controller) is bound by the following notice.

In accordance with 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 Directive 95/46/EC (General Data Protection Regulation), we provide the following information.

This privacy notice governs the processing of data on the following website and its related subpages: szineserzsebetvaros.hu (including the subpages and microsites of this website)

THE DATA CONTROLLER AND ITS CONTACT DETAILS:

Name: Színes Erzsébetváros Association
Registered office: 1077 Budapest, Wesselényi utca 13.
Email: hello@szineserzsebevaros.hu

DEFINITIONS

1. "personal data" means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, a number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
2. "data processing" means any operation or set of operations which is performed on personal data or data files, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
3. "controller" means the natural or legal person, public authority, agency or any other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of the processing are determined by Union or Member State law, the controller or the specific criteria for the designation of the controller may also be determined by Union or Member State law;
4. "processor" means a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller;
5. ‘recipient’ means the natural or legal person, public authority, agency or any other body to which personal data are disclosed, whether or not a third party. Public authorities which may have access to personal data in the context of an individual investigation in accordance with Union or Member State law shall not be considered recipients; the processing of such data by such public authorities shall be in accordance with the applicable data protection rules in accordance with the purposes of the processing;
6. "consent of the data subject" means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which the data subject, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
7. “personal data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.

PRINCIPLES FOR THE PROCESSING OF PERSONAL DATA

1. a) Personal data shall be: a) processed lawfully, fairly and in a transparent manner in relation to the data subject (“lawfulness, fairness and transparency”);
2. (b) collected only for specified, explicit and legitimate purposes and not further processed in a manner incompatible with those purposes; further processing for archiving purposes in the public interest, scientific and historical research purposes or statistical purposes (‘purpose limitation’) shall not be considered incompatible with the initial purpose in accordance with Article 89(1);
3. c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (“data minimization”);
4. (d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes of the processing, are erased or rectified without delay (“accuracy”);
5. (e) stored in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for a longer period only where the personal data are processed for archiving purposes in the public interest, scientific and historical research purposes or statistical purposes in accordance with Article 89(1), subject to the implementation of appropriate technical and organisational measures to safeguard the rights and freedoms of data subjects as provided for in this Regulation (‘storage limitation’);
6. f) processed in such a way as to ensure adequate security of personal data, including protection against unauthorised or unlawful processing, accidental loss, destruction or damage to the data, by applying appropriate technical or organisational measures ("integrity and confidentiality").

The controller is responsible for compliance with the above and must be able to demonstrate it (“accountability”).

PROCESSING OPERATIONS

DATA PROCESSING RELATED TO THE OPERATION OF THE WEBSITE

1. Fact of data collection, scope of data processed and purpose of processing:

Data processed: Last name and first name
Purpose of processing: Keeping in contact

Data processed: Email address
Purpose of processing: Keeping in contact

Data processed: Phone number
Purpose of processing: Keeping in contact

Data processed: Date of registration
Purpose of processing: Carrying out a technical operation.

Data processed: IP address at the time of registration
Purpose of processing: Carrying out a technical operation.

2. Data subjects concerned: All data subjects registered on the website.
3. Duration of processing and deadline for erasure: the data are erased immediately upon deletion of the registration.
4. Potential controllers entitled to access the data and recipients of the personal data: The personal data may be processed by the controller's staff and volunteers, in compliance with the above principles.
5. Rights of data subjects in relation to the processing:
   • The data subject may request from the data controller access to, rectification, erasure or restriction of processing of personal data concerning him or her, and
   • object to the processing of such personal data, and
   • the data subject has the right to data portability and to withdraw consent at any time.
6. The data subject may request access to, erasure, modification or restriction of processing of the personal data, data portability, or object to the processing in the following ways:
   – by post at the data controller’s registered office,
   – by e-mail to hello@szineserzsebetvaros.hu,
7. Legal basis for processing:

7.1. Article 6(1)(b) of the GDPR,

7.2. Act CVIII of 2001 on certain issues of electronic commerce services and services related to the information society (hereinafter: Elker Act) Section 13/A (3):
The service provider may process personal data for the purpose of providing the service that is technically indispensable for the provision of the service. All other conditions being the same, the service provider must select and in all cases operate the means used in the provision of the information society service in such a way that personal data are processed only if this is absolutely necessary for the provision of the service and for the fulfilment of other purposes specified in this Act, but even then only to the extent and for the period necessary.

7.3. In the case of issuing an invoice in accordance with accounting legislation, Article 6(1)(c).

7.4. In the event of enforcement of claims arising from the contract, the period of limitation is 5 years, pursuant to Section 6:21 of Act V of 2013 on the Civil Code.
Section 6:22 [Limitation]
(1) Unless otherwise provided by this Act, claims become time-barred after five years.
(2) The limitation period begins when the claim becomes due.
(3) An agreement to change the limitation period must be in writing.
(4) An agreement excluding limitation is null and void.

DATA PROCESSORS USED

Hosting provider

Activity carried out by the data processor: Web hosting

Name and contact details of the data processor:
Name: Hostinger International Ltd.
Registered office: 61 Lordou Vironos Street Larnaca 6023 Cyprus
Email address: gdpr@hostinger.com
Physical location of processing: The data are stored in Lithuania (Europe) on Hostinger's servers, IP address: 45.84.207.176.

Fact of processing and scope of data processed: All personal data provided by the data subject.

Data subjects concerned: All data subjects using the website.

Purpose of processing: Making the website available and operating it properly, keeping in contact, sending newsletters.

Duration of processing: processing lasts until the termination of the agreement between the controller and the hosting provider, or until the data subject's request for erasure addressed to the hosting provider.

Legal basis for processing: Article 6(1)(c) and (f), and Section 13/A(3) of Act CVIII of 2001 on certain issues of electronic commerce services and information society services.

HANDLING OF COOKIES

Cookies typical for websites are the so-called "password-protected session cookies", "shopping cart cookies" and "security cookies", the use of which does not require prior consent from the data subjects.

Fact of processing and scope of data processed: Unique identification number, dates, times

Data subjects concerned: All data subjects visiting the website.

Purpose of processing: Identifying users, recording the “shopping cart” and tracking visitors.

Duration of processing and deadline for erasure:

Potential controllers entitled to access the data: the controller does not process personal data through the use of cookies.

Rights of data subjects in relation to the processing: Data subjects can delete cookies in their browser's Tools/Settings menu, usually under the Privacy settings.

Legal basis for data processing: Consent from the data subject is not required if the sole purpose of using cookies is to transmit information via an electronic communications network or if the service provider absolutely needs it to provide an information society service explicitly requested by the subscriber or user.

USE OF GOOGLE ADWORDS CONVERSION TRACKING

The data controller uses the online advertising program “Google AdWords” and, within its framework, uses Google’s conversion tracking service. Google conversion tracking is an analytics service provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”).

When a User reaches a website through a Google ad, a cookie required for conversion tracking is placed on their computer. These cookies have a limited validity and do not contain any personal data, so the User cannot be identified by them.

When the User browses certain pages of the website and the cookie has not yet expired, both Google and the data controller can see that the User clicked on the advertisement.

Each Google AdWords customer receives a different cookie, so they cannot be tracked across AdWords customers' websites.

The information – obtained using conversion tracking cookies – is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. This allows customers to see the number of users who clicked on their ads and were redirected to a page with a conversion tracking tag. However, they do not receive any information that could be used to identify any individual user.

If you do not wish to participate in conversion tracking, you can refuse this by disabling the installation of cookies in your browser. You will then not be included in the conversion tracking statistics.

Further information and Google's privacy statement can be found on the following page: www.google.de/policies/privacy/

USE OF GOOGLE ANALYTICS

This website uses Google Analytics, a web analytics service of Google Inc. (“Google”). Google Analytics uses so-called “cookies”, text files that are saved on the User's computer and help analyze the use of the website visited by the User.

The information generated by the cookie about the website used by the User is usually transmitted to and stored on a Google server in the USA. By activating IP anonymization on the website, Google will shorten the User's IP address beforehand within member states of the European Union or in other states party to the Agreement on the European Economic Area.

Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate how the User has used the website, to compile reports on website activity for the website operator, and to provide further services related to website and internet use.

Within the framework of Google Analytics, the IP address transmitted by the User's browser will not be merged with other data held by Google. The User can prevent the storage of cookies by setting their browser accordingly, but please note that in this case not all functions of this website may be fully usable. You can also prevent Google from collecting and processing the data generated by cookies and relating to your use of the website (including your IP address) by downloading and installing the browser plugin available at the following link. 

SOCIAL MEDIA

The fact of data collection, the scope of data processed: your name registered on the social networking sites Facebook and Instagram and the fact of identification by Facebook.

Scope of data subjects: All data subjects who have registered on the social media sites Facebook and Instagram and visited the website.

Purpose of data collection: Identification of activity on social media sites, activity with certain content elements of the website, or activity with the website itself.

Duration of processing, deadline for erasure, potential controllers entitled to access the data and rights of data subjects in relation to the processing: The data subject can find information on the source of the data, its processing, the method of transfer and its legal basis on the social network concerned. The processing takes place on the social networks, so the duration and method of processing and the options for erasing and modifying the data are governed by the rules of the social network concerned.

Legal basis for data processing: the data subject's voluntary consent to the processing of their personal data on social media sites.

RIGHTS OF THE DATA SUBJECTS

Right of access
You have the right to obtain confirmation from the controller as to whether or not your personal data are being processed, and, where such processing is taking place, the right to access the personal data and the information listed in the Regulation.

The right to rectification
You have the right to request that the controller rectify inaccurate personal data concerning you without undue delay. Taking into account the purpose of the processing, you have the right to request that incomplete personal data be completed, including by means of a supplementary statement.

The right to erasure
You have the right to request that the controller erase your personal data without undue delay, and the controller is obliged to erase your personal data without undue delay under certain conditions.

The right to be forgotten
Where the controller has made the personal data public and is obliged to erase them, the controller, taking into account available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform the controllers processing the data that you have requested the erasure of links to the personal data in question or of copies or replications of those personal data.

Right to restriction of processing
You have the right to obtain from the controller restriction of processing where one of the following applies:
• You contest the accuracy of the personal data, in which case the restriction shall apply for a period of time that allows the controller to verify the accuracy of the personal data;
• the processing is unlawful and you oppose the erasure of the data and instead request the restriction of its use;
• the data controller no longer needs the personal data for the purposes of data processing, but you require them for the establishment, exercise or defense of legal claims;
• You have objected to the processing; in this case, the restriction applies for a period of time until it is determined whether the legitimate grounds of the controller override your legitimate grounds.

The right to data portability
You have the right to receive the personal data concerning you, which you have provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to whom the personal data have been provided (…).

Right to object
You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data (…), including profiling based on the aforementioned provisions.

Objection to direct marketing
If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such purposes, including profiling, insofar as it is related to direct marketing. If you object to the processing of your personal data for direct marketing purposes, your personal data will no longer be processed for such purposes.

Automated decision-making in individual cases, including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
The previous paragraph shall not apply if the decision:
• is necessary for entering into, or the performance of, a contract between you and the controller;
• is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
• is based on your explicit consent.

DEADLINE FOR ACTION

The controller will inform you of the action taken on the above requests without undue delay, and in any event within 1 month of receipt of the request.

If necessary, this can be extended by 2 months. The data controller will inform you about the extension of the deadline within 1 month of receipt of the request, indicating the reasons for the delay.

If the controller does not take action on your request, it shall inform you without delay, but no later than one month from the date of receipt of the request, of the reasons for the failure to take action and of the possibility of lodging a complaint with a supervisory authority and of exercising your right to a judicial remedy.

SECURITY OF DATA PROCESSING

The controller and the processor shall implement appropriate technical and organizational measures to ensure a level of data security appropriate to the risk, taking into account the state of the art and the costs of implementation, the nature, scope, circumstances and purposes of the processing, and the varying likelihood and severity of the risk to the rights and freedoms of natural persons, including, where appropriate:

1. a) pseudonymisation and encryption of personal data;
2. b) ensuring the continued confidentiality, integrity, availability and resilience of systems and services used to process personal data;
3. (c) the ability to restore access to and availability of personal data in a timely manner in the event of a physical or technical incident;
4. d) a procedure for regularly testing, assessing and evaluating the effectiveness of the technical and organizational measures taken to guarantee the security of data processing.

COMMUNICATING A PERSONAL DATA BREACH TO THE DATA SUBJECT

If the data breach is likely to result in a high risk to the rights and freedoms of natural persons, the controller shall inform the data subject of the data breach without undue delay.

The communication to the data subject shall describe in clear and plain language the nature of the personal data breach, communicate the name and contact details of the data protection officer or other contact point where more information can be obtained, describe the likely consequences of the personal data breach, and describe the measures taken or proposed to be taken by the controller to address the breach, including, where appropriate, measures to mitigate its possible adverse effects.

The data subject does not need to be informed if any of the following conditions are met:
• the controller has implemented appropriate technical and organizational security measures and these measures have been applied to the data affected by the data breach, in particular measures – such as the use of encryption – that make the data unintelligible to persons not authorised to access the personal data;
• the controller has taken subsequent measures following the personal data breach which ensure that the high risk to the rights and freedoms of data subjects is no longer likely to materialize;
• it would involve disproportionate effort. In such a case, there shall instead be a public communication or a similar measure whereby the data subjects are informed in an equally effective manner.

If the controller has not already communicated the personal data breach to the data subject, the supervisory authority, having considered whether the breach is likely to result in a high risk, may require it to do so.

NOTIFYING THE AUTHORITY OF A PERSONAL DATA BREACH

The controller shall notify the personal data breach to the supervisory authority competent pursuant to Article 55 without undue delay and, where feasible, not later than 72 hours after having become aware of the personal data breach, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. If the notification is not made within 72 hours, it shall be accompanied by reasons justifying the delay.

RIGHT TO LODGE A COMPLAINT

Complaints about a possible infringement by the controller can be lodged with the National Authority for Data Protection and Freedom of Information:

National Authority for Data Protection and Freedom of Information (NAIH)
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
Email: ugyfelszolgalat@naih.hu

AMENDMENTS

The methods and circumstances of our data processing may change. We therefore reserve the right to amend this privacy notice at any time. We will announce any amendment on our website. 

Budapest, June 1, 2025.