This is a courtesy translation of the Hungarian privacy notice. In the event of any discrepancy, the Hungarian version prevails.
1. Name of the data controller
If you would like to contact our Company, you can reach the data controller through our contact details. Trader Trainer Kft deletes every email that reaches it, together with the personal data it contains, at the latest 1 year after the data were disclosed.
Trader Trainer Korlátolt Felelősségű Társaság
Short name: Trader Trainer Kft
Registered office: 2072 Zsámbék, Csillagerdő utca 29, Hungary
Email: ugyfelszolgalat@tradertrainer.hu
Telephone: +36/70-3975992
Website: www.tradertrainer.hu
2. Purpose of this privacy notice
Trader Trainer Kft (address, hereinafter service provider, data controller), as data controller, recognises the content of this legal notice as binding on itself. It undertakes that all data processing connected with its activity complies with the requirements set out in this policy, in the national legislation in force and in the legal acts of the European Union.
The data protection principles arising in connection with the data processing of Trader Trainer Kft are continuously available at the privacy policy address. Trader Trainer Kft reserves the right to amend this notice at any time. It will of course inform its audience of any changes in good time.
If you have a question in connection with this notice, please write to us and our colleague will answer it. Trader Trainer Kft is committed to protecting the personal data of its clients and partners, and considers respecting its clients’ right to informational self-determination to be of particular importance. Trader Trainer Kft treats personal data confidentially and takes every security, technical and organisational measure that guarantees the security of the data.
The primary purpose of the data processing of Trader Trainer Kft is to stay in contact in order to inform you properly, to handle any technical problems that may arise effectively and quickly, to send system messages in connection with the service, and to reply to the message you have sent.
Trader Trainer Kft sets out its data processing practice below.
3 The scope of the personal data processed
3.1 Personal data to be provided during registration
Name (required), email address (required), telephone number (optional), subject of enquiry (optional), message (optional).
By sending a message to Trader Trainer Kft you consent to us processing your personal data. Providing personal data is voluntary, so the legal basis for the processing is your consent in accordance with Section 5 (1) a) of the Hungarian Information Act.
Name of the processing: Contact
Purpose of the processing: So that the Data Controller can answer and respond to the question and thereby fulfil what is set out in your enquiry.
Legal basis of the processing: The consent of the data subject, GDPR Article 6 (1) a)
Scope of the data processed: any personal data that you, as the data subject, provide to the Data Controller during the contact.
Duration of the processing: the Data Controller stores the personal data for 1 year, or until you withdraw your consent. After that, all personal data provided by you are deleted permanently and irrecoverably.
3.2 Technical data
Trader Trainer Kft selects and operates the IT tools used in the provision of the service for processing personal data so that the data processed are:
- accessible to those entitled to them (availability);
- authentic and their authentication assured (authenticity of the processing);
- verifiably unchanged (data integrity);
- protected against unauthorised access (confidentiality of the data).
Trader Trainer Kft protects the data with appropriate measures against unauthorised access, alteration, transfer, disclosure, deletion or destruction, as well as against accidental destruction.
Trader Trainer Kft ensures the security of the processing with technical, organisational and structural measures that provide a level of protection appropriate to the risks arising in connection with the processing.
During the processing, Trader Trainer Kft preserves
- confidentiality: it protects the information so that only those entitled can access it;
- integrity: it protects the accuracy and completeness of the information and of the method of processing;
- availability: it ensures that when the entitled user needs it, they can genuinely access the desired information and that the related tools are available.
3.3 Cookies
3.3.1 What cookies do
- they collect information about visitors and their devices;
- they remember the individual settings of visitors, which can be used for example when carrying out online transactions, so they do not have to be typed in again;
- they make the website easier to use;
- they provide a quality user experience.
In order to deliver a tailored service, a small data packet, a so-called cookie, is placed on the user’s computer and read back during a later visit. If the browser sends back a previously saved cookie, the provider handling the cookie is able to link the user’s current visit with earlier ones, but only in respect of its own content.
3.3.2 Strictly necessary session cookies
The purpose of these cookies is to let visitors browse the tradertrainer.hu website fully and smoothly, and to use its functions and the services available there. Cookies of this type are valid until the end of the session (the browsing); when the browser is closed, this kind of cookie is deleted automatically from the computer or from the other device used for browsing.
3.3.3 Third-party cookies (analytics and marketing)
Two third-party solutions run on this website, and both of them start only after your prior consent. Until you consent, neither places a cookie on your device nor sends any data about you.
Google Analytics 4 (measurement ID: G-JYKF2N7X0N) - statistics. It shows me how many visitors arrive, which pages they view and where they come from. I use the data to develop the site and improve the user experience. Data controller: Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland), privacy policy: policies.google.com/privacy. I use Google Consent Mode v2, which means that until you give your consent, Google stores no cookie on your device and uses no advertising identifier.
Meta Pixel (ID: 1414193218644126) - marketing. I use it to measure whether my ads on Facebook and Instagram are effective. I do not use it for remarketing or for building custom audiences. Data controller: Meta Platforms Ireland Limited (Merrion Road, Dublin 4, Ireland), privacy policy: facebook.com/privacy/policy.
These cookies remain on your computer or on the other device used for browsing until they expire, or until you delete them. You can change or withdraw your consent at any time with the Cookie settings button in the footer; once withdrawn, the transfer of data to Google and Meta stops immediately.
If you would like to prevent Google Analytics from adding your visits to the analytics on any website at all, use this add-on (available for any browser).
4. List of cookies used on the site and their expiry
The list below always reflects the cookies actually used on this site. A more detailed description, grouped by service, is available in the Cookie Policy.
5.1 General data processing principles
The data processing carried out in the activity of Trader Trainer Kft is based on voluntary consent or on statutory authorisation. In the case of processing based on voluntary consent, data subjects may withdraw that consent at any stage of the processing.
In certain cases the processing, storage and transfer of a range of the data provided is made mandatory by law, of which we notify our clients separately. We draw the attention of those disclosing data to Trader Trainer Kft to the fact that if they provide personal data other than their own, it is the discloser’s obligation to obtain the consent of the data subject.
Its data processing principles are in line with the data protection legislation in force, in particular the following:
- Act CXII of 2011 on informational self-determination and freedom of information (Information Act);
- 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, GDPR);
- Act V of 2013 on the Civil Code;
- Act C of 2000 on accounting;
- Act LIII of 2017 on the prevention and combating of money laundering and terrorist financing;
- Act CCXXXVII of 2013 on credit institutions and financial undertakings.
6. Physical locations where the data are stored
Your personal data (that is, data that can be connected with your person) may come into our processing in the following ways: on the one hand, in connection with maintaining the internet connection, technical data relating to the computer, browser and internet address you use and the pages you visit are generated automatically in our computer system; on the other hand, you may also provide your name, contact details or other data if you wish to get in touch with us personally while using the website.
Data recorded technically during the operation of the system: the data of the data subject’s logging-in computer that are generated during use and that the system of Websupport Magyarország Kft. (hosting) records as the automatic result of technical processes. The system logs the automatically recorded data on entry and exit without any separate statement or action by the data subject. These data cannot be linked with other personal user data, except in cases made mandatory by law. Only Websupport Magyarország Kft. (hosting) has access to the data.
7. Data transfer, data processing, the range of those who learn the data
Apart from me, no other person or company has access to the personal data sent from the Contact menu item.
To operate and measure the website, however, I do use external service providers. The following data reach them:
- Websupport Magyarország Kft. (hosting) - the technical data recorded in the server logs. This is necessary for the website to work and is not tied to consent.
- Google Ireland Limited (Google Analytics 4) - if you consent, the technical data of your visit and a random identifier tied to your device. Google may also transfer the data to the United States; the legal basis for this is the EU-US Data Privacy Framework.
- Meta Platforms Ireland Limited (Meta Pixel) - if you consent, the fact of your visit and an identifier tied to your browser. Meta may also transfer the data to the United States, likewise under the Data Privacy Framework.
- SalesAutopilot - the application and subscription forms embedded in the website are served by this provider, so the data you enter in a form reach them.
The transfer of data to Google and Meta takes place solely on the basis of your consent, and stops immediately when you withdraw it.
8. Rights of the data subject and remedies
The data subject may request information about the processing of their personal data, and may request the rectification or, with the exception of mandatory processing, the deletion or withdrawal of their personal data; they may exercise their right to data portability and their right to object in the manner indicated when the data were collected, or at the contact details of the data controller given above.
8.1 Right to be informed
Trader Trainer Kft takes appropriate measures to provide data subjects with all information relating to the processing of personal data referred to in Articles 13 and 14 of the GDPR and each communication under Articles 15-22 and 34 in a concise, transparent, intelligible and easily accessible form, using clear and plain language.
8.2 The data subject’s right of access
The data subject has the right to obtain confirmation from the data controller as to whether or not their personal data are being processed, and, where that is the case, to obtain access to the personal data and the following information: the purposes of the processing; the categories of personal data concerned; the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations; the envisaged period for which the personal data will be stored; the right to rectification, erasure or restriction of processing and the right to object; the right to lodge a complaint with a supervisory authority; information about the sources of the data; the existence of automated decision-making, including profiling, together with meaningful information about the logic involved and the significance and the envisaged consequences of such processing for the data subject. The data controller provides the information within one month of the submission of the request at the latest.
8.3 Right to rectification
The data subject may request the rectification of inaccurate personal data concerning them processed by Trader Trainer Kft, and the completion of incomplete data.
8.4 Right to erasure
The data subject has the right to obtain from Trader Trainer Kft the erasure of personal data concerning them without undue delay where one of the following grounds applies:
- the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
- the data subject withdraws the consent on which the processing is based, and there is no other legal ground for the processing;
- the data subject objects to the processing and there are no overriding legitimate grounds for the processing;
- the personal data have been unlawfully processed;
- the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
- the personal data have been collected in relation to the offer of information society services.
Erasure of the data cannot be initiated where the processing is necessary: for exercising the right of freedom of expression and information; for compliance with an obligation under Union or Member State law which requires processing by the controller, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; for reasons of public interest in the area of public health, or for archiving purposes, scientific and historical research purposes or statistical purposes; or for the establishment, exercise or defence of legal claims.
8.5 Right to restriction of processing
At the data subject’s request, Trader Trainer Kft restricts the processing where one of the following applies:
- the data subject contests the accuracy of the personal data, in which case the restriction applies for a period enabling the accuracy of the personal data to be verified;
- the processing is unlawful and the data subject opposes the erasure of the data and requests the restriction of their use instead;
- the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; or
- the data subject has objected to the processing; in this case the restriction applies for the period until it is verified whether the legitimate grounds of the controller override those of the data subject.
Where processing is restricted, such personal data may, with the exception of storage, only be processed with the data subject’s consent, or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the Union or of a Member State.
8.6 Right to data portability
The data subject has the right to receive the personal data concerning them, which they have provided to the controller, in a structured, commonly used and machine-readable format, and to transmit those data to another controller.
8.7 Right to object
The data subject has the right to object at any time, on grounds relating to their particular situation, to processing of their personal data which is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, or which is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, including profiling based on those provisions. In the event of an objection, the controller may no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
8.8 Automated individual decision-making, including profiling
The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.
8.9 Right of withdrawal
The data subject has the right to withdraw their consent at any time.
8.10 Right to turn to a court
In the event of an infringement of their rights, the data subject may turn to a court against the data controller. The court deals with the case out of turn.
8.11 Data protection authority procedure
A complaint can be lodged with the Hungarian National Authority for Data Protection and Freedom of Information:
Name: Nemzeti Adatvédelmi és Információszabadság Hatóság (Hungarian National Authority for Data Protection and Freedom of Information)
Registered office: 1125 Budapest, Szilágyi Erzsébet fasor 22/C, Hungary
Postal address: 1530 Budapest, Pf.: 5, Hungary
Telephone: 0613911400
Fax: 0613911410
Email: ugyfelszolgalat@naih.hu
Website: http://www.naih.hu
9. Other provisions
We provide information about processing not listed in this notice when the data are collected. We inform our clients that the court, the prosecutor, the investigating authority, the authority for administrative offences, the public administration authority, the Hungarian National Authority for Data Protection and Freedom of Information, the National Bank of Hungary and other bodies authorised by law may approach the data controller in order to obtain information, to have data disclosed or handed over, or to have documents made available.
Trader Trainer Kft discloses personal data to the authorities, where the authority has indicated the exact purpose and the scope of the data, only to the extent and in the measure that is indispensable for achieving the purpose of the request.
GLOSSARY
Processor: the natural or legal person, public authority, agency or any other body which processes Personal data on behalf of the Data Controller.
Processing: any operation or set of operations performed on personal data or on sets of personal data, 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.
Restriction of processing: the marking of stored personal data with the aim of limiting their processing in the future.
Data Controller: 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 Data Controller or the specific criteria for its nomination may also be provided for by Union or Member State law.
Personal Data Breach: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
Consent of the Data Subject: any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.
Data Subject: a natural person identified or identifiable on the basis of any information.
Third Party: a natural or legal person, public authority, agency or any other body other than the Data Subject, the Data Controller, the Processor and the persons who, under the direct authority of the Data Controller or Processor, are authorised to process personal data.
Law/legislation/legal obligations: the Hungarian and European Union legislation in force from time to time.