Login

DATA PROCESSING POLICY

  1. Fluenta Europe Ltd. as Data Controller expresses their consent to be bound by the contents of this Data Processing Policy. They shall commit to ensuring that any processing of data relating to their activities complies with the provisions of the law. Any changes to this Policy shall be communicated in due time.
  2. Fluenta Europe Ltd. considers it their priority to honor the right to informational self-determination of their customers, employees, and partners (henceforth referred to as Data Subjects). Fluenta Europe Ltd. processes personal data with the consent of the Data Subjects and on the basis of the Hungarian Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information (Information Act). Fluenta Europe Ltd.’s organizational unit established for this purpose takes all the necessary security, technical and organizational measures to ensure the security of this data.
  3. Personal data can be processed if
    a) the Data Subject has given explicit consent, or
    b) it is decreed by law or – under the authority of the law, within the scope specified therein – local government regulations for reasons of public interest (mandatory processing).
    Personal data can also be processed if acquiring Data Subject’s explicit consent is not possible, or would incur disproportionate expenses, and processing the personal data falls under the Data Controller’s legal obligations or serves the Data Controller’s or an involved third party’s legitimate interest, and the pursuit of this legitimate interest is proportionate to the restriction of the Data Subject’s right to the protection of personal data.
  4. If the personal data was acquired with the consent of the Data Subject, the Data Controller shall, unless otherwise regulated by law, process the recorded data even without further explicit consent and following the withdrawal of the Data Subject’s consent
    a) to comply with a legal obligation to which it is subject, or
    b) to pursue the legitimate interest of the Data Controller or an involved third party, if the pursuit of this legitimate interest is proportionate to the restriction of the Data Subject’s right to the protection of personal data.
  5. Personal data shall be processed only for clearly specified and legitimate purposes, in order to exercise certain rights and fulfil obligations. The purpose of processing shall be met in all stages of processing; data shall be collected and processed fairly and lawfully. Only personal data that is essential and suitable for achieving the purpose of processing may be processed. Personal data may be processed only to the extent and for the period of time necessary to achieve its purpose.
  6. The Data Subject must be informed prior to the start of data processing whether the data processing is based on consent or whether it is mandatory. The data controller must provide the Data Subject with any notification or information on all the facts relating to the processing of their data – in particular the purposes and legal basis of the processing, the identity of the data controller and the data processor, the duration of the processing, whether the controller is processing the Data Subject’s personal data with the Data Subject’s consent and for the purposes of complying with a legal obligation to which the controller is subject or for the purposes of the legitimate interests of a third party, and who has access to the data – in easily accessible and legible form, with concise, clear, and plain content. The notification or information shall also cover the rights of the Data Subject in relation to the processing and the legal remedies available to them.
  7. The accuracy, completeness, and up-to-date status of the data shall be ensured throughout the processing; the identification of the Data Subject shall be possible for no longer than necessary for the purpose of the processing.
  8. Personal data may be transferred to a controller or processor engaged in processing in a third country if the Data Subject has given explicit consent to the international data transfer, or the conditions of processing laid down above are fulfilled in the course of the international transfer and the adequate level of protection of the personal data transferred is provided by the controller or processor engaged in processing in the third country. Transfer to EEA States shall be regarded as transfer within the territory of Hungary.
  9. Data processing in connection with the activities of Fluenta Europe Ltd. is based primarily on voluntary consent. Fluenta Europe Ltd. reminds the Data Subjects that if they provide data that is not their own personal data, the provider of this data is obliged to obtain consent from the subject of that data.
  10. Data processing operations of Fluenta Europe Ltd.:
    a) Recording calls to the telephone helpdesk (call center)
    - purpose of the data processing: The users of the Fluenta system operated by Fluenta Europe Ltd. may contact the telephone helpdesk with any request or question related to the operation of the system. The entirety of the call audio is recorded in the call-center software solution operated by the data processor. The purpose of the recording is to make the instructions and statements made during these telephone conversations retrievable and searchable. The archiving of audio material takes place in two stages: in accordance with archiving and audio recording regulations, the data is archived for 410 days, after which it is deleted. After this period, the option to restore deleted audio material is available for 15 days. After the 15 days, the data is permanently deleted from the system. The Data Subject may request a copy of the audio data at the contact details of the data controller indicated in section 11.
    - legal base for the data processing: voluntary informed consent of the Data Subject,
    - scope of the processed data: the telephone conversation with the Data Subject in its entirety,
    - duration of the data processing: compliant with archiving and voice recording regulations, 425 days from the date of the call,
    - data controller: Fluenta Europe Ltd. (Floor 8, Building B, 43‑47    Bartók Béla Street, Budapest 1114),
    - data protection registry number: NAIH-84136/2015,
    - data processor: Arenim Technologies Kft. (6 Lechner Ödön Alley, Budapest 1095),
    - the data processor’s activities in relation to data processing: Office Anywhere Contact Center service (recording and storing calls to the call center, organizing calls in a searchable database, server service).
    b) Sending newsletters
    - purpose of the data processing: Sending newsletters about the Fluenta system and data controller’s services to those who subscribed to newsletters through the fluenta.eu website,
    - legal base for the data processing: consent of the Data Subject,
    - scope of the processed data: name and email address of the Data Subject,
    - duration of the data processing: until Data Subject’s request for deletion,
    - data controller: Fluenta Europe Ltd. (Floor 8, Building B, 43‑47    Bartók Béla Street, Budapest 1114),
    - data protection registry number: NAIH-85372/2015.
    c) Customer database
    - purpose of the data processing: Records containing the data of existing and potential customers of the data controller for the purposes of direct marketing, product information, market research, contact management,
    - scope of the processed data: company name, name, company address, position, work email address and phone number,
    - duration of the data processing: until Data Subject’s request for deletion,
    - data controller: Fluenta Europe Ltd. (Floor 8, Building B, 43‑47     Bartók Béla Street, Budapest 1114),
    - data protection registry number: NAIH-85374/2015.
    d) Managing user data
    - purpose of the data processing: Records of data entered and processed in the Fluenta system by persons using the system,
    - legal base for the data processing: consent of the Data Subject,
    - scope of the processed data:
    ) Information system users must provide: country, tax number, company name, company address (city, street, zip code), user name, password, first name, last name, email address, language,
         ii.) Information system users may choose to provide: company information (email address, phone number, fax number), user information (department, position, phone number, fax number),
    - duration of the data processing: until Data Subject’s request for deletion,
    - data controller: Fluenta Europe Ltd. (Floor 8, Building B, 43‑47     Bartók Béla Street, Budapest 1114),
    - data protection registry number: NAIH-85373/2015.
    Fluenta system users manage the data entered in the system themselves.
    The Data Subjects are not using the services of the data controller as individuals, but as employees of the legal entities using the data controller’s services.
  11. With regard to all the data processing operations listed in points 10(a) to 10(d), the Data Subject is uniformly entitled to request information, rectification, restriction, erasure, or objections to the processing of personal data at any time at the following contact details:
    - by letter: addressed to Floor 8, Building B, 43‑47    Bartók Béla Street, Budapest 1114,
    - by email: addressed to privacy@fluenta.eu or info@fluenta.eu,
    - by telephone: on + 36 1 8 555 999, providing your name and address,
    - in person: at Floor 8, Building B, 43‑47     Bartók Béla Street, Budapest 1114.
  12. Fluenta Europe Ltd. informs the Data Subjects that a court, prosecutor, investigative authority, law enforcement authority, administrative authority, the National Authority for Data Protection and Freedom of Information, or other bodies authorized by law may contact the data controller to provide information, to disclose or transfer data, or to provide documents.
  13. Fluenta Europe Ltd. only discloses personal data to public authorities – if the public authority has indicated the precise purpose and scope of the data –to the extent that such disclosure is strictly necessary for the purpose of the request.
  14. Fluenta Europe Ltd. selects and operates the IT tools used to process personal data in the course of providing the service in such a way that the data processed are:
    a) accessible to those authorized to access them;
    b) ensured to be authentic and verified;
    c) certifiably unaltered;
    d) protected from unauthorized access.
  15. Fluenta Europe Ltd. takes appropriate measures to protect personal data, in particular against unauthorized access, alteration, transmission, publication, erasure or destruction, accidental destruction or accidental damage, or inaccessibility resulting from changes in the technology used. In order to protect the electronically managed data files in their various registers, they ensure, by appropriate technical means, that the stored data cannot be directly linked and attributed to the Data Subject, except where permitted by law. Fluenta Europe Ltd. ensures the security of data processing, especially considering the current state of technology, by technical and organizational measures which provide a level of protection appropriate to the risks associated with data processing.
  16. The Data Subject may request information about the processing of their personal data and may request the rectification or – except for processing required by law – the erasure of their personal data in the manner indicated when the data were collected, at the contact details indicated in point 11.
  17. At the Data Subject's request, the data controller shall provide information on the data processed by the controller or by a processor on the controller’s behalf, the source of the data, the purpose, legal basis and duration of the processing, the name and address of the processor and the activities of the processor in relation to the processing, and, in the case of a transfer, the legal basis and the recipient of the transfer. The data controller shall provide the information in writing in a clear and plain form within the shortest possible time, but not later than 30 days from the submission of the request, unless the information cannot be provided due to the grounds for refusal provided for in the Information Act. The fulfilment of this information request is free of charge if the Data Subject has not already submitted a request for the same set of data in the current year. In other cases, the data controller may call for reimbursement.
  18. Fluenta Europe Ltd.
    a) blocks the collected personal data if the Data Subject requests it or if, on the basis of the information available to it, it is likely that deletion would harm the Data Subject's legitimate interests. Blocked personal data may be processed only for as long as the processing purpose that precluded the deletion of the personal data persists.
    b) marks the collected data if the accuracy, the correctness or the completeness of the personal data processed by the controller is contested by the data subject, and the accuracy, the correctness or the completeness of the personal data processed cannot be verified beyond doubt.
    c) erases the personal data if the processing is unlawful, the Data Subject requests it, the processed data is incomplete or inaccurate – and this situation cannot be lawfully remedied – provided that erasure is not precluded by law, the purpose of the processing has concluded or the statutory period for storing the data has expired, or the court or the Hungarian National Authority for Data Protection and Freedom of Information has ordered it.
  19. The data collector has 30 days to erase, block or rectify the collected personal data. If the data collector refuses to fulfil the Data Subject’s request for erasure, blocking, or rectification, the Data Subject shall be informed of the reasons for refusal in writing in 30 days. The data controller shall notify the Data Subject – and all those to whom the data were previously transmitted for processing – of the rectification, blocking and erasure. The data collector may refrain from notifying the Data Subject if this does not harm the legitimate interests of the Data Subject in relation to the purpose of the processing.
  20. The Data Subject may object to the processing of their personal data
    a) if the processing or transfer of personal data is necessary only for the fulfilment of a legal obligation to which the data controller is subject or for the purposes of the legitimate interests pursued by the data controller, the data recipient or a third party, unless the processing is required by law;
    b) if the personal data are used or transmitted for direct marketing, public opinion polling or scientific research purposes;
    c) in other cases specified by law.
  21. The data controller reviews the objection, determines whether it is justified, and notifies the Data Subject of this decision in writing within the shortest possible time, but not later than 15 days from the submission of the objection. If the Data Subject’s objection is justified, the data processing, including further data collection and transfer, will be ceased, the data will be blocked, and all those to whom the personal data concerned by the objection have been previously disclosed and who are obliged to take measures to enforce the right to object will be notified of the objection and the action taken on the basis of the objection. If the Data Subject does not agree with the data controller’s decision, they may challenge it in court within 30 days of the notification.
  22. Fluenta Europe Ltd. shall not erase the Data Subject’s data if the data processing was decreed by law. However, the data may not be transferred to the data recipient if the data controller has agreed to the objection or if the court has ruled that the objection is justified.
  23. The data collector informs the Data Subjects that when visiting the fluenta.eu website, their personal data (i.e. data that can be associated with the data subject) may be collected by the controller for data processing in two ways: on the one hand, technical data in connection with the maintenance of the Internet connection, relating to the computer used by the Data Subject, the browser program, the Internet address and the pages visited, are automatically generated in the computer system of the data controller; on the other hand, the Data Subject may also provide their name, contact details or other data if they wish to contact the controller personally when using the website.
  24. The data controller may also collect data on the usage patterns of the websites and systems operated by Fluenta Europe Ltd. through browser cookies. Browser cookies typically contain small pieces of information (such as the name of the Data Subject's internet service provider, the pages visited, the type of browser used, etc.); for analytic purposes, the website may store cookies on the Data Subject's own device (computer, laptop, smartphone, etc.), largely to enhance user experience when visiting the website. By visiting the website, the Data Subject agrees to accept cookies in their browser.
  25. The data controller informs the Data Subjects that in order to enforce their rights, they can turn to the Hungarian National Authority for Data Protection and Freedom of Information (registered office: 22/C Szilágyi Erzsébet Alley, Budapest 1024), or in case of violation of their rights or for legal remedy against the decisions of the data controller, they can bring the issue before the court.