MAXWHERE SOLUTIONS LLC.
PRIVACY POLICY

Preamble

The Data Controller declares that it processes personal data in accordance with the Fundamental Law of Hungary, Act 112 of 2011 on Informational Self-determination and Freedom of Information and Regulation (EU)no. 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”).

The Data Controller respects the personal data of its employees, clients, contractual partners, furthermore of the visitors of the https://www.maxwhere.com. It shall treat and process all data and facts that come to its knowledge as confidential and such data is processed solely on the basis of performance of a contract, legal obligation, its own legal interest with respect to the data subject’s interests and their consent based on prior information.

Principles of Data processing

The processing of personal data is carried out by the Data Controller by following the below principles at all times:

Personal data is processed lawfully, fairly and in a transparent manner in relation to the data subject.

The principle of purpose limitation shall govern data processing, and the processing of personal data shall be compatible and relevant with its purpose, furthermore it shall be necessary for such purposes.

Data processing shall be accurate and, where necessary, kept up to date. The Data Controller shall make every reasonable step to ensure that inaccurate personal data is erased or rectified without delay.

Personal data are stored in a limited manner until the purpose of their processing has been met.

It ensures appropriate security of personal data against unauthorized or unlawful processing and accidental loss, destruction or damage.

Personal data are processed solely for the purpose and in the manner specified in present Privacy Policy, in order to exercise the rights and fulfil the obligations specified herein. The Data Controller declares that it meets these objectives during all stages of data processing.

The Data Controller only processes personal data that is essential for the realization of the purpose of data processing; suitable for the achievement of these purposes and only to the extent and time necessary for the realization of the purpose.

It uses appropriate technical or organizational measures in order to ensure the appropriate security of personal data against unauthorized or unlawful processing and against accidental loss, destruction or damage.

Information provided to Data Subjects

By the issuance of present Privacy Policy, the Data Controller makes adequate steps in order to ensure that the information addressed to the data subjects is handed over in a way that is concise, easily accessible and easy to understand in a clean and plain language.

The partners aiding the work of the Data Controller(s) and Data Processor(s) are bound by the obligation of confidentiality with regard to the personal data of the data subjects.

Definitions

1. data security: a set of technical, personnel and organizational measures and procedures to protect data security criteria such as confidentiality, integrity and availability.

2. data processing: Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

3. limitation of data management: marking of stored personal data for the purpose of restricting their future processing

4. data controller: Means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

Data Controller regarding present Privacy Policy:

DataController
Name:
MaxWhereSolutions LLC.
Seat:
9021 Győr, Szent István utca 10/A. 3. em. 321.
Company registry number:
08-10-001955
Tax number:
27964413-2-08
Website:
Email address:
contact@maxwhere.com

5. processing: The execution of the technical tasks relating to data processing, regardless of the used technique and instrument, or the place of processing, where the technical task is performed on personal data.

6. data processor: A natural or legal person, public authority, agency or other body which – based on Retainer Agreement with Data Controller - processes personal data on behalf of it.

Data for accounting purposes is processed by Qualinnova Consulting Kft. (seat: 6726 Szeged, Cinke utca 2. 3.; company registry number: 06-09-018869; tax number: 23934373-2-06; képviselője: representative: Szabolcs János managing director; email: szabolcs.hajdu@qualionnova.hu;).

Data Controller’s IT infrastructure is processed by Amazon Web Services. The Data Processor stores the personal data in the cloud platform of Amazon Web Services’ database seated in Frankfurt and in Ireland. The Privacy Policy of Amazon Web Services can be reached here: https://aws.amazon.com/privacy/.

Mistems Ltd. (seat: 9021Győr, Szent István utca 10/A. III.em. 321.; company registry number.:08-09-025466; tax number.: 24704090-2-08; represented by: Hetényi Márk and dr. Galambos Péter jointly.) has access to the personal data of licensed customers, by measuring customer satisfaction and ratings, for quality assurance purposes and for the regular maintenance and development of the software.

The Data Controllers declare that the data processors contracted by them shall use the personal data solely on the basis of the instructions of the Data Controller and in accordance with the purpose for which they are processed and shall not perform any other processing operation other than that purpose. The processing will respect the personal data of the data subjects and the provisions of this Privacy Statement.

Principles of Data processing

The processing of personal data is carried out by the Data Controller by following the below principles at all times:

Personal data is processed lawfully, fairly and in a transparent manner in relation to the data subject.

The principle of purpose limitation shall govern data processing, and the processing of personal data shall be compatible and relevant with its purpose, furthermore it shall be necessary for such purposes.

Data processing shall be accurate and, where necessary, kept up to date. The Data Controller shall make every reasonable step to ensure that inaccurate personal data is erased or rectified without delay.

Personal data are stored in a limited manner until the purpose of their processing has been met.

It ensures appropriate security of personal data against unauthorized or unlawful processing and accidental loss, destruction or damage.

Personal data are processed solely for the purpose and in the manner specified in present Privacy Policy, in order to exercise the rights and fulfil the obligations specified herein. The Data Controller declares that it meets these objectives during all stages of data processing.

The Data Controller only processes personal data that is essential for the realization of the purpose of data processing; suitable for the achievement of these purposes and only to the extent and time necessary for the realization of the purpose.

It uses appropriate technical or organizational measures in order to ensure the appropriate security of personal data against unauthorized or unlawful processing and against accidental loss, destruction or damage.

1. Destruction of data: the total physical destruction of the data medium on which the data are stored ;

2. Erasure of data: making data unrecognizable in such a way that their recovery is no longer possible;

3. Transfer of data: making the data available to certain third parties;

4. Data blocking: the marking of data with an identification mark for the purpose of limiting their further processing permanently or for a limited period of time;

5. Personal data breach: 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;

6. Confidentiality (secrecy): the characteristic of the data that only a predefined group of users (authorized users) is allowed access to it, access by all others is illegal;

7. Loss of confidentiality: loss of confidentiality is called disclosure, where confidential data becomes known and/or accessible to unauthorized persons;

8. Security incident: any event that may adversely affect the confidentiality, integrity or availability of an IT device or the data stored on it;

9. Recipient: a natural or legal person, public authority, agency or any other body to whom or with 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 are not recipients; the processing of such data by those public authorities must comply with the applicable data protection rules in accordance with the purposes of the processing;

10. GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016;

11. Third party: a natural or legal person, public authority, agency or any other body other than the data subject, the controller, the processor or the persons who, under the direct authority of the controller or processor, are authorized to process personal data;

12. Consent: a clear affirmative act establishing a freely given, specific, informed and unambiguous indication of the data subject's agreement to the processing of personal data relating to him or her, such as by a written statement, including by electronic means, or an oral statement;

13. Information Act: Act CXII of 2011 on Informational Self-determination and Freedom of Information;

14. Integrity: the criterion of existence, authenticity, integrity and intrinsic completeness of data, ensuring that the data, information or program can only be altered by those who are authorized to do so and cannot be altered without being detected;

15. Personal data: 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, an identification 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.

16. Objection: the declaration of the data subject in which he/she objects to the processing of his/her personal data, and demands the termination or erasure of his/her processed data

Description of the Controller's activities, exclusion of liability  

The Data Controller is a software development company whose main profile is to provide users with a creative and effective presentation tool in three dimensions through its software MaxWhere, which users can freely use, upload content and share with other users according to their own purposes. The MaxWhere software, served by the MaxWhere Client, can be used in conjunction with the MaxWhere Store and MaxWhere 3D Cloud.

The Data Controller, as a developer and service provider, is solely responsible for providing the platform, hosting and software. Its content is developed by the user.

The Data Controller undertakes to make the conclusion of licence agreements subject to compliance with the requirements of the lawful exercise of rights and to draw the attention of users to the observance of personal rights and data protection regulations, but at the same time excludes its liability in the event that the user uses the presentation interface in a manner that is contrary to the law, despite its undertaking. The Data Controller declares that it does not regularly monitor the content uploaded by users, however, in the case of explicitly reported content, we reserve the possibility to monitor and, if necessary, remove or refuse to make available content that causes harm to other persons and violates legal requirements.

The Data Controller processes your personal data under the following rights and purposes

Data processing based on the performance of a contract [GDPR Article 6 Section 1 paragraph b]

As part of the performance of a contract, the Data Controller processes the personal data of natural persons for the following purposes.

Personal data of employees:

name; birth name; place and date of birth; mother’s maiden name; qualification; address; phone number; e-mail address; name of financial institution and account number; specimen signature

Personal data of clients and contractual partners:

name/company name; address; shipping address; name of contact person; phone number; e-mail address

The purpose of data processing is to enter into the relevant written contracts, fulfil contractual obligations and to provide contact details.

The Data Controller stores the provided personal data in a written form at its branch office, electronically in its electronic database and online in the database of its websites. It handles personal data from the conclusion of the contract until the existence of the contractual relationship or the expiry of the contractual relationship. Personal data processed in this context will not be transferred.

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With the purchase of a licence, you will need to create a MaxWhere 3D Cloud account to use the presentation platform.

by entering your name and e-mail address and password .

The purpose of creating a personal account is to register purchases, licence agreements, invoices and to edit, store and share content created in the presentation platform.

The Data Controller stores the personal data provided in digital format on a digital cloud server. The personal data provided to create a personal account will be processed until the account is deleted. The Controller will not transfer personal data processed in this context.

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Customers who have purchased a software licence will be able to renew and upgrade their licences at a later date. To do so, you will be required to provide the following personal data:

user name for the license to be extended/extended; password; user license key

Refusal to provide the data shall constitute an obstacle to the conclusion of the contract. It is in the interest and responsibility of the customer to provide the data and to ensure that they are correct. .

The purpose of processing the data is to fulfil the contract and to facilitate contact with customers.  

The personal data provided will be stored electronically on the Data Controller's server. The personal data provided will be stored from the conclusion of the contract until its termination or cancellation by either party, or until the expiry of the contractual relationship. The Controller shall not transfer personal data processed in this context.

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During the purchase process, the MaxWhere Store (web store) redirects the customer to the Stripe payment interface, which is a separate interface from the Data Controller's web store. The Data Controller declares that it does not know and does not process the personal (credit card) data provided during the online payment. The Data Controller informs the data subject that Stripe acts as an independent data controller for online credit card payments.

Data processing based on compliance with a legal obligation [GDPR Article 6 Section 1 paragraph c]

The following personal data of the contractual partners are processed on the basis of the legal provisions on accounting, VAT and taxation :

name(s); address/place of residence; tax number

Contractual partners data are processed for the purpose of issuing invoices for purchases and deliveries .

The Data Controller stores the personal data provided in digital format on a cloud-based digital server and transfers it to the Data Processor in charge of accounting and payroll. Purchases are invoiced using an online invoicing program. The invoices issued, with the data content contained therein, are processed by the Data Controller until the invoice is kept for accounting purposes..

Data processing based on consent [GDPR Article 6 Section 1 paragraph a]

Without purchasing a license, you can use the presentation platform in a so-called "free" version by creating a MaxWhere 3D Cloud account. In this context, the Data Controller processes the following personal data of the data subject :

name; e-mail address; password

The purpose of creating a personal "free" account is to allow you to upload up to a certain amount of data to the cloud for free.

The Data Controller stores the personal data provided in digital format on a digital cloud server. The personal data provided to create a personal account will be processed until the account is deleted. The Controller will not transfer personal data processed in this context.

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Through its website https://www.maxwhere.com/contact-sales, the Data Controller enables data subjects to request a personalised offer for its products and services or to contact the Data Controller with any questions they may have.

In this context, the Data Controller processes the following personal data of the interested party:

first name, surname, work e-mail address, job title, telephone number, company name, company size

The Data Controller stores the personal data provided in digital format on a digital cloud server. The personal data provided during the application and contact process will be processed until the offer is made, but for a maximum period of 1 year. The Controller shall not transfer personal data processed in this context.

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The Data Controller provides the user with product support, which can be requested via the website https://www.maxwhere.com/contact-sales

In this context, the Data Controller processes the following personal data of the interested party:

first name, surname, work e-mail address, job title, telephone number, company name, company size

The Data Controller stores the personal data provided in digital format on a digital cloud server. The personal data provided during the application and contact process will be processed until the offer is made, but for a maximum period of 1 year. The Controller shall not transfer personal data processed in this context.

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Personal data of subscribers who contact the Data Controller through the social media platform https://www.youtube.com/channel/maxwhere. In this context, the following personal data of the interested party are processed by the Data Controller:

profile name; profile picture

The data controller stores the personal data thus collected on the database area of the website for the purpose of contacting subscriber, until they unsubscribe. The Data Controller will not transfer personal data processed in this context.

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The Data Controller informs the data subjects that it is available through Facebook and LinkedIn under the names "MaxWhere" and "MaxWhere VR". Our news feeds published on the social channels' message wall, data subjects can subscribe to us by clicking on the "follow"/"subscribe" link on the page, unsubscribe by clicking on the "unfollow"/"unfollow"/"unsubscribe" link on the same page, or delete unwanted messages on the message wall by using the message wall settings.

The operators of social networking sites are all separate data controllers from the Data Controller. For information on the data processing of the Facebook social networking site, please see: Meta Platforms Ireland Limited (seat:4 Grand Canal Square Grand Canal Harbour Dublin 2, Ireland; https://www.facebook.com/privacy/explanation).

The LinkedIn social networking site is operated by LinkedIn Ireland Unlimited Company (Wilton Place, Dublin 2, Írország) whose privacy policy is available at: https://www.linkedin.com/legal/privacy-policy

If the data subject follows the Data Controller, his or her profile becomes available.

This context, the Data Controller processes the following personal data:

profile name; profile picture; public data processed on the profile

The Data Controller declares that through its social media profile, the Data Controller does not process or record any data in its internal system and the social media platform will not be used by the Data Controller for any purpose other than the communication of news.

The purpose of data processing is to inform the data subject about current information and to publish information material about technological developments. The published news will appear in the news feed for as long as the data subject wishes. By "unsubscribing"/"opting out", the above news and information will no longer appear in the news feed of the data subject. The Data Controller stores the personal data provided on the website's database interface server and processes the personal data of the data subjects until consent is withdrawn.

Data processing based on legitimate interest [GDPR Article 6 Section 1 paragraph f]

With the maxwhere software, the data subject has the possibility to invite additional users to the digital space and presentation designed by him/her in order to view and follow the presentation.

In this context the Data Controller will inform the other participants to be invited to the presentation:

name and e-mail address.

The Data Controller sends an invitation message to the e-mail address provided, which allows the invited participant to join the presentation by clicking on the link. Refusal to provide the data will constitute an obstacle to the conclusion of the contract. It is in the interest and responsibility of the customer to provide the data and to ensure that they are correct.

The purpose of the processing is to enable you to connect to the presentation. In the information e-mail, the Data Controller allows the possibility to object to the processing of personal data on this legal basis. The Data Controller stores the personal data provided in digital format on a digital cloud server. The personal data thus provided will be processed for a period of 5 years from the date of their provision and until the explicit objection of the invited participant. The Controller will not transfer personal data processed in this context.

Access, Use and Transfer of Data

Only those persons shall have a right to access the personal data of the Data Subjects processed by Data Controller, who need it for the assertion of their rights. The name of the data controller, or other persons entitled to access the data, the purpose and date of the access shall be registered in a record.

It shall be considered use of data if the personal data are used as evidence in a court process or in other processes before an authority. The person whose rights or rightful interests are concerned by the storing of data, along with proving his/her right or rightful interest, may request within 3 (three) working days from the storing of his/her data, for the data to not be erased or destroyed by the Data Controller. Upon request from a court or other authority, the personal data shall be immediately sent to the requesting court or authority. If no official request arrives within 30 (thirty) days from the day of the request for the data to not be erased or destroyed, the stored picture and/or sound recording, and other personal data shall be erased or otherwise destroyed.

The Data Controller receives certain personal data from its contractual partners indirectly or transfers them to its Data Processor and its contractual partners (data transfer). In particular, information about a junior member of staff who applies for a junior position in a recruitment programme and information about the junior member of staff which is provided to the school association.  In this context, the Data Controller shall inform the applicant for the position about the data processing operations in a separate Privacy Notice. When transferring data to a third country or an international organisation, the Data Controller shall comply with Chapter V of the GDPR in order to ensure that the level of protection guaranteed to natural persons is not compromised in any way.

Data Breach

The Data Controller operates the electronic contact point compliance@maxwhere.com for the notification of any data protection breach related to the data processed by the Data Controller or the Data Processor..

The Data Controller guarantees that the contact details provided are kept under constant control.

The Processor shall, within 24 hours of becoming aware of a potential data breach, report it electronically to the Data Controller.

Investigate within 48 hours a notification of a data breach sent by the Data Processor or a notification of a data protection breach brought to their attention or suspected in its internal system and decide whether the potential breach poses a risk to the rights and freedoms of the data subject. .

If the investigation proves that no data protection breach has occurred, the Data Controller will inform the potential notifier and close the case.

In case you can demonstrate, in accordance with the principle of accountability, that the personal data breach is unlikely to pose a risk to the rights and freedoms of natural persons, you may choose not to notify the competent supervisory authority.

If the investigation proves that an infringement has occurred, the Data Controller shall:

a. notify the competent supervisory authority within 72 hours of becoming aware of the infringement

b. If the notification cannot be made within 72 hours, the Data Controller shall indicate in the notification made the reason for the delay and provide the required information in detail, without further undue delay.

c. If the investigation reveals that a high risk of a breach of the rights and freedoms of natural persons has occurred, the Data Controller shall inform the data subject of the personal data breach within 72 hours of becoming aware of it.

The Data Controller shall provide the data subject with clear and plain information about the nature of the personal data breach and the content of the mandatory notification to the supervisory authority, and shall provide information about the steps the data subject can take to protect himself or herself from the consequences of the breach. In any event, the information to the data subject will be sent by a separate message (e-mail, or, failing that, by post, or, failing that, by SMS).

It is not necessary to inform the data subject of a data breach if the Controller:

• implements appropriate technical and organisational protection measures and applies these measures to the data affected by the data breach;

• took additional measures following the data breach to ensure that the high risk to the rights and freedoms of the data subject is no longer likely to materialise;

• information would require a disproportionate effort . In such cases, the Data Controller will inform the data subject by means of publicly disclosed information (by publishing a notice on our website) or by taking similar measures to ensure that the data subject is informed in an equally effective manner.

Rights of Data Subjects and their assertion

Information about the Data Controller, the Data Processor, the processed data, the purpose of processing, the rights and the options for asserting of rights of data subjects, are provided for the data subjects in the Privacy Policy issued.

a) right of access ~ during the data processing, the data subject is entitled to access all data stored about him/her, and to be informed about the purpose, legal basis, storage and the duration of storage of his/her data. The right to information covers the rectification, erasure and restriction of processing concerning the processed data, and the option to file a complaint to the supervisory authority. Fulfilment of the request of the data subject to exercise his/her rights shall not be denied, unless it may be demonstrated that the data subject shall not be identified. For any further hard-copies requested by the data subject, we may charge a reasonable fee based on administrative costs.

b) right to rectification ~ the data subject is entitled to ask from the Data Controller to have any of the data subject’s data that may be incorrect or incomplete, rectified

c) right to erasure (”right to be forgotten”) ~ Erasing of the data by the Data Controller upon the request of the data subject, but this does not mean a general obligation for the Data Controller. The data subject is entitled to have his/her data to be erased (forgotten), where at least one of the following conditions applies:

(i). the personal data are no longer necessary in relation to the purposes for which they are collected or otherwise processed ;

(ii). the data subject has withdrawn his or her consent to the processing of personal data concerning him or her, and the data processing does not have other legal basis ;

(iii). the data subject objects to the processing of personal data concerning him/her, and there is no other prioritized reason for the data processing ;

(iv). the data processing was unlawful ;

(v). the data needs to be erased under applicable legislative duties of the Data Controller.

Following the termination of the legal basis for the data processing, including the case in which the data subject withdraws his/her consent to the processing of personal data, any personal data processed by the data controller shall be erased within a short period of time.

d) right to blocking of data ~ Instead of erasure, the Data Controller shall block the personal data upon the data subject’s request, if based on the available evidence it can be assumed that the erasure would infringe the rightful interests of the data subject.

Personal data blocked this way shall only be processed until the purpose prohibiting the erasure of the data, stands.

e) right to restriction of processing ~ if the accuracy, lawfulness, or necessity of processing concerning the personal data is contested by the data subject, or if the data subject objects to the processing of personal data, the data subject is entitled to obtain from the Data Controller restriction of processing, concerning his/her data.

f) right to obtain a copy of personal data ~ the data subject is entitled to obtain from the data controller a digital copy (pdf, doc, excel, txt) of the personal data undergoing processing, in order for the data to be provided to another data controller.

g) right to object ~ where personal data are processed for the exercise of rights of the controller or any third parties; and where personal data are processed or forwarded for direct marketing or statistical purposes, scientific or historical research, and in the cases and under the conditions provided for by law, the data subject is entitled to object at any time to the processing of personal data concerning him or her.

The objection shall be without delay, and no later than 15 days:

• examined,

• the objection’s merits be decided, and

• the objector be informed about the decision.

Data Security

The data shall be protected by adequate means especially against unauthorised access, modification, transfer, disclosure, erasure or destruction and accidental destruction or damage, and against inaccessibility resulting from the change of the technology used for access.

The Data Controller and the Data Processor shall consider the present state of technology at the time of taking actions regarding data security.

The Data Controller has drafted a data breach policy for data breaches, which contains the possibilities of reporting the data breach and the persons responsible for preventing data breaches, and also the relevant deadlines.

The Data Controller shall keep record of all data breaches.

Upon infringement of their rights, the data subjects may contact the Hungarian National Authority for Data Protection and Freedom of Information  (seat: 1055 Budapest, Falk Miksa 9-11.; telephone: +36 (1) 391-1400, fax: +36 (1) 394-1410, e-mail: ugyfelszolgalat@naih.hu) and they are also entitled to enforce their rights before the competent courts .

The Data Controller shall be obliged to repair any and all damages caused by unlawful data processing, or by the violation of the obligation regarding data security. In the event that the Data Controller violates the rights relating to personality of the Data Subject, the Data Subject shall be entitled to claim restitution.

The Data Controller may use any personal data lawfully processed in order to prevent legal disputes between the parties, and also during any meetings, hearings, and official proceedings as well.

About Cookies and how to use them

On the https://www.maxwhere.com/ content published in the public domain can be viewed without providing personal data .

The following so-called "cookies" are used on the websites and applications operated by the Data Controller:

• Necessary and functional cookies ~ used for basic functionality and to remember user preferences

This includes analytical cookies, such as the Google Analytics cookie, which collects and reports information from statistical data about the use of the Controller's website/application without individually identifying visitors to Google and which allow the Controller to measure the use and performance of its website/application and to improve its operation based on the data collected. Session cookie, which stores the visitor's location, browser language, payment currency. Its lifetime is the time the browser is closed or up to 2 hours. Mobile version, design cookie that detects the device used by the visitor and helps to facilitate transparency on mobile. Lifetime 365 days. Backend ID cookie, which is the ID of the backend server serving the site. Its lifetime lasts until the browser is closed.

• Third-party cookies ~ which measure and improve interactivity

Our website relies on third-party service providers, so you may find links or icons of these providers on our website.

Share buttons:

• Facebook

• Youtube

• LinkedIn

These websites also use cookies, information about which can be found on the relevant pages. The Data Controller does not control third party websites and is not responsible for the content of other external websites.

The data stored in cookies is processed to enhance the user experience and improve the online services of the website/application. Cookies used on the website/app do not store personally identifiable information.

The user can remove the cookies placed on his/her computer at any time during the visit of the website/application, or disable the use of cookies in his/her browser.

Please note that from time to time we may collect information about you from third parties or publicly available sources such as: business registers.

The Data Controller hereby informs its users (data subjects) that the cookies used on the lunk/application require the preliminary acceptance by the user (data subject) according to section (4) paragraph 155 of Act 100 of 2003 on electronic newsfeed. Therefore upon the first visit of the website, a pop-up window shall appear on the upper part of the monitor regarding the website’s use of cookies, and also a link shall appear which points to present policy. The user (data subject) may accept the use of cookies by clicking the “I accept” button. Exit #2 cookie: option #2 will automatically exit a user who has not logged out of their customer account after 90 days. It has a lifetime of 90 days.

In the event that You do not approve of the use of certain types of cookies, you have the option to set up your web browser in a way for it to disallow the use of unique identification data, or to notify you whenever a website is attempting to use cookies..

In case you wish to know more about these functions or wish to set your cookie preferences, please refer to the instructions or help-desk of your web browser, or you may also freely toggle the cookies of each service providers on the following link: http://www.youronlinechoices.com/hu/ad-choices

Effective from: 2023.05.05.

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