Privacy Policy


1. Purpose of the Privacy Policy

 

The goal of our Privacy Policy is to provide all necessary information about processing your personal data in a concise, transparent, intelligible and easily accessible form, using clear and plain language, and assist the Data subjects in exercising their rights under Section 4.

The legal basis of our duty to communicate information is Article 12 of Regulation 2016/679 of the European Parliament and Council (hereinafter referred to as: GDPR) and the relevant Hungarian data protection regulations.

In the Privacy Policy, we may define you as “data subject”, or “contact person of our business partners” in the following.

You may find further definitions concerning your personal data within the Appendix of the current Privacy Policy

 

2. Data of the controller

 

Name

iScaleIT Solutions Kft.

Registry number

06-09-024190

Registered seat

6726 Szeged, Kőrösmező utca 39. HUNGARY

E-mail

info@iscaleit.com

Tax number

26269997-2-06

   

3. Data processing concerning contacting and communication

 

It is possible to connect us through our availabilities located on the website. Also, by communicating with our business partners, we process the personal data of their contact person. The details of these processing are described hereunder.

3.1.1. Processed personal data and purpose of processing

 

personal data

purpose of processing

name

identification of the Data subject, or the contact person of our business partner

phone number

contacting and communication with the Data subject, or the contact person of our business partner

e-mail address

contacting and communication with the Data subject, or the contact person of our business partner

 

3.1.2. Legal basis of processing

 

If you contact us through our website, we process your personal data on your freely given consent that you provide in the moment of your connection by phone or email (article 6 (1) a) of GDPR).

If you, as the representative of our business partners provide your personal data to communicate with us, the legal basis of processing personal data is the legitimate interest of us and our business partners (section 6 paragraph 1 point f of GDPR). It is each Party’s legitimate interest to maintain an effective business communication and to perform the contract. Since it is the part of your scope of duty (representation of our business partners), in our view, processing your name and contact data doesn’t restrict disproportionately your privacy and freedom of self-determination.

 

3.1.3. Duration of the processing

 

If you contact us through our website, we process your personal data until the withdrawal of your consent. You have the right to withdraw your consent at any time via email. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

 

In relation to the processing of the personal data of our business partners’ contact persons, we process their personal data until the personal data are no longer necessary in relation to the purposes for which they were collected or as long as it is possible according to the relevant acts (pursuant to the Hungarian Civil Code, 5 years following the performance or the termination of the contract, or 8 years following invoicing, in accordance with the Hungarian accounting act).

 

3.1.4. Mode of processing

 

Your personal data are collected manually, in electronic form.

 

3.1.5. Data protection contractual clause

 

Taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for rights and freedoms of natural persons posed by the processing concerning communicating with our business partners, we, as data controllers, while performing the contracts concluded with our business partners, both at the time of the determination of the means for processing, and at the time of the processing itself, implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing in order to meet the requirements of GDPR.

 

3.2. Processing concerning newsletter

 

In order to provide relevant information to you, it is possible to subscribe our newsletter both in the registration form and on our website’s specific surface serving for this purpose. The details of such processing are described hereunder.

 

3.2.1. Processed personal data and purpose of processing

personal data

purpose of processing

name

to address the user

e-mail address

connecting the user by newsletter

phone number

sending text messages to you on your request

 

3.2.2. Legal basis of processing

Your consent (article 6 point (1) a of GDPR).

 

3.2.3. Duration of processing

We process the personal data until the withdrawal of your consent. You can anytime unsubscribe our newsletter by clicking the “Unsubscribe” box.

 

3.2.4. Mode of processing

Personal data are collected automatically and manually, in electronic form.

3.3. Processing concerning customer service

 

In order to answer your questions or to inspect the circumstances you requested a complaint for, we operate customer service.

 

3.3.1. Processed personal data and purpose of processing

personal data

purpose of processing

name

identification of the user

e-mail address

connecting with the user and providing information

phone number

connecting with the user and providing information

3.3.2. Legal basis of processing

We process the personal data we collect from you by legal obligations (article 6 point (1) c) of GDPR).

 

3.3.3. Duration of processing

We process your personal data as long as the relevant consumer protection acts determine it.

 

3.3.4. Mode of processing

Personal data are collected automatically and manually, in electronic and paper form.

3.4. Processing concerning invoicing

 

After the performing of the orders we – with regard to Act C of 2000 on accounting – make out a bill. The details of such processing are described hereunder.

 

3.4.1. Processed personal data and purpose of processing

 

 

personal data

purpose of processing

name

confirmation of the accounting

address 

confirmation of the accounting

 

3.4.2. Legal basis of processing

 

Processing is necessary for compliance with a legal obligation; with regard to section 6 paragraph 1 point f of GDPR, section 5 article 1 point b of Information Act and section 166 paragraph 1 to 3 of Act C of 2000.

 

3.4.3. Duration of the processing

 

8 years after accounting.

 

 

3.4.4. Mode of processing

 

Personal data are collected manually, in electronic form.

 

3.4.5. Provision of processing

 

Since we cannot perform our accounting obligations without knowing any information about you, the processing is a statutory requirement.

4. What are your rights?

 

4.1. Right to access

You have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the information featured in point 3.

You have the right to access to the following information concerning the processing of your personal data:

  • 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 organizations;

 

  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

 

  • the existence of the right to request from us rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing;

 

  • the right to lodge a complaint with a supervisory authority;

 

  • the existence of automated decision-making, including profiling, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

 

4.2. Right to rectification

You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

 

4.3. Right to erasure

You have the right to obtain from us the erasure of personal data concerning you without undue delay and we shall have the obligation to erase personal data without undue delay if it is mandatory according to Article 17 of GDPR. The erasure of your personal data is obligatory for us in the following instances:

 

  • the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

 

  • you withdraw consent on which the processing is based, and where there is no other legal ground for the processing;
  • you object 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.

 

4.4. Right to be forgotten

If we made the personal data public and are obliged to erase your personal data, we inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

We do not make your personal data public.

 

4.5. Right to restriction of processing

You have the right to obtain from us restriction of processing if is obligatory according to Article 18 of GDPR. Such instances are the following:

 

  • the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;

 

  • the processing is unlawful and you oppose the erasure of the personal data and requests the restriction of their use instead;

 

  • we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims;

 

If you obtain restriction of processing in accordance with the above, we inform you before the restriction of processing is lifted.

 

4.6. Right to data portability

You have the right to receive the personal data concerning you, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us if is possible according to Article 20 of GDPR. Where technically feasible, you have the right to have the personal data transmitted directly from us to another controller.

 

4.7. Right to object

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (f) of Article 6(1) of GDPR (see: point 3.2. of the current policy). In such case, we no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

 

4.8. Right to lodge complaint

You have the right to appeal to the Austrian and Hungarian courts and to make a complaint to the Austrian (https://www.data-protection-authority.gv.at/) and the Hungarian (https://naih.hu/) Supervisory Authority.

 

5. Measures and notification

 

5.1. Informing Data subjects

We communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1) and Article 18 of GDPR to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. We also inform you about those recipients on the request of yours.

 

5.2. Mode and deadline of notification

We provide information on action taken on a request under Articles 15 to 22 of GDPR to you without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We inform you of any such extension within one month of receipt of the request, together with the reasons for the delay. Where you make the request by electronic form means, we provided the information by electronic means where possible, unless you request it otherwise.

If we do not take action on your request, we inform you without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy (see point 4.7.).

 

5.3. Monitoring

If we have reasonable doubts concerning the identity of the natural person making the request, we may request the provision of additional information necessary to confirm the identity of the data subject.

 

5.4. Costs of measures and notifications

We provide you information and take the necessary measures free of charge. 

If your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested or we refuse to act on your request.

 

6. Possible recipients

 

6.1. During the operation of our website

 

Our website’s hosting provider (data processor) can have access to the personal data you provide while using the website. The data processor’s data are the following:

 

Name: Jimdo GmbH

Address: Stresemannstr. 375 22761 Hamburg, Germany

E-mail: info@jimdo.com

Website: www.jimdo.com

Tel.: +49 40 - 8 22 44 997

Fax: +49 40 - 8 22 44 998

6.4. Social media

Our website has several social media profile so that if you „like” us on Facebook or „follow” us on Instagram, we may learn all the personal data which is public on your profile.  

7. Other provisions

 

7.1. Processing for different purpose

If we intend to further process the personal data for a purpose other than that for which the personal data were collected, we provide the you prior to that further processing with information on that other purpose and with any relevant further information.

 

7.2. Data protection

We secure your personal information from unauthorized access, use or disclosure. We secure the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When personal information (such as connection data) is transmitted to other Web sites, it is protected through the use of encryption.

 

7.3. Record of processing

To comply with section 30 of GDPR, we maintain a record of processing activities under our responsibility.

 

7.4. Data breaches

Data breach is 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. In case of data breach, we act according to section 33 and 34 of GDPR.

 

7.5. Changes to our Privacy Policy

We will occasionally update this Privacy Policy to reflect feedback. We encourage you to periodically review this Policy to be informed of how we are protecting your information.

Effective: 1st June 2018

 

iScaleIT Solutions Kft.

 

Appendix - Definitions

 

  • ‘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, 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;

 

  • ‘processing’ means 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;

 

  • ‘restriction of processing’ means the marking of stored personal data with the aim of limiting their processing in the future;

 

  • ‘pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;

 

  • ‘filing system’ means any structured set of personal data which are accessible according to specific criteria, whether centralized, decentralized or dispersed on a functional or geographical basis;

 

  • ‘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; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

 

  • ‘processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

 

  • ‘recipient’ means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;

 

  • ‘third party’ means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data;

 

  • ‘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;

 

  • ‘data concerning health’ means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status;

 

  • ‘enterprise’ means a natural or legal person engaged in an economic activity, irrespective of its legal form, including partnerships or associations regularly engaged in an economic activity;

 

  • group of undertakings’ means a controlling undertaking and its controlled undertakings;

 

  • ‘supervisory authority’ means an independent public authority which is established by a Member State pursuant to Article 51;

 

  • ‘supervisory authority concerned’ means a supervisory authority which is concerned by the processing of personal data because:

 

  • ‘relevant and reasoned objection’ means an objection to a draft decision as to whether there is an infringement of this Regulation, or whether envisaged action in relation to the controller or processor complies with this Regulation, which clearly demonstrates the significance of the risks posed by the draft decision as regards the fundamental rights and freedoms of data subjects and, where applicable, the free flow of personal data within the Union;


Important note concerning data processing in connection with Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Ireland Limited. If the responsible body for the data processing that occurs via this website has their basis outside of the European Economic area and Switzerland, then the associated Google Analytics data processing is carried out by Google LLC. Google Ireland Limited and Google LLC. will hereinafter be referred to as “Google”.

Google Analytics uses “cookies”, which are text files saved on the site visitor’s computer, to help the website analyze their use of the site. The information generated by the cookie (including the truncated IP address) about the use of the website will normally be transmitted to and stored by Google.

Google Analytics is used exclusively with the extension "_anonymizeIp ()" on this website. This extension ensures an anonymization of the IP address by truncation and excludes a direct personal reference. Via this extension Google truncates the site visitor’s IP address within member states of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional situations will the site visitor’s full IP address be transmitted to Google servers in the United States and truncated there. The IP address, that is provided by the site visitor’s browser in using Google Analytics will not be merged by Google with other data from Google.

On behalf of the site operator, Google will use the information collected to evaluate the use of the website, to compile reports on website activity and to provide other website and internet related services to the site operator (Art. 6 (1)( f) GDPR). The legitimate interest in data processing lies in the optimization of this website, the analysis of the use of the website and the adaptation of the content. The interests of the users are adequately protected by the pseudonymization of their data.

Google LLC. offers a guarantee to maintain an adequate level of data protection on the basis of European standard contractual clauses. The data sent and linked to the Google Analytics cookies, e.g. user IDs or advertising IDs will be automatically deleted after 50 months. The deletion of data whose retention period has been reached is carried out automatically once a month.

The website visitor may refuse the use of cookies by selecting the appropriate settings in their browser. The website visitor can also prevent Google from collecting information (including their IP address) via cookies and processing this information by downloading this browser plugin and installing it: http://tools.google.com/dlpage/gaoptout

The website visitor can prevent data collection via Google Analytics on this website by clicking here. An "Opt-out Cookie" shall then be applied which shall prevent any future collection of the site visitors data when visiting this website.

Further information concerning data processing and use by Google, the settings and deactivation possibilities can be found in the Google Privacy Policy (https://policies.google.com/privacy) as well as in the Google Ads Settings (https://adssettings.google.com/authenticated).