Privacy statement

NetAcademia Oktatóközpont Kft.
 

Privacy Policy

http://netacademia.hu/

 

Effective as of: June 2017

 

This privacy policy sets forth how NetAcademia Oktatóközpont Kft. (hereinafter referred to as: “NetAcademia”) as data manager manages and protects such information as is provided to NetAcademia by the person participating in the training (hereinafter referred to as: “Client”).

Data manager

NetAcademia Oktatóközpont Korlátolt Felelősségű Társaság
Registered seat: 1074 Budapest, Rákóczi str. 70-72. T3 tower 1st floor
Telephone number: +36 21 200 6960

E-mail address: iroda@netacademia.net
http://netacademia.hu/

Legal basis for managing data

Netacademia manages the personal data of its Clients in accordance with the provisions set out in Act CXII of 2011 on Informational Self-Determination and Freedom of Information ("Information Act") and in 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) and it is committed to the protection of the personal data of its Clients and deems it as definitely essential to respect the users’ rights to informational self-determination.

Other key statutory regulations considered in preparing this Information:

  • Act CXIX of 1995 on the Use of Name and Address Information Serving the Purposes of Research and Direct Marketing;
  • Act CVIII of 2001 on certain issues of electronic commerce services and information society services.

Basic terms of data management

personal data:  means any information relating to an identified or identifiable natural person (‘data subject’) and any conclusion that can be deducted from the data in respect of the data subject. Personal data retain their nature in the course of data management as long as their link to the data subject can be restored. A person can be regarded as identifiable directly or indirectly in particular by reference to an identifier such as a name, an identification number, an online identifier or to one or more factors specific to the physical, physiological, mental, economic, cultural or social identity of that natural person;

sensitive information:

a) refers to racial origin, nationality and ethnic minority, political opinion or party preference, religious or other ideological conviction, membership in interest representing organisations,

b) to state of health, subnormal passion, sexual life and personal criminal records;

consent: means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to such processing of personal data relating to him or her as is either complete or extends to certain transactions;

protest: means a statement by the data subject objecting to the management of his or her personal and asking for  the discontinuati9on of data management and the deletion of the data managed;

data manager: is a natural or legal person or an organisation without legal entity who or which determines the purposes of the processing of personal data, makes the decisions on and implements data management (including the means thereof) or has it implemented by the retained data processor;

data management: any operation or the totality of operations performed with the data irrespective of the process applied, such as gathering, taking, entering, sorting, storing, altering, using, forwarding, publishing, harmonizing or connecting, locking, deleting or destruction as well as prevention of data from further use. Data management is understood to mean the making of photo, audio or video records as well as the recording of such physical characteristics as are suitable for identifying a person (e.g. fingerprint, palm print, DNA sample, iris image);

data forwarding: means that the data is made accessible to a specific third person;

publishing: means that the data is made accessible to anyone;

deletion of data: rendering data unrecognizable so that they cannot be retrieved anymore;

data locking: making it impossible permanently or for a specific period of time to forward, learn, publish, alter, change, destroy, delete, connect, harmonize and use the data;

data destruction: means the complete physical destruction of the data or the respective data carrier;

data processing: means the performance of technical tasks linked with the data processing operations regardless of the methods and means used to carry out the operations and of the place of its application;

data processor: is a natural or legal person or an organisation without legal entity who or which performs the processing of personal data on behalf of the data manager;

third person: is a natural or legal person or an organisation without legal entity who or which is not identical to the data subject, the data manager or the data processor;

third country: means any and all countries that are not members of the European Economic Area.

The purpose of data management

NetAcademia shall not manage personal data but of such natural persons as become its clients by attending its training courses.

Data are managed by NetAcademia for the following purposes:

·         to make out documents required for the conclusion and fulfilment of the Contract, to make out invoices,

·         to liaise with client during the course, to allow for corrections and appraisals by the teacher, to return homeworks and to make out certificates,

·         to fulfil other contractual obligations of NetAcademia,

·         to inform Client, subject to his or her consent, directly of additional training courses and services,

·         - subject to Client’s consent -  to facilitate communication between clients via the website of NetAcademia,

·         to assert the rights of NetAcademia in case of breach of contract by client,

·         to assess and analyze the markets, customers. products and services of NetAcademia,

·         to communicate with clients in relation to the above.

An additional purpose of data management is to have the students of NetAcademia contact each other via the website in order to share with each other the contents specified by them (images, videos, comments).

Data management in its every phase complies with the purpose of data management.

Principles for data management

In managing and processing automatically the personal data of Clients NetAcademia as data manager shall be attentive to the following requirements:

·         NetAcademia shall obtain and manage the personal data in a fair and legitimate way,

·         NetAcademia shall store and manage the data only for specified and legitimate purposes and shall not use them in any different way,

·         NetAcademia shall not manage but such data as are indispensable for achieving the purpose of data management and are suitable for achieving the objective specified,

·         Personal data shall not be managed by NetAcademia but to the extent and as long as it is necessary for the realization of the particular goal,

·         NetAcademia shall take appropriate safety and security measures to protect the personal data stored in the data files and to prevent them from being accessed, changed, forwarded, published, deleted or destroyed as well as from unintentional destruction or damage, furthermore from any inaccessibility due to changes in the technology applied,

·         In the course of managing data, NetAcademia shall ensure the accuracy, completeness of the data as well as that client can be identified only as long as it is necessary for the purpose of data management.

Scope of the data managed

The scope of personal data managed by NetAcademia includes such data as can be linked to client or can reveal the identity of client. including client’s name, residential address, e-mail address, telephone number, mother’s name, date of birth and the name at birth and the deductions based on the data and relating to client. This nature is retained by the personal data as long as its connection with client can be restored.

Scope of personal data managed by NetAcademia:

  • First name and last name
  • Corporate name (optional)
  • Area of expertise
  • Delivery address
  • Billing address
  • E-mail address
  • Telephone number
  • Fax

NetAcademia precludes any responsibility in respect of any unauthorized data management performed by its Clients.

Source of data

The personal data of its Clients are obtained by NetAcademia in various ways and from different sources, in particular, client provides NetAcademia with data when it concludes the contract. Information relating to Client may be managed by NetAcademia together and linked, for the above indicated purposes of use, with such data on client as are brought to the knowledge of NetAcademia in a different way.

Term of data management

NetAcademia shall have the right to manage client’s personal data during their legal relationship and, in case client is delayed in paying, NetAcademia shall have the right to manage and process the data as long as the debt toward NetAcademia is not settled.

Legal base for data management

By becoming familiar with and agreeing to this Privacy Policy, pursuant to preliminary and detailed information, client gives voluntary, unambiguous and definite consent for  NetAcademia and the data processors below to manage such personal data as relate to him or her.

By becoming familiar with and agreeing to this Privacy Policy, client gives voluntary and definite consent for  NetAcademia to record on the website a part of such personal data as relate to him or her (name, the course taken by client, country)e.

The data may be managed by NetAcademia without specific consent and even after the withdrawal of Client’s consent, to fulfil its relevant legal obligations or to assert the rightful interests of NetAcademia or a third person provided that the assertion of such interests shall be proportionate with the limitation of the right to the protection of personal data.

Persons performing data management

The right to manage and process data and to become familiar with the data shall lie exclusively with NetAcademia and its employees, institution partners and their staff and with the affiliated companies of NetAcademia and their legal successors for the purposes and to the extent specified above.

The persons involved in data management by NetAcademia shall be liable to treat confidentially any data that they have become familiar with.

Data processing

The rights and obligations of data processors with regard to the processing of personal data shall be determined by NetAcademia within the limits of the law. Responsibility for the lawfulness of its instructions shall lie with NetAcademia. No decision in merit shall be made by data processors in relation to data management and they shall not process the personal data brought to their knowledge but according to the provisions  Data processors shall not make decisions in merit with regard to data management and they shall not process the data brought to their knowledge but according to the dispositions of NetAcademia and they shall not process data for their own purposes, furthermore they shall store and keep the personal data according to the dispositions of the data manager.

Data forwarding

In the event Client fails to fulfilment his or her payment obligation to NetAcademia and NetAcademia employs a debt collecting firm or legal representative to collect the debt, it shall have the right to forward to them client’s data. The debt collecting firm or  legal representative shall manage client’s data pursuant to the mandate from NetAcademia for the purpose of collecting the claims of NetAcademia and such claims (e.g. administrative fees, legal expenses, etc) as are incurred by the debt collecting firm in connection with the collection whether payable to NetAcademia or the debt collecting firm till the expiration of the administration term stipulated in the agreement between NetAcademia and the debt collecting firm, that is for 90 says as a general rule or till the successful collection of the claim within this period. The debt collecting firm or the legal representative may manage the forwarded data also to assert claims in litigation, tort and in proceedings other than litigation. The forwarded data may be disclosed to the staff of the debt collecting firm and the legal representative. Client gives his or her consent to the collection by the debt collecting firm or the legal representative of further data in addition to the data already provided on client in order to collect the claim (e.g. to record Client’s new address or telephone number included in the public telephone directory). NetAcademia shall have the right to forward Client’s data to firms providing book-keeping and auditing services for NetAcademia and to the debt collecting firms or to the legal representative and also in every case where mandatory data supply is required by law for the authorities designated in law.


To check the lawfulness of data forwarding and to inform Client, NetAcademia keeps records that include the date of forwarding of the data managed, the legal base and the address of data forwarding, the definition of the scope of the personal data forwarded as well as other information specified in the law on data management. Data in the records on data forwarding shall be kept for 5 years in respect of personal data and for 20 in respect of sensitive information.

 

Sending newsletters and direct marketing

Subject to consent by Client, NetAcademia will inform Client directly about the products, services, promotions and special offers of NetAcademia and about everything that – in the opinion of NetAcademia –may be of interest to Client (direct marketing).

Consent by Client will be requested by NetAcademia by way of checking the respective “consent” box.

Such information will be sent to Client by NetAcademia in various ways, in particular by e-mail and by post.

Client may opt out from the newsletters as described in the newsletter. Newsletters may contain advertisements.

Client may bring it to the knowledge of NetAcademia, freely, without limitations or explanation if he or she does not wish that the data managed be used by NetAcademia or by a third party for direct marketing purposes.

information

Client has the right to request information about the management of his or her personal data and to request the correction, deletion or locking of his or her personal data.

To the request submitted by Client in any form NetAcademia shall provide written, articulate information within 30 days of the data managed and processed in relation to the data subject and about the purpose, legal bases, duration of data management as well as of the name, address and the operations relating to data management of the data processor, furthermore – where client’s personal data are forwarded – of the legal base and recipient of data forwarding. In case of recorded telephone conversations NetAcademia– in addition to the above and at Client’s request– shall provide Client with the voice record of such telephone conversation. NetAcademia shall provide the information and voice recordings under this clause in writing and in articulated form within the shortest time possible but not later than 30 days after the submission of the request. The information will be free of charge in the event the person requesting the information has not submitted to the data manager any prior request for information on the same scope of data in the current year. Otherwise, the compensation shall amount to HUF 2.000, - for each instance of information.

Information to Client shall not be denied but in cases specified by law and with appropriate reference to the specific provision of the statutory regulation. Where information is denied, the data subject shall be informed of the options available such as legal remedy via court proceedings and the application to Hungarian National Authority for Data Protection and Freedom of Information.

 

Rights of data subject

Should any personal data about the data subject be not genuine, the data subject will be entitled to request the correction of his or her data commensurate with reality.

Commensurate with the applicable statutory regulations, Client may protest against the management of his or her personal data if it does not comply with the law. The personal data managed shall be deleted if the managing thereof is against the law or if the deletion is requested by the data subject or the purpose of data management does not exist anymore; if it is incomplete or wrong, furthermore in case it is so ordered by Hungarian National Authority for Data Protection and Freedom of Information or a court. 

Personal data shall be locked rather than deleted if so requested by the data subject or it the information available gives rise to the assumption that the rightful interests of the data subject would be infringed upon by deletion. Personal data locked in this way shall not be managed but as long as such purpose of data management exists as precludes the deletion of the personal data.

Notification about correction, locking and deletion shall be given to the data subject and everyone to whom the data was forwarded before for the purpose of data management. (Such notification may be Notification may be omitted if it will not infringe upon the rightful interests of the data subject with regard to the purpose of data management.) In the event it is not possible to honour the data subject’s request for correction, locking or deletion, the data subject shall be informed in writing within 30 days about the rejection and the factual and legal reasons for the rejection of the correction, locking or deletion. In such an event the data subject shall be informed of the options available for legal remedy or applying to the Authority.

Assertion of rights

We request our Clients to be as kind as to contact us to remedy any infringement if they feel their rights to protect their personal data have been infringed upon by the Data manager.

NetAcademia Oktatóközpont Korlátolt Felelősségű Társaság
Registered seat: 1074 Budapest, Rákóczi str. 70-72. T3 tower 1st floor
Telephone number: +36 21 200 6960

E-mail address: iroda@netacademia.net
http://netacademia.hu/

We are advising the persons concerned that they may assert their claim in civil proceedings, too, or may apply for help to Hungarian National Authority for Data Protection and Freedom of Information (NAIH): http://www.naih.hu/kapcsolat.html

Civil disputes, if any, shall be governed by Hungarian law.

 

The term of the Privacy Policy

This policy will enter into force as of the day it is published and shall remain in force for an indefinite period of time. The data manager shall have the right to amend this policy unilaterally at any time. Such amended privacy policy shall be effective also as of the day it is published.

The data manager shall apply this policy as of its effective date to the management of data existing prior to the effective date.

The provisions set forth in this policy and such requirements in respect of which this policy does not contain any specific provisions, shall be applied by adhering simultaneously to the provisions set forth in the statutory regulations on data protection, applicable at any one time, in particular, to those set forth in Act CXII of 2011 on Informational Self-Determination and Freedom of Information ("Information Act").