Privacy Policy - Brightly Kft.

Name:

Brightly Kommunikációs Ügynökség Korlátolt Felelősségű Társaság

Registered office:

H-2724 Újlengyel, Ady Endre utca 41., Hungary

Branch office:

H-1143 Budapest, Ilka utca 50., Hungary

Company Reg. No.:

Cg.13-09-140780

Mailing address:

H-1143 Budapest, Ilka utca 50., Hungary

E-mail cím:

brightly@brightly.hu

Telephone:

06-1-264-2090, 06-20-299-9031

Represented by:

Sándor Zakor Managing Director, Gábor Kulicz Managing Director and Anita Surányi Company Manager, independently

The Controller is not required to designate a data protection officer; however, this does not affect the fact that your personal data and your rights to the protection thereof are completely protected.

We process your personal data mainly for the following two purposes: firstly, the processing enables us to inform Clients contacting us in order to enter into an agreement about the contractual terms and conditions and to conclude a contract with them; secondly, it helps us enable the application of prospective new team members. The majority of data we process for contractual purposes pertain to companies, institutions and organisations and not private individuals, and such data do not constitute personal data under the applicable laws. We process the name, e-mail address and telephone number of the executive officers authorised to represent such entities, as well as the contact persons of the latter, as personal data. We extract such data from authentic public records and the sources you have submitted. When we enter into an agreement with companies, the provisions governing the processing and protection of personal data are specified separately; such agreements are not concluded directly via the website.

Given the nature of the specific provisions of processing involving the application of prospective employees, we have created a separate policy governing the latter. Please read this under the “Work with us” menu item. Should you find anything unacceptable in this document, please do not send us your application or CV. If you submit your documents, despite our utmost efforts and diligence, wemust assume that you have read and accepted its content.

Due to online access, IP addresses and browsing data (operating system, browser application) are processed. You can find more detailed information about this in Section 12 (“Cookies”). We limit the scope of our processing activities to personal data that are strictly necessary for the provision of the services. Pursuant to the laws, processing of the managing director’s name is essential, given that we must verify whether an individual is authorised to act on behalf of a company, as companies are unable to make any statements directly themselves, only via their representatives. The e-mail address is also essential for contact purposes; please note that if such data is available, we prefer to use an e-mail that does not contain names or other personal details. When we implement campaigns and marketing activities as agents, we will provide separate information about the terms governing each processing activity involved.

The legal basis for processing: performance of a contract; compliance with obligations laid down by law; furthermore, in respect of cookies (Section 12), the consent of the Data Subject and the legitimate interest. Performance of a contract: If you enter into an agreement with us, you purchase a service offered by us, which we will be able to realise if you submit the above data; even if you contact us to indicate your intent to enter into an agreement with us, since we need to be aware of such data to be able to provide you adequate information about the service. Furthermore, pursuant to Section 13/A of Act CVIII of 2001 on Certain Issues of Electronic Commerce Activities and Information Society Services, the service provider - i.e. our company in this case - shall be entitled to process, for the purposes of providing the services, personal data technically strictly necessary for the provision of such services. The data specified in Section 3 qualify as such.

Consent of the Data Subject: Cookies are required for the use of the website. Refusing to accept such cookies will prevent you from using some functions of the website and its operation will also be limited. You must also expressly consent to our policy governing job applications prior to submitting any such application to us; you will be able to voluntarily apply for any position thereafter, following receipt of sufficient information.

Legitimate interest: Using cookies required for the operation of the website shall constitute processing based on legitimate interest. Please note that, pursuant to Preamble (47) of the GDPR, the processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest, by taking account of the present Privacy Policy. Gathering and processing information for such direct marketing purposes, however, do not take place via the website; for example, there is no contact form. Based on an interest balancing test completed in respect of such cookies, we have established that such cookies are compliant with the legal terms and conditions governing processing. Cookies are strictly necessary for the operation of the Controller’s website in terms of functionality and security, and restrict or affect the rights of Data Subjects less significantly; they can be disabled, and are restricted to the processing of the least data required for the shortest time necessary; therefore, the legitimate interests of the Controller override the Data Subjects’ right of informational self-determination. Personal data processed for such purposes and on such legal basis shall not be used for other purposes, and may be disclosed to third parties (such as the operator or the police) to the extent required for such purposes.

Obligations laid down by law: If we issue an invoice to a private individual, we are required by law to process the personal data indicated therein.

Personal data are processed by the Controller, its managing director(s) and administrative staff member(s). Personal data indicated on invoices are disclosed to the accounting firm, P-Menedzsment Holding Kft. (H-1143 Budapest, Ilka utca 50, Hungary) and are also shared with the Tax Authority, to enable us to comply with our tax return submission and data reporting obligations under the laws. Invoicing is carried out using the billing application of “Revolution Iroda” on a server and not online basis (the owner of the server is Gbart Solutions Kft., H-1029 Budapest, Zsíroshegyi út 16, Hungary; tax number: 25194188-2-41, EU VAT number: HU 25194188; company registration number: 01-09-205300; in the capacity of a processor carrying out solely data hosting services), by using our own billing module; i.e. the foregoing entities do not process personal data, invoices are issued by the Controller, and are transmitted to the Tax Authority in accordance with the legal requirements. The website is managed and operated by the Controller. The Controller has its own repository, where the data of the website are recorded.

The Controller does not transfer any personal data abroad.

Pursuant to the Accounting Act, we are obliged to process data required for invoicing (name, address, tax identification number, invoice number and amount) for a period of 8 years. Other data specified in Section 3 are processed for 1 year following termination of our contractual relationship.

You shall have the right to request information concerning the processing, such as on your personal data being processed and the scope of recipients to whom they are transferred; you shall have the right of access, so you can verify whether we process your data, and if so, what kind of data, for what purposes and duration; and you may also learn about your relevant rights and where you may lodge a complaint. You shall also have the right to request the correction or rectification of your personal data if such data are not completely correct. Other than mandatory processing, you may also request that your personal data be erased or blocked, if such processing is unlawful, the purpose thereof no longer exists, you withdraw your consent to the processing of your personal data, the data processed is incorrect or incomplete, and this cannot be lawfully rectified, or a court or the National Authority for Data Protection and Freedom of Information (“NAIH”) has issued an order to that effect. You shall also have the right to be forgotten, i.e. we shall make every effort possible at the current state of the art to make sure that any data you requested to be erased be deleted from everywhere. Please note that if the legal basis of processing is your consent, you may revoke such consent any time; however, the withdrawal of your consent shall not affect data that has been lawfully collected prior to such withdrawal or any data processed pursuant to mandatory legal provisions; furthermore, we shall be entitled to continue the processing of your personal data for the purposes of pursuing our legitimate interests, for example, in proceedings aiming at the collection of overdue invoices, as well as in connection with our tax return submission or data reporting obligations, or in procedures involving the unauthorised use of works of rightsholders represented by us. You may also object to the processing of your personal data if you do not agree with the perceived manner in which personal data are processed by us. If processing or the transfer of personal data is solely necessary for compliance with a legal obligation to which we are subject or for enforcing our or third parties’ legitimate interests, or if personal data are used or transferred for the purposes of direct marketing, public opinion polling or scientific research, and provided that your objection is legitimate, we shall erase such personal data, unless you choose the blocking of data or the restriction of processing instead of deletion. Processing shall also be restricted if you contest the accuracy of the personal data - for a period permitting us to verify such inaccuracy - or we no longer need such data, but you require them for the exercise of your legal claims, for instance.

If you consider that you have suffered any harm in the course of the processing of your personal data, please notify us immediately, and we shall immediately, and at the latest within 30 days, take action to remedy such infringement. If you consider that the measures taken by us are insufficient, please note that you may seek judicial remedy for the protection of your rights (such matters fall within the competence of the courts with jurisdiction over your place of residence, i.e. Regional Courts), or, alternatively, you may also lodge your complaint at the National Authority for Data Protection and Freedom of Information (H-1055 Budapest, Falk Miksa utca 9–11, Hungary, 06-1-391-1400, ugyfelszolgalat@naih.hu, www.naih.hu). Please note that you have 30 days to seek legal remedy from a court or authority from the date we made and communicated our decision concerning your complaint or objection, or we failed to give you a timely response. You may also choose to lodge your complaint directly with an authority or seek judicial remedy without contacting us first.

Personal data:

means any information pertaining to an identified or identifiable natural person (“Data Subject”)

Sensitive data:

means personal data revealing nationality or racial origin, political opinions or any affiliation with political parties, religious or philosophical beliefs or trade-union membership, and personal data concerning health, pathological addictions, sex life or criminal record

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

Processor:

means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller (i.e. technical operations)

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, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, etc.

Technical processing:

means the technical tasks carried out in respect of the data processing operations

We and our partners specified in Section 5 all do our utmost to keep your personal data safe and secure. To that end, we use IT equipment to protect such data, we make backup copies and immediately notify you of any occurrence of personal data breach.

Cookies are text files placed by a web server on a terminal device (typically a computer or mobile phone) of the website’s visitors that store information about the user, the operation of the website, or even any link between the user and such web server. When a web page is loaded, the web server often uses such information to improve user experience or offer certain services. We do not use cookies that process personal data.

Submissions of applications to our open positions are available under the “Work with us” menu item on our website, www.brightly.hu. The provisions governing the processing activities involving job applications are laid down in a separate document entitled “Privacy Policy Governing Job Applications” (Hungarian title: “Tájékoztatás álláspályázatok adatkezeléséről”). Please ensure that you read, acknowledge and agree to such policy prior to submitting your application.