THE PURPOSE OF THE INFORMATION
The purpose of this privacy notice is to set out the data protection and data management principles applied on the https://dna.hu website and related social networking sites (hereinafter referred to as "websites") and to inform readers in an easily understandable way.
We use cookies on our website to help us operate and facilitate the use of the website, to track activity on the website and to display relevant offers.
NAME AND CONTACT DETAILS OF THE CONTROLLER
Name: Digital Network Agency Kft.
Located at: 1031 Budapest, Zaránd Utca 18.
Company registration number: 01-09-344355
E-mail: hello@dna.hu
LEGAL BASIS AND PURPOSE OF PROCESSING
The legal basis for the processing of data is the voluntary consent of the data subject to subscribe to the newsletter and to order and participate in prize draws, pursuant to Article 6 (1) (a) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the right to information (hereinafter: GDPR), applicable from 25 May 2018, and pursuant to Article 5 (1) (a) of Act CXII of 2011 on the right to information self-determination and freedom of information (hereinafter: Info Act).
The legal basis for the processing of data in the framework of the Online Content Service is the provision of the fundamental rights to information and expression of opinion within the framework of the law.
Purpose of the processing:
- content delivery
- identification of the User, communication with the User;
- Providing the services available through https://dna.hu
- Display of personalised content and advertisements, statistics
- Direct marketing or solicitation (e.g. newsletter)
- Providing hosting for the publication of user-generated content (e.g. comments, chat, blog, forum, etc.);
- In specific cases, organising and running prize draws, contacting the winners and providing them with their prizes;
- In the case of distribution of a newspaper, creating a contract between the parties, defining its content, amending it, monitoring its performance, delivering the ordered product or service, invoicing the purchase price and enforcing the related claims, documenting the adequacy of performance, fulfilling accounting obligations;
For the purposes of this notice, a User is a person who uses the media content service (i.e. accesses the website or application), subscribes to the www.dna.hu newsletters, participates in any prize draws announced on www.dna.hu or contacts the Data Controller (hereinafter referred to as the User) on the www.dna.hu website and mobile or tablet application.
THE SCOPE OF THE PERSONAL DATA PROCESSED
When you visit the website, our system automatically records your IP address for security and legal security reasons.
If the User sends a message to us (e.g. e-mail, reader mail), we will process the User's address and e-mail address to the extent and for the duration necessary to provide the service.
We do not record or store personal data in the case of telephone enquiries.
In the context of any prize draws that may be organised, we process the following Personal Data: name, date of birth, address, e-mail, telephone number, occupation, personal data indicated in the advertisement of the prize draw
We also process personal data for the purpose of subscribing to our newsletter service, to which our readers can subscribe on our website. To subscribe to our newsletter, you must provide your name and e-mail address.
HOW TO SUBSCRIBE
- by ticking the checkbox, the subscriber confirms that he/she has read the privacy policy available on the link;
- then enter his/her name and e-mail address;
- a confirmation link will be sent to the e-mail address provided, which he/she can click to confirm the subscription;
- he/she can unsubscribe by clicking on the link at the bottom of the newsletter.
Our readers have the right to withdraw their consent given in this way at any time by sending an e-mail to the contact details provided above.
COOKIE USAGE POLICY
Our website places a small data package (a so-called "cookie") on the user's computer in order to provide a personalised service. The purpose of the cookie is to ensure the highest possible quality of the functionality of the site in order to enhance the user's experience.
In the course of providing personalised services, we use cookies to process the following Personal Data: demographic data and information on interests, habits and preferences (based on browsing history).
The user can delete the cookie from his/her computer or set his/her browser to refuse the use of cookies. By disabling the use of cookies, the user acknowledges that without a cookie the functionality of the site is not fully functional.
Session cookie: this contains the visitor's session ID, it is necessary for the functioning of the website, it does not store any personal data about the visitor, it expires after 2 years.
Google analytics cookie: the website uses Google Analytics, a system that creates cookies on the visitor's computer. These are used for statistical measurements and do not store any personal data about the visitor.
For more information, please click here:
https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
Newsletter subscription cookie: this is used to store when the user has subscribed to the newsletter, so that it is not offered to them unnecessarily more than once, and does not store any personal data about the user.
Voting cookie: it contains the votes a user has cast for the polls on the site, so that a user can only vote once. It does not store any personal data.
Cookie consent cookie: remembers the click of the cookie warning bar at the bottom of the page, so that the user does not have to see it unnecessarily. It does not store any personal data.
18+ cookie: to view adult content, the user must declare that they are over 18, the result of which is stored here so that you don't have to confirm this each time. No personal data is stored.
Hotjar cookie: statistical cookie, used to create heat maps, does not store any personal data about the user.
More information:
https://www.hotjar.com/legal/policies/cookie-information
PRINCIPLES OF DATA MANAGEMENT
We will process Personal Data in accordance with the principles of good faith and fairness and transparency, as well as the applicable laws and the provisions of this Notice.
The processing of Personal Data will only be carried out for a specific purpose. Personal Data will not be used for any purpose other than its original purpose, unless the User gives his/her express consent.
The use of the data in aggregate statistical form does not constitute Processing or a transfer of data, given that it may not contain any other form of data that can identify the User concerned.
The data that comes to our knowledge will be processed in accordance with the data protection principles set out in the GDPR, the Info TV and this Privacy Policy and will not be disclosed to third parties, except for the data controllers and external service providers specified in this Privacy Policy.
If we intend to use the Personal Data for a purpose other than that for which it was originally collected, we will inform the User and seek his or her prior explicit consent or provide him or her with the opportunity to object to the use of such data.
The Personal Data provided will not be verified. The person providing the Personal Data is solely responsible for the correctness of the Personal Data provided.
Our system may collect information about the activity of Users, which cannot be linked to other information provided by Users at the time of registration or to information obtained from other websites or services.
We take care of the security of Personal Data, we take technical and organizational measures and establish procedures to ensure that the data collected, stored and processed are protected and to prevent accidental loss, unlawful destruction, unauthorized access, unauthorized use, unauthorized alteration and unauthorized disclosure. We will require all third parties to whom we transfer Personal Data to comply with this obligation.
DURATION OF DATA PROCESSING
The automatically recorded IP addresses are stored together with the Users' data as defined in this Policy and are deleted at the same time as the Users' data is deleted.
In the case of e-mails sent by a User, if the User is not registered, the e-mail address will be deleted on the 15th day following the closure of the case referred to in the request, unless in a specific case our legitimate interest justifies the continued processing of the Personal Data, until such legitimate interest has been established.
The processing of Personal Data provided by the User in connection with the services provided by the User on our Website will continue until the User unsubscribes from the relevant Service, under the relevant username, or otherwise requests the deletion of the Personal Data. In that case, the Personal Data will be deleted from our system. The User's right to use the Service is not affected by the User's request to cease Processing without unsubscribing from the Service, but the User may not be able to use certain Services without the Personal Data.
Personal Data of participants of events and competitions organised by us will be processed until the end of the event or competition, unless the User has consented to the processing for other purposes.
Data related to the Service ordered by the User but not paid for, if the User has not contributed to the newsletter, will be stored for 2 days.
Data of Users who have successfully paid for the ordered Service but do not subscribe to the newsletter will be stored for 5 days after delivery, unless the User has consented to the further processing of his/her data.
The personal data of users who have subscribed to the newsletter will be deleted at the same time as they unsubscribe. You can unsubscribe from the newsletter service by clicking on the link in the newsletter.
For users subscribed to the newsletter, additional data (delivery , billing address) provided during the ordered and paid service will be stored until 5 days after successful delivery, unless the User has requested to store the data further.
PROVISION OF PERSONAL DATA
By providing any User's e-mail address and the data provided during registration (e.g. user name, ID, password, etc.), the User also assumes responsibility for the fact that the data and consents provided are his/her own and are true and that he/she will use the service exclusively by using the data provided.
With regard to this assumption of responsibility, any liability in connection with access to the Service using an e-mail address and/or data provided shall be borne solely by the User who registered the e-mail address and provided the data. If the User has provided third party data during registration for the use of the Service or has caused damage in any way during the use of the Website, the Owner shall be entitled to claim damages from the User. In such a case, the Owner shall provide all reasonable assistance to the competent authorities in order to establish the identity of the offending person.
Before collecting, recording or processing any of our readers' personal data as defined above, a link to this notice will be placed in a clear, prominent and unambiguous manner on the home page of our website, informing them of the method, purpose and principles of data collection.
You can request information in writing via the contact details provided in the introduction about what personal data of our readers we process, on what legal basis, for what purpose, from what source and for how long. Information may also be requested about to whom, when, under what law, to which personal data we provide access or to whom we transfer personal data. We will comply with this request within 30 days by sending a letter to the contact details.
You may request in writing, via the contact details provided in the introduction, that we correct or amend any personal data (for example, if your e-mail address has changed). Taking into account the purpose of the processing, the User may request the completion of incomplete Personal Data.
We will delete Personal Data if its processing is unlawful; if our customer requests the deletion of his or her Personal Data; if the Personal Data is incomplete or inaccurate and this situation cannot be lawfully remedied, provided that deletion is not excluded by law; if the purpose of the processing has ceased or the statutory period for storing the Personal Data has expired and if the deletion of the Personal Data has been ordered by a court or public authority.
In the course of the Research, the data will be used only anonymously and will not be used to identify the individual User. We use the anonymous research results generated during the Research Activity to improve our Services, to introduce new Services and to send targeted on-line and traditional advertisements and newsletters to specific Users.
The User may request that Personal Data provided by the User and processed by automated means by the User be provided to the User in a structured, commonly used, machine-readable format and/or transferred to another data controller.
WHO IS ENTITLED TO ACCESS THE DATA
The personal data provided may be accessed by employees of Digital Network Agency Kft. who are employed, subcontracted or otherwise engaged in the performance of their duties.
THE DATA PROCESSORS
For the purposes of this notice, a Data Processor is a service provider that processes Personal Data on behalf of the Data Controller.
Personal Data will be transferred to the following Data Processors:
HOSTING PROVIDER:
Name: DAVERIAN Concept Kft.
Located at: 2724 Újlengyel Petőfi Sándor utca 48.
Company registration number: 13-09-198-660
E-mail: hello@daverian.hu
(Access to full website content and mailing system)
NEWSLETTER:
MailChimp newsletter sending system
(access to the mailing system database)
Contact details of the Data Protection Officer:
E-mail: privacy@mailchimp.com
Address: 675 Ponce de Leon Ave NE, Suite 5000 Atlanta, GA 30308 USA
Privacy Policy: https://mailchimp.com/legal/privacy/
(Access to personal data of subscribers to the newsletter sending service).
Data Processors do not make decisions on their own and are only authorized to act in accordance with the contract with us and the instructions we give them, and we may only use additional data processors with the consent of the Users.
The scope of this Policy does not cover services and data processing related to promotions, sweepstakes, services, other campaigns and content published by third parties other than the Data Controllers, which are advertised or otherwise displayed on the https://dna.hu websites in this Policy. Likewise, unless otherwise indicated, the services and data processing of websites, service providers to which links are provided on the websites covered by this Policy shall not be subject to this Policy. Such services shall be governed by the provisions of the privacy policy of the third party service providers and the Data Controllers shall not be liable for any such processing.
The Data Controllers record the User's IP address when the User accesses certain Websites in connection with the provision of the Service, in the legitimate interest of the Data Controller and for the lawful provision of the Service (e.g. to filter unlawful use or unlawful content), without the User's consent.
By registering on the Website or by using the Service, the User as a customer consents to the storage, processing and use of the Personal Data provided during registration and/or purchase by the Service Provider and its business partners (e.g. postal service, simple pay, courier service) involved in the provision of the service related to the distribution of the Magazines, in accordance with the applicable legal provisions, for the purpose of fulfilling the order.
The Personal Data contained in the receipt issued by the Data Controller shall be processed by the Data Controller in accordance with the Accounting Act.
EXTERNAL SERVICE PROVIDERS
In many cases we use an External Service Provider, which we work with, to provide the Services.
The Personal Data processed in the systems of the Third Party Service Providers is governed by the Third Party Service Providers' own privacy notices. We will use our best efforts to ensure that the Third Party Service Provider processes the Personal Data transferred to it in accordance with the law and uses it only for the purposes specified by the User or as set out in this Notice.
We will inform Users of the transfers to External Service Providers in this Notice.
EXTERNAL SERVICE PROVIDERS THAT FACILITATE REGISTRATION OR ACCESS
They provide registration and login facilitating applications for Users. In the context of this cooperation, certain Personal Data (e.g. IP address, e-mail, registration name) may be transferred by these External Service Providers to the Data Controllers and/or the Processor. These External Service Providers collect, process and transfer Personal Data in accordance with their own privacy policies.
External Service Providers that cooperate with the Data Controller to facilitate registration or login:
Meta Inc.
EXTERNAL WEB ANALYTICS AND AD SERVING SERVICE PROVIDERS
We work with third party web analytics and ad serving service providers for the Services pages.
These third-party service providers may have access to the User's IP address, and in many cases they may also use cookies, sometimes web beacons (web markers used on websites, sometimes in emails or mobile applications to record the IP address, the website visited), click tags (a metric identifying when an advertisement has been clicked on) or other click metrics to personalize or analyze the Services and to provide statistics.
The cookies set by the above Third Party Service Providers can be deleted from the User's device at any time, and the use of cookies can generally be refused by selecting the appropriate settings on the browser(s). A cookie placed by an External Service Provider can be identified by the domain associated with that cookie. It is not possible to refuse web beacons, clicktags and other click metrics.
The above Third Party Service Providers will process the Personal Data transferred to them in accordance with their own privacy policies.
Third-party web analytics and ad serving service providers working with the Data Controllers:
Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland.
DAVERIAN Concept Kft. (2724 Újlengyel Petőfi Sándor utca 48., cégjegyzékszám: 13-09-198-660)
Meta Platforms Ireland Ltd., 4 Grand Canal Square, Dublin 2 Ireland
OTHER EXTERNAL SERVICE PROVIDERS
There are some External Service Providers with whom we do not have a contractual relationship or with whom we do not intentionally cooperate in relation to the processing of data, but regardless of this, the Website / Services - even with the User's cooperation (e.g. (whether or not by connecting his/her individual account to the Service), and by doing so, collect data about Users or User activity on the Services' websites, which may sometimes be used to identify the User, either individually or in combination with other data collected by this External Service Provider. Such External Service Providers may include, but are not limited to:
- Meta Platforms Ireland Inc.,
- Google LLC,
- YouTube LLC
These External Service Providers process the Personal Data transferred to them in accordance with their own privacy policies.
OTHER EXTERNAL SERVICE PROVIDERS
Users may contact us with any questions or comments regarding data processing by registered or certified mail to the above address or by e-mail to hello@dna.hu.
The User may directly contact the National Authority for Data Protection and Freedom of Information (address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c.; phone: +36-1-391-1400; e-mail: ugyfelszolgalat@naih.hu; website: https://www.naih.hu/) with any complaints regarding the Data Processing.
In case Users perceive a breach of the data management principles, they may assert their rights before a court of law in a civil action.
The court of law has jurisdiction to hear the case, which may be brought before the court of the place of residence of the data subject (for a list of courts and their contact details, please click on the link below):
https://birosag.hu/torvenyszekek
Budapest, 2023. december 18.
