Data Protection Policy

DATA PROTECTION POLICY

 

The National Union of Students in Hungary notifies You, as the visitor of our website and the user of our Services, in this Policy about the data processing performed during the use of the website.

 

I Data controller

Name: National Union of Students in Hungary
Registered office: H-1134 Budapest, Dózsa György út 150.
Electronic mailing address: shmh@hook.hu
Represented by : Tibor GULYÁS

 

II Principles

•  We shall process your personal data lawfully, fairly and transparently.

•  Your personal data shall be collected only for well-defined, clear and legal purposes, and they shall never be processed in a way not complying with the purposes.

•  We shall take all reasonable measures to ensure the accuracy and, as necessary, the actuality of the processed data; in case of receiving information about any of the processed personal data being inaccurate, we shall delete or correct it immediately.

•  Personal data shall be stored in such from, that it shall be identifiable only for the duration specified in the law and/or until necessary.

•  By applying appropriate technical and organizational measures, we shall ensure the safety of your personal data to prevent the unauthorized or illegal processing, accidental loss,           destruction or damage of your personal data.

•  Your personal data shall be processed, i.e. collected, recorded, organized, stored and used in the extent required to provide services via the website and limited to its purpose, and upon  your informed and voluntary consent in the necessary extent and in all cases with purpose limitation.

•  In certain cases, the processing of your personal data shall be in our lawful interest, such as the operation, development and the security of our website.

 

III Main relevant laws related to the data processing

•  Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data (hereinafter: Regulation)

•  Act CXII of 2011 on Informational Self-Determination and Freedom of Information (hereinafter referred to as: Information Act)

 

IV Features of processing of certain personal data

1. Data processing required to avail services provided on the website

1.1. The purpose of data processing

a)      Related to the services available on the website, the processing of your personal data is necessary due to the following:

-   we have to identify You in order to manage your profile and to use other services available on the website,

-   to make the ‘mentoring’ service, provided as our main service, the most appropriate for You, data related to the location and field of your studies shall be provided, and we need to have information on which country do You come from.

 b) You can also manage the data content appearing about You on the website. You have the opportunity to provide data about You, which are not mandatory for availing our services. These data, however, may help us improving our offer with even more services You may be interested in. We shall process your data with your consent.

 

1.2. Scope of processed data

a) HÖOK shall process your following data according to point 1.1. a):

a)  your name

b)  your country of origin

c)   the higher education institution where You study

d)  the specialisation where You study at

e)   your e-mail address

 

b) HÖOK shall processes your following data according to point 1.1. b):

a)  your date of birth

b)  your gender

c)  the name of the faculty of higher education institution, where You study

d)  your health status

e)  profile image

1.3. Legal basis of data processing

The legal basis of the data processing regarding your data listed in point 1.2. a) is Article 6. (1) b) of the Regulation, i.e. the performance of the contractual obligation. The contract shall be concluded between HÖOK and You by accepting the Terms & Conditions, activating the registration and choosing a mentor.

The legal basis of the data processing regarding your data listed in point 1.2. b) is Article 6. (1) a) of the Regulation, i.e. the consent of the data subject (in this case: You).

By filling the field next to the optional data on the website, and by checking the checkbox next to the ‘I consent to the processing of my data above’ and by clicking on the ‘consent’ button, You give your voluntary and express consent to process your data (provided that you finish your registration or save your changes).

1.4. Recipients of your personal data provided

Only your mentor and the agent co-operating in the operation of the website upon the assignment of HÖOK may have access to your personal data specified in point 1.2. a).

The mentor and the website operator are deemed data processors regarding the processing of your personal data.

The mentor is entitled to process your personal data only to the extent required to perform the ‘mentoring’ activity, whilst the website operator is entitled to process your personal data related to the provision of the website operability and the fixing of occurring errors.

Your personal data specified in point 1.2. b) may be learnt by the person co-operating on the HÖOK’s assignment.

Data processor co-operating in the operation of the website on HÖOK’s assignment: Roland KIRÁLY s. p. (registered office: H-3300 Eger, Gyóni G. u. 21/a, tax registration number: 643711027-1-30)

1.5. Duration of data processing

We shall process your personal data specified in point 1.2 a) for 60 days from the termination of your registration.

We shall process your personal data specified in point 1.2. b) until the revocation of your consent. You may revoke your consent according to the provisions of point 2.6. of the Terms & Conditions.

1.6. Providing personal data

Provision of your personal data specified in point 1.2. a) is the precondition of availing our services.

Provision of personal data specified in point 1.2. b) is not mandatory.

 

2. Notification about cookies used by the website

2.1. The purpose of data processing

The website uses different cookies to collect information about the visitors, and to enable the optimal display of the website.

2.2. Scope of processed data

a) session ID to identify the user during registration

b) for the cookie accepting layer a cookie based on the specific browser and host (the program shall recognize in the future the browser used by the computer and does not request the acceptance of cookies)

2.3. Legal basis of data processing

The legal basis of the data processing is Article 6. (1) b) of the Regulation, i.e. the performance of the following contractual obligation: HÖOK shall make the website’s operation user-friendly and simplify its use (cookies are not required to accept at every login), in this case personal data are not stored; data are furthermore processed to identify the registering person during the registration.

2.4. Recipients of your personal data provided

The data that you provide shall only be available for the HÖOK and the co-operating person assigned to operate the website, and your personal data shall not be transmitted.

The website operator is entitled to process your data in relation with the provision of the website’s operability and the fixing of arising errors.

Data processor co-operating in the operation of the website on HÖOK’s assignment: Roland KIRÁLY s. p. (registered office: H-3300 Eger, Gyóni G. u. 21/a, tax registration number: 643711027-1-30)

2.5. Duration of data processing

The data required for identification during the registration process shall be erased following the registration.

2.6. Providing personal data

Providing data at login to the website is mandatory.

 

3. Data processed regarding the services available on the Website

2.1. The purpose of data processing

The purpose of the data processing is to make the activities performed by the data subjects recoverable and recallable by the data subjects

2.2. Scope of processed data

All activities performed by the users on the website (messages, comments on the message board)

2.3. Legal basis of data processing

The legal basis of the data processing is Article 6. (1) b) of the Regulation, i.e. the performance of the following contractual obligation: HÖOK shall, in the framework of providing community building service, enable sending and receiving messages by the data subjects, and provide the message board service appearing on the public platform within each event.

2.4. Recipients of your personal data provided

Only the HÖOK and the database managing contributors may access the data provided by you

Data processor co-operating in the operation of the website on HÖOK’s assignment:

Tamás Töhötöm Kazinger (Stipendum Hungaricum Mentor Network Manager)

Tímea Hetei (Stipendium Hungaricum Network manager)

2.5. Duration of data processing

Until the deletion of the registration.

2.6. Providing personal data

Following registration, it is mandatory when availing the services.

 

V. Other notifications regarding the data processing

Your data shall only be transmitted within the limits specified by the law; in the case of our data processors, we ensure (by stipulating contractual conditions) the prevention of using your personal data for purposes other than you have consented.

HÖOK does not transmit data to abroad, and there is no automated decision making or profiling in place.

The courts, the prosecution and other authorities (e.g. police, tax authority, Hungarian National Authority for Data Protection and Freedom of Information) may contact HÖOK requesting notification, data or documents. In these cases, we shall fulfil our data provision obligation, but only to the extent absolutely necessary for the purposes of the request.

We shall protect your personal data with appropriate technical and other measures, and ensure the safety and availability of your data, and we shall also protect them against unauthorized access, tampering, damage and disclosure, as well as any other unauthorized use.

Within the technical measures, we shall use password protection and anti-virus software. However, please be advised that data transmission via the Internet shall not be deemed completely secure data transmission. HÖOK shall do its best to make the procedures as secure as possible, however, we shall not undertake complete liability for data transmission via our website, although with respect to the data received by HÖOK, we shall apply strict regulations to protect your data and to prevent unauthorized access.

Regarding security matters, we ask your help in properly keeping the password used to access our website, and to never share the password with anyone.

 

V. Your rights regarding data processing

1. Right to information

You are entitled to information about the data processing and your right is deemed to be fulfilled by HÖOK by providing this information note.

2. Consent-based data processing

If the legal basis for data processing is the data subject’s consent according to Article 6(1)(a) of the Regulation, you are entitled to withdraw at any time your prior consent to data processing. However, please note that the withdrawal of the consent relates solely to the data for the processing of which there is no other legal basis. If there is no other legal basis for the processing of the personal data concerned, the personal data will be permanently and irrevocably deleted by HÖOK after the withdrawal of the consent. The withdrawal of your consent shall not affect the lawfulness of the data processing carried out on the basis of the consent prior to the withdrawal.

3. Right to access

At your request, HÖOK will inform you at any time whether your personal data are being processed and if so, HÖOK shall provide access to your personal data and to the following information:

a)     the purpose of data processing;

b)    the categories of personal data concerned;

c)     the recipients or categories of recipients with whom or which the HÖOK communicated or will communicate personal data, including in particular third country recipients or international organizations;

d)    the intended duration of the storage of personal data or, if this is not possible, the criteria to determine this period;

e)     HÖOK will also inform you on your right to apply for correction, cancellation or limitation of the processing of personal data relating to you by HÖOK and you have the right to object to the processing of such personal data;

f)     the right to submit a complaint to a supervisory authority or to initiate legal proceedings;

g)    if the data is not collected directly from You by HÖOK, all information available related to the sources of the data;

h)    if automated decision-making takes place, on the fact of it, including profiling, and at least in such cases about the logic applied, namely the relevance of such data processing and the likely consequences for the data subject.

4. Right to rectification of personal data

You have the right to obtain from the HÖOK without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purpose of the data processing, you may request the amendment of your incomplete personal data (among others) through supplementary statement.

To make changes to your personal information, please report it to HÖOK as soon as possible, making legitimate data processing and the enforcement of your rights easier.

 

5. Right to erasure

HÖOK shall erase your personal data without undue delay on your request where one of the following grounds applies:

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

b)    in the case of consent-based data processing, you withdraw your consent on which the processing is based and where there is no other legal ground for the processing;

c)     you object to the processing of personal data and there are no overriding legitimate grounds for the processing or you object to the processing of personal data for direct marketing purposes;

d)    the personal data have been unlawfully processed by HÖOK;

e)     your personal data have to be erased for compliance with a legal obligation in Union or Member State law;

f)     your personal data have been collected in relation to the offer of information society services. 

HÖOK will not fulfil your erasure request if further processing is required for one of the following reasons:

a)     exercising the right of freedom of expression and information;

b)    compliance with a legal obligation which requires processing under Union or Member State law or for the performance of a task carried out in the public interest;

c)     reasons of public interest in the area of public health;

d)    archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, in so far as the erasure is likely to render impossible or seriously impair this processing; or

e)     the establishment, exercise or defence of legal claims.

Data shall be erased definitively and unrestorably.

 

6. Right to restriction of processing

On your request the HÖOK will restrict the processing, if one of the following applies:

a)     The accuracy of the personal data is contested by You; in such case the restriction shall apply to a period enabling HÖOK to verify the accuracy of the personal data;

b)    the processing is unlawful and You object to the erasure of the personal data and You request the restriction of their use instead;

c)     HÖOK no longer needs the personal data for the purposes of the processing, but they are required by You for the establishment, exercise or defence of legal claims; or

d)    you have objected to processing; in that case, the restriction applies to the period in which it is established that the HÖOK's legitimate grounds do not take precedence over your legitimate grounds.

 

If data processing is restricted, such personal data, except for storage, will be processed by HÖOK only

a)     upon your consent,

b)    for the establishment, exercise or defence of legal claims,

c)     in order to protect the rights of another natural or legal person, or

d)    in the important public interest of the Union or one of the Member States.

7. Right to object

If the legal basis of the processing of your personal data is HÖOK's legitimate interest, you have the right to object on grounds relating to your particular situation, at any time to processing of personal data concerning you, including profiling.

In this case HÖOK shall no longer process the personal data unless HÖOK demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

Where your personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

8. Right to data portability

You have the right to receive the personal data concerning you, which you have provided to HÖOK, in a structured, commonly used and machine-readable format and you have the right to request to transmit those data to another controller.

***** 

9. Rules of procedure for the enforcement of your rights

You can exercise your rights specified above via e-mail sent to […] address or via postal mail addressed to the registered office of HÖOK (H-1134 Budapest, Dózsa György út 150.) or in person at HÖOK’s registered office. HÖOK shall start investigating and fulfilling your application without undue delay upon receipt. HÖOK shall inform you about the measures that had been taken on your request within 30 days upon receiving your application. If your application can not be accomplished by HÖOK, you will be informed within 30 days about the reasons of the refusal and the right to appeal.

VI Legal remedies

You shall be entitled to the following with regard to your personal data:

•       request information,

•       request the rectification, modification and amendment of your personal data processed by us,

•       object to the data processing, and request the erasure of your data and the restriction of data processing (with the exception of mandatory data processing),

•       file an appeal at court,

•       file a complaint at the supervisory authority, or initiate a proceeding

Supervisory Authority: Hungarian National Authority for Data Protection and Freedom of Information (NAIH)

•       Registered office: H-1125 Budapest, Szilágyi Erzsébet fasor 22/c

•       Postal address: H-1530 Budapest, P.O. Box 5.

•       Phone: +36 1 391 1400

•       Fax: +36 1 391 1410

•       E-mail:ugyfelszolgalat@naih.hu

•       Website: www.naih.hu

 

On your request, we shall provide notification about the following in terms of our data handling or processing – through the assigned data processor:

•       your data,

•       the purpose and the legal basis of data processing,

•       its duration, or if it is not possible, the criteria of the determination of this duration,

•       the name and the contact details of the data processors, and their activity related to the data processing,

•       the circumstances and the effects of personal data breaches and measures taken to prevent them, and

•       in case of transmitting your personal data, the legal basis of the transmission of data and their recipients.

 

We shall provide information as soon as possible from submitting the application, but not later than within 1 month. The notification is free of charge.

Our company shall notify those persons (including You) about the rectification, blocking, marking and erasure of your personal data, whom it had transmitted the data for data processing purposes earlier, except if the absence of notification does not infringe your lawful interest.

If You object to the processing of your personal data, the objection shall be examined within 10 days from submitting the claim as default (but not later than within 1 month), and we shall notify You on our decision in writing. If we find that your objection is well-founded, we shall cease the data processing (including additional data collection and transmission) and block your data and notify those persons on the objection and the measures taken upon that, whom we had previously transmitted your personal data, and who shall take measures to enforce the right to objection.

We shall refuse to perform your request, if it is proven that the data processing has such compelling legitimate causes that override your interests, rights and freedoms, or which are required to submit, enforce or protect legal claims. If You disagree with our decision, or if we fail to meet the deadline, You may appeal to the court within 30 days from receiving the decision or the expiry of the deadline.

Regional courts shall have the competence to rule upon data protection cases and the data subject (in this case You) may bring an action – according to your choice – before the regional court having competence according to your place of residence or place of stay.

Foreign citizens may also file a complaint to the supervisory authority having competence according to their place of residence.

Please contact us before filing a claim to the supervisory authority or to the court, in order to make arrangements and to resolve the arisen problem as soon as possible.

HÖOK reserves the right to amend this Data Protection Policy and to notify the data subjects on it appropriately. Information regarding data processing are disclosed at the www.shmh.hu website.

 

15th August 2018.