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DATA PROCESSING POLICY

DATA PROCESSING POLICY
in relation to the website of www.feherlegal.hu

Dear Visitor!

Thank you for visiting the website of FEHÉR AND PARTNERS LAW FIRM at the domain address of www.feherlegal.hu. The purpose of this policy is to let you know which personal data are collected on this website and how do we process such data.

The protection of your personal data is important to us! When visiting our website, your data are stored and processed accordingly to the respective laws.

The data controller

The data controller in connection with the data processing of your personal data set out in the present policy is our company. Our company data and contact information are the following:

Name of data processor: FEHÉR AND PARTNERS LAW FIRM
registered seat: H-1134 Budapest, Váci út 33.
bar association registry number: 00942
tax number: 18242605-2-41
(hereinafter: ”our office”)

Our contact information regarding questions of data processing:

mailing address: H-1134 Budapest, Váci út 33.
e-mail address: info@feherlegal.hu
phone number: +36(1) 786-2810
website: www.feherlegal.hu

1. data processing in connection with our website

We conduct the following data processing activities on the website:

  • Registration for direct marketing purposes;
  • Use of user account;
  • Sending e-mails to us via contact sheet;
  • Applying to job postings via contact sheet on the website;
  • Cookies and monitoring other activities of users.

1.1.          Registration for direct marketing purposes (sending newsletters and promotional offers) 

The purpose of data processing:

The purpose of the direct marketing registration on our website (link) is to send to your e-mail address advertisements of our services and notify you about the latest legislative news (data processing for the purpose of direct marketing).

Please note that we might categorize you into different groups on the basis of some of your personal data (e.g. country, nature of activity) which are necessary to select the most personalized offers regarding your preferences.

In case of newsletters, we might monitor your activity (opening, clicking) and evaluate which newsletter topics and services could be of interest to you with a view to let you know offers in the realm of your interests.

Processed personal data:

Name and e-mail address.

Legal ground for data processing

We process your personal data based on your voluntary consent. You provide us your consent by filling out and sending the registration form.

In the lack of consent we cannot provide you with our letters of our service portfolio and our electronic newsletters regarding changes of legislation.

Section 1 a) of Article 6 of Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation, commonly known as GDPR) and Section (5) of Article 5 of Act No. XLVIII. of 2008 on the basic conditions and certain limits of business advertising activities regulate where data processing is based on consent.

Time period of data processing

Your personal data shall be deleted from our database if (i) you request us to do so or (ii) you withdraw your consent of data processing (unsubscription) or (iii) we end our direct marketing activities.

You can unsubscribe from our newsletters and advertisements anytime:

  • by clicking on “Unsubscribe” at the bottom of the newsletters or
  • by sending a statement to info@feherlegal.hu via e-mail or
  • by sending a letter via post to FEHÉR AND PARTNERS LAW FIRM (H-1134 Budapest, Váci út 33.).

In the event of a subscription, we shall delete your personal data (including your username and password) from our newsletter database and shall no longer send you newsletters and offers.

1.2. Communications

Purpose of data processing and the group of processed data

Should you contact us via any contact information displayed on our website with a question or request, we process the data provided by you in order to send a response (e-mail address from where you sent the e-mail or the address filled out on the contact sheet or any further personal data, e.g. your name, the content of your letter).

Legal ground for data processing

The data processing set out in this section is based on your voluntary consent, which is provided by getting in touch with us. In the lack of consent, we cannot process your inquiry.

The data processing based on consent is allowed by Section 1 a) of Article 6 of GDPR.

Time period of data processing

Please note that in case you withdraw your consent, we delete your personal data designated over the course of getting in touch with us, provided that the data processing has no other legal ground. We delete your personal data processed under the present section even in the lack of withdrawal of consent following the general 5 year statute of limitations civil law deadline.

1.3. Applying to job postings

We act accordingly to the rules set out above in the section of Communications.

1.4. The data processing relating to the website of www.feherlegal.hu

1.4.1. Webserver logging

The IT system responsible for the website processes personal data over the course of its proper operating activities, which are necessary for the internet protocol based communication. These technological solutions ensure that you may visit the website.

1.4.2. Use of cookies

On www.feherlegal.hu we use so-called session cookies to ensure the smooth use of the website. Our session cookies only process the session identifiers (random numbers) which are required so that the use of the website is safe and effective. The session cookies applied by us ignore the use of such IT solutions which would breach the confidential nature of the users’ browsing and do not collect personal identifiers. 

The website uses some functions that analyze the users’ browsing on a statistical basis or improve the access to content or allow targeted advertisements to be displayed on the website.

The website uses the Google Analytics system in an anonymous form, which is a web analytical service provided by Google, Inc. (“Google”). Google Analytics as well as similar other systems installs cookies on your computer to help analyze the use of the website. The data recorded by the cookie (your IP address) becomes stored and transferred to the US headquarters of Google. Google uses this data to evaluate the use of the website and creates a report of the activities of the website to the operator of the website. In case of a statutory obligation, Google shall be obliged to transfer such data to third persons or to make such data accessible to its own data processors. Google does not connect your IP address with further data related to you processed by Google.

By using this website, you consent that your personal data are the subject of the data processing by Google as per the above purpose and method.

You can turn off the use of cookies by the proper settings of the browser (e.g. browsing anonymously). However, turning off cookies may hinder some features functioning on the website.

We do not use the cookies for other purposes. We do not use constant cookies or other user following solutions.

We use the following cookies on our website:

  • PHP session cookie,
  • cookieAccepted cookie.

2. who can see my data?

The personal data you provided us shall be processed confidentially and shall not disclose such data to any third party not designated in the present policy.

Your personal data could be accessed by our colleagues (managing partner attorney, partner and of counsel attorneys) and employees who are not lawyers (office manager, financial manager) and our data processors (please see Annex No. 1.) and their colleagues. Such persons are also entitled to process such data confidentially. 

We may release your personal data to courts, prosecutors, other authorities as per respective laws to the extent and method stipulated in such laws to discharge our legal duties.

In the event that we may enforce any legal claim against you, your personal data could be seen by our cooperating legal partners to the extent necessary to enforce such claim.

OUR DATA PROCESSORS

We hire data processors in connection with the above data controlling operations. The data processors act according to respective laws and our instructions when processing data.

We reserve the right to involve further data processors in the future of which we shall notify you by the amendment of the present policy.

Our data processors and their tasks are set out in Annex No. 1.

3. data security

FEHÉR AND PARTNERS LAW FIRM shall make all the necessary data security measures to protect the confidential nature of data. By doing so, it accepts, creates, systematically reviews those technical and organizational measures and procedural rules that guarantee to provide the safety of the personal data controlled by it and shall do everything in its power to prevent the deletion, unauthorized use or modification of data, shall see to it that the controlled data does not become available to unauthorized persons and such data will not be made public, forwarded, modified or deleted.

In line with the above, FEHÉR AND PARTNERS LAW FIRM establishes the informational technology solutions to ensure the exclusive access to authorized persons and to preserve the authentication and lack of modification of the data. On the basis of this, it applies password protected systems, activity logging, regular safety backups.  

FEHÉR AND PARTNERS LAW FIRM monitors at all times the innovation of technology, the available technical, technological, organizational solutions and applies the necessary solutions to comply with the reasonable protection leveli n relation to its data controlling.

4. personal data breach management

Any breach of personal data shall be immediately reported to us by all of our employees or colleagues. Personal data breach means all cases when unauthorized person acquire access to personal data or the data becomes deleted, lost, modified e.g. our server is broken into or stored data becomes destroyed or a company cell phone or laptop gets lost with personal data on it.  

In case of a personal data breach, we evaluate its impact and risks (which data are concerned, what is the volume of such data, could such data be replaced etc.) and we shall immediately take the necessary measures to terminate the breach. Should we not be able to terminate the risks, we shall notify the data protection authority within 72 hours following our detection of such breach and we shall post a notification on our website as well. In addition to the above, we keep a registry of personal data breaches with as much detail as stipulated by law, which we shall store for 5 years following the detection of the personal data breach.

5. your rights

Withdrawal of consent You are entitled to withdraw your consent at any time without reasoning. In the event of withdrawing an consent, we shall delete the respective personal data. A withdrawal of consent shall not affect the lawfulness of the data controlling prior to the consent.

Requesting information / Right to access

You can ask anytime on the contact information set out above in section 1 if we control any of your personal data and you can request information regarding the following: purpose of the data processing, your personal data being processed by us, its categories, its source, its legal ground, time period, the name and address of the data processor and its activities regarding the processing of data, the circumstances of a potential data protection breach, its impacts and the measures taken to terminate such breach, and – in case of transferring personal data –the legal ground and addressee of such transfer, the categories of addressees, the rights of the data subjects and potential measures to legal remedy.

You may also request information what conclusions have we made in the course of profiling and to which group has your profile been selected.

Concurrently at your notification, we provide you with the copy of the personal data processed by us. The first copy is free of charge. We shall be entitled to charge a reasonable fee for any further copies. We shall notify you of the fee in advance.

Right to rectification and supplementation Should you detect that any of your personal data is processed erroneously, mistakenly or incompletely or in case that your data changed in the meanwhile, please let us know the correct, changed or supplementary data so that we can rectify or supplement it immediately.

Right to delete personal data (”right to be forgotten”) You are entitled to request the deletion of your personal data. Please note that we are entitled to deny the deletion of your personal data, specifically when we need or might need such data to honor our duties set out by law or in the course of enforcing our claims. The withdrawal of the consent relating to the processing of data or an objection leads to data deletion.

Personal data could be deleted in case

a)    there is no further need for data on the grounds of the original purpose of the processing of data;
b)    the processing of data is unlawful;
c)     we are obliged to delete the data by the laws of Hungary or the European Union.

Objection In the course of our direct marketing activities, we are profiling to evaluate your interests with a view to find you with our most relevant offers. You are unconditionally entitled to object to the processing of data. Upon receiving your objection, we delete your personal data and in this regard shall no further process it.

Restriction of data processing Over the course of data processing you may request the restriction of data processing if (i) you have submitted a rectification request and it takes time to evaluate the accuracy of the data; (ii) the data processing is unlawful and you are against the deletion; (iii) you need it to enforce or protect a legal claim and the purpose of the data processing has ceased to exist.

In the event of a restriction, we merely store the data and do not perform any operations on it, unless you approve of further operations or it is necessary for the protection of your or third persons’ personal data or the public interest.

In case of restricting the data processing, we shall notify you in advance regarding its termination.

Right to data portability You may request that we give your personal data that have been processed by us electronically in a well-known and easily-applicable electronic format to your or to a person designated by you.

5.1.     Submitting and responding to requests

In case of enforcing any of your above rights, please submit a written request either in person at our office or via e-mail (info@feherlegal.hu) or post (H-1134 Budapest, Váci út 33.) to FEHÉR AND PARTNERS LAW FIRM. In your letter please provide us with your data necessary to your identification and your mailing address. Should we have any doubt regarding your identity or the data provided by you is not enough for identification, we are entitled to request further identification data from you.

We perform your request within 1 month. In case it is necessary, we are entitled to prolong such deadline with 2 months, of which we shall send a notification to you with the respective reasoning.

Substantiated requests are performed free of charge. However, if the request is obviously unsubstantiated or – based on its particularly repetitive nature – exaggerated, we are entitled to charge a reasonable amount or deny to perform the task stipulated in the request.

Please note that we notify those persons who are concerned of the rectification, deletion and/or restriction of the data, unless it seems impossible or requires disproportionately big efforts. Upon your request we notify you who (which addressees) have we notified or will we notify accordingly to the above. 

6. how to enforce your claim

6.1. Contacting the data controller

Should you be of the opinion that we do not act lawfully over the course of processing your personal data, please let us – as data controllers – know firsthand your remark or claim via the contact information designated above in section 1 so that we could process and manage your request as soon and effectively as possible.

6.2. Turning to the data protection authority, filing a complaint

In case of unlawful data processing, you are entitled to turn to the National Authority of Data Protection and Freedom of Information (NAIH) and request to commence proceedings.

The contact information of NAIH:

website: http://www.naih.hu/
address: H-1125  Budapest, Szilágyi Erzsébet fasor 22/c
mailing address: 1530 Budapest, Pf.: 5.
electronic mailing address (e-mail): ugyfelszolgalat@naih.hu

6.3. Turning to court

Please note that you are also entitled to enforce your claim in front of a court. The tribunal (in Hungarian törvényszék) is competent in such cases. You may commence court proceedings before the competent tribunal based on the location of our headquarters of your domicile or temporary place of residence.

Budapest, 24 May, 2018.

FEHÉR AND PARTNERS LAW FIRM         
data controller                         

Annex No. 1.

Data processors of FEHÉR AND PARTNERS LAW FIRM

Data processor
Activity carried out by the data processor in relation to the data processing

Armadilló Kreatív Ügynökség
web developer and advisor

Tárhely.eu Szolgáltató Kft.
web storage services

WebDream Magyarország Kft. 
newsletter

AD Rendszerház Kft.
IT services

Hegedűsné Hegyesi Annamária 
accounting

Member of Alliott Group

 

Deutsche Anwalts Cooperation