I. Name of data controller
Klear B2B Growth Ltd.
Solymár, Budai Nagy Antal u. 12, Hungary
Tax ID: HU29018642
II. Legislation underlying data management
The following legislation shall apply to the processing of data relating to customer service: Regulation (EU) No 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data; repealing Regulation (EC) No 95/46, in force: https://eurlex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016R0679&from=EN CXII of 2011 on freedom of information Act (hereinafter: Info Act), in force: https://net.jogtar.hu/jogszabaly?docid=A1100112.TV on the CLV. Act, current text: https://net.jogtar.hu/jogszabaly?docid=99700155.TV
III. Information on the data processed.
The scope of the data processed and the purpose of the data processing The scope and purpose of the data processed, the duration, the legal basis and the method of processing 2020/11 / newsletter-subscription-supplement-data-management-klear.pdf
IV. Data access and security measures
1. Access to and transfer of data
2. Data security measures
The Data Controller stores the personal data you provide on the Data Controller’s servers and, if applicable, in its paper-based archives. The Data Controller does not use the services of another company to store personal data. The controller shall take appropriate measures to protect personal data against, inter alia, unauthorized access or alteration. For example, access to personal information stored on the server is logged by the Data Controller, which means that you can always check who, when, and what personal information.
V. The data management rights of the data subject
1. Your access rights
You, as the right holder, can access your personal data. If you ask the Data Controller to provide feedback on whether you process your personal data, the Data Controller is obliged to provide information on the following: a. what personal information, b. on what legal basis, c. for what data management purpose, d. from what source, e. how long you treat. Your right to receive feedback on whether or not the Data Controller handles your personal data, a. covers personal information about you; b. does not cover anonymous data; c. does not cover personal information not about you; and d. includes pseudonymous information that is clearly associated with you. The Data Controller will provide you with access to and a copy of your personal data upon request. If you request an additional / repeated copy of your personal data, the Data Controller may charge a reasonable fee to pay the administrative costs incurred in complying with the request, which will be borne by you.
2. Your right to rectification
You have the right to rectify your personal data. This right a. does not cover anonymous data; b. covers personal information about you; c. does not cover personal information not about you; and d. includes pseudonymous information that is clearly associated with you. The Data Controller will correct or supplement your personal data accordingly at your request. The Data Controller will inform the recipients of the personal data (if any) of the correction of your personal data. However, the Data Controller will not inform the recipients of the correction of personal data if it proves impossible or disproportionate to inform the recipients.
3. You have the right to delete your personal data.
The Data Controller is obliged to delete your personal data without undue delay if a. the Data Controller processes this personal data, and b. You are requesting the deletion of your personal information, and c. personal data is not required for the purposes for which the Data Controller processes the personal data. The Data Controller is obliged to delete your personal data without undue delay if a. the Data Controller handles your personal information, and b. You are requesting the deletion of your personal information, and c. You withdraw your consent on which the processing of your data is based, and d. there is no other legal basis for further processing of your data. The Data Controller is obliged to delete your personal data without undue delay if a. the data processing is necessary to enforce the legitimate interests of the Data Controller or a third party, and b. You object to the Data Controller’s handling of your personal data, and c. the legitimate reason for processing such personal data does not take precedence over your protest. The Data Controller is obliged to delete your personal data without undue delay if:
a. You request the deletion of your personal information, and
b. the processing of such data by the Data Controller is not illegal, or
c. cancellation is mandatory under applicable law, or
d. your data is collected in relation to information society services.
The Data Controller will inform the recipients of the personal data (if any) of the deletion of your personal data. However, the Data Controller will not inform the recipients of the deletion of personal data if it would be impossible or disproportionate to inform the recipients.
4. Your right to restrict the processing of your data
You may request a restriction on the processing of your personal data. Your right to request a restriction on the processing of your personal data (a) does not extend to anonymous data; (b) cover personal information about you; (c) does not cover personal information not about you; and (d) includes pseudonymous information that is clearly associated with you. The Data Controller will restrict the processing of your personal data for the period during which it verifies the accuracy of such data if you request a restriction on the processing of your personal data and you dispute the accuracy of such data. The Data Controller restricts the processing of your personal data if you request a restriction on the processing of data the processing of which is unlawful and you object to the deletion of such data. The Data Controller restricts the processing of your personal data if (a) you request a restriction on the processing of your personal data, and (b) the Data Controller no longer needs this data for the purpose of processing your data, and (c) you use your data to submit, enforce or requires protection. The Data Controller restricts the processing of your personal data if a. You object to the processing of your personal data that is necessary for the legitimate interests of the Data Controller, and b. You are awaiting confirmation that there is a legitimate reason for the processing of your personal data by the Data Controller which does not take precedence over your protest. The Data Controller will inform the recipients of the personal data (if any) of any restrictions on the processing of your personal data. However, the Data Controller will not inform the recipients of such a restriction if it would be impossible or disproportionate to inform the recipients. If the Data Controller restricts the processing of your personal data, it may (a) store such personal data, (b) process such personal data with your consent, (c) process personal data for the purpose of making, enforcing or protecting a legal claim, or to protect your rights.
5. Your right to data portability
You have the right to receive personal data about you provided by you to a data controller in a structured, widely used machine-readable format and to transfer this data to another data controller without hindrance (where technically possible) the controller to whom the personal data have been made available, if the processing is based on consent or necessary for the performance of a contract and the processing is automated. Your right to data portability (a) does not extend to anonymous data; (b) cover personal information about you; (c) does not cover personal information not about you; and (d) does not cover clearly pseudonymous data. 6. Deadline for processing your application as a data subject The Data Controller will respond to your requests for the above rights without undue delay, but no later than within one month. 7. Right to lodge a complaint If you believe that your rights have been violated, the Data Controller will do so suggests that you initiate a consultation with the Data Controller by contacting the Data Controller directly. If such consultation is unsuccessful or you do not wish to take part in such an action, you may apply to the courts or the NAIH. If you institute legal proceedings, you may decide to bring the proceedings before the court having jurisdiction over your address or place of residence. The contact details of the NAIH are as follows: 1125 Budapest, Szilágyi Erzsébet fasor 22 / C .; phone: +36 1 391 1400; fax: +36 1 391 1410; e-mail: ugyfelszolgalat@naih.hu; website: www.naih.hu 8. Amendments to this prospectus The Data Controller reserves the right to amend this prospectus at any time. The Data Controller shall inform customers of such changes by letter or e-mail, as appropriate, and in any case in accordance with applicable law.
Privacy Policy for Cookie Usage
I. Name of data controller
Company name: Klear B2B Growth Ltd.
Registered office: Solymár, Hungary
Company registration number: 01 09 379134
Tax number: HU29018642
Represented by: Daniel Zsolt Rényi
II. Legislation underlying data management
The following legislation applies to data processing: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data Repealing Regulation (EC) No / 46, in force: https://eurlex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016R0679&from=EN on the right to information and freedom of information 2011 CXII. Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Economic Advertising Activities (hereinafter: Info Act), in force: https://net.jogtar.hu/jogszabaly?docid=A1100112. law, current text: https://net.jogtar.hu/jogszabaly? docid = A0800048.TV of the 1997 CLV on consumer protection. Act, current text: https://net.jogtar.hu/jogszabaly?docid=99700155.TV
III. Information on the data processed.
The scope of data managed by the data controller: the online ID of the data subject. Legal basis for the processing: Consent of the data subject Duration of the processing: Until the withdrawal of the consent.
IV. Data access and security measures
About the cookie in general (1) Cookies (cookies) are short data files that are placed on the user’s computer by the website you are visiting. The purpose of the cookie is to make the given infocommunication and internet service easier and more convenient. There are many varieties, but they can generally be divided into two major groups. One is the temporary cookie that the website places on the user’s device only during a specific session (e.g. during the security authentication of an internet bank), the other is the persistent cookie (e.g. the language setting of a website) that remains until then on the computer until the user deletes it. According to the guidelines of the European Commission, cookies [unless they are absolutely necessary for the use of the given service] may only be placed on the user’s device with the user’s permission. (2) In the case of cookies that do not require the user’s consent, information shall be provided during the first visit to the website. It is not necessary for the full text of the information on cookies to appear on the website, it is sufficient for the operators of the website to briefly summarize the essence of the information and to indicate the availability of the full information via a link. (3) In the case of cookies requiring consent, the information may also be related to the first visit to the website in case the data processing related to the use of cookies starts already with the visit to the website. If the cookie is used in connection with the use of a function specifically requested by the user, the information may also be displayed in connection with the use of this function. In this case, it is not necessary for the full text of the information on cookies to appear on the website, a short summary of the essence of the information and a link to the availability of the full information is sufficient. (4) The visitor shall be informed about the use of cookies on the website in the data management information set out in the annex to these regulations. With this information, the Data Controller ensures that the visitor can find out at any time before and during the use of the information society-related services of the website which data types the Data Controller handles, including the processing of data that cannot be directly contacted by the user.
V. Use of cookies
The Data Controller informs its Users that it uses Google Analytics, Google Remarketing, AdWords Conversion Tracking, and Facebook Remarketing and LinkedIn remarketing to measure traffic to its Website and its subpages and to track the behavior of its visitors, generate statistics, and perform ads. The referenced programs on the user’s computer are called they place cookies that collect user data. Visitors to the Website (Stakeholders) allow the Data Controller to use Google Analytics, Google Remarketing, AdWords Conversion Tracking, and Facebook Remarketing. They also consent to the Data Controller monitoring and tracking their user behavior and using all services provided by the programs. In addition, the user has the option to disable the recording and storage of cookies for future reference at any time, as described below. requirements of the data protection authority. Google reports that Google Analytics uses a number of first-party cookies to report visitor interactions on your site. These cookies only store non-personally identifiable information. Browsers do not share their own cookies between domains. You can find more information about cookies in the Google Advertising and Privacy FAQ.
1. Google Analytics
The data manager uses Google Analytics primarily to generate statistics for, among other things, the performance of his campaigns. By using the program, the Data Controller mainly obtains information about how many visitors have visited your Website and how much time the visitors have spent on the Website. The program recognizes the visitor’s IP address, so you can track whether the visitor is returning or a new visitor, and how the visitor traveled to the Website and where they entered.
2. Google Remarketing
In addition to the usual Google Analytics data, the Data Controller uses the Google Remarketing program to collect data from the DoubleClick cookie. The DoubleClick cookie allows you to use the remarketing service, which primarily ensures that visitors to your Website will later encounter your Ad Manager ad on free Google ad slots. The Data Controller uses Google Remarketing for its online advertising. Data Manager’s ads are also displayed on Internet sites by third-party service providers, such as Google. Data Management and third-party service providers, such as Google, share their own cookies (such as Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) based on users’ previous visits to the Website. to learn more and to optimize and display your ads.
3. Google AdWords Conversion Tracking
Google AdWords Conversion Tracking is designed to help Data Manager measure the effectiveness of your AdWords ads. This is done by using cookies placed on the User’s computer, which lasts for 30 days and does not collect personal information.
4. Facebook Remarketing
The Data Controller uses the Facebook remarketing pixel to increase the effectiveness of Facebook ads, so-called to build a remarketing list. This way, after visiting the Website, an external service provider, such as
Facebook, can display ads on Internet sites. Remarketing lists are not personally identifiable. The visitor’s personal information is not included, only the browser software is identified.
5. Disabling cookies
If you want to manage or disable cookie settings from your own computer, you can do so in your browser depending on your browser toolbar, but in the & quot; Settings & gt; Under Privacy Settings, you can set which tracking features you enable / disable on your computer. Users who do not want Google Analytics to report on their visit can install the Google Analytics Disable Browser Extension. To disable Analytics web activity, visit the Google Analytics Disable page and install the extension for your browser. For more information on installing and uninstalling the extension, see the help for your browser.
VI. Data access and security measures
1. Access to and transfer of data The personal data you provide may be accessed by the employees of the Data Controller in order to perform their duties. The data controller shall transfer the processed personal data to its subcontractors specified in the annex to these regulations. The Data Controller shall only transfer its personal data to other Data Controllers and state bodies not listed in the Annex only in exceptional cases. For example, if a case involving you is the subject of legal proceedings and the court seised requires the transfer of documents containing your personal data, the police will contact the Data Controller and request the transfer of the documents containing your personal data for investigation. 1. Data security measures The Data Controller stores the personal data you provide on the Data Controller’s servers and, if applicable, in a paper-based archive.
The Data Controller does not use the services of another company to store personal data. The controller shall take appropriate measures to protect personal data against, inter alia, unauthorized access or alteration. For example, access to personal data stored on the server is logged by the Data Controller, which means you can always check who, when, what personal data.
VII. The data management rights of the data subject
1. Your access rights
You, as the right holder, can access your personal data. If you ask the Data Controller to provide feedback on whether you process your personal data, the Data Controller is obliged to provide information on the following: a. what personal information, b. on what legal basis, c. for what data management purpose, d. from what source, e. how long you treat. Your right to receive feedback on whether or not the Data Controller handles your personal data, a. covers personal information about you; b. does not cover anonymous data; c. does not cover personal information not about you; and d. includes pseudonymous information that is clearly associated with you. The Data Controller will provide access to and a copy of your personal data upon request. If you request an additional / repeated copy of your personal information, the Data Controller may charge a reasonable fee to pay the administrative costs incurred in complying with the request, which will be borne by you.
2. Your right to modify or correct data
You have the right to have your personal information corrected. This right a. does not cover anonymous data; b. covers personal information about you; c. does not cover personal information not about you; and d. includes pseudonymous information that is clearly associated with you. The Data Controller will correct or supplement your personal data accordingly at your request. The Data Controller will inform the recipients of the personal data (if any) of the correction of your personal data. However, the Data Controller will not inform the recipients of the correction of personal data if it proves impossible or would require a disproportionate effort to inform the recipients.
3. Right to delete
Under certain conditions, you have the right to delete your personal data. The Data Controller is obliged to delete your personal data without undue delay if a. the Data Controller processes this personal data, and b. You are requesting the deletion of your personal information, and c. personal data is not required for the purposes for which the Data Controller processes the personal data. The Data Controller is obliged to delete your personal data without undue delay if a. the Data Controller handles your personal information, and b. You are requesting the deletion of your personal information, and c. You withdraw your consent on which the processing of your data is based, and d. there is no other legal basis for further processing of your data. The Data Controller is obliged to delete your personal data without undue delay if a. the data processing is necessary to enforce the legitimate interests of the Data Controller or a third party, and b. You object to the Data Controller’s handling of your personal data, and c. the legitimate reason for processing such personal data does not take precedence over your protest. The Data Controller is obliged to delete your personal data without undue delay if a. You request the deletion of your personal information, and b. the processing of such data by the Data Controller is not illegal, or c. cancellation is mandatory under applicable law, or d. your data is collected in relation to information society services. The Data Controller will inform the recipients of the personal data (if any) of the deletion of your personal data. However, the recipient shall not inform the recipients of the deletion of personal data if it would be impossible or disproportionate to inform the recipients.
4. You have the right to restrict your privacy
You may request a restriction on the processing of your personal information. Your right to request a restriction on the processing of your personal data (a) does not extend to anonymous data; (b) cover personal data concerning him or her; (c) does not cover personal information not about you; and (d) includes pseudonymous information that is clearly associated with you. The Data Controller will restrict the processing of your personal data for the period during which it verifies the accuracy of such data if you request a restriction on the processing of your personal data and you dispute the accuracy of such data. The Data Controller restricts the processing of your personal data if you request a restriction on the processing of data the processing of which is unlawful and you object to the deletion of such data. The Data Controller restricts the processing of your personal data if (a) you request a restriction on the processing of your personal data, and (b) the Data Controller no longer needs such data for the purpose of processing your data, and (c) you use your data to file, enforce or requires protection. The Data Controller restricts the processing of your personal data if a. You object to the processing of your personal data that is necessary for the legitimate interests of the Data Controller, and b. You are awaiting confirmation that there is a legitimate reason for the processing of your personal data by the Data Controller which does not take precedence over your protest. The Data Controller will inform the recipients of such personal data (if any) of any restrictions on the processing of your personal data. However, the Data Controller shall not inform the recipients of such a restriction if it would be impossible or disproportionate to inform the recipients. If the Data Controller restricts the processing of your personal data, it may (a) store such personal data, (b) process such personal data with your consent, (c) process personal data for the purpose of making, enforcing or protecting a legal claim, or to protect their rights.
5. Your right to data portability
You have the right to receive your personal data about you provided to you by a data controller in a structured, widely used machine-readable format and to transfer this data to another data controller without that this would prevent (where technically possible) the controller to whom the personal data have been made available if the processing is based on consent or necessary for the performance of a contract and the processing is automated. Your right to data portability (a) does not extend to anonymous data; (b) cover personal information about you; (c) does not cover personal information not about you; and (d) does not cover clearly pseudonymous data.
6. Deadline for processing your application as a data subject
The Data Controller will respond to your requests for the above rights without undue delay, but no later than within one month. 7. Right to lodge a complaint If you consider that your rights have been violated, the Data Controller recommends that you initiate a consultation with the Data Controller by direct contact. If such consultation is unsuccessful or you do not wish to take part in such an action, you may apply to the courts or the NAIH. If you institute legal proceedings, you may decide to bring the proceedings before the court having jurisdiction over your address or place of residence.
The contact details of the NAIH are as follows: 1125 Budapest, Szilágyi Erzsébet fasor 22 / C .; phone: +36 1 391 1400; fax: +36 1 391 1410; e-mail: ugyfelszolgalat@naih.hu; website: www.naih.hu 8. Amendments to this prospectus The Data Controller reserves the right to amend this prospectus at any time. The Data Controller will inform customers of such changes by letter or e-mail, as appropriate, and in any case in accordance with applicable law.
