DATA PROCESSING NOTICE
Processing of business card personal contact details and other contact-related personal information
Invescom M&A Tanácsadó Kft. (1117 Budapest, Dombóvári út 27, 2nd floor, company registration number: 01-09-952151) (hereinafter referred to as the Company/Data Controller) provides the following information regarding the processing of personal data:
Legal basis In cases where contact details are provided within the context of an employment relationship, the legal basis is the legitimate interest of the current or future contracting partners, taking into account the results of the legitimate interest assessment pursuant to GDPR (Article 6(f)). In cases where contact details are provided in a context not relating to an employment relationship, the consent of the data subject is required (Article 6(a) GDPR).
Pursuant to Point 6 of § 3 of the Information Act, the processing of publicly available data (including data in the Company Register) is conducted based on a legitimate interest of the public, and in accordance with all relevant provisions of the GDPR, in particular, but not limited to, the purpose limitation principle.
Purpose To build new and maintain existing contacts, facilitate discussions and communication, and to provide adequate information on news, reports, and analyses relating to the business activity.
Data concerned Personal data provided (primarily name, telephone number, e-mail address, and title of position), and personal data made publicly available in the public interest (name, e-mail address).
Duration: Not more than 1 year from the termination of legitimate interest or until the withdrawal of consent.
THE RIGHTS OF THE DATA SUBJECTS
The data subject has the right to request information about the processing of his/her personal data, which includes the rights to access, rectify, object, withdraw consent, and erase data (except in cases of mandatory processing), as well as the right to data portability. These rights can be exercised as specified at the time of data collection or by contacting the Company using the provided contact details.
Right to request information:
The Company shall take appropriate measures to ensure that data subjects are provided with all information regarding the processing of personal data, as outlined in Articles 13 and 14 of the GDPR, along with all relevant details specified in Articles 15-22 and 34, in a concise, transparent, intelligible, and easily accessible manner, using clear and plain language.
The aforementioned rights can be exercised in writing via the contact details of the Company as set out in this notice. At the request of the data subject and following the verification of his/her identity, the information may also be provided orally.
The data subject's right of access:
The data subject has the right to receive feedback from the Company as to whether or not his or her personal data are being processed and, if such processing is ongoing, has the right to access the personal data and the following information:
- The purposes of the processing;
- The categories of personal data concerned;
- The recipients or categories of recipients to whom or which the personal data have been or will be disclosed;
- The intended period of storage of the personal data;
- The right to rectification, erasure or restriction of processing and the right to object;
- The right to lodge a complaint with a supervisory authority;
- Information on the data sources;
- The presence of automated decision-making, including profiling.
The Company shall provide the information to the data subject not later than within one month of receiving the request.
Right to rectification::
The data subject can request the correction of inaccurate personal data relating to him/her processed by the Company and the completion of incomplete data.
Right to erasure:
If one of the following grounds applies, the data subject has the right, upon request and without undue delay, to have personal data relating to him or her erased by the Company:
- The personal data are no longer necessary for the purposes for which they were initially collected or processed by other means.
- The data subject withdraws the consent based on which the processing was carried out and there is no other legal basis for the processing.
- The data subject objects to the processing and there are no overriding legitimate grounds for the processing.
- The personal data have been unlawfully processed.
- Erasure of the personal data is required in order to comply with a legal obligation under the European Union or Member State law to which the Company is subject.
- Personal data have been collected in connection with the provision of information society services.
The erasure of data cannot be initiated if the processing is necessary:
- For exercising the right to freedom of speech and right to information;
- To comply with an obligation under the European Union or Member State law applicable to the Company that requires the processing of personal data, or to carry out a task in the public interest or in the exercise of official authority vested in the Company;
- In the public interest, for public health, archiving, scientific or historical research purposes, statistical purposes;
- For the establishment, exercise or defence of legal claims.
Right to restrict processing:
The Company will restrict processing at the request of the data subject if either of the following conditions is met:
- The data subject contests the accuracy of the personal data, in which case the restriction shall apply for the period of time necessary to allow the accuracy of the personal data to be verified.
- The processing is unlawful and the data subject opposes the erasure of the data and requests instead the restriction of their use.
- The Company no longer needs the personal data for the purposes of the processing but the data subject requires them for the establishment, exercise or defence of legal claims.
- The data subject has objected to the processing; in this case, the restriction shall apply for a period of time until it is determined whether the Company's legitimate grounds prevail over the data subject's legitimate grounds.
Where processing is subject to restriction, personal data may only be processed – aside from storage purposes – with the consent of the data subject, for the establishment, exercise, or defence of legal claims, for the protection of the rights of another natural or legal person, or for important public interests of the European Union or a Member State.
The Company shall inform the data subject of the lifting of the restriction on processing.
Right to data portability:
Where processing is carried out by automated means and the Company processes the data on the basis of the data subject's consent or on the basis of a contractual legal basis, the data subject has the right to receive the personal data relating to him or her, which he or she has provided to the Company, in a structured, commonly used, machine-readable format and to transmit such data to another controller.
Right to object:
The data subject has the right to object at any time, on grounds relating to his or her particular situation, to the processing of his or her personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Company, or necessary for the purposes of the legitimate interests pursued by the Company or a third party, including profiling based on the aforementioned provisions. In the event of an objection, the Company may no longer process the personal data, unless there are compelling legitimate grounds for doing so which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such purposes, including profiling. In the event of an objection to the processing of personal data for direct marketing purposes, the data shall not be processed for those purposes.
Automated decision-making in individual cases, including profiling:
The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
The above right shall not apply in case the processing is:
- Necessary for entering into, or the performance of, a contract between the data subject and the Company;
- Authorized by the European Union or Member State law to which the Company is subject and which also stipulates appropriate measures to protect the rights, freedoms and legitimate interests of the data subject; or
- Based on the explicit consent of the data subject.
Right of withdrawal:
The data subject has the right to withdraw his or her consent at any time. Withdrawal of consent does not affect the lawfulness of the processing based on consent prior to its withdrawal.
Right to remedies:
Right to apply to the courts:
The data subject may take legal action if his or her rights are violated. The court shall rule on the case out of turn.
Right to a judicial remedy:
Complaints may be submitted to the National Authority for Data Protection and Freedom of Information using the contact details provided on their website www.naih.hu .