Privacy Notice

Regarding the newsletters

When subscribing to the newsletter on the website orvostothnoemi.hu (hereinafter: OTN newsletter), you provide personal data which we process under Act CXII of 2011 on the right to informational self-determination and on the freedom of information (hereinafter:“Information Act”), 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 and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter: "GDPR"), Act CVIII of 2008 on certain issues of electronic commerce services and information society services (hereinafter: “Electronic Commerce Act”), and Act XLVIII of 2008 on the basic requirements and certain restrictions of commercial advertising activities (hereinafter: “Advertising Act”). 

In accordance with the provisions of the aforementioned laws, we hereby inform you of the details of how your personal data are processed, and your rights in this regard. The website administrator determines the scope, purpose and duration of the data requested when subscribing to the newsletter and other relevant conditions of processing for the purposes set out in this notice. 

Please only subscribe to the newsletter if you are over the age of 16!

1. Data controller: Egymás Kiadó Kft.
(Registered office: 1132 Budapest, Szent István park 17. I. em. 2.), e-mail: hello@egymas.hu, website: www.egymas.hu; hereinafter: “Publisher”). 

2. Scope of the processed data, purpose and duration of data processing

The data processed: the personal data provided at the time of subscribing (full name, e-mail address).

Purpose of data processing: the data will be requested for the purpose of sending you e-mails (e.g. newsletters and eDMs) in the future containing news, information on events, commercial advertisements, direct marketing and marketing matters about our products/services.

Duration of processing: until the user’s consent is withdrawn. The consent may be withdrawn any time by sending an e-mail to hello@egymas.hu or by clicking on the link in the newsletter.

Legal basis for data processing: voluntary, based on the data subject's consent, Article 6(1) point (a) of the GDPR, Section 13/A of the Electronic Commerce Act, and Section 6(1) of the Advertising Act.

3. By subscribing to the OTN newsletter, you consentthat the Publisher may track your activities (e.g. opening, clicks) in the newsletters sent to your e-mail address, and use them to display personalised advertisements, including third party advertisements, on its own or partners’ sites. Newsletters may also contain advertisements of third parties.

The provision of your data is voluntary. You are not obliged to provide your personal data, but without them we will not be able to inform you about our products and services. 

4. Profiling 

Profiling is any form of automated processing of personal data consisting of the use of personal data to evaluate, analyse or predict certain personal aspects relating to the user (characteristics of personal preferences, interests, health, behaviour, location or movements). 

After subscribing to the newsletter, the Publisher performs profiling on the basis of your consent, in order to provide you with offers tailored to your needs, wishes and interests. They may send offers via newsletters, in e-mails. 

5. Persons having access to personal data:

The data may be accessed by the Publisher's marketing staff, by the marketing agencies assigned by the Publisher, and by the Data Processors specified in this Notice, for the performance of their tasks. For example, the Publisher's administrator and the Data Processors specified in this Notice may access personal data for the purposes of administration and data processing. 

To carry out its activities, the Publisher uses the data processor named in this Notice. The Data Processor does not make any decision independently, and is entitled to act only in accordance with the contract concluded with the Publisher and the instructions received. The Publisher controls the work of the Data Processor. The Data Processor shall be entitled to use an additional data processor only with the prior written consent of the Publisher. 

Data and contact details of data processors:

Name of data processor: PW Stúdió Kft. 4024 Debrecen, Múzeum út 4. II. em.

Description of the operations performed by the data processor: ERP system operation, operation of servers for online sales systems on the physical and operational system level. Access to all personal data processed by the Publisher under this Notice.

Responsibility for the operation of the Publisher's customer relationship management (ERP) system and for providing the runtime environment for the Publisher's websites. Carrying out tasks related to the sending of e-mails to Users (in connection with this task, it has access to the following data: name, e-mail address, the fact that the subscriber is over the age of 16, the method of subscription.)
Actually managing the Publisher's promotional activities.

Duration of data processing and storage: according to the service contract, until the contract is terminated or the data subject's consent is withdrawn. 

6. Data security 

The Publisher is obliged to ensure the security of the data, to take technical and organisational measures and establish procedural rules to ensure that the data recorded, stored or processed are protected, as well as to prevent their destruction, unauthorised use or unauthorised alteration. In addition, it reminds third parties to whom the data subject's data were transferred of their obligation to comply with data security requirements. 

The Publisher ensures that no unauthorised persons can access, disclose, transfer, modify or erase any processed data. 

The Publisher makes all reasonable efforts to ensure that the data are not damaged or destroyed. The Data Controller shall also require its employees participating in the data processing activity, as well as the data processors acting on behalf of the Data Controller, to comply with the above commitment. 

7. Rights and legal remedies available to data subjects 

Under the GDPR, you may request access to your personal data, request information about the processing (to be provided by the Data Controller within 30 days at the latest), request the rectification or erasure of your personal data. The withdrawal of consent does not affect the lawfulness of processing based on consent prior to its withdrawal. You may request the restriction of processing and have the right to data portability. 

If you believe that the Data Controller has violated any legal provision applicable to data processing, please contact the Data Controller at first at the contact details above, or via e-mail at the address hello@egymas.hu. If this is unsuccessful, you may initiate a procedure at the National Authority for Data Protection and Freedom of Information (NAIH) (postal address: 1363 Budapest, Pf. 9.; registered address: 1055 Budapest, Falk Miksa u. 9-11.; e-mail: ugyfelszolgalat@naih.hu), or may turn to court. 

8. Record keeping

Please be informed that pursuant to Art. 6(1) of the Advertising Act, we keep a record of the personal data of persons who have given their consent, and will not send any further direct marketing e-mails containing advertising material, excluding general customer contact information, in the event of a request for erasure or restriction of the data subject or withdrawal of consent without explanation. 

9. Personal data relating to children and third parties 

Persons under the age of 16 may not provide their personal data unless they have obtained permission from a person with parental authority. By providing personal data to the Publisher, you represent and warrant to act in accordance with the above, and state that your capacity in relation to providing information is not restricted. 

In case you are not legally entitled to disclose any personal data independently, you are required to obtain the consent of the affected third parties (e.g. guardian, custodian or other person – such as a consumer – on whose behalf you are acting), or to offer other legal basis for providing such data. In this context, you are required to consider whether the consent of a third party is necessary in connection with providing certain personal data. It may occur that the Publisher is not in personal connection with you, therefore you are required to ensure compliance with this point, and the Publisher shall not be held liable in this respect. Nevertheless, the Publisher shall at all times be entitled to inspect the existence of the legal basis for the processing of personal data. For example, if you are acting on behalf of a third person – for example a consumer – we are entitled to request you to present your authorization and/or the appropriate consent of the data subject regarding the processing of their data in respect of the specific case. 

The Publisher makes all efforts to erase any personal data that has been provided to it unlawfully. The Publisher ensures that if it becomes aware of any such data, the personal data affected shall not be transferred to any other entity, and shall not be used by the Publisher. Please let us know immediately, using our contact information under Clause 1, if you become aware that a child has provided his/her own personal data or a third person has provided your personal data to the Publisher unlawfully. 

10. Miscellaneous 

This Privacy Notice has been drafted in Hungarian. 

Budapest, 12 December 2023.