PRIVACY POLICY

NOW technologies Zrt.

Last updated: 2018

This privacy policy (“Policy”) explains how NowTechnologies Zrt. a corporation operating under the laws of Hungary (H-1092 Budapest, Köztelek utca 6., City Gate Offices, Building 1, Floor 1, Hungary, registration number 01-10-048063, tax number: 24918028-2-41; hereinafter: “Company” “we” or “us”) processes personal data collected from our customers (“Customer” or “user”) using our online shop on our website located at www.nowtech.hu (“Website”) or subscribing for our newsletter (“Newsletter”) further from the representative our business partners (“Customer” and “Representative” hereinafter jointly: “you”).

The processing and collecting of personal data by the Company shall be in harmony with the directly applicable laws of the European Union and the provisions of the Hungarian laws in effect. In case of personal data processing, the Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter: “GDPR”; for relevant definitions please see Appendix No. 1), the Act CXII of 2011 on the Right to Informational Self-determination and Freedom of Information (hereafter: “Freedom of Information Act”), the Act XLVIII of 2008 on the essential conditions and certain limitations of business advertising activity (hereinafter: “Business Advertising Act”), furthermore the recommendations and the data protection practice of the Hungarian National Authority for Data Protection and Freedom of Information (hereinafter: “NAIH”) and the recommendations of the Article 29 Data Protection Working Party (hereinafter: “WP29”) shall apply.

The Company is data controller of any data which constitutes personal data and is uploaded and collected when subscribing for the Newsletter and the order initiated on the Website. The Company will keep confidential the received personal data of data subjects and takes all necessary steps to secure data processing.

1          WHAT INFORMATION DOES THE COMPANY COLLECT?

1.1       Information You Provide to Us on the Website:

The Website is free to visit without providing any personal data. The Company does not collect or process personal data regarding the visitors.

1.1.1     Newsletter-subscription

The service available on the Website requires subscription on the Website, whereby the following personal data shall be given for the registration:

  • Name
  • E-mail address

 

1.1.2     Product order

The Company offers its products on the Website and operate a web shop on the Website where the Customer can initiate an order. The Company requires the following personal data, when the Customer initiates an order on the Website:

  • Name
  • E-mail address
  • Telephone number
  • Postal and invoicing address

 

1.2       Connecting Distributors

The Company from time to time may collect data from publicly available sources on possible distributors in order to extend and improve the distribution of its products. These data may contain: i) name, ii) e-mail address, iii) registered office of the distributors, iv) telephone number, v) postal address, vi) tax number. If the Company collects and processes such data, the following provisions shall be abide by the Company, if the data protection regulations which the Company is subject are applicable to the distributor.

2          THE PURPOSE, LEGAL BASIS AND DURATION OF DATA PROCESSING

2.1       In case of Newsletter-subscription

Purpose of data processing: sending Newsletter to the User registered through the Website, in order to explore interest about the products developed by and the news about the Company.

Duration of data processing: starts by the subscription for the Newsletter and ends by the withdrawal of consent of the User on the Newsletter, as well as by the realization of the purpose of data processing, or until other date prescribed by law.

Legal basis of data processing: the consent of the User (subscribing to Newsletter), and Section 6 of Business Advertising Act.

If the User has given his or her consent to receive Newsletter from the Company to his or her email address, the User may freely withdraw his or her consent without any restriction and justification by email sent to the following address of the customer service: Info@nowtech.hu or by a declaration addressed to the Company, sent by post to the registered seat of the Company.

2.2       In case of Product order

Purpose of data processing: to perform the certain order and to perform the contract concluded between the customer and the Company regarding the ordered product.

Duration of data processing: starts by the initiation of the order and ends by the performance of the order respectively of the contract regarding the warranty period and the support period provided by the Company or upon or any other date prescribed by law.

Legal basis of data processing: performing the contract and legal obligation of the Company to keep the invoices for 8 years.

2.3       In case of collecting data of distributors

Purpose of data processing: to build B2B business with several distributors.

Duration of data processing: starts by the initiation of the business relationship and ends by the ending of the business relationship respectively by ending the warranty period of the contract between the Company and the distributor, or until the legitimate claim of the Company can be enforced.

Legal basis of data processing: legitimate interests of the Company for building business, performance of the contract.

3          What About Cookies?

We collect anonymous data from the Website. The anonymized data can include user session data such as web browser type, the time spent on the page by the user, and user-clicked buttons. We process anonymous data in order to improve the page, to bring it to perfection. During this procedure we can incorporate “cookies”, which collect the visitor’s first level domain name, the date and the exact time of access. The “cookie” alone can’t be used to reveal the identity of the visitor. The “cookie” is a file, which is sent to the browser of the visitor and stored on the hard drive of the visitor. Cookies don’t damage the computer of the visitor. The browser can be set to indicate when a cookie is received, so the visitor can decide to accept the so-called cookie or not. We do not collect or manage any information that would allow the identification of the visitor.

4          Data integrity and purpose limitation

We only collect and retain personal data which is relevant to the purposes for which the data is collected, and we will not use it in a way that is incompatible with such purposes unless such use has been subsequently authorized by you. We will take reasonable steps to ensure that personal data is reliable for its intended use, accurate, complete and current. We may occasionally contact you to determine that your data is still accurate and current. To secure your personal information processed we save your personal information to backup archives in every two weeks. The data stored in our backup archives will be deleted in every 5 years.

5          RIGHTS OF THE DATA SUBJECTS

5.1       Right to be informed, Right of access and to rectification: You have the right to obtain confirmation of whether or not we are processing personal data relating to you, have communicated to you such data so that you could verify its accuracy and the lawfulness of the processing and have the data corrected, amended or deleted where it is inaccurate or processed in violation of the GDPR.

5.2       Right of Erasure: In certain circumstances, you may have a broader right to erasure of personal information that we hold about you – for example, if it is no longer necessary in relation to the purposes for which it was originally collected. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.

5.3       Right to Object to Processing: You may have the right to request us to stop processing your personal information and/or to stop sending you marketing communications.

5.4       Right to Restrict Processing: You may have the right to request that we restrict processing of your personal information in certain circumstances (for example, where you believe that the personal information we hold about you is inaccurate or unlawfully held).

5.5       Right to Data Portability: In certain circumstances, you may have the right to be provided with your personal information in a structured, machine readable and commonly used format and to request that we transfer the personal information to another data controller without hindrance

7          DATA TRANSFER, DATA PROCESSING

7.1       The Company shall not ensure access for a third party to personal data provided by the Data subject without the preliminary consent of the Data Subject, except the cases, when the Company’s data transfer is prescribed by law.

7.2       The Company requests data process service for processing the personal data. During the service of data process, the data processor shall abide under the present Policy, relevant legislations in force, furthermore the provisions of the existing contracts of the Company.

The Company uses the data process service of the following companies:

 

Name Registered seat Activity (data processing service)
Elastic Inc. 1955 Landings Drive, Mountain View, CA 94043, USA CRM cloud service through close.io website to store the personal data
Google LLC 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA Google mail service to send e-mail during the support period.
Slack Technologies Limited 4th Floor, One Park Place, Hatch Street Upper, Dublin 2, Ireland Online workplace productivity tools and platform to manage the orders and supports for each product.
The Rocket Science Group LLC 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA MailChimp service to provide the Users with Newsletter.

 

There is no further data transfer relating to personal data processed by the Company.

7.3       Transfer of Personal Data collected from individuals located within the EU:

We only transfer personal data collected from individuals located within the EU to a third-party having a registered seat outside the EU or the United States of America acting as a data processor without appropriate safeguards when it is necessary for the performance of the contract. We will make every effort to ensure that the personal data transferred is safe and secure and that the personal data is processed in a manner consistent with the GDPR.

Based on the adequacy decision by the Commission of the European Union regarding third countries like United States (Privacy Shield) ensures an adequate level of data protection. Due to the fact that our service providers, Google LLC, The Rocket Science Group LLC have their registered seat in the USA and comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework, the transfer of your personal data to the mentioned service provider can take place.

 

 

8          RIGHT TO REMEDY

8.1       You may exercise your rights by email sent to Info@nowtech.hu or by a declaration addressed to us, sent by post to our registered seat.

8.2       If you don’t agree with our decision, you have the right to an effective judicial remedy or to lodge a complaint to the NAIH (registered seat: H-1125 Budapest, Szilágyi Erzsébet fasor 22/C., Website: http://www.naih.hu), or to any other competent supervisory authority of the European Union Member State.

9          Amending the Policy

We reserve the right to change the Policy, or to modify it according to the changes in the applicable laws of the European Union law or the Hungarian law.

The present Policy shall enter into force on June 01, 2018

  1. Questions

If you have any questions concerning this Policy or the Services, please contact us at Info@nowtech.hu . You can also contact us at our contact office at H-1053 Budapest, Reáltanoda utca 18., Hungary.

 

  • • •

 

Appendix No. 1

 

The following definitions are determined according to the GDPR:

 

‘personal data’: shall mean any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

 

‘consent’: shall mean any freely given, specific, informed and unambiguous indication of the will of the data subject by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

 

‘data controller’: where the purposes and means of such processing are determined by European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by European Union or Member State law;

 

‘data processing’: shall mean any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

 

‘data processor’: shall mean a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

 

‘third party’: shall mean a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data;

 

‘personal data breach’: shall mean a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed;

 

‘recipient’: shall mean a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with European Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;

 

‘supervisory authority’: shall mean one or more independent public authorities provided by each European Union Member State which is responsible for monitoring the application of the GDPR in order to protect the fundamental rights and freedoms of natural persons in relation to processing and to facilitate the free flow of personal data within the European Union;

 

‘supervisory authority concerned’: shall mean a supervisory authority which is concerned by the processing of personal data because: a) the controller or processor is established on the territory of the Member State of that supervisory authority; b) data subjects residing in the Member State of that supervisory authority are substantially affected or likely to be substantially affected by the processing; or c) a complaint has been lodged with that supervisory authority.