In order for you to use our services (for example purchase database or subscribe to our newsletter), it is inevitable that we process certain personal data. In this Notification, we describe in detail which of your personal data will be processed for what purpose and duration, to whom it will be transferred and for what reason, furthermore, we provide information on your related rights.

Please read this Information carefully, should any questions arise, please write to us at the info@opten.eu address before accepting the Information!

We call your attention in advance that you are entitled to object to the processing of your personal data at any time if they are processed for our justified legitimate interest or for the purpose of advertising!

Your data will be processed by OPTEN Informatikai Kft. (registered office: H-1138 Budapest, 22. Népfürdő str., Duna Tower, tower ’B’, floor 11.; Company Reg. No.: 01-09-367756) as data controller (hereinafter: “Opten”).

Contact:

• postal address: H-1138 Budapest, 22. Népfürdő str., Duna Tower, tower ’B’, floor 11.

• e-mail: info@opten.eu

• phone: +36-1-222-31-30

• website: www.opten.eu (“Website”)

• name of the representative of the data controller: Tamás Tóth Managing Director

• name and contact details of the data protection officer: Gergely Ferenczi, info@opten.eu

2.1. Every personal detail is processed for a definite purpose outlined below and the purposes are not connected to each other (for example we send you newsletter only if you expressly have given your consent for it upon contracting). If we wish to process your personal data for a purpose other than specified earlier, we will notify you on its details in advance.

2.2. Each data processing may have different legal basis depending on the purpose of the data processing: it may be done due to legal obligation (for example accounting) or the completion of the contract made with you, or possibly to enforce our legitimate interest (for example settlement of legal disputes), or even based on your consent:

2.3. The data processing purposes and the related legal bases are summarised in the table below.

3.1. Personal data is all such information which is applicable to you as natural person and according to which your person is directly or indirectly identifiable (for example customer identification, billing and contact details).

The personal data processed by data processing purpose can be found in the following table.

4.1. We process your personal data for the shortest possible time necessary for the given service. Upon expiration of this duration, we delete your digitally stored personal data, your data kept on paper will be destroyed.

4.2. The deeds, documents for the fulfilment of the tax and accounting obligations shall be kept by us for the duration specified by legislation (the accounting documents for at least 8 years, the taxation and VAT payment documents for at least until the expiration of the right of tax assessment).

4.3. In case of every data processing purpose listed we are entitled to process the personal data (according to legitimate interest and in case of condition providing ground for it) until the end of the enforceability of our legal claim.

4.4. The personal data processed and the related data processing durations are summarised in the table below.

5.1. We transmit some of your personal data to a so-called data processors (in some cases to other data controllers). The data transmission may take place due to the completion of the contract made with you or the improvement of our services.

5.2. For the company below – to perform the online payment – we may transmit some of your personal data according to your consent. OTP Mobil Kft. In order to perform the online payment OTP Mobil Kft. processes the following personal data: the number of the used bank card, the name on the card, the expiry date of the card and the CVC (security) code. This data processing based solely on your consent, while in the absence thereof, you will be unable to use the online payment function. By the acceptance of this Privacy Notice Opten considers your consent is to be given.

5.4. The recipients of the data transmissions related to each data processing purpose are summarized in the table below:

In the following, we present your rights and (in case of complaint or legal dispute) legal remedy options in connection with the Opten’s data processing.

6.1. Withdrawal of consent

You have the right to withdraw this consent free of charge, unconditionally if the legal basis of our given data processing is your consent (see the above tables). Upon the withdrawal of the consent we delete your personal data. For example if you unsubscribe our newsletter, we will delete all of your data provided at subscription and you will not receive any more newsletters from us.

It is important to know that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal! Moreover, in certain cases, in case of the withdrawal of your consent we may lawfully continue to process your personal data – we inform you on such case in details.

6.2. Access to your personal data

You may request information at any time whether we process your personal data for any purpose. If we to, we send you electronically (or on paper if requested) a copy of all data processing activities concerning you, and we also inform you on your related rights.

6.3. Rectification

You may indicate to us at any time if you notice any mistake in any of your personal data processed by us or you can request to complement or clarify them or transfer your new data into our records (for example in case of changing address of residence).

6.4. Deletion

You may request at any time to delete some or all of your personal data processed at us. We will delete your personal data also in the following cases: consent has been withdrawn; duration of data processing has expired; the deletion is mandatory due to legal rule or we do not need to process the given personal data any longer.

It is important to know that in some cases, the processing of your personal data for a specified duration is prescribed by legal rule, in other cases they are to be kept due to the enforcement of our legal claims. Should there be any obstacle to the deletion of your personal data, we will notify you about it in detail.

6.5. Restriction of data processing

It may be possible that neither the continuation of data processing, nor the deletion seems to be appropriate for you. In such cases you may request the restriction of your personal data: the personal data affected by restriction will only be stored, we will not perform any other operation on them.

You may request the restriction of data processing if:

• You assume that your data appear incorrectly in our database (in this case we investigate the occurrence: the restriction is active until the end of the investigation); or

• You assume that we process your data unlawfully but at the same time you are against their deletion; or

• we do not need to process your personal data any longer but you request not to delete them because you may need them at a later time for the enforcement of your legal claim; or

• You object to the data processing (see below; in this case we investigate the occurrence, the restriction is active until the end of the investigation).

It is important to know that the data restriction ordered upon your request may be lifted and we may continue the data processing if you expressly approve or it is needed for the enforcement of our legal claim or due to important public interest prescribed by legal rule – in this case we will inform you in advance.

6.6. Objecting to the processing of your personal data

You are entitled to object to the processing of your personal data for personal reasons at any time if they were used for sending advertisements or the legal basis of the data processing was marked as legitimate interest. In such cases we delete your personal data.

It is important to know, however, that if the legitimate interest was marked as legal basis of the data processing, then we may process your personal data against your objection. For this, however, we must prove that we unavoidably need to process your data or it is indispensable for the enforcement of our legal claims – in such cases we will inform you on this in advance.

6.7. Data transport

You are also entitled to receive the personal data you made available to us in an electronically editable format and send them to a another data controller or ask us to send them for you.

(So the data transport differ from the access right mentioned above that in the former case we provide only those personal details which you have given to us and those which we recorded based on your activities. However, this does not apply to those data which were generated by us from those listed through derivation/conclusion.)

This data transport is available for you only if the above indicated legal basis of your personal data is the consent or the completion of the contract. A further condition is that these personal data is processed in automated way. In any other cases the data transport is not available to you.

We call your attention that we can send your data upon your request directly for you to another data controller if it is technically feasible in that actual case – we will inform you on this in advance.

6.8. Right to complaint

Should you feel that we violated the legal rules appertaining to the processing of personal data during our data processing, you may file a complaint at the National Authority for Data Protection and Freedom of Information (NAIH) at the following contacts:

• registered address: 9-11, Falk Miksa St., Budapest, 1055

• postal address: 1363 Budapest P.O. Box: 9.

• e-mail address: ugyfelszolgalat@naih.hu

• website: http://www.naih.hu/

We are pleased if you ask us first with your complaint to have it investigated and rectified!

6.9. Right to apply to the courts

Should you feel that we violated your rights during our data processing, then (according to your choice) you may apply to the competent regional court of your residence. Further details on the judicial proceedings are available at the birosag.hu website.

7.1. Administration of applications

You can exercise your rights detailed above at any time, for this, just send an e-mail to the info@opten.eu address. (Of course, the submittal of a complaint or the court proceedings can be initiated at the NAIH and the competent court, respectively.)

Upon your request (particularly in case of rectification of data) we will try to act without undue delay and in any event within 1 month of receipt of the request. In case of an especially complex or extensive request, this administration deadline may be extended with 2 months at most.

We call your attention that prior to the completion of your request we are entitled to identify you in order to prevent the disclosure of data for unauthorized persons, and the completion of unauthorized requests (for example for data deletion).

We also call your attention that if your request is clearly unfounded, excessive or abusive, or if we were unable to identify you, then the action will be denied.

7.2. Data Security

We store your personal data on own servers (with antivirus protection, firewall and strong password) guarded by security service, the paper-based data are kept in lockable, fireproof lockers. We perform regular backups on the servers.

The personal data are accessible within the organization of the data controller only by the authorized employees, the data is transmitted in all cases in encrypted form to the data processors to whom our strict data security requirements also apply.

7.3.Your Responsibility

For the accuracy and protection of your personal details processed by us you are requested to make every reasonable effort to keep your personal data up-to-date in our databases:

• Since we cannot check the accuracy of the personal data provided and whether they have been provided by the duly authorized person, we ask you that in all cases provide only and exclusively your own personal details. We will not take any responsibility for any impairment of rights or damage resulting from the processing of personal details provided on behalf of other person.

• Use secure technical devices, software, network connections and passwords to prevent any unauthorized abuse of your personal data (for example prevent logging in to your account thus preventing the submittal of unauthorized requests to us).

• Should you detect any suspicious condition, notify us immediately.

• If any changes have occurred in your personal data you provided to us, notify us preferably in 3 days in the way described above.

7.4. Amendment of the Notice

The Notice may be unilaterally amended at any time: in such cases we notify you in advance via e-mail on the fact and the essence of the amendment and the time of its entry into force. The actual, up-to-date version of the Notice is always available at our website.

To any issues not covered in the Notice, the General Data Protection Regulation 2016/679 of the European Union (also known as GDPR) and the applicable Hungarian legislation shall apply. The Hungarian law shall apply to this Notice.