Last updated: December 18, 2019
1. PURPOSE OF THE NOTICE
The purpose of this notice (hereinafter: “Notice”) is to present how KNP LAW Nagy Koppany Lencs & Partners (registered seat: H-1011 Budapest, Hunyadi János út 20.; website: www.knplaw.com; hereinafter: “KNP LAW” or “Controller”) processes personal data you provide and how KNP LAW ensures the safety of such personal data when you subscribe to KNP LAW’s newsletter.
2.WHAT IS PERSONAL DATA?
a, Personal data
Any and all information that refers to an identified or identifiable natural person (i.e., a human being – or “data subject” as used by the law) shall be considered personal data. A natural person is identifiable if that person can unambiguously be identified directly, or indirectly, i.e., especially on the basis of an identifier such as a name, number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, intellectual, economic, cultural or social identity of that natural person.
b, Special categories of personal data
According to the GDPR, special categories of personal data are personal data revealing the racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, furthermore genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
KNP LAW does not process any personal data within a special category in connection with sending newsletters.
3. LEGAL BACKGROUND OF DATA PROCESSING
As a controller, KNP LAW is committed to being compliant with the provisions of the prevailing national and European laws and regulations – especially the General Data Protection Regulation No. (EU) 2016/679 (hereinafter: “GDPR”) and Act XLVIII of 2008 on the Basic Requirements and Certain Restrictions of Commercial Advertising Activities, when processing the data of its clients, partners and other natural persons it comes into contact with.
Therefore, KNP LAW will take every reasonable measure to ensure the safety of the personal data you provide at the highest possible level and will within such scope take every necessary technical and organizational measure and develop the required procedural rules to protect the personal data processed by KNP LAW from unauthorized access, disclosure, unauthorized alteration and deletion.
4. WHAT IS THE PURPOSE OF DATA PROCESSING PERFORMED BY KNP LAW?
KNP LAW processes the personal data listed in Section 6 of this Notice to send newsletters containing summaries of news and developments (primarily associated with KNP LAW’s service profile) that we deem important to the email address you provide.
KNP LAW sends newsletters to subscribers once or twice a month on average.
5. LEGAL GROUNDS OF DATA PROCESSING
The primary legal basis of data processing is obtaining your consent to said processing in accordance with Article 6(1) a) of the GDPR. You can consent to data processing in the following ways:
a, provide your email address at section “SUBSCRIBE TO NEWSLETTER” on KNP LAW’s website and then click on the “SUBSCRIBE” button;
b, click on the related link included in the message sent to your email address to indicate your consent to receive newsletters from us in the future.
Accordingly, we will only contact you by email if you are or were our client or strategic partner and you have not subscribed to our newsletter yet and you have not indicated that you do not want to receive newsletters from us.
Your consent is given freely (you decide if want to receive newsletters from us or not) and can be withdrawn at any time. However, we hereby inform you that the withdrawal of your consent to data processing does not affect the lawfulness of the data processing performed by us prior to the withdrawal.
If you withdraw your consent, KNP LAW will no longer be able to send you newsletters.
6. WHAT KIND OF PERSONAL DATA IS PROCESSED BY KNP LAW?
In order to achieve the purpose specified in Section 4 of this Notice, KNP LAW processes the following personal data provided by you:
a, your email address; b) the fact that you have subscribed to the newsletter
7. HOW LONG IS THE PERSONAL DATA PROVIDED BY ME PROCESSED AND HOW CAN I UNSUBSCRIBE FROM THE NEWSLETTER?
We will process the personal data specified in Section 6 of this Notice for the maximum period of three (3) years from the date of your subscription or until after you have canceled your subscription from our newsletter.
Upon the expiry of the above period of data processing, we might request that you re-consent to the continuous receipt of our newsletters in a message sent to your email where you receive the newsletters.
You can unsubscribe from the newsletter of KNP LAW at any time by clicking on the link “Unsubscribe from newsletter” at the bottom of each newsletter sent by us.
8. DATA PROCESSORS USED BY KNP LAW
In the course of data processing in accordance with this Notice, KNP LAW engages the following data processors to perform certain data processing activities:
NAME OF DATA PROCESSOR
Data processing activity performed by the data processor
|CENTER.HU Kft.(registered seat: H-1094 Budapest, Tompa utca 13.; Company Registration No.: 01-09-681704)
|Operate the IT systems of KNP LAW.|
|Dr. Péter Hanák individual entrepreneur (registered seat:
H-2183 Galgamácsa, Hétház utca 25.; registration No.: 11780289)
|Operate the IT systems of KNP LAW.|
KNP LAW reserves the right to change or extend the above list of data processors, if necessary; however, you can request KNP LAW at any time to provide you with the information with the name and contact details of their data processors. KNP LAW undertakes to ensure that the data processors it engages fully comply with KNP LAW’s instructions and with the applicable laws and statutory provisions pertaining either to data protection or other issues within the scope of carrying out their data processing activities.
9. IS PERSONAL DATA TRANSFERRED TO A THIRD COUNTRY?
As a general rule, the personal data you provide to KNP LAW will not be transferred to a country outside of the European Economic Area (hereinafter: “EEA”). If, however, due to any rare and important reason it becomes necessary to transfer any personal data on an ad-hoc basis to a country outside of the EEA, KNP LAW undertakes to perform any such transfer exclusively in compliance with an adequacy decision in accordance with Articles 45-46 of the GDPR, and sufficient guarantees, or if a special condition stipulated in Article 49(1) of the GDPR is fulfilled.
10. WHO HAS ACCESS TO THE PERSONAL DATA I PROVIDE?
The personal data you provide is exclusively accessible (in addition to the data processor we use in the given field) to KNP LAW members and employees who are involved in ensuring newsletters are delivered to you.
11.WHAT RIGHTS DO I HAVE IN CONNECTION WITH THE PROCESSING OF MY PERSONAL DATA?
According to the applicable Hungarian and EU data protection regulations, you have the right to:
– receive confirmation / feedback of whether or not your personal data are being processed, and if they are, you are entitled to request access to your personal data. Within such scope you can receive the following information: the purposes of processing, the categories of personal data concerned, the recipients or categories of recipients to whom personal data have been or will be disclosed, the duration of data processing, the source of the personal data processed and your right to lodge a complaint with a supervisory authority (see the detailed description of such right in Article 15 of the GDPR);
– request the rectification of your inaccurate personal data or have your incomplete personal data completed (see the detailed description of such right in Article 16 of the GDPR);
– request the erasure of your personal data in cases specified by the GDPR (e.g., if you have withdrawn consent on which the processing is based or your personal data are no longer necessary in relation to the purposes of data processing) (see the detailed description of such right in Article 17 of the GDPR);
– request the restriction of the processing of your personal data in cases specified by the GDPR. You can request the restriction of your personal data if you contest the accuracy of your personal data processed by KNP LAW, or you object to the processing of your personal data or if KNP LAW processes your personal data unlawfully and you request the restriction of processing instead of the erasure of your data. You are also entitled to exercise this right if KNP LAW no longer needs your personal data for the purposes of the processing, but you require them for the establishment, exercise or defense of legal claims. If you have requested the restriction of the processing of your personal data in the above way, the data concerned can only be further processed (beyond their storage) within the narrow scope specified by the GDPR (e.g., if the personal data affected by the restriction are required to exercise legal claims) (see the detailed description of such right in Article 18 of the GDPR);
– exercise your right to data portability by requesting KNP LAW as Controller to provide you with your personal data in a structured, commonly used and machine-readable format or to transmit such data to another controller. You have the right to data portability if the processing is based on your consent or on the performance of a contract which you are a party to, and – in both cases – if the processing is carried out by automated means (for example within the scope of a computer system) (see the detailed description of such right in Article 20 of the GDPR).
12. RIGHT TO OBJECT
In addition to the rights specified in the previous Section, pursuant to Article 21 of the GDPR, you have the right to object to the processing of your personal data for newsletter purposes. If you exercise this right, KNP LAW shall no longer process your personal data for this purpose.
13. HOW CAN I EXERCISE MY RIGHTS AND HOW CAN I CONTACT KNP LAW IF I HAVE QUESTIONS REGARDING DATA PROCESSING?
If you want to exercise your above rights or you have any questions or comments regarding this Notice or regarding the data processing we conduct, please contact us via any of the below contact details:
Contact details of KNP LAW as controller:
Name: KNP LAW Nagy Koppany and Lencs Law Office
Address: H-1011 Budapest, Hunyadi János út 20.
KNP LAW strives to reply to your queries or perform your requests concerning privacy as soon as possible, but no later than one (1) month following the receipt of your message. Please note, however, that – if necessary due to the complexity and/or number of your requests – KNP LAW may, on the basis of the GDPR, extend the above deadline by two (2) additional months. We shall inform you about any eventual extension of the deadline within one (1) month following the receipt of your request.
If we find your request not to be grounded and, consequently, KNP LAW cannot perform your request, we shall send you a related notification (also including the details of our refusal) within one (1) month following the receipt of your request.
Please also note that we can only perform your requests related to the processing of your personal data we conduct following the verification of your identity, without which (e.g., via the telephone) we can provide general information only.
14. WHAT LEGAL REMEDIES DO I HAVE?
If you believe KNP LAW (or its data processors) violated your rights in the course of the data processing it carried out, you have the following options:
– contact KNP LAW directly via the contact details specified in the previous Section;
– lodge a complaint with any of the supervisory authorities (e.g., in Hungary with the Hungarian National Authority for Data Protection and Freedom of Information, hereinafter “NAIH”). Contact details of NAIH: registered seat: H-1125 Budapest, Szilágyi Erzsébet fasor 22/c.; Telephone: +36-1-391-1400; e-mail: firstname.lastname@example.org;
– initiate an action before the court if you believe that KNP LAW or one of its data processors processed your personal data unlawfully. In this case you are entitled to initiate the action – apart from applying the general rules on competence – before the county court having jurisdiction over your home address or place of residence. See the competences and contact details of the courts on the following website: www.birosag.hu
In any case we advise you to contact us first with your privacy related concerns, complaints or observations, and we will do our best to comply with your requests and observations.
15. PRIVACY NOTICE UPDATES
We may amend this privacy Notice (primarily in order to comply with any amended statutory requirements) in the future. The amendments of the privacy Notice shall enter into force when the updated version of the Notice is published on our website www.knplaw.com.The date of the last update of the privacy Notice is indicated at the top of the document.