Privacy policy

1. Introduction

Please read this Privacy and Data Protection Notice (the “Notice“), which describes our practices regarding the processing of your personal data in accordance with the General Data Protection Regulation (the GDPR, i.e. Regulation 2016/679 of the European Parliament and of the Council).

This Notice applies to you as a user of the Data Controller’s services. It describes how the Data Controller collects, uses and, in certain cases, shares your personal data with third parties and provides information about your rights in relation to data processing.

This notice governs the processing of the following pages:

Website: http://actpartner.hu:8080
Social media platforms: https://www.linkedin.com/company/act-partner-strategia-kft/; https://www.linkedin.com/groups/13969834/; https://www.linkedin.com/groups/13972752/

We summarise how the site owner may collect information about you and how it may be used.

The data will not be disclosed to unauthorised persons and will be used in the manner set out in this Notice.

This notice provides you with information about the protection of your personal data and your rights in this regard.

If, as a user, you do not accept these terms and conditions, you have the right to suspend your use of the website and to stop browsing without providing any personal data.

The Data Controller is committed to protecting the personal data and privacy of individuals who visit the website and related professional LinkedIn pages. This Notice is about the confidential treatment and protection of personal data of the following users via the Internet:

visitors to the pages,
downloaders of executive summaries,
those who request an initial telephone consultation,
those who send messages,
as well as those who request an email newsletter about blog articles or posts.

2. Responsibility and contact details of the data controller

2.1 Data Controller

ACT Partner Stratégia Kft. is the data controller (hereinafter referred to as the “Data Controller“) for the data processing described in this Notice.

Tax number: 14468687-2-13
Company registration number: 13-09-227029
Managing Director: Dr. El-Adlyné Sarkadi Ildikó Anna
Court of registration: Metropolitan General Court of Budapest

The Data Controller collects, stores and uses personal data only for specific purposes. The information collected is always relevant, appropriate and adequate for the purpose for which it is collected. We will only use your personal data for promotional purposes (selling your services) with your consent.

Data Controller

Responsibilities

ACT Partner Strategy Ltd.

1136 Budapest, Pannónia utca 26. 2. floor 2.

Total activity

2.2 Identity of the potential controllers who may access the data

The personal data may only be accessed by the managing director and internal employees of the Data Controller, they are not disclosed or given to third parties.

2.3 Contact with the Data Controller

You may contact the Data Controller in writing with any comments, questions or complaints regarding access to, deletion, modification or restriction of processing of your personal data, or regarding our data protection procedures, using the following contact details:

Registered office and postal address: 2120 Dunakeszi, Örvény utca 3.
E-mail: actpartner@actpartner.hu

3. The data processors used

3.1 Hosting service provider

Name: Comp-Dock Kft.

Head office: 1033 Budapest, Szentendrei út 89-95.
Tax number: 25740040-2-41
Company registration number: 01-09-308410
Phone: +36 30 319 3825
E-mail: advisor@compdock.hu

The fact of processing, the scope of the data processed: all personal data provided by the data subject on the website.

Data subjects: all data subjects using the website.

Purpose of data processing: to make the website available and to ensure its proper operation.

Duration of data processing, deadline for deletion of data: until the termination of the agreement between the Data Controller and the hosting provider or until the data subject’s request for deletion to the Data Controller.

3.2 Newsletter software

Name: SalesAutopilot Kft.

Location: 1024 Budapest, Margit krt. 31-33. mezzanine 4.
Service: MailMaster / SalesAutopilot
Tax number: 25743500-2-41
Company registration number: 01 09 286773
Phone: (+36) 1 490 0172

The fact of data processing, the scope of the data processed: personal data provided by the data subject on the website in the individual forms.

Data subjects: all data subjects who fill in a form on the website.

Purpose of data processing: to provide the service requested service or to contact.

Duration of data processing, deadline for deletion of data: data processing lasts until the termination of the agreement between the Data Controller and the Data Processor or until the data subject’s request for deletion to the Data Controller.

4. Management of cookies

In order to improve the quality of the service, data processors (see point 3) and companies related to data management (see point 7) may place a small data package, a cookie, on the user’s computer, on the data carrier of the device used by the visitor (computer, notebook, tablet, smartphone, etc.), subject to the user’s consent.

You may choose to access our website and LinkedIn pages without providing any personal information, but you must accept our cookie policy and, if you download our management materials, you must agree to the Privacy Policy and the Privacy Statement.

Legal basis for data processing

Duration of data processing

Article 13/A (3) of Act CVIII of 2001 on certain aspects of electronic commerce services and information society services (Elkertv.)

Period until the end of the relevant visitor session

Scope of the data processed: the use of cookies does not involve the processing of personal data by the Data Controller.

Data subjects: all data subjects visiting the website.

Purpose of the processing: to track visitors, improve the advertising system, provide statistics to help us monitor and improve our content creation and marketing activities.

The data subject has the possibility to delete cookies in the Tools/Settings menu of their browsers, usually under the Privacy menu settings.

5. Processing of personal data

5.1 Personal data

Personal data means any information relating to a natural person who can be identified, directly or indirectly, by reference to an identification number or to data relating to that number. The data are collected in a transparent and confidential manner.

Your personal data is information that allows us to identifies you, such as your surname, first name, telephone number, e-mail address. Your personal data is collected voluntarily by the website owner when you browse the site, indicating in each case the information that you need to provide in order to achieve the purpose. If you do not wish to provide this data, you will not be able to access certain functions and services of the website. The collection of optional data serves to understand user needs and to improve the website and its services.

5.2 Personal data processed

Surname, first name (full name)
Company name
E-mail address (business or private)
Telephone number (business or private)
System information (IP address, system version, resolution, statistics on pages viewed on the website, browsing habits, behaviour patterns)

5.3 Duration of processing:

With regard to contributions for newsletter purposes, until the user’s consent is withdrawn.
For profile data, 4 years from the last login.

5.4 Principles governing the processing personal data.

The processing of personal data must be lawful, fair and transparent for the data subject (“lawfulness, fairness and transparency”);
collected only for specified, explicit and legitimate purposes and not processed in a way incompatible with those purposes (“purpose limitation”);
be adequate, relevant and limited to what is necessary for the purposes for which the data are processed (‘data minimisation’);
be accurate and, where necessary, kept up to date; all reasonable steps must be taken to ensure that personal data which are inaccurate for the purposes for which they are processed are erased or rectified without undue delay (‘accuracy’);
it must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (‘limited storage’);
be processed in such a way as to ensure adequate security of personal data, including protection against unauthorised or unlawful processing, accidental loss, destruction or damage (‘integrity and confidentiality’), by implementing appropriate technical or organisational measures.

6. Conditions for data transmission

The Data Controller may, to the excent necessary, transfer the data processed by it to persons and companies designated by it as being active int the following areas:

Data processing
Legal representation
Bodies entitled by law to handle disputes
Marketing

6.1 Download executive summaries, request notification of tender news (newsletter)

The owner, ACT Partner Stratégia Ltd. is responsible for the management and processing of the data.

When downloading the executive summary materials, the User may give his/her prior and explicit consent to be contacted by the Data Controller at the contact details provided at the time of registration.

The fact of data collection, the scope of the data processed and the purpose of the processing:

Personal data	Purpose of processing
Name, e-mail address, optional: company name	Identify yourself, send the executive summary (pdf), subscribe to the newsletter
Date of subscription	Perform a technical operation
IP address at the time of subscription	Perform a technical operation

Stakeholders: all stakeholders who subscribe to the download of the executive summary and the newsletter.

Purpose of the processing: to send the executive summary (pdf) and to provide information on the latest information on the indicated call and related services.

Duration of data processing, deadline for deletion of data: users may unsubscribe from the sending of the offers without any limitation and without giving any reason, free of charge. In this case, the Data Controller will delete all personal data from its records and will not contact the User with further correspondence. The User may unsubscribe at any time by clicking on the link in the e-mail message.

The data processor used for data processing is: SalesAutopilot Kft., MailMaster / SalesAutopilot.

6.2 Sending a message, contacting for a telephone consultation

Please not the following:

By filling in the forms you consent to the processing of your data.
Please fill in the required personal data (marked with *) in the form so that we can reply to your message or to contact you by phone.
Failure to provide this information will result in our inability to fulfil your request.

The fact of collection, the scope of the data processed and the purpose of the processing:

Personal data	Purpose of processing
Name, e-mail address, company name, telephone number (business or private)	Identifying you, responding to your telephone request or processing your message
Date of completion of the form	Perform a technical operation
IP address at time of subscription	Perform a technical operation

Data subjects: all data subjects who send a message on the website and fill in the form.

Duration of processing, deadline for deletion of data: processing lasts until the case is settled.

Potentiel data controllers who may access the data: personal data may be processed by the Data Controller, in compliance with the above principles.

If the interested party becomes a client of the company, the validated Privacy Policy of ACT Partner Strategy Ltd. will apply.

7. Companies related to data management

In the course of the Data Controller’s activities, companies other than the owner are involved in the processing and storage of users’ data:

7.1 Google LLC

1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Other contact details, mailing system, data and file storage in the cloud. Services used by the owner: Google Search Console, Google Analytics, Google Tag Manager, Google Ads, YouTube, Chrome browser.

Google’s Terms of Service and Privacy Policy can be found at these links.

Google Ads for advertising:

When you visit a website through a Google Ads ad, a cookie is placed on your computer for conversion tracking. These cookies have a limited validity and do not contain any personal data, so they do not identify the User. Their purpose is to provide conversion statistics for the advertiser. If you do not wish to participate in conversion tracking, you can opt-out by disabling the option to set cookies in your browser.

When using Google Analytics:

The website uses the Google Analytics web analytics application. Google Analytics uses so-called “cookies”, text files that are saved on the User’s computer to help analyse the use of the website visited by the User.

7.2 LinkedIn

Contact: https://www.linkedin.com/help/linkedin/ask/ppq or LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland.

LinkedIn’s Privacy Policy and Cookie Policy can be found at these links.

The company pages identified in point 1 allow us to showcase and communicate with our core activities to targeted LinkedIn users.

We use the data you and LinkedIn provide directly for the sole purpose of branding, visibility, communication with customers and prospects for legitimate interests within the meaning of Article 6(1)(f) of the GDPR, in order to provide you with the most relevant and valuable information.

LinkedIn provides us with anonymised aggregated statistical data about the users and visitors of our LinkedIn page. These are recorded by LinkedIn when users and visitors interact with our company profile and related content.

Visitor activity:

Visiting pages, viewing posts, videos or other content related to pages
following or unfollowing pages
Like or unfollow posts, recommend pages or posts
comment on, share and respond to posts on pages
click on contact details, buttons.

If you are logged in to your LinkedIn account and visit our company pages, LinkedIn may link this to your profile and therefore to the personal information you publicly disclose in your profile (name, description, employee, work experience, skills, etc.).

8. Data ownership rights and enforcement

The data subject may request the controller to access, rectify, erase without justification or restrict the processing of personal data relating to him or her, and
object to the processing of such personal data; and
the data subject has the right to data portability and the right withdraw consent at any time.

You must send your request for erasure to the Controller in writing, by e-mail or by post, to the contact details indicated in point 2.3. The data subject subscribed to the e-mail newsletter can unsubscribe by clicking on the link in the e-mail.

9. Informing the data subject of the personal data breach

Where the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, the Data Controller shall inform the data subject of the personal data breach without undue delay.

The information provided to the data subject shall clearly and prominently describe the nature of the personal data breach and provide the name and contact details of the Data Protection Officer or other contact person who can provide further information; describe the likely consequences of the personal data breach; describe the measures taken or envisaged by the Data Controller to remedy the personal data breach, including, where appropriate, measures to mitigate any adverse consequences of the personal data breach.

The data subject need not be informed if the controller has implemented appropriate technical and security measures to ensure that the risk to the rights of the data subject is no longer likely to materialise.

10. Possibility to complain

Complaints against possible violations of the Data Controller may be lodged with the National Authority for Data Protection and Freedom of Information:

1125 Budapest, Szilágyi Erzsébet fasor 22/C.
Postal address: 1530 Budapest, P.O. Box 5.
Phone: +36 -1-391-1400
Fax: +36-1-391-1410
E-mail: ugyfelszolgalat@naih.hu

11. Concepts

Processor: a natural or legal person, public authority, agency or any other body that processes personal data on behalf of the controller.
Data processing: 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, organisation, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure, transmission, dissemination, making available by other means, alignment, combination, restriction, erasure, destruction.
Controller: the natural or legal person, public authority, agency or any other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of the processing are determined by Union or Member State law, the controller or the specific criteria for the designation of the controller may also be determined by Union or Member State law.
Transfer: the making available to third parties of personal data processed by the Controller.
Data breach: a breach of security resulting in the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or access to personal data transmitted, stored or otherwise processed.
Identifiable natural person: a natural person who can be identified, directly or indirectly, by reference to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity, such as name, identification number, location data, online identifier, etc.
Recipient: a natural or legal person, public authority, agency or any other body with whom personal data are disclosed, whether or not a third party.
Data subject’s consent: a freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she signifies his or her agreement to the processing of personal data concerning him or her by means of a statement or an unambiguous act of affirmation.
Data subject: a natural person identified or identifiable on the basis of any information.
Users: visitors to the website http://actpartner.hu:8080 and the LinkedIn page https://www.linkedin.com/company/act-partner-strategia-kft/, as well as to the professional pages https://www.linkedin.com/groups/13969834/ and https://www.linkedin.com/groups/13972752/, operated by the Data Controller.
Third party: a natural or legal person, public authority, agency or any other body other than the data subject, the controller, the processor or the persons who, under the direct authority of the controller or the processor, are authorised to process personal data.
Partner/Customer: a natural person who enters into a contract with the Data Controller for the sale of a product or the provision of a service, other than on a website.
Personal Data: 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, 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;
Service: services provided by the Data Controller to its customers, partners and users on the Website or otherwise.

12. Amendment of the Privacy Notice

The Data Controller reserves the right to amend or update this Privacy Notice at any time without prior notice and to publish the updated version on its website. Any modification will apply only to personal data collected after the publication of the modified version.

Last update: May 2023