DATA MANAGEMENT INFORMATION

1. GENERAL PROVISIONS

(1) By using positivepsychologyteacher.com (Website), you agree to be bound by the provisions of this Privacy Policy. 

Data Controller (also the Service Provider) in respect of this notice:

Name: Mental Focus Korlátolt Felelősségű Társaság
Head office: 1611 Budapest, Kenéz utca 29.
Registration number: 01-09-983249
Court of registration: the Commercial Court of the Metropolitan Court of Budapest
Tax number: 23896406-2-42

Address for correspondence: 1147 Budapest, Miskolci u. 56.
E-mail: info@mentalfocus.hu
Phone number: +36 70 883 8194

(2) The purpose of this privacy statement is to define the scope of the personal data processed, the way in which the data are processed, to ensure compliance with the constitutional principles of data protection and data security, and to prevent unauthorised access to, alteration of, and unauthorised disclosure or use of the data, in order to respect the privacy of the natural persons of the user.

 (3) For the purposes of paragraph (2), we will treat your personal data confidentially and in accordance with the applicable legal provisions, ensure their security, take the technical and organisational measures and establish the procedural rules necessary to enforce the relevant legal provisions and other recommendations.

2. LEGAL BACKGROUND

Our processing is governed primarily by the provisions set out in the following legislation:

  • Act V of 2013 on the Civil Code, Act 2:43 § e.) (“Civil Code”)
  • Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information (“Data Protection Act”);
  • Regulation (EU) 2016/679 of the European Parliament and of the Council (“GDPR”)
  • Act CVIII of 2001 on certain aspects of electronic commerce services and information society services (“Eker. tv.”);
  • Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions on Commercial Advertising Activities (“Act XLVIII of 2008”)
  • Act No VI of 1998 on the proclamation of the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data, signed in Strasbourg on 28 January 1981;

3. THE SCOPE OF THE DATA PROCESSED, THE PURPOSES, LEGAL BASIS AND DURATION OF THE PROCESSING

3.1 Training application, contracting and invoicing

When you apply for a training course, we process the following personal data, which you must provide, without which your application will not be processed:

  • Surname and first name
  • e-mail address
  • billing address

The purpose of the processing is: to ensure the enrolment for the training of your choice; to conclude and perform the related service contract; to make the payment for the use of the service and the related invoicing. 

The legal basis for processing is Article 6 (1) (b) GDPR and § 13/A of the Eker tv – performance of the contract/provision of the service. Article 6(1)(c) GDPR with regard to the data contained in the invoice fulfilment of the legal obligation pursuant to Article 169(1) of Act C of 2000 on Accounting

Duration of data processing: data relating to the application will be stored for the purpose of providing evidence in the event of a dispute, until the general limitation period of 5 (five) years.

In order to fulfil our accounting obligations, we keep the invoicing data for 8 (eight) years pursuant to Article 169 of Act C of 2000 and until the statute of limitations set out in Act XCII of 2003 on the Rules of Taxation.

3.2 Product purchase and invoicing

If you order a product (“boxed” training material) from us, we will process the following personal data, which is necessary for you to purchase products through the Website:

  • Surname and first name
  • e-mail address
  • billing address

Purpose of data processing: fulfilling and completing the order and payment process; invoicing.

The legal basis for processing is Article 6 (1) (b) GDPR and § 13/A of the Eker tv – performance of the contract/provision of the service. Article 6(1)(c) GDPR with regard to the data contained in the invoice fulfilment of the legal obligation pursuant to Article 169(1) of Act C of 2000 on Accounting

Duration of data processing: data relating to orders are stored for the purpose of providing evidence in the event of disputes, until the general limitation period of 5 (five) years.

In order to fulfil our accounting obligations, we keep the invoicing data for 8 (eight) years pursuant to Article 169 of Act C of 2000 and until the statute of limitations set out in Act XCII of 2003 on the Rules of Taxation.

3.3 Sending notifications

For non-promotional purposes, we will send you a message to the email address you provided when you registered for training and/or purchased a product:

  • to send you the information you need to participate in the training
  • to send the link to download the product online
  • to send the fee request (if you choose to pay by bank transfer)
  • for the purpose of sending the invoice 

If you have not given your consent to receive a newsletter, such non-promotional e-mails may not contain advertising.

Purpose of the processing: to provide you with personalised service and to fulfil the contract you have entered into with us for the provision of services

Legal basis for data processing: article 6 (1) (b) GDPR and § 13/A Eker tv.

3.5 Use of cookies

What cookies do we use? There are some cookies that we must store, without them the Website cannot function. These are the so-called technically necessary cookies. We are entitled to use these cookies without your permission.

  • cookies that store information about you: these cookies are automatically deleted from your computer when you close your browser.  These cookies are only used to identify your computer and do not store any personal information about you.
  • authentication session cookies: these are used to identify users after they have logged in so that we can ensure that users can access personal pages, and they ensure that you do not have to log in again and again after each click while navigating.
  • user-centric security cookies: cookies that are designed to perform specific tasks related to enhancing the security of a service that the user has specifically requested. Examples include cookies used to detect repeated failed login attempts to the Website, or other similar mechanisms designed to protect the login system from abuse. Although logon cookies are usually set to expire at the end of the session (when you exit the browser program), security cookies have a longer expected expiry time to achieve their security purpose.
  • user interface customisation cookies are used to store user preferences for the service through Websites that are not linked to other persistent identifiers such as username (e.g. cookies for preferred language, cookies for preferred display of results when queried).

There are cookies that we can only use with your prior consent. These are:

  • Cookies to improve performance: collects information about how you use the Website. Google Analytics cookies are used to help us better understand the behaviour and characteristics of our users: which sub-pages they visit, how often they visit and for how long. These cookies only identify your computer and the data collected is anonymous.
  • Functional cookies: they allow the Website to remember your previous preferences, thus providing you with a higher quality, personalised service. They may also contain personal information that you have provided to our site.
  • Targeting cookies: allow us to display targeted, relevant ads to you. These cookies also allow you to connect to social networking sites. They only identify your computer and the data collected is anonymous.
  • We use remarketing services to deliver our personalised ads to you:
  • Google Adwords: is used to remember your recent searches, your previous interactions with each advertiser’s ads or search results, and your visits to advertisers’ websites. The AdWords conversion tracking feature uses cookies. To track ad sales and other conversions, cookies are saved on a user’s computer when they click on an ad.
  • Google Analytics:Google Analytics is Google’s analytics tool that helps website and application owners to get a more accurate picture of their visitors’ activities. The service may use cookies to collect information and report statistics about website usage without identifying visitors individually to Google. In addition to generating reports on site usage statistics, Google Analytics, together with some of the advertising cookies described above, may also be used to display more relevant advertising in Google products (such as Google Search) and across the web. Read more http://www.google.com/analytics/
  • Facebook Pixel, also known as Facebook pixel: code placed in the source code of the Website that is used to display personalised ads to visitors of the Website on Facebook.
  • Read more https://www.facebook.com/business/help/651294705016616 

Legal basis for processing: your prior, voluntary consent
Duration of processing: until your consent is withdrawn. Please note that the withdrawal of your consent does not affect the lawfulness of the processing carried out on the basis of your consent prior to its withdrawal.

3.6 Log files (logfiles

In order to use the services, the system automatically logs the following data:
-the dynamic IP address of your computer
-depending on your computer settings, the type of browser and operating system you use
-your activity on the Website
-date of activity

Purpose of the processing:
The use of this data is for technical purposes, such as analysing the secure operation of the servers, and for the purpose of post-checking, and is also used to compile statistics on the use of the site and to analyse user needs in order to improve the quality of the services. The above data cannot be used to identify you and will not be linked to other personal data. 

Legal basis for processing: legitimate interest of the Service Provider pursuant to Article 6 (1) (f) of the GDPR

Data storage period: 90 days from the date of creation

An interest balancing test has been carried out with regard to the processing pursuant to Article 6(1)(f) of the GDPR and as a result it can be concluded that your interests as a data subject do not necessarily prevail over the legitimate interests of the Data Controller and that the processing does not restrict your privacy as a data subject.

3.7 Processing other than for the purposes set out above 

We may only process personal data relating to you for any purposes other than those set out above, in particular to improve the efficiency of your service or for market research purposes, subject to the prior specification of the purpose of the processing and your consent. Such data may not be linked to your identification data and may not be transferred to third parties without your consent. We are obliged to delete this data if the purpose of the processing ceases to exist or if you so request.

4. THE DATA PROCESSORS’ DETAILS AND CONTACT DETAILS:

a.) We use Google Anatitycs software to obtain independent visitor and other web analytics data from www.positivepsychologyteacher.com, and Google Inc. acts as the data processor for this data. Google Inc. Privacy Policy is available at http://www.google.com/intl/hu ALL/privacypolicy.html.
By using this website, you consent to the processing of your data by Google.

b.) For invoicing, we use the online invoicing software samlazz.hu, which is operated by:
Company name: KBOSS.hu Kft.
Headquarters: 2000 Szentendre, Táltos utca 22/b
Phone number: +36-20-469-4994
E-mail address: info@szamlazz.hu

c.) Newsletter providers that contribute to the sending of the newsletter. In doing so, they process the name and e-mail address of the data subject to the extent necessary for the purposes of sending the newsletter.

Name: Active Campaign
Location: 160 Shelbourne Rd, Dublin, D04 E7K5, Suite 03-101, Dublin, Dublin, 2
Phone number: +1 (800) 357-0402
Website: https://www.activecampaign.com

d.) Details of our hosting provider:
Hosting provider name: Contabo GmbH
Location: Aschauer Straße 32a, 81549 Munich
E-mail address of the hosting company: info@contabo.com

We reserve the right to engage additional processors to those listed above, provided that the names and addresses of such additional processors are disclosed in a manner accessible to users no later than the start of processing.

5. HAVE THE RIGHT TO ACCESS PERSONAL DATA:

Our own employees, agents and other intermediaries who need to know the data processed in order to carry out their duties or to perform the tasks they are required to perform. We are committed to ensuring that those who have access to the data we process comply at all times with the requirements of this Privacy Notice and the applicable law. 

6. YOUR RIGHTS IN RELATION TO DATA PROCESSING

You can send your request to exercise your rights regarding data processing to the following e-mail address: info@positivepsychologyteacher.com.

6.1 Right to request information

(1) At your request, we will inform you about the data processed by us or by a data processor on our behalf, the source of the data, the purpose, legal basis and duration of the processing, the name and address of the data processor and its activities in relation to the processing, and, in the case of transfer of your personal data, the legal basis and the recipient of the transfer.

(2) The information shall be free of charge. However, if the request is manifestly unfounded or excessive, in particular because of its repetitive nature, subject to the administrative costs of providing the information or information requested or of taking the action requested:
a) we may charge a reasonable fee, or
b) refuse to act on the request.
In all cases, we have the burden of proving that the request is manifestly unfounded or excessive.

6.2 Right to cancellation

(1) We are required to delete personal data if.
a) unlawful treatment;
(b) you withdraw your consent on the basis of which the data are processed or request the erasure of your data and there is no other legal basis for the processing;
(c) it is incomplete or incorrect, a situation which cannot be lawfully remedied, provided that cancellation is not precluded by law;
(d) the purpose of the processing has ceased or the statutory time limit for the storage of the data has expired;
(e) the deletion of the data has been ordered by a court or the Authority.

(4) Instead of deletion, we will block the personal data if you request it or if, on the basis of the information available to us, we have reason to believe that deletion would harm your legitimate interests. Personal data blocked in this way may be processed only for as long as the processing purpose which precluded the deletion of the personal data is pursued.

6.3 Right of access

(1) You have the right to receive feedback from us as to whether your personal data is being processed and, if such processing is ongoing, you have the right to access your personal data and the following information:

  1. the purpose of the processing
  2. the categories of personal data concerned
  3. the recipients to whom we have disclosed or will disclose your personal data, in particular to recipients in third countries or international organisations
  4. the period for which the personal data are stored or, if this is not possible, the criteria for determining that period
  5. your right to request us to rectify, erase or restrict the processing of personal data concerning you and to object to the processing of such personal data; 
  6. the right to lodge a complaint with a supervisory authority; 
  7. if the data was not collected from you, any available information about its source


(2) We will provide you with a copy of the personal data processed. For any additional copies requested by you, the controller will charge a reasonable fee based on the administrative costs. If you have submitted your request electronically, we will provide the information in a commonly used electronic format, unless you request otherwise.

6.4 Right to rectification

(1) At your request, we will correct inaccurate personal data about you without undue delay. 

(2) If the correctness or the supplementary information is not available, the correction and completion will be made by means of a supplementary declaration.

6.5 Right to object

(1) You may object to the processing of your personal data if.

  1. where the processing or transfer of personal data is necessary for the fulfilment of our legal obligations or for the purposes of our legitimate interests or those of a third party, including profiling based on those obligations, except in cases of mandatory processing;
  2. if the personal data are used or disclosed for direct marketing, public opinion polling or scientific research purposes; and
  3. in other cases specified by law.


(2) By suspending the processing at the same time, we will examine the objection and inform you in writing of the outcome.

If the objection is justified, we are obliged to stop the processing, including further collection and transfer, and to block the data, and to notify the objection and any action taken in response to it to all those to whom we have previously disclosed the personal data concerned by the objection and who are obliged to take action to enforce the right to object.

6.6 Right to restriction of processing

(1) We will restrict processing if one of the following conditions is met: 

  1. You contest the accuracy of the personal data; 
  2. the processing is unlawful and you oppose the erasure of the data and request instead that its use be restricted; 
  3. we no longer need the personal data for the purposes of processing, but you require it for the establishment, exercise or defence of legal claims; or 
  4. You have objected to the processing. 

(2) If the processing is restricted, such personal data, except for storage, may only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for important public interests of the Union or of a Member State. 

6.7 Right to data portability 

You have the right to receive the personal data we have about you in a structured, commonly used, machine-readable, where technically feasible, format, where the processing is based on your consent or on a contract and the processing is carried out by automated means.

6.8 Time limit for the Data Controller in relation to the exercise of the data subject’s rights

We will inform you of the action taken on your request without undue delay, but in any event within one month of receiving it. 

If necessary, and taking into account the complexity of the application and the number of requests, this deadline may be extended by a further two months. You will be informed of the extension, stating the reasons for the delay, within one month of receipt of the request. 

We will also inform you without delay, but at the latest within one month of receipt of the request, of the reasons for the failure to act, of the possibility to lodge a complaint with a supervisory authority and of your right to judicial remedy. 

Information and action will be provided free of charge, however, if your request is manifestly unfounded or excessive, in particular because of its repetitive nature, having regard to the administrative costs of providing the information or information requested or of taking the action requested: 

  1. a) we may charge a reasonable fee, or 
  2. b) refuse to act on the request. 

The burden of proving that the request is manifestly unfounded or excessive is on us as the controller.



Your present 6. The rights set out in this paragraph may be restricted by law in the interests of the internal and external security of the State, such as national defence, national security, the prevention or prosecution of criminal offences, the security of law enforcement, the economic or financial interests of the State or of a local authority, the important economic or financial interests of the European Union, the prevention and detection of disciplinary or ethical offences in the exercise of the profession, infringements of labour law or of employment protection, including in all cases for the purposes of control and supervision, and the protection of the rights of the Data Subject or of others.

7. Remedies

In case of infringement, you can seek redress:

a.) directly to us as Data Controller:
Name:Mental Focus Ltd.
Address for correspondence: 1147 Budapest, Miskolci u. 56.
Phone number: +36 70 883 8194
E-mail: info@mentalfocus.hu

a.) to the National Authority for Data Protection and Freedom of Information
Head office: 1055 Budapest, Falk Miksa utca 9-11.
Postal address: 1363 Budapest, PO Box 9.
Phone: +36 (30) 683-5969
+36 (30) 549-6838
+36 (1) 391 1400
Fax: +36 (1) 391-1410
E-mail: ugyfelszolgalat@naih.hu

b.) to the competent court in your place of residence or domicile.

The Privacy Notice is valid from 10 November 2024 until its withdrawal