Privacy and Cookie Policy (hereinafter: the Policy)

1. Who and what does this Policy cover, and what is its purpose?

1.1. Which services and individuals does this Policy cover?

1.2. What is the purpose of this Policy?

2. What are the basic details of Guidance Zrt.?

3. For what purposes and how do we process your personal data?

3.1. Voluntary provision of data

3.2. Purpose of processing

Sending interested persons emails containing information, notices and announcements relating to the STH system, including information that may qualify as commercial advertising (updates on current news and offers).

3.3. Legal basis for processing

The voluntary provision of data and your consent thereby given, as well as the agreement between Guidance Zrt. and you and, in the longer term, the use of the STH system.

3.4. Categories of personal data processed

The personal data you provide (name, email address, telephone number), the date and time of subscription, your IP address, data on user interactions (e.g. visiting a page or opening emails), and information generated in connection with the use of the STH system.

3.5. Duration of processing

From the provision of the data until you unsubscribe or withdraw your consent to processing in any manner, and thereafter for the shortest possible period, but no longer than permitted under the applicable data protection legislation.

3.6. Data transfers (other recipients)

Unless otherwise required by law, only Guidance Zrt., as the developer and operator of the contact page and the STH system (processor), may access the personal data we process about you.

4. When is Guidance Zrt. not the Controller of your personal data?

4.1. The Customer's employees

Guidance Zrt. is not the Controller of your personal data if your data (name, email address, telephone number) is processed in any of the ways described above by your Employer (the Controller in this case), its representative or a person appointed by it, rather than by you, or if your data changes and the necessary amendments are made by your Employer, its representative or a person appointed by it.

4.2. Withdrawal of consent

If your data was provided without your consent, or if for any reason you wish to withdraw your consent to the processing of your data, including processing on behalf of a controller, you must notify your Employer acting as Controller of this request. Following its assessment, the Controller may initiate the permanent erasure of the personal data either directly or by notifying Guidance Zrt. Guidance Zrt., as the responsible Processor, will take the necessary technical steps unless another agreement concluded with you, a law or provision applicable to your data, or a legal consequence arising from these precludes this.

4.3. Third party

If the STH system does not operate within the cloud service provided by Guidance Zrt. because Guidance Zrt., as the developer of the system and the author and owner of the economic rights in the intellectual property, and the Customer using the system (an entrepreneur, business, organisation, company, etc., with or without legal personality) enter into an agreement under which the Customer uses the system containing the personal data you provided on its own equipment or through a third-party cloud service, Guidance Zrt. is neither responsible nor entitled to act as Controller or Processor in relation to the processing of data held in the system. In this case, Guidance Zrt. has no obligations or liability as a controller or processor, and no such obligations or liability will arise or may be imposed in the future.

5. What cookies do we use?

The Website uses cookies. Further details about the types and functions of the cookies we use, the purpose of processing, the data collected by cookies and their lifetimes are provided in the cookie section at the end of this Policy.

6. Do we carry out automated decision-making or profiling?

Your personal data may be subject to profiling as described in the cookie section at the end of this Policy.

7. What rights do you have?

Under Articles 15–20 of the legislation governing data processing (GDPR), you have the following rights in relation to personal data processed by Guidance Zrt.:

7.1. How can you exercise your rights?

7.2. Right of access

You have the right to obtain confirmation from Guidance Zrt. as to whether your personal data is being processed and, if so, to access that personal data and receive information about the circumstances of its processing.

7.3. Rectification

You have the right to request that Guidance Zrt. rectify inaccurate personal data without undue delay and that incomplete personal data be completed.

7.4. Right to erasure (“right to be forgotten”)

7.4.1. You have the right to request that Guidance Zrt. erase personal data without undue delay where one of the following grounds applies:

7.4.2. Guidance Zrt. will not erase personal data where applicable law permits its retention, for example where processing is necessary for the establishment, exercise or defence of legal claims (including, but not limited to, the use of software provided by Guidance Zrt. or the possible existence of legal or other claims arising from it).

7.5. Right to restriction of processing

In certain cases, we are required to restrict the use of personal data at your request. In such cases, we may use the data only for the limited purposes specified by law.

7.6. Right to object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data based on Guidance Zrt.'s legitimate interests or for direct marketing purposes. In this case, Guidance Zrt. may no longer process the personal data unless it demonstrates compelling legitimate grounds for processing which override your interests, rights and freedoms, or which relate to the establishment, exercise or defence of legal claims.

7.7. Right to data portability

Provided that this does not adversely affect the rights and freedoms of others, you have the right to receive your personal data in a structured, commonly used and machine-readable format, or to have Guidance Zrt. transmit that data directly to another controller, if:

8. What remedies are available to you?

8.1. Right to lodge a complaint

If you disagree with Guidance Zrt.'s response or action, you may lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (address: 1055 Budapest, Falk Miksa utca 9-11.; postal address: 1363 Budapest, P.O. Box 9.; telephone: +36-1-391-1400; email: ugyfelszolgalat@naih.hu).

8.2. Right to bring court proceedings

If you experience unlawful processing of your data, you may also bring civil proceedings against Guidance Zrt. The case falls within the jurisdiction of a regional court. At your choice, proceedings may also be brought before the regional court for your place of residence (a list of regional courts and their contact details is available at: https://birosag.hu/torvenyszekek).

9. What do the terms used in this Policy mean, and what are the key principles?

9.1. Key definitions

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

“processor”: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller (in this case, Guidance Zrt.);

“controller”: a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of processing personal data (in this case, Guidance Zrt.);

“personal data breach”: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;

“personal data”: any information relating to an identified or identifiable natural person (“data subject”);

“data subject”: an identifiable or identified natural person. An identified or 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, online identifier, or to one or more factors specific to that natural person's physical, physiological, genetic, mental, economic, cultural or social identity.

9.2. Data protection principles applicable to processing by Guidance Zrt.

As controller, Guidance Zrt. is responsible for complying with the following principles:

10. Where to find the current Policy

The current version of this document is available at https://sthservice.eu/en/privacy-policy.

11. Cookie Notice

11.1. Use of cookies

We use cookies on the contact page to operate the website, make it easier to use and track activity on it.

Please read this document carefully and use the website's services only if you agree with and accept all its provisions.

Please note that this Policy applies only to the use of cookies on the website concerned.

11.2. What is a cookie?

A cookie is a small packet of data that online services store in your browser. It is an essential technology for operating an online service that provides an efficient, modern user experience, and is supported by all browsers today.

11.3. How is a cookie created?

First, the browser running on your computer, tablet, mobile phone or other client device sends a request to the server. The server then creates a unique identifier and stores it in its own database, before sending the cookie or cookies it has created back to the client with all the information. The cookie received in this way is stored on the client device by the browser that initiated the connection.

11.4. How is a cookie used?

When the client device reconnects to the server in the same way using the same browser, it includes the cookie previously created and stored. The server compares the contents of the received cookie with those it has stored. This allows it, for example, to identify a registered user who is logged in. Without this, it would not be possible, for example, to log in to a website.

11.5. What cookies does the website use, and for what purposes?

The website uses cookies for the following purposes:

11.6. Types of cookies

11.6.1. Cookies required for basic functionality

These cookies ensure that the website functions properly, make it easier to use and collect information about its use without identifying our visitors. They include, for example, the storage of calculator input values, cookie consent status, remembered login methods and details, website notification status and Google Analytics code with reduced functionality. Without these cookies, we cannot guarantee convenient use of our website.

11.6.2. Statistical cookies

These cookies enable us to obtain information about how visitors use our website. They cannot identify you personally and collect only information such as:

11.6.3. Performance cookies

These include Google Analytics and Google Optimize cookies. Further information is available at:

https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

11.6.4. Targeting and advertising cookies

The purpose of these cookies is to display advertisements on websites that are more closely aligned with your interests or more relevant to you. These cookies cannot identify you personally without your consent. To determine what content may interest you, they collect information such as:

If you consent to these cookies, we may combine the information collected while you use the website with your personal data in order to tailor our marketing communications more closely to your needs and draw your attention to offers that are as personalised as possible.

11.7. Providers of advertising cookies used on the website:

Google Adwords

Information: https://www.google.com/intl/hu/policies/privacy

Facebook

Information: https://www.facebook.com/privacy/policies/cookies/

Doubleclick

Information: https://www.google.com/intl/hu/policies/privacy

Instagram

Information: https://privacycenter.instagram.com/policies/cookies/

11.8. How can you check and disable cookies?

All modern browsers allow you to change your cookie settings. Most browsers automatically accept cookies by default, but these settings can be changed so that the browser prevents automatic acceptance and offers you a choice each time as to whether to allow cookies.

Cookies are intended to facilitate or enable the use and operation of our website. Blocking or deleting them may therefore prevent you from fully using all the website's features or cause the website to function differently from intended in your browser.

11.9. Cookie settings for the most widely used browsers: