DATA MANAGEMENT INFORMATION

Regarding Data Management by 22 Media and Design Studio Ltd.

The purpose of this information is to record the data protection and data management principles applied by 22 Media and Design Studio Ltd. (hereinafter: Data Controller), which it recognizes as binding upon itself, and to inform the Data Subjects about their rights related to data management according to Regulation (EU) 2016/679 of the European Parliament and the Council (hereinafter: GDPR) and the Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information (hereinafter: Infotv.).

The Data Controller undertakes to ensure that all data management related to its activities complies with the requirements set out in applicable laws, handles the data confidentially, and takes technical and organizational measures to ensure secure data management, preserving the confidentiality and integrity of the data.

Definitions

The terms used in this information shall be interpreted according to the definitions set out in Article 4, Chapter 1 of the GDPR:

• "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, an identification 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.
• "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, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• "Data Subject": An identified or identifiable natural person who can be identified, directly or indirectly, by reference to specific personal data.
• "Restriction of processing": The marking of stored personal data with the aim of limiting their processing in the future.
• "Profiling": Any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
• "Pseudonymization": The processing of personal data in such a manner that the personal data can no longer be attributed to a specific Data Subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
• "Filing system": Any structured set of personal data which are accessible according to specific criteria, whether centralized, decentralized or dispersed on a functional or geographical basis.
• "Data Controller": The natural or legal person, public authority, agency or 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 such processing are determined by Union or Member State law, the Data Controller or the specific criteria for its nomination may be provided for by Union or Member State law.
• "Processor": A natural or legal person, public authority, agency or other body which processes personal data on behalf of the Data Controller.
• "Recipient": A natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
• "Third party": A natural or legal person, public authority, agency or body other than the Data Subject, Data Controller, Processor and persons who, under the direct authority of the Data Controller or Processor, are authorized to process personal data.
• "Consent of the Data Subject": Any freely given, specific, informed and unambiguous indication of the Data Subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
• "Personal data breach": A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.
• "Genetic data": Personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person and which result, in particular, from an analysis of a biological sample from the natural person in question.
• "Biometric data": Personal data resulting from specific technical processing relating to the physical, physiological or behavioral characteristics of a natural person which allow or confirm the unique identification of that natural person, such as facial images or dactyloscopic data.
• "Data concerning health": Personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status.
• "Main establishment":
  • (a) As regards a Data Controller with establishments in more than one Member State, the place of its central administration in the Union, unless the decisions on the purposes and means of the processing of personal data are taken in another establishment of the Data Controller in the Union and the latter establishment has the power to have such decisions implemented, in which case the establishment having taken such decisions is to be considered as the main establishment.
  • (b) As regards a Processor with establishments in more than one Member State, the place of its central administration in the Union, or, if the Processor has no central administration in the Union, the establishment of the Processor in the Union where the main processing activities in the context of the activities of an establishment of the Processor take place to the extent that the Processor is subject to specific obligations under this Regulation.
• "Representative": A natural or legal person established in the Union who, designated by the Data Controller or Processor in writing pursuant to Article 27, represents the Data Controller or Processor with regard to their respective obligations under this Regulation.
• "Enterprise": A natural or legal person engaged in an economic activity, irrespective of its legal form, including partnerships or associations regularly engaged in an economic activity.
• "Group of undertakings": A controlling undertaking and its controlled undertakings.
• "Binding corporate rules": Personal data protection policies adhered to by a Data Controller or Processor established on the territory of a Member State for transfers or a set of transfers of personal data to a Data Controller or Processor in one or more third countries within a group of undertakings, or group of enterprises engaged in a joint economic activity.
• "Supervisory authority": An independent public authority which is established by a Member State pursuant to Article 51.
• "Cross-border processing":
  • (a) Processing of personal data which takes place in the context of the activities of establishments in more than one Member State of a Data Controller or Processor in the Union where the Data Controller or Processor is established in more than one Member State; or
  • (b) Processing of personal data which takes place in the context of the activities of a single establishment of a Data Controller or Processor in the Union but which substantially affects or is likely to substantially affect Data Subjects in more than one Member State.
• "Relevant and reasoned objection": An objection to a draft decision as to whether there is an infringement of this Regulation or whether the envisaged action in relation to the Data Controller or Processor complies with this Regulation, which clearly demonstrates the significance of the risks posed by the draft decision as regards the fundamental rights and freedoms of Data Subjects and, where applicable, the free flow of personal data within the Union.
• "Information society service": A service as defined in point (b) of Article 1(1) of Directive (EU) 2015/1535 of the European Parliament and of the Council.
• "International organization": An organization and its subordinate bodies governed by public international law, or any other body which is set up by, or on the basis of, an agreement between two or more countries.

Data Controller's Details

• Address: 1221 Budapest, Vihar Street 5. D. Building, 4th Floor, 15.
• Tax Number: 25550155-2-43
• Phone: +36-1-208-0015
• Email: info@22.design

Purpose of Data Processing

The purpose of data processing is always detailed in the "Data Management Consent Statement and Information" appendix. Data collection and processing related to the Data Controller's services are based on the voluntary consent of the Data Subject or contractual relationships.

The Data Controller handles the recorded personal data in compliance with applicable data protection laws, particularly the GDPR and the Infotv., and in accordance with this information.

Principles for Processing Personal Data

The Data Controller observes and adheres to the following principles when processing personal data:

• Lawfulness, fairness, and transparency: Processing must be lawful, fair, and transparent to the Data Subject.
• Purpose limitation: Data must be collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes. Further processing for public interest archiving, scientific, or historical research, or statistical purposes is not considered incompatible.
• Data minimization: Personal data must be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.
• Accuracy: Personal data must be accurate and kept up to date. Every reasonable step must be taken to ensure that personal data that are inaccurate are erased or rectified without delay.
• Storage limitation: Data must be kept in a form that permits identification of Data Subjects for no longer than necessary. Personal data may be stored for longer periods for public interest archiving, scientific or historical research, or statistical purposes, with appropriate safeguards.
• Integrity and confidentiality: Processing must ensure appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.
• Accountability: The Data Controller must be able to demonstrate compliance with these principles.

Data Transmission

The Data Controller may transfer personal data to processors listed in the data source and process registry while ensuring the confidentiality and integrity of the data. The Data Controller does not transfer personal data to other entities within the country, the Union, or third countries, or to international organizations outside of those listed.

Use of Processors

The Data Controller may use processors for its activities, as listed in the data source and process registry.

Duration of Data Processing

The duration of data storage lasts until the purpose of data processing is achieved and is specified in the "Data Management Consent Statement and Information" document.

Scope of Data Processed

During and following the provision of services, the Data Controller may process the following personal data based on the voluntary consent of the Data Subject or contractual relationships: company name, contact person/Data Subject name, corporate/business phone numbers, corporate/business email addresses, corporate/business postal addresses, Data Subject's IT device data, Microsoft personal data, usernames, and passwords.

The listed data categories are indicative, with exact specifications made in the "Data Management Consent Statement and Information" document.

Data Subject's Right of Access

The Data Subject has the right to receive confirmation from the Data Controller on whether their personal data is being processed, and if so, access to the personal data and the following information:

• Purpose of processing
• Categories of personal data concerned
• Recipients or categories of recipients to whom personal data has been or will be disclosed, including particularly third-country recipients or international organizations
• Where possible, the envisaged period for which personal data will be stored, or if not possible, the criteria used to determine that period
• The right to request rectification, erasure, restriction of processing of personal data, and to object to such processing
• The right to lodge a complaint with a supervisory authority
• If data was not collected from the Data Subject, any available information regarding the source
• The existence of automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the Data Subject
• If personal data is transferred to a third country or international organization, the Data Subject has the right to be informed of the appropriate safeguards under Article 46 of the GDPR.

The Data Controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the Data Subject, the Data Controller may charge a reasonable fee based on administrative costs. If the Data Subject submits the request electronically, the information shall be provided in a commonly used electronic format unless otherwise requested.

Right to Rectification

The Data Subject has the right to obtain from the Data Controller without undue delay the rectification of inaccurate personal data concerning them. Taking into account the purposes of the processing, the Data Subject has the right to have incomplete personal data completed.

Right to Erasure ('Right to be Forgotten')

The Data Subject has the right to obtain from the Data Controller the erasure of personal data concerning them without undue delay, and the Data Controller has the obligation to erase personal data without undue delay where one of the following grounds applies:

• The personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed
• The Data Subject withdraws consent on which the processing is based, and there is no other legal ground for processing
• The Data Subject objects to the processing and there are no overriding legitimate grounds for processing, or the Data Subject objects to the processing for direct marketing purposes
• The personal data has been unlawfully processed
• The personal data must be erased to comply with a legal obligation in Union or Member State law to which the Data Controller is subject
• The personal data has been collected in relation to the offer of information society services to children

If the Data Controller has made the personal data public and is obliged to erase it, the Data Controller, taking into account available technology and implementation costs, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the Data Subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

The right to erasure does not apply to the extent that processing is necessary:

• For exercising the right of freedom of expression and information
• For compliance with a legal obligation requiring processing by Union or Member State law or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller
• For reasons of public interest in the area of public health
• For archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes
• For the establishment, exercise, or defense of legal claims

Right to Restriction of Processing

The Data Subject has the right to obtain from the Data Controller restriction of processing where one of the following applies:

• The accuracy of the personal data is contested by the Data Subject, for a period enabling the Data Controller to verify the accuracy of the personal data
• The processing is unlawful and the Data Subject opposes the erasure of the personal data and requests the restriction of their use instead
• The Data Controller no longer needs the personal data for the purposes of processing, but they are required by the Data Subject for the establishment, exercise, or defense of legal claims
• The Data Subject has objected to processing pending verification of whether the Data Controller's legitimate grounds override those of the Data Subject

Where processing has been restricted under the above conditions, such personal data shall, with the exception of storage, only be processed with the Data Subject's consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

The Data Controller shall inform the Data Subject before the restriction of processing is lifted.

Right to Object

The Data Subject has the right to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them which is based on the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller, or processing necessary for the purposes of the legitimate interests pursued by the Data Controller or a third party, including profiling based on those provisions. The Data Controller shall no longer process the personal data unless the Data Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the Data Subject or for the establishment, exercise, or defense of legal claims.

Where personal data is processed for direct marketing purposes, the Data Subject has the right to object at any time to processing of personal data concerning them for such marketing, including profiling to the extent that it is related to such direct marketing. If the Data Subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

Where personal data is processed for scientific or historical research purposes or statistical purposes in accordance with the GDPR, the Data Subject, on grounds relating to their particular situation, shall have the right to object to processing of personal data concerning them unless the processing is necessary for the performance of a task carried out for reasons of public interest.

The right to object can be exercised electronically by the Data Subject.

Right to Data Portability

The Data Subject has the right to receive the personal data concerning them, which they have provided to a Data Controller, in a structured, commonly used, and machine-readable format and has the right to transmit those data to another Data Controller without hindrance from the Data Controller to which the personal data have been provided, where:

• The processing is based on consent or on a contract
• The processing is carried out by automated means

The Data Controller shall provide the requested data in XML format to the Data Subject on a data carrier provided by the Data Subject.

In exercising the right to data portability, the Data Subject shall have the right to have the personal data transmitted directly from one Data Controller to another, where technically feasible. Such a request must be made in writing by the Data Subject, accompanied by proof of identity.

The right to data portability shall not adversely affect the rights and freedoms of others.

Right to Withdraw Consent

The Data Subject has the right to withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Before giving consent, the Data Subject shall be informed thereof. The consent withdrawal can be done using the "Data Management Consent Withdrawal Statement" document.

Right to Lodge a Complaint with a Supervisory Authority

Without prejudice to any other administrative or judicial remedy, every Data Subject has the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work, or place of the alleged infringement, if the Data Subject considers that the processing of personal data relating to them infringes the GDPR.

The supervisory authority to which the complaint has been submitted shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy.

The Data Controller is obliged to comply with the decision of the supervisory authority.

In Hungary, the competent supervisory authority is the National Authority for Data Protection and Freedom of Information, whose contact details are:

• Address: 1125 Budapest, Szilágyi Erzsébet fasor 22/C.
• Mailing address: 1530 Budapest, Pf.: 5.
• Phone: 06.1.391.1400
• Fax: 06.1.391.1410
• Email: ugyfelszolgalat@naih.hu
• Website: www.naih.hu

Automated Decision-Making and Profiling

The Data Controller ensures that no decision is made regarding the Data Subject solely on automated processing, including profiling, which produces legal effects concerning them or significantly affects them. Exceptions include:

• If it is necessary for entering into, or the performance of, a contract between the Data Subject and the Data Controller
• If it is authorized by Union or Member State law to which the Data Controller is subject and which also lays down suitable measures to safeguard the Data Subject's rights and freedoms and legitimate interests
• If it is based on the Data Subject's explicit consent

Data Management Consent Statement and Information for Newsletter Subscription

Data processing is based on the Data Subject's voluntary, informed declaration, which includes the Data Subject's explicit consent for the use of personal data provided during newsletter subscription.

The Data Subject can unsubscribe from the newsletter at any time using the contacts in the newsletter or the "Unsubscribe" feature, which constitutes withdrawal of consent. In such cases, all data of the Data Subject will be immediately deleted.

• Personal Data Processed:
  • Name (surname, first name)
  • Email address
• Purpose of Data Processing:
  • Sending newsletters to the email address provided by the Data Subject. The Data Controller uses the data provided by the Data Subject exclusively for sending newsletters on the following topics:
    • 22 Media and Design Studio Systems Ltd. products, services, events
    • Promotional material
• Legal Basis for Data Processing: The Data Subject's consent.
• Persons Authorized to Access Data: The data is primarily accessible to the Data Controller and its employees who are responsible for managing and processing the data.
• Duration of Data Processing: Personal data is processed until the Data Subject unsubscribes from the newsletter.

The Data Controller does not verify the accuracy of the personal data provided. The Data Subject is solely responsible for the accuracy of the data provided. By providing their email address, the Data Subject assumes responsibility for the use of the service from the provided email address.

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