1. Purpose of the data processing

Solvere Media Bt. (Address: 1133 Budapest Váci út 104 fsz. 7.), hereinafter, service provider, data controller) as a data controller, acknowledges the content of this legal notice as binding on it.

It undertakes that all data processing related to its activities complies with the requirements set out in these regulations and in the applicable national legislation, as well as in the legal acts of the European Union.

This privacy statement covers the following domains and their subdomains:

● solveremedia.com      

Privacy policies related to the data controller's data management are constantly available at solveremedia.com/adatkezelesi-tajekoztato.

The data controller reserves the right to amend this information at any time. Stakeholders will be informed of the changes in due time.

If you have any questions regarding this notice, please write and answer your question.

The data controller is committed to the protection of the personal data of its customers and partners, and considers it extremely important to respect the right of its customers to self-determination of information. The data controller shall treat the personal data confidentially and shall take all security, technical and organizational measures that guarantee the security of the data.

The data controller describes his data management practices below.

2. Data controller

If you would like to contact the company, you can contact the data controller at the email address gabor.varga@solveremedia.com and the telephone number +36 20 268 7168.

Name : Solvere Media Bt.

Head office : 1133 Budapest, Váci út 104. Fsz. 7.

Tax number : 26605629-1-41

Company registration number : 01-06-794098

Phone number : +3620 268 7168

Email : gabor.varga@solveremedia.com

2.1 Data protection officer

The controller shall not engage in any activity that would justify the appointment of a data protection officer.

3. Range of personal data processed

3.1. Technical data

The data controller selects and operates the IT tools used to manage personal data during the provision of the service in such a way that the managed data:

● accessible to those entitled to it (availability);      

● authenticity and authentication are ensured (authenticity of data management);      

● its invariability can be verified (data integrity);      

● be protected against unauthorized access (data confidentiality).      

The controller shall take appropriate measures to protect the data against unauthorized access, alteration, transmission, disclosure, deletion or destruction, and accidental destruction.

The data controller shall ensure the protection of the security of data processing by technical, organizational and organizational measures that provide a level of protection appropriate to the risks associated with the data processing.

The data controller maintains confidentiality during data management: it protects the information so that only those who have the right to access it can access it; integrity: protects the accuracy and completeness of information and the method of processing; availability: ensures that when an authorized user needs it, they can actually access the information they need and have the tools to do so.

3.2 Cookies

3.2.1 The function of the cookies

Cookies collect information about visitors and their devices; remember the individual settings of the visitors, which can be used e.g. when using online transactions so you don’t have to retype them; facilitate the use of the website; they provide a quality user experience and participate in the collection of some visitor statistics.

In order to provide customized service, a small data packet, the so-called places a cookie and reads it back at a later visit. If the browser returns a previously saved cookie, the cookie provider has the option to link the user's current visit to the previous ones, but only for their own content.

Some cookies do not contain personal information that can be used to identify an individual user, some contain a secret, randomly generated sequence of numbers that is stored by the user's device and ensures the user's identity.

3.2.2. Necessary cookies

The purpose of these cookies is to allow visitors to fully and seamlessly browse the solveremedia.com website, use its features and the services available there.

3.2.3. Statistic, marketing cookies

We are also using Google Analytics, Facebook, and Google Ads as third-party cookies on the websites of solveremedia.com and their subdomains. Using Google Analytics, Google Ads, Facebook for statistical and marketing services, the websites of solveremedia.com and its subdomains collect information about how visitors use the websites. You use the data to improve the website and improve the user experience and to display online advertisements. These cookies also remain on the visitor's computer or other device used for browsing, in its browser, or until the visitor deletes them until they expire.

3.2.4. Legal basis for cookie management

The legal basis for the handling of cookies is the consent of the website visitor, in accordance with Article 6 (1) (a) of the relevant Regulation.

If you do not accept the use of cookies, then 3.2.3. Some features of the websites listed in section 1 will not be available when you use the websites, or some features may not work properly.

You can find more information about deleting cookies for the most common browsers at the following links:

● Firefox: Delete cookies placed by websites from your computer      

● Chrome: Clear cache & cookies      

● Safari: Manage cookies and website data in Safari on Mac

3.2.5. List of cookies on the data manager's website

4. General data processing guidelines, name, usage, legal basis, and retention period

The data management of the data controller's activity is based on voluntary consent or legal authorization. In the case of data processing based on voluntary consent, data subjects may withdraw their consent at any stage of the data processing.

In some cases, the handling, storage and transmission of a set of provided data is required by law, of which we notify our customers separately. We would like to draw the attention of informants to the Data Controller that if they do not provide their own personal data, the informant is obliged to obtain the consent of the data subject. Its data management principles are in line with the applicable data protection legislation, in particular the following: 2011 CXII. Act on the Right to Information Self-Determination and Freedom of Information (Infotv.);

Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Regulation (EC) No 95/46 ( General Data Protection Regulation, GDPR); Act V of 2013 - on the Civil Code (Civil Code); Act C of 2000 - on Accounting (Act on Accounting); 2017 LIII. Act on the Prevention and Suppression of Money Laundering and Terrorist Financing (Pmt.); 2013 CCXXXVII. Act on Credit Institutions and Financial Enterprises (Hpt.).

The data maps of the data controller were prepared, on the basis of which the scope of the processed data, their use, legal basis and retention period were determined.

4.1. Information related to online and telephone administration

Personal information requested during the contact:

Name (required field)

Email address (required field)

Phone number (optional field, optional, to initiate a callback)

Purpose of data management, intended use of the managed data: The data will be used for contact purposes.

The legal basis for data management is voluntary consent.

Retention period: the duration of a business relationship or a cancellation request.

4.2. Invoicing information

The data controller enters into a contract with its customers during the provision of services, during which it stores the following data:

Name

E-mail address

Title

Purpose of data management, intended use of the managed data: invoicing.

Legal basis for data management: legal requirement.

Shelf life: 8 years according to legal regulations

5. Phisycal storage of data

Your personal information (that is, information that may be associated with you) may be processed by us in the following ways:

● on the one hand, in connection with the maintenance of the Internet connection, the technical data related to the computer, browser program, Internet address and pages visited by you are automatically generated in our computer system,      

● on the other hand, you can also provide your name, contact information or other details if you wish to contact us personally when using the website. Data to be technically recorded during the operation of the system: the data of the computer of the affected login, which is recorded by the systems of solveremedia.com domain and subdomains as an automatic result of the technical processes.      

The data that is automatically recorded is automatically logged at entry and exit without a separate statement or action by the data subject.

This data may not be combined with other personal user data, except in cases required by law. Only solveremedia.com domain and its subdomains have access to the data.

6. Data transmission, data processing, data knowledge

As part of its business activities, the data controller uses the following data processors:

Hosting service:

Webflow, Inc., 398 11th Street, 2nd Floor, San Francisco, CA 94103

Email: contact@webflow.com

Google Analytics:

Google Inc., Mountain View, California, USA

Contact: https://support.google.com

Facebook page:

Facebook Inc., Menlo Park, California, USA

Contact: https://www.facebook.com/help

6.1 Transfer of data to a third country

The data will be transferred to the United States, with which a decision on compliance was taken on 12 July 2016 ( https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu- us-privacy-shield_en ).

The decision on compliance also applies to

Webflow (https://webflow.com/legal/eu-privacy-policy),

Google (https://policies.google.com/privacy/frameworks),

Facebook (https://www.facebook.com/about/privacyshield),

in the case of data processing.

7. Right and enforcement options of the person concerned

The data subject may request information on the processing of his / her personal data, as well as request the correction or deletion or revocation of his / her personal data, except for mandatory data processing, exercise his / her right to data and protest in the manner indicated at

7.1. Right to information

The controller shall take appropriate measures to provide the data subject with all information concerning the processing of personal data referred to in Articles 13 and 14 of the GDPR and Articles 15 to 22. and Article 34 shall provide each information in a concise, transparent, comprehensible and easily accessible form, in a clear and comprehensible manner.

7.2. Right of access to the personal information, and its usage

The data subject shall have the right to receive feedback from the controller as to whether the processing of his or her personal data is in progress and, if such processing is in progress, to obtain access to the personal data and the following information:

● purposes of data management;      

● the categories of personal data concerned;      

● the recipients or categories of recipients to whom or with whom the personal data have been or will be communicated, including in particular third country recipients or international organizations;      

● the planned duration of the storage of personal data;      

● the right to rectify, erase or restrict data processing and to protest;      

● the right to lodge a complaint with the supervisory authority;      

● information on data sources;      

● the fact of automated decision-making, including profiling, and understandable information about the logic used and the significance of such data management and the expected consequences for the data subject.      

The controller shall provide the information no later than one month after the submission of the request.

7.3. Right of correction

The data subject may request the correction of inaccurate personal data processed by the Data Controller and the addition of incomplete data.

7.4. Right to cancel

The data subject has the right to delete personal data concerning him / her without undue delay at his / her request if one of the following reasons exists: personal data are no longer needed for the purpose for which they were collected or otherwise processed; the data subject withdraws his or her consent on which the processing is based and there is no other legal basis for the processing; the data subject objects to the processing and there is no overriding legitimate reason for the processing; personal data have been processed unlawfully; personal data must be deleted in order to fulfill a legal obligation under Union or Member State law applicable to the controller; personal data was collected in connection with the provision of information society services.

Deletion of data may not be initiated if the processing is necessary: ​​for the purpose of exercising the right to freedom of expression and information; for the purpose of fulfilling an obligation under Union or Member State law applicable to the controller to process personal data or performing a task carried out in the public interest or in the exercise of official authority vested in the controller; in the field of public health, or for archival, scientific and historical research or statistical purposes, in the public interest; or to bring, assert or defend legal claims.

7.5. Right to restrict data processing

At the request of the data subject, the Data Controller shall restrict the data processing if one of the following conditions is met: the data subject disputes the accuracy of the personal data, in which case the restriction shall apply for a period that allows the accuracy of the personal data to be checked; the processing is unlawful and the data subject opposes the deletion of the data and instead requests that their use be restricted; the controller no longer needs the personal data for the purpose of data processing, but the data subject requests them in order to make, enforce or protect legal claims; or the data subject has objected to the processing; in that case, the restriction shall apply for as long as it is established whether the legitimate reasons of the controller take precedence over the legitimate reasons of the data subject.

Where processing is restricted, personal data may be processed, with the exception of storage, only with the consent of the data subject or for the purpose of bringing, enforcing or protecting legal claims or protecting the rights of another natural or legal person or in the important public interest of the Union or a Member State.

7.6 Right to data carrier

The data subject shall have the right to receive the personal data concerning him or her made available to the controller in a structured, widely used machine-readable format and to transmit this data to another controller.

7.7. Right of objection

The data subject shall have the right to object at any time, for reasons related to his situation, to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of public authority, or to the processing of data controllers or third parties, including profiling based on those provisions. is. In the event of an objection, the controller may not further process the personal data, unless justified by compelling legitimate reasons which take precedence over the interests, rights and freedoms of the data subject or which relate to the submission, enforcement or protection of legal claims.

7.8. Automated decision-making in individual cases, including profiling

The data subject has the right not to be covered by a decision based solely on automated data processing, including profiling, which would have legal effects on him or her or would be similarly significant.

7.9. Right of withdrawal

The data subject has the right to withdraw his or her consent at any time.

7.10. Right to go to court

If the data subject's rights are violated, he or she may take legal action against the data controller. The court is acting out of turn in the case. 8.11 Data protection authority procedure A complaint can be lodged with the National Data Protection and Freedom of Information Authority:

Name: National Authority for Data Protection and Freedom of Information Headquarters: 1125 Budapest, Szilágyi Erzsébet fasor 22 / C. Mailing address: 1530 Budapest, Pf .: 5. Telephone: 0613911400 Fax: 0613911410

E-mail: ugyfelszolgalat@naih.hu Website: http://www.naih.hu

8. Other provisions

Information on data processing not listed in this prospectus will be provided at the time of data collection. We inform our clients that the court, the prosecutor, the investigating authority, the infringement authority, the administrative authority, the National Data Protection and Freedom of Information Authority, the Magyar Nemzeti Bank, or other bodies are authorized to provide information, disclose data, transfer or documents they may contact the controller to make it available. The controller shall provide personal data to the authorities, provided that the authority has indicated the exact purpose and scope of the data, only to the extent and to the extent strictly necessary for the purpose of the request.

(This data management information has been prepared on the recommendation of the Budapest Chamber of Commerce and Industry.)