1. Introduction
Our company, Natív Hirdetés Ltd., has created the |related| intelligent content recommendation and native advertising system (hereinafter: System) to provide a solution for our contractual partners (hereinafter: Contractual partner) to efficiently utilize unused spaces on their websites and to assist users visiting our Contractual partners' websites (hereinafter: Users) in finding the most valuable content for them.
For the secure, lawful, and efficient operation of the System, it is indispensable that we process the personal data of Users. During data processing, we always act in accordance with the principles of good faith, fairness, transparency, accuracy, and accountability, respecting and enforcing the rights of users related to data processing. We have designed our data processing in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter: GDPR), Act CXII of 2011 on the right to informational self-determination and freedom of information (hereinafter: Infotv.), Act CVIII of 2001 on certain aspects of electronic commerce services and information society services (hereinafter: E-com tv.), Act V of 2013 on the Civil Code (hereinafter: Ptk.), and Act XLVIII of 2008 on the basic conditions and certain restrictions of economic advertising activity (hereinafter: Grtv.).
Our goal is to ensure that personal data is adequate, relevant, and limited to what is necessary in relation to the purposes of data processing. During data processing, we ensure the confidentiality of the personal data we handle and prevent unauthorized access.
2. Data Controller
The controller of personal data is our company:
- Natív Hirdetés Ltd
- headquarters: 1064 Budapest, Podmaniczky utca 57. 2nd floor, 14.
- company registration number: 01-09-281818
- statistical code: 25552937-7311-113-01
- tax number: 25552937-2-42
- website: www.related.hu
- e-mail: [email protected]
- mailing address: Natív Hirdetés Kft. - 1064 Budapest, Podmaniczky utca 57. 2nd floor, 14.
3. Data Processor
Our company carries out the tasks related to the operation and development of the System and the website - www.related.hu (hereinafter: Website) -, as well as the processing of personal data arising from these tasks, with the involvement of an external company (hereinafter: Data Processor). The Data Processor carries out data processing in accordance with the GDPR, Infotv., and other specific data protection legislation under the instruction rights of our company, as set out in the data processing agreement.
- data processor name: Mediadyn Ltd
- registered office: 9700 Szombathely, Váci Mihály street 65. 4th floor. 19.
- company registration number: 18-09-109982
- tax number: 23062595-2-18
- statistical code: 23062595-6311-113-18
- e-mail: [email protected]
- mailing address: 9700 Szombathely, Váci Mihály street 65. 4th floor. 19.
The servers serving the Website and the System are located at an external server hosting provider (hereinafter: additional Data Processor).
- additional Data Processor name: Rackforest IT Commercial Service Provider and Consultant Ltd
- registered office: 1064 Budapest, Podmaniczky street 57. 2nd floor. 14. 3rd floor. 3008.
- company registration number: 01-09-914549
- tax number: 14671858-2-41
- statistical code: 14671858-6202-113-01
- e-mail: [email protected]
- mailing address: 1064 Budapest, Podmaniczky street 57. 2nd floor. 14. 3rd floor. 3008
4.1. Scope of personal data processed
The System exclusively stores online identifiers provided by the devices and equipment (computer, mobile phone, other internet access device - hereinafter collectively referred to as: computer) used by Users, thus the IP address and cookie identifier of the Users' computers. Furthermore, the System automatically logs the IP address of the computer initiating access; the day and time of access/request; the name of the visited page or file; the referral to the page from which access to the System's services was made; the type and version number of the browser used by Users; and the operating system used by Users (hereinafter collectively referred to as: data recorded in the log file).
The IP address is a unique network identifier, a unique set of numbers that identifies Users' computers to send data to other computers and receive data from them. Our System automatically records the IP address of Users when they visit the Contracting partner's website.
A cookie, also known as a web cookie, is a small file used to store useful information and improve the browsing experience, which is placed on Users' computers when they visit a website. A cookie, as a sequence of characters, is not capable of identifying Users in any way on its own, but only of recognizing their computer and uniquely identifying their browser.
Our System places the following cookie on the User's computer:
| Cookie name | Stored personal data | Purpose | Validity period | Legal basis |
|---|---|---|---|---|
| r_uid | does not store personal data | Necessary cookie for the operation of the System, its purpose is to recognize returning visitors, optimize ad display, and content recommendations | 60 days | User consent |
4.2. Purpose of data processing
Our Company processes the IP address and log file data of Users for the purpose of ensuring the security and legality of the System's operation. By storing the IP address, we can protect the System's data, traffic, and Users from potential abuse, illegal use, and hacker attacks.
We manage cookies in the System to improve the quality of the System's advertising and content recommendation services. With the help of the placed cookie, returning visitors can be recognized, and the repetition and frequency of the same advertisement display can be determined for them.
Personal data is processed and used exclusively for the above purposes, until the purpose is achieved. The use of collected personal data for purposes other than the intended purpose is only possible with the prior, explicit consent of the Users.
4.3. Legal basis for data processing
IP Address: With regard to our legitimate interest, our Company automatically records the Users' IP address when they access our Contractual Partners' websites, without the Users' separate consent. Our legitimate interest is to ensure the legal provision of the System's services, filter out illegal use, and protect the System from external attacks.
Log file data: During the use of the System's services, the storage and use of data recorded in the log file by our Company are exclusively for technical and security purposes, analyzing the secure operation of the System, and subsequent control.
Cookies: The placement of cookies used by the System is based on the consent given by the Users, which can be provided by the User when visiting the Partner's website.
We would like to draw the attention of Users to the fact that they have the option to delete or disable cookies in their browser, as most browsers support the management of cookies. If Users do not want cookies to be placed on their computer, they can set this in the "Options" or "Settings" menu of their browser to not allow the placement of cookies. During the settings, individual cookies can be deleted, stopped, or completely disabled manually. Users also have the option to enable cookies only on certain websites. Please be aware that by disabling cookies, certain services of the System will not be available.
The following links can help with performing cookie settings:
- Chrome: https://support.google.com/chrome/answer/95647?hl=en
- Edge: Delete and manage cookies (microsoft.com)
- Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer?redirectlocale=en-US&redirectslug=Cookies
- Internet Explorer: https://support.microsoft.com/hu-hu/topic/cookie-k-t%C3%B6rl%C3%A9se-%C3%A9s-kezel%C3%A9se-168dab11-0753-043d-7c16-ede5947fc64d
- Safari: Manage cookies and website data in Safari on your Mac: https://support.apple.com/hu-hu/guide/safari/sfri11471/mac
4.4. Duration of data processing
Automatically recorded IP addresses and data recorded in log files are stored for up to 60 days following their recording.
Cookies remain on the users' computers until they expire or until the users delete them. The validity period of the cookies we use is 60 days.
The above duration is necessary to optimize the display of editorial content and advertisements, as well as to identify possible fraud and unlawful use.
4.5. External ad-serving tools
Adverticum provides ad serving on the advertising surfaces of the System. Users are evaluated solely based on cookies, which ensures that users remain anonymous. The data management information of the service can be accessed here:
https://adverticum.net/adatvedelmi-tajekoztato/
5. Data processing on www.related.hu website
5.1. Scope, purpose, legal basis, and duration of personal data processing
On our website, personal data is not collected beyond the technically automatic data processing and the voluntarily provided data on the contact form.
5.1.1. IP addresses and data recorded in log files
Our company automatically records users' IP addresses when they access the website, based on our legitimate interest. Our legitimate interest is to ensure the lawful operation of the website, and to detect unlawful use and fraud. The website also automatically logs the date and time of access/requests, the name of the visited page or file, the referral link from which the user accessed our services, the type and version number of the browser used by users, and the operating system used by users (collectively referred to as data recorded in log files).
The aforementioned automatically recorded data is stored for up to 60 days following their recording. This duration is necessary to identify potential fraud and unlawful use.
5.1.2. Cookies
When visiting our website, the following cookies are placed on the user's computer:
| Cookie name | Stored personal data | Purpose | Validity period | Legal basis |
|---|---|---|---|---|
| related_session | no personal data is stored | Essential for the operation of the website. | automatically deleted from the computer within 2 hours after leaving the website | legitimate interest |
| XSRF-TOKEN | no personal data is stored | Essential for the operation of the website. It is used in various forms. The purpose of its use is to prevent others from submitting forms on behalf of the user | automatically deleted from the computer within 2 hours after leaving the website | legitimate interest |
5.2. Web analytics and ad-serving external tools
On the one hand, our company collects information on how users use the website with the help of analytical tools, and on the other hand, we use measuring pixels provided by ad-serving providers to measure the effectiveness of our marketing communication and to better tailor online ads.
5.2.1. Web analytics tool used on our site
Google Analytics, which is a statistical service that collects information about how users use the website. Users are evaluated exclusively based on cookies. No other data is used, and as a result, users remain anonymous. The use of the tool can be restricted or disabled in the "Advertising settings" menu. Google's English language privacy policy is available here: https://www.google.com/intl/hu/policies/privacy
5.2.2. Ad-serving tools used on our site
Adverticum, which is a tool for measuring the effectiveness of marketing online communication and for better tailoring online advertising. Users are evaluated exclusively based on cookies, which ensures that users remain anonymous. Adverticum's privacy policy is available here: https://adverticum.net/adatvedelmi-tajekoztato/. The use of the tool can be restricted or disabled at https://adverticum.net/szolgaltatasaink/adserver/opt_out/
Facebook also serves to measure the effectiveness of marketing online communication and to better tailor online advertising. Users are evaluated exclusively based on cookies, which ensures user anonymity. Facebook's English language privacy policy is available here: https://www.facebook.com/business/gdpr
We draw the attention of our users to the fact that cookies from third parties are set by services appearing on our pages, over which we have no control. Detailed information about these cookies can be found in the links above.
5.3. Contact
Visitors to our website have the opportunity to send us a message using a form. The user provides the information on the form. The user's name, email address, and phone number must be filled in. We need this information to respond to inquiries by phone or reply email. Our company does not use the user's phone number or email address for any other purpose or for any subsequent contact. If the user fills out the form incompletely, they will not be able to contact our company and will not receive answers to their questions.
We handle the personal data provided on the form for 30 days from the date of sending the response to the information request for the purpose of resending the response email to the user if it does not reach them.
6. Data transfer, data processing, and the scope of persons authorized to access the data
Our company does not transfer personal data to third parties or authorities, except if required by law, authority decision, or if the user has previously consented to it. Before fulfilling any potential authority data requests, we always examine whether we can legally transfer the data.
Our company does not transfer data to third countries.
In addition to our company's employees, Mediadyn Kft., as the developer of the system, the operator of the system and the website, and the data processor, has access to the data automatically known during the technical operation of the system and the data known on the www.related.hu website.
Data transfer to the Data Processor can be carried out without the separate consent of the Users.
The servers storing the personal data are located in the data centers of Rackforest Kft., a server hosting provider, acting as an additional Data Processor. The authorized employees of Rackforest Kft. have physical access to the machines. Their privacy policy can be found at the following link: https://rackforest.com/wp-content/uploads/2020/04/adatkezelesi-szabalyzat-2020-kls-1.pdf
7. Information on data security measures
Both our company and the Data Processors listed in this Information maintain the security of personal data by storing and processing the data in a closed, continuously monitored IT environment. We ensure that unauthorized persons do not have access to personal data, cannot modify, delete, or copy them. We also ensure that the data management system can be restored in case of malfunction and that the system remains operational, with reports on any errors occurring during its operation. Furthermore, we ensure that personal data stored cannot be altered due to system malfunctions. Within this framework, we provide measures to protect against unauthorized access, including software and hardware protection, as well as physical protection (access control, network protection). Our computers are password-protected, and we continuously update the software used. To defend against potential external attacks, we provide firewall protection. The possibility of restoring data files is ensured by regular backups.
8. Users' rights and enforcement options
Users have the right to be informed about whether their personal data is being processed. If so, they have the right to access their personal data, correct inaccurate, incorrect, or incomplete personal data, request the deletion of personal data, and, in certain cases, restrict their use, unless this is restricted by law.
Users are entitled to request the permanent and irreversible deletion of their personal data if the processing of their data is based on their consent.
Users may restrict the use of their personal data in cases where they dispute the accuracy, validity, or completeness of their personal data, or if the data processing is unlawful and the Data Controller opposes the deletion of the data, or the Data Controller no longer needs the personal data for the purpose of data processing, but the Users require them for the submission, enforcement or protection of their legal claims; or if the Users have objected to the data processing.
In case of clarification of personal data accuracy, the restriction may last until the accuracy of the personal data is verified, and in case of objection, until it is determined whether our Company's legitimate grounds prevail over the Users' interests.
Furthermore, Users have the right to the portability of their personal data provided voluntarily or for the performance of a contract, that is, to receive a copy of their data in a machine-readable and conventional format, and to transmit this data to another data controller without hindrance.
Users may object to the processing and use of their personal data for the benefit of our Company. They have the right to withdraw their consent to the use of their data for specific purposes at any time. In case of withdrawal of consent, the processing and use of the data prior to the withdrawal shall be considered lawful.
Our Company shall comply with the request of Users, if it is well-founded, without undue delay, in the shortest possible time, but no later than one month after the receipt of the request, which may be extended by a further two months if necessary.
Our Company shall inform the affected Users and all those to whom the personal data has been previously transmitted for data processing purposes about the restriction, deletion, and correction of the processed personal data. The notification may be omitted if it does not infringe upon the legitimate interests of the data subject in light of the purpose of data processing.
We ask Users to contact us if they believe that their rights related to the protection of their personal data have been violated so that we can examine their complaints and remedy any possible infringement.
If Users believe that our Company or the Data Processor indicated in the Notice processes their personal data in violation of the law or the provisions of the European Union regulation, they are entitled to turn to the Court. In this case, Users may decide to initiate the lawsuit before the court according to their place of residence or domicile.
Users also have the right to file a complaint with the competent authority (National Authority for Data Protection and Freedom of Information, headquarters: 1055 Budapest, Falk Miksa utca 9-11.; mailing address: 1363 Budapest, Pf. 9., phone: +36 (1) 391-1400, email: [email protected], website: www.naih.hu.)