Privacy Notice

The purpose of this notice is to inform you (hereinafter: you or the data subject) about our practices relating to the processing of your personal data, the categories of data we process, the measures we take to secure your data, and your rights in connection with the processing, in line with the requirements of EU Regulation 2016/679 (hereinafter: the Regulation or GDPR) and the relevant Hungarian legislation, during your visit to the ethicode.eu website.

1. Who is the data controller?

This notice covers the data processing of Legalnet Kft. as data controller in connection with the use of the ethicode.eu website.

Details and contact of the data controller:

2. Principles

• We are committed to protecting your personal data and processing it lawfully, to the extent and for the time necessary to achieve the purpose.
• Where the nature of the processing allows, we provide a simple and effective choice regarding your data.
• We carefully select the partners involved in processing personal data, and we transfer personal data to our partners only in accordance with the content of this privacy notice, subject to legal and technical guarantees.
• We apply appropriate technical and organisational measures to protect your personal data against unauthorised access, use, modification or deletion.
• We take data protection aspects into account in every case when designing our processes (data protection by design).
• We work to ensure that our measures protect data to the greatest possible extent even when data protection has to be balanced against other obligations.

3. Definitions

• 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,
• special categories of personal data: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation,
• 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,
• processor: the natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

4. Categories of personal data we process

During the visit to the website, contact made via the website and – where it takes place – the conclusion and performance of a contract, we process the following data:

The website does not use cookies, and does not carry out profiling or advertising tracking. To measure traffic we use a cookie-free, privacy-friendly analytics solution (Cloudflare Web Analytics) that does not collect personal data and cannot identify or track individual visitors. In your browser's local storage (localStorage) we store only your selected language setting (Hungarian/English), which is necessary for the convenient operation of the website, remains solely on your device, and is not transmitted anywhere.

• Your contact details (name, address, email address, company data) for the purpose of keeping in contact.
• Contact details necessary for concluding a contract (name, email address, phone number, company identification data).

5. Legal basis of our processing

We always process your data on a legal basis defined by law. This differs for the various processing activities; such legal bases are:

• Consent: in cases where you give your consent, we process your data on this basis (for example, contact via the form on the website). You may withdraw your consent at any time, but this does not affect the lawfulness of processing before the withdrawal.
• Legitimate interest: in the case of technical storage necessary for the operation and security of the website (for example, storing the language setting locally in the browser).
• Preparation and performance of a contract: the company identification and contact data necessary for concluding and performing a contract.

6. Purpose of the processing

We process the personal data falling into the categories listed above for the purpose of the proper operation of the website, providing the information you request, and concluding and performing a contract.

7. Data transfers

In order to carry out certain activities and achieve data processing purposes, or possibly to fulfil a legal obligation, it is necessary to transfer your personal data to third parties. In certain cases we share your data with the following service providers:

• Hosting provider: the website is served by Cloudflare, Inc. During the technical operation of the hosting, the provider's server logs may temporarily process certain technical data (for example, IP address). Cloudflare operates with guarantees compliant with EU data protection requirements.
• Contact form: the technical transmission of the data sent via the website's contact form (name, email address, company, message) is carried out by the Web3Forms (Backpack Lab) service as a data processor. After the form is submitted, the data is forwarded to our address [email protected].
• Email provider: we use an email provider for keeping in contact (Google LLC).

Occasionally we also share data with other contractors providing services to us in connection with the purposes defined in this notice (for example, an accounting service provider in the case of contracting and invoicing).

If we transfer your personal data to a country outside the European Economic Area (for example, where data is stored on servers and in a data centre outside the EEA), we ensure that such transfer takes place on an appropriate legal basis and that your personal data enjoys protection compliant with the applicable legislation, for example through the use of standard contractual clauses (SCC) approved by the competent authorities and by requiring other appropriate technical and organisational measures to protect your personal information.

8. Duration of the processing

We retain your personal data for the period prescribed by law. Where the law does not prescribe a period for storing the given data and purpose, we store them for the period strictly necessary to achieve the purpose, after which we ensure the deletion or anonymisation of the data. In cases where such long storage of the data is not necessary, we delete them sooner. We always determine the time of deletion at the earliest possible time, after weighing the circumstances and purposes. Data processed on the basis of your consent will be deleted at any time upon withdrawal of consent, provided that no other legal basis is available for their further processing. The withdrawal does not affect the lawfulness of processing carried out before the withdrawal of consent.

9. Security of your data

We apply strict security and organisational measures to the best of our knowledge to protect your personal data against unauthorised access, use, data loss, disclosure or destruction. To this end, for example, we store them in a controlled environment with restricted access, we protect data stored in IT systems with a firewall and antivirus protection, and in the case of data stored on physical media we ensure physical protection. Only those may access your data who need it for the achievement of the data processing purpose.

When designing our processes, we keep in mind the incorporation of appropriate data protection measures and security guarantees.

10. Your rights regarding your data

You have a number of rights regarding your personal data, which you may exercise by a request sent to the email address [email protected]. These rights are:

• Right of access: you may request information about the data we process about you, and upon request we provide a copy of it.
• Right to rectification or updating of your data: you have the right to have the data we hold corrected if it is not recorded correctly.
• Right to object: you have the right to object to the processing of your personal data in cases where the processing is based on our legitimate interest. In this case, if no other legal basis can be established for the processing, we terminate it.
• Right to erasure: in certain cases you have the right to request that we delete the personal data we store about you.
• Right to restriction of processing: you may request the restriction of the processing of your data if you feel that the data is not correct, or you do not want us to process it, until the enforceability of another right is decided.
• Right to data portability: in certain cases you have the right to take the personal data you provided to us, in which case we hand it over in electronic form.

In the case of a request to exercise your rights, we examine it without delay and comply with it within one month at the latest, or inform you of the reason for any refusal.

11. Remedies

If you have any concern regarding the processing of your personal data, we ask that you first contact us so that we can clarify the question or concern. If we are unable to provide a satisfactory answer, you may lodge a complaint with the data protection authority or bring an action before the court.

Contact of the data protection authority:

12. Scope of the privacy notice

This notice is effective from the day of publication; however, we update it regularly, so we recommend that you check it from time to time.