Promera Management Ltd. © All rights reserved.
Promera Management Ltd. (as Service Provider, in Hungary: Promera Menedzsment Kft.)
Address: 8200 Veszprém, Deák Ferenc u. 10/H
E-mail: kozpont@promera.hu
ProtectionIn its data management practice, the Service Provider considers the relevant laws in force at all times. The data management principles published in this policy are in accordance with the following laws:
4.1 Personal data
Any data that can be associated with a specific natural person (hereinafter referred to as the data subject) identified or - directly or indirectly - identifiable based on personal data - especially the data subject's name, identification mark, and one or more physical, physiological, mental, economic, cultural, or social identity characteristics -, as well as conclusions drawn from the data concerning the data subject.
4.2 Consent
The voluntary and determined expression of the data subject's will, based on adequate information, with which they give their unambiguous consent to the processing of their personal data - in full or for certain operations.
4.3 Objection
The statement of the data subject by which they object to the processing of their personal data and request the termination of data processing or the deletion of processed data.
4.4 Data Controller
The natural or legal person, or organization without legal personality, who or which alone or jointly with others determines the purposes of data processing, makes and executes decisions regarding data processing (including the tools used) or has it executed by a data processor appointed by them.
4.5 Data Processing
Any operation or set of operations on data, regardless of the procedure applied, such as collection, recording, organization, storage, alteration, use, retrieval, transmission, disclosure, coordination or linking, blocking, erasure, and destruction, as well as preventing further use of the data, taking photographs, audio or video recordings, and recording physical characteristics suitable for identifying the person (e.g., fingerprint or palm print, DNA sample, iris image).
4.6 Data Transmission
Making the data accessible to a specified third party.
4.7 Disclosure
Making the data accessible to anyone.
4.8 Data Erasure
Rendering the data unrecognizable in such a way that their restoration is no longer possible;
4.9 Data Blocking
Marking the data with an identifying sign to limit their further processing permanently or for a specified period.
4.10 Data Destruction
The complete physical destruction of the data carrier containing the data;
4.11 Data Processing
Performing technical tasks related to data processing operations, regardless of the method and tools used for the execution of the operations and the place of application, provided that the technical task is performed on the data.
4.12 Data Processor
The natural or legal person, or organization without legal personality, who or which processes data on the basis of a contract with the data controller - including contracting based on legal provisions.
4.13 Third Party
A natural or legal person, or organization without legal personality, who or which is not the same as the data subject, the data controller, or the data processor.
4.14 Third Country
Any state that is not a member of the European Economic Area.
4.15 Cookie
A text file stored on our computer through the internet browser when visiting a website. Its function is to make surfing more convenient and personalized, as it allows us to store various personal data and passwords. Cookies can also be used to execute targeted/personalized advertising campaigns.
Personal data may be processed if:
Personal data may only be processed for a specified purpose, for the exercise of rights, and the fulfillment of obligations. At every stage of data processing, it must meet the purpose of data processing, and the collection and processing of data must be fair and lawful.
Only personal data that is essential for the realization of the purpose of data processing, suitable for achieving the purpose, may be processed. Personal data may only be processed to the extent and for the duration necessary for the realization of the purpose.
During data processing, the accuracy, completeness, and - if necessary for the purpose of data processing - up-to-dateness of the data must be ensured, and the data subject can only be identified for the time necessary for the purpose of data processing.
Personal data may only be processed with the appropriate prior consent based on information.
Personal data may be transferred by the data controller to a data controller or data processor conducting data processing in a third country if the data subject has expressly consented to it. Data transmission to a state belonging to the European Economic Area should be considered as if it were data transmission within the territory of European Union.
Before starting data processing, the data subject must be informed whether the data processing is based on consent or is mandatory. Before starting data processing, the data subject must be clearly and detailedly informed about all facts related to the processing of their data, especially about the purpose and legal basis of data processing, the person entitled to data processing and data processing, the duration of data processing, and who may know the data.
The information must also cover the data subject's rights and remedies related to data processing.
Data processing is based on the voluntary consent of users registering on the https://www.promeram.com website. Registration includes filling out a form containing personal data and accepting the terms described in the data management policy.
6.1 Data of visitors to the www.promeram.com website
Purpose of data processing: ensuring the operation of the website, monitoring, preventing security events, and subsequent evaluation.
Legal basis for data processing: Section 13/A (3) of Act CVIII of 2001 on certain issues of services related to the information society.
Scope of managed data: the date of the visit, the exact time, the address of the visited webpage, the address of the page visited before, the visitor's IP address, and data characterizing the used browser and operating system.
Deadline for data deletion: 2 years from the visit
6.2 Data collection by external service providers on the website
External service providers do not collect and manage personal data on behalf of Promera Management Ltd.
The web analytics service provider on behalf of Promera Management Ltd., Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043), is only entitled to manage data stripped of individual information. The applied data management principles can be found at https://www.google.com/intl/hu/privacy/.
6.3 Contact
On the oditsolitions.hu website, downloading certain studies, trial versions, requesting callbacks, and registering for webinars are treated as contact by the service provider.
Purpose of data processing: contact.
Legal basis for data processing: voluntary consent of the data subject.
Scope of managed data: company name, country, email address, name, telephone number, job position.
Deadline for data deletion: 2 years from the last contact
6.4 Subscription to the newsletter
Purpose of data processing: information, contact, and sending advertising offers.
Legal basis for data processing: voluntary consent of the data subject.
Scope of managed data: email address, name.
Deadline for data deletion: 2 years from the last activity
6.3 Application for job advertisements
Purpose of data processing: recruitment, contact.
Legal basis for data processing: voluntary consent of the data subject.
Scope of managed data: name, email address, year of birth, time spent in a programming position, known programming languages, language skills, highest educational qualification, previous workplace.
Deadline for data deletion: 5 years from the application date
The Service Provider deletes personal data if its processing is illegal, the purpose of data processing has ceased, or the legally defined time limit for data storage has expired, it was ordered by the court or the data protection commissioner.
The user can request the deletion of his personal data, which must be sent by e-mail to kozpont@promera.hu. The Service Provider deletes the data within 15 working days from the receipt of the deletion request.
8.1 What is a cookie?
Cookies are small text files in which websites store information about visits for a specific period of time and for a specific purpose. During repeated visits, the website can recognize the text file, thereby identifying the previous visitor.
The primary function of cookies is to make browsing more convenient and personalized, as we can store various personal data and settings with their help. Well-targeted, personalized advertising campaigns can also be implemented with the help of cookies.
8.2 Types of cookies
Cookies used on the site123.com website can be classified into 4 different categories, according to the classification of the International Chamber of Commerce: absolutely necessary for operation, performance-enhancing, storing individual settings, web analytics and advertising targeting. Acceptance and setting of their use takes place when the page https://promera.hu is opened using the CookieYes software.
8.3 It is absolutely necessary for operation
This type of cookie enables browsing on the website. Without these cookies, it would be impossible to serve the content visited on the site123.com website (including the use of secure protocols).
The site123.com website uses a cookie containing an encrypted character string to identify you while using the website. Every time you enter the user interface, we place this cookie containing a unique identifier on your computer.
8.4 Performance enhancer
These cookies collect information about how visitors use a website. For example, which pages are visited most often, where visitors encounter error messages.
These cookies do not store any information that could be used to identify visitors to the website. The information collected with their help is only aggregated and used anonymously. Their goal is to improve the functions and user experience available on the site123.com website.
8.5 Stores individual settings
These cookies make it possible to store the user name used on the website and the selected language preference. For example, a website can serve local news based on the visitor's geographic location stored in a cookie. These cookies are suitable for storing the changed font size and other similar settings. The settings stored in cookies are anonymous. Their stored values cannot be traced back to individual users for the operator.
8.6 Cookies for web analytics and ad targeting
These cookies make it possible for visitors to encounter advertising messages that match their interests.
The operator of the site123.com website uses the Google Analytics service for statistical analysis of visitor behavior. Even though the information transferred to the third party does not contain personal data, the visitation data can be traced back to the users in some cases.
The operator of the site123.com website uses Google Adwords and other advertising systems to display its online advertisements. These service providers can store the IP address of the visitors and other identification information, which is not considered personal data, in order to later display site123.com's advertisement on external websites.
We store personal data on dedicated servers.
Service Provider reserves the right to unilaterally modify this data management policy with prior notice to users. By using the service after the effective date of the modification, you accept the modified data management policy.
Data subjects may request information about the processing of their personal data and may request the correction or deletion of their personal data, except in cases exempted by law. Upon request, the Service Provider shall provide the data subject with information about their data, the purpose and legal basis of the processing, the duration of processing, the name and address (registered office) of the data processor, and who and for what purpose received or will receive the data. The data controller shall provide the information in writing, in an intelligible form, within the shortest possible time from the submission of the request, but no later than within 30 days. This information is provided free of charge. Requests for information must be sent by email to kozpont@promera.hu, and the data subject will receive a response within 8 business days.
The data subject may object to the processing of their personal data:
The data controller shall examine the objection within the shortest possible time from its submission, but no later than within 15 days, make a decision on its justification, and inform the applicant in writing about the decision.
If the Service Provider establishes the justification of the data subject's objection, it shall terminate the data processing, including further data collection and transmission, and shall lock the data, and inform all those to whom the personal data affected by the objection has been previously transmitted and who are obliged to take action to enforce the right of objection.
If the data subject disagrees with the decision made by the data controller regarding the objection, or if the data controller fails to meet the 15-day deadline set for the investigation, the data subject may appeal to the court within 30 days from the notification of the decision or the last day of the deadline.
The data controller acknowledges the content of this information as binding and undertakes to ensure that the data processing related to its service meets the expectations specified in this information.
The newsletter service may be used voluntarily by the User based on their own decision by providing their name and email address voluntarily, which the operator of the website is entitled to process and store in its database for this purpose. The purpose of providing personal data related to the newsletter service is communication to the User. The operator of the website informs the User that the processing of the provided data is valid until the withdrawal of consent.
15.1 Managing Customer Orders
If we want to use your data for any other purpose, we will ask for your consent, and we will only use your data for that purpose(s) after obtaining your consent, except as ordered by the court.
15.2 Sharing Data with Third Parties
We do not share your personal data with third parties without your consent, except in the limited cases described below:
15.3 Analytics
We require such third parties to use the personal data provided by us only for the purposes for which it was transmitted and not to retain it for longer than necessary to achieve that purpose.
15.4 Others
We may disclose your personal data for the following purposes: (1) to comply with applicable laws, regulations, court orders, or other legal proceedings; (2) to enforce agreements with us, including this Privacy Policy; or (3) to respond to claims that the use of the Service violates the rights of third parties. If the Service or our company is merged or acquired by another company, your data is one of the assets transferred to the new owner.
The security of your data is important to us, and we take reasonable security measures to prevent the loss, misuse, or unauthorized alteration of data under our control. However, due to inherent risks, we cannot guarantee complete security, so you assume responsibility for transmitting information to us.
18.1 Data Processors
We use the szamlazz.hu software of KBOSS.hu Ltd. (1031 Budapest, Záhony utca 7/D.) to issue invoices.
MediaCenter Hungary Ltd. (6000 Kecskemét, Erkel Ferenc utca 5.) provides server hosting services.
18.2 Other Data Controllers
The accounting tasks of our company are performed by Szula Gyöngye Kft. (8200 Veszprém, Ányos Pál u. 20).
Depending on the applicable law, you may be entitled to access your personal data and correct or delete it, or you may receive a copy of your personal data, restrict or object to the active processing of your data, or ask us to share (carry) your personal data. You can request information for another legal entity, withdraw your consent to us processing your data, the right to file a complaint with a legal authority, and any other rights that may be relevant under applicable laws. To exercise these rights, write to us at kozpont@promera.hu. We will respond to your request in accordance with the relevant legislation.
Please note that if you do not allow us to collect or process the necessary personal data, or withdraw your consent to the processing of such personal data for the desired purposes, you may not be able to access or use the services for which your data was required.