DATA PROTECTION AND PRIVACY POLICY

Dr. Gergely Bán Law Office (registered seat: 1117 Budapest, Alíz utca 1. B/3.; represented by: dr. Gergely Bán attorney at law; the “Data Manager”) with respect to the provisions of Act No. CXII of 2011 on Informational Self-Determination and the Freedom of Information (the “Information Act”) adopts the following policy (the “Policy”) for the sake of the safety of the personal data being under its management. We notify the users that the browsing of the website found at www.ban-karika.hu (the “Website”) and the subscription to the newsletter shall simultaneously mean the acceptance of the following terms and conditions as well.


1. The person entitled to data management

1.1. The operator of the Website and the manager of the personal data are identical.
       Name of the Data Manager: Dr. Gergely Bán Law Office
       Address of the Data Manager:
       1117 Budapest, Alíz utca 1. B. épület 3. emelet
       Phone number of the Data Manager: +36 1 501 5360
       E-mail address of the Data Manager: office@ban-karika.hu

2. Scope of the Policy

2.1. The Policy enters into force on September 27, 2016 and shall remain valid and effective until the further action of the
       Data Manager.

2.2. The scope of the Policy covers all processes conducted by all organizational units of the Data Manager, in
        the course of which handling of personal data as stipulated in Section 3 Point 2 of the Information Act
       occurs.

3. Rules of data management

3.1. The Data Manager handles the personal data of the users revealed by them to the Data Manager in
       accordance to this Policy.

3.2. The Data Manager handles personal data solely for a designated purpose, in order to exercise rights and
       fulfil obligations, to the minimum extent and for the shortest period of time required for achieving the
       purpose. The data handling must comply with the purpose in all of its phases, and if the purpose of data
       handling ceases or the data handling is otherwise illegal, the data shall be deleted.

3.3. Prior to the registration of the data the Data Manager shall notify the data subject on the purpose and legal
       ground of the data handling in all cases.

3.4. The Data Manager handles personal data only if the data subject consents thereto voluntarily, firmly and
       expressively or if it is ordered by law or – on the basis of the authorization of law, within the scope
       stipulated therein – by decree of municipalities for a purpose based on public interest.

3.5. The employees performing data handling at the organizational units of the Data Manager and the
       employees of organizations participating in the data handling, performing an operation thereof as per
       engagement by the Data Manager shall handle the acquired personal data in a way as specified herein and
       in the Information Act.

3.6. Data protection obligations to be applied to natural and legal persons performing data processing as per
       engagement by the Data Manager are contained in the engagement agreement concluded with the data
       processor.

3.7. The director of the Data Manager shall, with respect to the particularities of the Data Manager, determine
        the organization of the data protection, the duties and powers related to data protection and the activities
        in connection thereto, and appoints the person performing the supervision of data handling.

3.8. The co-workers of the Data Manager shall ensure in the course of their work that unauthorized persons
       cannot look into the personal data, and to provide the personal data with appropriate protection against
       unauthorized access, change, transfer, disclosure, deletion or annihilation, as well as against accidental
       destruction and damage and becoming inaccessible due to changes of the technology applied.

4. Enforcement of the user’s rights

4.1. The user may apply to the Data Manager at its shown contact details for being informed on the
       management of his/her personal data, as well as for the correction and – with the exception of cases of
       data management ordered by law – the deletion thereof.

4.2. The Data Manager shall suspend the data handling for the period of evaluating the user’s objection
       against the handling of his/her personal data – but for a maximum of 5 days –, shall examine the
       substantiation of the objection and render its decision on which it shall inform the applicant in accordance
       with Section 21 Subsection 2 of the Information Act.

4.3. If the objection is justified, the Data Manager shall act according to Section 21 Subsection 3 of the
       Information Act.

4.4. Upon the user’s request related to the handling of his/her personal data the Data Manager shall provide
       the user with a written and easily understandable reply within the shortest period of time as from the
       receipt of the request, but within 25 – in the cases of exercising the right of objection within 15 – days the
       latest.

4.5. The Data Manager shall correct the incorrect data, provided that the required data and if necessary the
       underlying public documents providing substantiation thereof are available, and in the events of the
       occurrence of the reasons specified in Section 17 Subsection 2 of the Information Act, shall arrange for
       the deletion of the handled personal data.

4.6. The Data Manager may refuse requests only in the cases specified in Section 9 Subsection 1 or in Section
       19 of the Information Act, refusal may occur only in the form of a reasoned written notification as
       specified in Section 16 Subsection 2 of the Information Act.

4.7. Providing information is free of charge in principle, the Data Manager will charge the user for cost
       reimbursement only in the case specified in Section 15 Subsection 5 of the Information Act.

5. Data handling carried out in the course of using the Data Manager’s Website

5.1. The place of data handling: 1117 Budapest, Alíz utca 1. B. épület 3. emelet

5.2. Data handling of the Website
       Anyone has access to the Website maintained by the Data Manager without disclosing their personal data
       or revealing their identity, and can gain information from the contents stored on the Website and the sites
       attached thereto freely and without limitation.

5.3. Handling of the data of subscribers to the Newsletter
       The Data Manager sends newsletters regarding its activities (the “Newsletter”) to those who subscribe to
       this service. The users can subscribe to the Newsletter on the Website of the Data Manager.
       Registration number of the data handling: NAIH-61750/2013
       Purpose of the data handling: informing clients on changes of laws, legal points of interest and useful
       legal information
       Scope of handled data: name, e-mail address
       Legal ground of data handling: Section 5 Subsection 1 Point a of the Information Act – the consent of
       the data subject
       Deadline of data storage: until unsubscribing from the Newsletter, but the latest until the termination of
       the Data Manager
       Method of data storage: electronical

5.4. Handling data related to getting into contact
       All users may contact the Data Manager using all of its public contact details and the “Contact” section of
       the Website.
       In the course of contact the data subject decides on the handling of his/her personal data provided. The
       legal ground of the data handling is provided by the data subject by voluntarily providing the Data
       Manager with his/her data based on preliminary information for the purpose of making contact with
       him/her.
       By sending of the message, the users who use the “Contact” section voluntarily, firmly and expressively
       give their consent to their data be handled electronically by the Data Manager in a way as specified in the
       Information Act for up to 1 year as from the date of getting into contact.
       2By using the “Contact” section the user expressively consents to the usage of his/her name, e-mail
       address, the personal data provided in the course of contact, phone number and the description of the case
       presented by him/her by the Data Manager for the purpose specified in the course of getting into contact.

6. Rights and legal remedies related to data handling

6.1. The user may request from the Data Manager: (a) information on the handling of his/her personal data,
       (b) the correction of his/her personal data and (c) with the exception of obligatory data handling, the
       deletion or blocking of his/her personal data.
       If the user reckons that in the course of data handling by the Data Manager his/her right to protection of
       personal data has been violated, he/she may seek legal remedy at the competent authorities in accordance
       with the relevant statutes, i.e.
       a) may submit a complaint with the Nemzeti Adatvédelmi és Információszabadság Hatóság (National
           Data Protection and Informational Freedom Authority, address: 1125 Budapest, Szilágyi Erzsébet
           fasor 22/C.; www.naih.hu) or
       b) may file a lawsuit with the court.

       Rights and legal remedies related to data handling are regulated in detail in Chapters 13-17 and 30 of the
       Information Act.

7. Data processing

7.1. In the course of data handling the Data Manager shall not reveal the personal data handled to any third
       parties, and shall not avail itself of data processors.

8. Amendment of the Policy

8.1. The Data Manager reserves the right to amend this Policy in accordance with the laws in effect. Should
       the amendment of the Policy affect the handling of the personal data of the Website’s users in any way,
       the Data Manager shall inform the users on the changes via informational e-mail. Should the details of
       data handling also change deriving from the amendment of the Policy, the Data Manager shall repeatedly
       request the users’ consent to the further handling of their data.

9. Termination of data handling

9.1. The user may unsubscribe from the sending of newsletters any time without limitation or reasoning, free
       of charge. This can be done by sending a deletion request to the Data Manager (via e-mail or mail). In this
       case the Data Manager shall not send further newsletters to the user.

10. Miscellaneous

10.1. To any issues not regulated herein the provisions of the Information Act shall apply.

 

September 27, 2016
Dr. Gergely Bán Law Office
Data Manager

1117 Budapest, Alíz str. 1.
Office Garden B. building 3rd floor

Laworld Opten HVCA