This document details the policy of Eszter Alinka Balázs (hereinafter: Service Provider), tied insurance intermediary and the operator of the website http://www.4theclients.hu (hereinafter: Controller) on the processing of personal data provided by third parties (hereinafter: Data subjects) on the website.

Contact:

Email address: [email protected]

Telephone number: +36 20 359 67 36

The privacy policy was compiled in accordance with the provisions of General Data Protection Regulation No. 2016/679 (hereinafter: GDPR).

1. Scope of processed data, legal basis, purpose and duration of processing

1.1.   Data processed for purpose of requested proposals

Cases of processing, purpose of processing and scope of processed data

Visitors to the website interested in insurance services may request an insurance offer by filling out an online form. Following the request, the Service Provider contacts the requester to discuss the insurance options in person before entering into a contract.

The Service Provider is registered at the National Bank of Hungary as a tied insurance intermediary of Generali Biztosító Zrt. (registration number: 105030431434) and conducts its insurance brokerage activities in compliance with prevailing laws and regulations.

To provide an insurance offer, we process your name and email address.

The data received is handled in strict confidence as per the law.

Legal basis for processing

Pursuant to Article 6 (1) b) of the GDPR the legal basis of the processing is the preparation, and later conclusion and performance of an insurance intermediation agreement concluded by and between you and the Service Provider.

Duration of processing

Your data is processed while your request for an offer is handled. If an intermediation agreement is later concluded, the data provided is processed to facilitate the conclusion and performance of the agreement.

1.2.   Contact menu option

Cases of processing, purpose of processing and scope of processed data

On our website we enable you to contact us directly by filling in and submitting a contact form. On the form you need to provide your name, email address and your message.

Legal basis for processing

Your consent pursuant to Article 6 (1) a) of the GDPR is the legal basis for processing.

Duration of processing

Your data is processed while your contact request is handled.

1.3.   Data processed during complaints

Cases of processing, purpose of processing and scope of processed data

We process personal data when handling any issues related to our services or managing your complaint.

During complaint procedures we process your name, contact details (email, address, telephone number, postal address) and your complaint.

The purpose of the processing is to enable adequate complaint and guarantee management in accordance with laws and regulations.

Legal basis for processing

Pursuant to Section 6 (1) c) of the GDPR, the legal basis for processing in complaint management by insurance companies, multi-agents and brokers is governed by the detailed provisions of Government Decree 437/2016 (XII.16).

Duration of processing

In accordance with the consumer protection act, data are processed for 5 years following the complaint procedure.

2. Processors

We use the following processor for processing data:

• GOLDEN HIGHWAY Kft., H-2051 Biatorbágy, Nagy utca 30

3. Processing of cookies

Certain parts of the website use small data files (hereinafter: cookies) to identify you. By visiting the website and using its functions, Data subjects consent to the storage of such cookies on their computers and to the processor accessing these.

You may block cookie-related activities in your browser settings. However, please note that without allowing cookies you may not be able to access all the services of the website.

As a technical contributor, the Service provider may enable cooperating third parties, in particular Google Inc., to store cookie files to identify whether the Data subject has already visited the Service Provider’s website and display advertisements for the Data subject on this basis.

You can delete cookies from your computer or can set your browser to prohibit the use of cookies. Furthermore, Google ensures that users can choose to block Google cookies on a website operated by Google to turn advertisements off (https://policies.google.com/technologies/ads/). Use of the website may become more inconvenient for the Data subject if cookies are blocked or deleted.

What are cookies and how do we manage them?

Cookies are small data files that are created on your computer via a website by using said website; they are saved and stored by your browser.

General tasks of cookies:

• they collect data on the visitors and their devices;
• they save the visitors’ individual settings, which are (can be) used e.g. for online transactions, so data does not have to be typed in again.
• they make use of the website easier;
• they provide a quality user experience.

To ensure a customised service, data packages, so-called cookies, are placed on the computer of the user and read upon subsequent visits. If the browser returns a previously saved cookie, the service provider managing the cookie can link the current visit of the user to previous visits, but only in respect of its own content.

The majority of the most popularly used browsers (Chrome, Firefox, Edge, Explorer, Opera, Safari, etc.) accept and allow the download and use of cookies by default, but it is up to you whether you refuse or block these through your browser settings, or delete the cookies already on your computer.

You can read more on the use of cookies under the Help option of each browser.

How to turn off cookies in certain browsers:

• Chrome: https://support.google.com/accounts/answer/61416?hl=en
• Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
• Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies#ie=ie-11
• Safari: https://support.apple.com/kb/PH21411?viewlocale=en_US&locale=en_US
• Edge: https://support.microsoft.com/en-gb/help/10607/microsoft-edge-view-delete-browser-history
• Opera: https://help.opera.com/en/latest/web-preferences/#cookies

4. Your rights regarding processing

During the processing you have the following rights pursuant to the GDPR:

• access to personal data and information on processing,
• right to rectification
• restriction of processing,
• right to erasure,
• right to data portability,
• right to object,
• right to withdraw consent.

If you wish to exercise any of your rights, you need to identify yourself and we need to communicate with you. Therefore you will need to provide personal data for the purpose of identifying you (however, identification may only be based on data we already process about you), and your processing complaint will be accessible in our email box during the time frame set forth in this policy.

Complaints regarding data processing will be responded to within no more than 30 days.

4.1.   Right to withdraw consent

You are entitled to withdraw your consent to processing at any time. In such cases we delete the data provided by you from our systems.

4.2.   Access to personal data and information

You are entitled to obtain confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, you have the right to:

• access the processed personal data and
• gain information on the following:
  • the purposes of the processing;
  • the categories of personal data processed about you;
  • information on the recipients or categories of recipient, to whom or to which we disclosed or will disclose the personal data;
  • the planned period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period;
  • your right to request rectification or erasure of personal data concerning you or a restriction of processing such data, and if the processing is carried out based on a legitimate interest, to object to the processing of such personal data;
  • the right to lodge a complaint with the supervisory authority;
  • where the data are not collected from you, any available information as to their source;
  • the existence of automated decision-making (if applicable), including profiling, and, at least in these cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

The purpose of exercising your rights might be to establish the lawfulness of data processing and its controlling, therefore we may charge a reasonable fee as consideration for multiple information requests.

We ensure you have access to your personal data by sending the processed data and the information to you in an email after identifying you.

In your request, please indicate that you wish to access your personal data and ask for information on the processing.

4.3.   Right of rectification

You have the right to obtain without undue delay the rectification of inaccurate personal data concerning you.

4.4.   Right to restriction of processing

You have the right to obtain restriction of processing where one of the following applies:

• you contest the accuracy of the personal data, in which case the restriction pertains to a period enabling us to verify the accuracy of the personal data, and if verification is not needed, we will not apply the restriction;
• the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
• we no longer need the personal data for the purposes of the given processing, but they are required by you for the establishment, exercise or defence of legal claims; or
• you have objected to processing, but our legitimate interest may provide grounds for processing, in which case processing must be restricted until the verification about whether our legitimate grounds override yours is available.

Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

We shall inform you in advance about when the restriction of processing is lifted (at least 3 days prior to the lifting).

4.5.   Right to erasure – right to be forgotten

You have the right to request the erasure of your personal data without undue delay where one of the following grounds applies:

• the personal data are no longer needed in relation to the purposes for which they were collected or processed;
• you withdraw consent, and there are no other legal grounds for the processing;
• you object to the processing on the basis of legitimate interests and there are no overriding legitimate grounds (i.e. legitimate interests) for the processing;
• the personal data were illegally processed by us, and this was determined in a complaint procedure;
• the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which we are subject;

If we have published personal data concerning you for any legitimate reason and they need erased in line with any of the reasons above, then taking account of available technology and the costs of implementation we shall take reasonable steps, including technical measures, to inform other controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data. As a general rule, we do not publish your personal data.

Erasure shall not be applied if processing is necessary:

• for exercising the right of freedom of expression and information;
• for compliance with a legal obligation which requires processing by Union or Member State law to which we are subject (such cases include processing while issuing invoices, since retaining invoices is prescribed by law) or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• for the establishment, exercise or defence of legal claims (e.g. if we have outstanding receivables from you, or a customer or processing complaint procedure is underway).

4.6.   Right to object

For personal reasons you may object to the processing of your personal data based on legitimate interests at any time. In such cases we shall no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or are related to the establishment, exercise or defence of legal claims.

4.7.   Right to data portability

If processing is necessary to fulfil a contract, or is based on your voluntary consent, you have the right to request the data provided by you to be sent to you in a machine-readable format, which we shall give you in xml, JSON or csv format; if it is technically feasible you may request the data to be forwarded to other controllers in this format.

4.8.   Legal remedy options

If you believe we have violated any processing regulations or have not fulfilled any of your requests, you may apply for a review procedure at the National Authority for Data Protection and Freedom of Information (postal address: H-1530 Budapest, PO Box: 5, email: [email protected]) to have the alleged unlawful processing terminated.

In addition, please note you may initiate a civil lawsuit at a competent court.

5. Data security

During the operation of our IT systems we provide the necessary rights management, internal organisational and technical solutions to prevent your data being accessed, deleted, saved outside our system or modified by unauthorised persons. We ensure our data protection and data security requirements are complied with by our processors too.

We register any potential personal data breaches and we provide you with information on any breaches if necessary.

6. Other provisions

We reserve the right to modify this privacy policy without affecting the purpose and legal basis of the processing.

If, however, we wish to conduct further processing of the collected data for a purpose different from the purpose of collection, we shall inform you about the purpose of the processing and the following additional information prior to the further processing:

• the period for which the personal data will be stored, or if not possible, the criteria used to determine that period;
• your right to request access as well as the rectification or erasure of personal data concerning you or the restriction of processing such data, and if the processing is carried out based on a legitimate interest, to object to such processing; you may also request your right to portability for data which is processed based on consent or a contractual relationship;
• your right to withdraw consent at any time in the case of processing based on consent,
• the right to lodge a complaint with a supervisory authority;
• whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data, and what are the possible consequences of failure to provide such data;
• the existence of automated decision-making (if applicable), including profiling, and, at least in these cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

Processing may only begin thereafter; if the processing is based on consent, you also need to consent to your data being processed besides being informed about the privacy policy.

This Privacy Policy is effective as of 10 December 2019.