PRIVACY POLICY

Blaguss Travel Ltd. as the operator of the blagussdmc.com website (hereinafter referred to as: Website) hereby determines the general privacy policy rules of the use of the Website and the Services offered through the Website.

Definitions

Website
The blagussdmc.com website operated by Blaguss Travel Ltd.

Service Provider
The Blaguss Travel Ltd. registered by Metropolitan Company Court Budapest, Hungary under the No. 01-09-060504; headquarter: 1053 Budapest, Petőfi Sándor utca 11. 2. em. 6.; as the operator of the Website.

Services
Services offered by Service Provider through the Website, including Incentive Programs, services for Special Interest Groups, River Cruises, Congress Organization, Association Management, Accommodation Management, Product Shows, Corporate Events, Teambuilding Activities, Travel Services, services for FITs. The Service Provider is unilaterally entitled to modify, terminate, determine, introduce the Services he offers through the Website.

User
A private person, legal entity, person without legal entity or other organization visiting the Website and/or using the Services of the Website.

Privacy Act
Hungarian Act CXII of 2011 on the information freedom and information rights.

E-Commerce Act
Hungarian Act CVIII of 2001 on Electronic Commerce and on Information Society Services.

GTC
General Terms and Conditions on the use of the Website and on the Services offered by Service Provider through the Website, issued by Service Provider and published on the Website.

Acceptance of the Privacy Policy

1.

The User accepts the present Privacy Policy when she/he visits the Website or uses the Services offered through the Website. If the User has any concern about providing information to Service Provider or having such information displayed on the Website or in the Services or otherwise used in any manner permitted in this Privacy Policy and the GTC, he/she should not visit the Websites, register with the Website or otherwise use the Services.

Providing data on the Website or using the Services shall be deemed as acceptance of the present Privacy Policy and as granting consent to the management of the personal data without making any further legal statement.

Effect of the present Privacy Policy

2.

The present Privacy Policy shall be applied for the private persons’ personal data and does not cover the data of legal entities available in official public registry including but not limited to the companies’ company data.

Data manager

3.

Data manager is the Service Provider.

The personal data collected and managed

4.

Service Provider manages the following data with regard to the User on the Website:

4.1.

Related to sending e-mails to the Service Provider:
– name
– e-mail address
– other personal data provided by the User in the message.

4.2.

Personal data provided by the User in the communication with the customer service.

4.3.

Related to electronic direct marketing messages/newsletters the following personal data collected on the Website or on conferences, fairs, exhibitions, business trips, markets and other events by the colleagues of the Service provider or received from Euromic (12, rue du Helder – 75009 Paris, France) which the Service Provider is member of:

– name
– e-mail address
– phone number
– address
– postal address
– company name
– company position

4.4.

Data collected automatically:

During the use of the Website and the Services the following data are managed and technically saved by Service Provider: the data of the User’s login computer and mobile device which are generated during the use of the Website and which are saved as an automatic result of the technical processes on the Website, in particular:

– Internet Protocol (IP) address,
– type of the browser,
– language,
– operation system,
– internet service provider (ISP)
– timestamp
– The top-level domain-name used (for example .ie, .com, .org, .net)
– The pages visited on the BLAGUSS DMC Website, i.e. URL’s2 visited
– The previous Website address from which the visitor reached us, including any search terms used
– Clickstream data which shows the traffic of visitors around this Website (for example, pages accessed)

An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol (TCP/IP) network, such as the World Wide Web. Networks use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to your computer whenever you are surfing the Web, allowing Web servers to locate and identify your computer. Computers require IP addresses in order for users to communicate on the Internet, browse and shop.

A URL (Uniform Resource Locator) is the global address of documents and other resources on the World Wide Web. For example, http://blagussdmc.com is the URL for BLAGUSS DMC’s Home Page.

The data automatically saved on the Website are logged automatically when the User is logging in or logging out without any separate declaration or acting. These data shall not be linked to other personal User’s data, except in cases made biding by law. The data are only accessible to Service Provider as data controller.

Information collected according to the above are used for the purpose of the effective maintenance of the Website and the Services, the shadowing of the Users’ behaviour, the analysis of the trends and the collection of the demographic data of the totality of the Users by Service Provider. The above collected information may be used for the purpose of marketing and advertisement services and messages by Service Provider (e.g.: increasing the User’s experience, providing more attractive special offers and services).

Liability for the data provided by the User

5.

The Users are bound to provide real data in accordance with their valid identity card and they shall notify Service Provider of any changes in these data without delay, but no later than within 15 days.

Service Provider hereby excludes his liability for the damages arisen from providing misleading, wrong or false data or e-mail address, at the same time the Service Provider is entitled to claim the compensation of any and all damages arising from such activity of the User. Users are entitled to verify or modify their data at any time. Service Provider is entitled to cancel the data obviously wrong or false, in case of doubt Service Provider is entitled to control the reality of data.

Service Provider withholds the right to decline the registration of the User or the use of the Website or the Services in particular in case of providing unreal or false data or in case of suspicion of any abuse with the data provided by the User.

In the event that Service Provider becomes aware of that the User provides data of other or non-existing person or unreal or false data and/or the use of the Website and the Services which infringes the present Privacy Policy, third persons’ rights or the law, Service Provider is entitled to terminate the agreement concluded with the User with immediate effect and to delete the User and his/her all data from the database.

The personal data given by the User are not public and are not available for third persons.

The User acknowledges that persons under 18 years of age shall not use to the Website and the Services and shall not enter into a contract according to the present Privay Policy without their legal representative’s consent. Service Provider is not liable for the damages and penalties arisen from the lack of this legal representative’s consent.

6.

Users attend to download and install applications or programmes in case these are necessary for the functioning of the Website and Services on their devices.

The purpose of the data management

7.

The Service Provider processes the data prescribed in point 4 for the following purposes:

a) login to the Website
b) use of the Services available through the Website
c) identification of the User
d) conclusion of the contract related to the use of the Website and the Services, definition of its content, modification thereof, checking of its accomplishment, enforcement of claims resulted thereof
e) assuring the communication between Service Provider and the User
f) custom service, complaint management
g) use of the aggregated and anonymized data for statistical purposes to create surveys, statistics and demonstrations,
h) sending electronic newsletter, publicity, advertisement, direct marketing or other marketing content addressed to the User in case of the expressed consent of the User through the Website
i) sending system notices addressed to the User to the User’s e-mail address registered in the Website related to the Website and the Services
j) to increase the efficiency of, to improve the functioning of and to develop the Website and the Services
k) taking part in promotional games, notice of the winners, handing over the price to the winner (periodical promotions).

Provisions concerning subscription of eDM:

8.

According to the 7/h) point the User may subscribe freely, separately from the acceptance of the present Privacy Policy, to the dispatch of electronic publicity, advertisement, newsletter or marketing materials i.e. is he may expressly enable the sending of such content to his e-mail address entered on the Website or provided to the Service Provider or any third party Partner of Service Provider and the management of his e-mail address for this purpose. The User may freely unsubscribe from the newsletter at any time by clicking on the unsubscribe or similar button in the newsletter. Upon receipt of such notification Service Provider immediately but no later than within 1 working day ensures the cancellation of the e-mail address from the address list of the newsletter and that from this time the User shall not receive newsletter or other electronic advertisement, publicity or direct marketing material.

9.

The 7/i) point does not include the dispatch of system notice according to the 7/h) point, it is not considered as a direct marketing material, the User expressly agrees, by the acceptance of the present Privacy Policy to receive system notices to his e-mail address registered on the Website related to the Website and the Services, in particular but not limited to the functions and available Services on the Website, its modifications and expand, information relating to the modification of the present Privacy Policy or the GTC, accounting, payment, payment and purchase transactions.

Cookies

10.

Service Provider uses cookies and similar technologies, including mobile application identifiers, to help Service Provider recognize the User across different Services, learn about the User’s interests both on and off the Services, improve the User’s experience, increase security, measure use and effectiveness of the Services, and serve advertising. The User can control cookies through the user’s browser settings and other tools.

By visiting the Website and the Services, the User consents to the placement of cookies and beacons in the User’s browser and HTML-based emails in accordance with this Privacy Policy.

In general the cookie is a small file consisting of letters and numbers which is sent to the device of the User from the web server of Service Provider. It enables for example Service Provider to recognize the final appliance of the User when the connection is created between the web server of Service Provider and the device. The main purpose of the cookie is to enable Service Provider to make available individualized offers, publicity and advertisements for the User which may personalize the User’s experience during the use of the Website and may reflect more to the personal needs of the User.

11.

The purpose of cookies applied by Service Provider:

– Authentication: If the User is signed in to the Website, cookies help Service Provider show the User the right information and personalize the User’s experience.
– Security: Service Provider uses cookies to enable and support its security features, and to help Service Provider detect malicious activity and violations of the GTC.
– Preferences, features and services: Cookies can tell Service Provider which language the User prefer and what the User’s communications preferences are. They can help the User fill out forms on the Website more easily. They also provide the User with features, insights, and customized content in conjunction with Service Provider’ plugins.
– Advertising: Service Provider may use cookies to show the User relevant advertising both on and off the Website. Service Provider may also use a cookie to learn whether the Users who saw an ad on the Website later visited the advertiser’s site. Similarly, Service Provider’ partners may use a cookie to determine whether Service Provider has shown an ad and how it performed, or provide Service Provider with information about how the User interacts with ads. Service Provider may also work with a partner to show the User an ad on or off the Website, such as after the User has visited a partner’s site or application.
– Performance, Analytics and Research: Cookies help Service Provider learn how well the Website and plugins perform in different locations. Service Provider also uses cookies to understand, improve, and research products, features, and services, including when the User accesses the Website from other websites, applications, or devices such as the User’s work computer or the User’s mobile device.

12.

Type of cookies applied by Service Provider:

– analytics, tracking cookies
– session cookies which only last for as long as the session (usually the current visit to a web site or a browser session).
– persistent cookies which help us recognize the User as an existing user, so it’s easier to return to the Website without signing in again. After the User signs in, a persistent cookie stays in the User’s browser and will be read by the Website when the User returns to the site.

13.

Adobe Flash is another technology that can provide cookie-equivalent functionality. Adobe Flash is capable of storing information on the User’s device (in a file outside of your browser). Please note that not all browsers provide the ability to remove Adobe Flash “cookies” (also called “locally stored objects,” or “LSOs”). The User can restrict or block Adobe Flash cookies/LSOs through the Adobe website. As with any cookie, if the User does restrict flash cookies/LSOs, there may be some Website features the User is not able to use.

14.

Third party cookies:

Trusted partners help us serve advertising on and off the Website, and analytics companies like Google Analytics, Quantcast, Nielsen, and ComScore may also place cookies on the User’s device.

15.

Controlling cookies:

Most browsers allow the User to control cookies through their settings preferences. However, if the User limits the ability of websites to set cookies, the User may worsen the User overall user experience, since it will no longer be personalized to the User. It may also stop the User from saving customized settings like login information.

If the User does not want Service Provider to use cookies when he/she visits the Website, the User can opt out of some cookies on the User’s settings page. In order for Service Provider to recognize that the User has opted out of cookies, Service Provider has to place opt-out cookie on the User’s device so Service Provider can know not to set other cookies the next time the User visits. If the User does not want to receive cookies, the User can also change the browser settings on his/her computer or other device he/she is using to access the Services. If the User uses the Website without changing the browser settings, Service Provider will assume that the User is happy to receive all cookies on the Website. Please note that the Website will not work properly without cookies.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit wikipedia.org, www.allaboutcookies.org, or www.aboutcookies.org.

Legal basis of the data management

16.

The legal basis of the data procession is firstly the consent given by the Users and in case of the Invitation services the Receiving Parties pursuant to point a) of paragraph (1) of section 5 of the Privacy Act, secondly the authorization for data processing provided by the section 13/A of the E-Commerce Act pursuant to which the User’s natural identification data (name, birth name, mother’s birth name, time and place of birth) and address can be processed without the User’s consent for the purpose of establishing contracts for information society services and of defining their contents, of subsequent amendments and of monitoring the performance of these contracts, of invoicing the relevant fees, and of enforcing the claims arising out of or in connection with such contracts, additionally the natural identification data, address, and information relating to the date, the duration and the place of using the service of the User can be processed without its consent for the purposes of the payment of the fees payable under the contracts.

17.

The User by accepting present Privacy Policy and by registering to the Website accepts the data processing provisions of present Privacy Policy and gives consent to the procession of his/her personal data for the purpose, to the extent, in the manner, for the volume and time as prescribed in present Privacy Policy.

The duration of data processing

18.

Service Provider manages the data from the recording thereof to the extent and time necessarily suitable for the purpose of the data processing, but maximum until 5 years from the termination of the contract between Service Provider and the User aiming the use of the Website.

Scope of persons entitled to access the personal data

19.

Service Provider and the employees thereof are entitled to access the personal data of the User.

20.

Service Provider is the member of Euromic (12, rue du Helder – 75009 Paris, France) which is a non-commercial association of leading Destination Management Companies in Europe. Service Provider and Euromic cooperate in marketing issues in the framework of which the Service Provider forwards the data indicated in clause 4.3 and collected by Service Provider on different events, markets, conferences, fairs, exhibitions to Euromic for the purpose of sending electronic newsletters to those people. User hereby accepts this data forwarding.

Information about the rights and right enforcement possibilities of the persons affected

21.

According to the sections 14-19 of the Privacy Act the User is entitled to request from Service Provider:

a) information regarding the processing of his/her personal data
b) the rectification of his/her personal data
c) the erasure or blocking of his/her personal data

22.

In case of infringement in the procession of personal data the User may bring an action against Service Provider before the court competent at the Service Provider’s seat (Metropolitan Tribunal of Hungary).

Data security

23.

Service Provider stores on its central server the data entered on the Website by the User and the data entered into the database connected to the Website.

24.

Service Provider ensures that unauthorized third persons shall not access the User’s personal data entered into the Website. In order to fulfil this obligation, Service Provider shall implement appropriate technical and organizational measures and shall create adequate procedural rules for ensuring the security of the personal data according to the section 7 of the Privacy Act.

25.

If Service Provider detects the unauthorized access or its attempt to the User’s personal data stored and processed by Service Provider, it shall prohibit the access to the personal data and notify the User thereon immediately but maximum within 24 hours from the detection. The User shall cooperate with Service Provider in the investigation of the unauthorized access, and shall disclose the necessary information to Service Provider and to the competent authority.

26.

If Service Provider fails to fulfil its obligation prescribed in aforementioned point, Service Provider shall not be liable in any form whatsoever for the unauthorized access and for the attempt thereof, furthermore it shall not be liable for the damages caused to the User as a result of the unauthorized access.

Changes to the Privacy Policy

27.

Service Provider is entitled to modify this Privacy Policy on its sole discretion, at any time and for any reason. Service Provider will notify the User when Service Provider changes this Privacy Policy.

If Service Provider makes significant changes in the way Service Provider treats the User’s personal information, or to the Privacy Policy, Service Provider will provide notice to the User on the Services or by some other means, such as e-mail. User shall review the changes carefully. If the User agrees to the changes, simply continue to use our Services. If the User objects to any of the changes to the Privacy Policy and the User no longer wishes to the Services, the User may close his/her account(s). Unless stated otherwise, Service Provider’ current Privacy Policy applies to all information that Service Provider has about the User and the User’s account. Using the Services after a notice of changes has been communicated to the User or published on the Website shall constitute consent to the changed terms or practices.

Budapest, May 31, 2016