DATA PRIVACY POLICY

We are very delighted that you have shown interest in our enterprise. Data protection is a particularly high priority for the management of Blaguss Travel Ltd. The use of the Internet pages of the Blaguss Travel Ltd. is possible without any indication of personal data. The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to the Blaguss Travel Ltd. By means of this privacy policy, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.
As the controller, Blaguss Travel Ltd. has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.

1. Definitions

The privacy policy of Blaguss Travel Ltd. is based on the terms used by the General Data Protection Regulation (GDPR). Our privacy policy should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this privacy policy, we use, inter alia, the following terms:

a) Personal data

Personal data means 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.

b) Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

c) Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

e) Pseudonymisation

Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

f) Controller or controller responsible for the processing

Controller or controller responsible for the processing is 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; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

g) Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

h) Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

i) Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

j) Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and Address of the controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
Blaguss Travel Ltd.
Petőfi Sándor u. 11.
1052 Budapest
Hungary
Phone: +36 1 486 3260
Email: gdpr@blaguss.hu
Website: www.blagussdmc.com

3. Cookies

The Internet pages of Blaguss Travel Ltd. use necessarycookies. Cookies are text files that are stored in a computer system via an Internet browser.
Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies.
The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

The legal basis of the data processing regarding the use of necessary cookies is the legitimate interest of Blaguss Travel Ltd. to comply with section 13 (1)-(3) of the Act CVIII of 2001 and Art. 5 (3) of 2002/58/EC Directive.

4. Collection of general data and information

The website of Blaguss Travel Ltd. collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files.

The following categories of data may be collected (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, the Blaguss Travel Ltd. does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack.

Therefore, Blaguss Travel Ltd. analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

5. Subscription to our newsletters

On the website of Blaguss Travel Ltd., users are given the opportunity to subscribe to our enterprise’s newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.

Blaguss Travel Ltd. informs its customers and business partners regularly by means of a newsletter about enterprise offers. The enterprise’s newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter.(i.e. if the data subject gives his/her consent to such data process in accordance with Art. 6 (1) a GDPR). A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.

The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. The personal data collected lands in the system of our newsletter service provider: MailChimp.

The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given to receive the newsletter, may be revoked at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time by sending a message to marketing@blagussdmc.com or a letter to the above address of the company.

6. Contact possibility via the website

The website of Blaguss Travel Ltd. contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

7. Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of the processing, or as far as this is granted by EU law or other laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

8. Rights of the data subject

a) Right of access

Each data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and where it is the case, access to the personal data and the following information:

  • the purposes of the processing;
  • the categories of personal data concerned;
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  • the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
  • where the personal data are not collected from the data subject, any available information as to their source.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject wishes to avail himself of this right of access, he or she may at any time contact an employee of Blaguss Travel Ltd. at gdpr@blaguss.hu

b)  Right to rectification

Each data subject shall have the right granted to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact an employee of Blaguss Travel Ltd. at gdpr@blaguss.hu

c) Right to erasure (Right to be forgotten)

Each data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where the conditions set forth in the GDPR are met.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by Blaguss Travel Ltd, he or she may at any time contact an employee of Blaguss Travel Ltd. at gdpr@blaguss.hu. The employee shall promptly ensure that the erasure request is complied with immediately.

d) Right of restriction of processing

Each data subject shall have the right granted to obtain from the controller restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
  • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
  • The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by Blaguss Travel Ltd., he or she may at any time contact an employee of Blaguss Travel Ltd. at gdpr@blaguss.hu. The employee of Blaguss Travel Ltd. will arrange the restriction of the processing.

e) Right to data portability

Each data subject shall have the right granted to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent or on a contract, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject may at any time contact an employee of Blaguss Travel Ltd. at gdpr@blaguss.hu

f) Right to object

Each data subject shall have the right granted to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on the controller’s or a third party’s legitimate interest. This also applies to profiling based on these provisions.

Blaguss Travel Ltd. shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

In order to exercise the right to object, the data subject may directly contact an employee of Blaguss Travel Ltd. at gdpr@blaguss.hu

In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

g) Right to withdraw data protection consent

Each data subject shall have the right to withdraw his or her consent to processing of his or her personal data at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

If the data subject wishes to exercise the right to withdraw the consent, he or she may at any time directly contact an employee of Blaguss Travel Ltd. at gdpr@blaguss.hu

9. Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In some cases if the data is necessary to enter into a contract or if the provision of personal data is a statutory requirement and the data subject fails to provide such data, we might not be able to conclude the contract with you or provide certain services. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

The following personal data might be collected (necessary for the performance of a contract):

In case of conference/congress registration:
name, title/prefix, workplace, position, address, spoken languages, place of residence in Hungary, professional membership number, phone number, e-mail address, information on physiological conditions (food intolerance, allergy, disability), nationality, circle of interest, data of travel documents, date and place of birth

In case of provision of incoming services:
name, spoken language, place of residence in Hungary, phone number, information on physiological conditions (food intolerance, allergy, disability), nationality, circle of interest, data of travel documents, date and place of birth

10. The legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

11. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is determined by:

  • the respective statutory retention period,
  • the revocation or expiry of the related consent provided, or
  • the expiry of the deadline to enforce legitimate interests regarding the contract for the fulfilment of which the data was stored (in general 5 years after the termination of the contract).

Following the termination of the relevant period, the corresponding data is routinely deleted, as long as its keeping is not justified by other overriding legal interests.

12. The right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the applicable data protection laws. In case the supervisory authority is the Hungarian Data Protection and Freedom of Information Authority, please find below its contact data:

Postal Address:               1530 Budapest, Pf.: 5.,
Phone number:               +36 (1) 391-1400

Fax:                                       +36 (1) 391-1410,
E-mail:                                 ugyfelszolgalat@naih.hu
Website:                             http://www.naih.hu

Budapest, May 24, 2018