Copyright © 2024 EdX Hungary Kft.| All rights reserved.
The operator of the www.edtechkoalicio.hu portal (hereinafter: the “Portal”) is EDX Education’s Digital Experts Hungary Nonprofit Limited Liability Company (registered office: 2800 Tatabánya, Stúdium tér 1.; company registration number: 11 09 030188; tax number: 32212657-2-11; hereinafter: the “Company” or the “Service Provider”). Through the Portal, Users may register for the Coalition established by the Company, for events and project-based programmes organised by the Service Provider, and may subscribe to newsletters.
The Service Provider hereby informs Users about the data processing carried out on the Portal and in connection with the activities performed by the Service Provider, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter: “GDPR”), as well as Act CXII of 2011 on Informational Self-Determination and Freedom of Information (hereinafter: “Infotv.”).
This Privacy Notice applies to the processing of the personal data provided by the User to the Company, as well as to all personal data that the Company collects either on its online interfaces or through the use of cookies.
We kindly ask visitors of the Portal to read this Privacy Notice carefully.
For the purposes of this Privacy Notice:
Personal data: 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;
Processing: 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;
Controller: 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;
Processor: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
Destruction of data: the complete physical destruction of the data carrier containing the data;
Data transfer: making data available to a specified third party;
Deletion of data: rendering the data unrecognisable in such a way that its recovery is no longer possible;
User: any person who visits and browses the Portal, as well as any person who registers on the Portal or subscribes to the newsletter (data subject);
Online interface: the Portal (www.edtechkoalicio.hu) operated by the Company;
Any person may access the Company’s Portal without providing personal data, and may obtain information freely and without restriction on the Portal and its associated pages. It is also possible to register on the Portal by providing personal data.
With regard to any data processing that may take place on the Portal, the Service Provider qualifies as the controller. In the course of providing its Services, the Service Provider also qualifies as the controller.
Users are responsible for the data they provide and the content they upload, and the Service Provider excludes its liability for such data and content.
The Service Provider is entitled at any time to unilaterally amend this Privacy Notice. The Service Provider shall publish any amendment to the Privacy Notice on the Portal under a separate menu item. Users are requested to carefully read the Privacy Notice each time they log in to the Portal.
This Privacy Notice is continuously available on the Portal. Users may open, view, print and save this Privacy Notice on the Portal, but may not modify it; only the Service Provider is entitled to do so.
As a general rule, the legal bases for data processing are as follows:
a) Consent: pursuant to Article 6(1)(a) GDPR, the User’s voluntary consent to the processing of personal data based on appropriate information;
b) Performance of a contract: pursuant to Article 6(1)(b) GDPR, processing is necessary for the performance of a contract to which the User, as data subject, is party;
c) Compliance with a legal obligation: pursuant to Article 6(1)(c) GDPR, processing is necessary for compliance with a legal obligation to which the controller is subject (such as compliance with accounting obligations);
d) Vital interests: pursuant to Article 6(1)(d) GDPR, processing is necessary in order to protect the vital interests of the data subject or of another natural person;
e) Public interest: pursuant to Article 6(1)(e) GDPR, processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
f) Legitimate interests: pursuant to Article 6(1)(f) GDPR, processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party.
If the User contacts the Service Provider by telephone, e-mail or via the contact form, the Service Provider processes the data provided by the User based on Article 6(1)(a) GDPR. The purpose of the processing is to enable the Service Provider to respond to the User’s queries. The Service Provider logs the contact. The User’s consent is voluntary, as the contact is initiated actively by the User. Data related to this will be deleted when the communication in question is concluded and the specific matter has been finally resolved.
We inform Users that marketing communications and newsletters are sent only to persons who have expressly subscribed to the newsletter. Users can subscribe to the newsletter on the Portal by ticking the relevant checkbox. By ticking the newsletter checkbox, the User consents to the Company sending them marketing communications, business offers and newsletters.
Persons subscribed to the newsletter may unsubscribe at any time by clicking on the unsubscribe link at the bottom of each newsletter. The Service Provider will not send newsletters to a person who has unsubscribed.
In the event of withdrawal of consent, the User may give their consent again at any time. Giving consent is not a precondition of using any of the Services.
When giving consent, providing a name and e-mail address is mandatory, without which consent cannot be given. For the purpose of identification, providing a name and e-mail address is also mandatory when withdrawing consent.
Data subject
Type of data processed
Source of data
Purpose of processing
Legal basis of processing
Duration of storage / time of deletion
Newsletter recipient – Name
Source: data subject (User)
Purpose: sending electronic direct marketing messages, newsletters
Legal basis: Article 6(1)(a) GDPR – consent of the data subject
Storage: until withdrawal of consent
Newsletter recipient – E-mail address
Source: data subject (User)
Purpose: sending electronic direct marketing messages, newsletters
Legal basis: Article 6(1)(a) GDPR – consent of the data subject
Storage: until withdrawal of consent
Data subject
Type of data processed
Source of data
Purpose of processing
Legal basis of processing
Duration of storage / time of deletion
User visiting the Portal – IP address
Source: data subject (User)
Purpose: compilation of statistics, development of the Portal, identification and recognition of the User
Legal basis: Article 6(1)(f) GDPR – processing is necessary for the purposes of the legitimate interests pursued by the controller
Storage: 2 years from the visit
The Service Provider uses cookies and various other programmes on the Portal in order to learn about the needs and behaviour of Users in relation to the Portal and, on this basis, to further develop the Portal. The Service Provider compiles anonymous statistics on Portal visits.
The above processing is based on the Service Provider’s legitimate business interest, as this enables it to further develop and make its Portal more secure. The scope of data processed and collected is not significant. The Service Provider only uses these data in anonymised form for the purpose of preparing statistics and analyses, does not collect behavioural preferences, does not carry out automated decision-making based on these data and does not send personalised offers to Users on this basis. Consequently, this data processing does not disproportionately affect Users’ fundamental rights and freedoms.
Further information is contained in the Cookie Management Policy, which is identical to and may be downloaded from the EduTech Hungary website.
The Service Provider enables online registration for the Coalition. The aim of the Coalition is to connect domestic and international actors in digital education in Hungary and to support the spread of educational technology in order to make teaching and learning more effective. For members of the Coalition, the Company provides opportunities to participate in international conferences and also offers product and service development consultancy, organisation of market research and international contacts necessary for entering target markets. Furthermore, the Service Provider offers opportunities to participate in its project-based programmes.
Registration for the Coalition begins with completion of the online form available on the Portal. Natural persons, legal entities and organisations without legal personality (hereinafter, collectively: “Organisations”) may register for the Coalition. Thus, a natural person User or a natural person representing an Organisation may voluntarily register themselves and/or the Organisation they represent by completing the form available on the Portal. During registration, the Company processes the data of the natural person who intends to register and/or the natural person representative and/or natural person contact person of the Organisation, as set out below.
The following data must be provided during registration:
Type of data processed – Source of data – Purpose of processing – Legal basis of processing
Surname
Source: data subject (User carrying out the registration)
Purpose: maintaining contact, identification, establishment of membership relationship
Legal basis: Article 6(1)(b) GDPR – performance of a contract
First name
Source: data subject (User carrying out the registration)
Purpose: maintaining contact, identification, establishment of membership relationship
Legal basis: Article 6(1)(b) GDPR – performance of a contract
Institution name
Source: data subject
Purpose: maintaining contact, identification, establishment of membership relationship
Legal basis: Article 6(1)(b) GDPR – performance of a contract
Title
Source: data subject (User carrying out the registration)
Purpose: maintaining contact, identification, establishment of membership relationship
Legal basis: Article 6(1)(a) GDPR – consent of the data subject
E-mail
Source: data subject (User carrying out the registration)
Purpose: maintaining contact, identification, establishment of membership relationship
Legal basis: Article 6(1)(a) GDPR – consent of the data subject
Phone number
Source: data subject (User carrying out the registration)
Purpose: maintaining contact, identification, establishment of membership relationship
Legal basis: Article 6(1)(a) GDPR – consent of the data subject
Message-sending IP address
Source: data subject (User carrying out the registration)
Purpose: performance of a technical operation
Legal basis: Article 6(1)(a) GDPR – consent of the data subject
We inform Users that the Service Provider may take image and audio recordings at Coalition events. If the User or their child under the age of 18 appears in any way (in person or online) at events organised by the Service Provider, they voluntarily consent, upon entering the event, to image and audio recordings being made of them and/or their child under the age of 18 at the events, and acknowledge that photos and audio recordings may be transmitted to third parties and then made public.
Scope of data subjects
All natural persons requesting Coalition membership via the website, as well as their natural person representatives (contact persons), are data subjects.
Duration of processing / deadline for deletion
Processing lasts until withdrawal of consent, but at the latest until termination of the membership relationship, or, in the absence of a membership relationship being established, for a maximum of 2 years.
Giving and withdrawing consent
The User gives their voluntary consent to the processing of their personal data for the purposes set out above by actively submitting their application. The User may withdraw their consent to the processing of their data at any time by sending an e-mail to koalicio@edtechkoalicio.hu, indicating the company name, the contact person’s name and contact details, so that the Service Provider can identify whose data must be deleted. In the case of withdrawal of consent, all processed data will be deleted. The obligation to delete data applies to data stored both electronically and on paper.
Participation in events (hereinafter: “Events”) organised by the Company or implemented with the Company’s involvement is possible upon registration and by providing the following personal data:
Type of data processed – Source of data – Purpose of processing – Legal basis of processing
Surname
Source: data subject (applicant)
Purpose: maintaining contact, identification, ensuring participation in the Event
Legal basis: Article 6(1)(b) GDPR – performance of a contract
First name
Source: data subject (applicant)
Purpose: maintaining contact, identification, ensuring participation in the Event
Legal basis: Article 6(1)(b) GDPR – performance of a contract
E-mail address
Source: data subject (applicant)
Purpose: maintaining contact, identification, ensuring participation in the Event
Legal basis: Article 6(1)(a) GDPR – consent of the data subject
Phone number
Source: data subject (applicant)
Purpose: maintaining contact, identification, ensuring participation in the Event
Legal basis: Article 6(1)(a) GDPR – consent of the data subject
Institution name
Source: data subject (applicant)
Purpose: maintaining contact, compilation of statistics
Legal basis: Article 6(1)(a) GDPR – consent of the data subject
Message-sending IP address
Source: data subject (applicant)
Purpose: performance of a technical operation
Legal basis: Article 6(1)(a) GDPR – consent of the data subject
The Service Provider informs Users that, for the purpose of online registration, it transfers the data listed in the above table to third parties. If any User, in exercising their right of access pursuant to Article 15 GDPR, requests information on the recipients to whom personal data have been or will be disclosed, the Service Provider is obliged to comply with such a request.
“VIP invitees” to Events are invited via the contact details they have already provided earlier, provided they have previously given their consent to the processing of their data in this manner.
Image and audio recordings
We inform Users that the Service Provider takes image and audio recordings at its Events. If the User or their child under the age of 18 appears in any way (in person or online) at an Event organised by the Service Provider, they voluntarily consent, upon entering the event, to image and audio recordings being made of them and/or their child under the age of 18 at the events, and acknowledge that photos and audio recordings may be transmitted to third parties and then made public.
Scope of data subjects
Persons registering for EdTech Summit Events.
Duration of processing / deadline for deletion
Processing lasts until withdrawal of consent, but at the latest for 6 months following the Event, after which the Service Provider deletes the data it processes.
Giving and withdrawing consent
The User gives their voluntary consent to the processing of their personal data for the purposes set out above by actively submitting their application. The User may withdraw their consent to the processing of their data at any time by sending an e-mail to koalicio@edtechkoalicio.hu, indicating the company name, the contact person’s name and contact details, so that the Service Provider can identify whose data must be deleted. In the case of withdrawal of consent, all processed data will be deleted. The obligation to delete data applies to data stored both electronically and on paper.
Type of data processed – Source of data – Purpose of processing – Legal basis of processing
Surname
Source: data subject (applicant)
Purpose: maintaining contact, identification, conclusion and performance of contract
Legal basis: Article 6(1)(b) GDPR – performance of a contract
First name
Source: data subject (applicant)
Purpose: maintaining contact, identification, conclusion and performance of contract
Legal basis: Article 6(1)(b) GDPR – performance of a contract
E-mail address
Source: data subject (applicant)
Purpose: maintaining contact, identification, conclusion and performance of contract
Legal basis: Article 6(1)(a) GDPR – consent of the data subject
Phone number
Source: data subject (applicant)
Purpose: maintaining contact, identification, conclusion and performance of contract
Legal basis: Article 6(1)(a) GDPR – consent of the data subject
Institution name
Source: data subject (applicant)
Purpose: maintaining contact, identification, compilation of statistics
Legal basis: Article 6(1)(a) GDPR – consent of the data subject
Message-sending IP address
Source: data subject (applicant)
Purpose: performance of a technical operation
Legal basis: Article 6(1)(a) GDPR – consent of the data subject
Image and audio recordings
We inform Users that the Service Provider takes image and audio recordings at its Events. If the User or their child under the age of 18 appears in any way (in person or online) at an Event organised by the Service Provider, they voluntarily consent, upon entering the event, to image and audio recordings being made of them and/or their child under the age of 18 at the events, and acknowledge that photos and audio recordings may be transmitted to third parties and then made public.
Scope of data subjects
Persons registering for EdTech Summit Events.
Duration of processing / deadline for deletion
Processing lasts until withdrawal of consent, but at the latest for 6 months following the Event, after which the Service Provider deletes the data it processes.
Giving and withdrawing consent
The User gives their voluntary consent to the processing of their personal data for the purposes set out above by actively submitting their application. The User may withdraw their consent to the processing of their data at any time by sending an e-mail to koalicio@edtechkoalicio.hu, indicating the company name, the contact person’s name and contact details, so that the Service Provider can identify whose data must be deleted. In the case of withdrawal of consent, all processed data will be deleted. The obligation to delete data applies to data stored both electronically and on paper.
Type of data processed – Source of data – Purpose of processing – Legal basis of processing
Surname
Source: data subject (applicant)
Purpose: maintaining contact, identification, conclusion and performance of contract
Legal basis: Article 6(1)(b) GDPR – performance of a contract
First name
Source: data subject (applicant)
Purpose: maintaining contact, identification, conclusion and performance of contract
Legal basis: Article 6(1)(b) GDPR – performance of a contract
E-mail address
Source: data subject (applicant)
Purpose: maintaining contact, identification, conclusion and performance of contract
Legal basis: Article 6(1)(a) GDPR – consent of the data subject
Image and audio recordings
We inform Users that the Service Provider takes image and audio recordings at its Events. If the User or their child under the age of 18 appears in any way (in person or online) at an Event organised by the Service Provider, they voluntarily consent, upon entering the event, to image and audio recordings being made of them and/or their child under the age of 18 at the events, and acknowledge that photos and audio recordings may be transmitted to third parties and then made public.
Scope of data subjects
Persons who register for EdTech Summit Events and actually participate in them following registration.
Duration of processing / deadline for deletion
Processing lasts for a maximum of 15 days following the Event, after which the Service Provider deletes the data it processes.
Giving and withdrawing consent
The User gives their voluntary consent to the processing of their personal data for the purposes set out above by actively submitting their application. The User may withdraw their consent to the processing of their data at any time by sending an e-mail to koalicio@edtechkoalicio.hu, indicating the company name, the contact person’s name and contact details, so that the Service Provider can identify whose data must be deleted. In the case of withdrawal of consent, all processed data will be deleted. The obligation to delete data applies to data stored both electronically and on paper.
The controller of the data specified in Section III is the Service Provider:
EDX Education’s Digital Experts Hungary Nonprofit Limited Liability Company
Registered office: 2800 Tatabánya, Stúdium tér 1.
Registering authority: Company Registry Court of the Metropolitan Court of Budapest
Company registration number: 11 09 030188
Tax number: 32212657-2-11
E-mail: edx@edutechhungary.com
On the part of the Service Provider, employees of the Service Provider have access to the User’s data to the extent and in the scope strictly necessary to perform their work. Access rights to personal data are set out in internal regulations.
For the handling and storage of User data, the Service Provider uses the assistance of various companies with which it concludes data processing agreements. The following processors process the Users’ data:
Name and address of processor – Purpose of processing – Scope of data processed
ViaCom Informatikai Kereskedelmi és Szolgáltató Korlátolt Felelősségű Társaság
(2360 Gyál, Deák Ferenc utca 17.)
Purpose: making the website available and ensuring its proper operation
Data: data specified in Section III.3.
Google LLC
(USA, Google Data Protection Office, 1600 Amphitheatre Pkwy, Mountain View, California 94043 – Google Analytics)
Purpose: Google Analytics service
Data: data specified in Section III.3.
With regard to processors established in the United States of America, it should be noted that on 10 July 2023, the European Commission adopted a new adequacy decision for the safe and trustworthy transfer of personal data between the European Union and the United States of America, finding that the United States ensures an adequate level of protection – comparable to that of the European Union – for personal data transferred from the European Union to US companies.[1]
The Service Provider is entitled and obliged to transfer any personal data at its disposal that it lawfully stores to the competent authorities if such transfer is required by law or by a final and binding regulatory order. The Service Provider cannot be held liable for such data transfers and their consequences. The Service Provider does not carry out any other data transfer.
The Company respects the rights of Users as set out in legislation.
The Company uses personal data that are strictly necessary for the use of the Company’s services solely on the basis of the consent of the data subjects and strictly for the purposes defined. The Company uses Users’ personal data specified in Section III only in the manner and for the purposes defined in this Privacy Notice.
The Company, as controller, undertakes to process the data in its possession in accordance with the provisions of the GDPR, the Infotv., other applicable legislation and this Privacy Notice, and not to disclose such data to third parties other than the processors specified in this Privacy Notice. An exception to this is the use of data in aggregated statistical form, which does not contain the User’s name or any other data suitable for identifying the User, and therefore does not constitute data processing or data transfer under the GDPR.
In certain cases – in particular in response to official court or police requests, legal proceedings due to alleged or actual infringement of copyright, property or other rights, or in cases where the Company’s interests are adversely affected, the provision of its services is jeopardised, on the basis of court or other authority decisions unless otherwise provided by law – and in the case of the User’s prior, express consent, the Company may make the User’s contact data available to third parties.
Employees of the Company shall do their utmost to ensure that the processing and handling of Users’ data is afforded the protection required under applicable legislation, and to this end the Company operates a security system.
The Company fulfils its obligations under the applicable data protection legislation by:
keeping personal data up to date;
storing and destroying them securely;
not collecting or retaining excessive amounts of data;
protecting personal data from loss, misuse, unauthorised access and disclosure; and
ensuring that appropriate technical measures are in place to protect personal data.
The Company takes appropriate technical and organisational measures to protect Users’ personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorised transmission or access – in particular where processing involves the transmission of data over a network – as well as against all other unlawful forms of processing.
Accordingly, the Company, among other things, applies different levels of access rights to the data to ensure that only persons with appropriate authorisation who need to know the data in order to perform their job-related or associated obligations can access the data.
Under the data protection legislation, the User has the right to:
a) request access to their personal data;
b) request rectification of their personal data;
c) request erasure of their personal data;
d) request restriction of the processing of their personal data;
e) object to the processing of their personal data;
f) request data portability;
g) object to the processing of their personal data (including objection to profiling and other rights related to automated decision-making);
h) withdraw their consent and lodge a complaint with the competent supervisory authority.
The User has the right to obtain from the controller confirmation as to whether or not personal data concerning them are being processed, and, where that is the case, request access to those personal data.
The User has the right to request a copy of the personal data undergoing processing. For identification purposes, the controller may request further information from the User or may charge a reasonable fee for any further copies based on administrative costs.
The User has the right to request the controller to rectify inaccurate personal data concerning them. Taking into account the purposes of the processing, the User has the right to request that incomplete personal data be completed, including by means of a supplementary statement.
The User has the right to request the controller to erase personal data concerning them, and the controller is obliged to erase such personal data. In such a case, the controller will not be able to provide further services to the User.
The User has the right to request restriction of processing of their personal data. In such a case, the controller marks the personal data in question, which may then only be processed for certain purposes.
The User has the right to object at any time, on grounds relating to their particular situation, to the processing of their personal data by the controller, including profiling, and may request the controller to no longer process their personal data.
In addition, where the Company processes the User’s personal data on the basis of legitimate interests, the User has the right to object at any time to the processing of their personal data for this purpose.
Furthermore, the User has the right to request human intervention in the context of decisions based solely on automated processing in individual cases. We inform you that the controller does not apply any automated decision-making mechanisms.
The User has the right to receive the personal data concerning them, which they have provided to the controller, in a structured, commonly used and machine-readable format, and has the right to transmit those data to another controller without hindrance from the Company, where technically feasible.
If the processing of the User’s personal data is based on consent, the User may withdraw their consent at any time without justification by clicking on the relevant link in the newsletters or by sending a written statement to the Controller. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
If the User withdraws their consent to the processing of their personal data given to the Company, the Company may not be able to provide the requested services at all or may only be able to provide them in part.
If the User believes that their personal data have been misused, they may turn to their local data protection authority and lodge a complaint. This is primarily the authority in the Member State of their habitual residence, place of work or place of the alleged infringement.
In Hungary, the User may also turn to the National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság):
Address: H-1055 Budapest, Falk Miksa utca 9–11., Hungary
Telephone: +36-1-391-1400
Fax: +36-1-391-1410
E-mail: ugyfelszolgalat@naih.hu
If the User wishes to exercise their rights or submit a complaint in relation to data protection matters, they may contact the Company’s designated staff member by sending a letter to the e-mail address below. In addition, the Company may also be contacted by post at the addresses below:
E-mail: koalicio@edtechkoalicio.hu
Postal address: 2800 Tatabánya, Stúdium tér 1.
In the event of a personal data breach, the Company shall notify the supervisory authority of the personal data breach without undue delay and, where feasible, not later than 72 hours after having become aware of it, in accordance with the applicable legislation, and shall keep a record of such incidents. In cases defined by law, the Company shall also inform the data subjects of the personal data breach.
The controller regularly monitors its online interfaces and the information published thereon, and makes every effort to ensure that the information is up to date and accurate. Nevertheless, information found on the online interfaces may become outdated. The Company does not accept any financial liability for such information.
Visitors to the online interfaces and Users may also navigate from the Company’s online interfaces to other portals that are not operated by the Company. The Company is not responsible for the accuracy of the data or the content published on such websites, nor for the security of the data provided by visitors and Users on the Company’s online interfaces. Therefore, when using such websites, please make sure to review the data protection policies of the respective companies.
This Privacy Notice is effective as of 13 August 2024.
[1] The adequacy decision is available at the following link:
https://commission.europa.eu/document/download/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en?filename=Adequacy%20decision%20EU-US%20Data%20Privacy%20Framework_en.pdf
Copyright © 2024 EdX Hungary Kft.| All rights reserved.