Intager Ltd.
Privacy Policy
2019.
Important Notice: This Privacy Policy has written in English. For information in other languages, please contact us at support@intager.com.
Content
Prolog
Controller
Concepts
Concerned
Personal data
Data controller
Data processor
Costumer
Visitor
Employee
Concerned by personal data
Concerned by non-personal data
Data processing
Data management
Consent
Data destruction
Data deletion
Database
Agreement
Labor agreement
Newsletter database
Websites
Belonged laws/Relevant legislation
Purpose of data management
Purpose of data management for costumers
Purpose of data management for employees
Range of managed data
Visitors
Cookies and logged activity
Managed data in the newsletter database
Provided data trough quotation request
Clients
Cookies and logged activity
Managed data in the newsletter database
Provided data trough quotation request
Clients’ stored data in the case management system and its sales surface
Legal base for data management
Personal data
Non-personal data
Processing of data management
Visitors
Cookies and logged activity
Managed data in the newsletter database
Provided data trough quotation request
Management of provided data by clients
Logged date by Cookies
Managed data in the newsletter database
Provided data trough quotation request
Case management
Data security
Data controllers and data processors
Data controller
Data processor
Accountant
Server and hosting provider
Newsletter provider
Local representatives
Rights
Right of access
Right of rectification
Right of restriction and erasure
Fulfillment
Infringement by personal data
Infringement by non-personal data
Miscellaneous and final provisions
Unilateral amendment
Transmission of data
Data of unauthorized third parties
Prolog
This Privacy Policy (hereinafter referred to as “PP”) is to fix the provisions relating to personal data processing activities in an easily accessible form, concise, comprehensible to those Concerned.
Data controller
Company name: Intager Ltd.
Registered office: Hegedűs Gyula str 67, 8/2, 1133, Pest county, Hungary
Mail address: Hegedűs Gyula str 67, floor 8, door 2, 1133, Pest county, Hungary
E-mail: info@intager.com
Phone: +36 (70) 702 7632
Website: intager.com
DPO: Tallódi Márk
DPO contact: mark.tallodi@gmail.com
Concepts
Concerned
Directly or indirectly identifiable natural person based on any personal data such as name, identification, physical, physiological, mental, economic, cultural, or social
Personal data
Any data that may be related to the Concerned and identifies the Person concerned.
Data controller
The natural person or legal entity or non-legal entity that manages personal data at the request of the Data Controller.
Data Processor
The natural person or legal entity or non-legal entity that manages personal data at the request of the Data Controller.
Costumer
Who uses INTAGER Ltd’s products and/or services for business purposes, is interested in them. Who makes an offer, requests for an offer our uses INTAGER Ltd’s website, Facebook page, LinkedIn site, YouTube channel, Messenger platform, Instagram site, Whatsapp platform for this purpose. Who isn’t Data controller or Employee. Customer may be Concerned by Personal Data or non-personal data.
Visitor
Who contacts INTAGER Ltd for non-business purposes or uses INTAGER Ltd’s website, Facebook page, LinkedIn site, YouTube channel, Messenger platform, Instagram site, Whatsapp platform not for this purpose. Who isn’t Data controller or Employee. Customer may be Concerned by Personal Data or non-personal data.
Employee
Natural person with employment or other employment relationship with INTAGER Ltd.
Concerned by personal data
Identified or identifiable natural person based on any information. The person to whom the Visitor, Customer or Employee communicates personal data to the Data Controller is concerned by personal data. Concerned by personal data the Employee, whose personal data is handled as an employer by INTAGER Kft. May be concerned by personal data: Visitors, Clients, Employees, and other persons.
Concerned by non-personal data
The natural person, legal entity or non-legal entity to whom applies non-personal data or may relate it with them. Visitors, Clients, Employees, and others may be concerned by non-personal data.
Data processing
Perform technical tasks related to data management operations, irrespective of the method and device used to perform the operations and the location of the application, provided that the technical task is performed on the data.
Data management
Regardless of the procedure used, any operation performed on the data, such as collecting, recording, recording, organizing, storing, modifying, using, retrieving, transmitting, disclosing, coordinating or linking, blocking, deleting or destroying data, and preventing further use of the data , capturing photos, sound or images, and recording physical characteristics (finger- or palmprint, DNA sample, iris image, etc.) that can identify the person.
Consent
After appropriate information, the Concerned voluntarily declares his/her will, and he/she expresses or expresses his/her consent to the processing of his/her data in an unambiguous manner. If he/she provides his/her data to the Data Controller in accordance with the relevant legal requirements and the Data Collector ensures him/her that the Data Collector can lawfully handle it without any subsequent action, it is considered a contribution.
Data destruction
Physical destruction of data media containing data.
Data deletion
Deleting data, it is no longer possible to restore the data.
Database
A set of data processed in a register.
Agreement
The legal statement between the Client and INTAGER Ltd., which is mutually and unanimously accepted by both parties, thus creating an obligation to perform the tasks and to be entitled to the claims.
Labor agreement
A legal statement between the Employer and INTAGER Kft, which has been mutually and unanimously accepted by both parties to create an employment relationship or other employment relationship.
Newsletter database
Firstly, a database containing email addresses. The Data Controller operates to store and organize contact information for recipients and future recipients of our newsletters.
Websites
A set of coded digital interfaces that are hosted on a given domain. The scope of this Privacy Policy is https://www.intager.com/ and https://www.intagergames.com/.
Belonged laws/Relevant legislation
Data Controller creates present PP – with special attention but not exclusively – below in accordance with specific legislation:
- Regulation (EC) No 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Regulation (EC) No 95/46 (hereinafter referred to as “GDPR”);
- Hungary’s Fundamental Law;
- Act V of 2013 on the Civil Code (hereinafter: CC);
- CXII of 2011 on Information Self-Determination and Freedom of Information Act (hereinafter: Info law)
- See Section XLVIII of 2008 on the basic conditions and uniform limits of economic advertising activities (hereinafter: EAA)
- CVIII of 2001 on Certain Issues of Electronic Commerce Services and Information Society Services (hereinafter referred to as “EC law.”);
- Act I of 2012 on the Labor Code (hereinafter: LC.)
Purpose of data management
Purpose of data management for Costumers
- Requested and relevant information (eg: quote)
- Customer Identification – for signing and performing
- In order to fulfill the contractual INTAGER Ltd. requested data, documents and information gathering and processing and use in the context of contractual performance
- Documenting contract performance
- Invoicing
- Minimize new data entries for new contracts
- Sending newsletters and entering the database in case of consent
- Making statistics
- In order to develop the marketing activities and website of INTAGER Ltd.
Purpose of data management for Employees
- Data necessary for the conclusion and performance of the labor agreement in order to identify the Employee
- Data services and payments to competent authorities
- Compliance with other statutory obligations related to employment
In the Employee’s case, Intager Ltd details in detail the Personal Data Management Guidelines for each Employee in the Labor Agreement for each Employee.
Range of managed data
Visitors
Cookies and logged activity
Websites contain so-called cookies that are saved by the visitor’s browsers during use and are required for certain functions of the websites. These are small text files that save the visitor’s activities on websites (hereafter: activity data) and make it possible to identify the Visitor. Cookies are notified by the websites to the Visitor so they can refuse and approve the use of cookies. Cookie placements do not pose a threat to your browser or device, they do not contain a virus.
Activity data is stored by a closed, IT-protected system, to which only the Data Controller is entitled to access and the persons named in the “Data Controllers” section of “Data Controllers and Processors” paragraph.
Managed data in the newsletter database
Visitors may subscribe to the Newsletter List when using the Website or at the time of purchase. When they sign up for INTAGER Ltd. Newsletter, they are asked to:
- Name
Provided data trough quotation request
Visitors have the opportunity to request quotes on https://intager.com, Intager Ltd’s Facebook, LinkedIn, YouTube channel, Messenger platform, Instagram, Whatsapp, Skype, Snapchat platform, and via email. they are asked to
- Name (required)
- Email (required)
- Phone number (optional)
- Country (optional)
- Company name (optional)
- Website lint (optional)
- Short message (optional)
Clients
Cookies and logged activity
Websites contain so-called cookies that are saved by the visitor’s browsers during use and are required for certain functions of the websites. These are small text files that save the Client’s activities on websites (hereafter: activity data) and make it possible to identify the Client. Cookies are notified by the websites to the Client so they can refuse and approve the use of cookies. Cookie placements do not pose a threat to your browser or device, they do not contain a virus.
Activity data is stored by a closed, IT-protected system, to which only the Data Controller is entitled to access and the persons named in the “Data Controllers” section of “Data Controllers and Processors” paragraph.
Managed data in the newsletter database
Clients may subscribe to the Newsletter List when using the Website or at the time of purchase. When they sign up for INTAGER Ltd. Newsletter, they are asked to:
- Name
Provided data trough quotation request
Clients have the opportunity to request quotes on https://intager.com, Intager Ltd’s Facebook, LinkedIn, YouTube channel, Messenger platform, Instagram, Whatsapp, Skype, Snapchat platform, and via email. they are asked to
- Name (required)
- Email (required)
- Phone number (optional)
- Country (optional)
- Company name (optional)
- Website lint (optional)
- Short message (optionla)
Clients’ stored data in the case management system and its sales surface
The Data Controller in its own case management system stores the following Customers’ data:
- Company name
- Address
- Contact name
- Contact phone number
- Contact email
- Other necessary data for agreement
- Other necessary data for the performance of the agreement (eg: invoicing, shipping information)
Legal base for data management
Personal data
Personal Data shall be handled by the Data Controller with the consent of the Concerned, which may be withdrawn at any time by the Concerned.
A further legal basis for the processing of personal data is that personal data are necessary for the performance of a contract in which at least one of the parties is involved or necessary to take action at his request prior to the conclusion of the contract.
Processing of some personal data It also required by law (eg billing data).
Non-personal data
Data management is based on a statement by the Visitor, Customer or Employee that the provided data is lawfully managed by the Data Controller.
Processing of data management
Visitors
Cookies and logged activity
Activity data is saved and stored by a closed, IT-protected system, to which only the Data Controller is entitled to access and the persons named in the “Data Controllers” section of “Data Controllers and Processors” paragraph.
The Data Controller handles the data until the purpose of data management is fulfilled. The review of the need for data management is reviewed and documented at a maximum of 3 years, which is retained for a maximum of 5 years.
Managed data in the newsletter database
The Visitor shall voluntarily and unambiguously consent to the handling and recording of the above data in the newsletter database of INTAGER Ltd when using the website or concluding a contract.
As in the previous section, the newsletter database also handles the data in a closed system. The Data Controller expressly undertakes not to hand over the data contained therein to any unauthorized third party or to disclose it. In the case of unsubscription, the data related to the Visitor from the newsletter database will be deleted as soon as possible from the Data Controller.
Provided data trough quotation request
The legal basis for handling the data provided during the contact and/or quotation request is the Concerned’s consent. The data thus provided is saved and stored by a closed, IT-protected system, to which only the Data Controller is entitled to access and the persons named in the “Data Controllers” section of “Data Controllers and Processors” paragraph.
If the data entry is recorded on a paper basis, the Data Controller keeps it in a room in a technically lockable building, systematically maintained and accessed only by persons specified in the “Data Controllers” section of “Data Controllers and Processors” paragraph.
The Data Controller handles the data until the purpose of data management is fulfilled. The review of the need for data management is reviewed and documented at a maximum of 3 years, which is retained for a maximum of 5 years.
During telephone, e-mail, and facebook contacts, the legal basis for data management is that the data management has been requested by the Visitor, necessary to take pre-contract steps. Such data shall be deleted or destroyed by the Data Controller at the written request of the Concerned after the response has been given.
Case management
In order to store the above data, the Data Controller operates a case management system to facilitate the conclusion of contracts.
The Customer may provide the data necessary for the conclusion of the contract by telephone or e-mail.
The legal basis for data management is that it is necessary for the steps requested by the Client prior to the conclusion of the contract.
Customer may consent to the data management during the conclusion of the contract. If there is no contract between the Customer and the Data Controller, the Data Controller will store them for a maximum of 5 years.
Such data is saved and stored by a closed, IT-protected system, to which only the Data Controller is entitled to access and the persons specified in the “Data Controllers” section of “Data Controllers and Processors” paragraph.
The Data Controller handles the data until the purpose of data management is fulfilled. The review of the need for data management is reviewed and documented at a maximum of 3 years, which is retained for a maximum of 5 years.
Data security
The above data is saved and stored by a system protected by an IT algorithm, to which only the Data Controller is entitled to access and the persons named in the “Data Controllers” section of “Data controllers and processors” paragraph.
If the data entry is recorded on a paper basis, the Data Controller keeps it in a room in a technically lockable building, systematically maintained and accessed only by persons specified in the “Data Controllers” section of “Data Controllers and Processors” paragraph.
The Data Controller shall take all reasonable and necessary steps to ensure the security of the managed data, such as unauthorized access, forwarding, alteration, deletion, disclosure, destruction, damage, and unavailability of the technique used, as expected.
Data controllers and data processors
Data controller
Only INTAGER Ltd., its emlpyees and persons with other employment relations with it (hereinafter: Data Controller) are entitled to process, store, manage and understand the above-described managed data. In addition to the specified goals, the Data Controller does not use the data.
Data processor
Data Controller applies Data Processors to perfom its obligations under certain laws and agreements.
Accountant
In order to fulfill its accounting obligations, the Data Controller applies the following Accountant (hereinafter: Accountant):
Name: Adóterv Ltd.
Representative: Dóra Pauer
Contact: ado-terv@ado-terv.hu
For the Accountant, the Data Controller shall only provide data for the purpose of fulfilling its accounting obligations and solely in relation to it. The Accountant shall store the data only for the period specified in the relevant legislation.
Server and hosting provider
With a server hosting service, Data Controller applies the following service provider (hereinafter: Server hosting provider):
Name: DotRoll Kft.
Representative: Zsolt György Komáromi
Contact: dpo@dotroll.com
The Server hosting provider does not see the data on the server and does not perform any other operations, only server hosting service. The data processing shall be continued only for the time necessary for the performance of the contract with the Data Controller.
Newsletter provider
With Newsletter Software and Mailing System Services, the Data Controller applies the following service provider (hereinafter referred to as Newsletter Service):
Name: The Rocket Science Group, LLC (MailChimp)
Representative: Meghan Farmer
Contact: dpo@Mailchimp.com
The information you provide when signing up for our newsletter via our website is sent directly to the Newsletter Service Database. Otherwise, the Data Controller uploads the data himself into the Newsletter Service Database.
The Newsletter Service will only process data to the extent necessary for the provision of Newsletter Software and Mail Server Services.
The Newsletter Service shall continue the data processing only for the time necessary for the performance of the Contract with the Data Controller.
Local representative
With local representative services, the Data Collector applies the following service providers (hereinafter: Local Service Providers):
Name: Action Distribution SAS. (France, Belgium)
Representative: Patrice Guigou
Contact: patrice@action-distribution.com
Name: Vuurlinie Beverwijk Import Ltd. (Benelux, Germany)
Representative: Bas Mensink
Contact: intager@vuurliniebevrwijk.nl
Name: Extreme Sports LLP (Singapore)
Representavie: Ben Seow
Contact: sales@paintballersworld.com
Name: Black Hawk Laser Games Ltd (United Kingdom)
Representative: Paul Farry
Contact: uk@intager.com
In case of contact, quotation request, or use of the website, the Data Controller gives, for Local Service Providers, access to personal information that helps to provide the proper service.
Local Representatives only handle data in connection with the Data Controller’s activity.
Rights
Right of access
The above persons and entities at any time may request the Data Controller to provide them the relevant data and information relating to their management. They have the right to receive such data and information in a widely used machine-readable format. They may also request the Data Controller to forward the data to another Data Controller if this does not hinder the purpose of the data management.
Right of rectification
The above persons and entities may at any time request the Data Controller to supplement and correct the data relating to them.
Right of restriction and erasure
The above persons and entities may at any time request the Data Controller to limit or delete data relating to them. Exceptions to this are data subject to mandatory data management.
Fulfillment
The Data Controller shall execute the requests within the shortest possible time, but no later than 25 days from the date of receipt of the request, or shall notify the above persons/entities of the rejection and the reasons for the refusal and the remedies available.
Infringement by personal data
In case of violation of their previous rights Concerned may contact the
- Data Controller
- To the Hungarian National Authority for Data Protection and Freedom of Information (Hungary, Budapest, 1125, Szilágyi Erzsébet fasor, 22/c)
- The competent court for the place of residence
Infringement by non-personal data
The data handling dispute that arose between the Concerned by non-personal data and the Data Controller is settled primary by common agreement. After unsuccessful consultation, the person concerned may apply to a court in accordance with the rules set forth in the Code of Civil
Miscellaneous and final provisions
Unilateral amendment
The Data Controller is entitled to unilaterally amend this PP, prior notice to Visitors, Clients and Employees.
Transmission of data
Neither the Visitor nor the Customer and the Employee may transfer any data to the Data Controller that violates the rights or legitimate interests of third parties and/or Data Controllers.
Data of unauthorized third parties
The Data Controller may consider the Visitor’s, Client’s or Employee’s Legal Notices and Newsletter subscription void if the Visitor, Customer or Employee has provided the third party’s data in an unauthorized manner.
This Privacy Policy contains 14 numbered pages and has been accepted by INTAGER Ltd. as a basic document.
Signed at Budapest, 2 April 2019
