Privacy Policy

1. Purpose of the Privacy Policy

Our Company, as controller, determines, alone or jointly with others, the purposes and means of the processing of personal data, and as processor, it processes personal data on behalf of the controller.

Processing means 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.

Technical processing is a processing activity of technical nature, where the processor does not have the right to dispose of the data or to make decisions in respect thereof.

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 on-line identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

SKC-Consulting Kft., in its capacity both as controller and processor, respects the privacy of every individual who discloses his or her personal data to it and is committed to the protection thereof.

SKC-Consulting Kft. as controller (hereinafter ‘the Controller’) acknowledges the content of the present legal notice as binding. The Controller undertakes to ensure that each processing carried out in conjunction with its activities shall comply with the requirements laid down in the present Privacy Policy, the applicable national laws as in force from time to time as well as in the legal acts of the European Union.

The data protection guidelines governing the processing activities of the Controller are continuously available at wingateproject.com/adatkezelesi-tajekoztato.

The Controller reserves the right to modify this Privacy Policy at any time; however, it shall notify its audience about any changes in due time. Should you have any questions about the present Privacy Policy, please send us a letter, and one of our colleagues will reach out to you with an answer.

The Controller is committed to the protection of the personal data of its customers and partners, and the right to informational self-determination is of paramount importance to it.

The Controller shall handle the personal data as confidential and implement any and all security and technical and organisational measures that ensure the security of such data.

The Controller’s data processing practices are described below.

Term of processing:

The storage period applicable to data disclosed for contact purposes is 1 year following the end of the relationship.
The storage period of answers submitted with the Needs Assessment Questionnaire is 5 years.

2. Details of the Controller:

If you wish to contact our Company as Controller, please write us at info@skc.hu.

The Controller will preserve every e-mail received by it together with the personal data stored from the date of disclosure until withdrawal of the consent.

Name: SKC-Consulting Kft.
Address: H-1031 Budapest, Rozália utca 11.
E-mail: info@skc.hu

Contact person: PÁTKA-SZITTER Katalin
E-mail: wingatecomm@skc.hu

Categories of processors and the recipients of the transfer of personal data:

Company name: BlazeArts Kft.
Address: H-6090 Kunszentmiklós, Damjanich János u. 36.
Telephone: +36 1 610 5506
E-mail: admin@forpsi.hu
Tax number: 12539833-2-03
Category: hosting service provider

Company name: SalesAutopilot Kft.
Address: H-1024 Budapest, Margit krt. 31-33.
Telephone: +36 1 490 0172
E-mail: info@salesautopilot.hu
Tax number: 25743500-2-41
Category: Newsletter services

Definitions

The GDPR (General Data Protection Regulation) means the new Data Protection Regulation of the European Union:

Processing means 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;

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

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 on-line identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Controller means 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;

Consent of the data subject means 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;

Personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;

Recipient means 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;

Third party means 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;

Restriction of processing means the marking of stored personal data with the aim of limiting their processing in the future;

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;

Pseudonymisation means 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;

Filing system means any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis;

3. Scope of personal data processed

Technical data

The IT tools used during the provision of services for the processing of personal data are selected and operated by the Controller in a manner that the processed data:

  • are accessible to authorised persons (availability);
  • are authentic and authenticated (authenticity of processing);
  • remain verifiably unchanged (integrity of data);
  • are protected against unauthorised access (confidentiality of data).

The Controller shall implement appropriate measures to protect the data against unauthorised access, modification, transfer, public disclosure, erasure or destruction, as well as incidental destruction.

The Controller shall ensure the security of processing by implementing technical and organisational measures that ensure an adequate level of protection against risks associated with such processing.

During its processing activities, the Controller shall maintain:

  • the confidentiality: by protecting the information, so that only authorised persons have access to it;
  • the integrity: by ensuring the accuracy and completeness of the information and the method of its processing;
  • the availability: by making sure that the authorised users have real access to the required information when needed, and by granting that the necessary tools are available.

Cookies

Cookies are designed to:

  • gather information about visitors and their devices;
  • remember the specific settings of users that may be used for e.g. on-line transactions, so that there is no need to type such information again;
  • facilitate the use of the website;
  • provide quality user experience.

For customised service, a small data package, a so-called cookie is placed on the user’s computer and retrieved at a later visit. If the browser returns a cookie that was placed earlier, the service provider managing such cookie will be able to combine the most recent visit of the user with former visits, but only for its own content.

Strictly necessary, session cookies

The purpose of these cookies is to enable visitors to browse the entire wingateproject.com website without interruption, to use the functions thereof and the services offered therein. These types of cookies will expire at the end of each session (browsing), and such cookies will be automatically deleted from the computer or any other device used for browsing.

The website will use the data collected to improve user experience. Such cookies will also be stored on the visitor’s computer or other device used for browsing, in the browser, until they expire or are deleted by the user.

  1. Data collected for newsletter subscription purposes

The following data are recorded upon newsletter/magazine subscription on the wingateproject.com website? name, e-mail address. Such data are not transferred to third parties or abroad.

4. Intended use and storage periods of processed data

Description of processing Use of collected data Legal basis Storage period
Surname, forename, nickname Sending of newsletters Consent of the visitor Until withdrawal
Website analytics Visitor statistics Consent of the visitor 50 months
E-mail address Contact purposes Consent of the visitor Until withdrawal

5. Purposes, means and legal basis of processing

General processing guidelines

The processing activities carried out by the Controller in the course of its operations are based on freely given consent or statutory authorisation. In the case of processing based on a freely given consent, data subjects may withdraw their consent any time during the processing.

The Controller processes data in accordance with the laws for the following purposes:

  • The Controller processes the data (name, e-mail address, address, telephone) of the users of its services, in conjunction with its activities (such as education, training, etc.) for compliance with a legal obligation and to maintain customer relations;
  • For marketing activities targeted to potential customers and visitors;
  • Processing the contact details of the contractual partners’ contact persons for the performance of such contracts;
  • For compliance with statutory obligations.

The data processing principles of the Controller are harmonised with the applicable data protection laws as in force, in particular the following:

Act CXII of 2011 on the right to informational self-determination and on the freedom of information (‘the Info Act’);

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 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 (General Data Protection Regulation) (‘the GDPR’);
  • Act V of 2013 on the Civil Code (‘the Civil Code’);
  • Act C of 2000 on accounting (‘the Accounting Act’);
  • Act LIII of 2017 on the prevention and combating of money laundering and terrorist financing (‘the Money Laundering Act’);
  • Act CCXXXVII of 2013 on Credit Institutions and Financial Enterprises (‘the Banking Act’).

6. The physical location where the data are stored

Your personal data (i.e. data that could be attributed with you) are transferred into our possession the following manner: regarding maintaining the internet connection, on the one hand, technical data associated with the computer, browser application, internet address used by you are automatically generated in our IT system; on the other hand, you may submit your name, contact details or other information if you wish to reach out to us in person or wish to subscribe to our newsletter while using the website.

7. Data transfer, technical processing and the scope of recipients

We request your name and e-mail address when you subscribe to our newsletter on the wingateproject.com website; such data are not transferred to third parties and are known and processed exclusively by the owner of the website for communication/contact/marketing purposes.

8. Rights of the data subject and the exercise thereof

Data subjects have the right to demand information on the processing of their personal data; to request the rectification, the erasure and withdrawal of their personal data, save where processing is rendered mandatory by the laws; to exercise their right to data portability and the right to object in a manner specified at data recording or at the above contact details of the Controller.

Rights of information

The Controller shall take appropriate measures to provide any information referred to in Articles 13 and 14 of the GDPR and any communication under Articles 15 to 22 and 34 relating to processing to the data subject in a concise, transparent, intelligible and easily accessible form, using clear and plain language.

Right of access by the data subject

The 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 that 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 recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations; the envisaged period for which the personal data will be stored; the right to request rectification or erasure, or restriction of processing, or to object to such processing; the right to lodge a complaint with a supervisory authority; information as to the source of the data; the existence of automated decision-making, including profiling, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject. The Controller will respond to requests within one month from the submission thereof at the latest.

Right to rectification

The data subject shall have the right to obtain from the Controller the rectification of inaccurate personal data and the completion of incomplete personal data concerning him or her and processed by the Controller.

Right to erasure

The data subject shall have the right to obtain from the Controller the erasure of personal data concerning him or her without undue delay in any of the following cases:

  • the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  • the data subject withdraws consent on which the processing is based, and where there is no other legal ground for the processing; the data subject unsubscribes from the newsletter;
  • the data subject objects to the processing and there are no overriding legitimate grounds for the processing;
  • the personal data have been unlawfully processed;
  • the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
  • the personal data have been collected in relation to the offer of information society services.

Erasure of data shall not be requested to the extent that processing is necessary:

  • for exercising the right of freedom of expression and information;
  • for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller;
  • for reasons of public interest in the area of public health or for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes;
  • for the establishment, exercise or defence of legal claims.

Right to restriction of processing

At the request of the data subject, the Controller shall restrict the 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 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; or
  • the data subject has objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject.

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

Right to data portability

The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to the Controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.

Right to object

The data subject shall have the right 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 processing that 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 or for processing serving the legitimate interests pursued by the Controller or by a third party, including profiling. The Controller shall no longer process the personal data unless there are 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.

Automated individual decision-making, including profiling

The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

Withdrawal of consent

The data subject shall have the right to withdraw his or her consent at any time.

Right to judicial redress

The data subject shall have the right to seek judicial remedy if his or her rights have been violated. The issue shall be decided upon by the court as a matter of priority.

Proceedings before the data protection authority

You may lodge a complaint with the National Authority for Data Protection and Freedom of Information:

Name: National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság)
Head office: H-1125 Budapest, Szilágyi Erzsébet fasor 22/C.
Mailing address: H-1530 Budapest, Pf.: 5.
Telephone: +36 1 391 1400
Fax: +36 1 391 1410
E-mail: ugyfelszolgalat@naih.hu
Website: https://www.naih.hu

9. Taking photographs, making audio and video recordings and the use thereof

Subscribers to our courses and trainings acknowledge that their photograph might be taken as well as audio and video recordings may be made at the events, occasions or trainings related to the activities of SKC-Consulting Kft. (hereinafter ‘the Controller’).

By accepting the Privacy Policy, they give their consent to have their photograph taken and audio and video recordings made at the events, occasions associated with the activities of the Controller.

In order to promote the Controller, subscribers consent to the uploading of their photograph, audio and video recordings to the Controller’s public website and social media platforms, the publication thereof in printed brochures, as well as to the processing and storage involved in the course of the foregoing.

The legal basis of processing is the preliminary consent of the legal representative pursuant to Act CXII of 2011 on the right to informational self-determination and on the freedom of information. The term of processing is 5 years or, in the event of withdrawal of the data subject’s consent, until such withdrawal.

The entity authorised to carry out the processing is the Controller, and it does not engage a processor or transfer any data.

10. Miscellaneous

We provide information about any processing not mentioned in the present Privacy Policy upon data recording.

We inform our customers that the court, the public prosecutor, the investigating authority, the authority dealing with administrative offences, the administrative authority, the National Authority for Data Protection and Freedom of Information, the Central Bank of Hungary, or other bodies mandated by the laws may contact the Controller and demand that it provide them with information, disclose or transfer data, or make available documents.

The extent to which the Controller will disclose personal data to such authorities — provided that the exact purpose and the scope of data was specified — is limited to what is strictly necessary for ensuring compliance with the purposes of such request.

COOKIE POLICY

SKC-Consulting Kft. uses cookies on its wingateproject.com website to ensure a better user experience. To take full advantage of the wingateproject.com website (hereinafter ‘the Website’), you must accept cookies on your computer, tablet or mobile phone. It is important for us that you find out about the cookies used by our website and their purpose. The purpose of this is to protect your data and to provide the best possible user experience at the same time.

What are cookies?

Cookies are small text files containing small amounts of information, downloaded to and possibly stored on your device, e.g. on your computer (or other device with internet connection, such as your smartphone or tablet). The wingateproject.com website may use other similar techniques, for example pixels, web beacons or digital fingerprints. For the sake of consistency, all such techniques are hereinafter jointly referred to as ‘cookie(s)’.

The Cookie Policy offers information about the cookies we use and their purpose. Our data protection guidelines provide detailed information about the personal data we collect and the manner wee use your personal data. Our Privacy Policy also offers an explanation of cookies, we recommend that you explore the latter as well.

Cookies used by the website

By authorising the use of cookies you give your consent to wingateproject.com to place such cookies and to retrieve them. There are various types of cookies used by wingateproject.com: (1) functional cookies; (2) analytics cookies; and (3) advertising cookies. Some of these are temporary, so-called session cookies that enable us to follow your movement during your browsing across our pages. Temporary cookies will expire when you close your browser. There are other, so-called permanent cookies that will remain on your device for a time specified in their description. The website uses these cookies for the following purposes:

FUNCTIONAL COOKIES

Functional cookies are essential and help you navigate the website. They make the website more user-friendly. Such cookies ensure that you need to confirm your age only once, and/or they remember the content of your shopping bag during the shopping process. They are also useful in supporting the security and basic functions of the website.

ANALYTICS COOKIES

Analytics cookies enable us to understand the behaviour of visitors and their use of the website in context. These cookies offer insight into, for example, how our visitors use the website. This means that we can ascertain what works and what doesn’t; they enable us to continuously improve the website and measures the efficacy of our advertisements and communication.

ADVERTISING COOKIES

Advertising cookies remember your sub-page preferences and that you visited the website. We endeavour to offer you relevant advertisements that attracted your interest on other on-line platforms, based on your visits and search behaviour on our website and the websites of third parties, whenever possible. We create a segmented profile based on all this and adjust the content and advertisements on our website to the interests of various customer groups. Third parties who place cookies via our website may also apply the same method to evaluate your interest, and they might use the information gathered to offer you content or advertising that attract your interest to you on websites other than wingateproject.com as well. In this case, information about your visit on this website may be combined with information about your previous visits to other websites as well. Furthermore, advertising cookies limit the number of occasions you see an advertisement and help measure the efficacy of such advertisements.

External social networks (e.g. Facebook, Twitter, LinkedIn, etc.) may also place cookies on this website. This enables you to share the content of this website on such social networks. Such external parties may use cookies for their own purposes. The wingateproject.com website and its owner, SKC-Consulting Kft. does not control how your data are used by these social media networks. Further information about cookies set by social media networks is available in their own privacy and cookie policies.

Cookie settings

SKC-Consulting Kft. offers you the opportunity to consent to the use of cookies by the wingateproject.com website and to set your preferences regarding certain types of cookies by clicking on the ‘Cookie settings’ option on the pop-up banner. You may change your settings at any time by clicking on the hyperlink appearing on our website; and you may withdraw your previously given consent as well. Such hyperlink contains every analytics and advertising cookie.

Please note that certain parts or functions of our website might be unavailable if you just block every cookie in your browser settings, given that the browser will prevent us from placing functional cookies required by such parts or functions to remain functional. Therefore, we recommend that you use the cookie settings offered by our website instead of blocking the cookies in your browser.

Cookie overview

The following table contains the full list of cookies used by the wingateproject.com website:

Name Source Purpose Expiry
_ga google.com It uses Google Analytics for statistics and analytics purposes 2 years
_ga_WHK16GNZQM google.com It uses Google Analytics to adjust query limits 1 day
uncode_privacy It stores consents and settings entered in the privacy settings 1 year