Privacy Notice

The purpose of this Privacy Notice is to provide you with accurate and comprehensive information regarding the use of your Personal data with respect to thePlatform (as defined below). This Privacy Notice was prepared taking into account the relevant laws and regulations, most notably:·      

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of27 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, “GDPR”);
  • The Hungarian Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information;
  • The Hungarian Act C of 2003 on ElectronicCommunications, and
  • The Hungarian Act XLVIII of 2008 on the Basic Requirements and Certain Restrictions of Commercial Advertising Activities

1.    Basic concepts

This list of basic concepts is aimed at helping you to better understand this Notice.

Notice: this PrivacyNotice.
Personal data: any information relating to an identified or identifiable natural person such as a name, or contact data, based on which the given natural person can be directly or indirectly (that is, combined with other information) identified.
Data subject: you, as a natural person with respect to whom the Data Controller processes Personal data.
Data Controller or “we”: the entity determining the purposes and means of the Data processing.The controller of your Personal data is KÖR Innovatív Zrt. (company registry number: 13-10-042118, registered seat: H-2600 Vác, Gödöllői út 6. B. ép.; Hungary).
Data processing: any action performed on Personal data, such as collection, structuring, storage, transmission, erasure or anonymization.
Data Processor: an entity which processes Personal data on our behalf, as per our instructions.
Recipient: an entity to which we transfer Personal data.
Platform: the online platform made available by us to you as a private entrepreneur or to the company or other organization that employs you, which platform enables service providers (including us) to sell, distribute, advertise, promote the sale of, or otherwise make available their laboratory and engineering services, subject to our Terms and Conditions, to us or to our customers who wish to make use of such services.
Cookie: cookies are small text files that are placed on your device (e.g. a computer) used when visiting the Platform. Each cookie is stored on your device for a specific period of time, allowing the Platform to “remember” certain data and settings. Cookies do not pose any security risk to your device and do not cause any malfunctions.
IP address: short for Internet Protocol address, an IP address is a unique set of numbers associated with each device connected to the internet. Devices use these addresses to communicate with one another. It also identifies the device you use when visiting the Platform.
Third country: all countries outside the European Economic Area. (In addition to the Member States of the European Union, the countries of the European Economic Area are Norway, Iceland and Liechtenstein.)

2. Why and when do we process your Personal data?

The Data Controller is the owner andoperator of the Platform. The purpose of the Platform is to create an onlinemarketplace that links business organizations in need of laboratory andengineering expert services with organizations and individual entrepreneurs whooffer such capabilities. In accordance with our Terms and Conditions, thecompany or other organisation that employs you or you as an individualentrepreneur can register to the Platform and use it to sell, distribute,advertise, promote the sale of, or otherwise make available, search for, accessto, use or otherwise purchase laboratory and engineering services.

In order to allow for theregistration and subsequent use of the Platform, it is necessary to processcertain Personal data of the natural persons acting as the representatives orcontact persons of the organizations or the Personal data of individualentrepreneurs using the Platform. Therefore, to the extent such Personal datais processed, the use of the Platform and certain related processes entail theprocessing of Personal data.
You can find a detailed summary of the categories of Personal data processed, the purposes of the Data processing, the legal grounds of the processing as well as the applicable data retention periods in Section 4.   

3. What are the principles of our Data processing?

When processing your Personal data, we adhere to the following principles:

  • We process your Personal data lawfully, fairly and in a transparent manner. This means that you will always be provided with all the relevant information that relates to how and why your Personal data is processed and what privacy related rights you may exercise during the course of the Data processing. It also means that the Data processing will always have a valid, real and lawful purpose. We will never process your Personal data for non-disclosed or not sufficiently specific purposes.
  • We do not collect or store any data that is not necessary for the purposes described in Section 4. Apart from the data specified there, we do not collect or use any Personal data, nor do we collect Personal data that we plan to use only in the future for a purpose yet to be determined.
  • We process your data only for as long as necessary given the underlying purpose. We do not store your data indefinitely, the applicable retention periods are communicated to you in a transparent manner and once the given period is over, your data will be erased without the possibility to restore them.
  • We shall do our best to ensure that your Personal data is kept accurate and up to date. For this purpose, we kindly ask you to inform us of any change in your Personal data that we process.
  • We always take appropriate steps to ensure the safety of your Personal data and minimize the risk of unauthorized access, disclosure or any other event or data breach that could compromise the confidentiality, integrity or availability of your data.
  • We know that first and foremost, you are the one who has the right to decide what happens to your Personal data. We examine and address any queries, requests or complaints you have in relation to the processing of your Personal data and respond to those within the statutory deadline. The same is true when you wish to exercise your rights detailed in Section8.

4. How do we process your Personal data?

In this Section we describe all possible cases when we process your Personal data. This helps you see what Personal data we process, why, on what grounds and for how long.

4.1. Business contact details for the purpose of communication

What Personal data do we process?
Your contact data are used when your organization registers on the Platform and gives us your business contact details. We will need your business email address, for the purposes of communicating with your organization.If your name, job title and business phone number are provided as well, we will use those to facilitate contact with the organization.

Why do we process your Personal data?
We process your Personal data for the following purposes:

  • registering the organization, therebyallowing access to the Platform,
  • providing support in the context of using the Platform;
  • communicating with your organization regarding the use of the Platform and in relation to our contractual arrangements with your organization,
  • preparation, execution and fulfilling of contractual arrangements with your organization in accordance with our Terms and Conditions.

On what legal grounds do we process your Personal data?
We process your Personal data on the grounds of our legitimate interest related to operating thePlatform, providing services to our registrants in line with our Terms andConditions and performing our contractual obligations arising from any specific contractual arrangements concluded with the organization appointed you as a contact person.

How long do we store your Personal data?
We process your Personal data:

  • until your organization informs us that another contact person has taken your place, but in no case after the expiry of the civil law statutory limitation period (5years), which starts when the contractual arrangement is terminated between your organization and us for any reason; or
  • until you, as Data subject object to the Data processing, and our assessment finds no compelling cause that overrides your objection.

4.2. Registration on the Platform as individual enterpreneur

What Personal data do we process?
If you register on the Platform as an individual entrepreneur, we will process your name, job title, business email address, business telephone number, registration no., VAT no. or other tax identification no., URL of your website as an individual entrepreneur (if any), your registered address and address(es) of your other business premises, your mailing address, your billing name and address, the amount of fee agreed under any contractual arrangement concluded by using the Platform and any other business information of you as an individual entrepreneur shared with us or became known to us in connection with the use of the Platform. You can also disclose to us yourPersonal data pertaining to your professional qualifications, expertise, licenses or other information that has relevance for us to achieve the purposes of the Platform specified in our Terms and Conditions (the Personal data that we collect will, under no circumstances, extend beyond your professional domain).

Why do we process your Personal data?
We process your Personal data in order to:

  • register you as an individual entrepreneur, thereby allowing access to the Platform;
  • provide support in the context of using the Platform;
  • communicate with you regarding the use of the Platform and in relation to our contractual arrangements;
  • prepare, execute and fulfill contractual arrangements with you in accordance with our Terms and Conditions;
  • meet our mandatory accounting and tax payment obligations.

On what legal grounds do we process your Personal data?
If you register as an individual entrepreneur, we process your Personal data as it is necessary for the performance of the contractual arrangement concluded by and between you and us.Your billing and other data used for invoicing will be processed in order to ensure our compliance with legal obligations to which we are subject under the statutory provisions of accounting and tax law.

How long do we store your Personal data?We process your Personal data until the expiry of the civil law statutory limitation period (5 years), which starts when the contractual arrangement is terminated between you and us for any reason. Regarding accounting and taxation, we will retain your Personal data as required to do so by the mandatory provisions of law (i.e. documents related to financial settlement shall be retained for eight years).

4.3. Information on expertise, qualifications and licenses of professionals

What Personal data do we process? If a service provider which employs you as an engineer or other expert shares information through the Platform with us about you, we will process your Personal data pertaining to your professional qualifications, expertise, licenses or other information that has relevance for us to achieve the purposes of the Platform specified in our Terms and Conditions (the Personal data that we collect will, under no circumstances, extend beyond your professional domain).

Why do we process your Personal data?
We process your Personal data in order to offer, promote and sale the laboratory or engineering services of your organization to our clients.

On what legal grounds do we process your Personal data?
We process your Personal data on the grounds of our legitimate interest related to operating the Platform and offering your organization’s laboratory and engineering services to our clients.

How long do we store your Personal data?
We will process your Personal data:

  • until the expiry of the civil law statutory limitation period (5 years), which starts when the contractual arrangement is terminated between your organization and us for any reason; or
  • until you, as Data subject object to the Data processing, and our assessment finds no compelling cause that overrides your objection.

4.4.  Inquiries, complaints and exercising Data subject rights

What Personal data do we process?
Your contact data (especially your name, email address, phone number, the name and other data of the organization that employs you), further, any Personal data you disclose to us in the course of handling complaints or responding to queries related to the use of thePlatform, the contractual relationship between us and you or the organization employing you, or the exercising of Data subject rights (such as the detailed description of the complaint or query).Please disclosePersonal data in your request or complaint only to the extent absolutely necessary in order to fulfill your request or complaint. Please do not disclose any data that falls into the special categories of Personal data (such as data relating to ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health related data, or data concerning a person’s sex life or sexual orientation). If you deem that it is absolutely necessary to disclose special data to us, please include your explicit consent in your query / complaint (or, incase the special data do not relate to you, the explicit consent of the Data subject it relates to), allowing us to process such data.

Why do we process your Personal data?
We process your Personal data for the purposes of handling complaints, answering queries related to the use of the Platform or the exercising of the Data subject rights detailed in Section 8.

On what legal grounds do we process your Personal data?We process your Personal Data on the grounds of our legitimate interest related to handling and responding to queries, complaints related to the Platform, the contractual relationship between us and you or the organization employing you, further, our legitimate interest related to fulfilling our obligation to ensure you can exercise Data subject rights under the GDPR.

How long do we store your Personal data?
We process your Personal data:

  • until the end of the civil law statutory limitation period (5 years), which starts from the conclusion ofhandling the complaint or responding to the query or Data subject request; or
  • until you, as Data subject object to the Data processing, and our assessment finds no compelling cause that overrides your objection.

4.5.  Anonymization

What Personal data do we process?
We will make anonymous all the reports and other deliverables provided by laboratory or engineering service providers to us or to our customers in accordance with our Terms and Conditions.Once we have deleted your personally identifiable information (such as name or email address) the deliverable becomes anonymous and is not considered Personal data. All deliverables are anonymized before being disclosed to the customer ordering them. We may use the anonymized data to develop or enhance the Platform and our services.We ask you not to include any Personal data in the user content (as defined in our Terms and Conditions) uploaded and posted through the Platform.

Why do we process your Personal data?
We process your Personal data for the purposes of the anonymization of the Personal data contained in the deliverables so that it can be disclosed to the customer and it can be used for development and enhancement of the Platform and our services. 

On what legal grounds do we process your Personal data?
We process your Personal data on the grounds of our legitimate interest related to operating the Platform, developing or enhancing the Platform and our services, and performing our contractual obligations arising from any specific contractual arrangements concluded. More specifically, on the grounds of our legitimate interest related to ensuring that only anonymized deliverables are disclosed to the customer, or used for developing the Platform and our services, thereby we adhere to the principle of data minimization and do not process unnecessary Personal data.

How long do we store your Personal data?
We process your Personal data until the end of the anonymization process that takes no more than two business days from the disclosure of the deliverable to us.

4.6.  Cookies

What Personal data do we process?
Data collected by Cookies and tracking codes active on the Platform.

Why do we process your Personal data?
We process your Personal data for the purposes of balancing the technical load of the Platform as a website and optimizing its efficiency in various ways such as sending personal content and tracking user activity on the Platform.

What Personal data do we process?
Your name and business email address provided when registering yourself as an individual entrepreneur or your organization on the Platform.

Why do we process your Personal data?
We process your Personal data for the purposes of sending newsletters and information on our services.

On what legal grounds do we process your Personal data?
We process your Personal data on the grounds of your explicit, informed and voluntary consent, which you can withdraw at any time. Such withdrawal will not affect the lawfulness of our Data processing carried out before you withdrew your consent.

How long do we store your Personal data?
We process your Personal data:

  • until the withdrawal of your consent; or
  • if we erase your contact details for the reason specified in Section 4.1 of this Notice (i.e. because your objected to the use of your contact details).

4.7. Legal claims

What Personal data do we process?
YourPersonal data disclosed to us through the Platform.

Why do we process your Personal data?
We process your Personal data for the purposes of the establishment, exercise or defense of our legal claims incase of an authority, court or arbitration tribunal procedure.

On what legal grounds do we process your Personal data?
We process your Personal data on the grounds of the establishment, exercise or defense of our legal claims in case of an authority, court or arbitration tribunal procedure.

How long do we store your Personal data?
Until the end of the civil law statutory limitation period (5 years), which starts when the registered profile of the organization you represent, or your individual entrepreneur profile is deleted from the Platform.

5. How do we store your Personal data?

We store and process all your Personal data on properly protected servers. All servers we use are located in the territory of the European Union and the Personal data stored on the servers and are not accessible from Third countries, with the following exception.

We cooperate with an IT service provider (see details in Section 6) based in the United States ofAmerica. Given that this service provider could have access to Personal data in order to provide its services to us (e.g. system maintenance, repairs), we employ the following additional safeguards to ensure your data remain safe, even when accessed from the United States of America.

To whom do we disclose your Personal data?
We treat your Personal data confidentially and do not disclose it to third parties except as listed here.

These exceptions are the following:

  • Webflow, Inc. 398 11th Street, 2nd Floor San Francisco, CA 94103 which provides information technology services to us required to operate the Platform and address any technical issues. In order for our information technology service provider to be able to provide us with its services, it is essential that the service provider has access to certainPersonal data. However, the IT service provider, as our Data Processor will always act in line with our instructions, bound by a data processing agreement;
  • in the case of exercising legal claims or defending against the legal claims of others, we might need to transfer your Personal data to our legal advisors, who will, at all times, be bound by confidentiality obligations as well as the professional secrecy rules applicable to attorneys at law;
  • if a court procedure is initiated in relation to the contractual arrangements between you or your organization and us, your Personal data might be disclosed to the court and other participants of such procedure;
  • upon the request of authorities or courts, we are obliged to provide the information requested, which may contain yourPersonal data. We cannot be held responsible for such data transfers and their consequences. You will be notified if such a transfer takes place, to the extent permitted by the applicable laws.

6. What are your rights with respect to the Data processing?

You, as Data subject have various rights with regards to the processing of your Personal data. These are set forth in the GDPR and you can exercise them at any time by contacting us.

Our contact details:
Data protection coordinator: Peter Kiss
email: peter.kiss@kor-group.com
Postal address: 1025 Budapest, Csejtei utca 16. Hungary

We consider your request on exercising your rights under GDPR authentic, if we can clearly identify you based on your request. We will consider your request authentic only if it is made in writing or it is submitted via e-mail from your e-mail address known to us. Unless you voluntarily verify your identity in a different way, we cannot send information to any other email or postal address not previously known to us – in order to ensure the security of your Personal data.We ask you to describe your request in a concise, clear manner in your own words and we will make sure to examine it and take the necessary steps. We will respond to each request submitted within 25days of receiving the request. Exercising your rights is free of charge.

6. 1. Right to access

Right to access means that you are entitled to request information about our processing of your Personal data. You can request us at any time to inform you whether we process your Personal data and if yes

  • what data we process about you,
  • what is the purpose of our Data processing,
  • to which recipients we disclose your Personal data,
  • how long does the retention period take (how long we keep your Personal data),
  • what rights you have in relation to the Data processing, and
  • whether we transfer your Personal data to any Third countries or organizations and if we do, what additional guarantees we put in place to ensure the safety of your Personal data.

Additionally, you can request us to provide you with a copy of your Personal data processed by us. These copies will always be provided to you in the form of a pdf file, an email or in another form depending on the circumstances. We can only deny providing such a copy to you if it has a negative impact on the rights and freedoms of someone else or would violate the intellectual property or business secrets of someone else.

6. 3. Right to erasure (“right to be forgotten”)

You have the right to be forgotten.This means that we will, without undue delay erase any or all of your Personaldata, if at least one of the following criteria is met:

  • we no longer need the data for any of the purposes specified in Section 4 above;
  • we were processing your data on the basis of your explicit consent (e.g. for marketing purposes) and you withdraw such consent;
  • we were processing your data based on our legitimate interest and you object to such processing, provided that based on our assessment, there are no legitimate grounds that override your objection;
  • despite our best efforts, for some reason the data is has been processed unlawfully;
  • we must erase the data in compliance with a mandatory provision in the laws either of the European Union or Hungary;

If feasible, we will also inform any Recipients of the erasure of your Personal data. We will provide you on request a list of Recipients to whom we communicated the fact of erasure.

Please note that we are not required to delete your data if the Data processing is necessary for the establishment, exercise or defense of our legal claims, or we are required by European Union of Hungarian law to store the data.

6. 4. Right to restriction of Data processing

You can request restriction of Data processing if at least one of thefollowing criteria is met:

  • you contest the accuracy of the data – in this case, the restriction extends to the period while we check the accuracy of the data;
  • despite our best efforts the Data processing was unlawful, however, instead of erasing your data, you request that its processing be restricted;
  • we no longer need your Personal data for any of the purposes specified above, but the data is needed for the establishment, exercise or defense of our legal claims;
  • you objected to the processing – in this case, the restriction extends to the period until which we assess whether there are any legitimate grounds that override your objection.

When Data processing is restricted, we are permitted to store the Personal data, but we are not allowed to use it. Please note that the restriction of Data processing does not apply, if the Data processing is necessary for the establishment, exercise or defense of our legal claims or for the protection of the rights of another person.

If you registered on behalf of a business organization, please consider that your Personal data is always processed as part of a business organization profile registered on the Platform. Therefore, if you request the restriction of the processing of your Personal data, this might result in our inability to maintain contact with the organization on behalf of which your data was provided and we might not be able to fulfill our contractual obligations to your organization.

We explicitly exclude any and all liability for the event when communication with your business organization or performing our obligations becomes impossible because you requested the restriction of the processing of your Personal data.

6. 5. Right to object

If the legal basis for the processing of your Personal data is our legitimate interest or that of a third party, you may object to the processing at any time. Upon objection, we will erase your Personal data, except if

  • our Data processing is justified by legitimate and compelling causes that override your objection, or
  • the Data processing is required for the establishment, enforcement or defense of our legal claims.

If you registered on behalf of a business organization, please consider that your Personal data is always processed as part of a business organization profile registered on the Platform. Therefore, if you object to the processing of your Personal data, this might result in our inability to maintain contact with the organization on behalf of which your data was provided and we might not be able to fulfill our contractual obligations to your organization.

We explicitly exclude any and all liability for the event when communication with your business organization or performing our obligations becomes impossible because you objected to the processing of your Personal data.

6. 6. Right to data portability

You can request that we provide you with your Personal data specified in Sections 4.2 and 4.7 in a commonly used, machine-readable format (e.g. a pdf file or email) or that your Personal data be transferred directly to another data controller of your choice.You can exercise this right only if the legal basis for the Data processing is your explicit consent or the Data processing is necessary for the preparation or conclusion of a contract between you and us.

6. 7.  Right to lodge a complaint, right to an effective judicial remedy

We hope that you will never have reason to lodge any complaint against the processing of your Personal data by us.

Nevertheless, we inform you of your rights to effective legal remedy as follows.

If you believe that your Personal data is processed unlawfully, you may file a complaint with the competent data protection supervisory authority. In Hungary, this is the National Authority for Data Protection and Freedom of Information (in Hungarian: “NemzetiAdatvédelmi és Információszabadság Hatóság”, “NAIH”).

Website: http://naih.hu/
Address: 1055 Budapest, Falk Miksautca 9-11.
Postal address: 1374 Budapest,Pf.:603.
Telephone: +36-1-391-1400Fax: +36-1-391-1410
Email: ugyfelszolgalat@naih.hu

If you live or work abroad (i.e.in a European Union Member State other than Hungary) you can also file a complaint with the competent authority of the country of your residence or workplace.

You may also bring proceedings before a court if

  • you believe your Personal data is processed unlawfully (you can go directly to court, there is no need for a preceding procedure byNAIH);
  • NAIH made a binding decision concerning you that you wish to contest;
  • NAIH fails to address your complaint or does respond to it within three months of receiving it (in the latter two cases, the proceedings must be brought against NAIH).