Adatkezelési
Tájékoztató
Elérhetőségeink az adatkezeléssel kapcsolatos kérdésekben:
Telefon:
+36 20 204 5000
e-mail postafiók:
info@redlemon.hu
Postai levelezési cím:
1137 Budapest, Vígszínház utca 5
1. Az adatkezelőről
A jelen tájékoztatóban ismertetett adatkezeléseket érintően adatkezelő:
Red Lemon Media Group Kft.
Székhelye: 1137 Budapest, Vígszínház utca 5.
Cégjegyzékszáma: 01-09-937773
Nyilvántartást vezető cégbíróság: Fővárosi Törvényszék Cégbírósága
Adószám: 22658814-2-41
(a továbbiakban: „Red Lemon”)
effective from: 25 May 2018
For our company, Red Lemon Media Group Kft, the legality of the processing of personal data and the protection of personal data are of particular importance. This Notice is intended to inform individuals, business partners and clients interested in our services making contact with us, on what kind of personal data we collect about them, how we process those and what their rights are.
Personal data are processed by our company strictly in accordance with the purpose of the data processing, to the extent necessary, in a manner and for the period defined by statutory requirements. In order to ensure the security of the data, we ensure high standards are maintained for the necessary data security, technical and organisational measures.
For details on data processing, please read the information below.
Please feel free to contact us at any of our contact details provided above if you have any further questions regarding the contents of this Notice or regarding the processing of your personal data you have already provided.
II. OUR DATA PROCESSING ACTIVITIES
1. MEDIA CONTACT DATABASE
Media contacts shall mean the following persons: journalists, photographers (employed or freelance), publishers, editors, production staff, influencers, bloggers, persons posting on social media or Twitter, other persons whose professional task is to inform the public or to publish news and photos through media outlets to the public.
What is the purpose of data processing?
We provide PR services for our clients, in which we focus on continuously providing media outlets with information (relating to clients, our clients’ products or services), generating, coordinating and allocating media publications, coordinating media relations and ensuring the presence of the media at events. We process the data of media contacts in order to carry out our business activity.
What personal data do we process for the above mentioned purpose?
For the above purpose, we process the name, phone number, e-mail address and current media contacts (which media outlet they are in contact with) of the media contacts.
These personal data are brought to our attention directly by the media contact or from third parties or public sources.
On what legal ground do we process these personal data?
The above personal data of the media contacts will be processed according to Article 6 (1) f) of the GDPR on the basis of our legitimate interest for the performance of our business and PR activities.
How long do we process these personal data?
The personal data contained in the media contact database is kept up-to-date, and we monitor whether the media contact person is still in the sector or whether they have possibly changed to another form of media. If the data subject ceases their media contact activity, they shall be erased from our database. We update the changing data.
In addition, media contact data will also be erased if:
- the concerned media contact requests the erasure of the data
- they object to data processing
- our company ceases PR activities.
– – –
the concerned media contact requests the erasure of the data; they object to data processing;
our company ceases PR activities.
COMMUNICATION WITH POLITICALLY EXPOSED PERSONS
Politically exposed person shall mean all those people who are well-known in Hungary, are generally popular and regularly appear in the Hungarian media.
What is the purpose of data processing?
Within the framework of our PR services, our task is to ensure the attendance, presence and involvement of politically exposed persons at PR events organised for our clients, to generate media attention with the involvement of the politically exposed persons, harmonise them and schedule their publication and to coordinate PR appearances with the involvement of politically exposed persons. In order to accomplish this, we need to contact the concerned politically exposed person through one of their contact channels.
What personal data do we process for the above mentioned purpose?
For the above purpose we process the names, phone numbers and e-mail addresses of politically exposed persons.
These personal data are brought to our attention directly by the politically exposed person or from third parties or public sources.
On what legal ground do we process these personal data?
The above personal data of the politically exposed persons will be processed according to Article 6 (1) f) of the GDPR on the basis of our legitimate interest for the performance of our business and PR activities.
How long do we process these personal data?
The personal data contained in the contact database of the politically exposes persons is kept up- to-date, and the modified data is updated. In addition, we keep track of how the person’s visibility, activity, and popularity evolve in order to determine if further processing of their contact data is justified.
Contact data for politically exposed persons shall be erased if
- their politically exposed classification or popularity from a PR point of view no longer exists;
- the concerned politically exposed person requests the erasure of the data;
- they object to data processing;
- our company ceases PR activities.
3. CONCLUSION AND PERFORMANCE OF THE CONTRACT
This paragraph applies to contracts concluded within the framework of our business activity, that is, contracts that we conclude with our clients or subcontractors, our cooperating partners or suppliers. This paragraph does not cover employment contacts.
In the case of contracts covered by this paragraph, personal data processing may take place on the one hand, if our contracting partner is an individual or a private entrepreneur, who consents to the processing of personal data as required. In this case, all data made available to us that concerns or relates to the contract or references our partner, shall be considered personal data of our partner. If however, our contracting partner is a company (legal entity), personal data processing is generally carried out in relation to the data of the contact person designated by the partner, as well as in the case when the subject of the contract is the processing of the personal data of a third party natural person.
What is the purpose of data processing?
If our contracting partner (either on the client or supplier side) is a natural person or a private entrepreneur, the purpose of processing personal data is to conclude, manage and perform the contract.
In the case of an obligation to provide invoices for a contract, in the case of a natural person and a private entrepreneur contractor, data related to the invoice issues in accordance with the contract, whose purpose is to fulfil our statutory accounting obligations (issuing of invoices, storage of invoices), shall be considered personal data.
In the case of a natural person and a private entrepreneur, the purpose of data processing in the performance of the contract also covers the handling of possible guarantee and warranty claims and other legal disputes.
If our contracting partner is a company (including all legal entities), the personal data of the contact person acting on their behalf shall be processed, and if the subject of the contract is the editing or management of the Facebook page or another social media page of a natural person or the supply of other PR services relating to them, then we shall also process their direct personal data for the performance of the contract. The purpose of the processing of the personal data of the contact person and the third parties affected by the subject of the contract is the smooth conclusion and performance of the contract.
What personal data do we process for the above mentioned purpose?
In the case of natural persons and private entrepreneur contractors:
- requested service, name, identification data, quantity and price of the purchased product;
- order, date and status of conclusion of the contract;
- data relating to the performance of the subject matter of the contract (place ofperformance, date and time, data of the certificate of performance);
- invoice data (name and address of the contractor, invoice number, date of delivery,deadline for payment, gross and net amount, VAT amount, discount amount and type, etc.);
- payment details (payment date, amount, method of payment, bank account number of thecontracting partner in case of transfer);
- declared guarantee and warranty claims, the content of the record of the claim, themethod and the date of performance of the claim.For both natural persons and corporate contracting parties:
- contact details the contact person (surname, first name, phone number, e-mail address);
- personal data relating to third parties depending on if the subject of the contract is themanagement of a Facebook or other social media profile or the provision of another PR activity.On what legal ground and for how long do we process these personal data?In the case of a contract with a natural person and a private entrepreneur, we require your personal data to conclude and perform the contract; therefore the provision of this data is a precondition for the conclusion of the contract. With regard to these data, the legal ground for data processing is the performance of the contract pursuant to Article 6 (1) b) of the GDPR. These data are primarily processed with the general 5 year limitation period (Section 6:22 of the Civil Code) and are erased following its expiry, even in the absence of a request.
In addition, in the case of a natural person or a private entrepreneur, certain personal data will be processed in accordance with the following statutory obligations (Article 6 (1) c) of the GDPR):
- in the case of invoice issuing or retaining obligations, billing data (billing name and address) shall be processed in accordance with Act C of 2000 on Accounting (Accounting Act) and pursuant Section 169 of the Accounting Act, we must keep the receipts issued in connection with the contract together with the data contained therein for 8 years;
- if our client is a taxable legal person, then, if the VAT amount charged in the invoice reaches HUF 100,000, we are obliged to indicate the tax number of the customer or the user of the service on the invoice pursuant to Section 169 paragraph d) sub-paragraph dc) of Act CXXVII of 2007 on Value Added Tax (hereinafter: VAT Act);
- in the case of a consumer contract, we are obliged to keep a record of claims made in connection to guarantee and warranty services and retain them for 3 years pursuant to NGM Decree 19/2014.In the case of a contract with a company, we process the data of the contact person and the personal data relating to third parties affected by the subject of the contract (e.g. personal data processed in the context of the managing Facebook or other social media profiles) during the performance of the contract and the limitation period of claims (5 years), pursuant to Article 6 (1) f) of the GDPR for our legitimate interest in the smooth performance of the contract. When there is a change in contact person, the data of the former contact person shall be erased simultaneously with the updating of the changed data.
4. CUSTOMER SERVICE DATA PROCESSING
What is the purpose of data processing?
If you contact us with any of your questions (initiate contact), we shall process the personal data provided in your message, e-mail, letter or phone call for communication with you and for the answering of your inquiry.
This paragraph also covers the request for information. If the correspondence is related to the preparation of a contract, a contract already in progress or to a concluded contract or to a media contact, then for correspondence the details of the particular data processing activity shall apply.
Which of your personal data do we process for the above mentioned purpose?
For requests received via e-mail:
name, e-mail address, other personal data by the inquiring party (including in particular the contact details of the inquiring party or those of other persons concerned and the circumstances of the case regarding which the inquiring party turned to us)
We process the following data for requests received via the telephone:
name, telephone number, date and time of the conversation, personal data provided by the inquiring party (including in particular the contact details of the inquiring party or those of other persons concerned and the circumstances of the case regarding which the inquiring party turned to the customer service team)
For letters sent by post:
the sender’s name, date of receipt of the letter, other personal data by the inquiring party(including in particular the contact details of the inquiring party or those of other persons concerned and the circumstances of the case regarding which the inquiring party turned to us).
On what legal ground do we process your personal data?
We process the personal data of the data subjects pursuant to Article 6 (1) f) of the GDPR for registration purposes and for answering of the requests of data subjects in our legitimate interestrelating to the settlement of the resulting claims.
How long do we process your personal data for?
Personal data (including e-mails) processed in connection with the requests will be erased after termination of the purpose of the data processing. Thus, if there is no further need for the e-mail and its response for further processing or enforcement, the erasure shall take place immediately, otherwise the request and its response shall be erased after they are no longer required for these purposes.
5. HANDLING THE RECORD OF CONSUMER COMPLAINTS
What is the purpose of data processing?
Recording, handling and documenting complaints received from consumers using our services in relation to our business activities (i.e. our natural person contracting partners).
Which of your personal data do we process for the above mentioned purpose?
The unique identification number of the complaint, the name and address of the consumer (you), the place, time and method of reporting the complaint, papers, documents and records of other evidence provided by the consumer (you), the subject matter and content of the complaint, our response to the complaint, the place and time of creating the record, the signature of the keeper of the record and your signature.
On what legal ground do we process your personal data?
We are required to keep a record of consumer complaints pursuant to Section 17/A (7) of Act CLV of 1997 on Consumer Protection (Consumer Act). (Article 6 (1) c) of the GDPR)
How long do we process these personal data relating to you?
Concerning the copies of the complaint records and responses to the written complaints, for 5 (five) years pursuant to Section 17/A (7) of the Consumer Act.
III. WHO MAY ACCESS THESE DATA RELATING TO YOU?
We process personal data confidentially. Your personal data will only be transferred to third parties if you have consented to it or if it is our legal obligation or is justified by our legitimate interest.
In order to participate in a press event, we are not entitled to provide the names of the mediaoutlet’s contact persons but we may provide the names of the media outlets represented at theevent to the event organisers in order to ensure their entry into the event. The names of politically exposed persons invited to the event shall also be given to the organisers to ensure entry.
Your personal data may be accessed by the employees of Red Lemon Media Group Kft and the data processors of Red Lemon Media Group Kft. and their staff. These persons are also required to treat the personal data available to them as confidential.
Processors used by us and their tasks:
The Processor |
Data processing related activities performed by the Processor |
name: Marianna Valiskó |
Activity: Accounting services |
name: Szamlazz.hu, KBOSS.hu Kft. |
Activity: operation of the online billing program used by us. |
5
e-mail: info@szamlazz.hu |
|
name: Redda-Motor Kft. registered office: 1097 Budapest, Gubacsi út 30., |
Activity: courier service |
name: Mind2 futárszolgálat Ász- Infomatika Kft. e-mail: iroda@mind2.hu |
Activity: courier service |
name: Silver Frog Informatikai Kft. |
Activity: providing web site hosting |
Red Lemon Media Group Kft reserves the right to involve other data processors in data processing in the future, and to inform the Users about it by amending this Notice.
Your personal data shall be disclosed to the court, the prosecutor’s office or other authorities in accordance with our statutory obligations, to the extent and in a manner prescribed.
If have initiated a legal claim against you, your personal data may also be made available to our legal collaboration partners and our claim management partners to the extent required for claim enforcement.
IV. DATA SECURITY
Red Lemon Media Group Kft undertakes to implement the necessary data security measures. In this context, it approves and develops and regularly reviews all technical and organisational measures and procedural rules, which ensure that the personal data it processes is secured, and will do its utmost to prevent the destruction, unauthorised use or alteration of the data, to ensure that no unauthorised person can access, disclose, transfer, modify or erase the personal data processed. Red Lemon Media Group Kft advises the parties to whom it had transferred personal data, with the consent of the data subject, to comply with data security requirements.
Within the framework of the above, Red Lemon Media Group Kft designs and selects information technology solutions to ensure exclusive access to the data is granted only for authorised persons and to guarantee authenticity and integrity of the data. This includes, among others, password- protected access systems, activity logging, and regular backups.
Red Lemon Media Group Kft always monitors the evolution in technology, utilises the available technical, technological and organisational solutions and the appropriate solutions to meet the level of protection required by its data processing.
At the same time, Red Lemon Media Group Kft informs the data subjects that, when entering their personal data on the Website, full data protection cannot be guaranteed on the internet despite the fact that it has up-to-date security equipment to prevent any unauthorised access to data. In the event of unauthorised access to the latest data security systems and methods, Red Lemon Media Group Kft shall not be held liable.
V. HANDLING OF DATA BREACH INCIDENT
All cases are classified as data breach incidents where an unauthorised person gains access to personal data or where the data is destroyed, lost or altered, such as, for example, where the database is destroyed or the data carrier on which the data are stored is lost.
In the event of a data breach incident, we evaluate its impacts and risks (what kind of data are affected, in what quantity, can they be restored, etc.) and take immediate action for its prevention. If the risks cannot be prevented, we shall report the incident to the data protection authority within 72 hours its detection and we shall publish a notification on our website in reference to it. In addition, we also keep a record of data breach incidents in as much detail as required by law, which shall be kept for 5 years from the detection of the data breach incident.
VI. YOUR RIGHTS
ACCESS RIGHTS: You can request information through any of our contact channels listed in paragraph I. in relation to whether we are processing your personal data, and if so, you can request further information regarding the below:
the purpose and legal ground of data processing, your personal data processed by us and their categories, the recipients or categories of recipients (including the processors used by us) with whom we have shared or will share the personal data (the adequate data protection guarantees in the case of transferring data to third countries), the legal ground of the data transfer, the right of the data subject to request the data controller to rectify, erase or restrict the personal data relating to the them and to object to the processing of the personal data, the right of submitting a complaint to NADPFI, the source of the data, the circumstances and effects of the possible data breach incident and the measures implemented for their prevention.
Simultaneously with the notice, we shall also provide you with a copy of your personal data processed by us. The first copy is free of charge, but for any additional copies we are entitled to charge a reasonable fee based on our administrative costs of each copy. The amount of which we communicate to you in advance.
RIGHT TO RECTIFICATION AND SUPPLEMENTATION: If you find that your personal data is stored erroneously, incorrectly or incompletely, please provide us with the correct or additional data as soon as possible so that we can carry out rectifications and supplementation.
RIGHT TO ERASURE (‘RIGHT TO BE FORGOTTEN’): You are entitled to request the erasure of your personal data. Please note that erasure of data may be refused, especially if you need or may be required to comply with a statutory obligation or enforce your claim.
In the case of data processing carried out based on legitimate interest, the objection to data processing involves the erasure of the data, provided there is no more important reason why the erasure cannot be performed.
Furthermore, erasure takes place if
- a) the data is no longer needed for the original processing purposes;
- b) the data processing is unlawful;
- c) we are obliged to erase the data in accordance with EU or national legislation.
RIGHT TO RESTRICTION: During the data processing activity, you may request a restriction of data processing if (i) you contests the correctness of the personal data, in which cases the restriction shall only apply to the time period necessary for us to verify the correctness of the personal data; (ii) the data processing is unlawful, but you does not consent to the erasure of the data and instead requests the restriction of their use; (iii) we no longer require the personal data for data processing purposes, but you request the data for the submission, enforcement or protection of legal claims, (iv) you objected to data processing based on our legitimate interest; in such cases the restriction shall only apply to the time period necessary to determine whether the justified needs precede your justified needs.
In the case of a restriction, the data will only be stored and no other processes shall be carried out with them unless you provide consent for their use in further processes or they are required to protect our own or third party rights or it is in the public interest.
When data processing is restricted we shall inform you in advance if the restriction is lifted.
RIGHT TO OBJECTION: With regard to data processing based on our legitimate interest or that of a third party, you may object to our data processing if you feel that the data processing is prejudicial to you.
In the case of objections we erase personal data, unless their preservation is necessary for more important reasons. Such a major reason might be, if we intend to enforce a claim against you.
RIGHT TO DATA PORTABILITY: Regarding the data processing associated with your contracts with us, you may request that your personal data provided to us be made available to you or to another person designated by you in a well-known and easy-to-use electronic format.
VII. SUBMISSION OF REQUESTS AND THEIR REPLY
We ask that your requests regarding the exercising of your rights be sent to us in writing to our info@redlemon.hu e-mail address or to Red Lemon Media Group Kft. 1037 Budapest, Montevideo utca 9 by post. In the letter, we ask that you provide the data required for your identification along with your correspondence address. If we have any doubts about your identity or the data provided for identification is insufficient, we are entitled to request additional identification data from you.
We shall fulfil your request within 1 month. If necessary, we are entitled to extend this deadline by a further 2 months, regarding which we shall send you a notification complete with our reasoning.
We fulfil substantiated requests free of charge. However, if the request is manifestly unfounded or exaggerated in view of its particularly repetitive nature, we are entitled to charge you a reasonable fee or even refuse to take the measure to be performed based on the request.
We shall notify all parties with whom we have shared the particular data of any rectification, erasure or restriction, unless this proves impossible or involves disproportionate effort. Upon your request, we shall share with you the identities of the recipients who we are informing or have informed in accordance to the above.
VIII. LIABILITY AND RESTITUTION
If we should cause damages to you or another party with the unlawful or unsecure processing of your personal data, then you or the damage incurring party is entitled to recover the damages from us.
If, in this regard, we are in violation of your personality rights, you are entitled to claim damages.
Please note that we shall not be subject to any compensation or damages if the damage is proven to be caused by an unavoidable external cause outside the scope of the data processing activity or if the damage comes from your deliberate or grossly negligent behaviour.
IX. CLAIM ENFORCEMENT METHODS
1. Contacting the Controller
If you feel that during the processing of your personal data we are proceeding unlawfully, please advise us, as the controller, of your observations or claims first, on any of our contact details listed in paragraph I so that we can process and handle your observations as quickly and efficiently as possible.
2. Turning to and submitting a complaint to the data protection authority
In the event of the unlawful processing of data you may turn to the National Authority for Data Protection and Freedom of Information (NADPFI) and initiate their proceedings.
Contact details of NADPFI:
website: http://www.naih.hu/
address: 1125 Budapest, Szilágyi Erzsébet fasor 22/cpostal address: 1530 Budapest, Pf.: 5.
e-mail address: ugyfelszolgalat@naih.hu
3. Bringing proceedings before the court
Please note that you may also enforce your claim before a court. The courts have jurisdiction over lawsuits. The lawsuit may be brought before the general court located in the vicinity of either our registered office or your home address or temporary residence.
Budapest, 25 May 2018
Red Lemon Media Group Kft.
Controller
INTEREST BALANCING TESTMEDIA CONTACT DATABASE
Subject of data processing: Processing of the personal data of media contacts (employed or freelance journalists, photographers, publishers, editors, production staff, influencers, bloggers, persons posting on social media or Twitter, other persons whose professional task is to inform the public or to publish news and photos through media outlets to the public).
Personal data: The name, telephone number, e-mail address and current media contacts (which media outlet they in contact with) of the media contacts.
Purpose of data processing: Supplying news, press releases, articles and photos to the given media outlet, and publish of these.
Legitimate interest: Executing our business activities, fulfilling orders for PR services. Legal ground for legitimate interest: Article 6 (1) f) of the GDPR
Rights of the Data Subject,
which may be violated: protection of privacy
Balance of interests: Red Lemon Media Group Kft provides PR services to its clients, for the performance of which it is essential for it to be able to contact those media outlets to whom the particular article, story or photo may be of interest, thereby facilitating the publication of the stories and photos to the target audience. In the absence of media contact data, our company is unable to perform its business activity.
Data processing also serves the legitimate interests of media contacts as it is in the professional and business interest of media contacts to receive news about our clients, their activities and their products, and to publish articles relating to them. They have access to the information forming the subject of their articles through us. We send news directly to them, invite them to press events, etc.
In the PR profession, contact between media contacts and PR professionals is essential and indispensable for the mutual interest of both parties.
Guarantees: Based on the principle of data minimisation, we only process personal data that is indispensable for the purposes of the data processing.
The contact data is either collected from the data subject or from a public source where the contact data of the data subject was explicitly disclosed for communication in connection to their professional activity. Personal data is also accepted from third parties if the personal data may be used for professional type communication purposes (e.g. business card data or data that is obviously used for business type communication purposes).
Naturally, we do not process contact data that is used for private purposes.
Our company processes personal data only based on the legitimate interests defined herein.
Outside of normal business hours, we avoid direct telephone contact, thus ensuring privacy.
Only authorised persons have the right to access the data, and we take the necessary data security and organisational measures to safeguard the confidentiality of the data.
Summary:
On the basis of the above, the controller considers that their legitimate interest is justified for processing the data of media contacts, and that the legitimate interest is not overridden by the individual’s rights and freedoms.
Red Lemon Media Group Kft.
Budapest, 25 May 2018
Controller
INTEREST BALANCING TEST
CONTACT DATA OF POLITICALLY EXPOSED PERSONS:
Subject of data processing: Processing of the personal data of politically exposed persons for the performance of our PR activities
Personal data: Name, telephone number and e-mail address of politically exposed persons
Purpose of data processing: Ensuring the presence, appearance and participation of politically exposed persons at PR events and events organised for our clients.
Legitimate interest: Executing our business activities, fulfilling orders for PR services.
Legal ground for legitimate interest: Article 6 (1) f) of the GDPR
Rights of the Data Subject,
which may be violated: protection of privacy
Balance of interests:
Red Lemon Media Group Kft provides PR services to its clients, for the performance of which it is essential for it to be able to contact those politically exposed persons, whose participation and presence at the particular PR event would be advantageous from a PR point of view.
Data processing also serves the legitimate interests of politically exposed persons, as we are in contact with politically exposed persons who regularly appear in the public, participate in events and encourage their invitation to build their own image and popularity.
In the PR profession, public relations between politically exposed persons and PR professionals is essential and indispensable for the mutual benefit of both parties.
Guarantees:
Based on the principle of data minimisation, we only process personal data that is indispensable for the purposes of the data processing.
The contact data is either collected from the data subject or from a public source where the contact data of the data subject was explicitly disclosed for communication purposes. Personal data is also accepted from third parties if the personal data may be used for PR communication purposes (e.g. business card data or data that is obviously used for PR communication purposes).
Naturally, we do not process contact data that is exclusively used for private purposes.
Our company processes personal data only based on the legitimate interests defined herein, and during communication with politically exposed persons fully respects their privacy.
Outside of normal business hours, we avoid direct telephone contact, thus ensuring privacy.
Only authorised persons have the right to access the data, and we take the necessary data security and organisational measures to safeguard the confidentiality of the data.
Summary:
On the basis of the above, the controller considers that their legitimate interest is justified for processing the contact data of politically exposed persons, and that the legitimate interest is not overridden by the individual’s rights and freedoms.
Budapest, 25 May 2018
Red Lemon Media Group Kft.
Controller
INTEREST BALANCING TEST CONTRACTUAL CONTACT PERSON DATA
Subject of data processing: Processing of the contact person data provided by our corporate contracting partner, as well as the processing of personal data relating to
Personal data: third parties subject to the contract
Name, telephone number and e-mail address of the contact personaccording to the contract; the contract’s subject matter related personaldata of a third party affected by the subject matter of the contract (e.g. personal data that is uploaded to Facebook or other social media profiles).
Purpose of data processing: Maintaining contact for the fulfilment of the obligations specified in the contract and for the enforcement rights, was well as for the
performance of the contract.
Legitimate interest: To facilitate the effective fulfilment of the contract by the controller.
Legal ground for legitimate interest: Article 6 (1) f) of the GDPR Rights of the Data Subject,
which may be violated: identifiability of a natural person based on other data; protection of privacy.
Balance of interests:
Contact Persons: The fulfilment of the contractual obligations as efficiently as possible, the efficiency of the cooperation and the coordination of the execution is in the common interest of the contracting parties. In the context of the performance of the contract, communication between the parties may be necessary. Contact persons are usually employees of the contracting parties and the contact details provided are the company contact details on which they are required to be available during working hours as part of their duties.
Affected third parties: In the case of celebrities it happens that they are not directly our clients, but a legal person concludes a contract on their behalf, e.g. for the management of a Facebook profile. In such cases, the contract is for the benefit of the third party concerned, but they are not a contracting party. If the contract is intended for the management of a Facebook or other social media profiles or to increase the popularity of the third party concerned, performance of the contract is not possible without personal data being processed. Since the contract is for the benefit of the person concerned and their personal data is typically provided to us by them personally, the processing of their personal data is within their rights and in their interest.
Guarantees:
The data controller only processes the data of the data subject to fulfil the provisions of the contract.
Confidentiality provisions contained in the contract are also binding to the company .
The data is only accessible to authorised persons.
Summary:
On the basis of the above, the controller considers that their legitimate interest is justified for processing the data of contact persons specified in the contract, and that this legitimate interest is not overridden by the individual’s rights and freedoms.
Budapest, 25 May 2018
Red Lemon Media Group Kft.
Controller
INTEREST BALANCING TEST
FOR CUSTOMER SERVICE DATA PROCESSING
Subject of data processing: Making contact for purposes not relating to the contract concluded with the controller or media contact
Personal data:
For requests received via e-mail, the contact initiator’s:
name, e-mail address, other personal data by the inquiring party
(including in particular the contact details of the inquiring party or those of other persons concerned and the circumstances of the case regarding which the inquiring party turned to us)
For requests received via the telephone, the contact initiator’s:
name, telephone number, date and time of the conversation, personal data provided by the inquiring party (including in particular the contact details of the inquiring party or those of other persons concerned and the circumstances of the case regarding which the inquiring party turned to the customer service team)
For letters sent by post:
the sender’s name, date of receipt of the letter, other personal databy the inquiring party (including in particular the contact details of the inquiring party or those of other persons concerned and the circumstances of the case regarding which the inquiring party turned to us).
Purpose of data processing:
Making contact with us, receiving, recording and answering inquiries.
Legitimate interest: Responding to and handing of inquiries for the enforcement of claims.
Legal ground for legitimate interest: Article 6 (1) f) of the GDPR
Reviewed rights of the data subject: protection of privacy
Balance of interests:
In the case of customer service activities, the data subject is the person who initiates the contact and voluntarily makes available their personal data. It is in the interest of the data subject to receive a response to their inquiry, for which it is essential record the personal data necessary for receiving the inquiry, its recording and response.
Guarantees:
The controller only processes the personal data to the extent necessary to comply with the request. Only authorised persons have the right to access the data, and we take the necessary data security and organisational measures to safeguard the confidentiality of the data.
Summary:
On the basis of the above, the controller considers that their legitimate interest is justified for processing the personal data contained in inquiries, and that the legitimate interest is not overridden by the individual’s rights and freedoms.
Budapest, 25 May 2018
Red Lemon Media Group Kft.
Controller