P92 IT Solutions Kft. & Subsidiaries (“P92”) Privacy Notice Version 1.0 (published on 15/05/2018)

 

HOW WE USE YOUR INFORMATION

We, P92, are committed to protecting your privacy and developing technology that gives you the most powerful and safe online experience. This privacy notice (“Notice”) applies to this website and governs data collection and usage. This Notice is drafted to ensure compliance with your rights under the Data Protection Act 1998, the General Data Protection Regulation, and the rights detailed in the forthcoming UK and Hungarian Data Protection Bills. By using this website, you consent to the data practices described in this Notice.

 

WHO WE ARE

We are P92 IT Solutions Kft. & Subsidiaries, a Hungarian company whose registered office address is at: Fürdő Utca 2, 1038 Budapest, Hungary. Our administrative offices are located at the same address and our contact details are: EMAIL: info@p92.com

 

THE INFORMATION WE COLLECT

We may collect from you and use many different kinds of personal information, and group them together like this.

• Categories of personal information.

• Socio-Demographic - This includes details about your work or profession, nationality, education and where you fit into general social or income groupings.

• Transactional - Details about activity with us.

• Contractual - Details about the products or services we provide to you.

• Locational - Data we get about where you are, such as may come from your mobile phone, the address where you connect a computer to the internet, or a shop where you buy something with your card.

• Behavioural - Details about how you use our products and services.

• Technical - Details on the devices and technology you use.

• Communications - What we learn about you from letters, emails and conversations between us.

• Usage Data - Other data about how you use our products and services.

• Consents - Any permissions, consents or preferences that you give us. This includes things like how you want us to contact you and what optional communications you wish to receive.

 

HOW WE USE YOUR INFORMATION

In addition to our privacy commitment, your privacy is protected by law. This section explains how that works.

Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it with third parties. The law says we must have one or more of these reasons:

• To fulfil a contract we have with you, or

• When it is our legal duty, or

• When it is in our legitimate interest, or

• When you consent to it.

• A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.

 

Here is a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are.

What we use your personal information for our legitimate interests or legal duty:

• To manage our relationship with you or your business.

• To develop new ways to meet our customers’ needs and to grow our business.

• To develop and carry out marketing activities.

• To study how our customers use products and services from us and other organisations.

• To provide advice or guidance about our products and services.

• To track your consent.

• Fulfilling contracts.

• Keeping our records up to date, working out which of our products and services may interest you and telling you about them.

• Seeking your consent when we need it to contact you.

• To obey laws and regulations that apply to us.

• To respond to complaints and seek to resolve them.

 

If we act as a technology provider or a data processor to deliver a service to you through one of our clients then our client acts as the controller of your data, and if you have any questions regarding your data you should in the first instance contact our client.

 

WHO WE SHARE YOUR INFORMATION WITH

We may share your personal information with companies within the P92 Network Group and these other organisations:

• Agents and advisers who we use to help run your accounts and services and explore new ways of doing business.

• HM or Hungarian Revenue & Customs, regulators and other authorities.

• Any party linked with you or your business’ product or service.

• Companies we have a joint venture or agreement to co-operate with.

• Organisations that introduce you to us.

• Companies that we introduce you to.

• Market researchers.

• Companies you ask us to share your data with.

• We may need to share your personal information with other organisations to provide you with the product or service you have chosen.

• If you use direct debits, we will share your data with the Direct Debit scheme.

 

We may also share your personal information if the makeup of our company changes in the future:

• We may choose to sell, transfer, or merge parts of our business, or our assets. Or we may seek to acquire other businesses or merge with them.

• During any such process, we may share your data with other parties. We’ll only do this if they agree to keep your data safe and private.

• If the change to our Group happens, then other parties may use your data in the same way as set out in this notice.

 

HOW WE STORE YOUR INFORMATION

Once we have received your information, we use strict procedures and security features to try to prevent unauthorised access.

All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

The information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"), in which case we will make sure that your privacy rights are protected as required by the General Data Protection Regulation.

 

HOW LONG WE WILL KEEP YOUR PERSONAL INFORMATION FOR

We will keep your personal information for as long as you are our customer.

After you stop being a customer, we may keep your data for up to 7 years for one of these reasons:

• To respond to any questions or complaints.

• To show that we treated you fairly.

• To maintain records according to rules that apply to us.

• We may keep your data for longer than 7 years if we cannot delete it for legal or regulatory reasons.

 

GRANTING & WITHDRAWING CONTACT CONSENT

As long as you give us your explicit consent to do so, we shall tell you about our products and services and those of the P92 Group that we think may be of interest. We may do this by email or post. If you don’t want us to send you any marketing materials you can tell us in one of the following ways:

• By visiting your online profile page on the relevant P92 service website and changing your contact preferences when this function is available; by clicking once on the unsubscribe link contained in our Newsletters and non-essential email communications.
• by contacting us at: info@p92.com
• by writing to us at: Fürdő Utca 2, 1038 Budapest, Hungary or our office in your country – please see our website for details www.p92.com

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy notices and that we do not accept any responsibility or liability for these notices. Please check these notices before you submit any personal information to these websites.

 

ACCESSING YOUR INFORMATION

If you want to know what information we hold about you, please contact us at the email address below. We may have to contact you to verify the authenticity of any communications received by us that indicate they have been sent by you.

 

CORRECTING YOUR INFORMATION

If any information you have provided to us needs correcting or amending, please contact us by writing to us by email using the contact details below.

If you do, we will take reasonable steps to check its accuracy and correct it.

 

RESTRICTING USE OF YOUR INFORMATION

You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.

There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.

We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted.

If you want to object to how we use your data, or ask us to delete it or restrict how we use it, please contact us at the address below.

 

PORTING YOUR INFORMATION

From 25 May 2018 you will have the right to get your personal information from us in a format that can be easily reused. You can also ask us to pass on your personal information in this format to other organisations.

This is called the ‘right to portability’.

If you wish to obtain a reusable copy of the personal information held about you for the purposes of any of the services we provide to you please contact us on the email address below.

 

CHANGES TO OUR PRIVACY NOTICE

Any changes we may make to this Notice in the future will be posted on this page and, where appropriate, notified to you by email or highlighted to you when you visit one of our service websites. We recommend that you periodically review this Notice to make sure that you are aware of its content.

 

INFORMATION ABOUT THE ‘COOKIES’ USED ON THIS WEBSITE

P92 uses cookies (small text files placed on your device) and similar technologies to provide our websites and online services and to help collect data. Cookies allow us, among other things, to store your preferences and settings; enable you to sign-in; combat fraud; and analyse how our websites and online services are performing.

You have a variety of tools to control cookies, including browser controls to block and delete cookies, controls from some third-party analytics service providers to opt out of data collection and in application settings to control which cookies we will use. Your browser and other choices may impact your experiences with our products.

 

CONTACTING P92

Questions, comments and requests regarding this Notice are welcomed and should be addressed to info@p92.com

 

If you have any further queries or complaints that we are not able to answer you should contact the Data Privacy Supervisory Authority for the country in which you reside:

• United Kingdom: Information Commissioner’s Office

• Republic of Ireland: Data Protection Commissioner

• Hungary: Data Protection Commissioner’s Office

 

©2018 P92 IT Solutions Kft. All Rights Reserved.