Data protection statement

Nitro Communications Ltd. and Lead Generation Ltd. respect your right to the protection of your personal data. This page summarizes what information we may collect, how we may use it, the tools we may use, and your privacy and data protection enforcement choices.

Nitro Communications Kft. (hereinafter referred to as "Nitro"; registered office: 1027 Budapest, Tölgyfa utca 28. 2nd floor) and Lead Generation Kft. (hereinafter referred to as "Lead"; registered office: 1027 Budapest, Tölgyfa utca 28. 2nd floor) as joint controllers of personal data are subject to the provisions of the Hungarian Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information (hereinafter referred to as "Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information"). and 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 Regulation (EC) No 95/46/EC (General Data Protection Regulation), i.e. the GDPR, in relation to your personal data.

1. Scope and acceptance of this privacy statement

By using the websites operated by Nitro and Lead or by providing your personal data to Nitro and Lead, you consent to the collection and use of your personal data by Nitro and Lead as joint controllers as set out in this privacy statement (the "Statement").

If your personal data is not processed by Nitro and Lead as a joint controller, you will be expressly informed of this and, if you have given your consent on the basis of this Privacy Statement, a separate processing operation will be established.

You will also be expressly informed by Nitro and Lead if they are not acting in their capacity as data controllers, but as processors acting on behalf of third party or parties, and are contacting you and carrying out the processing operation(s) required by the controller(s).

If you do not consent to the collection and use of your personal data as described in this Privacy Notice, please do not use the Nitro and Lead websites or contact and other forms, or provide any personal data to them.

This privacy statement applies to the storage and processing of data voluntarily provided by visitors to this website. Personal data will be processed by the operator in accordance with the following principles:

1. personal data may only be processed for specific purposes, for the exercise of rights and the performance of obligations. The data must be processed in accordance with the purpose of the processing at all stages, and the collection and processing of the data must be fair and lawful
2. only personal data which is necessary for the purpose of the processing and adequate for the purpose of the processing may be processed. Personal data may only be processed to the extent and for the duration necessary to achieve the purpose
3. the personal data shall retain this quality during the processing for as long as the relationship with the data subject can be re-established. The link with the data subject may be re-established if the controller has the technical conditions necessary for such re-establishment
4. the processing must ensure the accuracy, completeness and, where necessary for the purposes of the processing, the up-to-dateness of the data and that the data subject can be identified only for the time necessary for the purposes of the processing
    

2. Concepts

In this Privacy Statement, we use the following terms, including but not limited to the following data protection terms.

personal data: any specific data relating to an identified or identifiable natural person [data subject] and any inference that can be drawn from that data relating to that data subject. Personal data shall retain this quality during processing for as long as its link with the data subject can be re-established. The link with the data subject may be re-established if the controller has the technical conditions necessary for such re-establishment.

data subject/contacted person: any natural person identified or otherwise identifiable, directly or indirectly, on the basis of specific personal data. In particular, a person is identifiable if he or she can be identified, directly or indirectly, by name, an identifier or one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity.

processing: any operation which is performed on data, regardless of the procedure used, such as collection, recording, recording, organisation, storage, alteration, use, consultation, retrieval, disclosure, alignment or combination, blocking, erasure or destruction of data, prevention of their further use, taking of photographs, audio or video recordings, or recording of physical characteristics which can be used to identify a person (fingerprints, palm prints, DNA samples, iris scans, etc.).

data controller: the person or entity that determines the purposes for which the data are processed, takes and implements the decisions concerning the processing (including the means used) or has the processing carried out by a processor on its behalf.

processing: the performance of technical tasks related to data processing operations (irrespective of the method and means used to carry out the operations and the place of application).

'processor' means the person or entity that carries out the processing of data on the basis of a contract with the controller, including a contract entered into pursuant to a legal provision.

'transfer' means making data available and accessible to third parties.

joint controllers: where the purposes and means of processing are determined jointly by two or more controllers, they are considered to be joint controllers.

3. Our policy on the collection, use and transfer of personal data

Nitro and Lead will comply with applicable legal requirements, restrictions and ethical standards when collecting and processing personal data.

The data controllers undertake to:

• Inform data subjects of their data management practices in a timely manner and as required,
• collect, process, use or transfer personal data only with the consent of the data subject. The nature of the consent required depends on the sensitivity of the information, the legal basis for the processing, the applicable legal requirements, the purposes and duration of the use, third parties and technologies. Depending on the above, consent may be either explicit or implicit.
  Personal data is collected, stored and used only for specific purposes. The information collected is always adequate, relevant and appropriate for the purpose for which it is collected.
• its data processing and management practices are always for the purposes for which the personal data were originally collected and to which the data subject consented prior to the collection or subsequently extended his or her consent.
• take reasonable steps, having regard to the purposes for which the personal data are collected, to ensure that the personal data are complete, accurate, up to date and reliable to the extent necessary for those purposes.
• use your personal data for promotional purposes only with your consent and give you the opportunity to opt-out of such communications.
• take reasonable and prudent steps to ensure the protection of the data subject's personal data, including where it is transferred to third parties. No data will be transferred to third parties without the prior explicit consent of the data subject.