1. Introduction

Ferenc Kozma and Ferencné Kozma, as the owners of the challenge4survivors.hu website,  hereby inform you about their practice in using personal data related to the use of challenge4survivors website (hereinafter: Website) and the services provided on the website, and the organizational and technical measures taken to protect the data, as well as its rights related to data management and the
possibilities ofenforcing its rights.

In the course of this prospectus and the processing of data, we act in accordance with the applicable legislation in force, in particular
:

• EU Regulation 2016/679 (General Data Protection Regulation, hereinafter: the Regulation)
• Act CXII of 2011 on the right to information self-determination and freedom of information. Act (Ektv.)
• Act CVIII of 2001 on certain issues of electronic commerce services and information society services. law
• Act XLVIII of 2008 on the basic conditions and certain restrictions of economic advertising activity. law.

2. Basic
concepts and interpretations of personal data

personal data :
any information relating to an identified or identifiable natural person („data subject”); identifies a natural person who, directly or indirectly, in particular by an identifier such as name, number, location, online identifier or one or more factors relating to the natural person’s physical, physiological, genetic, mental, economic, cultural or social identity identified;

„data management” means
any operation or set of operations on personal data or files, whether automated or non-automated, such as collecting, recording, organizing, segmenting, storing, transforming or altering, retrieving, viewing, using, transmitting, distributing or otherwise making available by batch,
coordination or interconnection, restriction, deletion or destruction;

„controller” means
the natural or legal person, public authority, agency or any 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 the processing are determined by Union or Member State law, the controller or the specific criteria for the designation of the controller may also be determined by Union or Member State law;

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

privacy incidents :
the security of injury to personal data transmitted, stored or otherwise treated against accidental or unlawful
destruction, loss, alteration, unauthorized disclosure of, or unauthorized access to,
results

3. The data controller

The data controller: Ferenc Kozma private person (hereinafter: Registered office of the data controller: 2112 Veresegyház, Viczián u. 34 .. phone: + 36202390227-e-mail address:)

4. Principles of data management

The processing of personal data must be carried out lawfully and fairly and in a way that is transparent to the data subject.

Personal collection may only take place for a specific purpose, for a specific, clear and legitimate purpose. The data
processed must be appropriate and relevant to the purpose of the processing and must be limited to what is necessary.

The data processed must be accurate and, where necessary, kept up to date. All reasonable measures shall be taken to ensure that personal data which are inaccurate for the purposes of data processing are erased or rectified without delay.

Personal data must be stored in a form which
permits identification of data subjects for no longer than is necessary for the purposes for which the data were processed .

The processing of personal data must be carried out in such a way as to ensure the adequate security of the personal data, including protection against unauthorized or unlawful processing, accidental loss, destruction or damage, by means of appropriate technical or organizational measures.

5. Stakeholders

Persons visiting the Website operated by the Data Controller, those subscribing to the newsletter, those who like the Website on Facebook and subscribers are affected by data management.

6. Data processed:

6.1. Newsletter on
the Website in   case of subscription

the Data Controller manages the following data of the relevant subscriber:  name, e-mail address, IP address .

6.2. Managed data of visitors to
the Website  :

when using the website, different types of cookies may be installed on the
device of the visitor concerned (see point 11 for details on cookies). Each cookie can store the visitor’s IP address
or part of it, the type of browser, information about the use of the website (time of visit,
pages visited , duration of the session, number of clicks).

If a visitor of the Website marks it as “favorite” using the Facebook plugin placed on the website, or if he / she subscribes to the Facebook page of the Website, the Data Controller manages the data (name, profile picture) of the affected Facebook profile.

7. Purpose of data management:

7.1. In   case of newsletter subscription

the purpose of data management is to provide the newsletter sending service, including information on discounts, the Products and
services of the Data Controller .

7.2. In case of interest sent through the Website

the purpose of data management is to inform the data subject about the service of interest to him or her.

7.3. The Website uses cookies for its intended purpose

the information in point 11.

When using the Facebook plugin placed on the Website, the purpose of data management is to ensure that the data subject can be marked as a favorite and subscribed.

8. Legal basis for data management

8.1.  In case of newsletter service

the legal basis for the processing is the voluntary consent of the data subject (Article 6 (1) (a) of the Regulation). To
manage the e-mail address and the IP address , the Data Controller uses the Ektv. 13 / A. § as they are technically necessary for the provision of the service
.

8.2. In  case of interest sent through the  Website

In the case of data provided, the legal basis for the processing is the voluntary consent of the data subject (Article 6 (1) (a) of the Regulation).

8.3. In the  case of cookies installed on the computer of the affected visitor via the Website, the  legal basis of data management is:

• In the case of cookies that are technically necessary for the operation of the Website, the use of the services and functions provided on the Website: Ektv. 13 / A. §., Decree Article 6 (1). b).
• In the case of cookies that serve a convenience or marketing function, or to analyze the use of the website, to improve its performance: the voluntary consent of the data subject (Article 6 (1) (a) of the Regulation).

In connection with the use of the Facebook plugin, the legal basis for data management is the Ektv. 13 / A. § and Article 6 (1) of the Regulation. (a)
.

8.7. The Data Controller may also process the data of the data subject if this is necessary for the enforcement of its legitimate interests,

unless those interests take precedence over the interests or fundamental rights and freedoms of the data subject which require the protection of personal data. (Article 6 (1) (f) of the Regulation). This may be the case if the Data Controller has a claim against the data subject (eg an unpaid account).

9. Duration of data management

9.1. The  newsletter service  in

managed data is managed by the Data Controller until the data subject unsubscribes from the newsletter service or otherwise requests the deletion of his or her data.

9.2. Interest sent through the  Website 

The Data Controller handles the data processed in the case of the data subject until the data subject is provided with the requested information. The Data Controller will automatically delete the data no later than 1 year thereafter, unless the data subject has contacted the Data Controller again. In the event of a repeated request, the Data Controller shall process the personal data no later than for 1 year from the fulfillment of the information.

9.3. See section 11 for information on the lifespan of cookies.

In case of marking the Website as “favorite” on Facebook, or in case of subscription, the data management
lasts until the data subject’s request for cancellation (unsubscribe, unmarking).

10. Scope of accesses (recipients) to the data:

The personal data may be accessed by the authorized employees of the Data Controller, their authorized representatives, who need access to personal data in order to perform their duties, as well as the Chief Executive Officer and the Deputy Data Controller.

We transfer personal data to third parties only for the purpose of data processing. The data processor may process the personal data obtained only in accordance with the provisions of the data controller, may not perform data processing for its own purposes, and is obliged to store and preserve the personal data in accordance with the provisions of the data controller.

10.1. The  newsletter service is provided by  the Data Controller through the newsletter management software.

The operator of the newsletter management software processes the personal data of the data subjects (name, e-mail, IP address) as a data processor during the provision of the service. The data controller uses the following data processor during the newsletter service:

• The Rocket Science Group, LLC (MailcNév: Active Campaign
  honlap: https://www.activecampaign.com
  email: info@activecampaign.com
  telefon: (773) 360-2270

10.2. The Data Controller to analyze the use of the website

uses Google Analytics, a service operated by Google, Inc., which collects information and generates a statistical report on website usage without uniquely identifying visitors. This service uses cookies,
which are installed on the affected person’s computer. The information collected by cookies about the use of the website is
stored on Google LLC as a data processing server (located at 1600 Amphitheater Parkway, Mountain View, CA 94043, USA., Phone: 650-253-0000, e-mail: data-protection -office@google.com)

Google LLC is listed on the Privacy Shiled Framework.

For data management related to the use of the Facebook plugin, the data processor is Facebook Inc., located at 1 Hacker Way, Menlo Park, California 94025, USA, phone: +1 650-543-4800, e-mail: privacyshield@support.facebook.com

Facebook Inc. is included in the compliance list maintained under the Privacy Shiled Framework Agreement.

11. Cookies used on the Website

A cookie is a set of textual information that the Website transmits to a small file on the hard drive of the affected user’s computer or mobile device. A cookie typically contains the name of the computer domain from which the cookie came, as well as the cookie expiration date and a randomly generated number (value).

The cookies used by the Website serve several purposes. Some cookies are technically necessary for the operation of the site, as without them the site and its basic functions would not be usable. Some cookies make it easier to use the Website by remembering the visitor’s actions and personal settings (such as language, font size and other custom settings related to the display of the website) for a specified period of time, so that the visitor does not have to re-enter them each time they visit. navigates from one page to another. There are cookies that are used to increase the performance of the Website by collecting information and reporting statistics on the use of the Website. Some cookies are for advertising purposes by

Cookies can be divided into the following categories:

• Session cookies: temporary cookies that remain in the cookie file of the affected browser’s Internet browser until you leave the Website and are automatically deleted at the end of the session or by closing the browser. These are necessary for browsing the website and using the functions, among other things, allowing the visitor to memorize the actions performed by the site, function or service.
• Usage Cookies: The purpose of the Website is to remind the user of the settings and how the user uses the Website. This is so that you do not have to enter them again on your next visit. Without the data contained in the cookies that store your preferences, our website will be able to operate less smoothly.
• Performance statistics cookies: cookies that are used by the Data Controller to collect information about how visitors use the Website, so which page they viewed, what session they started there, and how long they viewed the page, how long it took the session. The Data Controller uses Google Analytics, which uses cookies to collect information and generate a statistical report on the use of the website without uniquely identifying visitors. The purpose of using these cookies is to give the Data Controller an idea of the use of the Website and to be able to further develop and provide a user-friendly experience for visitors.
• Advertising, marketing cookies: these cookies can be used to display interesting advertisements to the affected visitor on the Website or to increase the effectiveness of your own marketing. For example, cookies in this feature can remember a visitor’s recent searches, past interactions with individual advertisers ‘ads or search results, as well as visits to advertisers’ websites, and help analyze relevant data to serve relevant ads.

Properties of cookies used

Cookie type	Cookie name	Purpose of cookie	Cookie duration
Use	__distillery	Play Wistia videos	1 év
Use	__smToken	Image sharing and liking functionality	1 év
Use	__smVID	Image sharing and liking functionality	1 év
Performance	__utmc	Visitor statistics (anonymous)	30 perc
Performance	__utmx	Visitor statistics (anonymous)	6 months
Performance	__utmxx	Visitor statistics (anonymous)	6 months
Performance	_ga	Visitor statistics (anonymous)	2 év
Performance	_gat	Visitor statistics (anonymous)	1 perc
Performance	_gid	Visitor statistics (anonymous)	24 hours
Marketing	ac_enable_tracking	Send unique offers to our newsletter subscribers	1 month
Session	cookie_nitoce_accepted	Accept cookie settings	1 month
Marketing	tu_campaign_impression_	Newsletter subscription tracking	1 év
Marketing	tve_leads_unique	Newsletter subscription tracking	2 days
Session	wp-settings-	Customize page	1 év
Session	wp-settings-time-	Customize page	1 év
Session	wordpress_	For logged in users	use during
Session	wordpress_logged_in_	For logged in users	use during
Session	wordpress_test_	For logged in users	use during

If the visitor concerned has consented to the use of cookies on the Website, he / she still has the opportunity to change the settings of the cookies or to change the settings. delete cookies from your device. Web browsers allow you to change cookie settings or delete cookies.

You can read more detailed information about changing cookie settings and deleting cookies in
different types of browsers at the following links :

• Google Chrome
• Firefox
• Internet Explorer
• Opera (English)

12. Security of personal data

During the handling and storage of data, the Data Controller ensures the security of the managed and stored data, protection from access by unauthorized persons and protection against unauthorized modification and alteration by measures in accordance with the state of the art (eg firewall).

The Data Controller provides the required level of protection during data management.

13. Rights of data subjects related to data management, legal remedies

You, as a data subject, may request from the Data Controller access to, rectification, erasure or restriction of the processing of personal data concerning you and may object to the processing of such personal data.

You have the right to receive feedback from the Data Controller as to whether your personal data is being processed.
If such data processing is in progress, you have the right to be informed about the purposes of the
data processing, the categories of personal data concerned , the categories of recipients of the data, the planned
period of storage (if this is not possible, the criteria for determining this period).

The Data Controller will provide you with a copy of the personal data processed. For additional copies, the Data Controller
may charge a reasonable fee based on administrative costs. If you have submitted your application electronically, the information must be provided in a widely used electronic format, unless you request otherwise.

Personal data must be deleted if:

• personal data are no longer required for the purpose for which they were collected or otherwise processed;
• the data subject withdraws his or her consent on which the processing is based and there is no other legal basis for the processing;
• the data subject objects to the data processing and there is no overriding legitimate reason for the data processing or the data subject
  objects to the data processing pursuant to Article 21 (2) of the Regulation;
• personal data have been processed unlawfully;
• personal data must be deleted in order to fulfill a legal obligation under Union or Member State law applicable to the controller;
• personal data was collected in connection with the provision of information society services directly to children.

You may request that the Data Controller restrict the data processing if one of the following is met:

• you dispute the accuracy of the personal data, in which case the restriction applies to the period of time that allows the controller to verify the accuracy of the personal data;
• the data processing is illegal and you oppose the deletion of the data and instead ask for a restriction on its use;
• the controller no longer needs the personal data for the purpose of data processing, but the data subject requests them in
  order to make, enforce or protect legal claims; obsession
• you objected to the data processing; in that case, the restriction shall apply for as long as it is established whether the legitimate reasons of the controller take precedence over the legitimate reasons of the data subject.

You have the right to receive the personal data about you provided to the Data Controller in a structured,
widely used, machine-readable format, and you have the right to transfer this data to another data controller.

You have the right to object to the processing of your personal data at any time for reasons related to your own situation, if the processing is based on:

• the processing is necessary for the performance of a task carried out in the public interest or in the exercise of a public authority conferred on the controller;
• the processing is necessary to safeguard the legitimate interests of the controller or of a third party.

In that case, the controller may not further process the personal data unless the controller demonstrates that the processing is justified by compelling legitimate reasons which take precedence over the interests, rights and freedoms of the data subject or which are necessary to bring, assert or defend legal claims. related.

Where personal data are processed for the purpose of direct business acquisition, the data subject shall have the right to object at any time to the processing of personal data concerning him or her for that purpose, including profiling, in so far as it relates to direct business acquisition.

If the privacy incident is likely to pose a high risk to your rights and freedoms, the Data Controller will inform you of the privacy incident without delay.

You can submit your request to the Data Controller in the above cases. The Data Controller will inform you without undue delay, but within 1 month of receipt of the request, of the action taken on the request.

If necessary, taking into account the complexity of the application and the number of applications, this deadline may be extended by a further 2 months. The Data Controller will inform you of the extension of the deadline within 1 month from the receipt of the request, indicating the reasons for the delay. If you have submitted your application electronically, the information should, if possible, be provided electronically, unless you request otherwise.

If the Data Controller does not take action on your request, it will inform you of the reasons for the failure to take action without delay, but no later than within 1 month from the receipt of the request. In the event of non-action or in connection with the action taken, you may lodge a complaint with the National Data Protection and Freedom of Information Authority and exercise your right of judicial redress.

You have the right to  initiate proceedings before the  National Data Protection and Freedom of Information Authority if there has been or is an imminent threat of an infringement of the processing of personal data. Contact details of the Authority: postal address: 1530 Budapest, Pf .: 5., telephone number: +36 (1) 391-1400, e-mail address:
ugyfelszolgalat@naih.hu, website:  http://naih.hu .

If your rights are violated, you can take legal action against the Data Controller. The trial falls within the jurisdiction of the tribunal. The lawsuit may, at your option, be brought before the court of your domicile or residence.

A party who does not otherwise have legal capacity to sue may also be a party to a lawsuit. The Authority may
intervene in the proceedings in order for the person concerned to succeed .

If you have any complaints or problems with the processing of your personal data, please contact the Data Controller before initiating any of the above procedures.