Roobycon Consulting Ltd. (Seat: Kemp House 152 City Road EC1V 2NX London; company registry nr: 9004173; Taxation ID: 51568 14547) shall be considered a data processor regarding the personal data collected and accepted to the Company, and shall execute its data processing activities according to the following principles.
Roobycon Consulting Ltd shall always comply the relevant legal regulations of Hungary as well as the GDPR-act (General Data Protection Regulation (EU) 2016/679) when executing its data processing activities.
Roobycon Consulting Ltd is fully dedicated to protect the personal data of its partners and employees; we keep it as a priority to respect our clients’ right of informational self-determination.
In this policy, the data-protection terms shall have the following meaning according to the relevant legal regulation:
- data subject shall mean any identified or identifiable natural person
- controller: means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data
- ‘processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller
- ‘third party’ means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;
- data protection authority: Nemzeti Adatvédelmi és Információszabadság Hatóság (email@example.com) naih.hu 1125 Budapest, Szilágyi Erzsébet fasor 22/c., +36 1 391-1400).
Other important definitions:
- ‘personal data’ means any information relating to a data subject
- an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
- ‘data processing’ shall mean any operation or set of operations performed on personal data or on sets of personal data (such as: collecting, recording, registering, classifying, storing, modifying, using, querying, transferring, disclosing, synchronising, connecting, blocking, deleting and destructing)
- ‘restriction of processing’ means the marking of stored personal data with the aim of limiting their processing in the future;
- ‘the data subject’s consent’ shall mean any freely and expressly given specific and detailed and informed and undoubtful indication of the will of the data subject by which he signifies his agreement to personal data relating him being processed.
- ‘personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;
III. Legal basis of the data processing, the rights of the data subject
The data subject is entitled to receive a feedback from the data controller whether his personal data is processed, and if so, the data subject is entitled to gain access to the processed personal data and the following information.
- The data subject is entitled to the correction of the data by the controller if the personal data is incorrect.
- With regard to the goal of the data processing the data subject is entitled to have his personal data amended by the controller if the data is incomplete.
- The subject is entitled for the deletion of his personal data at his request without hesitation, and the controller is obliged to comply with the request and delete the personal data of such data subject without unreasonable delay if the conditions of the deletion are fulfilled.
The data subject is entitled to file a complaint against the business purpose processing of his personal data.
The data subject is entitled for the restricted data processing by the controller if (1) the data subject disputes the appropriateness of the data, (2) the data processing is against the law, (3) the data subject claims the data for exercising legal claims but the goal of the data processing no longer exists, (4) if the data subject filed a claim against the data processing.
IV. Data protection
The computer systems and other data storage systems of Roobycon Consulting Ltd are situated both at the registered seat of the company at server computers and at cloud-based services.
Roobycon Consulting Ltd carefully chooses the information technology tools for processing personal data concerning its services in a way that the processed data shall only be available for authorized personnel, the authentication of such data is secured, the data is securely authenticated, the persistence of the data is verifiable, and the data is protected against unauthorized access.
Roobycon Consulting Ltd. protects the personal data against e.g. unauthorized disclosure and access, alteration, transfer, making available to public, accidental or unlawful deletion or destruction, and becoming inaccessible because of change of technology by applying appropriate measures.
However, we hereby inform the data subjects that electronic messages forwarded on the Internet are vulnerable regardless of the protocol (e-mail, web, ftp etc.) against network threats which lead to fraudulent activities, debating contracts, or revealing or altering information. Roobycon Consulting Ltd. performs every and all reasonable protective measure to protect the processed data from these threats.
It is the Managing director of Roobycon Consulting Ltd who is in the first place entitled to know the personal data processed by our company; the processed personal data may only be transferred to any third person if the transfer has a reasonable and lawful cause (such as exercising outstanding claims against the data subject), or in case the data transfer is based on a legal obligation, or if the data subject expressly and gives its prior consent to the data transfer.
V. Miscellaneous provisions
Controller has 30 days to provide information about the processed personal data, to delete or to correct the personal data. In case the controller does not fulfil such request of the data subject then he is obliged to reason the decision in writing and send the reasoning to the data subject in 30 days.
In case a possible data breach in Roobycon Consulting Ltd’s system possibly means high risk regarding the rights and freedoms of natural persons then the controller becomes obliged to inform the data subjects about the data breach without unreasonable delay
Our company does not check the validity of the data that is provided by the data subjects. The data subjects as data providers are solely responsible and liable for the appropriateness and validity of the provided data. All data subjects take responsibility when providing an e-mail address that they are the only persons who take services from that e-mail address.
We hereby inform our clients that law enforcement, data protection authority and (based on legal regulations) other bodies and authorities may lawfully request data from Roobycon Consulting Ltd.
During the visit at our website, roobycon.com the Service Provider may send one or more cookies – small files containing a series of characters – to the computer of the User that makes the web browser of the User individually identifiable. These cookies are sent only if the website is visited, and by these files we store no more data than the fact that the website was visited and the time of the visit.
The use of these so called cookie files if the following: third party service providers like web browsers use these cookies to store the information that a User has visited the website of Roobycon Consulting Ltd. before. May the User not wish that Google or other service providers store this data with the purpose and method described above, then the User shall download and activate a blocker application to his web browser.
Roobycon Consulting Ltd does not employ data processors.
In case You have any requests, questions or problems regarding our company, data processing or services, please do not hesitate to contact us: You may find our contact details at our website roobycon.com.