DATA MANAGEMENT INFORMATION



  1. NAME AND CONTACT DETAILS OF THE CONTROLLER:


Company name: 2100 International Digital Agency Kft. Headquarters: 1134 Budapest Váci út 47.

Tel: +36707571122

E-mail: [email protected]


This privacy notice applies to the following websites:


https://2100labs.com

https://www.2100labs.com

www.2100labs.com

2100labs.com


  1. RULES ON DATA PROCESSING


    1. 2100 International Digital Agency Ltd. (hereinafter referred to as the "Company") informs newsletter subscribers, applicants and customers that it processes personal data in connection with registration only on the basis of the provisions of this Privacy Policy.

    2. This Privacy Notice is effective from 26.04.2021 and will remain in force until revoked.

    3. The definitions in this Privacy Notice correspond to the interpretative definitions set out in the GDPR (Regulation (EU) 2016/679 of the European Parliament and of the Council).


    1. The scope of this Privacy Notice covers:

aa) the subscription to the newsletter on the Company's website and the processing of personal data within the meaning of Article 6(1)(a) of the GDPR in connection with the sending of newsletters following the subscription.

bb) to persons requesting an offer from the Company, in the course of which personal data within the meaning of Article 6(1)(a) of the GDPR are processed.

cc) In the event of acceptance of our Company's offer, to the customers as contracting partners in the course of which personal data within the meaning of Article 6 (1) (b) GDPR are processed.

    1. The Company declares that it will take all organisational and technical measures to ensure an adequate level of protection of the personal data processed, so that the processing complies at all times with the principles of purpose limitation and proportionality. If the purpose of the processing ceases to exist or the processing is otherwise unlawful, the data will be deleted.

    2. The Company will process the personal data provided for the registration on the above websites and the request for quotation only on the basis of the prior, voluntary and explicit consent of the data subject.

    1. The purpose of this Privacy Notice is to ensure that, in any case, before collecting personal data, the Company discloses to you, as the data subject, the purposes of the processing, the legal basis for the processing and all relevant information concerning the processing and necessary for your decision.


    1. Automated decision-making, profiling: no such processing takes place.


    1. As a general rule, we do not pass on your personal data to third parties. Data may only be transferred if it is necessary for the performance of the contract or if you have given your express and voluntary consent. In exceptional cases, this may also be necessary for the legitimate protection of our legal interests.


  1. THE PROCESSING OF DATA DURING REGISTRATION


    1. The information you provide must be voluntary, explicit and unambiguous. By completing the application form and clicking on the consent box, you expressly give your voluntary consent to the processing of your data.

    2. Purpose of data processing: free analysis of your website, development advice for your website, full online service for website development.

    3. Legal basis for processing: the data subject's consent [Article 5(1)(a) of the GDPR; Article 6(1)(a) of the GDPR]

    4. Data processed: name, name, email address, website address.

    5. Data subjects: natural persons who register for the online service, free of charge, on the website.

    6. The processing is carried out electronically, by automated means.

    7. Data source: directly from the data subject

    8. Duration of processing: until the purpose is achieved, but not later than the withdrawal of consent.

    9. Our company keeps anonymous statistics on the readership of the newsletters sent out, by means of the clicks on the links in the newsletters.


  1. PROCESSING OF DATA IN THE COURSE OF A REQUEST


    1. You can request a quote from our Company for the services offered by our Company on the above websites. Acceptance of our quotation or your order will result in a contract between our Company and you.

    2. When requesting a quote, the information you provide must be voluntary, explicit and unambiguous. By completing the quotation form, you expressly give your voluntary consent to the processing of your data.

    3. Purpose of processing: sending a quote.

    4. Legal basis for processing: the data subject's consent in accordance with Article 6(1)(a) of the GDPR.

    5. Data processed: name, email address, telephone number, tax identification number.

    6. Target group: natural persons requesting a bid.

    7. The processing is carried out electronically, by automated means.

    8. Data source: directly from the data subject.

    9. Duration of data processing: until the purpose is achieved, but not longer than the duration of the offer, unless an order is placed and a contract is concluded. For contracting and tax certificates, 8 years.




  1. USE OF COOKIES


    1. We use so-called cookies on our websites. Cookies are small text files that are stored on your computer. These cookies store certain settings and data. The cookies we use do not contain personal data and cannot be directly linked to users. Please note that some cookies are set as soon as you access our websites. You can configure your browser to be notified when cookies are set, and you can individually choose to accept them or to refuse the use of cookies in certain cases or in general. If you choose to disable cookies, you may have limited access to features available on our site.

    2. Our company uses the following cookies:


      1. Required cookies

These cookies are necessary for our websites to work. These include, for example, cookies that are necessary to access the areas available to registered customers.

      1. Analytical/performance cookies

These cookies allow us to collect anonymised information about our visitors' usage patterns. We evaluate this information later, for example to improve the functioning of our websites and to send you offers that are of interest to you.

      1. Functional cookies:

We use these cookies for certain functions of our websites, such as to improve navigation on our website or to allow us to provide you with personalised and relevant information (e.g. advertisements that match your interests).

      1. Targeted advertising

These cookies record your visits to our sites, the pages you visit and the links you open. We use this information to tailor our pages and the advertisements we send to you to your interests.

      1. Third party cookies

Such cookies from some of our advertising partners help us to make our online offers and our website more interesting for you. Therefore, when you visit our sites, cookies from our advertising partners are also installed on your hard drive. Personal data cookies from our partner companies. Only pseudonymous data is collected under the user ID. This pseudonymised data is never linked to your personal data.


  1. USE OF COUNTER PIXELS


It is important for us to know how often and from which regions our website is visited. We therefore place so-called counting pixels (small graphics) on our websites. IP addresses are only recorded in an abbreviated form, from which the identity of the visitor can in no way be identified. The identity of the visitor therefore remains anonymous to us.


  1. RETARGETING AND REMARKETING:


Our websites remember you and link to other websites to target you with targeted ads. This is to inform users of our services that are the same or similar to those they have previously viewed and that may be of interest to them, by following the procedure below:


    1. Google Re/Marketing Services:


The bidder uses the remarketing or "similar target groups function of Google Inc. ("Google") on the website.


Information about Google Remarketing and Google's privacy policy can be found at http://www.google.com/privacy/ads/.


Google stores a small number of files in the browsers of visitors to the site, and the number is used to record visits to the site, but this is anonymised data. It is important to note that no personal data of visitors to the website is recorded!


Google uses so-called cookies to analyse the use of the website, which is the basis for compiling interest-based advertising ads.


You can permanently disable the use of cookies on Google by downloading and installing the plug-in offered at the following link: https://www.google.com/settings/ads/plugin.


You can also opt-out of third-party cookies by visiting the Network Advertising Initiative opt-out page at http://www.networkadvertising.org/choices/ and following the opt-out instructions there.


    1. Google Double Click Cookie

Our websites also use a so-called DoubleClick-Cookie, which allows your browser to recognise you when you visit other websites. The information generated by the cookie about your visit to this website is transmitted to a Google server in the USA and stored there. As a general rule, the IP address is anonymised by shortening the IP address before it is transmitted to EU Member States and countries that are party to the EC Treaty. The IP address sent from your browser in the context of Google Analytics will not be linked to other data by Google!


For more information about Google's privacy practices, please visit:

http://www.google.com/privacy/ads/.


    1. Google Tag Manager


The purpose of using Google Tag Manager is to manage advertising based on user information. It is important to note that Tag Manager is a cookie-free tool, it does not record domain or personal data!


If you wish to opt-out of being recorded in Google Marketing Services, you can do

so by using Google's opt-in and opt-out options:

http://www.google.com/ads/preferences


    1. Using Google Adwords Conversion Tracking


Our websites use the "Google Adwords" online advertising program and the Conversation Tracking function within Google Adwords. Google Conversion Tracking is a service of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; "Google").


The information collected through conversion tracking cookies is used to provide conversion statistics for AdWords customers who have opted in to the conversion tracking feature. This is done by providing customers with information on the total number of users who clicked on the ad and thus reached the page with the Conversion Tracking Tag. These cookies expire after 30 days, they do not contain any personal data and are therefore not suitable for identifying the user!


However, it does not receive any information that would allow the user to be identified.

If

you do not wish to participate in tracking, you can disable the use of cookies by disabling the cookie in your browser software settings (opt-out option). It will then not be included in the conversion tracking statistics. For more information about the Google Privacy Policy, please visit the following links: :http://www.google.com/policies/technologies/ads/, http://www.google.de/ policies/privacy/


    1. Facebook retargeting


We advertise our websites on Facebook (Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA) on a Facebook platform. This is done by Facebook sending a cookie when you visit a website, which enables interest-based advertising based on the pseudonymous cookie ID and the page you visit.


As a Facebook member, you can deactivate the retargeting cookie by following the link below:

https://www.facebook.com/settings/?tab=ads


Alternatively, you can configure your browser to be informed about the use of cookies and decide individually whether to accept them, or to refuse cookies in certain cases or in general. Please note that not accepting cookies may limit the use of certain features of our websites.


  1. SOCIAL NETWORKING SITES:


    1. Facebook plugins: https://fb.me/2100ws


We have incorporated plug-ins from the Facebook social networking site (Facebook Inc. 1601 Willow Road, Menlo Park, California, 94025, USA) into our websites. Facebook plug-ins are recognised by the Facebook logo or "like" button on our site. You can find an overview of Facebook plugins here: http://developers.facebook.com/docs/plugins


When you visit our pages, the plugin connects your browser directly to the Facebook server. Facebook then receives information that you have visited our site with your IP address. When you log in to your Facebook page and click on the Facebook like button, you can link content from our pages to your Facebook profile. Facebook will then associate your visit to our page with your Facebook profile.


Please note that we, as the provider of the offer, are not informed about the content of the data transmitted by Facebook and their use by Facebook.


For more information, see the Facebook Privacy Policy: http://de- en.facebook.com/policy.php


    1. Instagram plugins: https://www.instagram.com/2100_ws/

On our websites, we use the so-called social plugins ("plugins") of the online service provider Instagram, operated by Instagram LLC., 1601 Willow Road, Menlo Park, CA 94025, USA ("Instagram"). The plug-ins are identified by an Instagram logo, e.g. "Instagram camera", an overview of the plug-ins and their appearance can be found here: http://blog.instagram.com/post/36222022872/introducing-instagram-badges.


When you open one of our web pages that contains an instagram plugin, your browser connects directly to instagram servers. By this connection, Instagram receives the information that this page of our web presence has been opened from your browser, even if you do not have an Instagram profile or are not logged in to Instagram. This information (together with your IP address) is sent directly from your browser to an Instagram server in the USA, which stores it.


For information about the purpose and scope of data collection, Instagram's further processing and use of your data, as well as your rights in this regard and the settings affecting the protection of your personal data, please see the Instagram Privacy Policy: https://help.instagram.com/155833707900388/.


You can also generally disable the download of Instagram plug-ins in your browser by using Add-Ons, e.g. the "NoScript" Script-Blocker (http://noscript.net/).


  1. USE OF ANALYTICAL TOOLS:


We use web analytics services on our websites to match pages to demand and to support advertising activity.


    1. Google Analytics:


Our websites use "Google Analytics", a service provided by Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA), which measures the website usage habits of users. The service uses cookies.


Our websites anonymise IP addresses IP addresses are abbreviated in EU Member States and EEC Member States. Thanks to the abbreviation, your IP address can no longer be linked to a person! In the context of the data processing agreement between the website operator and Google Inc., Google Inc. will evaluate the use of the website on the basis of the data collected and provide services related to website activity and internet usage.


You can turn off the storage of cookies on your computer by setting your browser accordingly. Please note that if your browser does not allow cookies, there is no guarantee that you will have unrestricted access to all the functions of our websites.

You can also use a browser Plugin to prevent the information collected by cookies (including your IP address) from being sent to and used by Google Inc..You can access the Plugin at https://tools.google.com/dlpage/gaoptout?hl=de



further information on the use ofAGoogleInc.by usersplease visit:

https://support.google.com/analytics/answer/6004245?hl=de


    1. Hotjar


Our websites use analytics software provided by Hotjar, an analytics company owned by Hotjar Ltd ("Hotjar") (http://www.hotjar.com, 3 Lyons Range, 20 Bisazza Street, Sliema SLM 1640, Malta, Europe). With Hotjar, it is possible to measure and analyse the user behaviour (clicks, mouse movements, scrolling, etc.) of visitors to the website. In doing so, the information generated by the "tracking code" and the "cookie" about your visit to our websites is sent in pseudonymised or anonymised form to the Hotjar server where it is stored. Important: Hotjar does not and cannot process personal data!


You can prevent the recording of your data by Hotjar by clicking on the following link and following the instructions provided: https://www.hotjar.com/opt-out


  1. DATA PROCESSORS


    1. Data processor: the Company uses the services of data processors for the present data processing:



      1. Hosting Provider : DigitalOcean, 101 6th Ave, New York, NY 10013

[email protected]



      1. Analytics software: Google Analytics, HOTJAR, Facebook pixel



  1. ENFORCEMENT OF DATA SUBJECTS' RIGHTS


Under the GDPR, you have the following rights:


    1. Right of access to personal data (Article 15 GDPR).


Based on this right, you have the right to request, free of charge, information about your personal data held by our Company.


    1. Right to rectification of personal data (Article 16 GDPR).

Based on this right, you may request our Company to correct inaccurate personal data concerning you or to complete incomplete data.


    1. Right to erasure (Article 17 GDPR).


Based on this right, you may request our Company to delete your personal data for the following reasons:



    1. Right to restriction of processing (Article 18 GDPR).


On the basis of this right, you have the right to request that we restrict processing if one of the following conditions is met:






If processing is restricted on the basis of the above, such personal data, except for storage, may only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for important public interests of the Union or of a Member State. You will be informed in advance of the lifting of any restriction on processing.


    1. The right to data portability (Article 20 GDPR).


Based on this right, you have the right to have the personal information about you that you

provide to us disaggregated, commonly used, machine-readable and you have the right to transfer these data to another controller without our hindrance if:


  1. the processing is based on consent within the meaning of Article 6(1)(a) or Article 9(2)(a) or on a contract within the meaning of Article 6(1)(b); and


  1. the processing is carried out by automated means.


In exercising the right to data portability as set out above, you have the right to request, where technically feasible, the direct transfer of personal data between controllers.


    1. The right to object (Article 21 GDPR).


Based on this right, you have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data based on Article 6(1)(e) or (f) of the GDPR, including profiling based on those provisions. In such a case, our Company may no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.


Where personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such purposes, including profiling, where it is related to direct marketing. If you object to the processing of your personal data for direct marketing purposes, your personal data may no longer be processed for those purposes.


    1. The right to withdraw consent (Article 6 GDPR):


Where you have given your voluntary consent to the processing of your data pursuant to Article 6(1)(a) of the GDPR, you may withdraw your consent at any time with effect for the future. You will find the unsubscribe link at the bottom of the newsletters.


    1. Right to complain


If you believe that your data is being processed in breach of data protection law or your data protection rights have been infringed in any way, you can complain to the supervisory authority:


National Authority for Data Protection and Freedom of Information 1055 Budapest, Falk Miksa u.9.-11.

e-mail: [email protected] Phone: +36 (1) 391-1400

Website: www.naih.hu



Budapest, 24/04/ 2021



2100 International Digital Agency Kft.

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