Privacy policy

JOINT VENTURE ASSOCIATION
FULL DATA PROCESSING POLICY

This full Data Processing Policy (the ‘Policy’) describes in detail the terms and conditions relating to the processing of the personal data of the natural person members of the Joint Venture Association, the member’s contact persons and website users. The Policy is divided under the following titles:

1. Who is the data controller and who is the subject of data processing?
2. Why do we process your personal data?
3. What personal data are processed by the JVSZ?
4. What is our legal basis for processing personal data?
5. Legitimate interest of the JVSZ in the processing of personal data
6. Who have access to your personal data?
7. Data transmission abroad
8. Information about cookies
9. What rights are you entitled to?
10. Contacting the JVSZ

1. Who is the data controller and who is the subject of data processing?

This full Data Processing Policy (the ‘Policy’) extends to the private person members of the Joint Venture Association (1051 Budapest, Szent István tér 11/b, Hungary, the ‘JVSZ’, ‘Association’ or ‘we’), the private person contact persons and senior officers of our members (collectively the ‘contact persons’), and the users of the websites of the JVSZ and people who indicate their intent to participate in the events of the JVSZ. The data relating to contact persons are called ‘personal data’. The JVSZ acts as the responsible data controller of your personal data.
The scope of this Policy extends to your data processed on the website (www.jointventure.hu and www.jvsz.hu ), Facebook page (https://hu-hu.facebook.com/jointventureszovetseg/) and LinkedIn page (https://www.linkedin.com/company/jointventureszovetseg) of the JVSZ.

2. Why do we process your personal data?

We process your personal data for the following purposes:

(i) to fulfil requests and to respond to inquiries submitted on the websites www.jointventure.hu and www.jvsz.hu and to the email addresses jvsz@jointventure.hu and event@jointventure.hu of the JVSZ and to our personal email addresses;
(ii) to exercise the rights and to fulfil the obligations arising from membership with the JVSZ;
(iii) to liaise with you in order to promote and monitor your existing membership;
(iv) to send out newsletters;
(v) to enable you to register and indicate your intent to participate in events;
(vi) to enable you to participate in professional and legislative consultations.

If you are our member or a member’s contact person, we process only information about you, which is necessary for you to be able to exercise your rights and to fulfil your obligations arising from your membership with the Association, and in order to liaise with you and/or your employer (as our member), which is aimed at promoting and monitoring our membership relationship. We typically process data about you which relate to your name, position and contact details, such as email addresses and phone numbers, and will not record data or retain them about you in any other way, which can be considered ‘special data’. We use only data in connection with you and for a purpose that can be considered common in respect of our membership relationship with you and your employer, so regular liaison relates to the programmes and events of the Association and news about the Association, including the provision of information and invitation to certain events or general information about the JVSZ.
If you are not our member yet and, being interested, you contacted us in writing, in person or virtually as a visitor to our website, the purpose of data processing is to liaise with you and to provide information regularly to you primarily, at your option, by sending you email newsletters or contacting you by telephone or post.

3. What personal data are processed by the JVSZ?

Personal data may come directly from you, our legal entity members, directly from the member’s contact persons or other public sources (such as the companies register). Such personal data can be included in the following wider categories:

  • personal identification data, such as name; address, and Facebook and LinkedIn usernames;
  • data required for applying a discount membership fee: age and birthday (voluntary);
  • contact details, such as address, email address and phone number; selected communication channels;
  • data relating to activities, title and position;
  • membership details, such as the date of entry, the fulfilment of payment obligations and positions, if any, held in the Association;
  • banking data, such as bank account number, tax number and payment/invoicing data;
  • opinion data: your position in matters related to the Association or legislative consultations;
  • communication data, such as the contents of emails, letters and contract and other business documents;
  • IT data: IP address of the computers of visitors to our website, the operating system, the browser type, the address of the visited site and the duration of the visit.

When we request that you provide personal data, we mark certain data as mandatory or necessary (*), since such data are necessary for us to be able to provide our services to you. If you decide that you do not provide these data to us, it is possible that we cannot accept you as a member or cannot provide you certain services.

4. What is our legal basis for processing personal data?

We rely on various legal bases in order to process your personal data:

  • Contract: If you are a visitor to our website or webpage, the processing of your personal data is based on Section 13/A of the Electronic Trade Act and Article 6(1)(b) of the GDPR. If you are a private person member of our Association, the legal basis for processing your personal data is usually Article 6(1)(b) of the GDPR (i.e. data processing is required for performing the contract (membership relationship) with us at your request). Data processing by us is also based on a contract if you register for our event.
  • Legitimate interest: Data processing is also based on the legitimate interest of the JVSZ to facilitate continuous liaison between you and the JVSZ in order to promote and monitor the membership relationship between you (your employer) and the JVSZ (on the basis of Article 6(1)(f) of the GDPR). Certain data processing relating to the security of our website is based on legitimate interest. The legitimate interests of the JVSZ will be described in the following section.
  • Consent: In certain cases, such as sending out newsletters and information brochures, we request your consent to data processing (on the basis of Article 6(1)(a) of the GDPR);
  • Legal obligation: processing your data may be mandatory for taxation and accounting reasons or on the basis of an inquiry by the authorities or the court (on the basis of Article 6(1)(c) and (e) of the GDPR).

If you are our legal entity member, you warrant, by providing us your personal data, that (i) you have the authorisation to provide us the personal data of the contact person provided by you, (ii) you have informed the contact person about the contents of this Data Processing Policy and (iii) you keep up-to-date and update the contact persons’ data provided.

The JVSZ does not transmit and does not make accessible your personal data to third parties without your consent or unless otherwise provided by the Website Terms of Use.

5. Legitimate interest of the JVSZ in the processing of personal data

Legitimate interests Legitimate interest test
Exercise of rights and fulfilment of obligations relating to the membership relationship The JVSZ has a legitimate interest in processing personal data in order to fulfil its obligations and to enforce its rights arising from the membership relationship. As part of this, in connection with the contract, it is necessary to process the personal data of the employees, agents and senior officers of the member of the Association who liaise with the JVSZ.
Analysis of user practices and preparation of hit statistics on the website www.jointventure.hu and www.jvsz.hu When you visit the www.jointventure.hu or www.jvsz.hu website and/or register, the JVSZ (or its technical service provider) records the Users’ IP addresses, from which the persons concerned can be inferred in certain cases; in addition, it records the operating system, the browser type and the address of the visited site. Making backups has primarily technical purposes: it is essential for the continuous operation of the system. Another goal of making backups is to analyse user practices and to prepare hit statistics, which help the provision of service to an even higher standard.

If you request more detailed information about the above legitimate interest of the JVSZ and the result of the consideration of interests, please contact us at jvsz@jointventure.hu.

6. Who have access to your personal data?

Within the JVSZ, members of the Presidency and the administrative employees of the JVSZ have access to your data.

We may transmit the personal data of members and their contact persons outside the JVSZ, to third parties, for the following reasons:

  • To certain third parties: We may transmit personal data about you to the supporters and external advisers of the JVSZ (e.g. attorneys-at-law, auditor) and financial institutions, in particular, for administering and making payments, communicating with you and third parties, responding to official inquiries and legal claims, and complying with them.
  • Service providers: In order to support its internal procedures, the JVSZ uses services provided by third parties. Personal data may be accessible to such service providers for the purposes of the given system or services under the appropriate data processing contract made between the JVSZ and the service provider. The websites under the www.jointventure.hu and www.jvsz.hu domains are operated and maintained and the personal data are electronically stored (hosting) by Progressive Studio Kft. as data processor (H-1066 Budapest, Nyugati tér 1., Skála Metró, 6th Floor, Hungary).
  • Data management activities performed through facebook.com are governed by Facebook’s own data management policy (data controller: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland).
  • Data management activities performed through linkedin.com are governed by Linkedin’s data management policy published on its own website (data controller: LinkedIn Ireland Unlimited Company, Attn: Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland).
  • In the event of registration with a Facebook/LinkedIn account, the Webplayer/Website will have access to the following data: the User’s public data and email address.

7. Data transmission abroad

If we transmit your personal data abroad, we rely on the European Commission’s decision establishing conformity or, in its absence, we will ensure by appropriate measures that the personal data are protected in accordance with the EU’s data protection rules (e.g. such as the EU’s General Data Protection Regulation, the GDPR).

Please contact us at jvsz@jointventure.hu if you would like to receive a copy of the relevant data transmission guarantees. In the absence of appropriate protection, we obtain your express consent to transmitting the data abroad.

8. Information about cookies

Cookies are small files comprising letters and numbers, which are stored in the browser of the user visiting the website or are transmitted to the hard drive of the user’s computer if you give your consent. The information of the JVSZ about cookies is available at the following link: https://jointventure.hu/cookie-policy.

How long do we retain personal data?

The personal data are retained by the JVSZ or the IT hosting provider on behalf of the JVSZ, but only until it is necessary for fulfilling our obligations and strictly as long as it is necessary to achieve the goal for which the data have been recorded. The personal data are erased from our records or are appropriately anonymised if they are no longer needed. If we have a membership relationship with you, we will retain your personal data during the membership relationship, then for the period of limitation under civil law (i.e. for 5 years). Retention requirements set in legislation apply to personal data stored in contracts, communication and business letters, which prescribe a retention period of at least 8 years applicable to accounting documents. However, in this case, access to personal data will be limited.

9.  What rights are you entitled to?

Your consent to the processing and use of personal data may be withdrawn at any time. The withdrawal of the consent does not affect the lawfulness of data processing before the withdrawal of the consent. Furthermore, as data subject, you have the following rights:

(i) Right of access: You are entitled to learn whether we have personal data about you or not, and if so, you may request information about the personal data relating to you. Among other things, we are obliged to answer questions like why we process a particular personal data, what data we have and to whom we have given access to the data. However, this is not an absolute right and such access rights may be limited by the interests of third parties.
(ii) Right to rectification: At request, we are obliged to correct inaccurate personal data or we have to supplement incomplete personal data.
(iii) Right to erasure (right to be forgotten): In certain cases, at your request, we are obliged to erase personal data.
(iv) Right to restriction of data processing: In certain cases, at your request, we are obliged to restrict the use of personal data. In such a case, we may use the data only for the limited purposes specified by legislation.
(v) Right to data portability: Under specific conditions, you are entitled to receive your personal data to which we have access in a structured, commonly used and machine-readable format, and after this you are entitled to transmit such data to another data controller without being prevented to do so by us.
(vi) Right to object:

You are entitled to object to the processing of your personal data at any time for reasons relating to your own situation, and in such a case, we might no longer process your personal data. If you are entitled to the right to object and exercising this right is well-founded, we will no longer process your personal data for the purposes involving the objection. Exercising this right is free of charge.
You are not entitled to this right if it is necessary to process your personal data for taking steps preceding the conclusion of a contract or performing of an already concluded contract (such as your membership relationship with us).

 

(vii) Right to complain: You may, furthermore, lodge a complaint with the National Authority for Data Protection and Freedom of Information (1125 Budapest, Szilágyi Erzsébet fasor 22/C, Hungary).

10. Contacting the JVSZ:

Please do not hesitate to contact us for further information or for any inquiry about exercising the above rights. If you have such a request, you may send an email re ‘DATA PROTECTION INQUIRY’ to the following address: jvsz@jointventure.hu

Last updated: 25 May, 2018.