PRIVACY POLICY

This general data protection notice is based on the 2016/679 (“GDPR”)  regulation of the EU on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing of  Directive 95/46 / EC.

Under “Stifler House”, “we”, “ours”, “us” mean the company Stifler Gozsdu Ltd registered in Hungary.

Address: 1061-Hungary, Budapest, 6 Paulay Ede Street,  Floor 2, Door 8. Company registration number: 01-09-374296

Stifler House is committed to confidentiality and the protection of personal information. As part of this basic obligation, Stifler House ensures personal data collected online is adequately protected and used (hereinafter referred to as “personal data”, “personally identifiable data”).

In general, we intend to collect only personal information that online visitors have voluntarily given us in order for us to provide information and / or services to those individuals.

In accordance with the above stated information, the purposes of the data management of Stifler House are the following in particular:

  • informing you about the activities, services and professional news of Stifler House through the website;
  • responding to your various types of contact requests, inquiries (about table reservations, offers, event registrations), and responding to your contact requests;
  • providing offers;
  • the use of cookies;
  • implementing measures to further develop services and products;
  • to comply with the requirements of accounting and tax legislation.

The content and data displayed on the website are intended to provide general information to those who visit the website. Despite the most attentive care of Stifler Gozsdu, the website may not contain the most up-to-date information, therefore the information found should in no way be construed as professional advice or the provision of other services provided by Stifler Gozsdu.

1. COLLECTION AND USE OF PERSONAL DATA

1.1.       PERSONAL DATA WHICH WE COLLECT

We will receive your personal information if you choose to provide it to us – for example, by e-mail or when you register for certain services and book a table through our website. In some cases, you have previously transferred your personal data to Stifler House (for example, if you are a former employee).

When you register or transfer personal data to Stifler House, we will use this personal data in accordance with this privacy statement. We will not use your personal information for any other pur-pose unless we have obtained your permission or otherwise are required or permitted to do so by law or professional standards.

1.2.       LEGAL BASIS FOR THE USE OF YOUR PERSONAL DATA

Stifler House usually only collects personal information that is necessary to fulfill your request. Where additional, optional personal information is also needed, we will notify you at this point in the data collection.

In Hungary, the law allows us to process your personal data as long as we have a legal basis to do so. The law also requires that we inform you of these grounds. As a result, when we process your personal data, we rely on one of the following data processing legal bases:

  • Contract fulfillment: This is when the processing of your personal data is necessary to fulfill the contractual obligations under the contract concluded with us.
  • Legal obligation: this is when we are obliged to process your personal data in order to comply with a legal obligation, such as the retention of data for tax purposes or the provision of data to a public authority or law enforcement agency.
  • Legitimate interest: we process data about you when we have a legitimate interest in running a legitimate business, as long as it does not exceed your interests; or
  • Your consent: In some cases, we ask you for special permission to process some of your personal information, and we will only process your personal information accordingly if you agree to do so. You can withdraw your consent at any time by sending an e-mail to info@stiflerhaz.hu .

Examples of the legitimate interest referred to above:

—  Offering information and / or services to individuals who visit our website or provide information about employment opportunities.

—  Preventing fraud, crime and protecting our IT systems.

—  Customizing the online experience of individuals and improving the performance usage and effectiveness of Stifler House’s online presence.

—  Performing and analyzing our marketing activities.

—  Meeting our corporate and social responsibility obligations.

—  Exercising our fundamental rights in the EU under Articles 16 and 17 of the Charter of Fundamental Rights, including the freedom of enterprise and the right to property.

In some cases, the personal data we collect falls into the category of special data, such as data related to diversity (including data on racial and ethnic origin, political opinion, religious beliefs and other similar beliefs, trade union membership, sexual life, and sexual orientation) or health data, or data about alleged or proven crimes, whenever permitted by law or when you consent to the processing of special data.

1.3. AUTOMATIC COLLECTION OF PERSONAL DATA

In some cases, Stifler House and the service providers involved in the service use cookies, web IDs and other technologies to automatically collect certain personal information when you visit us online or when we email each other. The collection of such personal data allows us to personalize your online spatial experience, improve the performance, usability and efficiency of Stifler Gozsdu’s online presence, and measure the effectiveness of your marketing activities.

1.3.1. IP addresses

An IP address is a number assigned to your computer when you connect to the Internet. This al-lows computers and servers to recognize and communicate with each other. The IP addresses from which visitors appear to be recorded are done so for IT security and system diagnostic purposes. This data is also typically used in aggregated form to conduct website trends and performance ana-lyzes.

1.3.2. Cookies

A Cookies are typically placed on your computer or Internet-enabled device when you visit us online. This allows the website to remember your computer or device and serves many of the purposes described in the table below.

Some of our websites display notification banners asking for your consent to collect cookies. If you do not consent to these, your computer or Internet-enabled device will not be tracked for marketing purposes. A secondary type of cookie, the “user-input” cookie, may be required for the website to function. Such cookies will not be blocked by the use of this notification banner. The settings you select are saved in the cookie and are valid for 90 days. If you cancel your previous selection, you can do so by deleting your browser’s cookies.

Although most browsers automatically accept cookies, you can choose whether or not to accept them in your browser settings (often found in your browser’s Tools or Preferences menu). You can also delete cookies from your device at any time. However, you should be aware that if you do not accept cookies, you may not be able to use the full functionality of our website.

You can find more information about the use of cookies in the ‘help’ function of your browser or on some sites such as www.allaboutcookies.org.

In order to provide additional functionality, we occasionally use other third party tools and widgets on our custom websites. By using these widgets and share buttons, cookies are typically placed on your device to facilitate the use of these services and to properly display your interactions on our websites.

Cookies do not in themselves reveal your e-mail address to us or otherwise identify you personally. We obtain other identifiers, including IP addresses, in our analyst reports, but this is used to identi-fy many different visitors to our websites, the geographic origin of visitor trends, and not individual visitors.

1.3.3. Google Analytics

A Stifler House uses Google Analytics. Learn more about the Google Analytics used by Stifler House here: http://www.google.com/analytics/learn/privacy.html

In order to allow website visitors to choose from several options for how Google Analytics collects their data, Google has developed the Google Analytics “Opt-out Browser Plugin”. This feature communicates with the Google Analytics JavaScript (ga.js) to indicate that information about a website visitor will not be sent to Google Analytics. Google Analytics “Opt-out Browser Plug-in” does not prevent information from being transmitted to a website or other web analytics services.

1.3.4. Web IDs

A web ID is a small image file on a web page that is used to collect certain information about your computer, such as the IP address, the date of the visit, the content you were viewing, the type of browser, and previous cookies set by the same server. Stifler House uses web IDs only in accordance with applicable law.

Stifler House or its contributors to the service use a web ID to track the effectiveness of third-party websites that provide us with recruitment and marketing services or collect aggregate visitor statis-tics and manage cookies.

You have the option to disable certain web IDs by rejecting the cookies associated with them. The web ID may record an anonymous visit from your IP address, but the cookie information will not be recorded.

In some of our newsletters and other communications, we monitor your activities, such as the number of times an email is opened via links embedded in an email. We collect this information to track user interest and enhance the future user experience.

1.3.5. Location-based devices

Stifler House collects and uses the geographical location of your computer or mobile device. This location data is used to provide you with information about services that we think may be of inter-est to you based on your geographic location and to develop location-based products and services.

1.4. SOCIAL MEDIA WIDGETS AND APPLICATIONS

Stifler House websites typically include the ability to allow sharing with third-party social media applications, such as the ‘Facebook Like’ button and Twitter widget. These social media applications collect and use information referring to your use of the Stifler House website. Any personal information you provide through such social media application is often collected and used by other members of social media applications, and such interactions are governed by the privacy policies of the companies that provide the application. We do not exercise control or are not responsible for these companies or the use of your personal data by these companies.

In addition, Stifler House websites may include blogs, forums, mass searches, and other applications or services (collectively, “social media tools”). Social media tools are designed to facilitate the sharing of knowledge and content. Any personal information you share on any Stifler House social media device will be shared with other users of such social media device (unless otherwise specified at the point of collection) over whom we often have no or limited control.

1.5.       CHILDREN

Stifler House understands the importance of protecting children’s data, especially in the online environment. In particular, our sites were not intentionally designed directly for children under the age of 14. Under our policies, we never collect and maintain data about anyone under the age of 14, except as part of a professional services engagement.

2. SHARING AND TRANSMISSION OF PERSONAL DATA

2.1. TRANSMISSION OF DATA WITHIN THE NETWORK OF STIFLER HOUSE MEMBER CORPORATES

We share personal information about you with other member companies of the Stifler House holding where legal and regulatory requirements must be met or recommended to be met worldwide. Other parts of the Stifler House network also provide services to us and you, such as hosting and support of IT applications, compliance with certain insurance forms for member companies and their customers, compliance with customer conflicts of interest and anti-money laundering, assisting customer orders and other issues that are required for the continuation of Stifler House’s activities.

2.2. TRANSFER OF DATA TO THIRD PARTIES, DATA PROCESSORS AND DATA CONTROLLERS

We do not share personal information with third parties, data processors, or data controllers unless necessary to meet our legitimate professional and business needs and / or to be able to answer your questions and / or comply with legal or professional standards required or permitted by law. More information about these third parties, data processors, and data controllers is available at this link. In addition, Stifler House will transfer certain personal data outside the EEA to companies that work with us or to those who process personal data on our behalf for the purposes set out in this Privacy Notice. Stifler House occasionally stores personal data outside the EEA. Stifler House typical-ly sends personal information to another independent Stifler House member company that works with us on an assignment for you. If we do so, your personal data will be protected on an ongoing basis under agreements we have entered into with companies and organizations outside the EEA that contain general data protection provisions approved in this form by the European Commission. You can request detailed information on third parties, data controllers and data controllers through the contact details in the first paragraph of point 8.

3. OPTIONS

In general, you are not obligated to provide any personal data to Stifler House, but we may ask you to provide certain personal data in order for you to receive additional information about our ser-vices and events. Stifler House also asks for your permission to use certain personal data and you can agree to this or refuse to use it. If you consent to certain services or communications, such as sending an e-newsletter, you have the option to unsubscribe at any time based on the instructions contained in all such communications. If you choose to unsubscribe from a service or communication, we will attempt to remove your personal information immediately, although we may request additional information before we process your request.

As described in the “Cookies” section, if you wish to avoid cookies following you as you navigate our site, you can reset your browser to reject all cookies or to indicate when a cookie is being sent. However, keep in mind that some of our sites will not function properly if you choose to decline cookies.

4. YOUR RIGHTS

If Stifler House handles personal data about you, you have the following rights:

In connection with the processing of personal data specified in this prospectus, we grant the data subject the following rights:

—    Right of access;
—    Right to information;
—    Right to rectification;
—    Right of cancellation;
—    The right to restrict data processing;
—    The right to data portability;
—    Right to protest.

AzThe individual rights of those concerned are detailed below:

—      Right of access and information

At your request, we will provide information on whether your data is being processed. If so, we will inform you about the categories of data processed, the purpose of the data processing, the recipients or categories of recipients, the duration of data storage or the criteria for determining the duration, the exercise of data subjects’ rights, about the right to report your case to the National Data Protection and Freedom of Information Authority (NAIH) , the source of the data and the fact of automated decision-making, including profiling. In the case of data transfers outside the Europe-an Union or the European Economic Area, the data subject shall also be informed of the appropriate guarantees provided in connection with the data transfer.

—    Right to rectification

You have the right to ask the Data Controller to correct your data if it is inaccurate.

If the correction of the personal data we process is necessary, you can request the correction of the data in writing (by post or e-mail) by indicating the correct data.

You must notify us in writing (by post or e-mail) of any change in any personal information we process about you immediately, but no later than 5 days after the change. You are liable for any dam-age to the Stifler House due to failure to do so or late delivery of this notice.

—    Right of cancellation

You have the right to delete personal data about you without undue delay upon request, and Sti-fler House is obliged to delete personal data about you without undue delay in the cases specified in the GDPR (Article 17).

In the event that the Stifler House discloses personal data, ie has transmitted it to third parties, in the exercise of your right to delete, Stifler House will take the reasonable steps to inform the other data controllers to whom the personal data have been transmitted about the fact that the data subject has requested them to delete the links directing to the personal data in question or a copy or duplicate of that personal data.

—    Right to restrict data processing

You have the right to restrict your data processing upon request if

—    You dispute the accuracy of your personal information;

—    data processing is illegal;

Stifler House no longer needs personal data for data processing purposes, but you do so in order to make, enforce or protect legal claims;

—    You have objected to the data processing.

—    Right to data portability

You have the right to receive personal data about you provided to us in a structured, widely used, machine-readable format, and you have the right to transfer this data to another data controller without being hindered by Stifler House if:

—    data management is based on consent; and

—    data management is automated.

—   Right to protest

You may object to the processing of your personal data based on Article 6 (1) (f) of GDPR. In this case, the personal data may no longer be processed for this purpose.

In connection with the exercise of the rights listed above, you are entitled to contact Stifler House at:

—    1061-Hungary, Budapest, 6 Paulay Ede Street, Floor 2, Door 8, and

—    by sending an email to info@stiflerhaz.hu.

We further inform you that if the data processing is based on consent, you may withdraw your con-sent to the data processing at any time, however, this does not affect the lawfulness of the data processing carried out on the basis of the consent prior to the withdrawal. We would like to inform you that your consent has only been given in connection with the management of the telephone number, e-mail address, address, notification address, so its revocation also covers this data. You can withdraw your consent by sending a statement via the above postal addresses or e-mail ad-dresses.

5. DATA SECURITY AND INTEGRITY

Stifler House has up-to-date security policies and procedures in place to protect personal data from unlawful destruction, loss, alteration, unauthorized disclosure or unauthorized access. However, despite the best efforts of the Stifler House, security is not fully guaranteed against all threats. To the best of our knowledge, your personal information may be accessed by those who need to know it. These individuals, who have access to the data, are obliged to maintain the confidentiality of such data.

We will also take the necessary steps to retain personal data only for as long as (i) the personal data is required in accordance with an individual request, (ii) in accordance with a legal, regulatory, internal business or regulatory requirement, or (iii) until the person has requests that personal data be deleted.

The period for which the data can be retained depends on the specific environment and circumstance during which the personal data was collected; however, it must meet the requirements (from i to iii) mentioned above.

6. LINKS TO OTHER SITES

Please note that Stifler Ház websites typically contain links to other sites, including those maintained by other Stifler Ház holding member companies, which are not covered by this Privacy Statement, but are covered by other privacy statements that often differ from this Privacy Statement. We encourage users to review the privacy statement of each website they visit before providing any personal information.

7. AMENDMENTS TO THIS DECLARATION

Stifler House may amend this Privacy Policy Notice from time to time in light of its current privacy practices. When we modify this statement, we will update the date at the top of this page. Any changes to the handling of personal data that are defined and affected by this Privacy Policy will be communicated to you through the appropriate channel, depending on how we communicate with you in general.

8. REGULATORY ISSUES AND IMPLEMENTATION

A Stifler House is committed to the protection of personal data processed online. If you have any questions or comments regarding the handling of your data, please contact us at the following con-tact: info@stiflerhaz.hu. You may submit your report to this contact if you have any concerns about compliance with this Privacy Policy Notice.

If you are not satisfied with the answer you have received, you can forward your report to the data protection officer of Stifler House at the following contact: info@stiflerhaz.hu. We will confirm your email within 14 (fourteen) days and will do our best to respond to your report within 1 (one) month of receipt. If the notification is complex or we have received a large number of notifications, we will notify you that we will respond later than 1 (one) month and will make every effort to respond to your notification within three months of the first submission. We may accept your report (and in this case take one of the actions listed in the “Your Rights” section), or we may decline your report for legitimate reasons.

In all cases, you have the right to file a complaint to the National Data Protection and Freedom of Information Authority (NAIH), whose contact details are as follows:

  • Postal address: 1530 Budapest, Hungary, Pf.: 5.
  • Street address: 1125-Hungary, Budapest, Szilágyi Erzsébet fasor 22/c/c
  • Phone: +36 (1) 391-1400
  • Fax: +36 (1) 391-1410
  • E-mail: ugyfelszolgalat@naih.hu
  • Website: http://naih.hu

In addition to and even without the breach of the above mentioned, you have the right to sue for the handling of your personal data in case of a breach of GDPR, and to claim damages against Stifler House if you have suffered material or non-material damage as a result of a breach of GDPR by Stifler House. If you turn to court, you must sue in the court of your place of residence or stay

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