Privacy notice

We, at Crome Communication, work with personal data and provide consulting in privacy-specific issues on a daily basis, and, therefore, we are above all committed to the protection, safety and ethical use of personal data. We perceive self-determination over personal data to be a very important fundamental right, and we believe that we all should be assertive as regards the processing of our personal data and informed in terms of our rights and possibilities so as to create an environment where the processing of personal data can be built on trust and safety. The following notice serves the same purpose: to inform you in a plain and comprehensible manner as to in what cases, for which purposes, on what grounds and during what time we may process your personal data, as well as the ways you can dispose of the processing of your data and exercise your rights related to the same.

We have divided the notice into the following chapters:

Who processes your personal data?
How can we use your personal data?
Whom do we share your personal data with?
How do we ensure the safety of your personal data?
What rights are you entitled to?
How do we modify this notice and how will you be notified of the changes?
Further information
Contact

Who processes your personal data?

Data Controller

The scope of this notice includes all data processing activities in the case of which Crome Communication Kft. (Registered seat: H-1095 Budapest, Máriássy u. 7., company registration no.: 01-09-933287) (hereinafter: "we", "the Data Controller", "Crome Communication") acts as a data controller in terms of the personal data pertaining to the visitors of the cromecommunication.hu website and the clients using the services of Crome Communication Kft, as data subjects. Which means that in any case your personal data is collected, generated or any other way processed by browsing this website, using its functions, getting in contact with us, or using our sevices, this privacy notice is applicable.

Data Protection Officer

The Data Protection Officer of Crome Communication and his contact details:
Nagy Tyukos Ádám
@
+36 20 262-1281		 The Data Protection Officer (DPO) supervises the ethics and legitimacy of the data processing operations of a particular organisation in an independent status within the organisation, and is available for all persons whose personal data is being processed by the particular organisation. If you have any questions or concerns as regards the processing of your personal data, don't hesitate to contact him.

 

How can we use your personal data?

In the followings, we present the information pertaining to the purpose, method, legal grounds and duration of the processing of your personal data. We may process your data for several purposes, therefore, we categorised this information according to the purpose of data processing. However, it is possible that each personal data pertaining to you is processed for different purposes, either by processing different data for different purposes or by way of processing the same data for multiple purposes.

Use of the website

Purpose of data processing: To collect statistical information regarding the use of the website for the purpose of understanding how the visitors use our website, and, thus, to develop its content and functions.

 We would like to understand which of our content is preferred by our visitors, what functions they need the most, what paths they take within the site and how much time they spend on the particular sites. This information helps us make our popular content more easily accessible, improve the functionality of the site and create content and functions through which the website will be more useful and functional to you.

Scope of data processed: IP address, geographical location deducted from the IP address, other unique identifiers, type and version of operating system, type and version of browser, type of device used for browsing, source of landing on the website, browsing route amongst the different pages of the website, time spent on each page, mouse movement within the website, clicking, scrolling, other navigation information within the website, date of starting and ending the browsing event, duration of browsing event, the frequency of visiting the website within a particular period.

  

Legal ground for data processing: Legitimate interest and Consent It is in our legitimate interest to process the data based on which the manner in which our website is used can be understood, thus enabling the development of the same. We compared the rights and freedoms of data subjects with our relevant legitimate interest in the framework of an impact analysis, considering the nature of data processed in this regard as well as the method of processing.

In terms of the data in relation to the processing of which the data subject may be affected adversely, because, for example, the data are forwarded to a data processor or enable cross-website monitoring, the legal ground for data processing is the data subject's consent, granted by the data subject when arriving to the website based on the information received pertaining to cookies.

You can find our detailed cookie policy here.

As a visitor of the website, it is also useful to you if we collect, store and use some specific information in relation to your visit, which are only indirectly associated with you. This can be, for example, an identifier telling us that you have been on our site before, or the information that you have already signed up to our newsletter, so we don't offer it again, as we would only bother you.

However, we only process certain information if and after you have granted your express consent to processing, for example where we analyse the data in systems the processing of which is not carried out in EU member states or with the help of which a third party may create a user profile of you or may draw other conclusions, such as Google or Facebook.
Duration of data processing: The period of preserving and processing personal data to achieve the purpose of data processing varies by data type. The duration may range from the period of visiting the website to two years calculated from the same, which periods will start again once you return to our website. The exact durations pertaining to each information can be found in our privacy policy Identifiers that are only necessary for us to know that you are not a new visitor when you navigate from one page to another within your visit will be deleted after you have closed the website, while information denoting website use preferences (e.g. the use of which cookies you consented to, whether you signed up to the newsletter, the language in which you use the website) will be preserved for a longer period of time, since we presume that these preferences of yours will not change that often.

Publication of user content

Purpose of data processing: Providing a commenting possibility regarding certain content elements of the website, as well as the identification of the commenter.

You can add comments to our blog entries or other contents where our website allows you to do so. Your comments will be published on the website. We process your data for IT security purposes and to avoid any abuses.

Scope of data processed: Name, e-mail address, IP address, information included in the generated user content qualifying as personal data.

The name you provided will be published, however, your e-mail address will not.
Legal ground for data processing: Legitimate interest It is in our legitimate interest to publish the comments of persons using these services of our website and to identify these persons who are adding comments to our content. We compared the rights and freedoms of data subjects with our relevant legitimate interest in the framework of an impact analysis, considering the nature of data processed in this regard as well as the method of processing.  
Duration of data processing: Your data will be processed until the website related to the comment is publicly available. We will preserve your comments until the particular entry or other content is available on our site.

Fulfilling request

Purpose of data processing: Answering, fulfilling and following up the questions and requests submitted via the contact forms or webchat interface of the cromecommunication.hu website, via telephone or e-mail. If you submit a request or question to us, we must preserve your data in order to be able to respond to you, and to ask you afterwards whether the response given was satisfactory.
Scope of data processed: Name, e-mail address, telephone number, company name, position/job, any other information included in the message sent potentially qualifying as personal data. The data you provide when submitting your request and in the course of the communication starting from your request.
Legal ground for data processing: Legitimate interest It is in our legitimate interest to process the data based on which we can answer and fulfil the questions and requests submitted to us. We compared the rights and freedoms of data subjects with our relevant legitimate interest in the framework of an impact analysis, considering the nature of data processed in this regard as well as the method of processing. The processing of these data is in the interest of both of us, as both of us would like us to fulfil the requests sent to us.
Duration of data processing: One year from the final answering of the particular request/question.  

Conclusion and performance of contract

Purpose of data processing: Conclusion of contracts, performance of contractual obligations. We need specific contact details for the preparation and conclusion of contracts, and certain personal data may also be needed for using the services subject to the contract, e.g. for accessing certain computer systems provided by us.
Scope of data processed: Name, telephone number, e-mail address, postal address, company name, position/job, information related to the services subject to the contract qualifying as personal data, identifiers related to the use of services provided in the contract.  
Legal ground for data processing: Performance and conclusion of the contract. The processing of these data is in the interest of both of us, as both of us would like the contract to be concluded and afterwards to have the tasks set out in the contract performed.
Duration of data processing: 6 years commencing at the termination of the contractual relationship. If a contractual relationship is terminated, guarantee-related or other legal issues may arise afterwards. This is the reason for the extensive preservation of the data processed for such purpose.

Keeping contact with customers

Purpose of data processing: Allowing keeping contact with customers and ensuring the proper quality of serving customers. If we work together, we must communicate, and it is necessary to document the communication carried out between us so that we can do a quality job.
Scope of data processed: Name, telephone number, e-mail address, other contact information, position/job, other information included in the client communication qualifying as personal data. For this purpose, we process personal data included in the communication carried out between us (e.g. in e-mails, chat messages, texts) in excess of your name, workplace, position and all kinds of contact information (including even your contact details related to the instant messaging systems used in business communication).
Legal ground for data processing: Legitimate interest It is in our legitimate interest to process the data based on which we can ensure keeping contact with customers. We compared the rights and freedoms of data subjects with our relevant legitimate interest in the framework of an impact analysis, considering the nature of data processed in this regard as well as the method of processing. The processing of these data is in the interest of both of us, as both of us would like to communicate effectively, and, thus, our cooperation to be more efficient and effective.
The processing of these data is in the interest of both of us, as both of us would like to communicate effectively, and, thus, our cooperation to be more efficient and effective. If a contractual relationship is terminated, guarantee-related or other legal issues may arise afterwards. This is the reason for the extensive preservation of the data processed for such purpose.

Invoicing

Purpose of data processing: Issuing invoices, compliance with accounting rules applicable to invoicing  
Scope of data processed: Name, position, telephone number, e-mail address, postal address, company name, position/job Personal data indicated on the invoice, purchase order, certificate of performance or acknowledgement of receipt.
Legal ground for data processing: Compliance with statutory obligations The preservation of invoices and other related documents (e.g. certificate of performance, acknowledgement of receipt) is set out by Act C of 2000 on Accounting.
Duration of data processing: 8 years from the issue date of the invoice This period is also provided for by Act C of 2000 on Accounting.

Newsletter service

Purpose of data processing: Sending newsletters, improving the quality of the newsletter service based on interactions associated with newsletters If you sign up to our company or blog newsletter, we will preserve your name and e-mail address so that we can send the newsletters to you. We will also record whether you open the newsletter, whether you click on links in it, and we will prepare the newsletters based on such information in order to make our newsletters relevant to you.
Scope of data processed: Name, e-mail address, data on newsletter delivery, opening and click-through.  
Legal ground for data processing: Consent We only send newsletters to persons subscribed to the same and who have consented to the relevant data processing. After you have subscribed to our newsletter, you may unsubscribe at any time. If you unsubscribe from our newsletter, your consent to this data processing will be considered withdrawn.
Duration of data processing: 1 year from the reactions given to the newsletters sent or the information received on the deletion of the e-mail address. Once you have subscribed to any of our newsletters, we will process your data and send newsletters to you until there is a 1-year-long period during which you do not even open any newsletters sent. If this happens, we draw the conclusion that our newsletters are no longer relevant to you. We act in the same manner if we receive information from a mail server that the e-mail address provided has been deleted.

Marketing enquiries

Purpose of data processing: Delivering the marketing messages related to the services and products of Crome Communication via e-mail, telephone calls, online advertisements or postal consignments. If we believe that any of our services, products or content generated by us may be of interest to you or your company, we will inform you of such services, products or content.
Scope of data processed: Name, telephone number, e-mail address, postal address, company name, position/job, website usage data, newsletter interaction data, information recorded in the course of client communication, interaction data related to marketing content, advertising system identifiers and information concluded from the above. We will process your data with which we can identify you, based on which we can determine which of our marketing messages may be of relevance to you and information indicating the level of interest you showed regarding the message sent to you and what interactions you made as a result of our marketing activities.

Legal ground for data processing: Legitimate interest and Consent It is in our legitimate interest to contact business representatives for marketing purposes directly via e-mail, postal mail, telephone or business community applications with offers or information that may be of relevance to them based on the activity of their companies, the content of previous communication carried out with us and the usage data of our website. We compared the rights and freedoms of data subjects with our relevant legitimate interest in the framework of an impact analysis, considering the nature of data processed in this regard as well as the method of processing.

We condition marketing activities on consent with which we displayed marketing messages on other websites using third party advertising systems based on unique identification, or which we delivered via telephone, e-mail or postal mail based on a created profile.

Since our services and products are addressed to business entities, we presume that once you are in contact with us, and either of our services, products or offers may be of use to you based on what we have understood of your company, you will not be offended if we contact you in this regard. If we are wrong, and you let us know that you do not wish to receive such offers, we will certainly comply with your wish and will cease the processing of your data for marketing purposes.

However, we will request your consent to display ads expressly targeted to your preferences using advertising means such as the advertising systems of Google Ads or Facebook on other websites or in other applications, or to contact you with offers or messages on any platforms based on your user profile created based on the information pertaining to you in the marketing automation system. You may withdraw your consent granted at any time.
Duration of data processing: 1 year from the reactions given to the marketing messages delivered. We will process your data and send marketing messages to you until there is a 1-year-long period during which you do not react to our marketing enquiries at all. In this regard, relevant reactions include the opening of our e-mails, clicking on online ads, expressing interest in the course of our telephone enquiries and contacting us triggered by a material sent by us via postal mail.

Personal recruitment

Purpose of data processing: Filling positions, building a database of potential employees. If you share personal data with us on our websites or social media pages managed by us (e.g. company Facebook or LinkedIn profiles, inbox) because you are interested in a job opportunity at our company generally or in terms of a specific position, we will use such information in our personnel recruitment processes.
Scope of data processed: Name, telephone number, postal address, address, other contact data, information pertaining to qualification, skills, professional experience and former employments, salary expectation, other information shared with us qualifying as personal data and additional data recorded in the course of the recruitment process. We will process your contact information, the data you included in your CV, as well as data shared by you and data recorded by us in the course of the communication carried out with us in the recruitment process.

Legal ground for data processing: Legitimate interest and Consent It is in our legitimate interest to process data pertaining to persons contacting us for job opportunities and that are necessary for us to carry out the recruitment process. We compared the rights and freedoms of data subjects with our relevant legitimate interest in the framework of an impact analysis, considering the nature of data processed in this regard as well as the method of processing.

However, we condition the preservation of such data on the data subject's consent after the position in relation to which the employment of the data subject was considered has been filled.
Duration of data processing: 3 months following the date the relevant position was filled, and, in the case of a separate consent, 3 years from the date consent was granted.  

Enforcing legal claims

Purpose of data processing: Substantiating, defending and enforcing any arising legal claims If any legal claims arise for us pertaining to you, or for you pertaining to us, we will process all data that may be necessary for settling such claims.
Scope of data processed: Any information that may be necessary for substantiating, defending and enforcing the legal claim to an extent not unreasonably restricting the rights and freedoms of the data subject.  
Legal ground for data processing: Legitimate interest It is in our legitimate interest to process personal data that may be necessary for substantiating, defending or enforcing legal claims. Since the legal claim, the scope of data processed in relation to such claim and the effects on the rights and freedoms of the data subject vary significantly by each case, we examine the effects of data processing in each case individually.  
Duration of data processing: Until the processing of data is necessary for the settlement of the legal claim, considering potential periods of appeal and limitation.  

 

Whom do we share your personal data with?

We share your personal data with our data processing partners (subcontractors and the service providers of the softwares used by us for data processing) who contribute to the achievement of the goals for which your data is being processed:

  • Use of the website
    IT and consulting partners participating in the development and operation of the website. The service providers of the analytics, administration, automation and communication systems related to the website.
  • Fulfilling request
    IT and consulting partners participating in the development and operation of the website. The service providers of the analytics, administration, automation and communication systems related to the website.
  • Conclusion and performance of contract
    Service providers of administration, automation, communication and invoicing systems and the legal consulting partners participating in the preparation of the contract.
  • Keeping contact with customers
    IT and consulting partners participating in the development and operation of the website. The service providers of the analytics, administration, automation and communication systems related to the website.
  • Invoicing
    Service providers of administration, automation and invoicing systems and partners providing accounting services.
  • Newsletter service
    IT and consulting partners participating in the development and operation of the website, and service providers of analytics, administration, automation and communication systems.
  • Marketing enquiries
    IT and consulting partners participating in the development and operation of the website, and service providers of analytics, administration, automation, communication and advertising systems.
  • Personnel recruitment
    IT and consulting partners participating in the development and operation of the website, and service providers of analytics, administration, automation and communication systems. HR partners involved in the recruitment process.
  • Enforcing legal claims
    IT partners participating in the development and operation of the website, and service providers of analytics, administration, automation and communication systems. Legal consulting partners.

We will only share your personal data with the above partners and service providers and only to an extent necessary for achieving the purpose of the particular data processing.

If you would like to receive information as to exactly whom we share your personal data with, please contact us.

How do we ensure the safety of your personal data?

We have established our data processing operations in a manner and we apply such hardware and software means that enable the processing of personal data in compliance with data protection principles, ensure the rights of data subjects concerning data processing and minimise the risk of data breaches in accordance with current state of science and technology at the limits of our capabilities. We achieve this with, amongst others, the following means:

  • Only employees and data processors can access your personal data for whom access is strictly necessary to achieve the particular purpose of data processing. Any modifications or use concerning your personal data is properly logged and is traceable.
  • Where the nature of data processing allows, we process your personal data in a pseudonymised or encrypted manner.
  • Our IT systems serving the purpose of preserving personal data are supplied with proper protective means, and the applied security systems and means are audited on a regular basis and are developed continuously adjusted to the changes of the security and legal environment.
  • In the case of data processors involved in the processing of personal data, we ascertain in the framework of regular audits that they act in compliance with their statutory obligations and our expectations in the course of processing the personal data.

What rights are you entitled to?

  • You are entitled to request information on the processing of the personal data pertaining to you and may access such information. This includes the kinds of data we process about you as well as the purpose, the legal grounds and the contemplated period for which we process your data. This further includes the entities with whom your personal data have been shared, whether your data have been transferred to countries qualifying as third countries under the GDPR and the manners in which you may file a complaint or seek legal remedy in relation to the processing of your personal data. You are entitled to receive this information in a concise, transparent, intelligible and easily accessible form, worded in a plain and comprehensible manner in writing or in an equal substitute electronic format.
  • You may request the rectification of your personal data.
  • You are entitled to request the erasure of your personal data that we process based on your consent (provided that there is no other legal ground for the processing of the particular personal data) and that are no longer necessary for a certain data processing purpose, or that are only processed for marketing purposes.
  • You may request the restriction of the processing of your personal data, may it be the preservation, transferring, use or erasure of your data.
  • You are entitled to receive your personal data made available to us in a widely-used machine-readable format and to deliver the same to another data controller.
  • You may object to the processing of your personal data provided that the legal ground of data processing is our legitimate interest or that of a third party, or provided that the particular data processing is carried out for marketing purposes.
  • You are entitled to withdraw your consent granted previously for the processing of your personal data at any time, either in part or in full.
    If you wish to exercise your above rights, you can contact us by filling out the form below or sending an e-mail to the @ e-mail address.
  • You may file a complaint in relation to the processing of your personal data with the competent supervisory authority:
    National Authority for Data Protection and Freedom of Information
    H-1055 Budapest, Falk Miksa utca 9-11.
    +36 1 391-1400
    @

How do we modify this notice and how will you be notified of the changes?

We will regularly update this notice, adjusting to changes occurring in our data processing activities, in legislation or to other relevant changes. If there is a major change concerning the information included in this notice or our data processing activities, we will inform you via e-mail or via our website.

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