PRIVACY POLICY

BAJZA TRANSLATION AGENCY

The present privacy policy (the “Privacy Policy”) governs the data processing activities carried out by Bajza Fordítóiroda (“we”, “us” or the “Company”).

The purpose of this Privacy Policy is to inform all data subjects (the “Data Subject” or “You”) visiting our website, ordering a translation from us or otherwise getting in touch with us on the ways we handle Your personal data.

In this Privacy Policy all commercial activities carried out by the Company are collectively referred to as “Services”.

This Privacy Policy may be updated if required in order to reflect the changes in data processing practices or otherwise. The current version can be found on our website. We will not make substantial changes to this Privacy Policy or reduce the rights of the Data Subjects under this Privacy Policy without providing a notice thereof to You.

The legal background of this Privacy Policy is mainly:

– Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)

– Act CXII. of 2011 on the right to information self-determination and information freedom (Infotv.)

WHO PROCESSES YOUR PERSONAL DATA?

Name:	ATLAS Fordítóiroda Kft.
Business ID:	Cg. 01-09-356591
Address:	1062 Budapest Bajza utca 54 alagsor 1
E-mail:	office@bajzaforditoiroda.hu
*Contact person:*
Name:	Józsa Ilonka
Telephone:	06 70 674 2570
E-mail:	office@bajzaforditoiroda.hu

THESE DEFINITIONS WILL HELP YOU UNDERSTAND MORE:

Below you can find the definitions of the most important legal terms used in this Privacy Policy:

– data subject: an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly;

– personal data: means any information relating to an identified or identifiable natural person (‘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;

– genetic data: means personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person and which result, in particular, from an analysis of a biological sample from the natural person in question;

– biometric data: means personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images or dactyloscopic data;

– data concerning health: means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status;

– consent of the data subject: means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

– objection: a statement of the data subject, in which he or she objects to the processing of his or her personal data, and requests the termination of processing and/or the deletion of personal data;

– controller: the natural or legal person who determines the purposes and means of the processing of personal data;

– data processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

WHAT KIND OF PERSONAL DATA DO WE PROCESS?

1. WHEN YOU REQUEST AN OFFER FROM US ONLINE

Types of personal data collected

Purpose of processing

Legal basis of processing

Data retention period

– full name

– e-mail address

The purpose of processing your personal data is to deliver an offer for the translation you require.

The legal basis for processing is mainly the fulfilment of the contract between Us and You.

We may also process your personal data for our legitimate interest of developing our business or enhancing our services.

All personal data will be erased or anonymized 30 days after the fulfilment of the contract or after an unsuccessful order.

2. WHEN YOU ORDER A TRANSLATION FROM US

Types of personal data collected

Purpose of processing

Legal basis of processing

Data retention period

– full name

– e-mail address

– telephone number

– address

– invoicing address (name, tax number, address)

– all personal data that may be contained in the translation

From the point of requesting an offer from us, until the delivery of the translation, the purpose of the processing is to deliver the required translation to You.

The legal basis for processing is mainly the fulfilment of the contract between Us and You.

We also process your personal data for legal requirements, such as invoicing obligations.

We may also process your personal data for our legitimate interest of developing our business or enhancing our services.

According to Hungarian law, all invoicing data must be stored for at least 8 years from the data of the issuance invoice.

Otherwise, all personal data will be erased or anonymized 30 days after the fulfilment of the contract.

3. THE PERSONAL DATA OF OUR SUBCONTRACTORS

Types of personal data collected

Purpose of processing

Legal basis of processing

Data retention period

– full name

– e-mail address

– telephone number

– address

– invoicing address (name, tax number, address)

The purpose of processing is to facilitate communication and work distribution within our network of translators.

The legal basis for processing is mainly the fulfilment of the contract between Us and our subcontractors.

We also process your personal data for legal requirements, such as invoicing obligations.

According to Hungarian law, all invoicing data must be stored for at least 8 years from the data of the issuance invoice.

Otherwise, all personal data will be erased or anonymized 30 days after the fulfilment of the contract.

4. COOKIES

Cookies are small text files sent and saved on your device that allows us to identify visitors of our website and facilitate the use of the Services and to create aggregate information of our visitors. This helps us to improve the Services. The cookies will not harm your device or files.

The Users may choose to set their web browser to refuse cookies, or to alert when cookies are being sent. For example, the following links provide information on how to adjust the cookie settings on some popular browsers:

Please note that some parts of the Services may not function properly if use of cookies is refused.

5. DATA PROCESSING UNDER LEGAL OBLIGATIONS

Types of personal data processed

Purpose of processing

Legal basis of processing

Data retention period

All types of personal data that may be legally required to be processed under the applicable laws.

The purpose of processing is to be compliant with the relevant laws on invoicing, money laundering and terrorism, and the laws on accounting.

The legal basis for processing is our legal obligation.

According to Hungarian law, all invoicing data must be stored for at least 8 years from the data of the issuance invoice.

DO WE TRANSFER YOUR DATA OUTSIDE THE EEA?

We store personal data primarily within the European Economic Area. However, we have service providers in several geographical locations. As such, we, and our service providers may transfer personal data to, or access it in, jurisdictions outside the European Economic Area.

We take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which it is processed. We provide adequate protection for the transfers of personal data to countries outside of the European Economic Area through a series of agreements with our service providers based on the Standard Contractual Clauses or through other appropriate safeguards, such as the Privacy Shield Framework.

WHO ELSE RECEIVES YOUR DATA?

We do not share personal data with third parties outside of the organization unless one of the following circumstances apply:

Recipient	Reason
Any national or international authority requesting personal data from us in an ongoing legal proceeding.	We may share personal data with third parties outside our organization if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect the interests, properties or safety of the Company, the users or the public in accordance with the law.
Our data processors	We may share personal data to authorized service providers (data processors) who perform services for us (including data storage, sales, marketing and customer support services). Our agreements with our service providers include commitments that the service providers agree to limit their use of personal data and to comply with privacy and security standards at least as stringent as the terms of this Privacy Policy.
Delivery companies	If you require the translation to be delivered to you, some of your personal data (name, address) will be transferred to a delivery company of our choice. This data transfer is necessary to fulfil our contractual obligations to you.
Subcontractor translators	Any personal data that may be contained in the translation files you provide to us may be forwarded to translators in our subcontractor translator network. All translators are subject to confidentiality obligations and follow the same stringent privacy measures as our Company.

YOUR RIGHTS AS A DATA SUBJECT

Right to access

You have the right to access the personal data relating to you and processed by the Company. This means that you may contact us, and we will inform what personal data we have collected and processed regarding to you and communicate the purposes such data are used for.

Right to withdraw consent

In case the processing is based on a consent granted by the you, you may withdraw the consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Right to rectify

Data subjects have the right to have incorrect, imprecise, incomplete, outdated, or unnecessary personal data we have stored about them corrected or completed.

Right to deletion

The data subject may also ask us to delete their personal data from our systems. We will comply with such request unless we have a legitimate ground not to delete the data. Such legitimate ground may be based on e.g. applicable legislation.

Right to object

You may have the right to object to certain use of your personal data if such data are processed for other purposes than necessary for the performance of the Services or for compliance with a legal obligation.

Right to restriction of processing

You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data.

Right to data portability

The data subjects have the right to receive their personal data from us in a structured and commonly used format and to independently transmit those data to a third party.

How to exercise your rights

The above rights may be exercised by sending a letter or an e-mail to us on the addresses set out above. We may request the provision of additional information necessary to confirm the identity of the data subject. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.

A LITTLE BIT ABOUT DIRECT MARKETING
From time to time, our company may engage in direct client acquisition activities, typically targeting companies that may benefit from our translation service at their publicly available email address. If our request is not based on your prior consent, we will carefully weigh our legitimate interest against the privacy of the targeted person before sending out the newsletter. We continually provide the option to opt out and unsubscribe of our email newsletters or advertisements.

IF WE HAVE A SERIOUS DEBATE, YOU CAN:

You can lodge a complaint with the local supervisory authority for data protection, in case you consider the Company’s processing of personal data to be inconsistent with the applicable data protection laws.

– Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH) (“Hungarian Data Protection and Information Freedom Authority”)

– 1125 Budapest, Szilágyi Erzsébet fasor 22/C

– Telephone: 1-391-1400

– fax: 1-391-1410

– E-mail: ugyfelszolgalat@naih.hu

– website: www.naih.hu

Please always get in touch with us to discuss your issues and solve them as quickly as possible, before contacting the Authority or initiating a legal proceeding against us.

HOW DO WE PROTECT YOUR DATA?

We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures include for example, where appropriate, encryption, pseudonymization, firewalls, secure facilities and access right systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability to restore the data. We regularly test the website, systems, and other assets for security vulnerabilities.

Should despite of the security measures, a security breach occur that is likely to have negative effects to the privacy of the Users, we will inform the relevant Users and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.

OTHERS

The up-to-date Privacy Policy can be found on our website at bajzaforditoiroda.hu. You can also find the current Privacy Policy in person at our office, where you can request a copy anytime in office hours.

We reserve the right to update this Policy at our own discretion.