Privacy Policy

Próbakő Communication and Publishing Limited Liability Company

PRIVACY AND DATA PROCESSING POLICY AND INFORMATION NOTICE (“Information Notice”)

Purpose and Scope of the Information Notice

  • The purpose of this Information Notice is to establish the data processing and privacy principles applied by Próbakő Communication and Publishing Limited Liability Company (registered office: 1064 Budapest, Izabella utca 68/B. A. lph. 2. em. 16.) (“Company” or “Data Controller”) and the Company’s privacy and data processing policy, which the Company, as data controller, acknowledges as binding upon itself regarding the Company’s operations and in the course thereof.
  • This Information Notice contains the principles for processing Personal Data provided by Contracting Parties (as defined below). The Company’s main activity is providing PR and communication services.
  • In developing the provisions of this Information Notice, the Company has taken into account the following legislation in particular, but not exclusively: Regulation 2016/679 of the European Parliament and of the Council (“General Data Protection Regulation”), Act CXII of 2011 on the right to informational self-determination and freedom of information (“”), Act V of 2013 on the Civil Code, and the provisions of Act I of 2012 on the Labour Code.
  • The scope of this Information Notice extends to data processing activities related to the Services provided by the Company. In the course of such data processing, the Company shall act in accordance with the provisions of this Information Notice.
  • The purpose of this Information Notice is to standardize the Company’s activities regarding data processing activities for the protection of the fundamental rights and freedoms of natural persons, to lawfully process the data of natural persons and to ensure proper handling of Personal Data.
  • This Information Notice is valid until revoked. The Data Controller reserves the right to modify this Information Notice at any time by unilateral decision.

Definitions

Data Processing: any operation or set of operations performed on Personal Data, regardless of the procedure used, in particular the collection, recording, organization, structuring, storage, adaptation, alteration, use, querying, consultation, use, disclosure, transmission, dissemination or otherwise making available, publication, alignment or combination, restriction, deletion and destruction of Personal Data. Data Controller: the person who determines the purposes and means of Data Processing – alone or together with others. Data Processor: a service provider who processes Personal Data on behalf of the Data Controller. For the services referred to in this Information Notice, Data Processors may be the natural and legal persons set out in section 9.2 below. Personal Data or Data: any data or information by which a natural person Contracting Party can be identified – directly or indirectly. Contracting Party: a natural person who uses the service provided by the Company, participates in it, and provides their data listed in section 7 below in this context. For the purposes of this Information Notice, in the case of a minor Contracting Party, both the minor using the service provided by the Company and their legal representatives shall be considered Contracting Parties. Service(s): services provided by the Data Controller, in particular the provision of IT services to facilitate business monitoring and decision support. Website: the probako.hu internet site operated by the Data Controller. External Service Provider: third-party service provider partners used by the Data Controller – either directly or indirectly – in connection with the provision of Services, to whom Personal Data are or may be transmitted for the provision of Services, or who may transmit Personal Data to the Data Controller.

The Data Controller

The Data Controller for the data processing covered by this Information Notice is as follows: Company name: Próbakő Communication and Publishing Ltd. Registered office: 1064 Budapest, Izabella utca 68/B. A. lph. 2. em. 16. Company registration number: 01-09-715316 Tax number: 13029492-2-42 Phone number: (+36) 555 0643 Email address: info@probako.hu Website: https://probako.hu/ Contact person: Fülöp Edit

Purpose of Data Processing

The Company processes Personal Data only for specific purposes. Data collection and processing is done fairly and lawfully. The Company strives to ensure that only Personal Data that is essential for achieving the purpose of data processing and suitable for achieving the purpose is processed. Personal Data may only be processed to the extent and for the time necessary to achieve the purpose. The purpose of data processing is to provide PR and communication services to Contracting Parties. In particular: contacting, maintaining contact, providing information, requesting information, identifying the Contracting Party, managing and monitoring services used by the Contracting Party; handling and managing individual inquiries, protecting the rights of Contracting Parties, enforcing the legitimate interests of the Data Controller.

Method of Data Processing

5.1 The Data Controller stores the Contracting Party’s data on its own servers, on the Data Controller’s computers, or in paper-based records. Only the Data Controller has the possibility to process the Personal Data of data subjects.
  • Data provision is voluntary in all cases, meaning the data subject can freely decide whether to provide the requested Personal Data. If the data subject consents to this, the Data Controller processes the data in accordance with applicable laws and within the limits of the data subjects’ consent.
  • To prevent unauthorized use of processed Personal Data and related abuse, the Data Controller applies security measures. The Company regularly reviews its security procedures and develops them in line with technological progress.

Legal Basis for Data Processing

6.1 The legal basis for data processing is Article 6(1)(a) of the General Data Protection Regulation, considering that the use of PR and communication services provided by the Company is voluntary and Contracting Parties enable the Company to fulfill their assignment and provide PR and communication services by providing their Personal Data. Contracting Parties consent to the Company’s processing of their voluntarily provided Personal Data within the scope of the Company’s mandate. 6.2 The legal basis for data processing is also Article 6(1)(b) of the General Data Protection Regulation, considering that data processing is necessary for the performance of a contract to which the Contracting Party is a party, or for taking steps at the request of the Contracting Party prior to entering into a contract.

Scope of Processed Data

7.1 If the Contracting Party (journalist, blogger) brings their intention to use the Company’s HR and communication services to the Data Controller’s attention, the Data Controller records the following personal data of the Contracting Party for the purpose of contacting and maintaining contact with the Contracting Party and potential future cooperation: name, phone number, email address, field of expertise, medium, position and column. The legal basis for data processing is the data subject’s consent. The source of data is the Contracting Party, the place of data processing: Budapest, responsible for data processing is the Company’s managing director. Data storage is electronic, in the Mailchimp system. The Data Controller stores the data until the data subject’s deletion request to the Data Controller, and deletes it immediately upon receipt of the deletion request. 7.2 If the Contracting Party has given their explicit consent to the Company’s direct marketing data processing, the Data Controller records the following personal data of the Contracting Party for the purpose of sending current newsletters, offers and other direct marketing materials – at the time of giving consent: email address, phone number, position. The legal basis for data processing is the Contracting Party’s consent. The source of data is the Contracting Party, the place of data processing: Budapest, responsible for data processing is the Company’s digital manager. Data storage is in electronic form. Messages are sent using the Mailchimp mailing system. The Data Controller deletes the data immediately upon the Contracting Party’s withdrawal of consent to data processing. 7.3 The Company records the following personal data of job applicants during job application – for the purpose of selecting the appropriate candidate for a specific position: data subject’s name, place and date of birth, education data, work experience data, email address, phone number, and any data or information that the data subject shares with the Data Controller during the selection process in application materials (CV, motivation letter, etc.) and in documents provided in connection with the interview. The legal basis for data processing is the data subject’s consent. The source of data is the job applicant, the place of data processing: Budapest, responsible for data processing is the Company’s HR manager. Data storage is on paper and electronically (by email). The Data Controller stores the data until the Company’s decision about the person filling the given position, then deletes it immediately. 7.4 The Company – for the purpose of fulfilling its legal obligations – records the following personal data of employees related to employment relationships, arising during the establishment and existence of employment relationships: data subject’s name, mother’s name, place and date of birth, social security number, tax identification number, address, education and qualification data, job title, start date of legal relationship, working time extent, possible reason and duration of long-term absence, citizenship, bank account number, phone number, email address, foreign language knowledge, FEOR number, employee’s health fitness, assignment to tasks not belonging to the job, additional legal relationship for work performance, disciplinary punishment, obligation to pay compensation, working time, overtime, wages, vacation, taken vacation, benefits provided to the employee and their legal titles, employee’s debts to the employer and their legal titles, performance evaluation, development plans, assessments. The legal basis for data processing is the Company’s legal obligation fulfillment. The source of data is the employee and employer, the place of data processing: Budapest, responsible for data processing is the Company’s managing director. Data storage is on paper and electronically. The Data Controller stores the data for payroll-related tasks. The Data Controller stores the data according to legal provisions. 7.5 The Company – for the purpose of fulfilling its legal obligations – stores the following personal data related to employment relationships of former employees, arising during the establishment and existence of employment relationships: employee’s name, mother’s name, place and date of birth, social security number, tax identification number, address, job title, start date of legal relationship, working time extent, possible reason and duration of long-term absence, assignment to tasks not belonging to the job, additional legal relationship for work performance, working time, overtime, wages, benefits provided to the employee and their legal titles, employee’s debts to the employer and their legal titles. The legal basis for data processing is the Company’s legal obligation fulfillment. The source of data is the employee and employer, the place of data processing: Budapest, responsible for data processing is the Company’s managing director. Data storage is on paper. The Data Controller stores the data according to legal provisions. 7.6 If the Contracting Party participates in a journalistic study-tour program of the Company’s client (e.g., Panasonic, Rockwell), the Data Controller stores the following personal data of the Contracting Party – as a data processor – for the purpose of fulfilling its contractual obligation (organizing journalistic study-tour) specified in the contract between it and its client: name, address, place and date of birth, contact details (email address, phone number), identity card number, passport number. The legal basis for data processing is the Data Controller’s contractual obligation fulfillment. The source of data is the Data Controller’s client, the place of data processing: Budapest, responsible for data processing is the Company’s Study-tour project manager. Data storage is electronic. The Data Controller transmits the data to courier companies for package delivery tasks (courier service). The Data Controller deletes the data immediately after fulfilling its contractual obligation (ad hoc task) with the client. 7.7 If the Contracting Party participates in a journalistic product testing program of the Company’s client (e.g., Panasonic), the Data Controller stores the following personal data of the Contracting Party – as a data processor – for the purpose of fulfilling its contractual obligation (organizing journalistic product testing) specified in the contract between it and its client: name, address, contact details (email address, phone number). The legal basis for data processing is the Data Controller’s contractual obligation fulfillment. The source of data is the Data Controller’s client, the place of data processing: Budapest, responsible for data processing is the Company’s project manager responsible for product testing. Data storage is electronic. The Data Controller stores the data for package delivery tasks (courier service). The Data Controller deletes the data immediately after fulfilling its contractual obligation (ad hoc task) with the client. 7.8 If the Contracting Party wins a contest advertised by the Company’s client on social media platforms (Facebook), the Data Controller stores the following personal data of the Contracting Party – as a data processor – for the purpose of fulfilling its contractual obligation (prize delivery) specified in the contract between it and its client: name, email, address, phone number. The legal basis for data processing is the Data Controller’s contractual obligation fulfillment. The source of data is the Data Controller’s client, the place of data processing: Budapest, responsible for data processing is the Company’s Project Manager. Data storage is electronic. The Data Controller transmits the data to courier companies for package delivery tasks (courier service). The Data Controller deletes the data immediately after fulfilling its contractual obligation (ad hoc task) with the client. 7.9 If the Contracting Party participates in a reseller program of the Company’s client (e.g., ASTRA), the Data Controller stores the following personal data of the Contracting Party – as a data processor – for the purpose of fulfilling its contractual obligation (postal and online delivery of marketing, informational and educational materials) specified in the contract between it and its client: customer contact details (email address, phone number). The legal basis for data processing is the Data Controller’s contractual obligation fulfillment. The source of data is the Data Controller’s client, the place of data processing: Budapest, responsible for data processing is the Company’s Project Manager. Data storage is electronic. The Data Controller stores the data for package delivery tasks (courier service). The Data Controller deletes the data immediately after the termination of the contract with the client. 7.10 If the data subject visits the Website interface, the Data Controller’s system automatically records the following personal data of the visitor – for the purpose of proper website operation and identification of returning visitors: IP address.

Duration of Data Processing

The Data Controller deletes Personal Data if
  1. its processing is unlawful: If it becomes clear that data processing is unlawful, the Data Controller immediately implements deletion.
  2. the data subject requests it (except for data processing based on law): The data subject may request deletion of data processed based on voluntary consent. In this case, the Data Controller deletes the data.
  3. the data is incomplete or incorrect – and this condition cannot be lawfully remedied – provided that deletion is not prohibited by law.
  4. the purpose of data processing has ceased, or the legally defined time limit for data storage has expired. The Data Controller processes data as long as the relationship between the Data Controller and the data subject exists, and as long as the Data Controller provides Services to the data subject. The Data Controller deletes all other data when it is obvious that the data will not be used in the future, i.e., the purpose of data processing has ceased.
  5. it has been ordered by a court or the National Authority for Data Protection and Freedom of Information: If a court or the National Authority for Data Protection and Freedom of Information orders deletion of data with final effect, the Data Controller implements the deletion. Instead of deletion, the Data Controller – with notification of the data subject – blocks Personal Data if the data subject requests this, or if based on available information it can be assumed that deletion would harm the data subject’s legitimate interests. Personal Data blocked in this way may only be processed as long as the data processing purpose that excluded deletion of Personal Data exists. The Data Controller marks Personal Data it processes if the data subject disputes its accuracy or correctness, but the incorrectness or inaccuracy of the disputed Personal Data cannot be clearly established. For legally mandated data processing, deletion of data is governed by legal provisions. In case of deletion, the Data Controller makes the data unsuitable for personal identification. If required by law, the Data Controller destroys the data carrier containing Personal Data.

Use of Data Processors

9.1 The Company is entitled to use Data Processors for carrying out its activities. Data Processors do not make independent decisions and are only entitled to act according to the contract concluded with the Company and received instructions. The Company monitors the work of Data Processors. Data Processors are entitled to use additional data processors only with the Company’s consent. 9.2 Data Processors used by the Company: Data processing activities related to journalist database: Data processor name: The Rocket Science Group, LLC d/b/a MailChimp Data processor registered office: 512 Means St., Suite 404, Atlanta, GA 30318, USA Data processor email address: info@mailchimp.com Data processor phone number: +1 678 999 0141 The Data Processor operates the Mailchimp system for managing journalist data. Data processing activities related to direct marketing: Data processor name: The Rocket Science Group, LLC d/b/a MailChimp Data processor registered office: 512 Means St., Suite 404, Atlanta, GA 30318, USA Data processor email address: info@mailchimp.com Data processor phone number: +1 678 999 0141 The Data Processor operates the Mailchimp mailing system for sending direct marketing materials. Data processing activities related to package delivery (courier service): Data processor name: GLS General Logistics Systems Hungary Kft. Data processor registered office: 2351 Alsónémedi, GLS Európa utca 2. Data processor mailing address: 2351 Alsónémedi, GLS Európa utca 2. Data protection officer name: dr. Katona Rita Data processor email address: adatvedelem@gls-hungary.com The Data Processor performs courier service-related activities. Data processor name: Redda Motor Kft. Data processor registered office: 1097 Budapest, Gubacsi út 30. Data protection officer name: Bachrathy Kornél Data processor email address: redda@redda.hu Data processor phone number: +36 1 218 08 88 The Data Processor performs courier service-related activities. Data processor name: TNT Express Hungary Kft. Data processor registered office: 1185 Budapest II. Logisztikai központ – Irodaépület, BUD Nemzetközi Repülőtér 283. ép.; Data processor email address: evelin.torocsik@tnt.com Data processor phone number: 06 8031 3131 The Data Processor performs courier service-related activities. Data processor name: Magyar Posta Zártkörűen Működő Részvénytársaság Data processor registered office: Budapest, 1138 Budapest, Dunavirág utca 2-6. Data processor email address: ugyfelszolgalat@posta.hu Data processor phone number: +36 1 767 8282 Accounting Data processor name: LESS TAX BT. Data processor registered office: Budapest, Örs vezér tere 1 Data processor phone number: +36 30 924 6264 The Data Processor performs accounting-related activities. Data processing activities related to web hosting service Data processor name: Jumu Kft. Data processor registered office: 1025 Budapest, Törökvész út 3/a Data processor phone number: +36-20-555-0644 Data processor email address: marosi.imre@jumu.hu The Data Processor performs hosting service-related activities. Data processing activities related to website analytics service Data processor name: Google Inc. Data processor registered office: Amphitheatre Parkway, Mountain View, CA 94043, United States of America, The Data Controller uses Google Ads and Google Analytics services. Data processor name: Facebook Ireland Ltd. Data processor registered office: 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland The Data Controller uses Facebook Ads and Facebook Pixel services.

Persons Authorized to Access Processed Data. Data Transfer

10.1 The data processed during the data processing specified in this Information Notice may be accessed by the Company’s employees in connection with their duties. The Data Controller’s employees perform individual searches and individual operations on data only at the request of the Contracting Party, or if this is necessary for the provision of services. 10.2 Other persons may not access or have access to Personal Data processed by the Company. The Company does not transmit data to third parties either within the European Economic Area or to third countries outside it, except for the Data Processors listed in section 9.2. 10.3 Regardless of the above, the Company only transmits Personal Data to third parties if the data subject has clearly consented to this – with knowledge of the scope of data transmitted and the recipient of data transfer – or if the law authorizes data transfer. The Company documents all data transfers and maintains records of data transfers.

Data Security and Data Protection Incident

11.1 The Data Controller ensures data security, takes those technical and organizational measures and establishes those procedural rules that are necessary for the enforcement of applicable laws and data and confidentiality protection rules. The Data Controller protects data with appropriate measures against unauthorized access, alteration, transmission, disclosure, deletion or destruction, as well as accidental destruction and damage, and inaccessibility resulting from changes in applied technology. 11.2 A data protection incident is a breach of security that results in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or unauthorized access to, personal data transmitted, stored or otherwise processed. The prevention and management of data protection incidents and compliance with relevant legal requirements is the responsibility of the Company’s digital manager. Company employees are obliged to report to the Company’s managing director and digital manager if they detect a data protection incident or an event indicating one. Data protection incidents can be reported at the Company’s central email address and phone number, where employees, contracting partners, and data subjects can report underlying events and security weaknesses. In case of reporting a data protection incident, the Company’s digital manager, with the involvement of the managing director, immediately examines the report, identifies the incident, and decides whether it is a real incident or a false alarm. The following must be examined and established:
  • the time and place of the incident;
  • description, circumstances, and effects of the incident;
  • the scope and number of data compromised during the incident;
  • the scope of persons affected by compromised data;
  • description of measures taken to resolve the incident;
  • description of measures taken to prevent, remedy, or reduce damage.
In case of a data protection incident, the affected systems, persons, and data are identified and isolated, and the Company’s digital manager ensures the collection and preservation of evidence supporting the occurrence of the incident. After this, damage repair and restoration of lawful operation can begin. Records must be kept of data protection incidents. Data relating to data protection incidents recorded in the register must be preserved for 5 years. If the data protection incident is likely to result in a high risk to the rights and freedoms of natural persons, the Company must inform the data subject of the data protection incident without undue delay. The information must clearly and comprehensibly describe the nature of the data protection incident and communicate the following information and measures:
  • the name and contact details of the contact person providing information;
  • the likely consequences resulting from the data protection incident;
  • measures taken or planned by the Company to remedy the data protection incident.
The data subject need not be informed, but must be informed through publicly published information if
  • the Company has implemented appropriate technical and organizational protective measures, and these measures were applied to the data affected by the data protection incident;
  • the Company has taken additional measures following the data protection incident that ensure that the high risk to the data subject’s rights and freedoms is unlikely to materialize in the future;
  • the information would require disproportionate effort.

Rights Related to Data Processing, Data Processing Guidelines

12.1 Personal Data processing must be carried out lawfully and fairly, and in a transparent manner for the data subject. 12.2 Personal Data collection may only occur for specified, explicit and lawful purposes. 12.3 The purpose of Personal Data processing must be adequate and relevant, and only to the necessary extent. The Data Controller processes Personal Data only for the purposes specified in this Information Notice and applicable laws. The scope of processed Personal Data is proportionate to the purpose of data processing and may not exceed it. 12.4 Personal Data must be accurate and up-to-date. Inaccurate Personal Data must be deleted immediately. 12.5 Personal Data storage must occur in a form that permits identification of data subjects only for as long as necessary. Personal Data may be stored for longer periods only if storage is for public interest archiving purposes, scientific and historical research purposes, or statistical purposes. 12.6 Right to request information: Any person may request information at any time through the provided contact details about what data the Company processes about them, on what legal basis, for what data processing purpose, from what source, and for how long. Upon request, information must be sent immediately, but within 30 (thirty) days at the latest, to the provided contact details. 12.7 Right to rectification: Any person may request at any time through the provided contact details the modification or rectification of any data processed by the Company about them. Upon request, action must be taken immediately, but within 30 (thirty) days at the latest, and information must be sent to the provided contact details. 12.8 Right to deletion: Any person may request in writing at any time, free of charge and without restriction, through the provided contact details the deletion of their data, or may withdraw consent previously given for data processing. Upon request, this must be done immediately, but within 30 (thirty) days at the latest, the Company must delete the data subject’s data processed by it from its records, and information must be sent to the provided contact details. 12.9 Data that must be stored due to legal, statutory or contractual obligations for maintaining commercial records are blocked instead of deleted. 12.10 Right to blocking, restriction: Any person may request blocking of their data through the provided contact details. Blocking lasts as long as the specified reason necessitates data storage. Upon request, this must be done immediately, but within 30 (thirty) days at the latest, and information must be sent to the provided contact details. 12.11 Right to object: Any person may object to data processing through the provided contact details. The objection must be examined within the shortest possible time from submission of the request, but within 30 (thirty) days at the latest, a decision must be made regarding its validity, and information about the decision must be sent to the provided contact details. 12.12 Personal Data absolutely necessary for using the Services is used by the Data Controller based on the consent of the affected Contracting Party and exclusively for the specified purpose. 12.13 In all cases where the Data Controller wishes to use Personal Data for purposes other than the original data collection purpose, it informs the Contracting Party about this and obtains their prior, explicit consent, or provides them with the opportunity to prohibit the use. 12.14 The Data Controller does not verify the provided Personal Data. The person providing the Personal Data is solely responsible for the adequacy of the provided Personal Data. When providing an email address or phone number, any Contracting Party also assumes responsibility that only they will use services from the provided email address or phone number. In consideration of this assumption of responsibility, any liability related to provided data exclusively burdens the Contracting Party who provided the data. 12.15 Personal Data of persons under 16 years of age may only be processed with the consent of the adult exercising parental supervision over them. The Data Controller has no means to verify the authorization of the consenting person or the content of their statement, so the Contracting Party or the person exercising parental supervision over them warrants that the consent complies with laws. In the absence of a consent statement, the Data Controller does not collect Personal Data relating to data subjects under 16 years of age – except for the IP address used when using the Service, which is automatically recorded due to the nature of internet services. 12.16 The Data Controller does not transfer Personal Data it processes to third parties except for the Data Processors specified in this Information Notice and in certain cases referenced in this Information Notice – External Service Providers. 12.17 An exception to the provision in this section is the use of data in statistically aggregated form, which may not contain any other data suitable for identifying the affected Contracting Party in any form, thereby not qualifying as Data Processing or data transfer. 12.18 The Data Controller in certain cases – official court, police requests, legal proceedings due to copyright, property or other rights violations or reasonable suspicion thereof, harm to the Data Controller’s interests, endangering the provision of Services, etc. – makes the affected Contracting Party’s available Personal Data accessible to third parties. 12.19 The Data Controller notifies the affected Contracting Party and all those to whom it previously transmitted Personal Data for Data Processing purposes about the rectification, restriction, or deletion of Personal Data it processes. Notification may be omitted if this does not harm the data subject’s legitimate interests considering the purpose of Data Processing. 12.20 The Data Controller ensures the security of Personal Data, takes those technical and organizational measures, and establishes those procedural rules that ensure that collected, stored, or processed data are protected, and prevents their accidental loss, unlawful destruction, unauthorized access, unauthorized use, unauthorized alteration, and unauthorized distribution. The Data Controller calls upon all third parties to whom it transmits Personal Data to fulfill this obligation.

Contracting Parties’ Enforcement Options

13.1 Based on Article 37(1) of the General Data Protection Regulation, the Company is not obliged to designate a data protection officer for activities under the scope of this Information Notice. 13.2 Contracting Parties may file complaints about data processing at any time with the Company’s contact person specified in section 3 of this Information Notice. The contact person investigates the complaint within 30 (thirty) days of receiving it, then takes action as necessary, and informs the complaining Contracting Party about the investigation results and measures taken. 13.3 If the Contracting Party disagrees with the Company’s investigation results or measures, or otherwise believes they have suffered legal harm in connection with the processing of their Personal Data, they may turn to the National Authority for Data Protection and Freedom of Information (postal address: 1530 Budapest, Pf. 5.; address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c.; phone number: +36 1 391 1400; fax number: +36 1 391 1410; email address: ugyfelszolgalat@naih.hu; web: http://naih.hu). 13.4 In case of violation of the Contracting Party’s rights, they may turn to court. Hearing the case falls under the jurisdiction of the regional court. The case may also be initiated – at the data subject’s choice – before the regional court of the data subject’s residence or place of stay. Upon request, the Data Controller informs the Contracting Party about the possibility and means of legal remedy. Budapest, August 7, 2020.