IWEBMA LTD.
AS OF 26 JUNE, 2018
CONTENTS
- Name of the data controller
- The aim and legal basis of data processing, the scope of the processed data, data subjects and the period of data processing
- Data processing during the performance of contracts (in case of natural persons)
- Data processing during the performance of contracts (in case of representatives of legal persons)
- Data processing for direct marketing purposes
- Data processing related to sending professional newsletters
- Data processing related to third party cookies (analytics)
- Information on the use of data processors
- Information on the persons entitled to access the data, on the transfer of data and on data security measures
- Rights related to data processing
- Opportunities of remedy
- The personal data breach and its circumstances, effects and measures taken to remedy it
iWebMa Limited (hereinafter referred to as iWebMa Ltd.) informs you about the key information regarding the processing of your personal data, including especially the purpose, legal basis of the data processing, and the scope and the retention period of the data being processed (hereafter referred to as “the Policy”, as well as your rights and the available remedies regarding the data processing.
iWebMa Ltd. as data controller ensures that the Policy is available to you when your personal data is recorded, and that you can learn its contents. iWebMa Ltd. reserves the right to unilaterally modify the Policy. iWebMa Ltd. provides you with continuous access and the opportunity to review the current data processing information at the homepage of iWebMa Ltd. (https://www.iwebma.com). At your request, we will send you a copy of the current data processing information.
iWebMa Ltd. keeps the personal data provided by you confidential and will do its best to provide the security, technical and organizational measures that guarantee the security of the data.
Any information regarding the identified or identifiable natural person (“data subject”) shall be considered as personal data. A natural person is considered identifiable if the natural person 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;
Please note that with regard to the recommendation of the Hungarian National Authority for Data Protection and Freedom of Information (NAIH) dated 29 September 2015, on the privacy requirements of prior information, iWebMa Ltd. refrains from the word-by-word reproduction of text of the legislation and provides the information in a clear and readily understandable way.
Please be informed that the Policy has been specifically made taking into account the following regulations:
- 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 Regulation (EC) No 95/46 (General Data Protection Regulation, hereinafter referred to as “GDPR”), and
- Act CXII of 2011 on the right to information self-determination and freedom of information; (hereinafter referred to as Infotv.).
- Act V of 2013 on the Hungarian Civil Code (a (hereinafter: Civil Code)
1. NAME OF THE DATA CONTROLLER
The data of iWebMa Ltd., as data controller
Company name: iWebMa Limited
Short name of the company: iWebMa Ltd.
Seat: 1 Bailey Close, Frimley, Surrey, GU16 7EN
Postal (correspondence) address: 1 Bailey Close, Frimley, Surrey, GU16 7EN
Company registry number: 06450122
Tax number: GB 933 6519 12
Authorized representative: Elin Asbjoernsen, Managing Director
E-mail: contact@iwebma.com
Phone: +44 20 8133 7021
Website: https://www.iwebma.com
2. THE AIM AND LEGAL BASIS OF DATA PROCESSING, THE SCOPE OF THE PROCESSED DATA, DATA SUBJECTS AND THE PERIOD OF DATA PROCESSING
2.1. DATA PROCESSING FOR THE PERFORMANCE OF A CONTRACT CONCLUDED WITH IWEBMA LTD., IF YOU ARE A NATURAL PERSON
The purpose of the processing of data: iWebMa Ltd. as entrepreneur processes the personal data provided by you as a natural person and client for the performance of the contract concluded. In the context of the data processing, the contact details provided by you will be used by iWebMa Ltd. to contact and communicate with you, and discuss the performance of the contract.
The legal basis of the data processing: the data processing is necessary for the performance of the contract between you and iWebMa Ltd., you being one of the contracting parties [Article 6 (1) (b) GDPR]
Please note that the data processing by iWebMa Ltd. is considered lawful if the data processing is required in relation to a contract or contractual intention. We also inform you that your personal data is required to conclude a contract iWebMa Ltd., and the data processing is necessary for the performance of the contract.
The data subjects: the natural persons contracting with iWebMa Ltd.
Scope of the processes data:
- your name
- your billing address
- your postal address
- your phone number
- your email address
Period of data processing: iWebMa Ltd. retains the data processed in accordance with sections 6:21-6:25 of the Civil Code (general limitation period) for five years from the termination of the contract with you for the establishment, exercise or defence of its legal claims [Article 17 (3) (e) GDPR]. Please note that if iWebMa Ltd. shall retain the data in accordance with section 169 of Act C of 2000 on Accounting, the company is obliged to store the data for 8 years and will only erase them after that date.
2.2. DATA PROCESSING FOR THE PERFORMANCE OF A CONTRACT CONCLUDED WITH IWEBMA LTD., IF YOU ARE A REPRESENTATIVE OR CONTACT PERSON OF THE CONTRACTING LEGAL ENTITY
The purpose of data processing: if you, as a natural person, are an authorized representative (chief officer, e.g. general manager) or a contact person of a legal entity concluding a contract with iWebMa Ltd., the data processing by iWebMa Ltd. is necessary for the performance of the contract. In this context, the contact details provided by you will be used by iWebMa Ltd. to contact you and communicate with you, and exchange information related to the performance of the contract.
The legal basis for the data processing: the data processing is based on your consent as data subject [Article 6 (1) (a) GDPR].
Please note that consent is to be understood as a voluntary, concrete, informed and explicit statement of your will, that you express by a statement or an unambiguous act of affirmation that you grant your consent to the processing of your personal data.
Data subjects: the representative or a contact person of a legal entity entering into contract with iWebMa Ltd.
The data processed include the following data of the legal representative or contact person of a legal entity contracting with iWebMa Ltd.
- name
- phone
Period of data processing: iWebMa Ltd. retains the data processed in accordance with sections 6:21-6:25 of the Civil Code (general limitation period) for five years from the termination of the contract with you for the establishment, exercise or defence of its legal claims [Article 17 (3) (e) GDPR]. Please note that if iWebMa Ltd. shall retain the data in accordance with section 169 of Act C of 2000 on Accounting, the company is obliged to store the data for 8 years and will only erase them after that date.
2.3. DATA PROCESSING RELATED TO DIRECT MARKETING
Purpose of data processing: By filling in a quote form and submitting it to https://www.iwebma.com, you may request iWebMa Ltd. to send you marketing offers related to online marketing services, training or consultancy. This direct marketing activity is performed by iWebMa Ltd. specifically based on your consent, so we will provide you with the opportunity to familiarize yourself with the Policy when submitting the form.
The legal basis for the data processing: the data processing is based on your consent [Article 6 (1) (a) GDPR] and section 6 (1) of Act XLVIII of 2008 on the Essential Conditions of and Certain Limitations to Business Advertising.
Please note that you may, without limitation or justification, withdraw your consent to direct marketing at any time, free of charge. In the event of withdrawal, all data processed for this purpose are erased immediately by iWebMa Ltd. and it will not send marketing offers to you in the future.
Your processed data: your name, e-mail address, phone number, and your website’s address.
The data subject: You, as the natural person providing your consent.
The duration of the data processing: the data is processed until the withdrawal of your consent.
2.4 DATA MANAGEMENT RELATED TO DIRECT MARKETING, INCLUDING SENDING PROFESSIONAL NEWSLETTERS ELECTRONICALLY
Purpose of data processing: If you wish to subscribe to a professional newsletter on https://www.iwebma.com, your personal information necessary for sending the newsletter is processed by iWebMa Ltd. on your prior, explicit and express consent.
The legal basis for the data processing: the data processing is based on your consent [Article 6 (1) (a) GDPR] and section 6 (1) of Act XLVIII of 2008 on the Essential Conditions of and Certain Limitations to Business Advertising.
Please note that iWebMa Ltd. provides you with the option to unsubscribe from the professional newsletter. Under this provision, you may, without limitation or justification, withdraw your consent to direct marketing at any time, free of charge. In the event of withdrawal, all your data processed for this purpose will be deleted immediately by iWebMa Ltd., and the company will not send professional newsletters to you in the future.
The data subject: You, as a natural person subscribing to a professional newsletter.
The processed data: your name, e-mail address, and phone number.
The duration of the data processing: the data is processed until the withdrawal of your consent.
2.5. DATA PROCESSING RELATED TO THIRD PARTY COOKIES (ANALYTICS)
The purpose of processing: iWebMa Ltd. uses so-called cookies placed by third parties (Google Analytics, SALESmanago) on the web page https://www.iwebma.com. The cookie itself is a small, simple data packet that collects information about visitors to the site.
Google Analytics is Google’s analytics tool that iWebMa Ltd. as the owner of https://www.iwebma.com uses to get a better overview of the activities of the visitors of the website. These cookies provide detailed statistics to help iWebMa Ltd. to optimize advertising campaigns. It is important that these cookies report on the statistics on how to use the site without individually identifying visitors to Google. Google Analytics shows the location where visitors click on the site, how much time they spend and their geographical location. The main cookie used by Google Analytics is the “__ga” cookie.
In addition to reports of site usage statistics, Google Analytics can also be used to allow iWebMa Ltd. to show more relevant ads in Google services (such as Google Search) and across the Internet, as well as to measure interactions with ads served by Google Analytics.
The Facebook Pixel cookie is a small piece of code that iWebMa Ltd. can use to track the activity of registered users on Facebook by placing the cookie in the source code of the webpage https://www.iwebma.com. Its functionality largely resembles the Google Analytics cookie described above.
SALESmanago is an automated marketing software, a program that enables iWebMa Ltd. to create and automatically conduct various direct marketing campaigns with its built-in features.
The legal basis for the data processing: the data processing is based on your consent as data subject [Article 6 (1) (a) GDPR].
Please note that you may, without limitation or justification, withdraw your consent at any time, free of charge.
The processes data: Your IP address, location and the time, duration and frequency of your visits to https://www.iwebma.com
The duration of the data processing: the data is processed until the withdrawal of your consent.
3. INFORMATION ON THE USE OF DATA PROCESSORS
The data processor is a natural or legal person who processes personal data on behalf of iWebMa Ltd. as a data controller.
iWebMa Ltd. informs you that it uses the following data processors during the processing:
| Name | Seat, other contact information | The description of the activity | Scope of the processes data, period of data processing |
|---|---|---|---|
| Contabo GmbH | seat: Aschauer Strasse 32a, D-81549 Munich, Germany Postal address: Contabo GmbH, Aschauer Strasse 32a, D-81549 Munich, Germany E-mail: info@contabo.com Phone: +49 89 3564717 70 Fax: +49 89 216 658 62 | hosts the webpages of iWebMa Ltd. | Storage and backup of website data (data of forms as well) |
| Google (Google Analytics) | https://www.google.com/about/datacenters/ | recording of website usage data for statistical and advertisement targeting purposes (third party cookies) | cookie data |
| Facebook Inc. | recording of website usage data for statistical and advertisement targeting purposes (third party cookies) | cookie data | |
| SALESmanago | SALESmanago Poland Headquarters Benhauer sp. z o.o. 21 Grzegórzecka St, 31-532 Cracow Poland | sending newsletters and direct marketing | the data provided by the user, based on his/her for sending newsletters or direct marketing |
4. PERSONS ELIGIBLE TO ACCESS THE DATA, DATA TRANSFER, AND INFORMATION ON DATA SECURITY MEASURES
The personal data you provide can be accessed by the employees of iWebMa Ltd. having access to the data related to the data processing purpose, i.e. the following employees:
| Purpose of data processing | The persons with the right to access the data in the access authorization system of iWebMa Ltd. |
|---|---|
| Data processing for the performance of the contract (see points 2.1 and 2.2) | office manager, sales manager, project manager, expert |
| Data processing for direct marketing purposes (see point 2.3) | managing director and sales manager |
| Data processing related to sending professional newsletters (see point 2.4) | project manager, expert |
| Data processing related to the cookies on the website (see point 2.5) | project manager, expert, Google Analytics analyst |
Please note that iWebMa Ltd. may not transfer your personal data to third parties under any circumstances.
iWebMa Ltd. shall make appropriate data security measures to safeguard the personal data provided by you. As part of this, the company protects its IT systems, including personal data stored in electronic form, with multiple levels of passwords.
5. YOUR RIGHTS RELATED TO DATA PROCESSING
You shall have the right to request iWebMa Ltd. to provide access to, rectify, erase or restrict the processing of your personal data, to object to the processing of personal data and you shall have the right to data portability.
Below we describe the content of certain rights you have in connection with data processing as well as some specificities of your exercising your rights.
5.1. RIGHT OF ACCESS
You shall have the right to obtain from the controller confirmation as to whether or not personal data concerning you are being processed. Where that is the case, you shall have the right access to the personal data and the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- the envisaged period for which the personal data will be stored;
- your rights related to data processing (in particular to request rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing);
- the right to lodge a complaint with a supervisory authority;
- any available information as to their source;
- the existence of automated decision-making, including profiling, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.
iWebMa Ltd. as a data controller shall provide a copy of the personal data undergoing processing. For additional copies you have requested, iWebMa Ltd. may charge a reasonable fee based on administrative costs. Where you make the request by electronic means, and unless otherwise requested by you, the information shall be provided in a commonly used electronic form. The right of access can be exercised via the contact details provided in Section 5.8.
5.2. RIGHT TO RECTIFICATION
You shall have the right to obtain from iWebMa Ltd. without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
5.3. RIGHT TO ERASURE (‘RIGHT TO BE FORGOTTEN’)
You shall have the right to obtain from iWebMa Ltd. the erasure of personal data concerning you without undue delay. iWebMa Ltd. shall erase your personal data without undue delay, where the personal data are no longer necessary in relation to the purposes for which they are processed, there is no legitimate grounds for the data processing, where you object to the processing of personal data concerning you, and there is no overriding legitimate grounds for the processing, or where your personal data was unlawfully processed, or the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which iWebMa Ltd. is subject;
Please note that iWebMa Ltd. may refuse the erasure of your personal data, if the data processing is necessary for compliance with a legal obligation which requires processing by Union or Member State law to which iWebMa Ltd. is subject or for the establishment, exercise or defence of legal claims.
5.4. RIGHT TO RESTRICTION OF PROCESSING
You shall have the right to obtain from iWebMa Ltd. restriction of processing where one of the following applies:a) you contest the accuracy of the personal data, (for a period enabling the controller to verify the accuracy of the personal data); or b) the processing by iWebMa Ltd. is unlawful and you oppose the erasure of the personal data and requests the restriction of their use instead; or c) iWebMa Ltd. no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims; d) you have objected to processing.
We hereby inform you that where processing has been restricted, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
5.5. THE RIGHT TO DATA PORTABILITY
You shall have the right to receive the personal data concerning you, which you have provided to iWebMa Ltd., in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller, if the processing is based on consent or contract, and the processing is carried out by automated means.
In exercising your right to data portability, you shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
5.6. RIGHT TO OBJECT
You have the right to object to the data processing by iWebMa Ltd. on grounds of its legitimate interests for any reason related to your situation, including profiling.
In the event of an objection, iWebMa Ltd. shall not process your personal data unless iWebMa Hungary Ltd. demonstrates that such data processing is justified by such compelling legitimate interest which override the interests or the fundamental rights and freedoms of the data subject, or which are necessary for the establishment, exercise or defence of legal claims.
You are also entitled to object to the processing of your personal data for direct marketing, including profiling at any time, in which case personal data may no longer be processed for such purpose.
5.7. RIGHT TO WITHDRAW CONSENT
You are entitled to withdraw your consent at any time. Your consent is considered the legal basis for data processing in case of the objectives mentioned in points 2.2-2.5 of the Policy. Please be informed that the legal basis for the consent does not affect the lawfulness of the data processing before the withdrawal, i.e. the earlier data processing of iWebMa Ltd. based on previous consent is not rendered unlawful by the fact that you withdraw your consent later.
5.8. RULES OF PROCEDURE
Please be advised that you will be able to notify iWebMa Ltd. about your request to exercise any of your rights related to the data processing through any of the following contact details:
- personally at the seat of iWebMa Ltd.: 1 Bailey Close, Frimley, Surrey, GU16 7EN
- in writing by post: 1 Bailey Close, Frimley, Surrey, GU16 7EN
- In Email: contact@iwebma.com
iWebMa Ltd. shall provide information on the action taken on a request to the data subject without undue delay and in any event within one month of receipt of the request. That period may be extended by iWebMa Ltd. by two further months where necessary, taking into account the complexity and number of your requests. iWebMa Ltd. shall inform you of any such extension within one month of receipt of the request, together with the reasons for the delay. iWebMa Ltd. shall inform you on the decision in writing, or, where you make the request by electronic form means, the information shall be provided by electronic means.
If iWebMa Ltd. does not take action on your request, then it shall inform you without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.
iWebMa Hungary Ltd. provides the information and takes the necessary action free of charge.
Where requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character, iWebMa Ltd. as controller may either:
charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or
may refuse to act on the request.
iWebMa Ltd. shall bear the burden of demonstrating the manifestly unfounded or excessive character of the request.
Please note that detailed rules on your rights related to data processing are governed by GDPR chapter III, entitled “Rights of the data subject” and sections 14-21 of the Infotv.
6. OPPORTUNITIES OF REMEDY
As judicial remedy, you have the opportunity to initiate two kinds of procedures, which are described below:
6.1. THE RIGHT OF COMPLAINT AT THE SUPERVISORY AUTHORITY
You are entitled to submit a complaint to the Information Commisioner’s Office (ICO) as an independent authority, if you consider that the processing of your personal data is in violation of the GDPR Regulation.
Contact details of the Information Commissioner’s Office:
Postal address: Information Access Team, Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline: 0303 123 1113
Official e-mailing address: accessicoinformation@ico.org.uk
The website of the Authority is https://ico.org.uk/
However, we request you to send your complaint to iWebMa Ltd. as a data controller before initiating the procedure.
6.2. THE RIGHT TO JUDICIAL REMEDY
You are also entitled to court remedies against the legally binding decision of your supervisory authority. You shall have the right to a judicial remedy where the supervisory authority does not handle your complaint or does not inform you within three months on the progress or outcome of your complaint. The lawsuit may be initiated before a court of law at your permanent or habitual residence.
7. THE PERSONAL DATA BREACH AND ITS CIRCUMSTANCES, EFFECTS AND MEASURES TAKEN TO REMEDY IT
Please note that personal data breach shall mean a violation of security which results in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure or unauthorized access to personal data transmitted, stored or otherwise processed.
iWebMa Ltd. shall notify the personal data breach to the supervisory authority without undue delay and, where feasible, not later than 72 hours after having become aware of it, unless the controller is able to demonstrate, that the personal data breach is unlikely to result in a risk to your rights and freedoms. To ensure this, iWebMa Ltd. takes all necessary measures.
iWebMa Ltd. communicates to you a personal data breach, without undue delay, where that personal data breach is likely to result in a high risk to your rights and freedoms. In such cases, iWebMa Ltd. shall describe the nature of the personal data breach in clear terms, the likely consequences of the breach, the measures taken or planned to remedy the breach including measures to mitigate the potential adverse consequences of the breach.