Teqtos summarises the most important information about the processing of your personal data in this Privacy Notice (hereinafter referred to as the "Notice"), in particular the purposes and legal basis of the processing, the scope of the personal data processed, the duration of the processing, your rights in relation to the processing and your possibilities for enforcement and redress.
 

Teqtos reserves the right to make unilateral changes to this Notice, which may be required due to changes in legislation, governmental decisions or guidelines, business needs or newly discovered security risks. 

Teqtos will keep the personal data you provide confidential and will take all reasonable security, technical and organisational measures to ensure the security of the data.

 

Personal data is any information relating to an identified or identifiable natural person ("concerned"). An identifiable natural person is a natural person who can be identified, directly or indirectly, in particular by reference to an identifier (such as a name, number, location data, online identifier) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

In particular, the following legislation has been taken into account:

a) 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, hereinafter "GDPR"), 

b) Act CXII of 2011 on the Right of Informational Self-Determination and Freedom of Information (hereinafter referred to as the "Infotv.").

 c) Act V of 2013 on the Civil Code (hereinafter: Civil Code)

d) Act XLVIII of 2008 on the Basic Conditions and Certain Limits of Economic Advertising Activities (Act XLVIII of 2008)

e) Act CVIII of 2001 on certain aspects of electronic commerce services and information society services (Eker.tv.)

 

1. The data controller  

Name: Teqtos Ltd (hereinafter referred to as Teqtos or the Data Controller)
Registered office: 1139 Budapest, Lomb utca 15. III. floor

Company registration number: 01-09-284499

VAT number: 25599617-2-41

Authorized to represent: Koszti Tamás János

Postal (mailing) address: 1139 Budapest, Lomb utca 15. III. floor

E-mail: vaszily.miklos@teqtos.com

Phone: +36 20 349 2901

Webpage: https://www.iclearnacademy.com/

 

2. Data processing activities

 

2.1. Preparation and execution of the contract 

Purpose of the processing: the Teqtos provides the services requested by the customer on the basis of a contract. The processing of personal data is necessary for the preparation (e.g. request for quotation via the form on our website) and performance of the contract, because without the processing of personal data it is not possible to identify with whom the terms of the contract have been agreed or concluded by the Data Controller.

Legal basis for processing: necessary for the preparation and performance of the contract [Article 6(1)(b) GDPR].

Scope of the data processed: name or designation, registered office, establishment or billing address, company registration number, tax number, telephone number, e-mail address

Duration of data processing: Teqtos will keep the personal data processed for 5 (five) years after the termination of the contract [general limitation period according to § 6:22 of the Civil Code]. 

If the request or offer is not followed by the conclusion of a contract, the personal data will be deleted after a maximum of 1 year from the last contact. 

If the contract is required to support an accounting document, Teqtos is obliged to keep the data for 8 years from the last financial performance, pursuant to Article 169 of Act C of 2000 on Accounting.

 

2.2. Contract-related contacts 

The purpose of the data processing: related to the preparation and performance of the contract, the provision of various information, the answering of questions, the handling of possible problems, i.e. the continuous cooperation and communication between the contracting parties (which is also expected under the Civil Code).

Legal basis for processing: processing is based on the legitimate interest of Teqtos in cooperation, communication and operational management with its business partners and customers [Article 6(1)(f) GDPR].

Data processed: name, position, company name, telephone number, e-mail address

Duration of data processing: Teqtos will keep the personal data processed for 5 (five) years after the termination of the contract [general limitation period according to § 6:22 of the Civil Code].

If the request or offer is not followed by the conclusion of a contract, the personal data will be deleted after a maximum of 1 year from the last contact. 

If the contract is necessary to support an accounting document and includes contact information, the contract will be kept by Teqtos for 8 years from the last financial performance.

 

2.3. Billing-related data processing

Purpose of data processing: processing of invoices related to the provision of services (including confirmation of performance, issuing, transmission, storage, etc.)

Legal basis for processing: processing based on the performance of a legal obligation [Article 6(1)(c) GDPR].

Data processed: name, billing address, name of product/service, quantity, amount of service fee, bank account number, payment ID, e-mail address, other necessary financial information (e.g. tax information)

Duration of processing: 8 years from the last day of the year in which the tax liability relating to the invoice was fulfilled 

 

2.4. Data processing for direct marketing purposes

The purpose of the processing: to collect information and leads and to send information to relevant leads based on the information collected.

Legal basis for processing: processing is based on the data subject's consent [Article 6(1)(a) GDPR].

Consent to direct marketing may be withdrawn at any time, without restriction and without giving reasons, free of charge. In case of withdrawal of consent, Teqtos will no longer send marketing offers for direct marketing purposes.

Data processed: name, e-mail address, telephone number

Duration of processing: data will be processed until consent is withdrawn.

 

2.5. Enforcing legal claims

Purpose of data processing: for the purpose of enforcing its claims in relation to the service it has provided or is to provide (e.g. non-payment, damages in relation to the service used), or in the event of any other dispute or claim in connection with the contract, Teqtos processes the following personal data of the contracting party (its representative) for the purpose of protecting its interests, regardless of which party is making the legal claim. The personal data processed may be transmitted to the lawyer/legal adviser used for the assertion of the legal claim or to the court conducting the proceedings.

Legal basis for processing: processing is based on legitimate interests pursued for the establishment and exercise of legal claims [Article 6(1)(f) GDPR].

Data processed: name, position, company name, registered office, company registration number, tax number, other data related to the legal claim (e.g. content of the claim, period)

Duration of data processing: Teqtos will keep the personal data processed for 5 (five) years [general limitation period according to Section 6:22 of the Civil Code] from the date of the legal claim.

 

2.6. Data Protection Incident Recording

Purpose of data management: pursuant to Article 33 of the GDPR, Teqtos keeps records of data breaches that have occurred. If Teqtos is notified of a possible data breach, it may be necessary to communicate with the notifying party (when, where, what he/she experienced, etc.).

Legal basis for processing: processing necessary for compliance with a legal obligation [Article 6(1)(c) GDPR]

Data processed: name of the data subject, contact details (e-mail address, telephone number)

Duration of data processing: 5 years from the end of the investigation of the data protection incident [general limitation period according to § 6:22 of the Civil Code].

 

2.7. Cookies placed on the website by third parties 

The purpose of data processing: to increase the effectiveness of Teqtos' activities, to maintain and improve customer service and the quality of its services

The tracking of business activities and the compilation of various statistical data are greatly assisted by data packages placed on the website to collect information, so-called cookies, some of which collect information that is not directly or indirectly personally identifiable. These cookies are usually kept for the duration of the session (e.g. until the website is closed). 

The use of cookies from third parties (e.g. Google) is influenced by user preferences (e.g. if you disable cookies in your browser, no or only partial data collection will take place).

 

Google Analytics 4 is Google's analytics tool that helps Teqtos, as the owner of the https://www.iclearnacademy.com/ website, to get a more accurate picture of the activities of visitors to the website. These cookies help Teqtos to optimise its advertising campaigns by generating detailed statistics. Importantly, these cookies generate reports on website usage statistics without identifying visitors individually and directly to Google or Teqtos. Google Analytics 4 shows you where visitors clicked on the website, how long they spend on it and where they are located geographically (by IP address). The main cookie used by Google Analytics is the "__ga" cookie, which keeps data for two years. 

In addition to reporting site usage statistics, Google Analytics 4 can also be used to display more relevant ads on Google services (such as Google Search) and across the web, and to measure interactions (clicks, read time, etc.) with ads displayed by Google Analytics. For more details about how Google Analytics 4 works and privacy, click here: https://policies.google.com/technologies/cookies?utm_source=ucbs&hl=hu

 

A meta pixel cookie is a small piece of code that Teqtos can place in the source code of the https://www.iclearnacademy.com/ website to track the activity of users who are also registered on Facebook, depending on the individual settings of the user's account. Teqtos Meta Ads can be displayed to existing or potential customers when they scroll through their Facebook feed, watch Reels videos on Instagram, or check their Messenger inbox. You can read more about Meta's cookie management by clicking on the following link: https://hu-hu.facebook.com/privacy/policies/cookies/?entry_point=cookie_policy_redirect&entry=0

And Meta's privacy notice can be found here: https://hu-hu.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0

 

Legal basis for processing: processing is based on the data subject's consent [Article 6(1)(a) GDPR].

Consent to data processing may be withdrawn at any time, without restriction and without giving reasons, free of charge.

Data processed: IP address, location (geographical area according to IP address), time, duration and frequency of visits to https://www.iclearnacademy.com/

Duration of processing: until the data subject's consent is withdrawn.

 

3. Processors of data 

Teqtos also works with intermediaries in its business activities. Depending on the content of their contribution, these intermediaries may be classified as data controllers (e.g. platform providers; see point 4) and data processors. 

A data processor is a natural or legal person who, on behalf of Teqtos, carries out processing operations (e.g. storage, transmission, disclosure) of personal data on the basis of a contractual mandate. Data processors are not allowed to make any decisions in relation to data processing (e.g. for what purpose, what personal data are processed, for how long), but are only entitled to act and carry out specific processing operations (e.g. collection, analysis, transmission, erasure) in accordance with the contract concluded with Teqtos and the instructions received.

Teqtos only uses data processors that take appropriate technical and organisational measures to guarantee a level of data protection and data security appropriate to the level of risk. 

 

Teqtos uses the following data processors for its data processing:

Name: Cookiebot
Registered office, other contact details: Usercentrics A/S,Head office: Havnegade 39, 1058 Copenhagen, Denmark.
Description of the activity covered: cookie management application
Scope of data processed, duration of data processing: See: point 2.7.

 

4. Platform providers, social networks

In this section you will find information on how to support Teqtos business operations. The terms and conditions related to the platform services and social networking sites used by Teqtos' business partners are set out in the business contracts and the business partners' own privacy notices.

Teqtos also uses the services of various platform providers (e.g. social networking sites) to support and promote its business. 

The basic aim of platform providers is to make the use of the platform "essential" in order to make a profit by creating and maintaining relationships between participants, building the user experience through different algorithms and increasing engagement with the platform. 

Platform providers are independent data controllers, with their own terms of use and privacy and data security rules, however, based on the technical/technological solutions used by platform providers (e.g. data collection, machine learning algorithms, language models) and the applicable legislation, the platform provider and Teqtos may be considered as joint data controllers. 

In the case of joint processing, Teqtos either acts itself or cooperates with the platform provider, depending on the processing operation that needs to be carried out in relation to the personal data concerned.

For the purposes of this section, a data subject is any natural person who views business content posted on a platform service used by Teqtos (e.g. social networking sites), reviews, responds (like, etc.) or comments on announcements, offers or services posted by Teqtos, or shares content or any of its posts (e.g. event invitations, campaign announcements) with others. 

The business interfaces provided by platform providers contain a number of features (including computer algorithms, collectively referred to as artificial intelligence) that the creator of the business fan pages (Teqtos) can use, but cannot change. This includes, for example, the machine learning or language modeling solutions used by the platform provider, the personal data collected from users, and the cookies used to track (count, analyse user behaviour) visitors to fan pages. As the operator of the business fan page, Teqtos will generally have access to statistical data about its audience (e.g. age, gender, marital status and occupational breakdown), information about the lifestyle and interests of its audience (including information about online purchases made by people who visit its fan pages), and geographic information that can be used to better target the content shared and to decide where to offer special discounts or organise events. 

Given that the aggregated data made available by the platform provider may sometimes be personally identifiable, but that Teqtos has no control over the collection and analysis of this data, it is advisable for users (visitors to the Teqtos fan page) to set privacy permissions in their personal profiles created in the platform service that allow the sharing of their private information as limited as possible. 

Teqtos strives to use only statistical data provided by the platform provider - which cannot be linked to a specific individual - when analysing the data on its fan pages. In general, the analysis of fan page data is carried out in order to improve Teqtos' activities and to ensure the effectiveness of its promotional campaigns.

Teqtos uses the following platform providers:

a) Facebook and Instagram - operated by Meta Platforms, Inc. and Meta Platforms Ireland Limited [European contact: Meta Platforms Ireland Limited; ATTN: Privacy Operations, Merrion Road Dublin 4 D04 X2K5, reland]; for more details about Meta's handling of personal data, please click here: Facebook: https://www.facebook.com/privacy/policy?section_id=13-HowToContactMeta; Instagram: https://help.instagram.com/155833707900388

b) LinkedIn (located at 1000 W Maude Sunnyvale, CA 94085, US), its Privacy Policy is available here:  https://www.linkedin.com/legal/privacy-policy

c) Google (Gmail and Google Drive) - operated by Google Ireland Limited (registered office: 4 Barrow Street Gordon House, Dublin, Ireland, registration number: 368047, tax number: IE6388047V), Privacy Notice: https://policies.google.com/privacy?utm_source=ucbs&hl=hu

d) O365 and Microsoft Teams - hosted by Microsoft Ireland Operations Limited (based in Ireland, Dublin 18, Leopardstown, South County Business Park, One Microsoft Place), Privacy Notice:  https://privacy.microsoft.com/hu-hu/privacystatement

 

5. Transfers, data security measures

Personal data held by Teqtos may only be accessed by employees who are authorised to have access to the data for the purpose for which it is processed.

Teqtos will only disclose personal data processed by it to public authorities, courts or other public bodies in the manner and for the purposes specified by law and in a documented manner. 

Potential recipients of the transfer of personal data:  

a) National Tax and Customs Office (invoicing data), 

b) National Authority for Data Protection and Freedom of Information (data protection procedures, data breach investigations), 

c) an authority or court conducting infringement or criminal proceedings.

Teqtos stores personal data on its own computer equipment. Teqtos takes appropriate IT, organisational and personnel measures to protect the personal data it processes against, among other things, unauthorised access or unauthorised alteration, loss or destruction of personal data. Access to the data contained in each register shall be subject to an authorisation scheme, password-protected and logged, so that it is possible to check who has carried out what data processing operation, when and by whom. 

 

5. Rights concerned, enforcement

 

5.1. Right of access

If you would like to know exactly what personal data we process, for what purposes, on what legal basis and for how long, and where we obtained your personal data, to whom, when and on what legal basis we transferred or gave access to it, please contact us using one of the contact details above. 

 

5.2. Right to rectification

If you believe that personal information we hold about you is incorrect, incomplete or not up to date, please notify us of your correct, complete and up to date personal information (e.g. your new email address or telephone number) using one of the contact details provided above. 

If you rectify personal data that we have previously disclosed to another party (for example, for a government inspection), we will also notify the previous recipient following the rectification, provided that notification is not impossible or involves a disproportionate effort.

 

5.3. Right to withdraw consent

Where the legal basis for processing is the consent of the data subject, consent may be withdrawn at any time. The lawfulness of processing prior to withdrawal is not affected by the withdrawal of consent to processing.

 

5.4. Right to erasure (right to be forgotten)

You can request the deletion of all or some of your personal data if one of the following grounds applies:

a) the personal data are no longer necessary for the purposes for which they were collected or processed;

b) if you have withdrawn your consent to the processing and there is no other legal basis for processing your personal data;

c) if you object to the processing of your personal data on the basis of legitimate interest and there is no overriding legitimate ground for the processing;

d) your personal data has been unlawfully processed;

e) personal data must be deleted in order to comply with an obligation under national or EU law that applies to us;

f) personal data are collected in connection with the provision of information society services to children [referred to in Article 8(1) of the GDPR].

We will not carry out the erasure if the processing is

a) for the exercise of the right to freedom of expression and information, or

b) to comply with an obligation under national or EU law that applies to us; or

c) for the establishment, exercise or defence of legal claims, or

d) necessary for public interest archiving, scientific and historical research or statistical purposes,

and deletion of the personal data would be likely to make it impossible or seriously undermine the achievement of those purposes.

We will also notify those to whom we have previously disclosed your personal data of the deletion of your personal data, provided that such notification is not impossible or involves a disproportionate effort.

 

5.5. Right to restriction of data

If you dispute the accuracy of your personal data or if you believe that the processing is unlawful but you do not request the deletion of your personal data, or if you need your personal data to be deleted in order to establish, exercise or defend legal claims or exercise your right to object, we will restrict (block) the processing of your personal data. 

Blocking of personal data means that no processing operation can be performed on the blocked personal data, except for storage. The restriction of the processing of personal data (blocking) is done by clearly indicating this feature and by separating it from other personal data. The restriction (blocking) of processing will last as long as necessary for the reason you have indicated.

 

5.6. Right to data portability

If the legal basis for the processing of your personal data is the data subject's consent or the performance of a contract and the processing is automated, you may request to receive the personal data you have provided and which relates to you in a structured, commonly used, machine-readable format, or you have the right to request the transfer of that personal data to another controller. The right to data portability is only possible in the case of those legal bases (data subject's consent, performance of a contract) and cannot be claimed for personal data processed on other legal bases (e.g. legitimate interest).

Ensuring the right to data portability does not mean that Teqtos is obliged to implement or maintain a technically compatible system that allows data portability to another controller.  

If the exercise of the right to data portability adversely affects the rights and freedoms of others, we will refuse to provide data portability to the extent necessary to protect the rights of others.

 

5.7. Right to protest

You may object to the processing of your personal data on the basis of a legitimate interest, in which case your personal data will be blocked (see previous point) and we will only continue processing if there are compelling reasons to override your rights and freedoms or if the processing is necessary for the establishment, exercise or defence of legal claims. 

 

5.8. Procedural rules for the exercise of rights of access

You can notify Teqtos of any request to exercise your data processing rights by using the contact details below:

1. in writing by post: 1139 Budapest, Lomb utca 15. III. floor

2. via email: vaszily.miklos@teqtos.com

 

Teqtos will inform you without undue delay, and at the latest within 30 days of receipt of your request, of the outcome of the request and the action taken. 

Please note that the protection of personal data is a private right, which means that only the person whose personal data is at stake can exercise the rights of the data subject. If you have appointed someone else (e.g. a lawyer) to exercise your rights on your behalf and for you, you must give a power of attorney. Teqtos will endeavour to ensure that the rights set out in the Notice are intended to be exercised by the data subject or by the person authorised by him or her, and may therefore request proof of identity and authorisation. Please do not send photocopies of any of your documents, as we do not use photocopies to verify your identity or the validity of your authorisation. If Teqtos has reasonable doubts about the identity of the person who wishes to exercise its rights or about the power of attorney, it will refuse to exercise the rights of the person concerned.

 

6. Legal remedies

 

To exercise your rights as a data subject or to make a complaint, you can contact us at any time using the contact details above. 

 

6.1. Right to complain to the supervisory authority

If you believe that your rights to the protection of your personal data have been infringed, you can seek redress from the designated data protection supervisory authority:

National Authority for Data Protection and Freedom of Information (NAIH)

Located at: 1055 Budapest, Falk Miksa u. 9-11.

Mailing address: 1363 Budapest, Pf. 9.

Phone: +36 (1) 391-1400

Webpage: www.naih.hu 

email: ugyfelszolgalat@naih.hu

 

6.2. The right to a judicial remedy

If the processing of your personal data is unlawful, you can initiate legal proceedings (civil lawsuit), which will be heard by a court of law. Depending on your choice, you can also bring the case before the court of your place of residence (for the contact details of the courts, please click on the link below): https://birosag.hu/torvenyszekek)