444.hu
DATA PROTECTION AND DATA PROCESSING NOTICE OF MAGYAR JETI ZRT. - 444
I. General Provisions 1. This Notice defines the data protection and data processing regulations that are recognised by Magyar Jeti Zrt. (registered address: 1024 Budapest, Margit körút 5/B, company reg. no.: 01-10-048381, hereinafter: Controller), the publisher and operator of the online portal 444.hu, as binding pursuant to the provisions the Regulation of the European Parliament and of the Council 2016/679 (General Data Protection Regulation, hereinafter: GDPR), Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information (hereinafter: Freedom of Information Act), Act V of 2013 on the Civil Code and Act XLVIII of 2008 on the Fundamental Conditions and Certain Limitations of Economic Advertising Activities (hereinafter: Economic Advertisements Act). 2. This Notice contains the principles governing the processing of personal data collected on Users from the Controller's website, as well as from its mobile or tablet application. 3. In the context of this Notice, the Controller is Magyar Jeti Zrt., which primarily carries out media content services and provides the necessary IT services related to this activity. 4. For the purposes of this Notice, a user (hereinafter: User) is a person who uses the media content services of Magyar Jeti Zrt. on the 444.hu web site, or on its mobile or tablet application (i.e. logs onto the website or into the application), subscribes to the newsletters of the 444.hu site, supports the operation of the 444.hu website as a sponsor, participates in the projects announced on the project.444.hu website or any of the 444.hu website’s own promotions, or initiates contact with the Controller. II. Data processed during the performance of the Controller’s core activity 1. Data processed when accessing the 444.hu web page and during the use of the tablet and mobile phone application During login, some data that are generated during the visit may be automatically recorded. The system logs the automatically recorded data without any specific declaration or act of the User when the User logs in or out. The system stores these data for the shortest possible time necessary for the provision of the service and safe operation, typically for a period shorter than 3 days, following which the data are overwritten, i.e. erased. In this way, for example, the following data may be stored: IP address, browsing data, visit parameters. For the optimum customised appearance, the Controller may place a so-called cookie onto the device of the User. The cookie allows a higher level of functionality to be provided on the 444.hu web page, and the provision of personalised services. A cookie can be deleted by the User from their own device or by setting up the browser in such a way that it prohibits the use of cookies. With the use of cookies placed by the Controller, within the scope of its own operation, the Controller does not collect data; the cookies are used in the User-side service process (on the device and browser of the User). Cookies are present in the user's system for an indefinite period of time, or until the cookies are deleted by the User. 2. Unless otherwise provided for by law, the personal data listed in this section may be processed by the Controller without any explicit consent for the purpose of compliance with any statutory obligation imposed upon them, for the enforcement of their own or a Third Party’s legitimate interest or for marketing purposes, if the enforcement of this interest is proportionate to the limitation of the right related to the protection of Personal Data. We would like to advise the User that these data are never linked by the Controller to other information that would allow the person behind these data to be identified. 3. Subscription to the Newsletter The Controller processes the User's e-mail address given at the time of subscribing to the newsletter with the consent of the User. Subscription to the newsletter may only be completed if the User consents to the data processing detailed in this Privacy Notice. Purpose of the data processing: to send a regular newsletter to the User. Duration of the data processing: the duration of the newsletter service or the date of unsubscribing from the newsletter. You can unsubscribe from the newsletter by clicking the link located at the bottom of the newsletter. Unsubscription from the newsletter is considered to be the withdrawal of consent. When consent is withdrawn, the processed data will be erased. The Controller does not transfer the data. 4. Sponsoring the 444.hu portal The primary aim of the 444.hu portal is to provide balanced, objective information on the current public, political, economic, social, cultural, technological, sports and scientific events, as well as news stories, which, for the long-term feasibility of its primary aim, collects operational sponsorship from Users in accordance with the GTC of Sponsorship available via the link below. Regardless of how the sponsorship is received, the Controller does not collect or process the names of the Users (sponsors), their bank account details or their bank card numbers. The Controller performs data processing only if the sponsor concerned (User) makes their e-mail address available during the sponsorship process and thus consents to the data processing. In this case, the data processing is directed at the User's email address. The purpose of the data processing is for the Controller to send a newsletter to the User in which it details its activities, including information regarding the use of the sponsorship received, at least once a year. Duration of the data processing: the duration of the newsletter service or the date of unsubscribing from the newsletter. You can unsubscribe from the newsletter by clicking on the link at the bottom of the newsletter or by sending an e-mail advising your intention to unsubscribe to the tamogatas@444.hu e-mail address. Unsubscription from the newsletter is considered to be the withdrawal of consent. When consent is withdrawn, the processed data will be erased. The Controller does not transfer the data. 5. Participation in the projects featured on the projekt.444.hu website The primary aim of the 444.hu portal is to provide balanced, objective information on the current public, political, economic, social, cultural, technological, sports and scientific events, as well as news stories. However, there are some planned projects that are mainly related to content or portal maintenance/operation that cannot be realised without the targeted sponsorship of readers/users. In order to use such targeted sponsorships, the Controller may occasionally announce different projects in accordance with the GTC of Project Sponsorship accessible through the link below. Usage of the project.444.hu site, created for the purpose of community financing, is subject to registration. If the User (sponsor) registers themselves simultaneously with sponsoring then they, through the provision of their e-mail address, Facebook profile or Google profile, consent to their data being processed. The Controller performs data processing only if the sponsor data subject (User) has consented to it during registration. The range of data involved in the data processing may vary depending on the content of the project, but it is primarily directed at the User's e-mail address, name and possibly their delivery address. The Controller informs the User separately of the data processed in each project. The purpose of the data processing is to enable the Controller to send a newsletter to the User, in which it details the activity of the Controller sponsored by the User, the circumstances and status of the project, the use of the sponsorship provided by the User (sponsor), or possibly individual; data processing objectives for the implementation of the project may arise, regarding which the Controller shall inform the User on a case-by-case basis. Duration of the data processing: the duration of the project or the date of de-registration. Regardless of how the sponsorship is undertaken, the Controller collects or processes the names of the sponsors and their bank account details or their bank card numbers. De-registration may take place by sending an e-mail stating the intent to de-register to the project@444.hu e-mail address. De-registration shall be deemed a withdrawal of consent. When consent is withdrawn, the processed data will be erased. The Controller does not transfer the data. 6. Newsletter subscription (Specialised Newsletter) The Controller processes the e-mail address provided by the User during their registration for the newsletter subscription, as well as the data necessary for invoicing purposes such as the User's name (company or private individual) and address. Subscription and registration to the newsletter may only be completed if the User consents to the data processing detailed in this Privacy Notice. Purpose of the data processing: to send a regular newsletter to the User in exchange for the payment of the subscription fee. Duration of the data processing: the duration of the newsletter subscription or the date of unsubscribing from the newsletter. You can unsubscribe from the newsletter by clicking on the ‘Unsubscribe’ link at the bottom of the newsletter or it may happen automatically if the User does not pay the subscription fee for the subsequent subscription period, thus not extending their subscription period. Unsubscription from the newsletter is considered to be the withdrawal of consent to data processing. When the consent is withdrawn, the processed data will be erased. The Controller does not forward the data. Regardless of how the subscription fee is paid, the Controller does collect or process the Users (subscribers) bank account or bank card details. 7. Participation in a promotion featured on 444.hu In this case, the Controller informs the User of the possible processing performed by it during each promotion and about the method and content of the consent required for it. 8. Contacting the Controller If the User initiates contact with the Controller (e.g. via e-mail, reader letter), they acknowledge and consent to the Controller recording their e-mail address and for it to process the same for the duration and to the extent necessary for the purpose of the given contact. During its content editing activity, the Controller processes the personal data of all natural persons involved in the production of content, either as a source or a reference in the edited content. In this case, the personal data most commonly processed by the Controller may be the following: name, position, place of work, age, place of residence, or other information that indicates how the data subject relates to the subject of the edited content. The Controller reviews the scope of the data processed in this manner pursuant to the intervals specified in the Internal Data Processing Policy and, if the purpose of the data processing has been fulfilled or the data processing is no longer required, it erases the data processed in this manner, unless, in a particular case, the Controller's legitimate interest justifies the further processing of personal data, for as long as the Controller’s legitimate interest prevails. III. Data processed during the performance of the Controller’s other activities 1. For marketing purposes, the Controller provides an interface for online advertising. For the provision of online advertisements serving it employs media advertising surface vendors, as well as web analytics and advertising service companies. Please note that the Controller, within the scope of its activity, may not place any cookies; however, third parties listed below may collect data and place cookies in order to personalise and/or optimise advertisements as outlined in the following paragraphs. The Controller uses the services of Sales Contact Kft. (1082 Budapest, Futó utca 47-53, Floor V) for the supply of media advertising surfaces (hereinafter: Media Advertising Surface Vendor). The Controller does not carry out data processing activities through the provision of online advertising surfaces even if it supplies its own surfaces, or if its surfaces are provided by the Media Advertising Surface Vendor. Data processing activities are carried out by the Media Advertising Surface Vendor or occasionally by the Controller’s partners using its online advertising surfaces (hereinafter: Third Party). The privacy notice of the Media Advertising Surface Vendor is available via the following page. During this secondary activity of the Controller, it is occasionally in direct contact with its clients (advertisers) (hereinafter: Third Party, Client). For advertisements published under the secondary activity on the 444.hu website, to measure the fulfilment of the appearances, our clients also use the external services of advertising service partners; in addition, they may use other technologies provided by External Service Providers to design and serve online advertisements even more effectively, in which they can collect data that is not capable of direct identification but which are considered Personal Data. We reiterate that the Controller does not carry out any data processing during the performance of this secondary activity. 2. Unless otherwise provided for by law, the Personal Data listed in Section III of this Notice may be processed by the Controller without any explicit consent for the purpose of compliance with any statutory obligation imposed upon it, for the enforcement of its own or a Third Party’s legitimate interest or for marketing purposes, if the enforcement of this interest is proportionate to the limitation of the right related to the protection of Personal Data. 3. With regard to the Personal Data processed in the systems of a Third Party, the provisions of the data protection notice of the Third Party shall be applied. The Controller shall take all reasonable efforts to make sure that the Third Party processes the Personal Data transferred to it in compliance with the legal regulations. After 25 May 2018, the Third Party registers, controls and processes Personal Data controlled, processed and transferred to it by the Controller in compliance with the provisions of the GDPR and shall issue a declaration with regard thereto to the Controller. 4. In the following points, the Controller provides information on the data processing activity performed by the Third Party. By using the web sites or mobile or tablet applications sold by the Controller and/or the Media Advertising Surface Vendor, the User consents to the use of the data relating to them as described in this Notice according to the following: When online ads appear on web sites, web analytics and advertising service systems handle various data from the User by placing cookies and other client-side storage on the User's computer. These data may be the following: The type and settings of the browser; The operating system running on the device and the type of device; Cookie information (e.g. for differentiation between devices and browsers, for unsubscribing etc.); the IP address from which the User accessed the website; the categorisation of the User into a segment based on the browsing history of the device and the time spent on certain websites, according to which more relevant advertising may be provided to them; data relating to the geographical location of the device, if allowed by the User when setting up their device. 5. The purpose of the Third Party data processing is to provide the various services listed below, for marketing purposes: online measurement - important for both web site operators and advertisers, it is important that they have information on how many different Users have visited each web site and have seen the advertisements they are ordering. It is also important for them to see how many times each User viewed their page and how many times they clicked on advertisements, etc. Online measurement using cookies provides this information to both promoters and advertisers, while the sale of advertising surfaces is also achieved with the help of website visitor statistical data, which the Controller shares with the Media Advertising Surface Vendor; avoiding excessive disturbance to Users with advertisements, which can also be achieved with cookies, as it is possible to measure how many times a particular advert has appeared for a particular User and if the User is not interested in it, e.g. does not click on the ad, it will no longer appear for them based on the request of the advertiser (frequency capping); provide more relevant advertisements to Users based on what websites have been visited or clicked on by the User in the past so that more appropriate and more relevant adverts appear; processing of data for security reasons in order to detect and prevent fraud and false visitor traffic. 6. In all cases, the data described in Section 4 will only be used to measure and improve advertising services and to improve the online experience. Cookie and IP address data are never linked by the Controller, Third Party or the Media Advertising Surface Vendor with other information that would allow the person behind these data to be identified. Information provided on online forms shall not be processed either. Information relating to the private life of the Users, such as their religion, political views or sexual orientation, shall not be recorded, stored or processed. 7. Users have the option to opt out of data processing through the system operated by External Service Providers. If a User has opted out, the service providers shall no longer collect data relating to them. Opting out works by placing one cookie onto the given browser - where the this setting was selected - of the User’s device, which indicates to the system of the External Service Provider that the User has opted out of data collection. If the User changes their browser or device, or deletes their browsing history, including cookies, they must opt out once more by changing the settings of the given device and browser. 8. Web analytics, advertising services and other External Service Providers By using the Controller's websites or the mobile or tablet applications. the User consents to the use of the information relating to their device by the External Service Provider listed in this chapter. During the use of the service, advertising services are performed by Internet BillBoard a.s., regarding the services and data processing of which information can be found on the following page. During the service, the AppNexus Inc. system collects data from Users that are capable of generating various profiles, based on their browsing history, for sales and marketing purposes; however, the platform does not collect any data that may be used for the direct identification of Users. More information about the services and the data processing of AppNexus and on the modification of settings can be found on the following page. The Controller uses the services of Google Inc. Google Analytics and Google AdSense. Google Analytics uses cookies to assist the analysis of the use of the given website. Google AdSense places cookies and uses web beacons to collect information. The information stored by the cookies (including the User's IP address) is stored on the servers of Google Inc. in the United States. Google Inc. may transfer the information collected to third parties if it is required by law or if the information is processed by the given third parties on behalf of Google Inc. Within the framework of the Google AdSense and Google Adwords remarketing, Google places visitor tracking cookies onto the device of the User, which observe the online behaviour of the visitors, according to which Google Inc. displays adverts from other websites that are based on the behaviour of the user and their interests. The tracking cookie allows Google Inc. to identify the website visitor on other websites. The ‘Data Protection Guidelines’ of Google Inc. can be found on the following webpage. Gemius Hungary Kft. uses online cookies during the provision of its online traffic and visitor measurement services to identify the browser used by the browsing individual, to distinguish between new and returning visitors and to create statistics relating to visitors. For more information about Gemius's data processing practices, the scope of the data being processed, and the method of blocking cookies used by Gemius, see the Gemius webpage. In addition to cookies, web analytics and advertising service partners use web beacons and click tags (click links and metrics) to collect information relating to tracking user habits and advertising services. Cookies placed by service providers can be deleted from the User's device at any time, and, by choosing the appropriate settings in their browser(s), cookies can generally be rejected. Identification of cookies placed by External Service Providers can be done based on the domain associated with the particular cookie. It is not possible to reject web beacons and click measurement tools. More information on cookies and how to manage them can be found on the following webpage. The Controller may cooperate with External Service Providers that offer registration and login assistance applications as well as bank card payment options for Users. Within the framework of that cooperation, certain personal data (e.g., IP address, e-mail registration name, bank account details, bank card details) are transferred by these External Service Providers to that Third Party. These External Service Providers collect, process and transfer personal data according to their own data protection guidelines. External Service Providers cooperating with the Controller making registration or log in easier: Facebook Inc., Google. External Service Providers cooperating with the Controller providing an option for bank card payment: PayPal Holdings Inc., Barion Payment Inc. There are some External Service Providers with which the Controller is not in a contractual relationship or does not cooperate with the particular data processing activity but, regardless of this, they have access to the 444.hu website and can therefore collect data on Users that may occasionally be capable of identifying the User. Such External Service Providers may include especially, but not exclusively: Facebook Ireland Ltd., Google LLC, Instagram LLC., Infogram Software Inc, Pinterest Europe Ltd., Playbuzz Ltd., Twitter International Company, Viber Media LLC, Vimeo INC., YouTube LLC., COUB Ltd. – These External Service Providers process Personal Data transferred to them according to their own data protection policies. IV. Purpose and general rules of the processing carried out by the Controller 1. Purpose of the processing performed by the Controller: provision of online content; maintaining contact with the User in order to inform the User of the individual projects and for their performance (see Newsletter, projects); management and implementation of user requests; to organise and implement promotions, to notify the winners and to supply the prizes to them in individual cases; to enforce the legitimate interests of the Controller. 2. The Controller shall not use the personal data provided for purposes other than those specified in these points. 3. Processing takes place on the basis of the voluntary declaration of the Users that is provided on the basis of adequate prior information. The declaration contains the express consent of the Users to the use of their personal data provided by them and the personal data generated about them while they use the page. When processing is based on consent, the User may withdraw their consent at any time, but it will not affect the lawfulness of processing prior to the withdrawal. 4. The Controller may use the services of a third party for the processing of the Personal Data, provided that the third party's data processing practices comply with the relevant legal requirements. With the acceptance of this Notice, the User grants their explicit consent for the data processing carried out by the third party. With regard to the newsletters, the Controller is MailChimp (512 Means St Suite 404 Atlanta, GA 30318 USA), which stores the data at the www.mailchimp.com website until consent to data processing is withdrawn. As far as commenting is concerned, additional data processing and data controlling activities can be performed by the operator of the commenting interface, Disqus Inc. (hereinafter: Disqus). V. Rights and obligations of the User 1. Right to information The User may request at any time for the Controller to provide information on whether it is processing the User’s personal data and if so to provide the User with access to the personal data processed by it. The User may request information regarding the processing of their personal data at any time in writing, by sending an e-mail to the adatkezeles@444.hu e-mail address or by sending a letter by registered mail or by registered mail with confirmed receipt to the registered address of the Controller. The Controller considers any request for information sent by letter to be authentic if the User can be identified clearly from the submitted request. The Controller only considers any request for information sent by e-mail to be authentic if it is sent from the User’s registered e-mail address. The request for information may be extended to the data of the User processed by the Controller, their sources, the purpose and legal ground as well as the duration of Processing, the name and address of the Processor, the activities relating to processing and, when Personal Data are transferred, the parties that received or still receive the User’s data and the related purpose. 2. Right to the rectification and modification of the processed data The User may request the rectification or modification of their personal data processed by the Controller, as well as the supplementation of incomplete data. The User may request the rectification or modification of their personal data in writing, by sending an e-mail to the adatkezeles@444.hu e-mail address or by sending a letter by registered mail or by registered mail with confirmed receipt to the registered address of the Controller. The Controller considers any request sent by letter to be authentic if the User can be identified clearly from the submitted request. The Controller considers any request sent by e-mail to be authentic only if it is sent from the User’s registered e-mail address. 3. Right to request erasure of personal data The User may request the erasure of their personal data processed by the Controller. The erasure may be refused if the data processing is necessary for exercising the right to express an opinion and obtaining information, or when the law provides authorisation for the processing of personal data and for the presentation, enforcement or defence of legal claims. The Controller shall always inform the User of the refusal of the request for erasure, specifying the reason for denying the erasure. Former (erased) data can no longer be recovered after the request for erasure of personal data has been fulfilled. The User may request the rectification or modification of their personal data in writing, by sending an e-mail to the adatkezeles@444.hu e-mail address or by sending a letter by registered mail or by registered mail with confirmed receipt to the registered address of the Controller. The Controller considers any request sent by letter to be authentic if the User can be identified clearly from the submitted request. The Controller considers any request sent by e-mail to be authentic only if it is sent from the User’s registered e-mail address. 4. Restriction of personal data processing The User may request the Controller to restrict the processing of their personal data if the User disputes the accuracy of the processed personal data. The restriction relates to the period during which the Controllers can verify the accuracy of the processed personal data; Restriction may also be requested if, according to the User, the data processing is unlawful, but they oppose the erasure of the processed personal data. Furthermore, restriction may also be requested if the purpose of the data processing has changed, but the User requests the processing of data by the Controller for the presentation, enforcement or protection of legal claims. The User may request the restriction of the processing of their personal data in writing, by sending an e-mail to the adatkezeles@444.hu e-mail address or by sending a letter by registered mail or by registered mail with confirmed receipt to the registered address of the Controller. The Controller considers any request sent by letter to be authentic if the User can be identified clearly from the submitted request. The Controller considers any request sent by e-mail to be authentic only if it is sent from the User’s registered e-mail address. 5. Right to request the provision or transfer of personal data The User may request the Controllers to transfer personal data supplied by the User and processed by the Controller in an automated manner in a delimited, widely used format that is machine readable and/or to transfer them to a different Controller. The User may submit such a request in writing, by sending an e-mail to the adatkezeles@444.hu e-mail address or by sending a letter by registered mail or by registered mail with confirmed receipt to the registered address of the Controller. The Controller considers any request sent by letter to be authentic if the User can be identified clearly from the submitted request. The Controller considers any request sent by e-mail to be authentic only if it is sent from the User’s registered e-mail address. 6. Right to objection The User may object at any time to the processing of their personal data if the processing of personal data is required only for fulfilling a legal obligation of the Controller or for the enforcement of a legitimate interest of the Controller or a Third Party; where the purpose of data processing is direct business acquisition; or if data processing takes place in order to fulfil a task in the public interest. The Controller assesses the lawfulness of the User’s objection and when it concludes that the objection is justified, shall cease processing and block the personal data and shall notify all parties to which the personal data affected by the objection were potentially transferred of the objection and the measure taken accordingly. The User may submit such a request in writing, by sending an e-mail to the adatkezeles@444.hu e-mail address or by sending a letter by registered mail or by registered mail with confirmed receipt to the registered address of the Controller. The Controller considers any request sent by letter to be authentic if the User can be identified clearly from the submitted request. The Controller considers any request sent by e-mail to be authentic only if it is sent from the User’s registered e-mail address. 7. Deadlines The Controller shall inform the User without undue delay, but by no later than within one month from the receipt of the request, of the measures taken in relation to a request submitted pursuant to Sections 1-6. This deadline may, however, be extended by two months if warranted by the complexity of the request or the number of requests. The Controller shall notify the User of any such extension within one month of receiving the request; such a notification shall include the reason for the extension. If the User submits the request via an electronic channel, the notification shall preferably be sent to them in electronic format unless the User requests a different format. If the Controller fails to act upon the data subject’s request they shall notify the User, without delay but no later than within one month of receiving the request, of the reasons for such a failure, and shall also inform the User that they may place a complaint at the supervisory authority, and may seek judicial legal remedy. 8. Right to complain Users may submit complaints relating to processing directly to the Hungarian National Authority for Data Protection and Freedom of Information (address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c.; phone: +36-1-391-1400; e-mail: ugyfelszolgalat@naih.hu; website: www.naih.hu). 9. Right of access to a court In the event that their rights have been violated, Users may turn to a court. The case shall be heard by the competent general court. If so requested by the data subject, the case may be brought before the general court in the jurisdiction of which the User’s home address or temporary residence is located. 10. User’s obligations The User warrants it has obtained the consent of the natural person data subject lawfully for the processing of Personal Data provided or made accessible by them about other natural persons. Whenever any User provides an e-mail address or other data during registration, they undertake that only they will use the service from the specified e-mail address or using the data provided by them. In view of that responsibility, any responsibility associated with any log-in made from the specified e-mail address and/or data shall lie with the User who registered the e-mail address and provided the data. The Controller uses the personal data on the basis of the consent of the data subject User and exclusively for the limited purpose. Controllers process personal data only for the purposes defined in this Notice and the applicable legal regulations. The scope of processed personal data is proportionate to the purpose of processing and may not exceed it. Whenever the controller intends to use the personal data for any purpose other than the intended purpose, it shall inform the User and obtain prior express consent from the User for that, providing also an opportunity to prohibit the use of data for such purposes. The Controller does not verify the personal data supplied. Only the person supplying the data is responsible for the accuracy of the personal data provided. Personal data of data subjects who have not yet reached 16 years of age may only be processed with the consent of the person of major age exercising parental supervision over them. The Controller may not verify the eligibility of the content of the declaration of the person providing consent, and therefore the User or the individual exercising parental supervision over them warrants that the consent complies with the laws and regulations. Without a declaration of consent, the Controller does not collect any personal data on the data subjects who have not yet reached 16 years of age, with the exception of the IP address, browsing data and visit parameters used during the Service, which are registered automatically, given the nature of online services. VI. Other provisions 1. The Controller makes accessible the available personal data of the Users concerned to third parties in certain cases, such as an official request from a court or the police, legal proceedings based on the violation of copyrights, property rights or other rights or a well-founded suspicion thereof. The Controller is entitled and obliged to transfer any personal data available and regularly stored by it to the competent authorities, the forwarding of which is its legal obligation, imposed by the law or in a legally binding order of an authority. The Controller may not be held liable for such data transfer or any consequences thereof. 2. The Controller uses the personal data on the basis of the consent of the data subject User and exclusively for the limited purpose. The Controller processes personal data only for the purposes defined in this Notice and the applicable legal regulations. The scope of processed personal data is proportionate to the purpose of processing and may not exceed it. Whenever the controller intends to use the personal data for any purpose other than the intended purpose, it shall inform the User and obtain prior express consent from the User for that, providing also an opportunity to prohibit the use of data for such purposes. 3. The Controller reserves the right to modify this Notice with a unilateral decision at any time. 4. With the next login, the User shall accept the currently effective provisions of the Notice and beyond that the consent of the individual User will not be required. Budapest, 24 May 2018 COMMENTING PROVISIONS From 21 January 2016, it is prohibited to post comments (posts) in the comment section below the articles published on the site which contain the following: personal or aggressive comments, comments that can violate the dignity or honour of another person, comments that can be used to harass hate speech, hateful comments, in particular on the grounds of discrimination based on sex, race, religion, ethnicity or sexual orientation, including posts containing links to such web sites infringing content sexually explicit posts, including images or video footage violent content, including images or video footage posts containing personal information regarding another person posts containing information that may be misused posts containing a link to a computer virus or a post containing the virus or any other post with content that can cause damage to the computing device content with regard to which a third party has rights posts containing open or hidden advertisements, including posts promoting other websites posts containing spam, multiple repetition of the same post (even under different articles) comments misusing the identity or image of another person comments containing an image or attachment greater than 2 MB In addition to the basic requirement of prohibited content detailed above, commenters are expected to behave in a civilised manner and to respect the dignity and personality rights of others. The Controller - or a person appointed by it - performs moderation within the Disqus system, with the tools offered by the system: it blocks the publication of posts that do not comply with the provisions, or deletes already published posts with such non-compliant content. As part of the moderation, within the Disqus system it is possible to provide a licence which allow the comments of certain contributors to be published more quickly, even without moderation, or to withdraw such a licence previously issued, in order to create a manageable quantity of verifiable content. Users may also apply for such a licence by sending their public Disqus profile to the whitelist@444.hu e-mail address if, at the time of their request, they have at least 30 posts, approved after 21 January 2016, that were posted within the past 30 days. The rules for commenting also fully apply to users with such a licence. The Controller reserves the right to block the publication of any comment/post on the pages of the 444.hu site it feels does not comply with the above specified moderation principles, and to remove any posts already displayed without justification. The Controller may also take the decision to block a commenter who fails to comply with the provisions from posting comments in the future. The Controller processes the commenter's data (username, e-mail address) exclusively in the Disqus comment management system, according to the rules defined by their Disqus provider. If any User has a query or observes a comment that in their opinion does not comply with the provisions, they may contact the Controller or its agent via the moderator@444.hu e-mail address.
Sinkovits András