This privacy notice specifies the rules of data processing through the Just Like Buddha mobile application (hereinafter: application), operated and provided by the Just Like Buddha Korlátolt Felelősségű Társaság (registered seat: 1132 Budapest, Csanády utca 16, 4th floor 3; corp. reg. no.: Cg. 01-09-303082; registered at the Registration Court of the Budapest Metropolitan Court; tax number: 26122258-2-41; e-mail address: petra@justlikebuddha.com; telephone number: +36 30 6940457) as data controller/service provider (hereinafter: Service Provider).
The Service Provider is dedicated towards protecting the Users’ personal data and regards it as especially important to respect its Users’ rights of informational self-determination (User = the natural person who downloads the app). The Service Provider handles the personal data confidentially and takes all security, technical and organizational actions that guarantee data security.
Downloading the app and providing personal data is at all times voluntary.
By downloading, using and registering for the application and by purchasing the subscription, the Users declare to have read the present privacy notice, to have understood its contents and to have accepted it as binding on them.
The Users shall be held exclusively liable for the correctness of the data provided by them. The Service Provider shall not be held liable for incorrectly provided data. The Users may request the Service Provider in e-mail (petra@justlikebuddha.com) to correct the data.
After registration within the application, the Users may subscribe to a newsletter. The Service Provider sends the newsletter to the Users on a monthly basis, via the Internet-based MailChimp service. By subscribing to the newsletter, the Users agree to forwarding (to third country) their provided data to MailChimp (The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE Suite 5000 Atlanta, GA 30308 USA), and the Users accept MailChimp’s data processing policy with regard to data processing. The privacy notice of MailChimp is accessible here: The Users may unsubscribe the newsletter at any time, however, unsubscription does not mean the simultaneous deletion of the registration.
Purpose of data processing: identifying the Users, sending newsletters to the Users in case of subscription as well as issuing and sending to the Users invoices – according to the effective legal regulations – if subscription is purchased for the application. Measuring advance in the case of subscription.
Legal ground of data processing: article 6 (1) a) and b) of the Regulation (EU) 2016/27 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), article 13/A (1)-(3) of Act CVIII of 2001 on Electronic Commerce and on Information Society Services (Ecommerce Act), Act CL of 2017 on the Rules of Taxation (Tax Act) and Act C of 2000 on Accounting (Accounting Act).
Categories of processed personal data: The Users’ID by downloading the application. The Service Provider processes the Users’ name and e-mail address exclusively in the case of registration, and if newsletters are requested, the newsletters are sent to the Users by using these data, and if subscription is purchased, the invoicing name and address and the date of purchase are processed in order to issue the invoice.
If the Users purchase the application, the application measures the Users’ advance, and for this purpose the relevant data are forwarded and stored in cloud and on servers (operator: Google Inc., registered seat: 1600 Amphitheatre Parkway Mountain View, CA 94043 USA). By purchasing the application the Users consent to the forwarding of their data (to third country) for this purpose.
The Users consent by using the application that the Service Provider keeps anonymous statistics about opening certain functions of the application and about the period of their use. The Users’ personal data are not assigned to the usage parameters, and the anonymous statistics do not qualify as personal data.
Period of data processing: The Service Provider processes the data during the registration period. When issuing the invoice, the Service Provider deletes the invoicing-related data, however, this shall not affect the obligation to store the data indicated in the invoice – as a part of the invoice – based on the effective legal regulations. The Service Provider processes the advance-related data during the term of the subscription. The Service Provider processes data regarding subscription to the newsletters during the term of newsletter subscription.
Access to data: the processed personal data are accessed – apart from the Users – exclusively by the Service Provider and its employees, to the extent required for operating the application.
Data controller, data processor: data are controlled and processed by the Service Provider, if newsletter services are used, the Service Provider forwards the data to the Mail Chimp newsletter sending and database operator, internet-based service provider (The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE Suite 5000 Atlanta, GA 30308 USA). The Service Provider provides no other third parties with access to the data, and the controlled data are not made public.
By using the Apple Store and/or Google Play system, the Users accept the privacy policy of the AppleStore (https://www.apple.com/legal/privacy/) and/or Google Play system (https://policies.google.com/privacy?hl=hu&gl=hu), which forms an inseparable part of this privacy notice.
The Users may submit to the Service Provider any comment, request or complaint regarding data processing by the Controller and the usage of the application at the following contacts: Just Like Buddha Kft. (registered office: 1132 Budapest, Csanády utca 16. 4. em. 3; email address: petra@justlikebuddha.com; telephone number: + 36 30 69 40 457)
The rights of the Users:
Under chapter III of the GDPR, the Users may have recourse to legal remedy as follows:
- To enforce the right to access personal data,
- To enforce the right to rectification personal data,
- To enforce the right to erasure personal data (‘right to be forgotten’),
- To enforce the right to restriction of data processing,
- To enforce the right to object against personal data processing and to enforce the rights related to automated individual decision-making and profiling,
- To enforce the right to data portability.
The Service Provider notifies the Users about the actions taken in response to the request under articles 15-22 of the GDPR within 25 days from receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. The Service Provider provides information about the extension of the deadline within 25 days of receipt of the request, together with the reasons for the delay [article 12 (3) of the GDPR].
If the User submitted a request in an electronic form (via e-mail), the information is also provided by the Service Provider by electronic means, unless the User requested it otherwise (e.g. by mail). In this case, you need to indicate this in your request.
The Service Provider provides information and takes actions free of charge, except where the User’s request is clearly unfounded or – in particular because of its repetitive character – excessive, with regard to the administrative costs related to providing the requested information or taking the required action [article 12 (4) of the GDPR].
Under chapter VIII of the GDPR, the Users may have recourse to legal remedy as follows:
I. The Users may submit a complaint to the supervisory authority:
Nemzeti Adatvédelmi és Információszabadság Hatóság
(Hungarian National Authority for Data Protection and Freedom of Information)
Registered office: 1125 Budapest, Szilágyi Erzsébet fasor 22/C.
Website address: https://www.naih.hu,
E-mail address: ugyfelszolgalat@naih.hu
II. The Users may seek legal remedy at court against the legally binding decision of the supervisory authority.
III. The Users may seek direct legal remedy at court if they believe that the Service Provider or the data processor violated their rights laid down in the GDPR as a result of inappropriately processing of their data. Proceedings against the Service Provider shall be brought before the courts of the Member State where the Service Provider has an establishment. Alternatively, such proceedings may be brought before the courts of the Member State where the User has his or her habitual residence.
The Users may withdraw their consent to personal data processing at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Deleting the application means withdrawal of the consent, and in this case the Service Provider deletes the Users’ personal data concerning the use of application. Deleting the application does not mean deletion of the subscription to newsletters, but it shall be separately requested by the User. Should the Users request the Service Provider to delete their personal data, it simultaneously means deletion of the subscription to the newsletter.
Issues not regulated by this privacy notice shall be governed by the legal regulations on data processing, especially by GDPR as well as Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information (Info Act).
According to its obligation set forth in articles 32-34 of the GDPR, the Service Provider shall do its best to provide for the security of the Users’ personal data, to take all technical and organizational measures, to establish procedural rules and to take actions required for enforcing the GDPR, the Info Act and other regulations on data and privacy protection.
Please note that the Service Provider may unilaterally modify this privacy notice. The modified provisions shall apply after their entry into force.
This privacy notice has been drawn up in Hungarian and English. Should there be any dispute about the provisions of the notice drawn up in two languages, the provisions of the Hungarian privacy notice shall apply.
Effective date of this privacy notice: 25 May 2018
Just Like Buddha Korlátolt Felelősségű Társaság
Controller