Privacy Policy
CyCortex Kft. (1108 Budapest, Oltó utca 12., Company Registration Number: 01-09-423967, Tax Number: 26574363-2-42) as the Data Controller considers it important to respect and enforce the data processing rights of the natural persons concerned (hereinafter referred to as “data subjects”) visiting the website zebeq.com and shall act in accordance with the substantive and procedural rules of the law in force and its internal regulations.
The purpose of the Privacy Notice is to inform data subjects about the processing activities of the Data Controller through the website zebeq.com, and therefore the scope of the Notice is limited to the processing of data through the said website(s) and the scope of the data processed in the course of such processing.
The purpose of the website is to provide useful information about ZEBEQ Platform and it’s services
1. Who is Affected?
The personal scope of the information notice therefore covers natural persons who enquire or request or send an offer via the website zebeq.com, as well as representatives and contacts of non-natural persons, natural persons who subscribe to the newsletter on the website, job applicants and the Data Controller’s own staff entrusted with the operation of the website zebeq.com.
In connection with job applications, the data subject is also a person who applies for a job or internship position advertised by CyCortex Kft. .
2. The Data Controller
The data controller for the processing of data related to the website is the operator of the website zebeq.com.
Company name: CyCortex Technologies Limited Liability Company
Office: 1103 Budapest, Kőér street. 2/A.
Registered office: 1108 Budapest, Oltó street 12. floor 5. door 20.
Contact: CyCortex Office Management
E-mail: [email protected]
Company Registration Number: 01-09-423967
Tax number: 26574363-2-42
Website: cycortex.com
3. Data handling activities
3.1. Newsletter subscription
Before using the newsletter service, the data subject may subscribe to the newsletter by providing the following information.
Purpose of data management: the purpose of data processing in connection with the sending of electronic newsletters is to provide the recipient company with comprehensive general or personalised information on the latest ZEBEQ events, training courses, news, and information on current economic events and the legal environment. The processing is also intended to contact businesses as recipients of advertising for direct marketing purposes by electronic mail, unless the Data Subject objects to the processing. Direct marketing typically involves the provision of information about the Controller’s events, sales and training.
Legal basis: Subscription to the newsletter is based on voluntary, prior consent. The legal basis for sending the newsletter can also be the legitimate interest of the Data Controller, if the newsletter is not specifically addressed to natural persons. Designation of legitimate interest: direct acquisition of business (see the authorization of the preamble paragraph (47) of Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR). The Data Controller always provides the possibility of objection (opt-out) (see below), so if the Data Subject declares that he does not wish to receive inquiries for advertising purposes from the Data Controller, the Data Controller will delete his data and will not use them for this purpose after receiving the request.
Scope of stakeholders: any natural person who wishes to receive regular information about news and events of CyCortex as Data Controller or ZEBEQ and therefore subscribes to the newsletter service by providing their personal data. In the case of electronic messages not specifically addressed to natural persons for direct marketing purposes, if the processing is based on the legitimate interest of the Data Controller, in addition to the persons subscribing to the newsletter service, the persons concerned may also be persons who have come into contact with a Data Controller in the course of their business or professional activities or have participated in a previous training or business event of the Data Controller. In the case of processing based on legitimate interest, data subjects may also include persons whose contact details have been provided on a publicly accessible website of professional relevance for the purpose of contacting them.
Scope and purpose of processed data:
Full Name | Identification |
Email Address | Sending newsletter |
Company name | Identification |
Date of Subscription | Identification |
Who handles the data: the newsletter is sent exclusively by the Marketing and PR department staff using the Online Marketing newsletter sending software.
How long will the data be processed: The Data Controller will only process the personal data collected for this purpose until the person concerned unsubscribes from the newsletter list or provides confirmation. The Data Controller reviews the newsletter list every three years and requests confirmation consent to send the newsletter after three years. The Data Controller will delete the data of the data subject who does not give affirmative consent from the data file.
Duration of data management: until deletion at the request of the data subject or if the data subject does not give further consent.
Unsubscribe: The data subject can unsubscribe from the newsletter at any time, by sending a cancellation request at the bottom of e-mails or sending the request to the e-mail address [email protected].
3.2. One-time information or request for an offer
In connection with information or a request for a proposal, CyCortex Kft. is considered the data controller.
Purpose of data management: providing appropriate information for the data subject and maintaining contact. The data manager allows the data subjects to request information or an offer related to the provision of services from the data manager via the website or the central email address by entering their details detailed below.
Legal basis: The request for information is based on voluntary consent.
Scope of stakeholders: All natural persons who contact the Data Controller and request information or an offer from the Data Controller in addition to providing their personal data.
Scope and purpose of processed data:
Full Name | Identification |
Email Address | contact |
Phone number | contact |
Company name | Identification |
Message | answering |
Who handles the data: The employees of the Data Controller can only handle the data to the extent absolutely necessary for the performance of their tasks.
Personal data is managed by the Data Controller, the data is not forwarded to other third parties.
The activity and process involved in data management are as follows
a. The data provided via the website will be sent to the data controller by e-mail. Emails requesting information or offers can also be sent to the central email address provided on the website. Incoming information requests are received by the Data Controller.
b.The Data Controller will answer the data subject’s question and deliver it to him – preferably by the same route as the request was received, if the data subject does not provide otherwise.
c. The data subject, in accordance with the purpose of the data management, voluntarily consents to the fact that, if he provided his contact information during the request for information, the data controllers will contact him so that the data subject can clarify the question or receive an answer.
Duration of data management: until the one-time request for information or offer is closed. If CyCortex Kft. establishes a business relationship with the applicant, the data protection information attached to the contracts will govern the handling of personal data. . In the event that the request for information and/or provision of information has a legal effect, or affects the data subject or data controllers to a similar extent, the Data Controller and the joint Data controllers will process the data until the applicable statute of limitations expires.
3.3. Recruitment process
If you apply for a job or internship via our website or email, CyCortex Kft. processes your personal data for the purpose of assessing your application and potentially entering into an employment or internship contract.
Types of personal data processed:
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Name
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Contact details (email address, phone number)
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Date and place of birth
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Educational background
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Previous employment history
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Any other information included in your CV (e.g., language skills, references)
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Any additional personal data you voluntarily provide (e.g., photo, motivation letter)
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Health-related information (if disclosed by you voluntarily)
Legal basis for processing:
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The primary legal basis is your explicit consent (Article 6(1)(a) GDPR), given when you submit your application.
Purpose of processing:
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To evaluate your application and suitability for the advertised position or internship.
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To potentially establish an employment or internship contract.
Data retention period:
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If your application is unsuccessful, your personal data will be deleted within 90 days after the position is filled or the recruitment process is closed.
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If you consent to being included in our candidate database for future opportunities, your data will be stored for a maximum of 2 years, after which it will be automatically deleted unless you renew your consent.
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If you are successfully hired, your personal data will be processed further under the terms of CyCortex’s employee privacy policy.
Other notes:
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Providing your data is voluntary, but necessary for us to consider your application.
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Your data will only be accessed by HR staff and the relevant hiring managers, and will not be disclosed to third parties without your consent.
4. References and links
The Data Controller’s website may also contain links that point to pages that are not operated by the Data Controller and are only for the information of visitors. The Data Controller has no influence on the content and security of the websites operated by the partner companies, so it is not responsible for them.
5. Website visit data
5.1 Google Analytics
The website uses Google Analytics, which is a web analysis service of Google Inc. (“Google”). Google Analytics uses so-called “Cookies”, which are text files that are stored on your computer and which enable the investigation of your use of the website.
The information created by the cookie (including the IP address) is transmitted to and stored on a Google server in the USA. Google uses this information to evaluate the use of the website and to prepare reports on website activity for the website operator, and to provide additional services related to websites and internet use.
Under no circumstances will Google associate your IP address with other Google data. You can block the installation of cookies by setting the Browser Software, however, we would like to draw your attention to the fact that in some cases you may not be able to use all the functions of the websites. The code set does not collect, store or transmit personal data. More information on the use and operation of the code set can be found on Google Support.
5.2 Hotjar
We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.
For further details, please see the ‘about Hotjar’ section of Hotjar’s support site .
6. Rights of data subjects
The data subject has the right to request information about the characteristics of data management defined in Articles 13 and 14 of the Regulation. CyCortex Kft. fulfills the data subject’s right to information in accordance with this Data Management Notice.
- The data subject has the right to access the data processed by CyCortex Kft. in relation to him (the affected person may request information on whether his personal data is being processed, and if such data processing is in progress, he is entitled to access the personal data and Article 15 of the Regulation get access to recorded information). The data subject may request a copy of the processed personal data. The first copy is free, CyCortex Kft. may charge a reasonable fee based on administrative costs for further copies. If the data subject submitted the request electronically, the information will be made available in an electronic format, via a secure channel, protected by a password, unless the data subject requests otherwise.
- The data subject has the right to request the correction of inaccurate data.
- If one of the following reasons exists, the data subject has the right to request that CyCortex Kft. delete his/her personal data without undue delay:
- the personal data are no longer needed for the purpose for which they were collected or otherwise processed
- the data subject objects to data processing and there is no overriding legal reason for data processing
- personal data has been processed unlawfully
- personal data must be deleted in order to fulfill the legal obligation prescribed by EU or member state law applicable to the data controller.
Deletion of data cannot be initiated if data management is necessary for the purpose of fulfilling an obligation under EU or member state law applicable to the data controller.
- In some cases, CyCortex does not delete the data, but restricts data processing to storage only. This may be the case
- where the data subject contests the accuracy of the personal data,
- where the processing is unlawful but the data subject does not wish to request the erasure of the data but only requests the restriction of the use of the data,
- where the purpose of the processing no longer exists but the data subject requests the processing for the exercise of a right,
- where the data subject has objected to the processing but CyCortex must assess whether CyCortex’s legitimate grounds override the data subject’s legitimate interests.
- The data subject has the right to receive the data processed by CyCortex and to request its transfer to another controller (right to data portability). The data subject has the right to receive the data provided by him/her in a structured, commonly used, machine-readable format, to transfer it to another controller and to request the direct transfer of his/her data to another controller.
- Where the processing is based on the data subject’s consent, the data subject may withdraw his or her consent at any time without giving reasons. Withdrawal of consent shall not affect the lawfulness of the processing carried out prior to the withdrawal.
- The data subject may object to the processing of his or her personal data,
- if it is based on legitimate interest, in which case processing shall not take place unless it is justified by compelling legitimate grounds relating to the protection of the interests, rights and freedoms of the data subject which override those of the data subject or for reasons connected with the establishment, exercise or defence of legal claims,
- if it is carried out for the purposes of or in connection with direct marketing; in such a case, the processing may no longer be carried out for such purposes.
- Remedies: If you have any complaints about your personal data, please contact CyCortex using one of the contact details set out in this notice in order to resolve your complaint amicably as soon as possible.
- Data Protection Authority procedure
You can also contact the Data Protection Authority using the following contact details to request an investigation into a claim or imminent threat of a breach of rights in relation to the processing of personal data:
Name: National Authority for Data Protection and Freedom of Information
Address: 9, Falk Miksa Street, 1055 Budapest, Hungary
Address for correspondence: 1530 Budapest, PO Box 5.
Phone: 06 – 1 – 391 – 1400
Fax: 06 – 1 – 391 – 1410
E-mail: [email protected]
Website: http://www.naih.hu - Right to apply to the courts
In the event of a violation of your rights, regardless of whether you have lodged a complaint, you may also bring an action against CyCortex before the competent court in the place where you reside. The court will decide the case out of turn.
7. How can you enforce your rights?
If you would like to contact us to exercise any of the above rights, please contact us using the contact details provided above.
If you notify us that you wish to exercise any of your rights, we will inform you of the action we have taken on your request without undue delay, but no later than one month after receipt of the request. If necessary, taking into account the complexity of the request and the number of requests, we may extend the time limit by a further two months. In any event, we will inform you of the extension, stating the reasons for the delay, within one month of receipt of the request. If you have submitted your request electronically, we will also reply electronically unless you explicitly indicate that you wish to receive a reply by other means.
If we consider that we do not need to take action on your request, we will inform you without delay, but at the latest within one month of receipt of your request, of the reasons for not doing so and of the possibility to lodge a complaint with the DPA and to exercise your right to judicial remedy.
8. Data security
CyCortex ensures the security of data. To this end, it has taken all technical and organizational measures necessary to enforce applicable legal regulations, data and secrecy protection rules.
CyCortex has taken all reasonable measures to protect the data from unauthorized access (protection of software and hardware devices), alteration, transmission, disclosure, deletion or destruction (regular backups, antivirus protection), as well as from accidental destruction and damage, and from becoming inaccessible due to changes in the applied technology.
9. Other Information
CyCortex does not perform profiling and does not make decisions based on automated data processing. CyCortex does not transfer the data of the data subject to any data controller located outside the EU.
10. Modification
CyCortex reserves the right to modify this notice. The modified and consolidated version of the Notice will be published on the website www.cycortex.com.
Sincerely,
CyCortex Team
