Information about cookies on the website

CyberShield Consulting Hungary Ltd. (hereinafter: Data Controller) uses so-called cookies on  the www.cybershieldconsulting.hu website.

Contact details of the data controller:

Name: CyberShield Consulting Hungary Kft.
E-mail: info@cybershieldconsulting.hu or info@csch.hu
HQ: 1148 Budapest, Kerepesi street 78/E

The data protection terms used in this notice are those defined in Article 4 of Regulation (EU) 2016/679 of the European Parliament and of the Council 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 (hereinafter: GDPR), and Act CXII of 2011 on Informational Self-Determination and Freedom of Information (Information Act.) shall be interpreted in accordance with the definitions supplemented.

About cookies in general:

A cookie is a file that can be placed on a computer or browsing device when the data subject (visitor) visits  a website (in this case, the  Data Controller’s website). A cookie is a small file, data package in the source code of the website, which is downloaded to the user’s device during browsing and stored in the browser itself. Cookies facilitate the use of the website, help the website to provide a real web experience and an efficient source of information for the data subjects, and provide the Data Controller, as the operator of the website, with the control of its operation, the prevention of abuse and the uninterrupted and adequate provision of the services provided on the website.

Cookies have multiple functions and can be used for multiple purposes, such as:

  • collect information about the data subject or his device,
  • remember certain individual settings of the data subject,
  • may be used for online transactions, or
  • may be used to optimize and target advertising content on the website and other websites.

1. Basic information on the circumstances of data processing

Accepting and enabling cookies is not mandatory for all cookies. The data subject can refuse the use of cookies based on consent through the settings of his computer or other device used for browsing, or of the browser used to access the website. There are also cookies that are essential for the smooth operation of the website, so they  are installed on the data subject’s device  even without the consent of the data subject.

Please be informed that the Data Controller does not have access to the data/information stored on  the data subject’s device in any way.

The party setting the cookie can be:

  • The Data Controller: these cookies are placed directly on the Data Controller’s device by the Data Controller’s website, only the Data Controller can read them and access the information stored in the cookies
  • Third party: These cookies are placed on the website by third parties other than the Data Controller. If the Data Controller decides to embed elements of other websites into its website, when the website is accessed, these third-party cookies are not placed on the device of the data subject by the visited website, but by a third party (cookie manager), an advertiser or the provider of an analytical (analytical) system (e.g. Meta, Google). These third parties may obtain information about your  browsing of the website visited by the data subject. When third-party cookies are placed, the website that places the cookies acts as an intermediary, and only the third party that places the cookie has access to the information stored in the cookie and transmitted by the cookie,  but not the Data Controller.

Types of cookies used on the Data Controller’s websites:

Detailed and up-to-date information about cookies can be found in the “Details” menu item of the pop-up window on the website, which provides information about the operation and types of cookies used on our websites, the associated retention periods, the service providers who place them, and the availability of their privacy policy. On the same interface, you can refuse the processing of cookies at any time, except for data processing purpose 1 (functional cookies). (Figure 1)

Figure 1

You can withdraw your consent to previous data processing at any time by clicking on the icon in the lower corner of the website, during which the pop-up window will become available again. (Figure 2)

coockiebot ikon

Figure 2

The consent given for data processing may be withdrawn at any time, but this does not affect the lawfulness of data processing based on consent before its withdrawal. If you contact us regarding your previous informed consent, please refer to your consent ID, which you can access by displaying Details by clicking on the icon icon in Figure 2 on the website. (Figure 3)

Figure 3

Purposes of individual data processing:

  • In order to facilitate the flawless technical and technical operation of the website, the Data Controller uses necessary (or essential) cookies.
  • In order to continuously develop, optimize the website and improve the customer experience, the Data Controller uses analytical/statistical cookies.
  • The Data Controller uses marketing cookies to facilitate its marketing activities (promotion of its products and services, targeting personalized offers).

Data processed by the Data Controller:
The following data are recorded and processed by cookies about the data subject, the computer used by the data subject, and the device used for browsing:

  • IP address of the device used by the data subject,
  • browser type,
  • characteristics of the operating system of the device used for browsing (e.g. type, language setting),
  • the exact date of the visit,
  • the address of the previously visited page,
  • the page, subpage, function or service visited,
  • time spent on the site.

Legal basis for processing certain types of cookies:

The legal basis for the use of necessary cookies is Article 6 (1) (f) GDPR, according to which processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. In this case, it is in the  legitimate interest of the Data Controller to ensure the proper functioning of its website both technically and technically.

Please be informed that in the case of data processing where the legal basis for data processing is a legitimate interest pursuant to Article 6 (1) (f) of the GDPR, the data subject is entitled to exercise his or her right to object specified in Article 21 of the GDPR prior to the commencement of data processing and during all stages of data processing by sending an e-mail to info@csch.hu.hu.

The legal basis for the use of analytical/statistical and marketing cookies is the voluntary and explicit consent of the data subject to data processing pursuant to  Article 6 (1) (a) GDPR.

Transfer of data to third countries
or some third-party cookies, personal data contained in cookies is transferred outside the European Economic Area (EEA). Detailed information on the data management of third-party cookies (pop-up window, Details) can be found in the description of each cookie, from which the data subject can obtain information about how third parties process the  personal data of the data subject.

II. Rights related to data processing and possibilities of enforcement

Rights of the data subject in relation to the processing of his or her personal data

The Data Controller shall comply with the request or request of  the data subject related to the exercise of his or her rights related to this data processing  without undue delay, but in any event no later than one month after receipt, unless this deadline is extended by a further two months due to the complexity of the request or the number of requests. The Data Controller shall inform the data subject of the extension of the deadline within one month of receipt of the request, indicating the reasons for the delay.

The data subject can change the settings of analytical/statistical and marketing cookies at any time in the cookie settings menu item of the website. In addition, the data subject may use the “Do not track” function in his or her browser at any time. In the most commonly used browser types, this feature can be set in the following places.


In any event, the data subject shall have the right to information and access, on the basis of which the data subject  shall have the right to obtain from the Data Controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to:

  • personal data processed,
  • the categories of personal data concerned,
  • the purposes of data processing,
  • to the recipients or categories of recipients to whom the personal data have  been or will be disclosed by the Data Controller,
  • where possible, the envisaged period for which the personal data will be stored, or, if that is not possible, the criteria used to determine that period,
  • information that the data subject may request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning him or her and object to processing of such personal data.
  • to inform you of the right to lodge a complaint with a supervisory authority,
  • if the Data Controller has not collected the data from the data subject, to all available information as to their source,
  • the existence of automated decision-making (including profiling) and, in these cases, the logic involved, the significance of such processing and the envisaged consequences for the data subject.

 

The data subject has the right to object to the use of necessary cookies at the commencement of data processing and throughout its lifetime, on the basis of which the data subject has the right to object, on grounds relating to his or her particular situation, at any time to processing of his or her personal data based on legitimate interest, including profiling based on those provisions. In this case, the Data Controller shall no longer process the personal data unless the Data Controller demonstrates that the processing is justified by compelling legitimate interests which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

In relation to this data processing, the data subject may  exercise his or her right to erasure, on the basis of which the data subject may request that the Data Controller erase personal data concerning him or her without undue delay if:

  • the personal data are no longer necessary by the Data Controller in relation to the purposes for which they were collected or otherwise processed,
  • the data subject withdraws his/her consent and there is no other legal basis for the processing,
  • the data subject objects to the processing and there are no overriding legitimate grounds for the processing,
  • the personal data have been unlawfully processed,
  • the personal data must be deleted in order to comply with a legal obligation to which the Data Controller is subject,
  • the personal data have been collected in connection with the offer of information society services.


The right to erasure can only be exercised in relation to purpose 1 of this Privacy Policy.

Enforcement options for the data subject in relation to this data processing

If you consider the way the Data Controller handles your personal data to be violating, we recommend that you first address your inquiry at one of the contact details provided by the Data Controller at the beginning of this notice or contact the Data Protection Officer. We will always investigate your complaint and do our best to handle it properly. If, despite your complaint, you continue to complain about the way the Data Controller handles your personal data, you have the following legal remedies.

Right to lodge a complaint with a supervisory authority:

Without prejudice to any other administrative or judicial remedy, every data subject shall have the right to  lodge a complaint with the National Authority for Data Protection and Freedom of Information (hereinafter: supervisory authority) if he or she considers that the Data Controller or the data processor entrusted by him or her  has committed an infringement or caused a threat thereof.

Contact details of the National Authority for Data Protection and Freedom of Information:

  • Address: 1055 Budapest, Falk Miksa street 9-11.
  • Mailing address:1363 Budapest, Pf. 9.
  • Phone number: (06 1) 391 1400
  • E-mail: ugyfelszolgalat@naih.hu

 

Right  to an effective judicial remedy against the Data Controller or the processor engaged by the controller:

Without prejudice to any available administrative or non-judicial remedy, including the right to lodge a complaint with a supervisory authority, each data subject shall have the right to an effective judicial remedy if he or she considers that his or her rights in relation to the processing of his or her personal data have been infringed.

The trial falls within the jurisdiction of the tribunal. The data subject may decide to bring the action before the court of his/her domicile or residence.

You  can access the list of tribunals  under the web address: https://birosag.hu/torvenyszekek.

Effective from: 06/03/2024

CyberShield Consulting Hungary Kft.