Effective from: November 1, 2022
1. Introduction
Compliance with current data protection regulations and laws is of great importance to us; therefore, we detail below the steps we take regarding data protection and the processes associated with data collection.
Data Controller Details:
Name: GLOBSERVER Kft.
Tax ID: 13663236241
Address: 1037 Budapest, Bojtár utca 34.
Contact: info@globserver.eu
2. Types of personal data and their legal basis
Personal data: data that clearly allows for the precise identification of an individual. We process the following personal data on the site, specifying the exact legal basis for each:
COMMUNICATION DATA
This includes any message sent to us via the website, email, social media messages, or any other form of communication. We process and retain this data to fulfill orders and to provide a basis for decision-making in the event of potential legal claims.
Our legal basis for this processing is the user’s demonstrable interest in our activities, as manifested in the messages addressed to us. USER DATA
This includes data generated during the use of the website that enables its technical operation, ensures site security, allows for the storage of records regarding user activity, and ensures you have access to the most relevant content possible.
The legal basis for processing this data is the user’s clear interest in our activities; storing this data is necessary to facilitate these activities and ensure the technical functioning of the site.
TECHNICAL DATA
This includes data generated during the use of the site, such as IP addresses, login information, browser details, time spent on specific pages, page views and navigation paths, the frequency and timing of visits, time zones, and details of the device used to view the site. This data is sourced from our analytics software. We process this data to analyze user behavior on the site, maintain secure operations, and evaluate the effectiveness of our marketing decisions.
The legal basis for processing this data is the user’s clear interest in our activities, which allows us to process this data in compliance with security standards and utilize it to grow the business and improve operational efficiency.
MARKETING DATA
This includes visitor preferences regarding the types of marketing content they wish to receive from us. We process this data to enable participation in prize draws and to send advertisements related to the products or services in which the user has expressed interest.
The legal basis for processing this data is the user’s clear interest in our activities, which allows us to process the data in compliance with security standards and utilize it to grow our business and operate more effectively.
We may occasionally use the collected data for purposes such as delivering targeted, relevant advertisements on the Facebook™ platform and various dynamic advertising channels, as well as for measuring the effectiveness of these advertisements.
The legal basis for processing this data is the user’s clear interest in our activities, which allows us to process the data in compliance with security standards and utilize it to grow our business and operate more effectively.
In the course of our operations, we do NOT collect sensitive data such as ethnicity, religious beliefs, sexual life and orientation, political opinions, trade union membership, health history, or genetic or biometric information.
3. Methods of data collection
We may collect personal data directly provided by the user (for example, by sending a message). Furthermore, certain data is collected automatically during the use of the site, such as through “cookies” and similar technologies. These only become active after the user has given their consent. For more information, please consult our Cookie Statement.
We receive certain data from external partners, such as analytics providers like Google (a non-EU partner) and advertising networks like Facebook™ (a non-EU partner).
4. Our practical steps regarding data protection
Protecting user data and complying with applicable regulations are of utmost importance to the Seller and/or the Data Controller. Therefore:
– Following a data protection impact assessment conducted for the site, we have compiled a list of the collected data, their necessity, their legal basis, and their statutory compliance. As protecting user data and complying with applicable regulations are paramount to the Data Controller and the Seller, we treat data protection as a top priority and have made significant efforts to ensure the secure collection of information by the site.
– To protect data provided via forms and data generated on the site, we employ SSL certification across the entire website (Let’s Encrypt Authority X3 certification).
– To protect the site against attacks, we use premium security software (Wordfence Security) to safeguard stored data against threats such as “brute force” and virus attacks.
– Purchase and user data within the site’s databases are stored in an encrypted (pseudonymized) format, rendering them unreadable to third parties.
– Through this privacy statement, we provide users with the means—via forms—to request information regarding the processing of their personal data, or to modify or delete their personal data.
– From time to time, it is necessary for our business operations to share data with our service partners (e.g., hosting providers, courier companies, newsletter software providers). In such cases, we always select partners who comply with GDPR requirements; for US-based partners, this includes participation in the EU-US Privacy Shield framework. We also require them to sign a data processing agreement to ensure the responsible handling of data.
5. Marketing communication
Engaging in marketing communication is essential to our business operations. The legal basis for the associated data processing is either an expression of interest in our services or the user’s explicit consent. In accordance with the European Union’s Privacy and Electronic Communications Regulations (PECR), we send marketing messages to users who have made a purchase from us or have explicitly consented to receive such messages.
We always provide a clearly visible way to withdraw consent and unsubscribe from messages. An unsubscribe link is included at the bottom of every email, or users may request removal from our database via the email address listed on our contact page. Even after unsubscribing from marketing communications, we may still send messages, but only those related to the fulfillment of orders. 6. Notes regarding personal data
It is sometimes necessary to share certain personal data with specific partners to maintain normal business operations:
– IT service providers and providers performing troubleshooting and maintenance on computer systems
– Expert partners, such as lawyers, accountants, bankers, and insurers
– Government bodies requesting reports on our activities
International data transfers
To maintain business operations, we may sometimes need to share user data with service partners located outside the European Economic Area (EEA). Countries outside the EEA often do not provide the same level of data protection; therefore, European laws prohibit the transfer of data unless appropriate conditions are met. Whenever personal data is transferred outside the EEA, in addition to the measures discussed in Section 4, we take the following steps to ensure the secure handling of data:
– We transfer data only to countries deemed adequate by the European Commission in terms of data security.
– We use only US-based services that participate in the EU-US Privacy Shield data security initiative.
If the above conditions are not met, we will seek the user’s explicit consent for the data transfer. Consent may be withdrawn at any time. Links to external sites
This site occasionally contains links to external websites or embedded code snippets that facilitate the operation of external services. Clicking these links or using the embedded solutions may allow external partners to collect data about users. While we make every effort to properly vet our partners, we have no control over their privacy policies and are not responsible for their data handling practices.
7. Duration of data processing
We store user data only for as long as required by our legal, accounting, or reporting obligations, or as necessary for the operation of the service. When determining the retention period, we consider the volume, nature, and sensitivity of the data, as well as the potential impact of a data breach.
For tax purposes, we are required to retain customers’ billing and purchase data for at least 8 years to comply with our legal obligations. Under certain circumstances, we may use the data in an anonymized form for statistical purposes; in such cases, we may store the data indefinitely without further notice.
8. Visitor rights
As citizens of the European Union, users of the site are granted the following rights under the General Data Protection Regulation (GDPR):
a) Access to personal data
Users of the site have the right to request a copy of the personal data stored by our website. Requests are generally fulfilled free of charge within 14 days of the request. In the event of repeated, abusive, or unjustified requests, the seller may charge a reasonable fee for providing the data, and additional time may be required to fulfill the request.
Furthermore, the seller and/or data controller requires proof of identity before releasing data to prevent misuse. To request personal data, please email us at the address found on our contact page.
b) Modification of personal data
If personal data has changed or was provided incorrectly, users have the right to request a modification of the data. To modify personal data, please contact us via the email address found on our contact page.
c) Request for deletion of personal data
Users have the right to request the deletion of all their personal data. We fulfill such requests free of charge within 14 days of the request. Once personal data is deleted, the user account will no longer be accessible; consequently, any purchased materials will also become inaccessible, as the personal data linked to the user account is essential for accessing the service. The seller and/or data controller requires proof of identity prior to the deletion of personal data to prevent misuse. To request the deletion of personal data, please contact us via the email address found on our contact page.
d) Request to restrict the processing of personal data
Users have the right to request a restriction on the sharing of their data with third parties (service partners). When submitting the request, users may specify which service partners are to be restricted. It is important to note that cooperation with certain service partners is essential for the operation of the site (e.g., Paylike as a payment service provider); therefore, restricting these partners will render the site’s services inaccessible to the user. The seller and/or data controller requires proof of identity prior to restricting the processing of personal data in order to prevent misuse. To request a restriction on the processing of your personal data, please contact us via the email address provided on our contact page.
The official authority responsible for data protection in Hungary is the National Authority for Data Protection and Freedom of Information (NAIH). Users can find further information regarding their data protection rights on the NAIH website.
National Authority for Data Protection and Freedom of Information (NAIH),
1125 Budapest, Szilágyi Erzsébet fasor 22/C, Postal address: 1530 Budapest, P.O. Box 5,
Phone: +36 1 391 1400,
Fax: +36 1 391 1410,
E-mail: ugyfelszolgalat@naih.hu
Website: http://www.naih.hu
9. Anonymized data and “cookies”
The website uses so-called “cookies” and similar technologies—such as tracking codes, remarketing tags, and pixels—in email messages and advertisements; these become active following the user’s consent. These technologies help us better understand user behavior and interests, thereby enabling us to operate more effectively and provide a higher quality of service. Our goal is to make the use of our website as user-friendly and personalized as possible. If the user wishes to prevent these technologies from recording non-personal data, this can be done in the following ways:
-by disabling their loading via the cookie notices displayed on the website
-by disabling cookies in the browser