Privacy Policy
Welcome to UDEMX’s privacy policy.
UDEMX respects your privacy and is committed to protecting your personal data. This privacy policy explains how we look after your personal data when you visit our website (regardless of where you visit it from) and tells you about your privacy rights and how the law protects you.
Last update: 22 July 2022.
Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how UDEMX collects and processes your personal data through your use of this website, including any data you may provide through this website.
This website is not intended for children and we do not knowingly collect data relating to children.
Please read this privacy policy together with any other privacy notice we may provide on specific occasions when we collect or process personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and is not intended to override them.
Controller
This privacy policy is issued on behalf of UDEMX Kft. When we mention UDEMX, “we”, “us” or “our”, we mean the company responsible for processing your data. UDEMX Kft. is the controller and responsible for this website.
Contact details
Email address: [email protected]
Postal address: 1089 Budapest, Elnök u. 1.
You have the right to make a complaint at any time to the Hungarian National Authority for Data Protection and Freedom of Information (www.naih.hu). We would, however, appreciate the chance to deal with your concerns before you approach the Authority, so please contact us first.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.
We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
The data we collect about you
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you, grouped as follows:
- Identity data: includes name.
- Contact data: includes email address.
We do not collect special categories of personal data about you (race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, genetic or biometric data). Nor do we collect information about criminal convictions and offences.
How is your personal data collected?
We use different methods to collect data from and about you, including through:
-
Direct interactions
You may give us your contact data by corresponding with us by post, phone, email or otherwise. This includes the personal data you provide when you give us feedback or contact us through website forms.
-
Third parties or publicly available sources
We may receive personal data about you from analytics providers such as Google.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly we use it:
- where we need to perform a contract we are about to enter into or have entered into with you;
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- where we need to comply with a legal obligation.
Generally we do not rely on consent as a legal basis for processing your personal data.
Purposes for which we will use your personal data
The table below describes the ways we plan to use your personal data and the legal bases we rely on. We have also identified our legitimate interests where appropriate.
We may process your personal data for more than one lawful ground depending on the specific purpose. Please contact us if you need details about the specific legal ground we rely on.
| Purpose / activity | Type of data | Lawful basis |
|---|---|---|
| To keep in touch with you as our customer or jobseeker | Contact | Performance of a contract with you |
| To manage our relationship with you, including notifying you about changes to our terms or privacy policy and asking you to leave a review or take a survey | Identity, Contact | Performance of a contract; legal obligation; legitimate interests (to keep our records updated and to study how customers use our services) |
| To administer and protect our business and this website (troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting) | Contact, Technical | Legitimate interests (running our business, IT services, network security, fraud prevention); legal obligation |
| To deliver relevant website content and measure or understand its effectiveness | Contact, Usage, Technical | Legitimate interests (to study how customers use our services, to develop them and to inform our marketing strategy) |
| To use data analytics to improve our website, services, marketing, customer relationships and experiences | Technical, Usage | Legitimate interests (to define types of customers, keep the website relevant, develop our business and inform our marketing strategy) |
HR
If you do not wish to be contacted with job opportunities that we believe may fit you after a closed application process, you can ask us to delete your data and not to reach out to you.
Change of purpose
We will only use your personal data for the purposes we collected it for, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Access is limited to employees, agents, contractors and other third parties who have a business need to know. They process personal data only on our instructions and are subject to a duty of confidentiality.
We have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator where we are legally required to do so.
Data retention
-
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including legal, regulatory, tax, accounting or reporting requirements. We may retain it for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation.
To determine the appropriate retention period we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, the purposes of processing and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see your legal rights below.
In some circumstances we will anonymise your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
If you wish to exercise any of the rights set out above, please contact us.
-
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
-
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take longer if your request is particularly complex or you have made a number of requests. In this case we will notify you and keep you updated.
Glossary
Lawful basis:
Legitimate interest means the interest of our business in conducting and managing our business to give you the best service and a secure experience. We consider and balance any potential impact on you and your rights before we process personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law).
Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Third parties
Third-party processors: our selected partners and service providers may process personal information about you on our behalf as described below.
External third parties
- Service providers acting as processors who provide software development, IT and system administration services.
- Digital marketing service providers — we periodically appoint digital marketing agents to conduct marketing activity on our behalf. Our current marketing agent is Prospect Global Ltd (trading as Sopro). You can view their privacy policy at sopro.io. Their Data Protection Officer can be emailed at [email protected].
- Professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors, insurers and recruitment agencies based in Hungary.
On behalf of the company the cloud-based processors listed below manage personal data:
| Third parties | Tasks of processor | Managed personal data |
|---|---|---|
| Cookie and analytics services | Personal data according to the Google Analytics privacy policy | |
| Business and employment-oriented online service | CV files and personal data according to the LinkedIn privacy policy | |
| Business online services | Personal data according to the Facebook privacy policy |
Your legal rights
You have the right to:
- Request access to your personal data (a data subject access request), so that you can receive a copy of the personal data we hold about you and check that we are lawfully processing it.
- Request correction of the personal data that we hold about you, so that incomplete or inaccurate data can be corrected. We may need to verify the accuracy of the new data you provide.
- Request erasure of your personal data where there is no good reason for us continuing to process it, where you have objected to processing, where we may have processed it unlawfully, or where we must erase it to comply with local law. We may not always be able to comply for specific legal reasons, which we will tell you about if applicable.
- Object to processing where we are relying on a legitimate interest and something about your particular situation makes you want to object. In some cases we may demonstrate compelling legitimate grounds that override your rights and freedoms.
- Request restriction of processing, for example if you want us to establish the data’s accuracy, if our use is unlawful but you do not want us to erase it, if you need us to hold it for legal claims, or if you have objected and we need to verify overriding grounds.
- Request the transfer of your personal data to you or to a third party in a structured, commonly used, machine-readable format. This right applies to automated information which you provided consent for, or which we used to perform a contract with you.