HARD DOG RACE Kft. (head office: 1036 Budapest, Lajos utca 78., business registry number: 01-09-291006) henceforth referred to as Data Handler (the organiser of the Race) and Trendline Kft. (head office: 1092 Budapest, Ráday u. 24/b., business registry number: 01-09-560558) henceforth: Operator, in accordance with Act CXII of 2011, are liable to the contents of this document, and accept responsibility to ensure that all data management related to their services conforms to the relevant laws and to the rules specified in the present document.
The Data Handler shall pay special attention to the protection of the privacy of their partners and clients and respect their rights to informational sovereignty. Therefore, the Data Handler guarantees to do everything in their power to ensure that all personal data provided to them will be handled discretely and safely.
This document is always available at www.harddograce.eu/rules-of-privacy-protection, however the Data Handler reserves the right to change the contents at any time. Those affected by these changes are notified via the website’s announcement.
The terms used in this Privacy Protection Policy carry the following meanings in accordance with Information Law (3) and Provision (4):
subject: any particular natural person identified or – directly or indirectly – identifiable based on personal data (Inform. Law 3 (1)); a natural person is identifiable who can be identified directly or indirectly – especially based on personal data pertaining to personal identification – via one or more factors (Provision 4, Article 1).
personal data: any information related to the subject – especially any identifier e.g. name, number, location data, devices, applications, online identifiers made available by devices and protocols (IP, cookie) used by the subject, or other identifiers (e.g. radio frequency identifiers – RFID) (Provision (30, preamble)), or knowledge pertaining to the physical, physiological, genetical, mental, economic, cultural or social identity – and all conclusions drawn from the former that are related to the subject (Inform. Law 3 (2), Provision 4, Article 1).
Data handler: natural or legal person or organisation with no legal representation, who – on their own or in cooperation with other parties – determines the goals and methods of data management, makes the decisions and executes actions related to data handling (including the tools used), or has their commissioned data processor execute them; (Inform Law 3 (9), Provision 4 (Article 7)).
Data handling: any action or series of actions applied on the data – especially collection, recording, organising, storage, change, use, request, allowing a third party to examine it, publication, linking to other information, limitation, closure, deletion or destruction, as well as prevention of further use of the data, taking photographic, audio or video recordings and recording physical characteristics suitable to identify a person (e.g. fingerprints or palm prints, DNA sample, iris image) – regardless of the methodology applied (Inform. Law 3 (10), Provision 4, Article 2).
Data processing: performing technical tasks pertaining to data handling actions, regardless of the methods and tools used for execution of said actions and of the place of action, as long as the technical tasks are performed on the data (Inform. Law 3 (17)).
Data processor: natural or legal person, organisation with no legal representation, public authority organisation, agency or any other entity that, based on their contract made with the Data Handler – including contracts made due to being required by law – processes personal data on behalf of the Data Handler (Inform Law 3 (18), Provision 4, Article 8).
Third party: natural or legal person or organisation with no legal representation that is neither the subject, the Data Handler or the Data Processor (Inform. Law 3 (22)), or persons working under the direct supervision of the Data Handler or Data Processor, authorised to handle personal data (Provision 4 (10));
Approval: voluntary and unambiguous statement of the subject resulting from factual and relevant information being previously provided to them. By giving this statement, the subject grants their unequivocal consent for their personal data to be – in whole or extending to certain operations – handled;
Data forwarding: making data accessible to a specified third party (Inform. Law 3 (11));
Data deletion: rendering data unrecognisable to the point where their restoration is no longer possible; (Inform. Law, 3 (13))
Objection: the subject’s statement wherewith they object to the handling of their personal data, and request the cancellation of the data handling and the deletion of managed data; (Inform. Law, 3 (8)) data protection incident: a breach in security which results in accidental or unlawful deletion, loss, change, unauthorised communication or unauthorised access to forwarded, stored or otherwise handled personal data.
RULES CONCERNING PERSONAL DATA HANDLING AND DATA PROVISION
Goal of data handling: The Data Handler and the Operator handles the subject’s personal data exclusively in order to be able to organise the Race and in accordance with the pertaining laws.
Scope of the handled personal data: the Racer’s data as specified on the application website: name, place and date of birth, mother’s name, postal address, e-mail address, telephone number, telephone number of the person to be notified in case of accident, dog’s data: name, chip number, vaccination book or dog passport number, and possible taxes or other charges. Data required for invoicing and other possible data necessary for payment by the organiser.
Data acquired during Registrations are confidential. The Operator in charge of data processing may use them to facilitate the Race’s execution. Apart from the Operator, only the data handler, that is, the Organiser may have access to the data.
The subject is responsible for the veracity of all data that do not violate their third party rights.
Racers automatically agree to and accept the Rules of Competition and the Rules of Privacy Protection by competing, and they also agree to the following:
- a) data provision is voluntary, data handling is made possible by the voluntary contribution of data; the racer provides their consent to data handling by competing in the Race, finishing the application process and providing the personal data voluntarily;
- b) data process is carried out by the Operator;
- c) the Organiser may make use of the racers’ personal data and personal information free of charge to execute and document the race;
- d) The racer, by accepting the Rules, accepts that the Data Handler or the Operator will send newsletters and information regarding the next race to the e-mail address provided during application.
- The Organiser, as the Data Handler of Hard Dog Race events, enables the Racers to have their data stored, so that they are not required to record their data for each subsequent race. If the Racer does not wish to have their data stored, they may initiate deletion of all their data after the Race is closed.
- The Organizer, as the Data Handler of Hard Dog Race events, shall forward the received personal data to their contracted franchise partner in relation to the given race. In this regard, the franchise partner qualifies as a data processor.
The legal basis of data handling is the subject’s approval, in accordance with the Inform. Law 5 (1, a) and Provision Article 6 (1, a).
Duration of data handling: Until revoked by the subject or a maximum of 8 years.
The Data Handler provides a newsletter (targeted commercial mail) service. The Data Handler provides the possibility to subjects to, should they so wish, receive newsletters on the services available and related news.
The goal of data handling is to inform subjects and to maintain contact with them to facilitate sending information – by delivering the newsletters to the subjects. The Data Handler shall send news and offers via online newsletters and direct marketing messages to those who subscribe for them.
Legal basis for data handling: the subject’s approval in accordance with the following: Inform. Law 5 (1, a); Business Adv. Law 6 (1); Electr. Trade Law 13/A (4) and Provision Article 6 (1, a).
Sending newsletters, in accordance with Business Adv. Law 6 (1) requires the previous, unambiguous and express approval of the visitor of the website. To approve marketing newsletters, the subject has to submit the approval statement received from the Data Handler, or accepting the terms of the Data Handling Information by selecting the appropriate checkbox and clicking the “Subscribe” button on online interfaces (website, mobil application, webshop). When subscribing electronically, the subject receives feedback on their successful subscription.
Scope of the handled personal data: To sign up for a newsletter, the subject must supply their name and email address. The name is needed to start communications with them, the email address is necessary to maintain contact.
The subject is responsible for the veracity of all data that do not violate their third party rights.
Duration of data handling: Until revoked by the subject or a maximum of 8 years. The Data Handler manages a registry of people who have approved newsletters to be sent to them. If the subject revokes their approval for data handling for marketing purposes, the Data Handler deletes the subject’s personal data from their registry and from their newsletter database if applicable. Unsubscribing is made possible via a direct link in all newsletters, and the Data Handler’s website also features an Unsubscribe from newsletters option.
In regards to sending newsletters, the Organiser qualifies as Data Handler, whereas the Operator and the franchise partner(s) for the race in question qualify as data processors.
A third party shall not be granted access to the data without the Data Owner (Racer) being previously informed and them giving their permission – excluding cases where withholding said data would violate the law.
The Organiser guarantees that data handling shall be carried out in adherence with the relevant legal requirements. In regards to the subject’s data handling rights and opportunities for judicial remedy, refer to Act CXII of 2011 on Informational Self-determination and Freedom of Information (henceforth: Inform. Law). For more information about the protection of personal data of natural persons and free flow of such data, refer to Regulation 2016/679 of the European Parliament. In accordance to the aforementioned laws, the Racer may request correction of their personal data or limitation of data handling, object against how their personal data is processed, or ask for information about the methods of data processing. The subject also has the right to receive their personal data in a machine-readable format or forward this data to another data processor if the data handling is based on their approval and performed in an automatised manner. Racers who wish to have their data deleted or changed in the database may request this at any time without limitation and justification, free of charge via the email@example.com address or via post (to the Organiser’s address). In both cases, the subject must be: Hard Dog Race event [time of the race] data deletion. The Racer shall accept that deletion of their data from the system while the Race is open results in their disqualification from the race, as the Organiser cannot ensure the Racer’s participation without their data.
Cookie handling: Cookies are small text-based data files sent from the website to your computer that is stored on your hard disk drive. This data is stored by the browser and is sent back to the website while you are browsing it. There are cookies that are deleted when the browser is closed, and ones that are called every time you open the website that sent it to your computer. The cookie includes the website’s name, the cookies’s name, value and its duration. You may configure the preferences for accepting or refusing cookies in your browser’s settings.
For the sake of adverts and statistics appearing on the Data Handler’s website, a third party (e.g. Google) may place cookies on your computer. One goal of this is to display ads more relevant to you, or to be able to make a statistic of the visitors of the website and their browsing activities.
Data Handler’s contact information:
Data Handler’s name: HARD DOG RACE Kft.
Data Handler’s address: 1024 Budapest, Lövőház utca 2-6., 4. em.,
Data Handler’s electronic mailing address used for maintaining contact: firstname.lastname@example.org
Business registry no.: 01-09-291006
Tax no.: 25820922-2-41
Name of registering authority: Fővárosi Törvényszék Cégbírósága
Telephone: +36 20 529 2110
Data Protection registry no.: NAIH-112808/2017.
The Organiser is liable to conform to their duties specified by Act CXIX of 1995 of management of name and address data for the purposes of direct marketing and research.
Participants have the right to protest against the handling of their data. The Organiser is liable to examine the complaint as soon as possible but within a maximum of 15 days, makes a decision on its validity, and informs the complainant in writing.
Subject’s right to judicial remedy:
If the subject disagrees with a decision made by the Data Handler, they may refer to the court within 30 days of being informed of said decision.
Inquiries about judicial remedy or complaints are to be referred to the National Authority for Data Protection and Freedom of Information:
Data protection incidents must be communicated to the supervisory authority (NAIH) – by the Data Handler without unwarranted delay – within 72 hours – except if the incident in question carries no risks in regards to the rights of natural persons. If the data protection incident carries a high risk in regards to the rights and freedoms of natural persons, the Data Handler informs the concerned party of the incident in question without undue delay.
The Organiser has informed the National Agency for Data Protection of the data management specified by the Rules of Competition; the Agency has registered it under the file NAIH-112808/2017.
By this document, HARD DOG RACE Kft. has fulfilled its duties for preliminary information, as specified by the Act CXII of 2011 of informational self-determination and freedom of information.
The Rules of Privacy Protection has been prepared in Hungarian, English, Polish, Czech, Slovenian, Italian and German languages.
In case of linguistic or interpretational problems, the Hungarian version of the document prevails.
Budapest, 10 July 2018
HARD DOG RACE Kft.