INFORMATION ON PROCESSING OF PERSONAL DATA

The owner of the portal www.edumodul.hu, (hereinafter referred to as: „Website”) is Rejtett Kincsek Down Egyesület (hereinafter referred to as „Operator”) having regard to Regulation (EU) no. 679 of 27 April 2016, on the protection of individuals with regard to their personal data and on the free movement of such data and repealing Directive 95/46 / EC (hereinafter “GDPR”), as well as the provisions of Law CXII / 2011 on the freedom of informing and information, the Operator informs the individuals who provide the Operator with personal data within the Erasmus + program under number 2018-1-HU01-KA201-047777, entitled "Developing the skills of children with atypical development through online support ”(hereinafter referred to as the“ Project ”), the following:

Data of personal data operator:

Rejtett Kincsek Down Egyesület 

Registration number: 15-02-0001646 

Registered at: Nyíregyháza court
Place: 4400 Nyíregyháza Közép street 17, Hungary 
VAT: 18801370-1-15  
Represented by: Kisari Károly, president
E-mail: info@rejtettkincsek.hu 
Phone: 0036 (42) 444-321 

Types of data processed, purpose of processing, legality of processing and period of data storage

1. Regarding the personal data of specialists who upload e-learning educational materials (hereinafter: "EM") on the Website:

Type of data processed	Purpose of processing	Legality of processing	Period of data storage
Data specified by the person concerned before loading EM, at the time of registration, as well: • name, first name* • e-mail address* • personal data specified in the introductory presentation *	The operator processes the personal data made available to him in order to draw up the contract, to define and modify its content, as well as to monitor its fulfillment.	The basis for processing is the conclusion and performance of the contract, in accordance with Article 6 para.(1) (b) of the GDPR.	The operator stores personal data during the contract concluded with the data subject, respectively after the end of the contract, at most until the expiration of the request validation term.
Data specified by the data subject before loading EM, at registration: • name, first name	The operator processes the personal data made available to him in order to display the name of the data subject on the registration platform of the Website, among the names of the specialists.	The basis of the processing shall be the consent of the data subject in accordance with Article 6 para.(1) (a) of the GDPR.	The operator stores personal data until the withdrawal of consent, but no later than 31.10.2025.
Data specified by the data subject before loading EM, at registration: • e-mail address	The operator processes the personal data made available to him in order to send newsletters to the data subject.	The basis of the processing shall be the consent of the data subject in accordance with Article 6 para. (1) (a) of the GDPR.	The operator stores personal data until the data subject unsubscribes.

Providing the personal data specified with * is a prerequisite for concluding the contract. In the absence of this data, EM cannot be uploaded to the Website.

2. Regarding the personal data of the children, respectively of the persons holding the parental responsibility over the child who is involved in testing the word recognition module on the Website:

Type of data processed	Purpose of processing	Legality of processing	Period of data storage
Data specified by the data subject at the time of registration for participation in the test, as well as: • e-mail address* • name* • country and place of residence * • telephone no.	The operator processes the personal data made available to it in order to test the operation, use and efficiency of the online e-learning platform on the Website, respectively in order to compile statistics that support the development of the platform.	The basis of the processing shall be the consent of the data subject in accordance with Article 6 para. (1) (a) of the GDPR.	The operator stores personal data until the completion of testing the module uploaded to the Website, ie until 30.04.2020.
Data specified by the data subject at the time of registration for participation in the test, as well as: • child’s name* • DOB* • the level of intellectual development of the child * (has or does not have mental retardation, is or is not able to group objects according to form, communicates or not through words, knows or not to read)	The operator processes the personal data made available to it in order to test the operation, use and efficiency of the online e-learning platform on the Website, respectively in order to compile statistics that support the development of the platform.	The basis for processing is the consent of the holder of parental responsibility over the child, in accordance with Article 8 (1), defined in Article 9 (2) (a) of the GDPR.	The operator stores personal data until the completion of testing the module uploaded to the Website, ie until 30.04.2020.
Data provided by the data subject recorded during the public event organized in connection with the Project, such as: • photo of the data subject • photo of the child	The Operator processes the personal data made available to him in order to fulfill the tasks assumed in the contract concluded in connection with the Project.	The basis of the processing is the fulfillment of the legal obligation incumbent on the Operator, according to Article 6 (1) point c) of the GDPR.	The operator stores personal data no later than 31.10.2025.

Providing the personal data specified with * is a prerequisite for participation in the test. In the absence of this data, the test module cannot be completed.

3. Regarding the personal data of the children, respectively of the persons holding the parental responsibility over the child who through the Website participate in the evaluation of the level of development and development activities:

Type of data processed	Purpose of processing	Legality of processing	Period of data storage
The data specified by the data subject in making the registration necessary to participate in the assessment of the level of development and development activities, such as: • name* • home address*	The Operator processes the personal data made available to it in order to prove the indicators assumed in the contract concluded in connection with the Project.	The basis of the processing is the fulfillment of the legal obligation incumbent on the Operator, according to Article 6 (1) point c) of the GDPR.	The operator stores personal data no later than 31.10.2025.
The data specified by the data subject in making the registration necessary to participate in the assessment of the level of development and development activities, such as: • child's name*	The operator processes the personal data made available to him in order to prove the indicators assumed in the contract concluded in connection with the Project.	The basis of the processing is the fulfillment of the legal obligation incumbent on the Operator, according to Article 6 (1) point c) of the GDPR.	The operator stores personal data no later than 31.10.2025.
Data provided by the data subject recorded during the public event organized in connection with the Project, such as: • photo of the data subject • photo of the child	The Operator processes the personal data made available to him in order to fulfill the tasks assumed in the contract concluded in connection with the Project.	The basis of the processing is the fulfillment of the legal obligation incumbent on the Operator, according to Article 6 (1) point c) of the GDPR.	The operator stores personal data no later than 31.10.2025.
Data provided by the data subject recorded during the public event organized in connection with the Project, such as: photo, voice of the data subject photo* ,voice* of the child	The Operator processes the personal data made available to him in order to fulfill the tasks assumed in the contract concluded in connection with the Project.	The basis of the processing is the fulfillment of the legal obligation incumbent on the Operator, according to Article 6 (1) point c) of the GDPR.	The operator stores personal data no later than 31.10.2025.

Providing personal data specified with * is a prerequisite for participation in the assessment of the level of development and development activities. In the absence of these data, it is not possible to assess the level of development.

4. Regarding the personal data of the visitors of the Website, who accept the use of Cookies on the Website:

Type of data processed	Purpose of processing	Legality of processing	Period of data storage
Cookies that store the personal data of the data subject are listed in the following table:	The operator collects the data obtained in this way in order to improve the user experience of the Website, respectively to monitor the browsing habits on the Website.	The basis of the processing shall be the consent of the data subject in accordance with Article 6 (1) (a) of the GDPR.	Personal data processed in this way are deleted according to the specifications in the table below.

Name	Value	Expires	Domain
KCFINDER_displaySettings	off	10 months	site_domain
KCFINDER_order	name	10 months	site_domain
KCFINDER_orderDesc	off	10 months	site_domain
KCFINDER_showname	on	10 months	site_domain
KCFINDER_showsize	off	10 months	site_domain
KCFINDER_showtime	off	10 months	site_domain
KCFINDER_view	thumbs	10 months	site_domain
ci_session	56b045c5b664346313856b4c33f0ffd107faf7e4	1 hour	site_domain
csrf_cookie_name	b3efb566abf933ffbebad701c2ec44b4	1 hour	site_domain

The operator informs the data subjects that through cookies, on the occasion of the processing of personal data, profiles are created, in case the data subject expresses his / her explicit consent by pressing the Ok button. displayed in a pop-up system on the Website.

Data access and data transfer: The Operator shall have access to the personal data made available to the Operator, for the purposes mentioned above for each type of data mentioned above.

Measures for data protection: The operator shall store the personal data made available to him on the computer at his premises. For the storage of the personal database, the Operator collaborates with the following data storage service provider as a data processor:

MediaCenter Hungary Ltd., 6000 Kecskemét, Sosztakovics street no. 3. II/6., Hungary
Postal address: 6001 Kecskemét, Cp. 588, Hungary
E-mail: mediacenter@mediacenter.hu, Tel.: 76 / 575-023

The operator shall take appropriate measures to protect the personal data made available to him, inter alia, from any unauthorized access to or modification thereof.

The rights of the data subject related to the processing of personal data

The Operator shall inform the data subjects that where the processing is based on Article 6 (1) (a) or Article 9 (2) (a) of the GDPR, the data subject has the right to withdraw consent at any time, without affect the legality of the processing carried out on the basis of the consent before its withdrawal.

The request submitted by a data subject related to the exercise of the rights listed below, will be analyzed by the Operator as soon as it is received, but not more than 25 days and will inform the data subject about the decision taken in writing or if the data subject has submitted the application in electronic format, electronically.

The controller will respond to the data subject's request related to the exercise of his / her rights regarding the processing of personal data listed below, without charging a fee, unless the data subject
a) in the current year, repeatedly submits a request for the same type of data and
b) upon request The operator has a legal basis not to rectify, delete or restrict the processing of his personal data.

Access right

The data subject has the right to be informed by the Operator about the fact that his personal data are being processed, and if they are, he has the right to obtain access to personal data and the following information:

a)   the purposes for which the personal data are processed;
b) the categories of personal data concerned;
c)   the recipients or categories of recipients of personal data, to whom the Operator has communicated or will communicate these data;
d)   in certain cases, the period for which the personal data will be stored;
e) the right of the data subject to request from the Operator, regarding the personal data regarding the data subject, their rectification or deletion or the restriction of the processing or the right to oppose the processing;
f) the right to lodge a complaint with a supervisory authority;
g)   if personal data are not collected from the data subject, any available information on their source.

The right to rectify
The operator, in case of a request from the data subject, will rectify the inaccurate personal data concerning him, without undue delay. The data subject has the right to request the completion of personal data that are incomplete, including by providing an additional statement.

The right to erasure of data (“the right to be forgotten”)
The operator shall delete the data subject's personal data without undue delay if one of the following reasons applies:
a)   personal data are no longer necessary for the purposes for which they were collected or processed;
b)   the data subject withdraws the consent on the basis of which the processing takes place (if the processing was based on consent), and there is no other legal basis for the processing;
c)   the data subject opposes the processing and there are no legitimate reasons prevailing in respect of the processing (such as, for example, processing based on a legitimate interest);
d) personal data have been processed illegally;
e)   personal data must be deleted in order to comply with a legal obligation incumbent on the Operator under Union or national law under which the Operator is subject.

The Operator will not process the request for deletion of personal data from the data subject if the processing is necessary in order to fulfill the legal obligations regarding the processing of personal data, applicable by the Operator.
If the Operator receives a request for the deletion of personal data, as a first step, the Operator will analyze whether the request for deletion really comes from the data subject. In this regard, the Operator may request the identification data of the legal relationship between the Operator and the data subject (such as number, contract date), the identification data of the data subject it records (but the Operator may not request additional data to identify about the person concerned, which he does not record).
If the Operator has to comply with the request to delete the data, he is obliged to do everything possible to delete the personal data from all databases.
The operator will record the deletion of the data in order to prove that the deletion has been performed. The register will be signed by the Operator. The data deletion register includes:
a)   name of data subject
b) the category of deleted personal data
c)   date of delition.

The right to restrict processing
The operator shall, at the request of the data subject, restrict the processing of data in the following cases:
a)   the data subject disputes the accuracy of the data, for a period that allows the Operator to verify the accuracy of the data;
b)   the processing is illegal, and the data subject opposes the deletion of personal data, requesting in return the restriction of their use;
c)   the controller no longer needs the personal data for the purpose of processing, but the data subject requests them for the establishment, exercise or defense of a right in court; or
f)   the data subject objected to the processing; in this case the restriction shall apply for the period of time during which it is verified whether the legitimate rights of the Operator prevail over those of the data subject.
Where processing has been restricted, such personal data may, except in the case of storage, be processed only with the consent of the data subject or for the establishment, exercise or defense of a right in court or for the protection of the rights of another natural or legal person. or for reasons of important public interest of the Union or of a Member State.

The right to opposition
If the data subject objects to the processing, the controller may no longer process personal data, unless the controller demonstrates that he has legitimate and compelling reasons justifying the processing and prevailing over the interests, rights and freedoms of the data subject or that the purpose is the finding, exercise or defense of a right in court.

The right to data portability

The right to data portability belongs to the data subject in the case of the processing of personal data based on consent or a contract, if the processing is carried out by automatic means.

The Operator shall make available to the data subject personal data concerning him and which he has provided to the Operator in a structured, commonly used and automatically readable format, so that the data subject may transmit this data to another operator.

Possibilities to exercise the rights related to the processing of personal data 

The right to submit a complaint with an authority: In order to exercise his rights, the data subject
a) may request an investigation into the lawfulness of the processing of data by the Operator, if the Operator limits him in exercising the rights listed above or refuses his request regarding the exercise of these rights, also
b) may request the investigation of the data protection authority, if in the process of processing his personal data the Operator does not comply with the provisions of GDPR.

Contact details of the Supervisory Authority:

Official name: Nemzeti Adatvédelmi és Információszabadság Hatóság
Office: 1125 Budapest, Szilágyi Erzsébet fasor 22/c, Hungary
Postal address: 1530 Budapest, Cp.: 5., Hungary
Telephone: +36 (1) 391-1400
Fax: +36 (1) 391-1410
E-mail: ugyfelszolgalat@naih.hu
Website: http://www.naih.hu

The right to go to court: The data subject, in case of illegitimate processing of his personal data may file a civil lawsuit against the Operator. The process is within the jurisdiction of the court. The process - depending on the option of the data subject - can also be initiated at the court within the domicile of the data subject (the list of courts and the related contact details can be consulted on the page: http://birosag.hu/torvenyszekek).

This information on the processing of personal data can be accessed on the page www.edumodul.hu.