DATA PROCESSING REGARDING THE OPERATION OF THE WEBSITE
1. GENERAL INFORMATION
Data Controller: VR Storm Studio Kft. (registered office:17/A Világos utca, Szeged 6725, Hungary; registration number: 06-09-026845).
Data Subject: Data Subject shall mean the visitor of Data Controller’s website (www.beanstalkergame.com; hereinafter referred: “Website”).
Personal Data: means any information relating to the Data Subject.
- The Data Controller is committed to the protection of the Data Subject’s personal data and particularly wishes to observe the Data Subject’s fundamental right to informational self- determination.
- processes the personal data lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);
- collects personal data for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (‘purpose limitation’);
- processes personal data that are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimization’);
- processes accurate and up to date data (’accuracy’);
- keep personal data in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (‘storage limitation’);
- processes the personal data in a manner that ensures appropriate security of the personal data (‘integrity and confidentiality’).
1.5. Data Controller’s data processing principles are in harmony with the relevant data protection regulations as effective, including but not limited to the following:
- The Constitution of Hungary (Freedom and Responsibility, Article VI);
- Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 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 (General Data Protection Regulation – “GDPR”)
- Act No. CXII of 2011 on the right to informational self-determination and on informational freedom (“Info Act”);
- Act No. V of 2013 on the Civil
2. DATA PROCESSING
- The Data Controller strives to limit its personal data processing activity to what is absolutely necessary. Nonetheless, the processing of some personal data is inevitable. The Data Controller processes the personal data that the Data Subject provides, as well as all the personal data generated during the visit of the Website. Data Controller processes the following personal data for the purposes and on the legal basis detailed below:
- Purpose of the data processing: Collecting personal data to contact the potential clients. Data Subject may provide his/her personal data to the Controller via the Website to require further information on the available
- List of processed personal data: name, email address, phone number, written communication between the
- Optional personal data: email address, name, phone number,
- Legal basis for the data processing: Data processing is necessary in order to take steps at the request of the data subject prior to entering into a contract (GDPR 1. (b) of Article 6).
- Duration of data processing: The contact data will be deleted after 2 (general limitation period)
- Provision of personal data: Data Subject is not obliged to provide the personal data, but without providing the personal data, the Data Controller cannot contact the Data Subject.
Data Subject may reject cookies on his/her computer, or on other devices used for browsing, or in the settings of the web browser (typically in Tool / Settings / Privacy / Cookies) Data Subject is using to access the Website. Should cookies be rejected, Data Subject will not be able to fully utilize the functionality and services of the Website, and – as a consequence – Data Controller cannot guarantee full, smooth and uninterrupted use of the Website. Data Subject may find more information on cookies at the European Interactive Digital Advertising Alliance’s Website.
- necessary cookies: their use is essential for navigating the Website and for the functionality of the Website. Without these, the Website, or parts of it, may not appear or may appear incorrectly. Website owner store necessary cookies based on Directive 2002/58/EC;
- functional cookies: the purpose of these cookies is to improve the user experience
e.g. by remembering the device the user used for browsing, the language settings, the custom settings;
- statistics cookies: statistic cookies are collected anonymously; they help to understand how visitors interact with the Website;
- marketing cookies: these cookies collect detailed information about the user’s browsing habits and are used to deliver advertised content to the user. These cookies are placed on the Website by third party service
The Website uses Google Analytics cookies. These cookies are set by external services and
- are under the control of the third-party service, not the Data Controller;
- can be accessed on any website that makes use of the service;
- can be used to track a user from one site to another;
- enable Data Controller to deliver more relevant advertising to
You may find more information on Google Analytics cookies at the following Websites
Cookies used on the Website:
Function Name Purpose Cookie Expires
Tracking cookie for Google Analytics
_ga (Google Analytics)
Time period of each visit
Until the end of session
- Purpose of the data processing: To send offers in the future to the Data
- List of processed personal data: name, email address, telephone number;
- Legal basis for the data processing: The Data Subject has given consent to the processing of his or her personal data (GDPR 1. (a) of Article 6).
- Duration of the data processing: The Data Controller processes the data until the withdrawal of the consent, but not more than 10
- The Data Controller does not use automated decision-making, including
- Disable, enable, restrict cookies
You have complete control over your browsing data. Such data includes your browsing and download history, cached data, cookies, passwords and saved form data. By clicking on “Clear browsing data” in the dialog box, you can delete all data and have the option to delete a data set collected over a certain period.
The steps required to clear your cache and cookies may vary by browser and program versions.
Get more information in the following link: https://support.google.com/google-ads/answer/32050?hl=hu&rd=1
2.3.1 How to delete cookies – in case of Google Chrome
Click the wrench icon on the browser toolbar. Select Settings. Click the Show advanced settings’ link in blue at the bottom of the page. In the Privacy section, click Content Options. To delete all cookies, in the Cookies section, click on “All cookies and website data…” option, then the stored cookies have been listed, click the “Remove All” option. If you want Google Chrome to automatically delete cookies when you close your browser windows, select the “Delete cookies and other plug-in and website data when I close my browser” checkbox in the section of Content Settings dialog / Cookies. You can also set up exceptions, so that cookies from specified websites are always deleted when you close your browser.
3. OTHER DATA PROCESSING
- The Data Subject is informed that the court, the public prosecutor, the criminal investigation authority, the infringements authority, the public administration authority, the National Data Protection and Informational Freedom Authority (“NAIH”), as well as other authorities authorized by legal regulation may request information, data and documents from the Data Controller, who will grant such requests to the extent it is required by the relevant legal regulations. The Data Controller will disclose personal data to the authorities only to the extent it is indispensable for the fulfilment of the authorities’ meticulously detailed request for information as regards the scope and purpose of
4. DATA PROCESSORS
- The Data Controller assigns the following data processor during its data processing activity:
- The Rocket Science Group, LLC (MailChimp), seat: 675 Ponce de Leon Ave NE, Suite 5000 Atlanta, GA 30308 USA, mailing address: 675 Ponce de Leon Ave NE, Suite 5000 Atlanta, GA 30308 USA, registration number: 20161685162, Tax ID: US EIN 58-2554149; office phone: +1 678 999 0141, email: firstname.lastname@example.org, website: https://mailchimp.com/
5. PROCESSING OF THIRD PARTIES’ DATA
- If the Data Subject provides personal data from third parties, Data Subject must have the required consent or other legal basis to share the personal data with the Data Controller and informs Data Controller of any change or update relating to them. All Data Subjects should refrain from providing third parties’ data, unless it is necessary to comply with the contract with the Data Controller. Data Subject is fully liable for these third parties’ personal data processing.
6. DATA SECURITY
- The Data Controller treats the Data Subject’s personal data confidentially, therefore Data Controller has adopted the technical and organizational measures necessary to ensure the security of personal data and avoid their accidental or unlawful destruction, loss, alteration,
processing or unauthorized access, given the state of the technology, the nature of the stored data and the risks to which they are exposed, whether they come from human action or from the physical or natural environment. The Data Controller selects and operates the IT equipment used to process personal data with respect to the contractual relationship in such a way that the processed data:
- is available to authorized persons (availability);
- authenticity and authentication are ensured (authenticity of data processing); (c)integrity can be proven (integrity of data); and
(d)is protected against unauthorized access (confidentiality of data).
7. RIGHTS AND REMEDIES
- The Data Subject has the right to:
- access the personal data: Upon the Data Subject’s request, the Data Controller supplies information about the Data Subject’s data processed by the Data Controller as data controller and/or processed by a data processor on the Data Controller’s behalf if any of the conditions stipulated in Article 15 of GDPR is
- request the rectification of the personal data: The Data Controller rectifies the Data Subject’s personal data if such data is inaccurate or incomplete while the correct personal data is available to the Data
- request the erasure of the personal data (right to be forgotten): The Data Controller erases any and all personal data if any of the conditions stipulated in Article 17 of GDPR is
- restriction of processing: The Data Subject obtains from the Data Controller the limitation of the data processing if any of the conditions stipulated in Article 18 of GDPR is fulfilled.
- data portability: The Data Subject receives the personal data concerning him or her, which he or she has provided to the Data Controller, in a structured, commonly used and machine-readable format, if the processing is based on a consent or contract and it is carried out by automated means.
7.2. The Data Controller provides information on action taken on the Data Subject’s request sent to the contract person specified in Section 2.7. without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, considering the complexity and number of the requests. The Data Controller informs the Data Subject of any such extension within one month of receipt of the request, together with the reasons for the delay. Where the Data Subject makes the request by electronic means, the information will be provided by electronic means where possible, unless otherwise requested by the Data Subject. If the Data Controller does not act on the Data Subject’s request, the Data Controller will inform the Data Subject without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.
- Data Subject’s right to remedy:
- filing a complaint with the authority: Without prejudice to any other administrative or judicial remedy, Data Subject may, in the event of an infringement of his or her rights, file a complaint with the data protection authority (Nemzeti Adatvédelmi és
Információszabadság Hatóság: address: 22/c Szilágyi Erzsébet fasor, Budapest 1125, Hungary; Office phone: +36 1 391 1400, Fax: +36 1 391 1410,
email: email@example.com; website: https://naih.hu/index.html).
- filing a complaint with the court: Without prejudice to any available administrative or non-judicial remedy, including the right to lodge a complaint with a supervisory authority, Data Subjects have the right to an effective judicial remedy where he or she considers that his or her rights have been infringed as a result of the processing of his or her personal data in non-compliance with the data protection regulation. The Data Controller is liable for any loss or damage caused by the unlawful processing of the Data Subject’s data or by any violation of applicable data-security requirements. The Data Controller will be exempted from such liability if the loss or damage was caused by circumstances beyond its control and outside the scope of data processing. No compensation shall be paid to the extent that the loss or damage was caused by the Data Subject’s willful or grossly negligent