According to the statements of Articles 6-III and 19 of Law No. 2004-575 of 21 June 2004 for the Confidence in the digital economy, known as LCEN, we bring to the attention of users and visitors of the site spaddicthome.com following information:
Owner Status: company
Company Name: Triniti Europe KFT
Address: Rózsa utca 38 / A. fszt., Budapest H-107, Hungary
Company Number: 01 09 342275
Company Director: Myroslav Shemshei
Email Address: firstname.lastname@example.org
Site Builder: Triniti Europe KFT
Publishing Manager: Triniti Europe KFT
Responsible Person for the publication: email@example.com
Responsible Person for the publication as a legal person:
Webmaster: Triniti Europe KFT
Contact the Webmaster: firstname.lastname@example.org
Consent of the data subject/user is any freely given, specific, informed and unambiguous indication of the data subject/user`s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Data subject/user is an identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing; a user to the Triniti Europe KFT Service.
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Personal data means any information relating to an identified or identifiable natural person (“data subject/user”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
In this title described the privacy practices for the Website operated by spaddicthome.com (hereinafter "Website" if singular, or, "Websites") and how the Website operated by Triniti Europe KFT collect and use the personal data you provide on Triniti Europe KFT Website, with the purpose to use Triniti Europe KFT Service. It also describes the choices accessible to you regarding our use of your personal details and how you can handle this information.
The visit of the Website can be accessed without any indication of personal data; however, if a user wants to use Triniti Europe KFT Service via our Website, collecting and processing of personal records could become necessary. If the processing of personal data is necessary we generally obtain agreement from the user as a data subject.
Based on Art 37/1 of the GDPR regulation, Triniti Europe KFT isn’t required to appoint a Data Protection Officer (DPO). However, there is a person in charge of GDPR implementation at Triniti Europe KFT and which will address all questions, queries, and requests on this topic. This person can be reached by email at email@example.com.
As the controller, Triniti Europe KFT has accomplished extensive technical and organizational measures to ensure the most complete protection of personal data processed through this Website.
Provision of our Service generally not aimed at children. This Website is not premeditated for use by children under the age of 18.
If you object to the changes, please contact us as provided below.
Data Types We Collect and the Ways We Use Them
The only data types we collect are marketing data vital for updates or promotional offers, and minimal personal information (name, address, telephone number & email address). No such data are disclosed to the third parties; they are treated as anonymous statistics.
Cookies Usage Control
Some browsers will let you block cookies that do not meet your privacy preferences. If necessary, you can stop accepting new cookies, be notified when you receive a new cookie, and disable existing cookies. Disabling all cookies could significantly affect your web browsing, rendering it’s impossible to take full advantage of all of our website features. Be aware that some parts of our websites require your accepting cookies for it to work in a proper mode. Cookies can be removed or declined by changing your web browser settings any time you wish. For more information, please visit www.allaboutcookies.org and/or www.youronlinechoices.com.
Clients who access the website from locations outside of the European Union are responsible for compliance with local laws if and to the extent that local laws are applicable.
Processors and Controllers
The GDPR also introduces two parties when it comes to collecting and processing personal data: data controllers and data processors.
A data controller governs the purposes and ways that personal data is processed. Triniti Europe KFT customers, be they organizations or individuals, are data controllers.
Triniti Europe KFT is consequently considered in the new GDPR as a data processor in the sense that it will process your personal data and is responsible to make sure that all processors with whom it deals will be GDPR compliant.
PERSONAL DATA GATHERING AND USE
We tend to be compliant with GDPR and implemented the data minimization principle. Personal data, as defined above, which we collect, consist of:
1) full name (first and last);
2) e-mail address, providing the data subject with the ability to register an account and become a user of our Service with the purpose to use the Triniti Europe KFT Service correspondingly;
3) billing information, which includes full address, zip code, city, country, telephone number;
4) payment method (not full credit card number and expiration date);
5) IP address – assigned by the Internet service provider (ISP) and used by the data subject/user;
6) location data – for statistics of user’s areas involvement.
When you purchase Triniti Europe KFT Service you have to fill the User’s Information, which should contain your personal information as ID (first name, last name) and email, which is processed and stored by Triniti Europe KFT.
You also have to fill the Billing Information, which should contain your Personal data, which is partly stored by Triniti Europe KFT and processed by the payment providers.
We may use your Personal Data to:
A. improve your browsing experience by personalizing the Website and to improve the Service;
B. send information to you by email regarding registration status, password verification, payment confirmation;
C. send you communications relating to your use of the Service and materials/content being Service;
D. provide our partners with statistical information about our users by secured channels under data processing agreements (DPA).
INFORMATION THAT IS AUTOMATICALLY COLLECTED. COOKIES. LOG FILES. PIXEL TAGS
We also collect and save information that is generated automatically as you navigate through our Website to expand your experience on our Website by using tracking technologies as Cookies, Log Files and Pixel tags.
If you do not wish to receive Cookies you may be able to refuse them by adjusting your browser settings to reject Cookies.
Triniti Europe KFT also may use Pixel tags (single-pixel image files also known as transparent GIFs, clear GIFs or web beacons) to access Cookies and to count users who visit the Website or open our HTML-formatted e-mail messages.
The data subject may, at any time, prevent the setting of cookies through our Website by means of corresponding settings of the Internet browser used, and may thus permanently deny the setting of Cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other Service programs.
We use cookie technology as part of our web site’s statistical reporting. Cookies are central to the customization of the internet and online behavioral advertising. We gather statistical data on which pages are visited, what is downloaded, the Internet provider’s domain name and country of the visitors, as well as the addresses of sites visited immediately before, and after, coming to Triniti Europe KFT.
Google Analytics helps us measure the effectiveness of our advertising, as well as the simplicity and efficiency of our site’s usage.
Triniti Europe KFT considers your use of its Service to be private. However, we may disclose your personal information stored in your account and/or on Triniti Europe KFT servers and databases, in order to:
· comply with the law or legal process served on us;
· investigate potential fraudulent activities;
· protect the rights, property, or safety of Triniti Europe KFT, its employees, its customers or the public.
We may share Information Gathering with third parties, including strategic partners, for marketing and promotional purposes under concluded data processing agreements, which secure the transfer and processing of personal data according to GDPR.
The controller may also transfer to one or more processors (e.g. a payment provider under DPA) personal data of a data subject for payment processing purpose, which is attributable to the controller and without which a user would not be able to purchase the Service and use Triniti Europe KFT Service.
As we use third-party technological services for the provision of Services, we may transfer your personal date internationally. Providers of such technological services may process personal data collected in the course of providing us their services as sub-processors only under DPA in accordance with GDPR.
However, the encryption is useless if the access password or other credentials are weakly protected and stored by the data subject. In this case, the controller is not responsible for a personal data breach.
In the case, of a personal data breach, the controller shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the competent supervisory authority.
In case there might be a risk of unauthorized disclosure of personal data the controller communicates the personal data breach to the data subject without undue delay. However, as the controller has implemented appropriate technical and organizational protection measures, as encryption, and it was applied to the personal data affected by the personal data breach, the controller is not required to communicate the data subject.
Routine Erasure and Personal Data Blocking
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of Service provision, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
Period For Which the Personal Data Will be Preserved
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After the expiration of that period and when we no longer need personal data, we routinely and securely delete or demolish it, as long as it is no longer necessary for a purpose.
RIGHTS OF THE PERSONAL DATA OWNER
Right to rectification
Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Right to erasure
Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
· The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
· The data subject withdraws consent to which the processing is based according to a point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
· The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
Right of restriction of processing
Each data subject shall have the right granted by the European legislator to get a restriction of processing from the controller where one of the following applies:
· The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
· The processing is unlawful and the data subject inhibits the erasure of the personal data and requests instead of the restriction of their use instead.
· The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
The data subject has objected to processing agreeably to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
Right to data portability
Each the data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which is provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority authorized in the controller.
Right of access
Each data subject shall have the right granted by the European legislator to get information from the controller about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
· the purposes of the processing;
· the categories of personal data concerned;
· the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
· where possible, the required period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
· the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
· the existence of the right to lodge a complaint with a supervisory authority;
· where the personal data are not collected from the data subject, any available information as to their source.
The existence of automated decision-making, including profiling, referred to in Article 22.1. and 22.4 of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
Right to object
Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
Right of confirmation
Each data subject shall have the right granted by the European legislator to get a confirmation from the controller as to whether or not personal data concerning him or her are being processed.
Last update: 13.06.2019