xLabs Hungary Kft. (head office: 1075 Budapest, Madách Imre út 13-14.); company registration number: Cg.01-09-184477; hereinafter: " xLabs ") hereby informs registrants for events, seminars and trainings organized by xLabs, including students, instructors and people participating in any other form (" Participants ") and visitors to the website www.xLabs.hu about the personal data it manages, about the principles and practices followed in the management of personal data, as well as about the method and possibilities of exercising the rights of the Participants.
1. Scope of personal data managed, purpose of data management, duration of data management
xLabs processes the personal data provided by the Participants for the following purposes:
1.1 Organization and conduct of the event.
Scope of processed personal data:
Personal identification and contact data: personal identification data, gender, citizenship, legal title of residence of a non-Hungarian citizen in Hungary and the document authorizing residence, name and number of the document, residential address, mailing address, electronic mail address and telephone number, social security identification number, tax identification number, educational identifier (the latter only and exclusively for the purpose of uploading to the adult education data service system).
Data related to the training, which the Participant:
- with his/her education, professional qualification, professional qualification and knowledge of foreign languages,
- by entering the training and completing the training, or in the absence of completing the training, leaving the training,
- evaluation and qualification during the training,
- they are related to your training-related payment obligations and the used training loan.
1.2 Data managed for the professional organization of training courses
Xlabs asks the Participants to provide the following information for the efficient professional conduct of the training and continuous development, as a result of which Xlabs processes the following data (in some cases, the information provided is not considered personal data):
- introductory text (Participant's education and workplace, long-term goals);
- image (Uploaded by Participant);
- image, video and audio recording (Uploaded by the Participant);
- goals, planned milestones (defined by the Participant);
- written/questionnaire feedback, feedback interviews, video interviews about the Participants, i.e. each other, about the instructors, about the training, about the mentors;
- professional (including research plans, research results, research documentation, sketches made on paper, online whiteboard (Miro) and design software (Figma), flowcharts, analyses, plans, screens, testing documentation, textual content, copy, comments, criticisms, opinions, test plans, test results, created during the individual and team work of the Participants.
Based on the above, Xlabs prepares an evaluation of the Participants, to which only xLabs and mentors/instructors have access.
2. Legal basis for data management
With the exception of the educational identifier, 1.1. The legal basis for data management according to point is the Fktv. Paragraph (1) of § 21. Regarding the educational identifier, the legal basis for data management (and transmission) is paragraph 21 (4) of the Fktv (only for the purpose of uploading to the adult education data service system - https://far.nive.hu/kezdolap).
The legal basis for data management according to point 1.2 is the Participant's consent to data management as a data subject in accordance with Act CXII of 2011 on the right to informational self-determination and freedom of information. Act (" Infotv .") § 5 (1) a.) and the European Parliament and the Council 2016 on the protection of personal data in terms of processing and the free flow of such data, as well as the repeal of Regulation 95/46/EC /679 (" GDPR ") according to Article 6 (1) a).
3. Access to data, data transmission, data security, data processing
Personal data can be accessed by xLabs employees and subcontractors participating in the organization of the training (mentors, trainers, professional leaders of the given training).
xLabs does not forward personal data to its other contractual partners and sponsors.
xLabs stores personal data on Google Workspace (meet.google.com, calendar.google.com, mail.google.com, drive.google.com) and Active Campaign (www.activecampaign.com) servers. xLabs requires data processors to regularly test the intrusion protection systems of their servers, to correct any discovered errors immediately, and their software solutions always use the latest possible security solutions, so that not only their servers but also their software itself is armed against intrusions. Two-step login ensures data security.
xLabs processes the data with automated data processing and uses the following service providers for this purpose:
Active Campaign (www.activecampaign.com), Szamlazz.hu (www.szamlazz.hu), Figma (www.figma.com), Miro ( www.miro.com ) Automat.io (www.automate.io), Zapier (www.zapier.com), Discord ( www.discord.com ), Make.io ( www.make.io ), Integrately (www.integrately.com)
xLabs takes the utmost care to avoid data protection incidents. It ensures maximum transparency for the Participant and the acting authorities in the event of any data protection incident.
1.1 above. data according to point can be used for statistical purposes and can be transferred to the Central Statistical Office in a way that is suitable for individual identification for statistical purposes and can be used for statistical purposes free of charge.
xLabs is Fktv. 20/A. § and § 21, paragraph (4), in fulfillment of his legal obligation, the Participant's gender, education ID, highest educational qualification, natural personal identification data (name, birth name, mother's name, place and time of birth, address, citizenship), electronic is obliged to provide data regarding his mailing address and tax identification number to the adult education state administration body in the adult education data provision system. The Participant may prohibit the transmission of this data (with the exception of the educational identifier, gender and highest educational qualification) in advance in writing or in a form suitable for recalling the contents of the statement unchanged, identifying the person who made the statement and the time of making the statement, but in this case the Participant acknowledges, that a certificate certifying the completion of the training cannot be issued to him in connection with the completion of the training. The Participant also acknowledges that Fkt. Xlabs is obliged to upload the data to the adult education data provision system provided for in § 21, paragraph (4) even if the Participant is banned, in which case the adult education data provision system will immediately delete the data after the generation of the educational identifier.
A cookie is a small text file that the visited website stores on the visitor's computer, the device used to browse the Internet. The visitor's device stores the cookie for a specified period of time. This allows the visited website to "remember" certain data and settings (e.g. language, font size and other display settings) for a specified period of time.
Legal basis for data management by cookies
xLabs uses the following cookies on its website www.xlabs.hu:
5. Right to remedy
The Participant may object to the handling of his personal data at any time even after giving his consent, request clarification of his personal data and request detailed information from xLabs on the way his personal data is handled, and may request the transfer of his personal data to a third party. Upon the Participant's request to delete or clarify personal data, xLabs will immediately take measures to clarify and delete the transmitted personal data.
In case of violation of the Participant's personal data, based on Infotv and the Civil Code (Act V of 2013):
i. to the National Data Protection and Freedom of Information Authority (address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c.; postal address: 1530 Budapest, Pf.: 5.; e-mail: email@example.com; phone: +36 (1) 391- 1400; website: www.naih.hu) can be contacted, or
ii. you can file an action to enforce your rights before the court of your place of residence or residence.
Before turning to the National Data Protection and Freedom of Information Authority or the court, please contact xLabs with the Participant's complaint first at any of the contact details listed in point 6 in order to investigate and remedy the complaint as soon as possible.
6. xLabs contact information
Mailing address: 1075 Budapest, Madách Imre út 13-14;
E-mail address: firstname.lastname@example.org;
Phone number: 06 70 773 86 63.
xLabs is not obliged to appoint a data protection officer.
xLabs reserves the right to change the regulations, or in the event of changes in the European Union or Hungarian legislation, to make appropriate amendments to the regulations, which will notify the Participants of such changes by e-mail.