Privacy Policy

Spirity on privacy

We hereby commit to defend your personal data from any illegal use, data leaks, and data breaches.

We believe that we, as a provider of services, need to be as open and straightforward as possible regarding our usage of the personal data of our visitors and clients. We will do everything in our power to only forward your personal data to third parties who provide the adequate measures for safety and security that your personal data requires.

This policy explains how we collect and handle your personal data across our website, in as plain and simple a manner as possible.

We can only speak for ourselves, so this policy does not cover the collection or use of your information by any other service provider which we may feature on our website. That means when you go to a different service provider’s website using our website, your information will be processed by them in accordance with their own privacy policy and terms of service.

If you have any form of question or suggestion, please feel free to contact us at hello@spirity.hu

Data controller

Controller

Spirity Enterprise Zrt. (Plc.) — hereinafter “Spirity”

Headquarters

1117 Budapest, Október huszonharmadika utca 8-10., Hungary

Tax number

26633710-2-43

E-mail contact

hello@spirity.hu

Website

https://www.spirityenterprise.com

About Spirity’s data processing in general

• We use your data to provide you our services and to maintain, improve, and protect our infrastructure and services.
• We may also use your personal data based on your consent to send you our newsletter and offers, to contact you regarding our business and marketing messages, or to track your use of the website.
• The personal data will either be provided by you to us directly, or will be sent along with your internet usage.
• All personal data we have on you will be deleted or anonymized at most 90 days after it has been collected or ceased being relevant.
• We only use third parties and host data in countries which provide adequate security comparable to the GDPR’s requirements.

On reasons for using personal data

We use your personal data to provide you our services — to authenticate you as a client, provide you bills, and maintain and improve our infrastructure.

We use your personal data

• to send you bills,
• for sending you our newsletter or offers,
• to enhance the quality of our service and thus elevate your user experience,
• to protect your data and our infrastructure,
• to communicate with you.

Our legal bases

• To perform a contract with our clients, including billing.
• Because it is in our legitimate interest to understand our clients and to improve and secure our service — via anonymous usage and user parameter statistics, maintenance and security logs, and the use of anonymous statistics.
• Based on your consent, to receive newsletters and additional offers, or to track website usage.
• Based on our legitimate interest, to send marketing emails to company email addresses.
• Out of legal obligations that require personal data.

On collecting personal data

We only collect the personal data we actually use, and no more. This happens by you directly providing us your personal data, by us observing how you use the website, or by seeing the requests your desktop and browser send us.

You directly provide us with

• your contact information,
• your billing information,
• any data which constitutes personal data you type to us as a message.

We observe automatically during your visit

• IP address or your region,
• information about your device or browser,
• the website URL you visited us from,
• third-party sites you visit when you leave our website,
• vendors you search for.

We receive from third parties

• when you log on to our website from a social media platform,
• when you visit our website via a promotional partner,
• from public social media platforms (company email address and name only).

Our services are not intended for children under 16 years of age, and no one under the age of 16 should provide any information to, on, or via our services. We do not knowingly collect personal data from children under 16 and will delete any that we learn we have collected or received that was not provided by, or with express consent on behalf of, the child’s parent or legal guardian.

On retention periods

We only keep your personal data as long as we absolutely need to, or are required to by law — that is, for 365 days after collection, or for 30 days after you request to have your personal data or contract terminated. Legal requirements will usually prescribe longer periods.

To perform a contract for our clients

• To establish and maintain the business partnership between Spirity Zrt. and our clients.
• To manage billing, we keep relevant personal data for 8 years, based on requirements prescribed by invoicing regulations.
• To secure our service via backups, kept for 90 days.

Because it is in our legitimate interest

• For our visitors: to maintain and secure our infrastructure, with logs kept for 90 days.
• To understand clients and improve our services, via analyzing usage and user parameter statistics that we keep, after anonymizing, for an extended time — or until the data subject opts out.

You can contact us any time about deleting your personal data, and if there is no contractual or legal reason to keep it, we comply with your request as soon as possible.

On location of data storage

We store your personal data only where we are certain that the appropriate safety, security, and legal measures have been made. To make our lives easier and our services more affordable, we mainly use Wix.com Ltd’s storage services located in the EEA to host our infrastructure.

These servers are provided and/or supported by our contracted third parties acting under our instructions. We only process European users’ personal data outside the European Economic Area where a European Commission-approved method of validating the transfer has been put in place.

On personal data security

We respect your privacy, and safeguarding your personal data is embedded into our culture. We use a combination of industry-standard and good-practice methods to protect it.

Unfortunately, no website or app can guarantee complete security, but we put great effort into our application and data security. We use a range of technical, organizational, and administrative security measures proportionate to the risks of data processing. The computer systems we use to store your data have access limitations and are hosted with reputable vendors. We use encryption to protect your personal data when we transfer it across the internet and when we store it on our servers. We carry out security assessments and do due diligence on third-party vendors who handle your data.

To maintain a culture of privacy by design, we provide thorough data protection and privacy training to all Spirity employees. We develop our services with the goal of using the minimum amount of personal data possible, including through data minimization techniques such as anonymization and pseudonymization. Whenever we develop or update our services in ways that involve the collection or use of new forms of personal data, we conduct a balancing test to understand and reduce the likelihood of any unintended impact on you.

In addition to Spirity, in some cases the data may be accessible to certain types of persons in charge, involved with the operation of the website (administration, sales, marketing, legal, system administration) or to external parties — such as third-party technical service providers, mail carriers, hosting providers, IT companies, and communications agencies — appointed, where necessary, as data processors by Spirity. The updated list of these parties may be requested from Spirity at any time.

Miscellaneous information

Compliance with a legal obligation

Clients’ personal data may be used for legal purposes by Spirity in court, or in the stages leading to possible legal actions arising from improper use of the website or other related services. Clients and visitors declare to be aware that Spirity may be required to reveal personal data upon request of public authorities. Spirity only provides personal data if the requesting third party provides the proper and exact legal basis of its request.

Our legal claims

We may disclose your information where necessary to enforce the contract between Spirity and our clients or other agreements. We may also disclose your personal data if necessary to prevent, detect or prosecute illegal or suspected illegal activities, including fraud, or to prevent other damage, or where necessary in response to legally binding requests or legal action against us.

Maintenance and security logs

For operation and maintenance purposes, the website and third-party service providers may collect files that record interaction with the website and use other personal data (such as the IP address, or requests leading to errors) for this purpose.

About “Do Not Track” requests

Spirity does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honour “Do Not Track” requests, please read their privacy policies.

Changes to our privacy policy

Spirity reserves the right to make changes to this privacy policy at any time by giving notice to its clients on this page, and — as far as technically and legally feasible — by sending a notice to clients via any contact information available to Spirity. It is strongly recommended to check this page often, referring to the date of the last modification listed at the top.

On personal data of visitors

As a visitor of our website, we will collect personal data on you as it is sent to us from your device or browser, or as we can observe as you browse. Any personal data we have on you will be deleted at the latest 365 days after collection.

We use personal data of visitors out of our legitimate interest to provide quality and secure services to you. Based on your consent, we will also collect usage statistics from our analytical cookies, to understand how you use our site.

During your visit we collect

• IP address and your region,
• information about your device and browser,
• third-party sites you visit when you leave our website,
• personal data provided via free-text message as a letter with a subject and additional exact personal data (name, email address) — on the contact page.

This can be by means of deletion, as in the case of our security logs, or by anonymization, as for site statistics. If you become one of our clients, we will continue to store your personal data on the legal basis of performing a contract.

Rights and questions

You may exercise certain rights regarding your data processed by Spirity:

• Withdraw your consent at any time where you have previously given consent to the processing of personal data, such as for our newsletter or analytical cookies.
• Object to processing of your data if the processing is carried out on a legal basis other than consent. Where personal data is processed for the purposes of our legitimate interests, you may object by providing a ground related to your situation. Should your personal data be processed for direct marketing purposes, you can object at any time without providing any justification.
• Access your data — learn whether data is being processed by Spirity, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the data undergoing processing.
• Verify and seek rectification — verify the accuracy of your data and ask for it to be updated or corrected.
• Restrict the processing of your data under certain circumstances. In this case, Spirity will not process your data for any purpose other than storing it.
• Have your personal data deleted or otherwise removed, under certain circumstances.
• Lodge a complaint — bring a claim before your competent data protection authority.

Any request to exercise your rights can be directed to Spirity through the contact details provided in this document. These requests can be exercised free of charge and will be addressed as early as possible, and always within one month.

Cookie policy

Spirity uses cookies for greater user experience, to understand usage, and for statistics. We use cookies to collect information for use in line with the purposes set out in this privacy and cookie policy, and to record information about experiments or improvements we might test. Cookies on our website may be set by us or by third parties we work with.

Necessary cookies

These cannot be turned off. Necessary cookies enable core functionality; the website cannot function properly without them, and they can only be disabled by changing your browser preferences.

Analytical cookies

You can turn these on or off at any time. Analytical cookies help us improve our website by collecting and reporting information on its usage.

Google Analytics (Google LLC)

A web analysis service provided by Google LLC. Google utilizes the data collected to track and examine use of the website, prepare reports on its activities, and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network.

Personal data collected

Cookies and usage statistics.

Place of processing

United States / EU

Third parties

• We use cloud-based third-party vendors to make our service more affordable and secure.
• We only use third parties and host data in countries which provide adequate security comparable to the GDPR’s requirements.

We share personal data only if

• you explicitly authorize us to do so,
• it is necessary for our service — mostly for hosting and data storage,
• there are legal reasons (claims, or requests by authorities).

About our use of third-party data processors

These third parties only process your personal data under our instructions. We require all of our contracted third-party data processors to:

• process personal data only as instructed, or as we gave them explicit consent,
• have the necessary and obligatory security measures,
• demonstrate compliance with the applicable data protection laws,
• ensure authorized processing and confidentiality,
• only engage another processor with our acknowledgement,
• assist us in fulfilling our obligation as controller to respond to requests for exercising data subject rights.

We will put in place appropriate measures to ensure that personal data is adequately protected if the third-party data processor is outside of the European Economic Area.

Our third-party data processors

Email management and distribution

When you sign up to receive Spirity newsletters or other marketing messages, we manage the delivery using a third-party email distribution tool. Spirity uses RAPIDOPS, INC and Wix.com email management services.

Data aggregation and analytics

These enable us to monitor and optimize the delivery of our services. Spirity uses Google LLC, Wix.com, Microsoft Corporation and RAPIDOPS, INC analytical services.

Online cloud hosting and storage

These providers run our infrastructure and our code in scalable public cloud environments, and all our databases are hosted in public cloud environments. Spirity uses Wix.com Ltd. as cloud hosting and storage service provider — https://www.wix.com/about/privacy

The competent supervisory authority

For complaints and exercising your data subject rights, please first reach out to us at hello@spirity.hu. If we cannot adequately address your concern, you can contact the Hungarian National Authority for Data Protection and Freedom of Information.

Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH)

Hungarian National Authority for Data Protection and Freedom of Information

Address

H-1125 Budapest, Hungary, Szilágyi Erzsébet fasor 22/c.

Phone

+36 1 391 1400

Fax

+36 1 391 1410

E-mail

privacy@naih.hu or ugyfelszolgalat@naih.hu

Web

https://www.naih.hu

Terms, definitions and their meanings

The legal and technical terms used throughout this privacy policy.

Client

Any natural or legal person who enters into a contract with Spirity Enterprise Zrt.

Cookies

A cookie is a small data file stored on your computer or device. Cookies record things like your preferences and settings, helping give us the information we need to provide a consistent and relevant experience. They consist of portions of code installed in the browser that assist Spirity in providing our service. Some services for which cookies are installed may also require the visitor’s consent; where installation is based on consent, such consent can be freely withdrawn at any time.

Analytical cookies

Snippets of code placed in the page to measure things like clicks and other interactions. We use them to find out more about how you interact with our services, how you found our page, and more generally how you use us.

Data controller

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data, including the security measures concerning the operation and use of the website. The data controller, unless otherwise specified, is Spirity Enterprise Zrt.

Data processor

The natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller, as described in this privacy policy.

Data subject

The natural person to whom the personal data refers.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states of the European Union and the European Economic Area.

Personal data

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person. This includes information that may of itself identify you, such as your name, contact details, IP address, cookie strings or device IDs, as well as information that may not on its own identify you but which we store alongside such identifiers.

Service

All services provided by Spirity Enterprise Zrt.

Third party

Any natural or legal person who does not have a direct connection with a legal transaction but who might be affected by it. In the case of Spirity’s services, a third-party individual is a natural or legal person who is not in direct connection with the legal relations between Spirity and the data subject.

Usage statistics

Information collected automatically through the website (or third-party services employed in it), which can include: the IP addresses or domain names of the computers used by visitors, the URI addresses, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer, the country of origin, the features of the browser and operating system used, the various time details per visit, and the details about the path followed within the service. Usage statistics can be anonymous, or more detailed if you consent to the use of analytical cookies.

Visitor

A natural or legal person who visits the website or contacts Spirity.

Web beacons and pixels

Small, transparent image files inside a web page or email. We use them to understand how you interact with our services, or if you have been redirected to a different website or app. We also use pixels to gather information such as whether you have opened an email, so that we can improve our communications to you.