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Privacy Notice
Last updated: 25 May, 2018
This Privacy Notice is provided to you by XET Kereskedelmi és Szolgáltató Korlátolt Felelősségű Társaság (registration number: 01-09-186623, tax number: 24865690-2-43, registered seat: 1115 Budapest, Fraknó utca 8., B épület, I/4., Hungary, hereinafter “XET Kft.”) in order to inform you as a user of XET Kft. services about the data processing and data protection policy of XET Kft. in concise, easily accessible, clear and plain language.
This Privacy Notice has been prepared in Hungarian and English languages. By accepting the provisions of such Privacy Notice you also accept that in case of any discrepancies between the Hungarian and English versions the Hungarian version shall prevail.
Data processing principles, controller, processors
XET Kft. adheres to the following principles when processing data
- XET Kft. processes personal data lawfully, fairly and in a manner transparent to you (principle of “lawfulness, fairness and transparency”).
- XET Kft. only collects personal data for specified, explicit and legitimate purposes, and does not further process the data in a manner that is incompatible with those purposes (principle of “purpose limitation”).
- Personal data collected and processed by XET Kft. are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (principle of “data minimisation”).
- XET Kft. takes every reasonable step to ensure that the data processed are accurate and, where necessary, kept up to date, and that personal data that are inaccurate are erased or rectified without delay (principle of “accuracy”).
- XET Kft. keeps personal data in a form which permits your identification for no longer than is necessary for the purposes for which the personal data are processed (principle of “storage limitation”).
- 6. XET Kft. ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (principle of “integrity and confidentiality”).
The legal basis for data processing by XET Kft.
The legal basis for the processing of your personal data by XET Kft. may vary depending on which XET Kft. services you provided your personal data for. XET Kft. only processes the personal data you provide to XET Kft., and does not in any other way collect personal data about you. The legal basis for processing the personal data may be:
your freely given and informed consent,
in certain cases, the processing of your data is a statutory requirement and is mandatory,
data processing may be necessary for the performance of our contract with you
and in certain cases, processing of your personal data is based on the legitimate interests pursued by XET Kft.
Data processors engaged by XET Kft.
During its processing activities, XET Kft. may engage third parties in order to offer certain services, comply with obligations to which XET Kft. is subject, or for your personal convenience. These third parties may process your personal data.
These controllers and processors are the following:
23VNET Kereskedelmi és Szolgáltató Korlátolt Felelősségű Társaság (registration number: 01-09-563212, tax number: 12188224-2-43, registered seat: 1094 Budapest, Liliom utca 24-26.,II/5., Hungary, hereinafter “23VNET Kft.”)
Gordiusz Könyvelő és Adótanácsadó Iroda Korlátolt Felelősségű Társaság (registration number: 06-09-019987, tax number: 24284891-2-06, registered seat: 6723 Szeged, Rókusi körút 21., II/10., Hungary, hereinafter “Accountant”)
Octonull Korlátolt Felelősségű Társaság (registered seat: 1085 Budapest, József körút 74., I/6., Hungary, registration number: 01-09-1981177, tax number: 25073364-2-42, hereinafter “Octonull Kft.”)
DotRoll Számítástechnikai Korlátolt Felelősségű Társaság (registration number: 01-09-882068, tax number: 13962982-2-42, registered seat: 1148 Budapest, Fogarasi út 3-5., Hungary, hereinafter “DotRoll Kft.”)
Facebook Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, D02 X525, Ireland, hereinafter “Facebook”)
Google Ireland Limited (registration number: 368047, registered seat: Gordon House, Barrow Street, Dublin 4, Ireland, hereinafter “Google”)
MaxMind Inc. (registered seat: 14 Spring Street, Suite 3 Waltham, MA 02451, United States of America, hereinafter “MaxMind Inc.”)
Legal representative of XET Kft.: Dr. Nagy Attila MBA Ügyvédi Iroda (registered seat: 1088 Budapest, Bródy Sándor utca 2., II/11., Hungary, hereinafter “Attorney”)
For information on when and how the above controllers and processors participate in the data processing activities of XET Kft., please see below.
Data processing by XET Kft.
This section contains information about the personal data processed, the purpose of processing, the period of processing and the legal basis for processing in case of the different services provided by XET Kft. While using the services of XET Kft., you may potentially transfer the personal data of third parties to XET Kft., for example by storing such data on the server provided to you by XET Kft. Please note that with regard to such data, you may qualify as controller, while XET Kft. may qualify as processor as defined in Article 4(8) of the GDPR, given that XET Kft. stores the transferred data as part of the provision of services to you. Please also note that if you qualify as controller under the applicable law, you are responsible for your data processing activities, and XET Kft. assumes no responsibility thereof.
Registration on the website
Brief description of the activity: You can register on our website using the following page: https://members.xethost.com/register.php. By registering on our website, you create your own user account. Registration is a prerequisite for using the services provided by XET Kft. While registration does not oblige you to order any services, the primary purpose of registration is to ensure the necessary conditions for the order of services; therefore, in order to successfully complete your registration, you must provide the data needed for ordering our services.
Purpose of processing: The purpose of registration is to ensure the necessary conditions for the order of services, thus the purpose of processing natural personal identification data in particular is to establish the contract coming into existence through the ordering of a service, define or modify the content and monitor the performance of the contract, invoice the fees thus incurred and enforce any associated claims. The purpose of processing your phone number and e-mail address is to enable correspondence during provision of the service and following its provision in relation to payment. A further purpose of processing your e-mail address is to ensure the fulfilment of a legal obligation imposed on XET Kft. by Section 6, Subsection 2 of the E-Commercial Code (confirmation via e-mail). Our website automatically records the exact time of registration, the time of your last login into the customer portal, and the IP address used for your last login. The purpose of recording these data is to ban customers abusing the order of our services by blocking their IP address. After detecting the misuse of a service, XET Kft. immediately blocks the IP address involved, and proceeds to investigate the circumstances of the misuse.
Legal basis for processing: If you do not order any services from XET Kft. following registration, the legal basis for processing your data is your consent, in accordance with Article 6(1)(a) of the GDPR. By completing your registration and clicking on the “Register” button, you give your unambiguous consent to the processing of your data.
Scope of the processed data: Ordering data (name, address, phone number, e-mail address), and additionally our website automatically records the exact time of registration, the time of your last login into the customer portal, and the IP address used for your last login.
Period of processing: You can check, modify and delete your data provided during registration under the “Customer Portal” menu of our website. XET Kft. interprets the deletion of your user account as withdrawal of your consent to data processing and as a request for the erasure of your data provided during registration. You have the right to withdraw your consent at any time. In accordance with the above provisions, XET Kft. will manually erase your data provided during registration within two (2) working days, except for data related to already completed orders and data whose retention period is defined by binding accounting and tax regulations (for further details, see applicable sections below).
Recipients of personal data: If you do not order any services from XET Kft. following registration, XET Kft. will not transfer your personal data to third parties; in such cases, the data is stored on XET Kft.’s own server. If you order any services from XET Kft., XET Kft. may transfer your data to third parties (for further details, see applicable sections below).
Dedicated server hosting service
Brief description of the activity: Dedicated server hosting means that XET Kft. provides you with a dedicated, separate server (leased by XET Kft.) in a manner that the total capacity of the physical server is at your disposal. You can order the service via our website. XET Kft. has no access to the data you store on the server; XET Kft. only provides you with the storage of the data.
Purpose of processing: The purpose of processing natural personal identification data is to establish the contract coming into existence through the ordering of the service, define or modify the content and monitor the performance of the contract, invoice the fees thus incurred and enforce any associated claims. The purpose of processing your phone number and e-mail address is to enable correspondence during provision of the service and following its provision in relation to payment. A further purpose of processing your e-mail address is to ensure the fulfilment of a legal obligation imposed on XET Kft. by Section 6, Subsection 2 of the E-Commercial Code (confirmation via e-mail). While using the service, you can store data on the server; XET Kft. provides storage of the data with the purpose of performing the service you ordered.
Legal basis for processing: Data processing is necessary for the performance of our contract with you and for compliance with the legal obligations to which XET Kft. is subject (GDPR, Article 6(1), points (b) and (c)).
Scope of the processed data: Ordering data (name, address, phone number, e-mail address), and additionally any data uploaded by you to the server we provide, as well as the IP address of the provided server.
Period of processing: Ordering data is processed by XET Kft. from completion of the order until the end of the general five-year term of limitation prescribed by civil law (Section 6:22 of the Civil Code), after which the data is erased. Invoices issued in connection with your contract need to be retained by XET Kft. for 8 years in accordance with Sections 169(1) and (2) of the Act on Accounting. Data you upload to the server is stored until deleted by you or for the duration of service provision.
Recipients of personal data: Invoices issued in connection with your contract are transferred to Accountant by XET Kft. XET Kft. uses the invoicing software billingo.hu for issuing invoices, and for this purpose XET Kft. will transfer your invoicing data to Octonull Kft. If XET Kft. provides dedicated server hosting through a leased server, your data stored on the server will be recorded on a server physically owned by 23VNET Kft. 23VNET Kft. has no access to the data you store on the server; 23VNET Kft. only provides you with the storage of the data.
Virtual private server hosting service (VPS)
Brief description of the activity: Our VPS service means that XET Kft. provides you with a dedicated, separate virtual server (owned or leased by XET Kft.) in a manner that the total capacity of the physical server is not at your disposal, only a part of it. You can order the service via our website. When ordering the service, you may expressly request the backup of the data stored on the virtual server (including server parameters). XET Kft. has no access to the data you store on the server; XET Kft. only provides you with the storage of the data.
Purpose of processing: The purpose of processing natural personal identification data is to establish the contract coming into existence through the ordering of the service, define or modify the content and monitor the performance of the contract, invoice the fees thus incurred and enforce any associated claims. The purpose of processing your phone number and e-mail address is to enable correspondence during provision of the service and following its provision in relation to payment. A further purpose of processing your e-mail address is to ensure the fulfilment of a legal obligation imposed on XET Kft. by Section 6, Subsection 2 of the E-Commercial Code (confirmation via e-mail). While using the service, you can store data on the server; XET Kft. provides storage of the data with the purpose of performing the service.
Legal basis for processing: Data processing is necessary for the performance of our contract with you and for compliance with the legal obligations to which XET Kft. is subject (GDPR, Article 6(1), points (b) and (c)). If, when ordering the service, you expressly request backup of the data stored on the virtual server (including server parameters), the legal basis for data processing is your freely given and explicit statement of consent, in accordance with Article 6(1)(a) of the GDPR.
Scope of the processed data: Ordering data (name, address, phone number, e-mail address), and additionally any data uploaded by you to the server we provide, as well as the IP address of the provided server.
Period of processing: Ordering data is processed by XET Kft. from completion of the order until the end of the general five-year term of limitation prescribed by civil law (Section 6:22 of the Civil Code), after which the data is erased. Invoices issued in connection with your contract need to be retained by XET Kft. for 8 years in accordance with Sections 169(1) and (2) of the Act on Accounting. If, when ordering the service, you expressly requested the creation of a backup, XET Kft. saves an “image backup” of the data stored on the virtual server (including server parameters), and stores it for thirty (30) days. Such data saved is automatically erased by XET Kft. on the thirty-first (31) day. In every other case, data you upload to the server is stored until deleted by you or for the duration of service provision.
Recipients of personal data: Invoices issued in connection with your contract are transferred to Accountant by XET Kft. XET Kft. uses the invoicing software billingo.hu for issuing invoices, and for this purpose XET Kft. will transfer your invoicing data to Octonull Kft. If XET Kft. provides virtual server hosting through a leased server, your data stored on the server will be recorded on a server physically owned by 23VNET Kft. 23VNET Kft. has no access to the data you store on the server; 23VNET Kft. only provides you with the storage of the data.
Hosting and e-mail service
Brief description of the activity: Our hosting and e-mail service means that XET Kft. provides you with web storage space in order to enable you to post and make your website accessible via the internet. While using the service, you can upload files and databases for your website into the storage space, and you can manage your incoming e-mails. You can order the service via our website. XET Kft. automatically creates a daily backup of the hosted data.
Purpose of processing: The purpose of processing natural personal identification data is to establish the contract coming into existence through the ordering of the service, define or modify the content and monitor the performance of the contract, invoice the fees thus incurred and enforce any associated claims. The purpose of processing your phone number and e-mail address is to enable correspondence during provision of the service and following its provision in relation to payment. A further purpose of processing your e-mail address is to ensure the fulfilment of a legal obligation imposed on XET Kft. by Section 6, Subsection 2 of the E-Commercial Code (confirmation via e-mail). XET Kft. provides the hosting of the files and databases for your website uploaded into the storage space and the hosting of your e-mails with the purpose of performing the service you ordered. The purpose of creating a backup of the hosted data is to enable system recovery.
Legal basis for processing: Data processing is necessary for the performance of our contract with you and for compliance with the legal obligations to which XET Kft. is subject (GDPR, Article 6(1), points (b) and (c)).
Scope of the processed data: Ordering data (name, address, phone number, e-mail address) and your hosted files, databases and e-mails.
Period of processing: Ordering data is processed by XET Kft. from completion of the order until the end of the general five-year term of limitation prescribed by civil law (Section 6:22 of the Civil Code), after which the data is erased. Invoices issued in connection with your contract need to be retained by XET Kft. for 8 years in accordance with Sections 169(1) and (2) of the Act on Accounting. Your hosted files, databases and e-mails are stored until deleted by you or for the duration of service provision. XET Kft. stores backup files for thirty (30) days, and automatically erases them on the thirty-first (31) day.
Recipients of personal data: Invoices issued in connection with your contract are transferred to Accountant by XET Kft. XET Kft. uses the invoicing software billingo.hu for issuing invoices, and for this purpose XET Kft. will transfer your invoicing data to Octonull Kft. In case of the hosting and e-mail service, XET Kft. stores all data (including the data stored by you) on its own server, and does not transfer the data to third parties.
Domain service
Brief description of the activity: Our domain service means that XET Kft. provides you with domain registration, renewal and transferral services. You can order the service via our website.
Purpose of processing: The purpose of processing natural personal identification data is to establish the contract coming into existence through the ordering of the service, define or modify the content and monitor the performance of the contract, invoice the fees thus incurred and enforce any associated claims. The purpose of processing your phone number and e-mail address is to enable correspondence during provision of the service and following its provision in relation to payment. A further purpose of processing your e-mail address is to ensure the fulfilment of a legal obligation imposed on XET Kft. by Section 6, Subsection 2 of the E-Commercial Code (confirmation via e-mail).
Legal basis for processing: Data processing is necessary for the performance of our contract with you and for compliance with the legal obligations to which XET Kft. is subject (GDPR, Article 6(1), points (b) and (c)).
Scope of the processed data: Ordering data (name, address, ID number, phone number, e-mail address).
Period of processing: Ordering data is processed by XET Kft. from completion of the order until the end of the general five-year term of limitation prescribed by civil law (Section 6:22 of the Civil Code), after which the data is erased. Invoices issued in connection with your contract need to be retained by XET Kft. for 8 years in accordance with Sections 169(1) and (2) of the Act on Accounting.
Recipients of personal data: Invoices issued in connection with your contract are transferred to Accountant by XET Kft. XET Kft. uses the invoicing software billingo.hu for issuing invoices, and for this purpose XET Kft. will transfer your invoicing data to Octonull Kft. In the case of our domain service, XET Kft. transfers your personal data (including your ID number for .hu domains) to DotRoll Kft. as domain registrar. DotRoll Kft. transfers the data necessary for registration to the Council of Hungarian Internet Providers (Internet Szolgáltatók Tanácsa, hereinafter “ISZT”). The ISZT registers the domain name, and makes your personal data related to the domain available on the following website: http://domain.hu. DotRoll Kft. and the ISZT process your personal data for the duration of the contract.
XET DNS service
Brief description of the activity: Our XET DNS service means that XET Kft. manages the DNS records necessary for running your domain names. You can order the service via our website. XET Kft. provides a paid and a free version of the XET DNS service.
Purpose of processing: The purpose of processing natural personal identification data is to establish the contract coming into existence through the ordering of the service, define or modify the content and monitor the performance of the contract, invoice the fees thus incurred and enforce any associated claims. The purpose of processing your phone number and e-mail address is to enable correspondence during provision of the service and following its provision in relation to payment. A further purpose of processing your e-mail address is to ensure the fulfilment of a legal obligation imposed on XET Kft. by Section 6, Subsection 2 of the E-Commercial Code (confirmation via e-mail).
Legal basis for processing: Data processing is necessary for the performance of our contract with you and for compliance with the legal obligations to which XET Kft. is subject (GDPR, Article 6(1), points (b) and (c)).
Scope of the processed data: Ordering data (name, address, ID number, phone number, e-mail address), your domain name and the current settings of the DNS records belonging to your domain.
Period of processing: Ordering data is processed by XET Kft. from completion of the order until the end of the general five-year term of limitation prescribed by civil law (Section 6:22 of the Civil Code), after which the data is erased. In case of the paid service, invoices issued in connection with your contract need to be retained by XET Kft. for 8 years in accordance with Sections 169(1) and (2) of the Act on Accounting.
Recipients of personal data: In case of the paid service, invoices issued in connection with your contract are transferred to Accountant by XET Kft. XET Kft. uses the invoicing software billingo.hu for issuing invoices, and for this purpose XET Kft. will transfer your invoicing data to Octonull Kft.
SMTP service
Brief description of the activity: Our SMTP service means that XET Kft. provides you with a safe private and business e-mail network. You can order the service via our website. XET Kft. provides a paid and a free version of the SMTP service.
Purpose of processing: The purpose of processing natural personal identification data is to establish the contract coming into existence through the ordering of the service, define or modify the content and monitor the performance of the contract, invoice the fees thus incurred and enforce any associated claims. The purpose of processing your phone number and e-mail address is to enable correspondence during provision of the service and following its provision in relation to payment. A further purpose of processing your e-mail address is to ensure the fulfilment of a legal obligation imposed on XET Kft. by Section 6, Subsection 2 of the E-Commercial Code (confirmation via e-mail).
Legal basis for processing: Data processing is necessary for the performance of our contract with you and for compliance with the legal obligations to which XET Kft. is subject (GDPR, Article 6(1), points (b) and (c)).
Scope of the processed data: Ordering data (name, address, phone number, e-mail address) and the e-mails sent by you.
Period of processing: Ordering data is processed by XET Kft. from completion of the order until the end of the general five-year term of limitation prescribed by civil law (Section 6:22 of the Civil Code), after which the data is erased. In case of the paid service, invoices issued in connection with your contract need to be retained by XET Kft. for 8 years in accordance with Sections 169(1) and (2) of the Act on Accounting. The e-mails you send through the SMTP service are stored by XET Kft. on its servers until the e-mails are delivered. In case of successful delivery, the system automatically deletes the e-mail. The SMTP service does not enable you to receive e-mails.
Recipients of personal data: In case of the paid service, invoices issued in connection with your contract are transferred to Accountant by XET Kft. XET Kft. uses the invoicing software billingo.hu for issuing invoices, and for this purpose XET Kft. will transfer your invoicing data to Octonull Kft.
Data processing in the case of contact from consumer
Brief description of the activity: You can contact XET Kft. via e-mail at [email protected], [email protected], [email protected] and [email protected]; you can also send us a message through the customer portal.
Purpose of processing: Fulfilment of the legal warranty obligation to which XET Kft. is subject, fulfilment and management of other civil claims, as well as resolution of any complaints or requests for information.
Legal basis for processing: Data processing is necessary for compliance with the legal obligations to which XET Kft. is subject (GDPR, Article 6(1)(c)).
Scope of the processed data: Last name, first name, e-mail address and data provided by you during complaint management (home address, postal mail address, etc.).
Period of processing: Complaints received need to be retained by XET Kft. for 5 years from the date of issue logging (start of complaint management), in accordance with Section 17/A, paragraph (7) of the Consumer Protection Act.
Recipients of personal data: Data recorded by XET Kft. during consumer complaint management are not transferred to third parties.
Data processing in the case of website visits
Brief description of the activity: When you visit our website, XET Kft. automatically collects data. These personal data do not allow XET Kft. to directly identify you.
Purpose of processing: To enable the normal and high-quality operation of our website, monitor and improve the quality of our services, identify malicious attacks on the website, measure the number of visitors and track statistical data.
Legal basis for processing: The legitimate interest of XET Kft. in ensuring the normal and safe operation of its website (GDPR, Article 6(1)(f)).
Scope of the processed data: IP address, time of visit, information on the subpages visited, operating system and type of browser you used.
Period of processing: Data are logged automatically by the website, and are stored for one hundred and eighty (180) days, after which the data are automatically erased.
Recipients of personal data: XET Kft. does not transfer these data to anyone.
Subscription to our newsletter
Brief description of the activity: Through a given section of our website, you can subscribe to the e-mail newsletter of XET Kft., which contains information on the services provided by XET Kft., potential discounts, etc. You may modify your data provided for your newsletter subscription at any time, and you may unsubscribe from the newsletter at any time using one of the following methods. After logging into the customer portal, uncheck the check box among your settings corresponding to the newsletter subscription. In this case, your subscription is terminated immediately. Alternatively use the link located at the bottom of the newsletter for unsubscribing. Furthermore, you can also unsubscribe by sending a request in e-mail to [email protected].
Purpose of processing: To promote the services of XET Kft. and spread information about sales and discounts.
Legal basis for processing: Your consent, which your provide by directly subscribing to the newsletter, and Section 6, paragraph 5 of the Commercial Advertising Act (GDPR, Article 6(1), points (a) and (c)).
Scope of the processed data: Name and e-mail address.
Period of processing: Data are processed until you unsubscribe from the newsletter. If you unsubscribe from the newsletter, XET Kft. processes your request without delay, and erases the data within two (2) working days of receipt of your request for unsubscribing.
Recipients of personal data: XET Kft. does not transfer your data provided when subscribing to the newsletter to third parties; XET Kft. stores the data on its own servers.
Use of cookies
The purpose and use of cookies
Cookies are small data files that your internet browser saves and stores on your computer when you visit a website. Internet browsers usually accept and allow the download and use of cookies by default; however, by modifying the settings of your browser you can refuse or disable the download and use of cookies, and you can also delete cookies already stored on your computer. For more information, see the “Help” menu of your browser.
The purpose of cookies is to ensure the highest possible quality of website operation, improve and customize user experience, and collect information on website usage.
XET Kft. does not use or allow any cookies that can be used by third parties for data collection without your consent.
Accepting the cookies is not mandatory; however, XET Kft. assumes no responsibility for the website not operating as expected due to cookies being disabled or deleted.
If you decide to remove some or all of the cookies, that may change the operation of the website, and will affect all users of your computer. In the case of cookies requiring your consent, XET Kft. will inform you about them at the time of your first visit, and ask for your permission to enable the cookies.
Cookies used on our websites
Our website uses so-called session ID cookies, which store data temporarily while you are using the website, and are then deleted automatically. Session ID cookies are essential for navigating the website, ensuring the functioning of key features and for accessing secure content. These cookies store the session in general (in particular, but not exclusively for multi-step processes, such as booking an appointment, requesting a quote, etc.). These cookies store data needed for completing forms, but they do not collect information about you that can be used for identifying you or for marketing purposes.
The website also uses long term cookies, which store data for a longer period or until the data is manually deleted. The storage period of the cookies may also depend on the settings of the internet browser you use. Furthermore, XET Kft. uses analytical or performance cookies in order to distinguish and count visitors of the website, and to see how visitors use the website, for example which pages they visit the most frequently or whether they receive an error message on the websites. These cookies enable XET Kft. to ensure secure login onto the website, to provide a consistent website appearance, and to collect information on website usage. These cookies do not collect information that is suitable for identifying you, as the data is aggregated and stored anonymously.
Finally, XET Kft. also uses functional cookies on the website. In order to improve user experience, these cookies detect the type of device used to open the website, and they store your decisions as user. Functional cookies are necessary for you to be able to use certain services on the website. Functional cookies do not track your activity on other websites, and XET Kft. does not use them to display advertisements to you through other websites.
XET Kft. uses code from various service providers, which may place cookies on your computer. These service providers are the following:
Facebook pixel code
The website contains embedded JavaScript code through the use of the Facebook Pixel (conversion tracking pixel) tool, which sends a message to Facebook when you visit the site or perform an action there. Facebook Pixel can be used to display personalized advertisements to visitors of our website on their Facebook pages. For more information on Facebook’s privacy policy, click here.
XET Kft. does not use Facebook Pixel to perform profiling. However, XET Kft. calls your attention to the fact that through the use of Facebook Pixel, Facebook may perform profiling or other forms of automated data processing. In relation to the Facebook Pixel code, Facebook is the data controller (Facebook GDPR policy).
Google Analytics cookie
Google Analytics is Google’s analytical tool, which helps XET Kft. obtain a more accurate picture of its website visitors’ activities. The service may use cookies to collect information and report on statistical data concerning the use of the website. Google Analytics does not identify you individually. The main cookie used by Google Analytics is the cookie named “__ga”. For more information on the use of Google Analytics, click here.
Google Adwords cookie
Google uses cookies to customize advertisements displayed in Google products, for example in Google Search. These cookies are used by Google to remember your most recent searches, your previous interactions with advertisements of given advertisers or with search results, and your visits to advertiser websites. The purpose of using these cookies is to select advertisements on the basis of what is relevant to you. For more information on the cookies used by Google, click here.
XET Kft. does not use Google Adwords to perform profiling. However, XET Kft. calls your attention to the fact that through the use of Google Adwords, Google may perform profiling or other forms of automated data processing. In relation to Google code, Google is the data controller.
Data security measures
Measures performed by XET Kft. for the security of your personal data
XET Kft. is only entitled to transfer your data as specified by applicable legislation; in relation to our data processors, contractual terms specify that the processors may not use your personal data for purposes other than the ones you consented to and that are specified in this Privacy Notice. XET Kft. does not transfer any data outside the European Union.
Courts of law, prosecutors and other authorities (e.g. the police, the National Tax Administration, the National Authority for Data Protection and Freedom of Information, consumer protection authorities) may – as part of their procedural steps – request information or the hand-over of documents from XET Kft. In such cases, XET Kft. is only required to disclose data to the extent that is strictly necessary for fulfilling the purpose of the request. Prior to complying with each data request from authorities, XET Kft. will examine in each case the existence of a legal basis and obligation for data transfer, as well as the legitimacy of the data request in the case of each requested data item.
The persons and employees involved in the data controlling or processing activities of XET Kft. are entitled to see your personal data only to the extent determined in advance, and they are bound by an obligation of confidentiality.
XET Kft. protects your personal data through appropriate technical and other measures, provides the security and availability of the data, and protects your data from unauthorised access, modification, damage, disclosure or any other unauthorised use. In order to ensure IT security, XET Kft. applies the most effective and modern devices and applications reasonably available. When determining and implementing measures for data security, XET Kft. must consider the current level of technological development. However, XET Kft. cannot be held liable for damages caused by unavoidable attacks that may occur despite the highest level of reasonable care.
All servers owned or leased by XET Kft. can be found in the server room of 23VNet Kft. The server room is locked, and its security is ensured 24/7 through video surveillance. Only persons registered in advance are allowed to enter the server room. The building of the server room is guarded by security service.
Only XET Kft. and 23VNet Kft. can physically access the servers hosting the VPS’s. All servers hosting VPS’s can only be accessed with password authentication. The physical machines cannot be accessed directly by unauthorised persons through the internet, as the security of the servers is ensured through a private management network only accessible to XET Kft.
Important: It is your task to ensure the security of the VPS and dedicated servers. XET Kft. provides you with administrator rights to the server, so it is your responsibility to monitor the data recorded on the server and ensure their security. Once you have received access, XET Kft. no longer has any access or login option into the VPS or dedicated server.
For invoicing, communication between the systems of XET Kft. and Octonull Kft. happens via automatic data transfer through an HTTPS encrypted channel, using the API key pair provided by Octonull Kft.
In case of our domain service, data transfer is done manually, and data security is ensured by the use of HTTPS encrypted communication, together with the use of an individual login and password.
When accessing the customer portal system of XET Kft., you are using a fully HTTPS encrypted connection. When new orders are placed, customer data are modified and proforma invoices or invoices are downloaded, all data transferred on the internet is encrypted.
Rights and obligations, applicable legislation
Your rights
- You have the right to request information about the data processing performed by XET Kft.
- You have the right to request the rectification, modification or completion of your personal data processed by XET Kft. You also have the right to object to processing and to request the erasure or blocking of your data (with the exception of mandatory data processing).
- You may exercise your right to data portability.
- You have the right to seek judicial remedy and to lodge a complaint at the supervisory authority (National Authority for Data Protection and Freedom of Information, registered seat: 1125 Budapest, Szilágyi Erzsébet fasor 22/c, Hungary, postal address: 1530 Budapest, Pf.: 5, Hungary, phone: +36 (1) 391-1400, fax: +36 (1) 391-1410, e-mail: [email protected], website: https://naih.hu/ ).
When accessing the customer portal system of XET Kft., you are using a fully HTTPS encrypted connection. When new orders are placed, customer data are modified and proforma invoices or invoices are downloaded, all data transferred on the internet is encrypted.
The right to be informed
Upon your request, XET Kft. will provide you with information concerning the data controlled by XET Kft. or processed by the data processors, the source of those data, the purpose of and legal basis for processing, the period of processing, or if that is not possible, the criteria for defining the processing period, the name and address of the data processors, their activities related to processing, the circumstances and impact of data security incidents, measures implemented for their management or prevention, and in case your personal data are transferred, the legal basis for and the recipients of the data transfer.
XET Kft. will inform you about the measures taken in response to your request related to the content of this Privacy Notice within the shortest time possible, no later than fifteen (15) days (or at most within one (1) month) following submission of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. XET Kft. shall inform you of any such extension within one month of receipt of the request, together with the reasons for the delay. Where you made the request by electronic means, the information shall be provided by electronic means where possible, unless otherwise requested by you.
XET Kft. provides the information free of charge; however, where your request is manifestly unfounded or excessive, in particular because of its repetitive character, XET Kft. may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested, or alternatively XET Kft. may refuse to act on the request. Any fee already paid shall be reimbursed in case the personal data had been unlawfully processed or the request for information resulted in rectification. XET Kft. may only refuse the provision of information in cases specified by law, indicating the specific provision of the relevant legislation, and providing information on the possibility for seeking judicial remedy or turning to the relevant authority.
The right to rectification/modification/completion
You have the right to obtain from XET Kft. without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
XET Kft. will notify you and all recipients to whom the data had been previously transferred for data processing about the rectification of your personal data, unless the lack of such notification does not affect your legitimate interests.
In case XET Kft. does not fulfil your request for rectification, XET Kft. will inform you in writing or – with your consent – electronically within fifteen (15) days (or at most within one (1) month) following receipt of the request about the grounds for refusal and about the possibility for seeking judicial remedy or turning to the relevant authority.
The right to erasure
You have the right to request the erasure of your personal data from XET Kft. XET Kft. is obliged to erase your personal data without undue delay where one of the following grounds applies: the personal data are no longer necessary; you have withdrawn your consent, and there is no other legal ground for the processing; you object to processing that serves the legitimate interest of XET Kft., and there are no overriding legitimate grounds for the processing; XET Kft. processed the personal data unlawfully; the personal data have to be erased for compliance with a legal obligation to which XET Kft. is subject; the personal data was collected in relation to the offer of information society services. Your right to erasure may only be limited on the grounds specified in the GDPR.
XET Kft. will notify you and all recipients to whom the data had been previously transferred for data processing about the erasure of your personal data, unless the lack of such notification does not affect your legitimate interests.
In case XET Kft. does not fulfil your request for erasure, XET Kft. will inform you in writing or – with your consent – electronically within fifteen (15) days (or at most within one (1) month) following receipt of the request about the grounds for refusal and about the possibility for seeking judicial remedy or turning to the relevant authority.
The right to restriction of processing
You have the right to obtain from XET Kft. restriction of processing where one of the following applies: you contest the accuracy of the personal data, for a period enabling XET Kft. to verify the accuracy of the personal data; the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead; XET Kft. no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims; or you have objected to processing that serves the legitimate interest of controller (third party), pending the verification whether the legitimate grounds of XET Kft. override your legitimate interests. Where processing has been restricted under the above provisions, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims 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.
XET Kft. will notify you and all recipients to whom the data had been previously transferred for data processing about the blocking and marking of your personal data, unless the lack of such notification does not affect your legitimate interests.
In case XET Kft. does not fulfil your request for blocking the data, XET Kft. will inform you in writing or – with your consent – electronically within fifteen (15) days (or at most within one (1) month) following receipt of the request about the grounds for refusal and about the possibility for seeking judicial remedy or turning to the relevant authority.
The right to object
In case you object to the processing of your personal data, XET Kft. will examine your objection within the shortest time possible, no later than 15 days (or at most within 1 month) following submission of the request, and will inform you of its decision in writing. Should XET Kft. establish that your objection is well-founded, it will terminate the data processing, including any further data recording or transfer, it will block the data, and it will send information about the objection and the measures taken thereupon to all recipients to whom the personal data affected by the objection were previously transferred and who are obliged to take steps for enforcing the right of objection.
XET Kft. will refuse to comply with your request if it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or which are related to the establishment, exercise or defence of legal claims. If you disagree with the decision, or XET Kft. fails to meet the respective deadline, you have the right to turn to court within 30 days following the day the decision was communicated or the day of the deadline.
The right to data portability
Where the legal basis for processing is your consent or the performance of a contract, and the processing is carried out by automated means, you have the right to receive your personal data which you have provided to XET Kft. in a structured, commonly used, machine-readable format, and to transmit it to another controller. To this end, depending on the processing of the data in question, XET Kft. will make the requested data available in .jpg, .pdf, .doc, .excel, and primarily in .json format on a storage medium or via e-mail to you or another controller specified by you.
Data protection lawsuits fall under the jurisdiction of tribunals, and may be initiated at the local tribunal per your home address or your place of residence, according to your choice. Foreign nationals may also turn to the competent supervisory authority of their place of residence.
Relevant legislation relating to the data processing done by XET Kft.
1. Regulation (EU) 2016/679 of the European Parliament and of the Council on the processing of personal data of natural persons (GDPR)
2. Act CXII of 2011 on Informational Self-Determination and the Freedom of Information
3. Act V of 2013 on the Civil Code (Civil Code)
4. Act CVIII of 2001 on Certain Issues Concerning Electronic Commerce Activities and Information Society Services (E-Commercial Code)
5. Act C of 2003 on Electronic Communication
6. Act CLV of 1997 on the Protection of Consumers (Consumer Protection Act)
7. Act XLVIII of 2008 on the Basic Requirements and Certain Restrictions of Commercial Advertising Activities (Commercial Advertising Act)
8. Act C of 2000 on Accounting (Act on Accounting)
Modification of the Privacy Notice
XET Kft. reserves the right to modify this Privacy Notice. The Privacy Notice and information on data processing are published on the http://xethost.com/legal/ subpage of the website.
Budapest, Hungary, 25 May 2018