Privacy Policy and Cookies Policy

Last updated: 11th of August 2021

1. Introduction

We are committed to protect your personal data and to respect your privacy. This privacy statement explains the reason for the processing of your personal data, the way we collect, handle and ensure protection of all personal data provided, how that information is used and what rights you have in relation to your personal data. It also specifies the contact details with whom you may exercise your rights. 

2. Definition

Account means a unique account created for You to access our Service or parts of our Service

Service Provider (‘Company’, ‘We’, ’ Our’, ‘Us’): Health Navigator Srl. (website owner; technical maintenance and support), Advice Generator Kft. (content and service management) reffers to website Data Collector.

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses

Device means any device that can access the Service such as a computer, a cellphone or digital tablet

Service refers to the Website

Third-party Social Media Service means any service and content (including data, information, products or services) provided by a third-party that may be displayed, included or made available by Service

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third/party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to Service or to assist the Company in analyzing how the Service is used

Usage Data refers to data collected automatically, either generated by the use of Service or from the Service infrastructure itself (for example the duration of a page visit)

Website refers to Student Navigator, accessible from www.studnav.hu

You (referred to as ‘Data Subject’, ‘User’)) means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable

We are committed to the protection of the personal data of its customers and partners, which is extremely important.

We respect our users' right to self-determinate the information. We treat the personal data confidential and we take all security, technical and organizational measures which guarantee data security.

3. Collecting and using your personal data

3.1. Personal data

While using Our Service We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

Sign up related data:

Email address

First name and last name

Nickname (user-name)

Phone number (optional)

Social media links (optional)

Resume (optional)

Photo (optional)

Country of origin

University related information (University name, Faculty)

Address (in case of ordering a Service)

Legal service Application form

Nationality

Passport number (for non-EEA citizens)

 ID card number (for EEA citizens)

We use pseudonymization (website-user ID), which is a technique that replaces or removes information in a data set that identifies an individual. 

3.2. Usage data

Each time the User logs in to Our website, the identifier, the website and the time will be recorded in a log file. The exact time of log-out will also be recorded for security purposes.

Usage data is collected automatically when using Services. Usage data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you Visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobil device, We may collect certain information automatically, including, but not limited to the type of mobil device You use, Your mobil device unique ID, the IP address of Your mobil device, Your mobile operating system, the type of mobile internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through mobil device.

3.3. Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags and scripts to collect and track information and ro improve and analyze Our Services. The technologies We use may include:

Cookies or Browser Cookies: A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However if you don’t accept Cookies, You may not be able to use some parts of Our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies our Service may use Cookies.

Flash Cookies: certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read How to Delete Privacy-Invading Flash Cookies - Adobe Support Community - 1884961

Web Beacons: certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity)

Cookies can be ’Persistent’ or ’Session’ Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about Cookies: Cookies, the GDPR, and the ePrivacy Directive - GDPR.eu

We use both Session and Persistent Cookies for the purposes set below:

Necessary/Essential cookies: type Session Cookies administrated by Us. Purpose: these Cookies are essential to provide You with services available through the website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies the Services that you have asked for cannot be provided and We only use these Cookies to provide You with those services.

Cookies Policy/Notice Acceptance Cookies: type Persistent Cookies administrated by us. Purpose: these Cookies allow us to remember choices You make when You use the website, such as remembering your login details or language preferences. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to reenter your preferences every time You use the website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy (below).

4. Use of your personal data

Our data management activities are based on voluntary consent or legal authorization. In the case of data processing based on voluntary consent, data subjects shall give their consent, they may be revoked at any stage of the data processing. In some cases, a set of data handling, storage, transmission is mandatory by the law, of which we will notify our customers separately. Our data management principles are in line with current data protection legislation, in particular with:

2011 CXII. Act - on the right to information self-determination and freedom of information;

Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 -  the protection of individuals with regard to the processing of personal data and the protection of such data’s free movement of goods and repealing Regulation (EC) No 95/46 (general Data Protection Regulation, GDPR);

Act V of 2013 - on the Civil Code (Civil Code);

Act C of 2000 - on Accounting (Act on Accounting);

2017 LIII. Act on the Prevention of Money Laundering and Terrorist Financing and prevention;

2013 CCXXXVII. Act - on Credit Institutions and Financial Enterprises.

Physical storage locations for data: personal information (that is, information that can be associated with You) they can be treated in the following way: on the one hand, by maintaining an Internet connection with the computer, browser, Internet address you use, the technical data related to the visited pages is automatically generated in our system, on the other hand. 

5. We (data collector) may use personal data for the following purposes 

To provide and maintain our Service and the Partner Service, including to monitor the usage of our Service.

To manage Your Account and Your Application forms, to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different of the Service functionalities (access our Members’ database, filtering among the Members, filling out the Application form(s) of the Services and Partner Services) that are available to You as a registered user.

For the performance of a contract: the development, compliance and undertaking of the purchase contract for products, items or services You have purchased.

To contact you: to contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, informative communications related to functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already accessed, purchased or enquired about unless You have opted not to receive such information: related to Our Tutor and Mentor system, job opportunities, searching for investors, business angels. 

The personal data of the self-registered individuals is processed based on their consent after having read, understood and agreed to this privacy statement. Consent can be withdrawn at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. 

To manage Your requests: your Account, your Application form(s) etc.

For business transfers: we may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about the Service users is among the assets transferred

For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience

6. We (data collector) may share your personal data for the following situations 

With Partner Service Providers: We may share your personal information with Service Providers to monitor and analyze the use of our Service and their Services to contact You

For business transfers: We may share or transfer Your personal information in connection with or during negotiations of any merger, sale of Company assets, financing or acquisition of all or a portion of Our business to another company

With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us

With Business Partners: We may share Your information with Our business partners to offer You certain products, services or promotions, in which case we will require those partners to honor this Privacy Policy

With other Users (Members): when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside

With your Consent: we may disclose Your personal information for any other purpose with your consent

7. Retention of your data

We will retain Your Personal Data only for as long as is necessary for the purpose set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreement and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service or We are legally obligated to retain this data longer time periods.

8. Transfer your personal data

Your information, including Personal Data, is processed at Our operating offices and any other places where the parties involved in the processing are located. It means that this information may be transferred to – and maintained on – computers located outside of Your state, province, country or other governmental jurisdiction where data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

We will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or country unless there are adequate controls in place including security of Your data and other personal information.

All personal data in electronic format (databases) are stored on European private servers. In order to protect your personal data, we have put in place a number of technical and organisational measures in place. Technical measures include appropriate actions to address online security, risk of data loss, alteration of data or unauthorised access, taking into consideration the risk presented by the processing and the nature of the personal data being processed. Organisational measures include restricting access to the personal data solely to authorised persons with a legitimate need to know for the purposes of this processing operation.

9. Disclosure of your personal data

Personal data is not shared with other recipients, or transferred to third countries or international organisations.

The information we collect will not be given to any third party, except to the following cases:

Business transactions: If We are involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement: Under certain circumstances, We may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or government agency)

Other legal requirements: We may disclose Your Personal Data in the good faith that such action is necessary to:

• Comply with legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability
• Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

10. Children’s privacy

Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Our servers. If You are a parent or guardian and You agree with the usage of Our website by your child (under the age of 18), please send Us an email to: hello@studnav.hu

11. Links to other websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

12. Rights and enforcement of the data subject

The Data Subject may request information on the processing of his or her personal data as well as rectification of it or, with the exception of mandatory data processing, cancellation or revocation of the data, the right to carry data and to protest against it related to the Person in charge.

Right to be informed: We take appropriate measures to ensure the data subject that we will provide information in a concise, transparent, comprehensible and easily accessible manner, according to the law about the personal data in Articles 13 and 14 of the GDPR and Articles 15 to 22 and Article 34. 

The data subject's right of access: The Data Subject has the right to receive feedback from the controller whether the processing of his or her personal data is in progress or not and, if such data processing is in progress, the Data Subject is entitled to have access to his or her personal data and to the following information: purposes of data processing; the categories of personal data concerned; the recipients or categories of recipients with whom or the personal data have been or will be communicated, including in particular from a third country recipients and international organizations; the intended duration of the storage of personal data; the right to rectify, erase or restrict data processing and to protest; addressed to the supervisory authority; the right to lodge a complaint; information on data sources; automated decision making including profiling and comprehensible information on the logic used and the significance of such data processing and what consequences are expected related to data subject. The controller shall do so within a maximum of one month from the submission of the request.

Right of rectification: The Data Subject may request the correction of inaccurate personal data processed by Us and the completion of incomplete data.

Right of cancellation: In the event of any of the following reasons, the Data Subject is entitled to request Us to delete personal data concerning him or her without undue delay: 

personal data are no longer required for the purpose for which they were collected or otherwise treated in this way; the Data Subject withdraws the consent on which the data processing is based and the data processing does not have other legal basis; 

the Data Subject objects to the processing and there is no overriding legitimate reason for doing so the data management; personal data have been processed unlawfully; 

personal data are required to be canceled in order to fulfill an obligation by the law of the European Union or Member State applicable to the controller; 

personal data was collected in connection with the provision of information society services.

Deletion of data cannot be initiated if the data management is necessary: the expression of opinion to exercise the right to liberty and security of information; requiring the processing of personal data, compliance with an obligation under European Union or Member State law applicable to the controller, or a task carried out in the public interest or in the exercise of a public authority ; public health related data collection or archiving, or for scientific and historical researches or statistical purposes, in the public interest; or to bring legal actions, to enforce or protect.

Right to restrict data management: at the request of the Data Subject We restrict data management if one of the following conditions is met:

the Data Subject disputes the accuracy of the personal data, in this case the limitation to that period which allows the accuracy of personal data to be verified;

the data processing is illegal and the data subject opposes the deletion of the data and requests instead the restrictions on the use of it

the data controller no longer needs the personal data for the purpose of data processing, but the data subject concerned requires them to bring, assert or defend legal claims; 

the Data Subject has objected to the processing; in this case, the restriction shall apply for the period until it is established whether the legitimate reasons of the controller take precedence against the legitimate reasons of the person concerned.

if the data processing is subject to restriction, the personal data, with the exception of storage, can be processed only with the agreement of the Data Subject, assert or defend legal claims, or to protect the rights of a natural or legal person, or for the European Union’s or a Member State’s important public interest.

Right to carry data: the Data Subject shall have the right to make available to him or her by the controller the personal data in a readable form, and being able to forward these data to a third-data controller.

Right to protest: the Data Subject has the right to protest any time against the profiling for reasons related to his or her own situation. Profiling which was made in the public interest or in the exercise of a public authority. In the event of an objection, the controller may no longer process the personal data unless it is justified by compelling legitimate reasons which take precedence over the interests of the Data Subject, rights and freedoms, or which are related to the pretention of submitting or enforcing legal claims or its protection.

Automated decision making in individual cases, including profiling: the Data Subject has the right not to be covered by purely automated data processing – including the profiling - which would have legal effects on him or her or would be significantly affected by it.

Right of withdrawal: the Data Subject has the right to withdraw his or her consent at any time.

Right to apply to the courts: in the event of a breach of his rights, the data subject may take legal action against the data controller. The court in this case acting out of line.

13. Disputes resolution

The EU laws shall govern this Privacy Policy.  If You have any concern or dispute about Our Privacy Policy and data process, You agree first try to resolve the dispute informally by contacting Us.

Data Protection Authority Procedure

Complaints can be lodged at the National Authority for Data Protection and Freedom of Information:

Name: National Data Protection and Freedom of Information Authority

Headquarters: 1125 Budapest, Szilágyi Erzsébet avenue 22 / C.

Mailing address: 1530 Budapest, Pf .: 5.

Phone: +36 1 3911400

Fax: +36 1 3911410

Email: ugyfelszolgalat@naih.hu

Website: http://www.naih.hu

14. Other provisions

Information on data processing not listed in this Privacy Policy will be provided at the time of data collection. We inform our Users that the court, the prosecutor, the investigating authority, the infringement authority, the administrative authority, the National Data Protection and Freedom of Information Authority, the Hungarian National Bank and other authorities may contact the controller for the purpose of handing over or making available documents, providing information.

We provide data to authorities - if the authority has indicated the exact purpose and the frame of the data – the Company shall disclose personal data only to the extent of necessary to achieve the purpose of the request

15. Changes to this privacy policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy or the changes on this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

16. Contact us

If you have any questions about this Privacy Policy, You can contact us:

By email: hello@studnav.hu

By visiting this page on our website: www.studnav.hu/contact-us

COOKIES POLICY

Last updated: 11th of August 2021

1. Introduction

This Cookies Policy explains what Cookies are and how We use them. You should read this policy so You can understand what type of Cookies We use, or information We collect using Cookies and how that information is used.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about You may be linked to the information stored in and obtained from Cookies. For further information on how We use, store and keep your personal data secure, see our Privacy Policy.

We do not store sensitive personal information, such as mailing addresses, account password, etc. in the Cookies We use.

2. Definition

Service Provider (referred to as either ’We’, ’Us’ or ’Our’ in the Agreement) refers Health Navigator Srl. (website owner; technical maintenance and support), Advice Generator Kft. (content and service management)

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses

Service refers to the Website

Website refers to Student Navigator, accessible from www.studnav.hu

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable

3. Type of cookies

Cookies can be ’Persistent’ or ’Session’ Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about Cookies: Cookies, the GDPR, and the ePrivacy Directive - GDPR.eu

We use both Session and Persistent Cookies for the purposes set below:

Necessary/Essential cookies: type Session Cookies administrated by Us. Purpose: these Cookies are essential to provide You with services available through the website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies the Services that you have asked for cannot be provided and We only use these Cookies to provide You with those services.

Functionality cookies: type Persistent Cookies administrated by us. Purpose: these Cookies allow us to remember choices You make when You use the website, such as remembering your login details or language preferences. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to reenter your preferences every time You use the website.

Your choices regarding cookies: If You prefer to avoid the use of Cookies of the Website, first You must disable the use of Cookies in your browser and delete the Cookies saved in your browser associated with this website. You may use this option for preventing the use of Cookies at any time.

If You do not accept Our Cookies, You may experience some inconvenience in Your use of Website and some features may not function properly.

If You’d like to delete Cookies or instruct your web browser to delete or refuse Cookies, please visit the official help pages of your web browser.

For more information about Cookies, please visit the following website: What Are Cookies? - Privacy Policies

If you have any questions about this Cookies Policy, You can contact us:

By email: hello@studnav.hu

By visiting this page on our website: http://www.studnav.hu/en/contact-us