Privacy policy

According to Act CXII / 2011 Paragraph 15 and Item 13 of the Regulation of the European Parliament and of the Council (EU) 2016/679 on self-determination and freedom of information.

 Website: https://multilearn.online (hereinafter Portal or System)

 

Data management

Data controller: 

Multilearn Digital Content Provider and Publisher Ltd.
Address: Hungary 1188 Budapest, Kisfaludy u. 31/a. 
Tax number: 423 9734 82
Trade register number: EORI GB423973482000

Data processor:

Prostep Consulting Ltd.
Address: 2089 Telki, Kamilla utca 23.
Tax number: HU23077496
Trade register number: 13-09-220637

It is the responsibility of the Data controller to create the Privacy Policy and to comply with its content. The effective version is always available on the portal.

The Data controller is responsible for ensuring that the personal data stored in the system are lawfully managed and that all employees, subcontractors and natural persons involved in other legal relationships are informed accordingly in accordance with Act CXII / 2011 Paragraph 3, Numbers 9, 17, 18. on informational self-determination and freedom of information and Article 4, Numbers 7 and 8 as well as Articles 24 and 28 (with the exception of Number 2) of the Regulation of the European Parliament and of the Council (EU) 2016/679 (General Data Protection Regulation), for the protection of natural persons in the Processing of personal data and the free movement of data and the repeal of Regulation 95/45 / EC, which came into force on May 25, 2018. The Data processor is only responsible for the proper operation of the system and the availability of the IT environment.

With regards to data management in connection with sales (invoicing) and the use of personal data provided during registration, the legal basis for managing personal data in the case of invoicing is Section 169 (2) of Law C (2000). The legal basis for managing personal data provided during registration and for sending newsletters is the prior, express and voluntary consent of the User involved.

Notifications of technical changes, downtimes and other changes to the general terms and conditions of the Portal will be sent without the separate consent of the User.

The Data controller may not pass on the processed personal data to third parties without the prior, express and informed consent of the data subjects, with the exception of the transmission of data to authorities with a legal title (e.g. Section 264 of Act XC of 2017 on criminal proceedings for investigative authorities ), in which cases the transmission of data to the data manager at the request of the competent authorities is required by law.

 

Data storage

Data that is requested and stored by default during registration:

  • name
  • user name
  • email address
  • password

Depending on the settings of the Data controller, other data can be requested during registration. All of these listed data can be changed later at any time by the registered User on the online interface.

The purpose of data storage is to identify users in the system, to send non-promotional notifications by email, e.g. forgotten password, access to published content, general technical information. At the express request of the user, a periodic marketing request can be made on the basis of the information provided.

When you make a purchase in a webshop, the Portal requests and stores the data required for billing.
The purpose of the data storage is to issue an electronic invoice and record the purchase data.

The Portal logs and stores data related to logins to the Portal. The purpose of the data storage: to track the operation of developers, administrators in the system.

  • username
  • IP address
  • domain
  • time
  • activity (e.g. logging into a course)

The system stores the data related to viewing of educational materials. The purpose of the data storage: to create statistics on the attendance of educational materials for organizers and customers.

  • username
  • tutorial name
  • time spent in the tutorial
  • results of tests, exams

The system stores the data related to the completion of questionnaires (e.g. test, exam, satisfaction questionnaire) for the purpose of: needs assessment, testing, statistics for the organizers, customers.

  • username
  • date of completion
  • title of the questionnaire
  • answers to questions
  • in case of test/exam: score, percentage, pass/fail

 

Registration by the employer

If an employee becomes a user of the portal during the organization of a training course ordered by his/her employer, the employee reads and accepts the Privacy Policy available to everyone on the portal and expressly agrees that his/her employer collects and forwards to the Data Controller the data necessary for registration and participation in the training course. In such cases the Data Controller will register the users into the System by importing the data received.

The employer is entitled to register users with special rights (Training supervisors) in the System who can query the activities of the employees in the portal for quality assurance and statistical purposes. The data that can be viewed by them: the time spent by the employee in the training material, the results of questionnaires completed by the employee (e.g. tests, exams) and the statistics generated. Training supervisors appointed by the employer can strictly only view the data of employees of their own organisation.

 

Data portability

The registered User has the right to data portability, i.e. the right to receive personal data about him, which are processed with his consent and made available to the data administrator in a structured, widely used, machine-readable format, and the transfer of this personal data directly to to request another data administrator if technically feasible (data portability).

 

Data transmission

Az Adatvédelmi tájékoztató elfogadásával a regisztrált felhasználó hozzájárul, hogy adatait bizonyos funkciók használata esetén (pl. vásárlás) az Adatkezelő a vele közvetlen szerződéses viszonyban álló szolgáltatók részére továbbítsa, akik a kapott adatokat kizárólag a szerződésben szereplő szolgáltatások teljesítése során használják fel, azokat harmadik félnek semmilyen formában nem adják tovább. 

Az Adatkezelő az alábbi cégek részére továbbíthatja az adatokat:

Billing partner

KBOSS.hu Ltd. – szamlazz.hu
Location: Hungary 1031 Budapest, Záhony utca 7.
Trade register number: 01-09-303201
Tax number: 13421739-2-41

Data transmitted: name, address, name of the service, for organization: tax number

Reason / purpose of the data transfer: create an electronic invoice.

 

Accounting and business partners

IM Bookkeeping Ltd.
Location: Marshall House, Ring Way, Preston PR1 2QD
Registration number: 08631599

Abacus-Audit Ltd.
Location: Hungary 1071 Budapest, Dózsa György út 66. 3. em.
Trade register number: 01-06-612036
Tax number: HU11571883

Data transmitted: name, address, name of the service, for organization: tax number

Reason / purpose of data transfer: Carrying out accounting tasks.

Analytical partners

Meta Platforms Ireland Limited (formerly: Facebook Ireland Limited)
Location: 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland
Data transmitted: for content viewing, registration: name, email address, phone number, IP address, browser data
Reason/ purpose of data transfer: measurement services, ad targeting (Facebook Conversion API)

Meta Ireland's Privacy Policy contains further information on how Meta Ireland processes personal data, including the legal basis for processing and the choices available to Data Subjects in relation to Meta Ireland as data controller.

Google Ireland Limited 
Location: 4 Barrow St, Grand Canal Dock, Dublin 4, D04 V4X7, Ireland
Data transmitted: for content viewing, registration: name, email address, phone number, IP address, browser data
Reason/ purpose of data transfer: measurement services, ad targeting

 

Data storage time

The processing of personal data required for invoicing takes 8 years after invoicing.

In the case of personal data that are processed on the basis of consent, the retention period is 5 years after the consent has been withdrawn, as the limitation period for data protection claims is 5 years. The Data controller does not use the relevant personal data in any way from the date of revocation of the consent, the data are only stored so that in the event of a data protection dispute, this can serve as evidence of the legality of the data management.

 

Data deletion

The consent to the processing of the personal data provided during registration, to the sending of the newsletter can be revoked by the user concerned at any time in the form in which the consent was given.

The registered User has the right at any time to request access to the correction, deletion or restriction of the processing of personal data concerning him and to object to the processing of this personal data.

 

Data security

Data controller declares that he guarantees the security of the data he manages as well as the security of the data provided, stored or processed and prevents their unauthorized use. The Data controller undertakes to establish the necessary data management rules, technical conditions and organizational processes that ensure the protection of the data. The Data controller takes all possible measures to ensure that the data is not damaged or destroyed.

The security measures are also binding for the employees of the Data controller who are involved in data management.

Data controller ensures that the processed data cannot be accessed, changed, deleted, disclosed or transferred by unauthorized persons. Only registered users of the system with the appropriate authorization can access the managed data; the data administrator does not transfer them to unauthorized third parties.

 

Data collected in connection with a visit to the portal (cookies)

IT cookies are processed by Google Analytics to track traffic to our various content. The data collected in this way will not be used for advertising or other commercial purposes. The legal basis for data management is the consent of the User.

The purpose of storing session cookies is to ensure that the portal works. Law CVIII/2001 is the legal basis for data management on certain issues relating to e-commerce and information society services.

Most web browsers automatically accept cookies by default. In the browser settings you can specify that you do not automatically accept cookies and ask you every time whether the user wants to accept cookies or not.

If the User has previously accepted the use of cookies but would like to revoke this authorization later and delete the cookies, he can do this in the settings of the browser.

Description of how to set and delete: Google Chrome browser, Mozilla Firefox browser, Microsoft Edge browser, Apple Safari browser.

Third-party cookies

Google Analytics, Facebook Pixel may also place cookies on the User's device for analytical purposes.

Google Analytics: to generate traffic statistics, to improve the website.

Facebook Pixel: to generate statistics on visitors from the Facebook page; to use remarketing services provided by Facebook; to display targeted advertising, optimize it for the right audience, display personalized ads, display ads, and generate reports, statements. (Read more)

Claim

The registered User is entitled to lodge a complaint against the data management of the data administrator with the National Authority for Data Protection and Freedom of Information, see contact details under the following link: https://naih.hu/about-the-authority.

 

Technical information

A list of the additional software used in the program code of the Portal can be found at this link.

 

Further Information

Should you require further information please contact us at multilearn.online/contact details.