Legal Information

1. Purpose of the Code

Optinvest Zrt

The purpose of this Policy is to set out the data protection and data management principles applied by the Service Provider (registered office: , tax number: ) and the Company's data protection and data management policy.

The purpose of this Policy is to ensure that in all areas of the services provided by the Service Provider, all individuals, regardless of their nationality or place of residence, are guaranteed that their rights and fundamental freedoms, in particular their right to privacy, are respected when their personal data are processed by automated means (data protection).

2. Name of the service provider as data controller

Optinvest Zrt

• Address: 1052 Budapest, Deák Ferenc tér 3. (Breitner Ház).
• Phone number: +36 20 9660 666
• E-mail: info@optinvest.hu
• Company registration number: 01-10-046259
• Tax number: 14593569-2-41
• Community EU tax number: HU14593569

3. Scope of personal data processed

3.1. Technical data

Data technically recorded during the operation of the system: the data of the Data Subject's computer logging in, which are generated during the use of the service and which are recorded by the Service Provider's system as an automatic result of technical processes. The data that are automatically recorded are automatically logged by the system on log-in or log-out without any specific declaration or action by the Data Subject. These data may not be linked to other personal user data, except in cases required by law. The data may only be accessed by the Service Provider.

3.2. Cookie

During visits to the Website, the Service Provider sends one or more cookies - small files containing a series of characters - to the visitor's computer, which will allow the visitor's browser to be uniquely identified. These cookies are provided by Google and are used through the Google Adwords system. These cookies are only sent to the visitor's computer when visiting certain sub-pages, i.e. they only store the fact and time of the visit to the sub-page in question, and no other information.

The use of the cookies sent in this way is as follows: external service providers, including Google, use these cookies to store if the Data Subject has previously visited the advertiser's website and, on this basis, display advertisements to the Data Subject on the websites of partners of external service providers, including Google. The Data Subject may opt-out of Google's cookies by visiting the Google Ads opt-out page. (You may also indicate to the Data Subject that you may also opt-out of cookies from third-party service providers by visiting the Network Network Advertising Initiative opt-out page.)

Once blocked, they will not receive personalised offers from the Service Provider.

Cookies used:

Session cookie: session cookies are automatically deleted after the Data Subject's visit. These cookies are used to enable the Service Provider's Website to function more efficiently and securely, and are therefore essential to enable certain functions of the Website or certain applications to function properly.

Persistent cookie: persistent cookies are also used by the Service Provider to improve the user experience (e.g. to provide optimised navigation). These cookies are stored for a longer period of time in the browser's cookie file. The duration of this cookie will depend on the settings of the Data Subject's web browser.

Security cookie:

External servers facilitate the independent measurement and auditing of the Site's traffic and other web analytics data (Google Analytics). The data controllers can provide the Data Subject with detailed information on the management of the measurement data.

Contact: www.google.com/analytics

If the Data Subject does not want Google Analytics to measure the above data in the manner and for the purposes described, he or she should install a blocking add-on in his or her browser.

The "Help" function in the menu bar of most browsers provides information on how to use the browser to

3.3. Processing for other purposes

Telephone conversations are not recorded.

4. Legal basis, purposes and methods of processing

4.1 The processing of the Internet content on the website www.optinvest.hu (hereinafter: Website) is based on the Data Subject's voluntary and informed declaration, which contains the Data Subject's explicit consent to the use of their personal data provided during the use of the Website. The legal basis for the processing of the data is the voluntary consent of the data subject pursuant to Article 5 (1) (a) of Act CXII of 2011 on the Right of Informational Self-Determination and Freedom of Information (Infotv.) and Act CVIII of 2001 on certain aspects of electronic commerce services and information society services.

Consent is given by the Data Subject in respect of each processing by using the Website or by voluntarily providing the data in question.

4.2 The purpose of data processing is to ensure the provision of the services available on the Website.

4.3 The purpose of the automatically recorded data is to compile statistics, to improve the technical development of the IT system and to protect the rights of the Data Subject.

4.4 The Service Provider shall not use the personal data provided for purposes other than those described in this section. The disclosure of personal data to third parties or public authorities, unless otherwise required by law, shall only be possible with the prior express consent of the Data Subject.

5. Data subjects, data transfers, data processing

5.1 The Service Provider has the right to know the data in the first place, but they will not be disclosed or given to third parties.

5.2 For the operation of the underlying IT system, the Service Provider may use a data processor (e.g. system operator, accountant).

Data processors (Company name / Address / Activity):

VOOV Informatikai Fejlesztő Kft. / website development

5.3 The Service Provider processes the personal data of the Data Subjects in a traceable manner and in accordance with the law. In addition to the above, personal data will be transmitted to third parties only and only with the consent of the Data Subject and will be disclosed only in the event of a request by a public authority.

6. Your rights and means of redress

6.1.The Data Subject has the right to request information at any time about the personal data concerning him/her processed by the Service Provider.

6.2.The Service Provider shall provide the Data Subject, upon request, with information about the data relating to him/her processed by the Service Provider, the data processed by the Data Processor or by a data processor appointed by the Service Provider, the source of the data, the purpose, legal basis and duration of the data processing, the name, address and activities of the data processor, the circumstances and effects of the data breach and the measures taken to remedy the data breach, and, in the event of the transfer of the Data Subject's personal data, the legal basis and recipient of the data transfer. The Service Provider shall provide the requested information in writing within 30 days of the request.

The Service Provider shall, if it has an internal data protection officer, through the internal data protection officer, keep records for the purposes of monitoring the measures taken in relation to the data breach and informing the Data Subject, which shall include the scope of the Data Subject's personal data, the scope and number of Data Subjects affected by the data breach, the date, circumstances, effects and measures taken to remedy the data breach, as well as other data specified in the legislation requiring data processing.

6.3 The data subject may exercise his or her rights by contacting:

Mailing address: Service provider

E-mail: info@optinvest.hu

The Data Subject may contact the Service Provider's employee with any questions or comments related to data processing via the contact details provided in section 6.3.

6.4 The Data Subject has the right to request the rectification or erasure of incorrectly recorded data at any time. In other cases, the Service Provider will delete the data within 3 working days of receipt of the request, in which case they will not be recoverable. The deletion does not apply to data processing required by law (e.g. accounting regulations), which will be kept by the Service Provider for the necessary period.

6.5 The Data Subject may also request the blocking of his/her data. The Service Provider shall block the personal data if the Data Subject so requests or if, on the basis of the information available to it, it is likely that deletion would harm the Data Subject's legitimate interests. The personal data blocked in this way may be processed only for as long as the processing purpose which precluded the deletion of the personal data persists.

Rectification, blocking and erasure must be notified to the Data Subject and to all those to whom the data were previously disclosed for processing. The notification may be omitted if this does not harm the legitimate interests of the Data Subject in relation to the purposes of the processing.

If the Service Provider fails to comply with the Data Subject's request for rectification, blocking or erasure, it shall inform the Data Subject in writing within 30 days of receipt of the request, stating the factual and legal reasons for the refusal of the request for rectification, blocking or erasure.

The Data Subject may object to the processing of their personal data. The Service Provider shall examine the objection within the shortest possible time from the date of the request, but not later than 15 days, and shall decide whether the objection is justified and inform the applicant in writing of its decision.

6.6. On the basis of the Info.tv. and the Civil Code (Act V of 2013), the Data Subject

You can contact the National Authority for Data Protection and Freedom of Information (1125 Budapest, Szilágyi Erzsébet fasor 22/c.; www.naih.hu) or assert your rights before the Court.

6.7 If the Data Subject has provided third party data during registration or caused damage in any way during the use of the Website, the Service Provider is entitled to claim damages from the Data Subject. In such a case, the Service Provider shall provide all reasonable assistance to the competent authorities in order to establish the identity of the offending person.

7. Other provisions

7.1 The Service Provider's system may collect data about the activity of the Data Subjects, which cannot be linked to other data provided by the Data Subject at the time of registration, nor to data generated by the use of other websites or services.

7.2 In all cases where the Service Provider intends to use the data provided for purposes other than those for which they were originally collected, the Service Provider shall inform the Data Subject thereof and obtain his/her prior express consent or provide him/her with the opportunity to prohibit such use.

7.3.The Service Provider undertakes to ensure the security of the data, to take technical measures to ensure that the data recorded, stored or processed are protected, and to take all necessary measures to prevent their destruction, unauthorized use or unauthorized alteration. It also undertakes to require any third party to whom it may transfer or disclose the data to comply with its obligations in this respect.

7.4. The Service Provider reserves the right to unilaterally amend these Terms and Conditions by giving prior notice to the Data Subjects through the Website. After the modification has entered into force, the Data Subject must accept the modifications in the manner provided by the Service Provider on the Website in order to continue using the Website.