Privacy policy

SPIRITY ON PRIVACY

We hereby commit to defend Your Personal Data from any illegal use, data leaks, and data breaches.

We believe that we as a provider of services need to be as open and straight forward as possible regarding our usage of Personal Data of our visitors and Clients. We hereby commit to defend Your Personal Data from any illegal use, data leaks, and data breaches. We’ll do everything in our power to only forward your personal data to third parties who provide the adequate measures for safety and security that your personal data requires.

This policy explains how we collect and handle your Personal Data across of our website in as plain and simple manner that is possible.

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

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

Data Controller:
Spirity Enterprise Zrt. (Plc.) – from hereinafter: “Spirity”
Headquarters: 1117 Budapest, Október huszonharmadika utca 8-10.
Tax number: 26633710-2-43
E-mail contact: hello@spirity.hu
Website: www.spirityenterprise.com

ABOUT SPIRITY’S DATA PROCESSING IN GENERAL
• We use your data to provision you our Services and to maintain, improve, and protect our infrastructure and services.
• We may also use your personal data based on your consent to send you our newsletter and offers, to contact you regarding our business and marketing messages or to track your use of the website.
• The personal data will be either provided by you to us directly or will be sent along your Internet usage.
• All Personal Data we have on you will be deleted or anonymized at most after 90 days of it having been collected or being relevant.
• We only use Third Parties and host data in countries which provide adequate security comparable to GDPR’s requirements.

On reasons for using Personal Data

We use your Personal Data to provision you our Services, like authenticate you as a Client, provide you bills, and to maintain and improve our infrastructure.

We use your Personal Data:

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

We use Personal Data:

To perform a contract to our clients, including billing.
Because it is in our legitimate interest to understand our clients and to improve and secure our service:
- via creating anonymous Usage and user parameter Statistics,
- via creating maintenance and security logs,
via the use of anonymous statistics.
Based on your consent to receive newsletters and additional offers or track website usage.
Out of legal obligations that require Personal Data.

On collecting Personal Data

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

To provide the Service we need to rely on Personal Data, there is no way around it. By using our service and browsing our website, we will collect Personal Data.

We collect data:

You directly provide us with
- your contact information,
- your billing information,
- any data which constitutes Personal Data you type to us as message.
We observe automatically during your visit and use of our website
- IP Address or your region,
- information about your device or browser,
- website URL you visited us from,
- third party sites you visit when you leave our website,
- vendors you search for.
We receive from Third Parties
- when you log on to our website from a social media platform,
- when you visit our website via a promotional partner.

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

On retention periods

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

The retention time depends on the purpose by which we collect and process Personal Data.

When we process data:

to perform a contract for our Clients:
- to establish and maintain business partnership between Spirity Zrt. and our Clients
- to manage billing of our Clients, we keep relevant Personal Data for 8 years based on requirements prescribed by invoicing regulations;
- to secure our service via backups kept for 90 days.
because it is in our legitimate interest
- for our Visitors:
  - to maintain and secure our infrastructure with logs kept for 90 days
- to understand Clients and to improve our services
  - via analyzing Usage and user parameter Statistics that we keep after anonymizing it for extended time.

You can contact us any time about deleting your Personal Data, and if there’s no contractual or legal reason to keep your Personal Data, we comply with your request as soon as possible.

On location of data storage

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

We are using Wix.com Ltd’s storage services with servers in EEA to store most of the data provided by our Clients and Visitors. These servers are provided and/or supported by our contracted third parties acting under our instructions.

We only process European users’ Personal Data outside the European Economic Area where a European Commission-approved method of validating the transfer has been put in place.

On Personal Data security

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

Unfortunately, no website or app can guarantee complete security, but we put great effort into our application and data security and do our best to keep your Personal Data as safe as possible. We use a range of technical, organizational, and administrative security measures and good practices proportionate to the risks of data processing. For example, the computer systems we use to store your data have access limitations and are hosted with reputable vendors. We use encryption to protect your personal data when we transfer it across the Internet and store it at our servers. We carry out security assessments and do due diligence on Third Party vendors who handle your data.

To make sure we maintain a culture of ‘Privacy by Design’, we provide thorough data protection and privacy training to all Spirity employees. We develop our services with the goal of using the minimum amount of personal data possible, including through use of data minimization techniques like anonymization and pseudonymization. Also, whenever we develop or update our services in ways that involve the collection or use of new forms of Personal Data, we conduct a balancing test to understand and reduce the likelihood of any unintended impact on you.

We take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the data. The data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to Spirity, in some cases, the data may be accessible to certain types of persons in charge, involved with the operation of www.spirityenterprise.com (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by Spirity. The updated list of these parties may be requested from Spirity at any time.

On reasons for using Personal Data

We use your Personal Data to provision you our Services, like authenticate you as a Client, provide you bills, and to maintain and improve our infrastructure.

We use your Personal Data:

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

We use Personal Data:

To perform a contract to our clients, including billing.
Because it is in our legitimate interest to understand our clients and to improve and secure our service:
- via creating anonymous Usage and user parameter Statistics,
- via creating maintenance and security logs,
- via the use of anonymous statistics.
Based on your consent to receive newsletters and additional offers or track website usage.
Out of legal obligations that require Personal Data.

On collecting Personal Data

To provide the Service we need to rely on Personal Data, there is no way around it. By using our service and browsing our website, we will collect Personal Data.

We collect data:

You directly provide us with
- your contact information,
- your billing information,
- any data which constitutes Personal Data you type to us as message.
We observe automatically during your visit and use of our website
- IP Address or your region,
- information about your device or browser,
- website URL you visited us from,
- third party sites you visit when you leave our website,
- vendors you search for.
We receive from Third Parties
- when you log on to our website from a social media platform,
- when you visit our website via a promotional partner.

On retention periods

The retention time depends on the purpose by which we collect and process Personal Data.

When we process data:

to perform a contract for our Clients:
- to establish and maintain business partnership between Spirity Zrt. and our Clients
- to manage billing of our Clients, we keep relevant Personal Data for 8 years based on requirements prescribed by invoicing regulations;
- to secure our service via backups kept for 90 days.
because it is in our legitimate interest
- for our Visitors:
  - to maintain and secure our infrastructure with logs kept for 90 days
- to understand Clients and to improve our services
  - via analyzing Usage and user parameter Statistics that we keep after anonymizing it for extended time.

You can contact us any time about deleting your Personal Data, and if there’s no contractual or legal reason to keep your Personal Data, we comply with your request as soon as possible.

On location of data storage

We only process European users’ Personal Data outside the European Economic Area where a European Commission-approved method of validating the transfer has been put in place.

On Personal Data security

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

Miscellaneous information

We may use your Personal Data as part of legal obligations, legal claims, handling illegal activities, etc. If you have any question about our data processing which is not properly described in this policy, please contact us.

Usage of Personal Data for compliance with a legal obligation

Clients' Personal Data may be used for legal purposes by Spirity in Court or in the stages leading to possible legal actions arising from improper use of www.spirityenterprise.com or other related services. Client and Visitor declares to be aware that Spirity may be required to reveal personal data upon request of public authorities. Spirity only provides personal data if the requesting Third Party provides the proper and exact legal basis of its request.

Usage of Personal Data for our legal claims

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

Additional information regarding processing of Personal Data

In addition to the information contained in this privacy policy, Spirity may provide Client with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request. Please see the contact information at the beginning of our policy.

Maintenance and Security logs

For operation and maintenance purposes, www.spirityenterprise.com and Third-Party service providers may collect files that record interaction with www.spirityenterprise.com and use other Personal Data (such as the IP Address, requests leading to errors) for this purpose.

About “Do Not Track” requests

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

Changes to our Privacy Policy

Spirity reserves the right to make changes to our privacy policy at any time by giving notice to its Clients on this page and possibly within www.spirtiy.hu and/or - as far as technically and legally feasible - sending a notice to Clients via any contact information available to Spirity. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

ON PERSONAL DATA OF VISITORS

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

We use Personal Data of Visitors out of our legitimate interest to provide quality and secure services to you. Based on your consent, we will also collect Usage Statistics from our Analytical Cookies, to understand how you use our site.

Our Legitimate Interests

Spirity within its legitimate interest collects Client data and Usage Statistics of our Visitors.

During your visit on our website, we collect following Personal Data:

IP Address and your region,
information about your device and browser,
website URL you visited us from,
third party sites you visit when you leave our website
Visitors’ personal data provided via free-text message as a letter with a subject and additional exact personal data (name, email address) – at the contact page.

For more information about your rights as a data subject please continue reading.

Retention Period

Any Personal Data we have on you will be deleted latest 365 days after your visit. This can be by the means of deletion, like in case of our security logs, or by anonymization, like for site statistics. If you become one of our clients, we’ll continue to store your personal data on the legal basis to perform a contract.

Rights and Questions

You may exercise certain rights regarding your data processed by Spirity. You have the right to do the following:

Withdraw your consent at any time: you have the right to withdraw consent where you have previously given your consent to the processing of Personal Data, like our newsletter or Analytical Cookies.
Object to processing of your data: you have the right to object to the processing of your data if the processing is carried out on a legal basis other than consent.
- Where Personal Data is processed for a for the purposes of the legitimate interests pursued by Spirity, you may object to such processing by providing a ground related to your situation to justify the objection.
- But: should your Personal Data be processed for direct marketing purposes; you can object to that processing at any time without providing any justification. To learn, whether Spirity is processing Personal Data for direct marketing purposes, you may refer to the relevant sections of this document.
Access your data: you have the right to learn if data is being processed by Spirity, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing.
Verify and seek rectification: you have the right to verify the accuracy of your data and ask for it to be updated or corrected.
Restrict the processing of your data: you have the right, under certain circumstances, to restrict the processing of your data. In this case, Spirity will not process your data for any purpose other than storing it.
Have your Personal Data deleted or otherwise removed: you have the right, under certain circumstances, to obtain the erasure of your Data from Spirity.
Lodge a complaint: you have the right to bring a claim before your competent data protection authority.

Exercising your rights:

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

COOKIE POLICY

Spirity uses cookies for greater user experience, to understand usage, and for statistics.

For the meaning of terms such as ’cookie’ or ’web beacons’ and ’pixels’, analytical cookies’ please visit our collection of definitions (please continue reading).

We use cookies to collect information for use in line with the purposes set out in our privacy- and cookie policy.

Spirity also uses cookies to record information about experiments or new improvements we might test to track how you use our services and find out whether they were effective. Cookies on our website may be set by us or third parties we’re working with.

Cookies used by Spirity

Necessary Cookies

These can’t be turned off.

Necessary cookies enable core functionality. The website cannot function properly without these cookies and can only be disabled by changing your browser preferences.

Analytical Cookies

You can turn these ON or OFF any time!

Analytical cookies help us to improve our website by collecting and reporting information on its usage.

Google Analytics (Google LLC)

Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes data collected to track and examine the use of www.spirityenterprise.com, to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network.

Personal Data collected: Cookies and Usage Statistics.

Place of processing: United States / EU

How to manage Cookies

Our visitors can manage preferences for Cookies directly from within their own browsers and prevent – for example – third parties from installing Cookies.

Through browser preferences, it is also possible to delete Cookies installed in the past, including the Cookies that may have saved the initial consent for the installation of Cookies by this website – at any time.

You can find information about how to manage Cookies in the most commonly used browsers at the following addresses: Google Chrome, Mozilla Firefox, Apple Safari, Microsoft Edge and Microsoft Internet Explorer.

THIRD PARTIES

We use cloud based Third Party vendors to make our Service more affordable and secure.
We only use Third Parties and host data in countries which provide adequate security comparable to GDPR’s requirements.

We share personal data only if:

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

Your personal data is collected:

by social logins if you use them,
by data processors that contribute in providing our services to you on our behalf, like online payment service providers, hosting providers, etc.

About Our Use of Third-Party Data Processors

These Third Parties only process your personal data under our instructions. These Third Parties are Data Processors.

We require all of our contracted Third-Party Data Processors to:

Process Personal Data only as instructed or as we gave them explicit consent,
Have the necessary and obligatory security measures,
Demonstrate compliance with the applicable data protection laws,
Ensure authorized process and confidentiality,
Only engage another processor with our acknowledgement,
Assist us in the fulfilment of the controller's (our) obligation to respond to requests for exercising the data subject's rights.

We will put in place appropriate measures to ensure that Personal Data is adequately protected if the Third-Party Data Processor is outside of the European Economic Area.

Our Third-Party Data Processors

Providers of email management and distribution tools

When you sign up to receive Spirity newsletters or other marketing messages, we will manage the delivery of these to you using a third-party email distribution tool.

Spirity uses RAPIDOPS, INC and wix.com email management services.

Providers of data aggregation and analytics software services

These enable us to effectively monitor and optimize the delivery of our services.

Spirity uses Google LLC’s, wix.com, Microsoft Corporation and RAPIDOPS, INC analytical services

Providers of online cloud hosting and storage services

These providers run our infrastructure and our code in scalable public cloud environments. Additionally, all our databases are hosted in public cloud environments:

Wix.com Ltd. as cloud hosting and storage service provider. Please find the privacy policy here: https://www.wix.com/about/privacy

THE COMPETENT SUPERVISORY AUTHORITY OF SPIRITY ENTERPRISE ZRT.

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

Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH)
Hungarian National Authority for Data Protection and Freedom of Information

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

Phone nr.: +36 1 391 1400

Fax nr.: +36 1 391 1410

e-mail: privacy@naih.hu or ugyfelszolgalat@naih.hu

web: https://www.naih.hu

coordinates: É 47°30'56''; K 18°59'57''

TERMS, DEFINITIONS AND THEIR MEANINGS FOR OUR PRIVACY POLICY

Find here the legal and technical terms used throughout this privacy policy.

Client

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

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

Data Controller

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of www.spirityenterprise.com. The Data Controller, unless otherwise specified, is the Owner of www.spirityenterprise.com – Spirity Enterprise Zrt.

Data Processor

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

Data Subject

The natural person to whom the Personal Data refers.

European Union (or EU)

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

Personal Data

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person. For example, this includes information that may of itself identify you such as your name, contact details, trek itinerary, internet protocol (“IP”) address, cookie strings or device IDs, as well as information that may not on its own identify you, but which we store alongside such identifiers, such as how you are using our services or the country you are in when you do so.

Service

All services provided by Spirity Enterprise Zrt.

Third Party

Any natural or legal person who does not have a direct connection with a legal transaction but who might be affected by it. In the case of the services of Spirity, a Third-Party individual is a natural or legal person, who is not in direct connection with the legal relations between Spirity and the Data Subject.

Analytical Cookies

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

www.spirityenterprise.com

Sprity online webpage by which the Personal Data of the Visitor and Client is collected and processed.

Usage Statistics

Information collected automatically through www.spirityenterprise.com (or third-party services employed in www.spirityenterprise.com), which can include: the IP addresses or domain names of the computers utilized by the Visitors who use www.spirityenterprise.com, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the Visitor or Client, the various time details per visit (e.g., the time spent on each page within the Service) and the details about the path followed within the Service with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the Client’s IT environment. Usage Statistics can be anonymous, or more detailed if you consent to the use of Analytical Cookies.

Visitor

A natural or legal person who visits www.spirityenterprise.com or contacts Spirity.

Web beacons and pixels

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

Published:

Budapest, 2022.10.17.

Spirity Enterprise Zrt.