NEOX Privacy Policy

This document contains the information provided by NEOX Smart Solutions Zrt. (hereinafter NEOX or the Data Controller) regarding data processing for marketing purposes.

This Privacy Policy has been prepared in accordance with the rules of the General Data Protection Regulation 2016/679 (hereinafter the Regulation).

1. The scope of the data processed, the legal basis and purpose of data processing, and the duration of data processing

Data processing for marketing purposes

NEOX provides the opportunity for the Data Subject to consent to data processing for marketing purposes on several platforms.

Within the framework of data processing for marketing purposes, NEOX processes the Data Subject's name, phone number, e-mail address, position and the name of the place of work.

Within this framework NEOX sends a professional newsletter and contacts the Data Subject with the recommendation of its own services. The purpose of data processing is to transfer professional knowledge to the Data Subject and to establish a business relationship.

Legal basis of data processing

The legal basis of the data processing is the consent of the Data Subject pursuant to Article 6 (1) a) of the Regulation.

Duration of data processing

NEOX processes the data until the consent is withdrawn.

2. Rights of the Data Subject in relation to data processing

Within the period of data processing, the Data Subject is entitled to the following rights in accordance with the provisions of the Regulation:

• Access to personal data and request information about data processing
• Right to rectification
• Restriction of data processing
• Right to erasure
• Right to object

Exercising these rights requires identification of the Data Subject, so personal data will be required for identification — but only data that NEOX processes anyway.

NEOX will respond to complaints related to data processing within 30 days at the latest.

Access to personal data and information

The Data Subject has the right to receive feedback on whether the processing of their personal data is in progress and, if so, to access the personal data processed and to information on the following:

• Purposes of data processing
• Categories of personal data processed about the Data Subject
• Recipients or categories of recipients to whom NEOX has disclosed or will disclose personal data
• The planned storage period, or the criteria for determining it
• The right to request rectification, erasure or restriction of processing, and to object to processing based on legitimate interest
• The right to lodge a complaint with a supervisory authority
• Where the data was not collected from the Data Subject, all available information on its source
• The fact of automated decision-making, including profiling, and information on the logic used

As the purpose may be to verify the lawfulness of data processing, NEOX may charge a reasonable fee for repeated requests for information.

NEOX provides access by sending the processed personal data and information by e-mail after identifying the Data Subject. The request must state whether access to the data or information about the processing is requested.

Right to rectification

The Data Subject has the right to have inaccurate personal data concerning them rectified without delay at their request.

Right to restriction of processing

The Data Subject has the right to obtain the restriction of data processing if one of the following applies:

• The Data Subject contests the accuracy of the personal data, for the period allowing NEOX to verify it
• The processing is unlawful and the Data Subject opposes deletion, requesting restriction instead
• The data are no longer needed for the stated purpose, but the Data Subject requires them for legal claims
• The Data Subject has objected to the processing, until it is established whose legitimate grounds take precedence

Where processing is restricted, such data may only be processed with consent, or for legal claims, the protection of another person's rights, or important public interest — storage excepted.

NEOX informs the Data Subject at least 3 working days before lifting the restriction.

Right to erasure — to be forgotten

The Data Subject has the right to obtain erasure without undue delay if one of the following applies:

• The data are no longer necessary for the purpose for which they were collected
• The Data Subject withdraws consent and there is no other legal basis
• The Data Subject objects to processing based on legitimate interest and there is no overriding legitimate reason
• The personal data were unlawfully processed
• Erasure is required to comply with a legal obligation

If NEOX has disclosed the data and is obliged to erase them, it takes reasonable steps, including technical measures, to inform other controllers. As a general rule, NEOX does not disclose the personal data of the Data Subject.

Erasure does not apply if the processing is necessary:

• for exercising the right to freedom of expression and information
• to comply with a legal obligation applicable to NEOX
• for the establishment, exercise or defence of legal claims

Right to object

The Data Subject may object at any time, on grounds relating to their particular situation, to processing based on legitimate interest. NEOX may then no longer process the data unless it proves compelling legitimate grounds that override the interests, rights and freedoms of the Data Subject, or grounds relating to legal claims.

Legal remedies

If the Data Subject believes that NEOX has violated a legal provision on data processing, they may initiate an investigation by the Hungarian National Authority for Data Protection and Freedom of Information (postal address: 1530 Budapest, Pf. 5., e-mail: ugyfelszolgalat@naih.hu).

NEOX also informs the Data Subject that they may file a civil lawsuit before the court.

3. Data security

In the operation of its IT systems, NEOX ensures that the Data Subject's data cannot be obtained, deleted, saved or modified by unauthorised persons. NEOX enforces data protection and data security requirements with its data processors as well.

NEOX keeps a record of any personal data breaches and, where necessary, informs the Data Subject of incidents.

4. Other provisions

NEOX reserves the right to amend this Privacy Policy in a way that does not affect the purpose and legal basis of data processing.

This Privacy Policy is effective from 1 September 2024.