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Privacy Policy

PRIVACY POLICY

TRANS-EUROPE CONSULTING Szolgáltató és Kereskedelmi Kft. (registered seat: 1026 Budapest, Torockó utca 4. magasföldszint 1.; company registration number: 01-09-162155; tax number: 10696172-2-41; hereinafter: "Company") shall guarantee the right of the data subjects to information by establishing and publishing this privacy policy (hereinafter: "Policy"), as provided for by REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter: "GDPR") and Act CXII of 2011 on Informational Self-Determination and Freedom of Information (hereinafter: "Privacy Act").

The Company is the Hungarian distributor of the following software: Adobe, Wacom, Corel, TeamViewer, Maxon, Quark, Autodesk, Protellerhead, Pantone, JetBrains, Filemaker, Datacolor, as well as the owner of the following infoportals: szoftver.hu, wacominfo.hu and jetbrainsinfo.hu. The Company is also the operator of the szoftverdoki support system, as well as the szoftversuli.hu training center and the oktatas.szoftver.hu e-learning portal. The Company also organizes the CinemArt and 3D Visual Conference events. The Company processes the personal data in connection with the above activities.

The material scope of this Policy shall apply to any and all processing of personal data carried out by the Company and its organizational units. The temporal scope of the Policy shall apply until its withdrawal. The Company reserves the right to amend the Policy. Notification of the amendment shall be done by publishing the amended Policy on the website of the Company.

I. Data controller

Data controller: TRANS-EUROPE CONSULTING Szolgáltató és Kereskedelmi Kft.

Registered seat: 1026 Budapest, Torockó utca 4. magasföldszint 1. 

Company registration number: 01-09-162155

Tax number: 10696172-2-41

II. Definitions

- Data subject: an identified or identifiable natural person (who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person);

- Personal data: any information relating to an identified or identifiable natural person (such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person);

- Special categories of personal data: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person%-%s sex life or sexual orientation;

- 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;

- Processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

- Processor: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

- Data breach: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Other referenced legislation:

- Security Services Act: Act CXXXIII of 2005 on Security Services and the Activities of Private Investigators

- Accounting Act.: Act C of 2000 on Accounting 

III. Data processing carried out by the Company

Description of processing personal data Purpose of processing personal data Legal basis of processing personal data Duration of processing personal data

DIREKT MARKETING If the data subject subscribes to the newsletter of the Company, the Company may send direct marketing messages to the subscriber at any frequency. By subscribing to the newsletter, the data subjects give their explicit consent for the Company to process the necessary personal data. In order to subscribe to the newsletter the following data is necessary: name, address, telephone number and e-mail address, so that the Company is able to deliver the direct marketing messages. The Company provides a direct link to unsubscribe at the bottom of every newsletter. The purpose of data processing is to send direct marketing messages to the subscribers, thus inform them about the products and services of the Company. The legal basis of processing personal data is the consent of the data subject [GDPR Art. 6. Sect. (1) Par. a)], as well as the legitimate interest of the data subject and the Company [GDPR Art. 6. Sect. (1) Par. f)]. The duration of data processing is until the revocation of consent or the request for erasure from the data subject.

QUOTATION, CONTRACTS The Company processes the data of the customers, resellers and suppliers that is necessary for the quotation and contract between the customer, reseller or supplier and the Company, as well as any warranty issues. The processed data are: the personal data provided in the quotations and contract, contact information and the data necessary for billing under the Accounting Act. The purpose of data processing is entering into and performance of the contract between the data subject and the Company, as well as the necessary communication. The legal basis of processing personal data is the consent of the data subject [GDPR Art. 6. Sect. (1) Par. a)], as well as the performance of contract between data subject and the Company [GDPR Art. 6. Sect. (1) Par. b)]. The duration of data processing is 8 (eight) years after the performance of the contract pursuant to the preservation obligation of the bills issued by the Company under the Accounting Act.

JOB APPLICATIONS The Company processes the personal data provided to the Company by the solicited and unsolicited CV-s and other documents attached to the job application. The purpose of data processing is to notify the applicant of any job opportunities matching their qualifications and interests, as well as making an appointment with the applicant and performing the application procedure. The legal basis of processing personal data is the consent of the data subject [GDPR Art. 6. Sect. (1) Par. a)], the consent is provided by sending the Company the CV and related documents of the data subject (applicant). Duration of data processing: 

- In case of a successful application the duration of the employment;

- In case of an unsuccessful application the duration of the hiring process (after that, all the documents provided by the unsuccessful candidates are destroyed).

CAMERA SURVEILLANCE The Company operates an electronic surveillance and recording system at its registered seat. The camera system records the entrance of the property. The camera system records only the picture and actions of the people entering the areas (the system does not record the voice of the data subjects). Only the authorized employees of the Company are entitled to view and review the live and recorded footages. The camera system is operated by the Company, no services providers are engaged, therefore the Company is the sole data controller in connection with this activity. The purpose of data processing is the protection of the property and personal safety of the visitors staying in the hotel, as well as the protection of business secrets and to prove any illegal activity.

The legal basis of processing personal data is the consent of the data subject [GDPR Art. 6. Sect. (1) Par. a)] that shall be deemed given by the subject entering into the building, as well as the legal grounds provided by Sections 30-32 of the Security Services Act. The duration of the processing is 3 (three) business days from the date of the recordings, after this period the recordings shall be deleted automatically pursuant to Paragraph 2 of Section 31 of the Security Services Act.

 

IV. Data processing of the websites operated by the Company

4.1. http://trans-europe.hu/ 

No personal data is necessary to browse the content made publicly available on the website of the Company at http://trans-europe.hu/. 

The Company uses the cookie PHPSESSID necessary for the operation of the website. This cookie is deleted at the end of the browsing session and helps to identify and remember the visitor of the website. The Company also uses the Google NID marketing cookie on this website. This cookie registers a unique ID that identifies a returning user%-%s device. The ID is used for targeted ads and expires 6 (six) months after the browsing session ends.

If the visitor wishes to register as a reseller and thus contact the Company, the following data are necessary: name, company name, position, phone number, e-mail address, registered seat of the company. These data are processed by the Company based on the explicit consent of the data subject [GDPR Art. 6. Sect. (1) Par. a)], as well as the performance of the resale contract between the data subject and the Company [GDPR Art. 6. Sect. (1) Par. b)].

4.2. http://szoftver.hu/

No personal data is necessary to browse the content made publicly available on the website of the Company at http://szoftver.hu/. 

The Company uses the cookie _cfduid necessary for the operation of the website. This cookie is deleted at the end of the browsing session and helps to identify and remember the visitor of the website. The Company also uses the Google NID marketing cookie on this website. This cookie registers a unique ID that identifies a returning user%-%s device. The ID is used for targeted ads and expires 6 (six) months after the browsing session ends. The Company also uses the following cookies of Google Analytics: _ga that registers a unique ID that is used to generate statistical data on how the visitor uses the website and expires 2 (two) years after the session ends; _gat that is used by Google Analytics to throttle request rate and expires at the end of the browsing session, and _gid that registers a unique ID that is used to generate statistical data on how the visitor uses the website and expires at the end of the browsing session. The Company also utilizes the services of LinkedIn on the website: the _lang cookie to remember the language preferences and the _bcookie to track the embedded services. The former expires at the end of the browsing session, the latter expires 2 (two) years after the browsing session ends.

If the visitor wishes to register on the website, the following data is necessary: full name, username, e-mail address, phone number, company name, position. These data are processed by the Company based on the explicit consent of the data subject [GDPR Art. 6. Sect. (1) Par. a)].

If the visitor wishes to subscribe to the newsletter of the Company, the following data is necessary: full name, e-mail address, phone number, company name. These data are processed by the Company based on the explicit consent of the data subject [GDPR Art. 6. Sect. (1) Par. a)].

4.3. http://wacominfo.hu/

No personal data is necessary to browse the content made publicly available on the website of the Company at http://wacominfo.hu/. 

The Company uses the cookie PHPSESSID necessary for the operation of the website. This cookie is deleted at the end of the browsing session and helps to identify and remember the visitor of the website. The Company also uses the following cookies of Google Analytics: _ga that registers a unique ID that is used to generate statistical data on how the visitor uses the website and expires 2 (two) years after the session ends; _gat that is used by Google Analytics to throttle request rate and expires at the end of the browsing session, and _gid that registers a unique ID that is used to generate statistical data on how the visitor uses the website and expires at the end of the browsing session. The Company also utilizes the services of YouTube on the website: the _GPS cookie registers a unique ID on mobile devices to enable tracking based on geographical GPS location; the _VISITOR_INFO1_LIVE cookie tries to estimate the users%-% bandwidth on pages with integrated YouTube videos. The _VISITOR_INFO1_LIVE expires 179 (one-hundred and seventy-nine) days from the end of the browsing session, while the other two cookies expire at the end of the browsing session. 

If the visitor wishes to contact the Company, they may do so by filling out the form on the website. In this case the Company processes the name and e-mail address of the visitor, as well as any other personal data provided to the Company by the visitor in the text of the contact message. The legal basis of processing these personal data is the consent of the data subject [GDPR Art. 6. Sect. (1) Par. a)], as well as the legitimate interest of the Company [GDPR Art. 6. Sect. (1) Par. f)].

The data subjects who have purchased Wacom tablets may also register their purchased items for the enforcement of guarantee packages. The following data are necessary: full name, zip code, address, company name, e-mail address, telephone number, date and place of the purchase, type and serial number of the tablet. These data are processed by the Company based on the explicit consent of the data subject [GDPR Art. 6. Sect. (1) Par. a)], as well as the performance of the contract between the data subject and the Company [GDPR Art. 6. Sect. (1) Par. b)].

4.4. http://szoftverdoki.hu/

No personal data is necessary to browse the content made publicly available on the website of the Company at http://szoftverdoki.hu/. 

The Company uses the cookie PHPSESSID necessary for the operation of the website. This cookie is deleted at the end of the browsing session and helps to identify and remember the visitor of the website. The Company also uses the following cookies of MiniCRM: SESS#, minicrm_sr and UserCode. These cookies expire after 1 (one) year.

The Company operates the website as a support portal mainly for buyers of Adobe, Wacom, Corel, Quark, Maxon software and hardware through the resellers of the Company (if the buyers are able to prove the purchase with the required bills).

In order to claim the warranty the buyer must first fill out the form provided on the website, indicating the exact product and description of the defect (preferably with screenshots attached). The following data is required: full name, company name, e-mail address, telephone number, status (consumer or reseller).

The visitor may also purchase a premium warranty, in this case they must provide the details of their bank cards on an online banking platform.

These data are processed by the Company based on the explicit consent of the data subject [GDPR Art. 6. Sect. (1) Par. a)], as well as the performance of the contract between the data subject and the Company [GDPR Art. 6. Sect. (1) Par. b)].

4.5. http://szoftversuli.hu/

No personal data is necessary to browse the content made publicly available on the website of the Company at http://szoftversuli.hu/. 

The Company uses the cookie PHPSESSID necessary for the operation of the website. This cookie is deleted at the end of the browsing session and helps to identify and remember the visitor of the website. The Company also uses the following cookies of Google Analytics: _ga that registers a unique ID that is used to generate statistical data on how the visitor uses the website and expires 2 (two) years after the session ends; _gat that is used by Google Analytics to throttle request rate and expires at the end of the browsing session, and _gid that registers a unique ID that is used to generate statistical data on how the visitor uses the website and expires at the end of the browsing session. The Company also utilizes the services of Google Doubleclick on the website: these cookies are used to enhance the users experience (including the display of relevant advertisements) and expire 1 (one) year after the browsing session ends. 

The Company operates the website as an offline educational portal. The services offered by the website can be accessed after registration and signing up to a course offered by the Company.

The following data are necessary for the registration: full name, occupation, address, e-mail address, telephone number, company data (if needed for billing). These data are processed by the Company based on the explicit consent of the data subject [GDPR Art. 6. Sect. (1) Par. a)], as well as the performance of the contract between the data subject and the Company [GDPR Art. 6. Sect. (1) Par. b)].

4.6. https://oktatas.szoftver.hu/

No personal data is necessary to browse the content made publicly available on the website of the Company at https://oktatas.szoftver.hu/. 

The Company uses the cookie PHPSESSID necessary for the operation of the website. This cookie is deleted at the end of the browsing session and helps to identify and remember the visitor of the website. The Company also uses the following cookies of Google Analytics: _ga that registers a unique ID that is used to generate statistical data on how the visitor uses the website and expires 2 (two) years after the session ends; _gat that is used by Google Analytics to throttle request rate and expires at the end of the browsing session, and _gid that registers a unique ID that is used to generate statistical data on how the visitor uses the website and expires at the end of the browsing session. The Company also utilizes the services of Facebook on the website: the _fr cookie is used by Facebook to display targeted advertisements to the visitor and expire 3 (three) months after the browsing session ends.

The Company operates the website as an online educational portal. The services offered by the website can be accessed after registration and signing up to a course offered by the Company. The following data are necessary for the registration: full name, company name, e-mail address, phone number.

In order to apply to a course, the applicants must provide the details of their bank cards on an online banking platform.

These data are processed by the Company based on the explicit consent of the data subject [GDPR Art. 6. Sect. (1) Par. a)], as well as the performance of the contract between the data subject and the Company [GDPR Art. 6. Sect. (1) Par. b)].

4.7. https://szoftverbolt.hu/

No personal data is necessary to browse the content made publicly available on the website of the Company at https://szoftverbolt.hu/. 

The Company uses the cookie PHPSESSID necessary for the operation of the website. This cookie is deleted at the end of the browsing session and helps to identify and remember the visitor of the website. The Company also uses the following cookies of Google Analytics: _ga that registers a unique ID that is used to generate statistical data on how the visitor uses the website and expires 2 (two) years after the session ends; _gat that is used by Google Analytics to throttle request rate and expires at the end of the browsing session, and _gid that registers a unique ID that is used to generate statistical data on how the visitor uses the website and expires at the end of the browsing session. The Company also utilizes the services of Facebook on the website: the _fr cookie is used by Facebook to display targeted advertisements to the visitor and expire 3 (three) months after the browsing session ends.

The Company operates this website as an online webshop for both retail and wholesale purposes. Visitors may register on the webshop, or purchase without registration. In order to register the visitors must provide their names, e-mail addresses, password, company name and company ID number. In order to purchase the visitors must provide their names, e-mail addresses, passwords, company name and ID numbers, telephone numbers and addresses. To finalize the purchase the details of a bank card must be provided on an online banking platform.

These data are processed by the Company based on the explicit consent of the data subject [GDPR Art. 6. Sect. (1) Par. a)], as well as the performance of the contract between the data subject and the Company [GDPR Art. 6. Sect. (1) Par. b)].

4.8. http://jetbrainsinfo.hu/

No personal data is necessary to browse the content made publicly available on the website of the Company at http://jetbrainsinfo.hu/. 

The Company uses the cookie PHPSESSID necessary for the operation of the website. This cookie is deleted at the end of the browsing session and helps to identify and remember the visitor of the website. The Company also uses the following cookies of Google Analytics: _ga that registers a unique ID that is used to generate statistical data on how the visitor uses the website and expires 2 (two) years after the session ends; _gat that is used by Google Analytics to throttle request rate and expires at the end of the browsing session, and _gid that registers a unique ID that is used to generate statistical data on how the visitor uses the website and expires at the end of the browsing session. The Company also utilizes the services of YouTube on the website: the _GPS cookie registers a unique ID on mobile devices to enable tracking based on geographical GPS location; the _VISITOR_INFO1_LIVE cookie tries to estimate the users%-% bandwidth on pages with integrated YouTube videos. The _VISITOR_INFO1_LIVE expires 179 (one-hundred and seventy-nine) days from the end of the browsing session, while the other two cookies expire at the end of the browsing session. 

The Company operates this website as an online portal about the products of Jetbrains. In order to use the products of Jetbrains, the visitors must provide their names and e-mail addresses, as well as pay the license fee of the software. To finalize the purchase the details of a bank card must be provided on an online banking platform.

These data are processed by the Company based on the explicit consent of the data subject [GDPR Art. 6. Sect. (1) Par. a)], as well as the performance of the contract between the data subject and the Company [GDPR Art. 6. Sect. (1) Par. b)].

IV. Data processors of the Company

The personal data processed by the Company is made accessible to only the employees of the Company with the relevant roles and responsibilities, as well as service providers performing data processing on behalf of the Company based on data processing agreements and solely in the scope that is necessary to perform the data processing activities.

The Company provides two types of services:

a) direct: the buyer buys the software directly from the developer through the Company (the personal data of the buyer necessary for the licence agreement will be forwarded to the developer).

b) through resellers: the buyer buys the software through resellers (this way the reseller forwards the personal data of the buyer necessary for the licence agreement to the Company, and the Company forwards these data to the developer).

The Company engages the data processing services of the following service providers based on data processing agreements:

a) Barion Payment Zrt. (registered seat: 1117 Budapest, Infopark sétány 1. I. ép. 5. em. 5.; tax number: 25353192-2-43)

This provider provides electronic payment services to the Company, therefore it acts as a data processor in connection with the personal data provided by the data subject regarding transactions.

b) PayPal (Europe) S.á.r.l. et Cie, S.C.A. (registered seat: 22-24 Boulevard Royal L-2449, Luxemburg)

This provider provides electronic payment services to the Company, therefore it acts as a data processor in connection with the personal data provided by the data subject regarding transactions.

c) Google Inc. (registered seat: Google Inc.; 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States)

This provider provides marketing services to the Company by using cookies and remarketing solutions, therefore it acts as a data processor.

d) MiniCRM Zrt. (registered seat: 1075 Budapest, Madách Imre út 13-14.; tax number: 23982273-2-42)

This provider provides a CRM software to the Company, therefore it acts as a data processor.

e) TRL Hungary Kft. (registered seat: 2510 Dorog, Mátyás király u. 11/A; tax number: 10928543-2-11)

This provider provides an ERP software to the Company, therefore it acts as a data processor.

f) T-Systems Magyarország Zrt. (registered seat: 1117 Budapest, Budafoki út 56.; tax number: 12928099-2-44)

This provider provides internet services to the Company, therefore it acts as a data processor.

g) C-Host Kft. (registered seat: 1115 Budapest, Halmi utca 29.; tax number: 23358005-2-43)

This provider provides hosting services to the Company, therefore it acts as a data processor.

V. Data security (data protection by design and by default)

The Company utilizes strict internal authorizations, as well as organizational and technological solutions to ensure that the personal data of the data subject cannot be accessed, stolen or modified.

In the event of a data breach the Company shall take all the necessary measures as well as inform the data subjects if the GDPR and the Privacy Acts requires to do so.

VI. Rights of the data subjects

6.1. Information and access to personal data

The data subject may request the Company in writing to provide information as to:

- the personal data processed by the Company regarding the data subject, as well as

- the legal basis of the processing,

- the purpose of the processing,

- from which source the personal data originate,

- the duration of the processing, 

- to whom the Company forwards the personal data and its legal basis.

The Company shall comply with the request of the data subject within 15 (fifteen) days by electronic or postal mail to the address provided by the data subject. Prior to complying with the request the Company may request the data subject to further specify the request or the data processing activities.

If the data subjects right to obtain information as described above adversely affects the rights and freedoms of others (especially regarding trade secrets and intellectual property rights) the Company is entitled to refuse to comply with the request in the necessary and proportionate amount.

In the event the data subject requests the above information in multiple copies the Company is entitled to bill a proportionate and reasonable amount of money in connection with the administrative costs of fulfilling the request. If the personal data indicated by the data subject is not processed by the Company, the Company shall nevertheless inform the data subject of this fact.

6.2. Right to rectification

The data subject shall have the right to obtain from the Company without undue delay the rectification of inaccurate, incorrect or incomplete personal data concerning him or her. The Company shall correct the inaccurate or inaccurate data immediately, but no later than within 5 (five) days. If it does not conflict with the purposes of the processing, the Company may complete the incomplete personal data by means of a supplementary statement provided by the data subject. The Company shall notify the data subject of the above by electronic or postal mail to the address provided by the recipient.

The Company shall be exempted from complying with the request for rectification if

- the accurate, correct and complete personal data are not available and the data subject does not provide those to the Company, or

- if the validity of the personal data provided by the data subject cannot be established.

6.3. Right to erasure ("right to be forgotten")

The data subject shall have the right to request from the Company the erasure of any personal data relating to the data subject. The data subject shall make the request in writing with specifying the personal data to be erased and the reason for the erasure.

The fulfilment of the request shall only be denied by the Company in case the processing of the personal data is obligatory for the Company by law. Should the Company not be obligated by law to process the personal data then the Company shall comply with the request no later than within 15 (fifteen) days and inform the data subject by electronic or postal mail to the address provided by the data subject.

6.4. Right to restriction of processing

The data subject may request the Company the restriction of processing the personal data in writing.  The restriction shall apply until the reasons specified by the data subject make it necessary. The data subject may request the restriction of processing if:

- the accuracy of the personal data is contested by the data subject (for a period enabling the controller to verify the accuracy of the personal data); 

- the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; 

- the data subject has objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject. 

Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with the data subject%-%s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.   

A data subject who has obtained restriction of processing shall be informed by the Company before the restriction of processing is lifted.

After complying with the request of restriction the Company shall inform of that fact any persons or legal entities to whom the Company has lawfully forwarded the personal data of the data subject, unless such a task is impossible or would require unproportionate effort from the Company. 

6.5. Right to an effective remedy

6.5.1. Dispute resolution with the Company

The data subject may announce their request regarding information, rectification, erasure and restriction in person or in writing at the Company at any addresses of the Company provided in Section I.

6.5.2. Right to complaint

In the event the dispute resolution with the Company proved unsuccessful or the data subject deems that their rights listed above were violated or a direct risk of such violation exists, the data subject is entitled to lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information.

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

Registered seat: 1125 Budapest, Szilágyi Erzsébet fasor 22/c. 

Mailing address: 1530 Budapest, Pf. 5

Telephone: +36(1)3911400

Telefax: +36(1)3911410

E-mail address: ugyfelszolgalat@naih.hu 

Website: http://naih.hu 

6.5.3. Right to a court

The data subject - regardless of their right to complaint - may file an action with the courts if their rights under the GDPR and the Privacy Act have been violated.

Any action against the Company may only be filed with a Hungarian court.

The data subject may file the action with the court of his jurisdiction. The Courts of Hungary and their jurisdiction is available at the following link: http://birosag.hu/torvenyszekek

VII. Additional information

7.1. Claims regarding personal data after the death of the data subject

In the 5 (five) years following the death of the data subject their original rights may be claimed by persons with power of attorney specifically for this matter (in a notarial document or in a private document representing conclusive evidence). If the data subject has not made such a declaration while they were alive, then their next of kin may exercise those rights (in the event that more than one kin is entitled to exercise those rights, the one exercising the rights first shall be entitled to do so).

7.2. Special provisions regarding camera recordings

7.2.1. Right to information

The data subject may inquire about the contents of the footage relating to the data subject within 3 (three) business days of the recording. The data subject shall note in the inquiry when and where the footage was recorded, and how the data subject may be identified on the recordings. The Company shall fulfill the inquiry within 15 (fifteen) days.

7.2.2. Right to hold the recording

The data subject may request the Company to hold the footage (so that it will not be deleted) relating to the data subject within 3 (three) business days of the recording by proving their right or lawful interest. The data subject shall note in the inquiry when and where the footage was recorded, and the reason for the request. The Company strongly advises the data subject to initiate any other necessary proceedings, as the Company shall only hand out the recordings based on a request from the authorities or the courts.

7.2.3. Right to view the footage

The data subject may request the Company to allow insight into the footage recorded about them within 3 (three) business days of the recording. The data subject shall note in the inquiry when and where the footage was recorded, and how the data subject may be identified on the recordings, and the date when the data subject wishes to view the footage. The Company shall provide access to the recordings on workdays from 9 to 15 oclock.