Open Minds Hungary KFT. PRIVACY POLICY FOR THE WEBSITE OPENMINDS.HU
I. General Information
I.1.Open Minds Hungary Kft. (headquarters: 7625 Pécs, Majorossy Imre utca 36., tax number: 14438147-2-02, company registration number: 02-09-079558, statistical number: 14438147-6201-113-02, hereinafter referred to as "Open Minds") operates the website openminds.hu.
I.2.The privacy policy of Open Minds (hereinafter referred to as "Privacy Policy") is available at the following page: https://openminds.hu/privacy-policy-hu
I.3.The Privacy Policy and its amendments come into effect on the date of publication on the page specified in Section I.2.
I.4. Open Minds' Name and Contact Information
Name: Open Minds Hungary Kft.
Mailing Address (Headquarters): 7625 Pécs, Majorossy Imre utca 36.
Email: info@openminds.hu
II. Data Provided by Users Managed by Open Minds, Purpose of Data Processing, and Legal Basis for Processing
II.1.Open Minds provides visitors to the website openminds.hu (hereinafter referred to as "User") the opportunity to contact Open Minds. Users can send messages to Open Minds through the openminds.hu website. To do so, the following information must be provided: the User's name, email address, and phone number. Once these details are submitted, the User can send messages to Open Minds.
II.2.The scope of data managed by Open Minds based on Section II, the purpose of data processing, and the legal basis for processing are summarized in the following table.
Personal Data | Purpose of Data Processing | Legal Basis for Data Processing | Scope of Data Subjects | Duration of Data Processing |
---|---|---|---|---|
Name | Identification | GDPR Article 6(1)(a), i.e., the user's consent | Users providing their data | Until the user requests the deletion of the data, but no longer than 2 years |
Email Address | Communication, sending response messages | GDPR Article 6(1)(a), i.e., the user's consent | Users providing their data | Until the user requests the deletion of the data, but no longer than 2 years |
Phone Number | Communication | GDPR Article 6(1)(a), i.e., the user's consent | Users providing their data | Until the user requests the deletion of the data, but no longer than 2 years |
Message Content | Necessary for providing a response | GDPR Article 6(1)(a), i.e., the user's consent | Users providing their data | Until the user requests the deletion of the data, but no longer than 2 years |
Contact Date/Time | Execution of a technical operation | GDPR Article 6(1)(a), i.e., the user's consent | Users providing their data | Until the user requests the deletion of the data, but no longer than 2 years |
IP Address at Contact | Execution of a technical operation | GDPR Article 6(1)(a), i.e., the user's consent | Users providing their data | Until the user requests the deletion of the data, but no longer than 2 years |
II.3.Open Minds provides users of the openminds.hu website the opportunity to apply for job positions posted by Open Minds or to express their interest in joining the Open Minds team independently. To do so, the following information must be provided: the User's name, email address, and phone number.
As part of the application process, the User must specify the position they are applying for and indicate which Open Minds office they wish to join. Additionally, the User is required to upload their resume to the openminds.hu website (the resume can be uploaded as a file or referenced via a URL). The User also has the option to upload a portfolio (the portfolio can be uploaded as a file or referenced via a URL).
Open Minds contacts users who express interest in joining the team and informs them about the employee selection process at Open Minds. The personal data provided by the User through the openminds.hu website is managed by Open Minds in accordance with its internal policies on handling employee personal data, should the User become a member of the Open Minds team.
II.4.The scope of data managed by Open Minds based on Section II.3, the purpose of data processing, and the legal basis for processing are summarized in the following table.
Personal Data | Purpose of Data Processing | Legal Basis for Data Processing | Scope of Data Subjects | Duration of Data Processing |
---|---|---|---|---|
Name | Identification | GDPR Article 6(1)(a), i.e., the user's consent | Users providing their data | Until the user requests the deletion of the data, but no longer than 2 years |
Email Address | Communication, sending response messages | GDPR Article 6(1)(a), i.e., the user's consent | Users providing their data | Until the user requests the deletion of the data, but no longer than 2 years |
Phone Number | Communication | GDPR Article 6(1)(a), i.e., the user's consent | Users providing their data | Until the user requests the deletion of the data, but no longer than 2 years |
Message Content | Necessary for providing a response | GDPR Article 6(1)(a), i.e., the user's consent | Users providing their data | Until the user requests the deletion of the data, but no longer than 2 years |
Contact Date/Time | Execution of a technical operation | GDPR Article 6(1)(a), i.e., the user's consent | Users providing their data | Until the user requests the deletion of the data, but no longer than 2 years |
IP Address at Contact |
Execution of a technical operation | GDPR Article 6(1)(a), i.e., the user's consent | Users providing their data | Until the user requests the deletion of the data, but no longer than 2 years |
Personal Data Provided in the CV | (e.g., education, work experience) Necessary for providing a response and for the selection process | GDPR Article 6(1)(a), i.e., the user's consent | Users providing their data | Until the user requests the deletion of the data, but no longer than 2 years |
III. Principles of Data Management by Open Minds
III.1. Open Minds manages users' personal data lawfully, fairly, and transparently, adhering to the principles of legality, fairness, and transparency.
III.2. Open Minds collects personal data solely for the purposes outlined in this Privacy Notice, in compliance with the principle of purpose limitation.
III.3. Open Minds requests only the personal data necessary to achieve the purposes described in this Privacy Notice, in accordance with the principle of data minimization.
III.4. Open Minds processes users' personal data accurately, based on the data provided by the users, and ensures the immediate correction or deletion of inaccurate personal data, in line with the principle of accuracy.
III.5. Open Minds stores users' personal data in a way that allows identification of the users only for as long as necessary to fulfill the purposes of data processing, in line with the principle of storage limitation.
III.6. Open Minds ensures the security of users' personal data through appropriate technical and organizational measures, protecting it from unauthorized or unlawful processing, accidental loss, destruction, or damage, in compliance with the principles of integrity and confidentiality.
III.7. Open Minds is accountable for complying with the principles outlined in sections III.1 to III.6 and is capable of demonstrating compliance, in line with the principle of accountability.
III.8. Data processing by Open Minds is conducted in accordance with the principles outlined in sections III.1 to III.6.
III.9. Only authorized employees of Open Minds handle the personal data provided by users.
III.10. Open Minds informs users that it is obliged to provide information, disclose, or make personal data available to authorities upon official request or based on legal authorization. In such cases, Open Minds discloses only the data necessary to fulfill the purpose of the request, provided the request specifies the exact purpose and scope of the data required.
IV. Users' Rights Regarding Personal Data Managed by Open Minds
IV.1. Users have the right to contact Open Minds with any questions related to data processing.
IV.2. Users are entitled to receive information from Open Minds about whether their personal data is being processed and, if so, to access the personal data and information specified in the applicable regulations.
IV.3. Users may request the correction of inaccurate personal data or the supplementation of incomplete personal data.
IV.4. Users may request the deletion of their personal data at any time.
IV.5. If Open Minds has made users' personal data public, it must delete the data upon users' request. Open Minds will take reasonable steps, including technical measures, considering available technology and implementation costs, to inform other data processors of the users' request to delete any copies or links to the personal data in question.
IV.6. Users may request a restriction on data processing if they dispute the accuracy of the data, believe the processing is unlawful but do not wish for deletion, or require the data for legal claims while Open Minds no longer needs it for processing.
IV.7. Users are entitled to receive their personal data in a structured, commonly used, machine-readable format and may transfer this data to another data controller.
IV.8. To exercise their rights under sections IV.1 to IV.7, users may contact Open Minds using the contact details provided in section I.4.
IV.9. Users have the right to lodge complaints against potential violations by Open Minds with the National Authority for Data Protection and Freedom of Information (NAIH). Contact details:
- Address: 1125 Budapest, Szilágyi Erzsébet fasor 22/C
- Mailing Address: 1530 Budapest, P.O. Box 5
- Phone: +36-1-391-1400
- Fax: +36-1-391-1410
- Email: ugyfelszolgalat@naih.hu
IV.10. Users may also seek legal remedies to protect their data in court, which will proceed with priority. Claims may be filed at the court of the user's residence or at the competent court of the Authority's headquarters. The competent court for the Authority's headquarters is the Budapest Metropolitan Court.
V. Obligations of Open Minds Towards Users
V.1. Open Minds establishes an internal organizational structure to respond promptly and substantively to user inquiries received via the contact details in section I.4.
V.2. Open Minds informs users without undue delay, but no later than one month from receipt of the inquiry, about actions taken based on requests under section IV.
V.3. Open Minds may extend the deadline for response by two months, if necessary, providing reasons for the delay within one month of receiving the inquiry.
V.4. If Open Minds does not take the requested action, it will notify the user within one month of receipt, explaining the reasons and informing the user of their right to lodge a complaint with a supervisory authority or seek judicial remedy.
VI. Data Collected via Cookies on OpenMinds.hu
VI.1. Open Minds uses cookies (information packets sent by the Open Minds server or a third-party server) during the operation of the openminds.hu website. These may include session cookies (stored until the browser is closed) or persistent cookies (stored beyond the session, which can be deleted by the user).
VI.2. Functional cookies are used for monitoring website functions that may require improvement or acceleration.
VI.3. Convenience cookies analyze user activities on the website.
VI.4. Users can manage, enable, or delete cookies in their browser settings.
VI.5. Instructions for managing cookies in various browsers:
- Google Chrome: Support Link
- Internet Explorer: Support Link
- Firefox: Support Link
- Safari: Support Link
VI.6. Users' consent for cookies is requested through a pop-up window when the website loads. Essential cookies are installed only for website functionality if consent is not given.
VI.7. Open Minds relies on Hungarian legal provisions to process essential cookies.
VI.8. Third-party cookies used include Google Analytics and Hotjar, with detailed information available on their respective websites.
VI.9. A summary of cookies used on the openminds.hu website is provided in the following table:
(Provide table with details)
Cookie Name | Validity (Data Processing Duration) | Level | Owner | Purpose of Cookie (Data Processing Purpose) |
---|---|---|---|---|
ForceFlashSite | Session | Necessary | Own | Determines whether to load the mobile or non-mobile version based on the visitor's browser when navigating to the mobile page. |
hs | Session | Necessary | Own | Security |
smSession | 2 days or 2 weeks | Necessary | Own | Identifies logged-in users |
XSRF-TOKEN | Session | Necessary | Own | Security |
svSession | 2 years | Functional | Own | Unique visitor identification |
SSR-caching | Session | Functional | Own | Indicates the rendering method of the page |
smSession | 2 weeks | Functional | Own | Identifies logged-in users |
VI.10. The legal basis for data processing and the scope of data subjects in relation to cookies are detailed in the following table:
Legal basis for data processing | Data subjects |
---|---|
Article 6(1)(a) of the GDPR, i.e., the user's consent | Users providing their data |
VI.11. The application of Google Analytics on the openminds.hu website is governed by the following rules:
VI.11.1. Google Analytics uses "cookies," which are text files saved on the user's device to help analyze the use of the website visited by the user.
VI.11.2. Information generated by cookies about the user's use of the website is generally transmitted to and stored on a Google server in the United States. By activating IP anonymization on the website, Google shortens the user's IP address within the member states of the European Union or other states party to the Agreement on the European Economic Area before transmission.
VI.11.3. Only in exceptional cases is the full IP address transmitted to and shortened on a Google server in the United States. Google will use this information on behalf of the operator of the openminds.hu website to evaluate the user's use of the website, compile reports on website activity for the website operator, and provide other services related to website and internet usage.
VI.11.4. The IP address transmitted by the user's browser within the framework of Google Analytics is not merged with other data held by Google. Users can prevent the storage of cookies by adjusting their browser settings; however, in this case, not all functions of the website may be fully usable. Users can also prevent Google from collecting and processing data generated by cookies related to their use of the website (including their IP address) by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
VI.12. The application of Hotjar on the openminds.hu website is governed by the following rules:
VI.12.1. Open Minds uses the Hotjar application on the openminds.hu website. Hotjar is a web analytics service provided by Hotjar Ltd ("Hotjar"). Hotjar uses "cookies," which are text files saved on the user's device to help analyze the use of the openminds.hu website.
VI.12.2. Information generated by cookies about the user's use of the website is transmitted to and stored on a server located within the European Union, in compliance with GDPR regulations. Hotjar has implemented the necessary measures to adhere to GDPR requirements. The analysis process ensures user anonymity. Hotjar provides interfaces that allow the operator of the openminds.hu website to access users' personal data stored in the Hotjar account only with the users' explicit consent.
VI.12.3. On behalf of the operator of the openminds.hu website, Hotjar uses information obtained through cookies to evaluate the user's use of the website, compile reports on website activity for the operator, and provide other services related to the website and internet usage.
VI.12.4. Hotjar does not merge the IP address transmitted by the user's browser with other data within the Hotjar framework. Users can prevent the storage of cookies by adjusting their browser settings; however, in this case, not all functions of the openminds.hu website may be fully usable. More information is available at https://www.hotjar.com/.
VII. Users' Rights Concerning Data Collected via Cookies Managed by Open Minds:
VII.1. Users can find information about managing, enabling, and deleting cookies in their respective browsers on the websites listed in Section VI.5 of this privacy notice. Users can delete cookies in their browsers' Tools/Settings menu, generally under the Privacy settings section. Users can also prevent the storage of cookies necessary for the proper functioning of the openminds.hu website, but in this case, certain features of the website may not function fully.
VII.2. Users may also exercise the rights specified in Section IV of this privacy notice, which apply to cookies where relevant.
VIII. Measures Taken by Open Minds to Ensure the Security of Data Processing:
VIII.1. Open Minds ensures the secure handling of personal data managed in accordance with this privacy notice by implementing technical and organizational measures proportionate to the level of risks posed by the data processing, particularly in cases involving the processing of special categories of data.
VIII.2. When establishing and implementing the necessary measures to ensure the security of data processing, Open Minds considers all circumstances related to the data processing, including the current state of science and technology, implementation costs, the nature, scope, and purpose of data processing, and the varying probability and severity of risks posed to the rights of data subjects.
VIII.3. Open Minds grants access to the data processing systems only to authorized individuals. It prevents unauthorized individuals from accessing the systems remotely via data transmission equipment. To prevent unauthorized access, Open Minds restricts access rights to personal data in the system to the specific data that each authorized person is permitted to handle. Open Minds ensures that the data processing system can be restored in the event of malfunction, remains operational, and that any malfunctions are reported. Additionally, it ensures that the stored personal data cannot be altered through improper operation of the system.
VIII.4. Open Minds prevents the unauthorized reading, copying, modification, or removal of data carriers containing personal data.
VIII.5. Open Minds implements measures to ensure that data transmission systems can track and verify which recipients received or could receive personal data transmitted or made available via the system.
VIII.6. The Open Minds system ensures that the personal data entered into the data processing system can be tracked and verified, including when and by whom the data was entered.
VIII.7. During the transfer or transport of personal data, Open Minds ensures that unauthorized persons cannot access, copy, modify, or delete the data.
VIII.8. To ensure the security of data processing, Open Minds has implemented specific data security measures, including equipping computer systems containing personal data with antivirus protection, limiting access to authorized personnel, and requiring login credentials (username and password) for access to the data.