Privacy Policy archive

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BREWIE’S PRIVACY POLICY

Last modified: May 31st, 2018.

What is this about?

We, the NEWITY Ltd. are the creator of Brewie, the world's first fully automated and highly user-friendly beer brewing machine.

By browsing our website, purchasing our products or just subscribing to our newsletter you will eventually get in touch with us by providing some of your personal data. Since we completely respect your privacy and are committed to protect it at all times, we would like to explain to you what data we collect, how we do it and what we do with it.

This is important, so please take time to read this Privacy Policy (“Policy”) very carefully. If you have any questions, please do not hesitate to contact us via support@brewie.org before moving on.

Table of Contents

1. Definitions
2. Application of the Policy
3. Information on the Controller
4. What rights and remedies you have
5. Scope of data processing
5.1. What kind of personal data we collect & process
5.2. How we collect & process your personal data
5.3. How long we keep your personal data
5.4. Who has access to your personal data (data transferring)
5.5. How we protect your personal data
6. Purposes
7. Cookie-policy
8. Liability
9. Exceptions related to Companies
10. Governing laws

1. Definitions

The following concepts shall have the meaning throughout the entire Policy as defined below regardless of the use of drop letters. All concepts that are not described hereunder are defined in the Terms & Conditions (“Terms”) which you can find in the FAQ/Legal menu.

1.1. “Controller” means NEWITY Ltd., a legal entity corporation formed under the laws of Hungary (see further information in Section 10). NEWITY determines the purposes and means of the processing of your personal data and is held accountable for the lawful, fair and transparent use of it. NEWITY means also its successors. “Us” and "we" are both synonymous with NEWITY, and references to "our" is construed accordingly.

1.2. “Cookies” are small pieces of text or log files containing information about you and the connection between you and your web server. It also may include the following data: your device’s Internet Protocol (IP) address, the type and version of your browser, the pages of the Website that you visit, the time and date of your visit, the time spent on those pages and other statistics.

Cookies are created on your device and sent by your browser allowing us to recognize you and by analyzing the received data we can make your next visit simpler and easier to you. It also allows us to authenticate Users and prevent fraudulent use of the Accounts and to track your browsing habits while you use the Website so that we can enhance the Website’s performance.

You can erase Cookies from your device and you can also block them, preferably with the Settings/Help (or alike) function of your browser. If you do so, you consent to that the Website’s performance might not be optimal or may not function as intended.

1.3. “GDPR” means the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 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. The GDPR contains all major regulations that the Controller must follow at all times when processing your personal data.

1.4. “Legal basis of processing” means a justified legal ground by which we are entitled to process your personal data. In this Privacy, you can read about four different legal basis as follows:

a) “Consent” means your permission actively given (e.g. by ticking a checkbox) to us by free will that allows us to process your personal data according to this Policy.

b) “Contractual obligation” means an obligation to which we committed ourselves in the Contract (performance of contract). In order to fulfill this contractual obligation (e.g. to provide guarantee and warranty rights), we have to process your data so that we can make sure that you are entitled to enforce such rights.

c) “Legitimate interest” means a sufficiently justified reason why we need to process your personal data without your previously given consent.

d) “Mandatory by law” means a specific regulation of a Hungarian legislation that requires the processing of your data regardless of your consent or the potential withdrawal of your consent.

1.5. “Personal data” or simply “data” means in general any information by which you can be identified directly (e.g. by full name) or indirectly (e.g. by e-mail address). However, we specifically describe hereunder which personal data we collect of you.

1.6. “Personal data breach” means in general any breach of security that might lead to the harm of your personal data, including erasure, loss, alteration, disclosure or access.

1.7. “Processing” means in general any operation which is performed on your personal data, including collection, storage, use, transferring or erasure.

1.8. “Processor” means a specific legal entity which processes personal data on behalf of the Controller. You can read more about the Processors in Section 4.

1.9. “Purpose” means a specific goal of data processing for which goal we process your personal data. You can read more about these purposes in Section 6.

1.10. “Supervisory Authority” means the Hungarian National Authority for Data Protection and Freedom of Information which supervises the data processing of the Controller. Contact:

a) Address: H-1125 Budapest, Szilágyi Erzsébet fasor 22/c. (Hungary)
b) E-mail: ugyfelszolgalat@naih.hu
c) Website: naih.hu
d) Phone: +36 (1) 391-1400

1.11. “Third party” means any person / legal entity other than you or the Controller / Processor.

2. Application of the Policy

2.1. This Policy describes and governs how we collect and process some of your personal data. Therefore, this Policy will apply in this matter from the first moment of recording your personal data until all your data are erased from our databases.

2.2. Please note that this is not a regular contract, however there are both rights and obligations deriving from it applying for both you and us.

2.3. This Policy must be interpreted jointly with the Terms.

2.4. This Policy is in Hungarian and English but is governed solely by the laws of Hungary and the GDPR, regardless of your shipping address / place of residence or the laws of your nationality or the actual location of Brewie’s use.

3. Information on the Controller

Full name: NEWITY Limited Partnership
(in Hungarian: NEWITY Korlátolt Felelősségű Társaság)
Short name: NEWITY Ltd. (in Hungarian: NEWITY Kft.)
Represented by: Mr. Balázs Marcell Pál as managing director
Company registration number: 01 09 891557
Court of Registry: Registry Court of Budapest-Capital Regional Court
Tax number: 14159097-2-41
Registered seat: H-1053 Budapest, Királyi Pál Street 13/A . 3rd floor 1. (Hungary)
Place of business: H-1089 Budapest, Orczy Road 4. 1st floor 1. (Hungary)
Mail address: H-1089 Budapest, Elnök Street 1. (Hungary)
E-mail address: support@brewie.org
Website: brewie.org

4. What rights and remedies you have

4.1. Here we inform you about the rights that you can enforce and the remedies that you have if there is a legal dispute between you and the Controller. You can enforce these rights from the moment we record your personal data until the erasure of such data anytime and free of charge or any precondition (unless indicated otherwise).

4.2. We will provide the requested information or action to take without undue delay and in any event within one month of receipt of the request. If you contact us via electronic form, we will reply the same way unless you explicitly request otherwise.

4.3. Right of access to your data: you have the right to obtain information from the Controller about whether we process any of your personal data and if so:
a) what are the purposes of the processing;
b) which data categories are being processed & for how long & from what sources;
c) to whom the personal data have been or will be disclosed or transferred;
d) what rights and remedies you have related to the above.

4.4. Right to correction of your data: you have the right to obtain the correction of your inaccurate personal data from the Controller, including the completion of any incomplete personal data.

4.5. Right to erasure: you have the right to obtain the erasure of your personal data from the Controller. However, you cannot request the erasure of your data if the processing of such data is mandatory by law or if we might need it for the establishment, exercise or defense of our potential legal claims.

4.6. Right to restriction: you have the right to obtain the restriction of processing from the Controller in any of the following cases:
a) you contest the accuracy of your data: the restriction will last until the Controller verifies the accuracy of such data;
b) you feel that our processing is unlawful but you do not want your data to be erased;
c) we inform you that we no longer need to process your data but you require them hereafter for the establishment, exercise or defense of your potential legal claims;
d) you have objected to processing of your data: the restriction will last until the Controller examines if the legitimate grounds of the Controller override those of your objection.

We will inform you in every case before the restriction of processing is lifted.

4.7. Right to data portability: you have the right to receive your personal data that you provided to the Controller, in pdf format and you have the right to transmit those data to another data controller in a structured, commonly used and machine readable format. You have also the right to have your data transmitted directly from the Controller to another, if this is technically feasible.

You have this right of data portability only if we have processed those data upon consent or contractual obligation.

4.8. Right to object: you have the right to object to processing of your personal data on grounds relating to your particular situation at any time. You have this right to object only if we have processed those data upon our legitimate interest. However, you do not have the right to object if we might need those data for the establishment, exercise or defense of our potential legal claims.

4.9. Right to withdraw consent: you have the right to withdraw your consent at any time via any of the following contact information:
a) by mail: H-1089 Budapest, Elnök Street 1. (Hungary)
b) by e-mail: support@brewie.org
c) by phone: +36 (1) 699-9018 (only between 10 AM and 16 PM CET)

Please note that the withdrawal of your consent will not affect the lawfulness of our processing based on your consent before its withdrawal.

4.10. Right to lodge a complaint: you have the right to lodge a complaint to the Supervisory Authority if you feel that there has been a harm of your personal data while processing or there is a potential risk of that or the regulations of the GDPR have been infringed by the Controller (see contact information in Section 4). You can also lodge your complaint to the supervisory authority of your residence as well.

4.11. Right to judicial remedy: you have the right to judicial remedy if you consider that your rights under this Policy and the GDPR have been infringed as a result of the processing of your data in non-compliance with the GDPR. You also have this right against a legally binding decision of any supervisory authority concerning you.

4.12. Right to compensation / restitution: you have the right to compensation and restitution from the Controller or the Processor if you have suffered material or non-material damage as a result of an infringement of the GDPR for the damage suffered. You only have the right to receive compensation / restitution if you bring your case before court.

5. Scope of data processing

5.1. What kind of personal data we collect & process

We only collect and process our Users’ and Customers’ personal data who visit our Website, buy our Products or otherwise use our services. We do not knowingly collect children’s personal data under any circumstances. We do not collect sensitive personal data either.

a) There are three different categories within personal data that we actually process:

1. account data, such as: full name, birth date, phone number, billing information, shipping address, purchase history, online ID (e-mail, password)
2. consumption data, such as: brewing experiences, comments, questions
3. operational data, such as: brewing data recorded by Brewie’s operational system (“Brewie OS”)

b) You can find a complete list of the actually processed personal data at each purpose in Section 6.

5.2. How we collect & process your personal data

a) In the first round, we collect your personal data on our website: when you fill out a form (e.g. to register, to buy a Product or to send us a feedback) and click on the Register/Purchase/Submit button after ticking the checkbox that you have read and understood this Policy, your data is registered in our servers provided by Google, in our mailing system provided by GetResponse and on the CRM (i.e. customer relationship manager) system provided by MiniCRM.

b) In the second round, we collect operational data by Brewie OS once you switched on your Brewie and accepted the appearing End User License Agreement (“EULA”). These data are stored only on our servers provided by Google.

Please note that the Brewie OS also records data while offline and will automatically sync these data when it is reconnected to the internet.

c) This means that all the personal data we process are coming directly from either you by consent or from the Brewie OS of your Brewie pursuant to the EULA.

d) It is important to know that if you click on the “Purchase” (or alike) button when finishing shopping, you will reach a subpage, where you can pay the subtotal price of the ordered Product via OTP SimplePay. You can pay with your credit card by providing the requested information. These payment data usually are: card number, expiration date, CVC code of your payment card and name of the card’s owner.

Please note that we neither process nor store your payment data you provide. We only receive a unique ID of your order from Shopify which does not contain any payment data whatsoever.

SimplePay is provided by OTP Mobil Kft.
Address: H-1093 Budapest, Közraktár utca 30-32. (Hungary)
E-Mail: ugyfelszolgalat@simple.hu.

e) In some cases, we transfer your personal data to a Processor for a specific reasons. You can read more about the possible data transferring in Section 4.

f) Unless you inform us otherwise (opt out) when you sign the Contract or anytime later, we will process account identifiers, consumption data and operational data for profiling purposes. This means that we, based on your account identifiers, consumption data and operational data will evaluate your preferences, and interests in different products provided by us. We use this data to provide you with customized information and news about our products and special offers to analyze how our service can be improved.

If you do not want your personal data to be processed for purposes relating to direct marketing based on your profile you may contact us by email.

5.3. How long we keep your personal data

a) We store and process personal data until it is necessary to reach the specified purpose. We also provide some services on a continuous base (e.g. newsletter) in which case this necessary time period cannot be defined in advance.

b) Regardless of the necessary time period, we only process your personal data until you withdraw your consent.

c) We also have to process some of your personal data as long as it is mandatory by law.

5.4. Who has access to your personal data (data transferring)

As a general rule, only the Controller and its employees and co-workers have access to your personal data. However, in some cases we need to grant access to a third party or directly transfer your data to one of our business partners so that we can fulfill the Contract and properly provide our services and meet our commitments.

Here we give you a list about the Processors who might access to your personal data for the purposes specified below. These companies can only process your data according to the Controller’s instructions under any circumstances.

a) Shopify is the online provider of our webstore which helps us maintain our online store and helps you walk through the process of purchasing.

Shopify is provided by Shopify Inc.
Address: 150 Elgin Street, 8th Floor; Ottawa, ON, Canada; K2P 1L4

b) MiniCRM is a customer relationship manager software which helps us to properly record, store and organize your account data and purchase history. We use this service when you register at our Website or buy our Products at the Brewie Shop. Your data is only recorded once you click on the Register/Purchase/Submit button (or alike).

MiniCRM is provided by MiniCRM PLC.
Address: H-1075 Budapest, Madách Imre út 13-14. (Hungary)
E-mail: help@minicrm.hu.

c) Szamlazz.hu is an online invoicing service which helps us to issue the electronic invoice of your purchase at the Brewie Shop. Once your payment was successful at Barion’s site, you are redirected to szamlazz.hu where your invoice is issued and automatically sent to you via e-mail.

Szamlazz.hu is provided by KBOSS.hu Kft.
Address: H-1031 Budapest, Záhony utca 7. (Hungary)
E-mail: info@szamlazz.hu.

d) Getresponse is an online mailing system which helps us inform our customers and subscribers about our current plans and activities and sends automated messages in cases of successful purchases, subscriptions, etc.

Address: Arkońska 6/A3; 80-387 Gdansk; Poland
E-mail: gr-support@cs.getresponse.com

e) The following companies help us to store and package your ordered Product(s) for proper shipping.

WinnTech
Address: WinnTech Industrial Park No. 2; Xianghe Road, Xinmin Area; Chang An, Dongguan City; Guangdong Province; 523879 China
E-mail: jerry.z@winn-tec.com

AIRMAX CARGO BUDAPEST ZRT.
Address: 2220 Vecsés, Lőrinci str. 154, Airport City Logistic Park, D. Bldg. Ramp 6
E-mail: linda.gergely@airmaxcargo.com

T-Pack Kft.
Address: H-2800, Tatabánya; Búzavirág utca 8.
E-mail: info@t-pack.hu

Keystone Homebrew Supply
Address: 435 Doylestown Rd; Montgomeryville, PA 18936; USA
E-mail: orders@keystonehomebrew.com

Grain and Grape
Address: 5/280 Whitehall Street 3013, Yarraville, Australia
E-mail: matt@grainandgrape.com.au

Kühne + Nagel Kft.
Address: Páty, M1 Business Park, 2071
E-mail: robert.sarudi@kuehne-nagel.com

f) The following companies help us to deliver your ordered Product(s) to your shipping address.

United Parcel Service, Inc.
Address: 55 Glenlake Parkway, NE Atlanta, GA 30328, USA
E-mail: upshungary@ups.com

DHL
Address: Vecsés, Airport Business Park, C6, Lőrinci út 59., H-2220

AIRMAX CARGO BUDAPEST ZRT.
Address: 2220 Vecsés, Lőrinci str. 154, Airport City Logistic Park, D. Bldg. Ramp 6
E-mail: linda.gergely@airmaxcargo.com

Kühne + Nagel Kft.
Address: Páty, M1 Business Park, 2071
E-mail: robert.sarudi@kuehne-nagel.com

GLS General Logistics Systems Hungary Csomag-Logisztikai Kft.
Address: H-2351 Alsónémedi, GLS Európa u. 2.
E-mail: info@gls-hungary.com

DSV Road Hungary
Address: Vasút str. 11. H-2040 Budaörs
E-mail: bettina.pek@hu.dsv.com

Flexport, Inc.
Address: 760 Market St., Floor 8, San Francisco, CA, 94102 USA
E-mail: Marjon@Flexport.com

Proair Logistics Co., Ltd
Address: A516-517 WDL Business Building, Shenzhen 518109, China
E-mail: sandy.liu@proair.cn

g) The following companies are our repair service partners which will fix your Brewie in case of malfunction.

Robotguru Trading House Ltd.
Address: H-1146 Budapest, Istvánmezei út 6. (Hungary)
E-mail: info@robotguru.hu

Quality Brands AG
Address: Neugutstrasse 88, CH-8600 Dübendorf, Switzerland
E-mail: gaunt@quality-brands.ch
BRYGGSELV AS
Address: Sofiemyrveien 4, NO-1412 Sofiemy, NORWAY
E-mail: espen.andersen@bryggselv.no

Hamilton Appliance Inc.
Address: 5694 Shelby Oaks Dr #8, Memphis, TN 38134, USA
E-mail: HamiltonApplianceInc@gmail.com

Hamilton Logistics
Address: 2216 Hamilton Blvd, South Plainfield NJ 07080, USA
E-mail: ms@hamilton3pl.com

Cameron Howe
Address: 28 Mountain St, GLEN WILLIAMS, L7G 2X4, Ontario, Canada
E-mail: cam.howe1@gmail.com

5.5. How we protect your personal data

a) Online security: we only use encrypted data transmission channels and methods between users and our servers, no 3rd parties can access or decode the information.

b) Storing: we primarly store your data in digital form. Our databases are always encrypted and password protected which means that even the co-workers of the Controller handle your data in an anonymous form when the data processing serves only statistical purpose and does not have to be associated with you. All data stored can be accessed only by certain employees of Newity, who have signed confidentiality obligations about storing and handling all data. All passwords are stored in encrypted form that cannot be deciphered even by Newity employees.

In certain cases, we have to store your data in physical form: these data sheets are always secured inside lockable cabinets to which only a few dedicated personnel have access to.

c) Erasure: our systems are capable of erasing your digital data upon request so that you will no longer be identifiable. We also take care about shredding of the physical data sheets as well.

As a general rule, we continuously erase all personal data with your prior notification that are no longer needed to provide our services or if such personal data have to be erased by law.

Erasure includes the erasure of any links to, or copy or replication of, those personal data in the Controller’s and the Processor’s databases as well.

6. Purposes

Here we inform you about the specific goal of data processing for which goal we process your personal data.

6.1. Registration on Website:
a) Processed data: account data: first name, last name, e-mail, password, birth date.
b) Source of data: User/Customer.
c) Legal basis of processing: consent.
d) Duration of processing: until withdrawal of consent or termination of service.
e) Place of storage: servers provided by Google and miniCRM’s system.
f) Processor(s): miniCRM.

We process your data detailed above to offer you personalized offers through your Account and make the shopping and the use of our other services easier.

6.2. Shopping at the Brewie Shop:
a) Processed data: account & consumption data
billing information: first name, last name, address (including street address, country, ZIP code, city, state), phone number, e-mail, coupon code.
shipping address: first name, last name, address (including street address, country, ZIP code, city, state), phone number.
purchase history: Product name, machine version, quantity, Product price, shipping price, subtotal price, time of transaction (date & hour), Barion ID.
consumption data: comment.
b) Source of data: User/Customer and Barion (Barion ID).
c) Legal basis of processing: performance of contract and mandatory by law.
d) Duration of processing:
8 years according to Section (2) of 169. of Act C of 2000 on Accounting;
beyond that 8 years: until termination of services.
e) Place of storage: servers provided by Google and miniCRM’s system.
f) Processor(s):
miniCRM;
Szamlazz.hu;
Companies that store and package your ordered Product(s) (see Section 4)
Companies that ship and deliver your ordered Product(s) (see Section 4)

We need all your data detailed above so that the Contract can be concluded between you and NEWITY, furthermore to properly deliver your ordered Product(s) to your shipping address, and also to keep in touch with you during procedure.

6.3. Subscribing to Newsletter:
a) Processed data: account & consumption data
account data in all cases: first name, last name, e-mail, country; and…
… in case you subscribe to ‘Beer lover’: experience.
… in case you subscribe to ‘Brewery’: average annual batch.
b) Source of data: User/Customer.
c) Legal basis of processing: consent.
d) Duration of processing: until unsubscribe or withdrawal of consent or termination of service.
e) Place of storage: servers provided by Google and miniCRM’s system.
f) Processor(s): none.
g) ID number issued by the Supervisory Authority: NAIH-116168/2017

We process your data detailed above to send you newsletter about the updates in our services, information about new Products, discounts, special offers, interesting articles and other content on brewery, whatnot.

You can unsubscribe from our newsletter anytime and free of charge by clicking on the ‘Unsubscribe’ link in the newsletter or by sending us an e-mail with this topic to support@brewie.org.

6.4. Customer and Tech Support:
a) Processed data: account & consumption data
account data in all cases: first name, last name, e-mail; and…
… in case of a ‘general question’: phone number, country, attachment (if any), interested topic, question.
… in case of a ‘specific question’: phone number, country, attachment (if any), Product, order ID, message.
… in case of a ‘report an issue’: phone number, country, attachment (if any), description of issue, damaged arrival, serial number of Brewie, voltage type of Brewie, software version of Brewie.
… in case of a ‘feedback’: phone number, country, attachment (if any), message.
b) Source of data: User/Customer.
c) Legal basis of processing: performance of contract.
d) Duration of processing:
until the Controller’s feedback is approved by the User/Customer in case of ‘general / specific question’ and ‘feedback’;
until the reported issue is solved and approved by the User/Customer in case of ‘report an issue’.
e) Place of storage: servers provided by Google and miniCRM’s system.
f) Processor(s):
Companies that service and fix machines (see Section 4)

We process your data detailed above to provide detailed answers to your inquiry whether you are an interested buyer or already a Brewie-owner. This way we can also contact with our repair service partner that is the closest to your place of residence in case your Brewie need repair. We also use your data to collect customer brewing experiences and improve our services.

6.5. Usage Analysis of Brewie:
a) Processed data: operational data
IP-address of Brewie, serial number of Brewie, calibrations of Brewie, personal account;
operation of brewing recorded by Brewie’s sensors (including: duration of brewing, boiling/temperatures, mashing, sparging, leveling wort, hopping, usage of hop cages, exceeding of recommended hop cage capacity, cooling, fraining, cleaning, quantity of ingredients, errors/malfunctions).
b) Source of data: Brewie OS.
c) Legal basis of processing:
contractual obligation (see Section 9. and 10. of the Terms);
legitimate interest beyond the Guarantee Period and Warranty Period.
d) Duration of processing:
Contractual obligation: until Guarantee Period and Warranty Period expire;
legitimate interest: until Brewie is in use.
e) Place of storage: servers provided by Google.
f) Processor(s):
Companies that service and fix machines (see Section 4)

We process your data detailed above to fulfill our contractual obligations undertaken in the Contract, i.e. to satisfy guarantee/warranty claims if proven to be grounded by the Brewie OS.

Our legitimate interests which entitle us to process the operational data of your Brewie are the following:
a) We need to monitor the operation of your Brewie so that we can answer all your questions about how to use it properly, safely and efficiently.
b) We also want to make sure that we can provide prompt solutions whenever you experience any errors during and beyond the Guarantee Period and Warranty Period.
c) All this information helps us to improve and update the Brewie OS so you can enjoy more using Brewie.
d) We also would like to use the gathered information during the development of the next generation of our Products.
e) Besides that, we also might need those data for the establishment, exercise or defense of our potential legal claims as well.

In light of the limitations regarding data processing, the safeguards, technical and
organizational measures implemented by us, we have established that where the
processing of your data is based on our legitimate interest, such interest is not
overridden by your interests, fundamental rights or freedom relating to data protection.

6.6. Repair of Brewie:
a) Processed data: account & operational data
account data: e-mail
shipping address (see above at ‘Shopping at the Brewie Shop’).
operational data (see above at ‘Usage Analysis of Brewie’)
b) Source of data: Customer and Brewie OS.
c) Legal basis of processing:
contractual obligation (see Section 11. of the Terms);
consent beyond the Guarantee Period and Warranty Period.
d) Duration of processing:
contractual obligation: until Guarantee Period and Warranty Period expire;
consent: until repair is finished and approved by the Customer.
e) Place of storage: servers provided by Google.
f) Processor(s):
Companies that service and fix machines (see Section 4)

We process your data detailed above to fulfill our contractual obligations undertaken in the Contract, i.e. to satisfy guarantee/warranty claims if proven to be grounded by the Brewie OS. Beyond the Guarantee Period and Warranty Period, we process your data to help you connect with our Repair Service Providers in case your Brewie need to be repaired by sending your data to the Repair Service Provider in advance, and also to keep in touch with you during procedure.

7. Cookie-policy

We use the following types of Cookies and statistical codes: Google Analytics cookie; Optimonk cookie; Facebook Pixel; identification cookie (collecting IP addresses and no personal data).

8. Liability

8.1. The Controller is liable for the damage caused by processing which infringes the GDPR or the relevant laws of Hungary. However, we will not be liable if we prove that we are not in any way responsible for the event giving rise to the damage, especially in the any of the following cases:
a) Vis Maior;
b) infringement of the GDPR by a Processor if the regulation is specifically directed to processors;
c) any negligence of yours while providing your personal data to the Controller.

8.2. You are solely liable:
a) to take all necessary measures in order to keep your passwords safe and secure related to your Account / e-mail address / Social Media Platforms;
b) to use safe and secure internet networks / connections, passwords and electronic devices;
c) to keep your personal data provided to the Controller up-to-date, real, accurate and complete at all times. If any of your personal data provided changes, you must inform us without undue delay and in any event within five days of becoming aware of the change in your data.

8.3. The Controller reserves the right to unilaterally change this Policy in which case the Controller will send a notification e-mail to inform you about the recent updates and the date when the updates will go into effect.
By the continuous use of the Product or our services after the date when the updates go into effect, you declare that you have read, understood and acknowledged the entire updated Policy as binding.

9. Exceptions related to Companies

9.1. If you provide data on behalf of a company, the following provided information will not be regarded as personal data: company name, TAX/VAT number, company address. All other provided data which are related to you as a representative or contact person will be handled as detailed above in this Policy.

10. Governing laws

10.1. This Privacy shall be governed and interpreted in accordance with the GDPR and the relevant laws of Hungary. To any issues not regulated in this Privacy Policy the provisions of the GDPR and the relevant Hungarian laws will prevail.

10.2. In case of any dispute arising from or in connection with this – if possible by the relevant laws – the dispute will be solved by the courts of Hungary.

Place and date: Budapest (Hungary), May 31st, 2018.

© 2018 All rights reserved! NEWITY Ltd.

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