INTRODUCTION

This Privacy Policy describes the data protection practices of Presskontakt Bt, creator of the IROSULI.HU online writing academy (referred as “IROSULI®”).

 

PRESSKONTAKT BT (“Presskontakt,” “us,” “we,” or “our”) respects the privacy concerns of our customers, the members of IROSULI.HU, and all users of our websites, www.irosuli.hu and www.irosuli.com, applications, and all other products and services (collectively, the “Product”).  We are committed to protecting and respecting your privacy. This Privacy Policy (the “Privacy Policy”) and any other documents referred to in it sets forth the basis on which any personal data we collect from you, or that you provide to us, in connection with the Product will be processed by us. We are providing this Privacy Policy so that you can better understand how we collect, use, and share information that is gathered using our Product.

 

We may change provisions of this Policy from time to time and will indicate when changes have been made by revising the date at the top of this Policy. We encourage you to review the Policy whenever you access our products and services to make sure that you understand our practices.  If we make material changes to this Policy, we will provide you with additional notice.

It’s important that you read the following carefully to understand our practices.

 

DATA PROTECTION

Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply common protections described in this policy. These protections align with well-known standards such as ISO 27001:2017 and others. 

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INFORMATION WE COLLECT THROUGH THE USE OF OUR PRODUCT

We may collect a variety of information that you provide directly to us. For example, we collect information from you through: (1) create an account; (2) subscribe to our Newsletter; (3) participate in events or promotions; (4) send questions or comments via email or live chat; (5) sign up for our Product  (6) interact with our sales or customer support team; (6) apply for a job with us online; (7) fill out surveys and questionnaires; or (8) requests or questions you submit to us via online forms, email or otherwise

 

The types of personal information that you provide may include your name, email address, telephone number, mailing address, credit card information, log-in credentials if you create an IROSULI® account, billing information (such as company address), log-in credentials, if you create an IROSULI® account, demographic information such as your gender, place of residence or other information you choose to provide as part of your IROSULI® profile, classes you register for, User-generated content you provide to us, such as when you comment on content on the Services, respond to a survey request, review a class, or participate in public forums and other information you choose to directly provide to us in connection with your use of the Services. We store, process, and maintain files and content that you create and/or upload using our Product, as well as other data related to your account in order to provide the Product to you.

If you request that your purchase be provided to someone other than yourself (such as a gift recipient), we use the information you provide about the other person to provide the service.

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We do not store any credit card information we receive except as necessary to complete and satisfy our rights and obligations with regard to such transaction, billing arrangement, and/or as otherwise authorized by you.

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Our servers automatically collect usage information about your use of the Product, including the webpages visited, number of log-ins, data displayed or clicked on, actions taken, your language preference, and other login information. We may collect automated error reports in the case of software malfunctions, which may contain some or all of the information in your account and content and may be reviewed to help resolve problems with the Product.

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If you participate in a video conference with us, we may record the session and retain the recordings. We will notify you first if the session is being recorded so that you can choose not to participate. If you participate in a course, we collect completion data.

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We collect information from the device and application you use to access our Product. Device data mainly means your IP address, operating system version, device type, device ID/MAC address, system and performance information, and browser type. If you are on a mobile device we also collect the UUID for that device.

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We use a variety of technologies to collect this information, such as first party and third party cookies and tracking services that employ cookies and page tags (also known as web beacons). This data includes usage and user statistics. Emails sent by IROSULI® or by users through our Product also include page tags that allow the sender to collect information about who opened those emails and clicked on links in them. We provide more information on cookies in our Cookie Notice.  

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Like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system versions, device type and timestamps.

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If you arrive at IROSULI® from an external source (such as a link on another website or in an email), we record information about the source that referred you to us.

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Information from third parties and integration partners

We may obtain personal information from third parties and combine such information with the information that we collect through our Product and such information may be used for the purposes described in the “How We Use the Information We Collect” section below. 

 

For example:

• You give permission to those third parties to share your information with us or where you have made that information publicly available online.

• You create or log into your account through a third-party social networking site or one of our integration partners, we will have access to certain information from that service such as your name and account information.

• If you purchase our Product, we may receive information from our third-party payment processors.

• We may collect information from unaffiliated third parties so that we can better understand you and provide you with information and offers that may interest you.
   

HOW WE USE THE INFORMATION WE COLLECT

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We may use the personal information collected through our Product to:

• Operate and improve our Product;

• Send you advertising or promotional materials;

• Provide and deliver the Product or other services you request, process transactions, and send you related information;

• Send you technical notices, updates, security alerts, and support and administrative messages;

• Respond to your comments, questions, and requests and provide you with requested customer support;

• Monitor and evaluate trends, usage, and activities in connection with our Product;

• Secure our systems, prevent fraud, and help us to protect the security of your account;

• Prevent, detect, and investigate potentially prohibited or illegal activities and to enforce our terms and policies;

• Personalize and improve the Product, and provide content, communications, or features that match users interests; and

• Link or combine with other information we obtain from third parties to help understand your needs and provide you with better service.
   

INFORMATION WE COLLECT FROM SOCIAL MEDIA AND OTHER CONTENT PLATFORMS

If you access the Product through a third-party connection or log-in (e.g., through a social network like Facebook or Twitter), you may allow us to have access to and store certain information from your social network profile. This can include your name, gender, profile picture, your “likes” and check-ins, and your list of friends, depending on your settings on such services. If you do not wish to have this information shared, do not use a social networking connection to access the Product. For a description of how social networking sites handle your information, please refer to their privacy policies and terms of use, which may permit you to modify your privacy settings. You may also have the option of posting your activities to Social Networking Services when you access content through the Product (for example, you may post to Facebook that you enrolled in a class); you acknowledge that if you choose to use this feature, your friends, followers and subscribers on any Social Networking Services you have enabled will be able to view such activity.

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We reserve the right at all times to review your content and information to help resolve problems with our software or Product, or to ensure that you remain in compliance with our Terms of Service and other policies.

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Information we may share:  We will never “sell” your personal information (as that term is defined in the policy of the European Commission Order (2016/679) and the law of 1992/LXIII. rectified by the Hungarian Parliament about personal data protection.

 

However, we may share your personal information with third parties as follows:

• Service Providers:  We use other companies, agents, or contractors to perform services on our behalf or to assist us with the provision of services to you. For example, we engage service providers to provide marketing, advertising, communications, security, payment processing, infrastructure and IT services, to customize, personalize, and optimize our Product, to process payment transactions, to provide customer service, and to analyze and enhance data.  While providing such services, these service providers may have access to your personal information. These service providers have agreed to maintain the confidentiality, security, and integrity of the personal information that they obtain from us and we do not authorize them to use or disclose your personal information except in connection with providing their services.

• Protection of IROSULI® and others:  IROSULI® and its service providers may disclose and otherwise use your personal information where we or they reasonably believe such disclosure is needed to (i) satisfy and applicable law, regulation, legal process, or governmental request; (ii) enforce applicable terms of use, including investigation of potential violations; (iii) detect, prevent, or otherwise address illegal or suspected illegal activity, security, or technical issues; or (d) protect against harm to the rights, property, safety of IROSULI®, our users, or the public, as required or permitted by law.

• Business transfers:  In connection with any reorganization, restructuring, merger, or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your privacy in a manner that is consistent with our Privacy Policy.

• Other Users:  Content that you create, upload, or copy into our Product, may, if you choose, be read, copied, used, and distributed by people you know, your members, or people you don’t know. Information that you disclose using the chat function of the Product may be read, copied, used, and distributed by people participating in the chat. Use care when including sensitive information, such as home addresses or phone numbers, in content you share or chat sessions.

• With Your Consent:  We may share your personal information when we have your consent.

 

Whenever in the course of sharing information, we transfer personal information to countries within the European Economic Area or other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with this Privacy Policy and as permitted by the applicable laws on data protection.

Advertising and analytics services provider by others:  We may allow others to provide analytics services and display advertisements for our Product.  These providers (for example, Google Analytics) may use cookies, web beacons, device identifiers, and other tracking technologies that collect information about your use of our Product. This information may be used by us and others to determine the popularity of our Product, deliver advertising and content targeted to your interests in the Product, and on other websites, apps, and other services, and to better understand your online activity. 

 

WHERE WE STORE YOUR PERSONAL DATA

Data Storage:  All data that you provide to use through our Product is stored on secure servers operated by our web developer partner Wix.com.  Any payment transactions will be encrypted using SSL technology; all payment data is stored by our payment processors and is never stored on our servers. Where we have given you (or where you have chosen) a password that enables you to access your account and the Product, you are responsible for keeping this password confidential. We recommend that you not share your password and that you change it frequently.

Data Security:  IROSULI® takes reasonable measures to protect your personal information and your content from loss, misuse, and unauthorized access, disclosure, modification, and destruction and to ensure that your content remains protected and available to you.  Unfortunately, the transmission of data via the internet is not completely secure and although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted through the Product.  All transmissions are at your own risk.

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Data Retention

IROSULI® stores the information we collect for as long as necessary for the purpose for which it was originally collected and in compliance with our legal obligations. The retention periods applied by IROSULI® comply with applicable legislation then in effect, namely:

• For data relating to your account, such data will not be retained beyond your request that your account be deleted.

• For transactional data relating to your purchases, such data is kept for the entire period of our contractual relationship, then in accordance with legal obligations and applicable statute of limitations periods. Please note that this data does not include payment card information, which is processed by our third-party payment processors and not IROSULI® or Presskontakt.

• For data collected based on your consent to receive marketing communications, we will use the data until you withdraw your consent or applicable law requires that such data is no longer used.

• For data collected in connection with your requests or questions, such data is kept for the period necessary to process and reply to your request or question.

• When cookies or other trackers are placed on your computer, they may be retained for a period of 12 months.

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RETENTION OF YOUR INFORMATION

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

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HOW WE PROTECT YOUR INFORMATION

IROSULI® takes technical and organizational security measures to protect the information provided via the Product from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. Please keep this in mind when disclosing any information to IROSULI® via the Internet.

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THIRD-PARTY LINKS AND FEATURES

Our website contain links to third-party websites such as social media sites, and also contain third-party plug-ins (such as the Facebook “like” button and Twitter “follow” button). If you choose to use these sites or features, you may disclose your information not just to those third-parties, but also to their users and the public more generally depending on how their services function. We are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third party websites or services, and not this Privacy Policy. We urge you to read the privacy and security policies of these third-parties.

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CHILDREN’S PRIVACY

The Product are intended for general audiences and for children above the age of 12. If we become aware that we have inadvertently collected “personal information” (as defined by the laws of Online Privacy Protection Act rectified by the Parliament of the Republic of Hungary) from children under the age of 12 without valid parental consent, we will take reasonable steps to delete it as soon as possible. We recognize the special obligation to protect personally identifiable information obtained from children age 12 and under. We do not knowingly process data of EU residents under the age of 12 without parental consent. If you are 12 years old or younger, the company requests that you do not submit any personally identifiable information to the site or to IROSULI® without valid parental consent.

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If we become aware that we have collected data from a child under the age of 12 without parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.

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IROSULI® nonetheless encourages parents to go online with their children. Here are four tips to help make a child’s online experience safer:

• Teach kids never to give personal information, unless supervised by a parent or responsible adult. Includes name, address, phone, school, etc.

• Know the sites your kids are visiting and which sites are appropriate.

• Look for Website privacy policies. Know how your child’s information is treated.

• If you are concerned about a website, contact the website owner and request information about their policies of data protection regarding children.
   

How We Use “Cookies” and Other Tracking Technologies

We use cookies, which are pieces of information that a website transfers to an individual’s computer hard drive for record keeping purposes, and similar tracking technologies on our website and when providing our Product. Cookies make using our website easier by, among other things, saving your passwords and preferences for you. These cookies are restricted for use only on our website, and do not transfer any personal information to any other party.  For more information about how we use these technologies, including a list of other companies that place cookies on our website, a list of cookies that we place when we power a customer’s business, and an explanation of how you can opt out certain types of cookies, please see our Cookie Notice.

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Your Choices and Rights

You have several options with respect to your personal information, as follows:

• You may terminate your use of the Product at any time. 

• If you have created an account, you may at any time access, edit, or delete your personal information. Please note that even if you delete information from your account, or deactivate your account, we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of your information for a certain period of time.

• You may opt out of receiving promotional emails, text messages, or mail from IROSULI® by visiting your user settings via the Log in section, and/or click on the Unsubscribe link in any promotional email. If you opt out, we may still send you transactional or relationship messages, such as emails about your account or updates to our Product.

• If you do not have a user account and wish to delete your email address or other personal information that you might have provided through your use of our Product and/or any other services, please email us at: support@irosuli.hu with the words “Delete My Data” in the subject line.
   

Malware/Spyware/Viruses

We do not knowingly permit the use of malware, spyware, viruses, and/or other similar types of software.

 

Links to External Sites

Our Product may, from time to time, contain links to and from third party websites, such as partners, affiliates, and advertisers. We may also refer our customers to businesses and sites we found useful in relation to the theme of our products (aka the art of writing, editing, book publishing etc.). If you follow a link to any external website, it will have its own privacy policy and we are not responsible for the content or practices of such third party websites or their policies. We are also not responsible for any information that you might share with such linked websites. You should refer to each website’s respective privacy policy and practices before you submit any personal information.

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Data Posted on Forums

IROSULI® users may have the ability to post content to one or more IROSULI® forums, such as chat rooms and bulletin boards, including our Facebook group. You should be aware that when you voluntarily disclose personal information in any forum, that information can be collected and used by others and may result in unsolicited messages from other people. You are responsible for the personal information you choose to submit in these instances. Please take care when using these features.  You may request and obtain removal of such posted content by contacting us at support@irosuli.hu and specifically identifying the content to be removed. Please be advised that any such removal does not ensure complete or comprehensive removal of all traces of the content posted on the IROSULI® forums.

 

Transfer of Information outside EU

For users located outside the jurisdiction of the European Union, IROSULI® operates and processes data in the European Union. Information we collect from you will be processed in the European Union, and by using this website you acknowledge and consent to the processing of your data in the European Union. We may have customers in the United States. The United States has not received a finding of “adequacy” from the European Union under Article 41 of the GDPR. We collect and transfer to the U.S. personal data only with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of ours in a manner that does not outweigh your rights and freedoms. When we transfer your personal information to other countries, we will protect that data as described in this Policy or in our agreement with you and take steps, where necessary, to ensure that international transfers comply with applicable laws.

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GDPR policy – data protection for the Residents of the European Economic Area

We provide the representations and information in this section in compliance with European privacy laws, in particular the European General Data Protection Regulation (GDPR). If you are a visitor from the European Territories (including the European Economic Area, Switzerland, and the United Kingdom), our legal basis for collecting and using the personal data described above will depend on the personal information concerned and the specific context in which we collect it.

We will normally collect personal data from you where the processing is in our legitimate interests. In some cases we may collect, and process personal data based on consent. 

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EU data subjects have certain rights with respect to your personal data that we collect and process. We respond to all requests we receive from individuals in the EEA wishing to exercise their data protection rights in accordance with applicable data protection laws.

• Access, Correction or Deletion. You may request access to, correction of, or deletion of your personal data. You can often go directly into the Service under Account Settings to take these actions.

• Objection. You may object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes and may do so using the options provided in this Policy. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override your rights and freedoms.

• Restriction. You have the right to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Portability. You have the right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw Consent. If we have collected and processed your personal data with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.

• File a complaint. You have the right to file a complaint with a supervisory authority about our collection and processing of your personal data. To file a request or act on one of your rights, please contact us at the contact details provided below. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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To submit a request regarding your European Privacy Rights, please see the instructions at the end of this Privacy Policy. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

General Data Protection Regulation (GDPR) - European Representative: Pursuant to Article 27 of the General Data Protection Regulation (GDPR), we have appointed European Data Protection Office (EDPO) as its GDPR representative in the European Economic Area. You can contact EDPO regarding matters pertaining to the GDPR by:

• Sending an email to privacy@edpo.brussels

• Using EDPO’s online request form at https://www.edpo.brussels/contact

• Writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium
   

Changes to our Privacy Policy

We reserve the right to amend this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Product, or advances in technology. We will make the revised Privacy Policy accessible through the Product, so you should review the Privacy Policy periodically. You can know if the Privacy Policy has changed since the last time you reviewed it by checking the “Date of Last Revision" included at the beginning of the document. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the Product, you are confirming that you have read and understood the latest version of this Privacy Policy.

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Contact Information for Complaints or Concerns

We welcome your questions, comments and requests regarding our Privacy Policy and they should be addressed to

PRESSKONTAKT
2131 Göd Pf 82. Hungary

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In the alternative you may reach our customer service at +36 27534359  or our email address info@presskontakt.hu

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Your Acceptance of These Terms

By using our website or Product, you accept the policies and restrictions set forth in this Privacy Policy. If you do not agree to this policy, please do not use the website or the Product.

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