Privacy Policy

This document provides information about the processing of personal data related to the Gammatica software („Gammatica” or "Software") owned and operated by Gammatica Korlátolt Felelősségű Társaság. as the data controller („Gammatica Kft.” or "Controller").

The personal data of the customers using the Software ("Data Subject"or "User") in the course of the operation of the Software is processed by the Controller in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 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 Regulation (EC) No 95/46/EC ("GDPR") and Hungarian data protection regulation.

Data Controller hereby informs the Data Subjects about the data processing that may be associated with the use of the Software.

Data Controller reserves the right to unilaterally amend this document at any time. The amended Privacy Notice shall be effective as of the date of its publication.

1.Data Controller

Company name: Gammatica Kft.

Registered office: 1123 Budapest, Nagyenyed utca 5. pinceszint

Postal address: 1123 Budapest, Nagyenyed utca 5. pinceszint

Company registration number: 01-09-434270

Court of registration: Hungary

Tax number: 32628186-2-43

Community Tax Number: HU32628186

Represented by: Várhegyi Viktor Dániel, Managing Director

Email address: hello@gammatica.com

hereinafter referred to as "Data Controller"

2. Data processing during the use of the Software

a) Contact by e-mail (hello@gammatica.com)

Purpose of processing: to contact the User and reply to the information he/she has sent by e-mail

Legal basis for processing: the User's prior informed and voluntary consent (Article 6(1)(a) GDPR)

Data processed: e-mail address, other personal data provided by the User (typically name)

Data retention period: Data Controller retain the e-mail(s) for 3 months from the date of contact / last communication with the User.

Authorised access: authorised employees or agents of Data Controller who are responsible for maintaining contact and responding to enquiries.

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b) Registration and user account management

By clicking on the "Registration" link, User declares that he/she has read the Terms of Service and the Privacy Notice, understands their contents and accepts the terms of data processing.

Purpose of processing: registration in the Software and access to the Software, sending reports to the User

Legal basis for processing: performance of a contract between Data Controller and  User (Article 6(1)(b) GDPR)

Data processed for registration: first name and last name, e-mail address of Users.

After registration, users can log in by entering their email address and password or by using their Google Account.

The head of the user organisation can invite team members to Gammatica by sending invitation to their e-mail addresses.

Data processed for user account management: first name and last name, password, e-mail address, language of Users. Voluntarily User's position can be add and User’s profile picture can be uploaded.

Data retention period: Data Controller shall keep the personal data relating to the registration for five years after the termination of the contract with User. Data Controller shall keep the contact details until User notifies Data Controller of the termination of the contact details.

Authorized employees and agents of Data Controller who are responsible for the operation of the Software.

When using Gammatica, users can upload different content (including private contents), clients’ data, comment on tasks for team members and give ratings, report problems and link posts to their calendars. These are all user-driven activities, for which Gammatica provides the platform and necessary data security, but Gammatica excludes all responsibility for the content, data adequacy, legality and availability of the linked third party service providers.

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c) Billing

Purpose of processing: Billing for services used

Legal basis for processing: Fulfilling the legal obligation of Data Controller (Article 6(1)(c) GDPR; Hungarian Acts: Article 169 (2) of Act C of 2000 on Accounting; Article 77-78 of the Act CL of 2017 on the Rules of Taxation )

Data processed for registration: name of the data subject/company, billing address, company tax number, bank account number in case of bank transfer

Data retention period:In accordance of the provisions of Act C of 2000 on Accounting the Data shall be kept for 8 years after the reference year

Authorized employees and agents of Data Controller who are responsible for billing and

Authorised access: authorised employees of the Data Controller whose financial and invoicing tasks fall within their remit and will be forwarded to the accountant.

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3. Recipients, Data transfers, Data processors

The Users’ personal data will be transferred or made available to:

Name

Contact information (address, e-mail address)

Purpose of the data transfer/ task performed by the recipient

VAMOSOFT Korlátolt Felelősségű Társaság

Located at 2310 Szigetszentmiklós, Kert utca 6., E-mail: info@vamosoft.hu, Privacy notice available: https://vamosoft.net/hu/data-privacy/

software development and support

Szigeti-Korán

Located at 1132 Budapest, Visegrádi utca 48. fszt. 4., E-mail: info@szigeti-koran.hu, Privacy notice available: http://www.szigeti-koran.hu/index.php/kapcsolat

Accountant

Digital Ocean

Located at DigitalOcean 101 6th Ave New York, NY 10013 ATTN: Legal.

Email: privacy@digitalocean.com.,

Privacy notice available:

https://www.digitalocean.com/legal/data-processing-agreement

Hosting service

Stripe Payments Europe Limited

Located at Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland, E-mail: privacy@stripe.com  

Privacy notice available: https://stripe.com/en-hu/privacy

Stripe - online payment  system

Billingo Technologies Zártkörűen Működő Részvénytársaság

Located at 1133 Budapest, Árbóc utca 6. I. emelet; E-mail: hello@billingo.hu, Privacy notice available: https://www.billingo.hu/adatkezelesi-tajekoztato

Billingo - online billing system

Smartsupp - Online chat system

Smartsupp.com, s.r.o. , ID No.: 036 68 681, with registered office at Šumavská 31, 602 00 Brno, represented by Vladimír Šandera, Managing Director, registered in the Commercial Register maintained by the Regional Court in Brno, file No. C 86206

Data Protection Officer: Mgr. Petra Stupková,  GDPR processing processes (contact: dpo@smartsupp.com)

Google Analytics and search console

Meta pixel

https://www.facebook.com/business/tools/facebook-conversions-api

https://developers.facebook.com/docs/marketing-api/conversions-api/

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Google Tag manager

https://developers.google.com/tag-platform/tag-manager/server-side/overview

https://support.google.com/google-ads/answer/11347292?sjid=13132835489466327554-NC

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4. Data Subjects' rights in relation to data processing

4.1. Right of access

Data Subjects have the right to request information from Data Controller, through the contact details provided in this Notice, as to whether or not their personal data are being processed and, if such processing is taking place, the right to be informed that

• what personal data Controller is processing; on what legal basis; for what purpose; for how long;
• to whom, when, under what law, to which personal data the Data Controller has given access or to whom Data Controller has transferred the personal data;
• the source of their personal data;
• whether Data Controller uses automated decision-making and its logic, including profiling.

Data Controller shall provide to Data Subjects’ a copy of their processed personal data free of charge for the first time upon the Data Subject's request, and may charge a reasonable fee based on administrative costs thereafter. In order to ensure data security and to protect the rights of Data Subject, Data Controller shall verify the identity of Data Subject and of the person who wishes to exercise his or her right of access.  The request of information, access to or copying of the Data shall be subject to the identification of Data Subject.

2. Right to rectification

Data Subject may request the Controller to rectify any of his or her personal data through the contact details provided in this Notice. If the Data Subject can credibly demonstrate the accuracy of the rectified data, the Controller shall comply with the request within a maximum of one month during the period of processing and shall notify Data Subject thereof using the contact details provided by Data Subject.

3. Right to restriction of processing

Data Subject may request, through the contact details provided in this Notice, that Data Controller restricts the processing of his or her personal data (by clearly indicating the restriction of processing and ensuring that it is kept separate from other data) where

• Data Subject disputes the accuracy of his or her personal data (in which case the Controller will limit the processing for the time necessary to verify the accuracy of the personal data);
• the processing is unlawful and Data Subject opposes the erasure of the Data and requests instead the restriction of their use;
• Data Controller no longer needs the personal data for the purposes of the processing but the Data Subject requires them for the establishment, exercise or defence of legal claims; or
• Data Subject has objected to the processing (in which case the restriction shall apply for a period of time until it is established whether the legitimate grounds of Data Controller override the legitimate grounds of Data Subject).

4.4. The right to object

Data Subject may object to the processing of his or her personal data if he or she considers that Data Controller is processing his or her personal data inappropriately in relation to the purposes stated in this Notice by contacting Data Controller via the contact details provided in this Notice. In such a case, Data Controller must demonstrate compelling legitimate grounds for processing the personal data which override the interests, rights and freedoms of Data Subject or for the establishment, exercise or defence of legal claims.

4.5 Right to erasure

In relation to the processing described in this Notice, Data Subject may exercise his or her right to erasure if the she or he has withdrawn his or her consent (in the case of processing based on consent) and there is no other legal basis for the processing or the purpose of the processing has ceased.

4.6 Right to data portability

Data Subject may request to receive the personal data provided to Data Controller in a structured, commonly used, machine-readable format, where the processing of personal data is based on consent and the processing is carried out by automated means.

4.7. Right to legal remedies

If you believe that Data Controller has infringed your rights in the processing of your personal data, you can contact us at hello@gammatica.com.

If you believe that your rights concerning your personal data have been infringed, you can lodge a complaint with the authority at the following contact address:

Nemzeti Adatvédelmi és Információszabadság Hatóság (Located at: 1055 Budapest, Falk Miksa utca 9-11 , Postal address: 1363 Budapest, Pf.: 9., Phone: +36 (1) 391-1400, Fax: +36 (1) 391-1410, E-mail address: ugyfelszolgalat@naih.hu.)

In the event of a breach in the processing of your personal data, you may also take legal action. The court has jurisdiction to hear the case. According to the choice of Data Subject the action may also be brought before the courts for the place where Data Subject resides or is domiciled.

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Dated on Budapest, 2024.07.01