Upon the customer related data managed by DBH Group we inform you about the following.
1./ Data Management regulations defined in this Policy may serve the following purposes:
a) Regarding the services provided by the company:
- Identification of the persons eligible for provision
- Identification of the beneficial owner
- Manage data of client, employees of client and the persons eligible for provisions in order to fulfill the contract with the client
- Invoicing services
- Invoicing of repair and maintenance associated services
- Fulfill data requests in relation of public interest
b) Related to other data management:
- Registration of students with traineeship contracts or other apprenticeship contracts
- Recruitment
2./ In order to comply with legal obligations our Company performs the following data management:
a) Identification of the Beneficial Owner/ Chief
Purpose of data management: comply with legal obligation Scope of managed data: name, birth name, place and date of birth, nationality, address, Social Security Number, Tax ID Legal basis of data management: comply with legal obligation (Act LIII of 2017 on the Prevention and Control of Money Laundering and the Prevention of Terrorist Financing, § 7- 8, hereinafter referred to Pmtv.) Duration of Data Management: 8 years from the date of data registration
b) Copies and details of documents:
Purpose of Data Management: the prevention and control of money laundering and terrorist financing, the proper fulfillment of legal obligations according to Pmtv, the full implementation of the obligation of due diligence and the effective performance of the necessary surveillance. Legal basis of Data Management: Pmtv. 7. § (8) Article
Scope of managed data:
- In case of Hungarian citizens: ID card, Certificate of domicile, Social Security Card, Tax card
- In case of foreign nationals: travel document or ID card if it entitles for Hungarian residence, document certifying the right of residence or document authorize for residence.
Duration of Data Management: 8 years from the date of data registration
c) Contracts for traineeship or apprenticeship
Purpose of Data Management: registering students with traineeship or apprenticeship contracts
Legal basis of Data Management: Act of CLXXXVII of 2011. in section 42.§ – 55.§ on professional trainings
Managed data: name, name of the mother, place and date of birth, ID card number, address (in case of minors: name, address, phone number of legal representative), Social Security Number, Tax ID
Duration of Data Management: 5 years
Transfer of data: for related county chambers of commerce and industry, and for the schools providing education
d) Invoicing services
Purpose of Data Management: sales associated invoicing
Legal basis of Data Management: Act of CXXVII. Of 2007, Article 169. § d) and e) about value added tax and the Act of C. of 2000, Article 169. § (1) about accounting
Managed data: name, address, tax ID
Duration of Data Management: 8 years
e) Invoicing of repair and maintenance associated services
Purpose of Data Management: Invoicing of repair and maintenance associated services
Legal basis of Data Management: Act of CXXVII. Of 2007, Article 169. § d) and e) about value added tax and the Act of C. of 2000, Article 169. § (1) about accounting
Managed data: name, address, premise
Duration of Data Management: 8 years
f) Fulfill data requests in relation of public interest
Purpose of Data Management: Fulfill data requests in relation of public interest and invoicing associated with that Legal basis of Data Management: Act of CXII. of 2011 (“Infotv.”), Article 26.-31. § about Informational Self-determination and Freedom of information;
Managed Data: name, address, telephone number, e-mail address
Duration of Data Management: until accomplishing the aim or until requesting deletion
g) Managing Resumes/Job applications
Purpose of Data Management: filling the advertised position, storing your application with your agreement in order to inform you about open positions that are relevant to your degree, professional qualifications and interests. Legal bases of Data Management: your previous, voluntary consent by submitting your Resume to our company. Duration of Data Management:
- If you are not selected for the position you have applied for or before filling the position you withdraw your application, the purpose of data management is terminated. In case you withdraw your application and explicitly indicate us your request for deleting your data, we will immediately delete your details and your resume. If you do not express your request for deleting your data while informing you about the results of your application or by withdrawal of your application, you agree to keep your application up to 24 months and to inform you about open positions that are relevant to your degree, professional qualifications and interests. After 24 months, we will lock or render your data anonymous, or delete your details and your resume.
- If you are selected for the position, your data will be managed in accordance with the regulations of managing our employee’s personal data, about you will be notified in details by the establishment of your employment.
Persons entitled for being aware of personal data:
- HR staff involved in the recruitment and selection process, leader of the team concerned in hiring the new employee, to the extent and time necessary to perform their duties.
Legal bases of Data Management: your previous, voluntary consent. From any other purposes described above we manage your personal data if we informed you about the purpose of data management and you agreed. About the data management that is not described in this policy, you will be informed when the data is recorded. Your personal data will be managed for a period of time appropriate to the purpose of the data management (e.g. recovery of the enforced claim, etc.) or until your consent is with drawn or tax, consumer protection, property protection and other regulations related to the data management operations.
h.) Processing for direct marketing purposes
The purpose of processing is to present the services in the DBH Group portfolio to potential business partners and circulate commercial advertisements and newsletters for the purpose of direct marketing.
Legal basis for processing: In view of the fact that direct marketing letters are sent exclusively to the electronic contact details (electronic contact address in the company register) of potential business partners who are not natural persons, the legal basis for processing electronic contact addresses (e-mail address containing the name of the natural person), which may constitute personal data, is our legitimate interest in carrying out our economic activity and direct marketing (Article 6(1)(f) of the GDPR).
Scope of the data processed: Electronic contact address (e-mail address)
Data source: Direct marketing database purchased from Opten Informatikai Kft.
Duration of processing: Until the natural person concerned objects.
If the data subject objects to the processing of personal data for direct marketing purposes, the personal data may no longer be processed for such purposes.
As a result of the balancing test carried out with regard to the legal basis, we have concluded that the interests of the data subject do not necessarily override our legitimate interest in processing and that processing does not restrict the privacy of the data subject.
h) Processing for direct marketing purposes
The purpose of processing is to present the services in the DBH Group portfolio to potential business partners and circulate commercial advertisements and newsletters for the purpose of direct marketing.
Legal basis for processing: In view of the fact that direct marketing letters are sent exclusively to the electronic contact details (electronic contact address in the company register) of potential business partners who are not natural persons, the legal basis for processing electronic contact addresses (e-mail address containing the name of the natural person), which may constitute personal data, is our legitimate interest in carrying out our economic activity and direct marketing (Article 6(1)(f) of the GDPR).
Scope of the data processed: Electornic contact address (e-mail address).
Data source: Direct marketingdatabase purchased from Opten Informatikai Kft.
Duration of processing: Until the natural person concerned objects.
If the data subject objects to the processing of personal data for direct marketing purposes, the personal data may no longer be processed for such purposes.
As a result of the balancing test carried out with regard to the legal basis, we have concluded that the interests of the data subject do not necessarily override our legitimate interest in processing and that processing does not restrict the privacy of the data subject.