This Privacy Policy (the “Policy”) explains how the SignAll Technologies Informatikai Zártkörűen Működő Részvénytársaság (registered seat: H-4024 Debrecen, Wesselényi utca 2. fszt. 19., Hungary; registration number: 09-10-000549; tax number: 25475261-2-09; hereinafter: “SignAll”, “Company” or “Data Controller”) processes personal data of you (“you” or “Data Subject”) while using the services of the Company (“Service” or “Services”). Furthermore, this Policy declares the rights and obligations regarding the processing of personal data and other essential provisions. This Policy forms an integral part of the Company’s terms of use (hereinafter: “Terms of Use”).
Please read and make sure you understand this Policy. If you do not agree with this Policy or our practices, you may not use our website (located at https://www.signall.us, including all its subdomains; hereinafter: “Website”) and our Services. This Policy may change from time to time and your continued use of our Website constitutes your acceptance of those changes. We encourage you to review this Policy periodically.
The processing and collecting of personal data by SignAll shall be in harmony with the directly applicable data protection laws in effect. In case of personal data processing, the Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter: “GDPR”), the Hungarian Act CXII of 2011 on the Right to Informational Self-determination and Freedom of Information (hereafter: “Freedom of Information Act”), the Hungarian Act XLVIII of 2008 on the Essential Conditions and Certain Limitations of Business Advertising Activity (hereinafter: “Business Advertising Act”), the Hungarian Act CVIII of 2001 on the ecommerce services and information society services (“Ecommerce Act”), furthermore the recommendations and the data protection practice of the Hungarian National Authority for Data Protection and Freedom of Information (hereinafter: “NAIH”) and the recommendations of the Article 29 Data Protection Working Party (hereinafter: “WP29”) and of the European Data Protection Board (hereinafter: “EDPB”) shall apply.
The Company is the data controller of any data which constitutes personal data and which is uploaded when using our Services.
The Company bound in honor to protect personal data therefore, the Company will keep confidential the personal data received and take all necessary steps to secure data processing.
The following definitions are determined according to the GDPR:
‘personal data’: shall mean any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
‘consent’: shall mean any freely given, specific, informed and unambiguous indication of the will of the Data Subject by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
‘data controller’: shall mean the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
‘data processing’: shall mean any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
‘data processor’: shall mean a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
‘third party’: shall mean a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data;
‘personal data breach’: shall mean a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed;
‘recipient’: shall mean a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with European Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;
‘supervisory authority’: shall mean one or more independent public authorities provided by each Member State which is responsible for monitoring the application of the GDPR in order to protect the fundamental rights and freedoms of natural persons in relation to processing and to facilitate the free flow of personal data within the European Union;
‘supervisory authority concerned’: shall mean a supervisory authority which is concerned by the processing of personal data because: (a) the controller or processor is established on the territory of the Member State of that supervisory authority; (b) data subjects residing in the Member State of that supervisory authority are substantially affected or likely to be substantially affected by the processing; or (c) a complaint has been lodged with that supervisory authority.
SignAll collects and processes the personal data of the Data Subjects solely for the purposes set forth in this Policy and ensures that the data processing is carried out at all stages in accordance with the purpose of the data processing.
The information we gather from users enables SignAll to provide, personalize and improve the Services.
SignAll processes the following personal data of Data Subjects who register on the Website:
To provide the Services to the Data Subject
Section 6 1. (a) of GDPR (consent of the Data Subject)
SignAll processes the personal data until the Data Subject withdraws its consent
SignAll processes the following personal data of Data Subjects who use the SignAll LAB installations of the Data Controller:
To provide the Services to the Data Subject
Section 6 1. (a) of GDPR (consent of the Data Subject)
SignAll processes the personal data until the Data Subject withdraws its consent
The Data Controller processes the following personal data of the Data Subject during the use of the ACE ASL mobile application:
Improving the Services
Section 6 1. (a) of GDPR (consent of the Data Subject)
SignAll processes the personal data until the Data Subject withdraws its consent
The Data Controller processes the following personal data of the Data Subject to provide its newsletter services:
To provide the newsletter services to the Data Subject.
Section 6 1. (a) of GDPR (consent of the Data Subject)
SignAll processes the personal data until the Data Subject withdraws its consent
The Data Controller processes the following personal data of the Data Subject when the Data Subject requests a consultation with SignAll on the Website:
To contact the Data Subject.
Section 6 1. (a) of GDPR (consent of the Data Subject)
SignAll processes the personal data until the Data Subject withdraws its consent
SignAll processes the following personal information of the natural person representative of the business partner of Data Controller:
To contact the Data Subject, furthermore, to fulfill obligations arising contract.
Section 6 1. (a) and section 6 1. (f) of GDPR (consent of the Data Subject / necessary for the performance of the contract)
SignAll processes the personal data of the Data Subject until it is necessary for the fulfillment of the contract or until it is prescribed by law (e.g. taxation laws)
We receive and store certain types of information whenever you interact with our Website or Services. SignAll automatically receives and records information on our server logs from your browser including your IP address, unique device identifier, browser characteristics, domain and other system settings, search queries, device characteristics, operating system type, language preferences, referring URLs, actions taken on our Website, page requested, content consumed (e.g., viewed, uploaded, and shared), dates and times of Website visits, and other information associated with other files stored on your device.
The time of the visit, the recording and storage of the IP address and the data of the browser and the operating system are a feature of the operation of the system, they are technically essential, they are used for statistical purposes only, SignAll does not perform further data processing with this data.
Improvement of the Website
Section 6 1. (a) of GDPR (consent of the Data Subject)
The collected data is stored for 60 days.
The Company processes anonymous data in order to improve the Website. During this procedure SignAll can incorporate “cookies”, which collect the visitor’s first level domain name, the date and the exact time of access. The “cookie” alone can’t be used to reveal the identity of the visitor. The “cookie” is a file, which is sent to the browser of the visitor and stored on the hard drive of visitor. Cookies don’t damage the computer of the visitor. The browser can be set to indicate when a cookie is received, so the visitor can decide to accept the cookie or not. The Company does not use cookies to collect or manage any information that would allow the identification of the user. Please see our cookie policy by visiting the following link in order to find out how our cookies work.
SignAll taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for rights and freedoms of natural persons posed by the processing, the controller shall, both at the time of the determination of the means for processing and at the time of the processing itself, implement appropriate technical and organisational measures, such as pseudonymisation, which are designed to implement data-protection principles, such as data minimisation, in an effective manner and to integrate the necessary safeguards into the processing in order to meet the requirements of the GDPR and protect the rights of data subjects.
Lawfulness, fairness and transparency: The Data Controller shall make every effort to ensure that the personal data provided to it is processed lawfully and fairly and in a manner that is transparent in relation to the Data Subject.
Purpose limitation: SignAll implements measures to ensure that, by default, only personal data that is necessary for a specific data processing purpose is processed. This obligation applies to the amount of personal data collected, the extent to which they are processed, the duration of their storage and their availability. These measures ensure that, by default, personal data will not be made available to an indefinite number of persons without the intervention of the Data Subject.
Data minimization: The Data Controller only collects and stores personal data that is relevant for the purposes of data collection and does not use it in a way that is incompatible with the purposes indicated by it, unless such use has been authorized by the Data Subject.
Accuracy: The Data Controller takes reasonable steps to ensure that personal data is reliable, accurate, complete and current for its intended use. From time to time, the Company may contact the Data Subject to determine that its information is still accurate and current.
Storage limitation: SignAll keeps personal data in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
Integrity and confidentiality: SignAll processes the personal data it collects in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
We will retain your personal data for so long as it is needed to fulfill the purposes outlined in this Policy or until you withdraw your consent, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements, further for the establishment, exercise or defense of legal claims). When we have no longer or no legal basis to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Information about our users is an integral part of our business, and we may share such information with our affiliated entities. Except as expressly described below, we neither rent nor sell your information to other people or nonaffiliated companies unless we have your permission.
SignAll shall not ensure access for a third party to personal data provided by you without your preliminary consent, except the cases, when data transfer is necessary for the performance of the contract or for enforcing of SignAll’s legitimate interest or prescribed by law.
SignAll may share certain personal information with third party vendors in the EU or in third countries, who supply software applications, web hosting and other technologies or services for the Website and our Services (hereinafter: “Data Processor”). The Company will only provide these third parties with access to information that is reasonably necessary to perform their work or comply with the law. Those third parties will never use such information for any other purpose except to provide services in connection with the Website and our Services. During the service of data process, the Data Processor shall abide under the present Policy, relevant legislations in force, furthermore the provisions of the existing contracts between them and SignAll.
We use the data process service of the following Data Processors:
SignAll shall comply with the Data Subject’s request for the exercise of their rights within a maximum of one month from its receipt. The date of receipt of the application does not count towards the deadline.
The Data Subject shall have the right to obtain from the Data Controller confirmation as to whether or not personal data concerning them are being processed, and, where that is the case, access to the personal data and the following information:
SignAll will provide a copy of the personal data subject to data processing free of charge for the first time upon the Data Subject’s request, after which it may charge a reasonable fee based on administrative costs.
In order to meet the data security requirements and to protect the rights of the Data Subject, SignAll is obliged to make sure that the Data Subject and the person wishing to exercise the right of access are the same, to that end, information, access to and the provision of a copy of the personal data shall be subject to the identification of the person concerned.
The Data Subject may request the Data Controller to change any of their personal data via the hello@signall.us e-mail address. If the Data Subject can reasonably prove the accuracy of the corrected data, the Data Controller shall comply with the request within a maximum of one month and shall notify the Data Subject on the contact details provided to the Data Controller.
In connection with the data processing specified in sections 2.1-2.7 of the Policy – subject to their legal basis -, the Data Subject is entitled to request the deletion of their personal data without undue delay, and the Data Controller is obliged to delete the personal data concerning the Data Subject without undue delay, unless there is another legal basis for the processing of the data.
SignAll will not comply with the Data Subject’s request for deletion if the data processing is necessary to fulfill the legal obligation applicable to SignAll requiring the processing of personal data.
If a deletion request is received by the Data Controller it will first inspect whether the deletion request actually originated from the right holder. To this end, the Data Controller may request data for the identification of the Data Subject (e.g. contract number, date of contract), the identification number of the document issued to the Data Subject by SignAll, or any personal data registered, however the Data Controller may not request personal data which it does not keep records of in relation to the Data Subject.
The Data Subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
In certain cases the Data Subject is entitled to object to the processing of their personal data if in their opinion, the Data Controller would not properly process their personal data in connection with the purpose indicated in the Policy. The Data Controller examines the lawfulness of the Data Subject’s objection and if the objection is justified, it shall terminate the data processing and block the processed personal data and notifies all those to whom the personal data affected by the objection have previously been transferred, about the objection and the measures taken by the Data Controller.
Subject to their legal basis, the Data Subject does not have the right to object against the data processing activities set forth in other sections of this Policy.
In connection with the data processing specified in sections 2.1-2.7 of the Policy – subject to their legal basis -, the Data Subject is entitled to receive the personal data concerning them, which they have provided to SignAll, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from SignAll.
Our Website is not directed to children under 16 and we do not knowingly collect personal information from children under 16. If we learn that we have collected personal information of a child under 16 we will take steps to delete such information from our files as soon as possible. If you are aware of anyone under 16 using the Website, please contact us at hello@signall.us.
If the Data Subject considers that SignAll has violated the applicable data protection laws in relation to the processing of their personal data, then
We will modify this Policy if our privacy practices change. We will notify you of such changes by posting the modified version on our Website and indicating the date it was last modified, and, if the changes are significant, we will provide a more prominent notice (including by email in certain instances). Please periodically review this Policy so that you are familiar with the current Policy and aware of any changes.
If you have any questions concerning this Policy or the Services, please contact us at hello@signall.us.