Your privacy is important to MIGRONIS. We developed this Privacy Notice to provide you with information on how we process your personal data when you prescribed your personal information, interact with our customer support specialists, visit website or visit other MIGRONIS websites that include a link to this Privacy Notice.
We process your personal data in an appropriate and lawful manner, in accordance with applicable data protection regulations and the General Data Protection Regulation EU 2016/679 (the “GDPR”) which is in force as of 25 May 2018.
“Personal data” means 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”.
We will only collect and process personal data about you where we have lawful bases.
Lawful bases are:
- • when you have given consent
- • when we start negotiations for or entering into a contract to supply services to us. (where processing is necessary for the performance of a contract with you (e.g. to deliver the MIGRONIS services you have requested))
- • when you filling in an enquiry form on the Website
- • when you corresponding with us by post, phone email or otherwise when you apply for our services
- • our prevailing legitimate interest to personalize and improve your overall customer experience and achieve the purposes set out above
- • the necessity to comply with legal obligations to which we are subject.
Information we collect about you from our website, we shall use this information:
- • to administer our website and for internal operations, including troubleshooting and in order to keep our website safe and secure;
- • to improve our website to ensure that content is presented in the most effective manner for you; and
- • to ensure that content displayed on the website is presented in a user-friendly manner.
We have implemented measures in an effort to maintain the confidentiality of all personal information in our custody and control, including only providing access to personal information to employees and authorized person who require such information for the purposes described in this document.
We maintain administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, modification and disclosure of personal information in our custody and control.
As concerns all personal data required for the performance of our contract or interaction with you, if you do not provide us with this personal data, we may not be able to deliver the requested service as mentioned in the above.
Personal Data is gathered in the following ways:
- • indirectly (e.g. using website technology that tracks and administers your visits through your browser, or similar technology;
- • directly (when you provide your information when you interact with us);
- • through your device (e.g. mobile, PC or tablet) where you have enabled location services for the applicable App or browser.
You are entitled to exercise the following rights under the GDPR:
You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
Change or Correct Data:
- You can ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate (the “right to rectification”).
Object to, or Limit or Restrict, Use of Data:
- You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
Right to Access and/or Take Your Data:
- You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.
Right to withdraw consent.
- Where you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
Right to move, copy or transfer your personal data (“data portability”).
Right to have your personal data erased (the “right to be forgotten”).
Right to compensation and liability.
You have the right to lodge a complaint with a supervisory authority at your home country. It has enforcement powers and can investigate compliance with data protection law.
You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
MIGRONIS KFT (Hungary) is the data controllers. If you have any questions, you can contact MIGRONIS.
Our contact details:
Mail address: H-2161, Csomád, Verebeshegy utca 11, Hungary
THE TYPES OF PERSONAL DATA WE COLLECT AND USE:
- • Personal details and include your first name, last name, nationality, country of residence, email address and phone number
- • Financial information (billing address, credit card numbers, bank details)
- • Identity documents (passport, ID, birth certificates, tax and bank statements etc.)
- • Website usage data (IP, OS, browser type, usage patterns, the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time) as well as other information regarding your experience on our website such as page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.)
- • Criminal records
- • Documents related to business activities
- • Technical Data from Google Analytics, Google Ads, пикселей Facebook, VK, Google Tag Manager, Yandex Metrika, Yandex Direct, Roistat.
RETENTION OF PERSONAL DATA
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
The following criteria are used to determine data retention periods for your personal data:
- • We will retain your personal data as while you are considered our client.
- • We will retain technical information about your visits to MIGRONIS websites for an unlimited time.
We may disclose your personal data to any of our international offices forming part of MIGRONIS who may act as joint data controllers or data processors to the company which will be the data controller for your data when you obtain our services and/or may provide administration, controls and reporting services. MIGRONIS respect and protect the security of your personal data in accordance with the applicable law (including the GDPR) and apply the security measures and safeguards for such personal data.
We may require to share your data with local agents or other service suppliers (in their capacity as data processors) which is necessary for us to provide the services you request. These local agents and suppliers store and process your data on the basis of strict confidentiality and subject to the appropriate security measures and safeguards.
We may also share your data with other third parties in their capacity as data controllers such as legal, tax, real estate, immigration or other advisors and consultants, (international) banks or other third parties providing other or additional services to you such as real estate agencies/owners/developers who you might wish to engage with under separate terms and conditions between you and such third parties. These third parties will be processing your data in their own right as data controllers and their data protection policies and processes shall be become applicable.
It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Services; or (5) exercise or protect the rights and safety of MIGRONIS, our Clients, personnel, or others. We may dispute legal demands when we believe, in our discretion, that such requests of government enforcement agencies are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
Such disclosures it will be for the purposes of Anti-Money Laundering/KYC checks, Anti-Bribery/Corruption Laws compliance and/or fraud protection.
NOTIFICATION OF A PERSONAL DATA BREACH
In the case of a personal data breach, MIGRONIS shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the supervisory authority competent in accordance with Article 55 of GDPR, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.
MIGRONIS shall document any personal data breaches, comprising the facts relating to the personal data breach, its effects and the remedial action taken.
TRANSFERS OF PERSONAL DATA TO THIRD COUNTRIES
Your Personal Data may be stored, processed and transferred to third countries where MIGRONIS have offices or in which we engage service providers. You consent to the transfer of information to third countries, which may have data protection rules that are different from those of your country by accepting of the possible risks of such transfers due to the absence of an adequacy decision and appropriate safeguards.
Transfers of personal data to a third country shall take place only on one of the following conditions:
- • the transfer is necessary for the performance of a contract between you and MIGRONIS or the implementation of pre-contractual measures taken at the your request;
- • the transfer is necessary for the conclusion or performance of a contract concluded in the interest of you between the MIGRONIS and another natural or legal person.
If you do not want information collected through the use of these technologies, there is a simple procedure in most browsers that allows you to automatically decline many of these technologies, or to be given the choice of declining or accepting them, as well as clear your browsing history and cookies from the specific site you visited, incl. https://migronis.com.
A “web beacon” or “pixel tag” is tiny object or image embedded in a web page or email. They are used to track the number of users who have visited particular pages and viewed emails, and acquire other statistical data. They collect only a limited set of data, such as a cookie number, time and date of page or email view, and a description of the page or email on which they reside. Web beacons and pixel tags cannot be declined. However, you can limit their use by controlling the cookies that interact with them.
We log your visits and use of our Services, including mobile apps.
We log usage data when you visit or otherwise use our Services, including our sites, app and platform technology (e.g., our off-site plugins), such as when you view or click on content (e.g., learning video) or ads. We use logins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.
TYPES OF COOKIES
The following types of cookies may be used when you visit the Site:
Analytics cookies that anonymously remember your computer or mobile device when you visit our website and recognize visits to our website across different devices.
Service cookies that help us to make our website work as efficiently as possible; remember your registration and login details; remember your settings preferences; to detect what device you are using and adapt how we present our services according to the screen size of that device.
The main cookies we are use:
- _gat_UA_ UA-83589234-1
CONTROL OF COOKIES
Most browsers are set to accept cookies by default. However, you can remove or reject cookies in your browser’s settings. Please be aware that such action could affect the availability and functionality of the Site. We have no access to third party cookies and third party organizations have no access to ours. The third party organizations that place cookies, including your browser (such as Google) and the third party companies who pay for advertising and analytics services using this information, will have their own privacy policies.
Our contact details:
Tel.: +351 800 50 08 61
Mail address: H-2161, Csomád, Verebeshegy utca 11, Hungary
Last updated: 04/13/2022