Privacy

Data Processing Policy

Budapest, 9 April 2018

Wanadis Kereskedelmi és Szolgáltató Kft. (registered office: 1112 Budapest, Budaörsi út 153., company registration number: 01-09-885144) provides the platform, named “Maileon” which is used by Deloitte in Hungary to send newsletters to you as contact person to a company interested in the activities of Deloitte CE. In order to enable Deloitte in Hungary to provide you with the newsletter service, Deloitte in Hungary needs to transfer your contact data to Wanadis Kereskedelmi és Szolgáltató Kft.

Please note that Deloitte Central Europe (hereinafter referred to as: Deloitte CE ) is planning to use a common system for marketing purposes (ELOQUA) and all the marketing activities will be realized through this system. Deloitte CE entities’ marketing departments and the regional marketing department will have access to this system and to the contact data uploaded into the system. With regard to the before mentioned, Deloitte in Hungary entities would like to upload your contact data into this system. Please be informed that ELOQUA is operated by Oracle East Central Europe Services BV, Cyprus Branch, carrying on business under its business name Oracle Cyprus Solutions, Acropoleos Avenue 58, 2012 Nicosia, Cyprus.

With regard to the data privacy changes after 25 May 2018, when the General Data Protection Regulation of the European Union becomes applicable to all data control carried out in the territory of the European Union, processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest, which means that no consent would be required from your side. Notwithstanding Deloitte would like to follow the safest practice and would like to obtain your consent for data management for marketing purposes. Please provide Deloitte in Hungary with your consent as per below. Please note that without your consent, Deloitte in Hungary will not be able to send you newsletters and event invitations or directly contact you with any marketing activities.

Your voluntary consent to the business related communication covers the following activities:

  • Email marketing (contacting and managing my preferences)
  • Profiling – analysing my personal preferences, interests in order to be able to get the targeted offers for my entity
  • Conducting business activities of Deloitte CE
  • Managing sales opportunities for Deloitte CE
  • Building my profile by analysing my personal preferences, behaviours and interests in order to be able to get the targeted content or offer for my entity

Controller(s) of personal data:
The below entities - as joint controllers - forming Deloitte in Hungary.

  • Deloitte Advisory and Management Consulting Private Limited Company, Dozsa Gyorgy ut 84/C, 1068 Budapest, Hungary (authorized to process data on behalf of all Deloitte in Hungary entities and to provide information about the data management to the contact persons and to reply all queries related to data management)
  • Deloitte Auditing and Consulting Ltd., Dozsa Gyorgy ut 84/C, 1068 Budapest, Hungary
  • Deloitte CRS Limited Liability Company, Dozsa Gyorgy ut 84/C, 1068 Budapest, Hungary
  • Deloitte Legal Erdős and Partners Law Firm, Dozsa Gyorgy ut 84/C, 1068 Budapest, Hungary

Processors of personal data under the “Maileon” platform:

  • Deloitte Advisory and Management Consulting Private Limited Company, Dózsa Gy út 84.C., 1068 Budapest, Hungary
  • Microsoft Corporation, One Microsoft Way, Redmond, WA 98052, USA
  • Wanadis Kereskedelmi és Szolgáltató Kft., 153 Budaörsi út, 1112 Budapest, Hungary

Processors of personal data under the ELOQUA system:

  • Deloitte Advisory and Management Consulting Private Limited Company, Dózsa Gy út 84.C., 1068 Budapest, Hungary
  • Deloitte CE Business Service Sp. z o.o., Al. Jana Pawla II 22, 00-133 Warsaw, Poland
  • Deloitte Central Europe Service Centre s.r.o., Karolinská 654/2, 186 00, Prague 8, Czech Republic
  • Deloitte CZ Services s.r.o., Karolinská 654/2, 186 00, Prague 8, Czech Republic
  • con4PAS, s.r.o., Novodvorská 1010/14, 142 01 Prague 4 – Lhotka, Czech Republic
  • SI-Consulting Sp. z o.o., Slezna Str. 118, 53-111 Wroclaw, Poland
  • Microsoft Corporation, One Microsoft Way, Redmond, WA 98052, USA
  • Oracle East Central Europe Services BV, Cyprus Branch, carrying on business under its business name Oracle Cyprus Solutions,
  • Acropoleos Avenue 58, 2012 Nicosia, Cyprus.

In case where the data processing include the transfer outside of the European Union (EU) the transfer is based on EU approved standard contractual clauses, thus ensuring an adequate level of personal data protection as required by the applicable data protection laws.

The personal data controllers and data processors shall establish technological, physical, administrative and procedural safeguards all in line with the industry accepted standards in order to protect and ensure the confidentiality, integrity or accessibility of the personal data processed; prevent the unauthorized use of or unauthorized access to the personal data or prevent a personal data breach (security incident) in accordance with Deloitte CE instructions, policies and applicable laws.

Recipients of personal data under the “Maileon” platform: marketing department of Deloitte in Hungary entities.

Recipients of personal data under the ELOQUA system: The personal data will be made accessible to the following categories of recipients: the authorized employees and representatives of the above listed controllers and processors and to Deloitte CE group of companies.

The personal data might be made available to other service providers, as data processors, in case Deloitte in Hungary decides to change its direct marketing platform. In this case you will be informed about the new data processor(s).

The personal data may be also disclosed to the competent authorities as authorized by the applicable laws.

The period for which the personal data will be processed: The data will be processed until the consent is revoked or in case of the lack of such withdrawal as long as it is necessary in relation to the purposes described above, but no longer than 10 (ten) years from the collection of the data. After the indicated period expires or I request so, or the data controllers become aware of the inaccuracy of my personal data and I refuse or miss to provide my accurate data, the personal data will be permanently deleted. However, I am aware that controller may retain limited scope of my personal data in order to prove compliance with the applicable laws.

The consent is given voluntarily but the processing of my personal data is necessary to fulfil the purposes described here-above. If consent is not granted or I later send a request for rectification or erasure of my data, and withdraw my consent, this will mean that I will have no possibility to participate in marketing or promotional activities or receive any newsletters or offers from Deloitte CE.

I acknowledge that as a personal data subject before 25 May 2018 I have the right to ask for information about the data processing, request from the controller access to and rectification or erasure of personal data or a restriction on the processing and the right to withdraw my consent at any time. Additionally to the before indicated rights, from 25 May 2018 I, as data subject have the right to object to the processing, as well as the right to data portability and the right to obtain a copy of my personal data controlled. All rights described in this paragraph can be enforced by myself, by sending an e-mail request to the authorized data controller, Deloitte Advisory and Management Consulting Private Limited Company to deloitteinhungary@deloittece.com.

I am aware that my personal data collected in relation to the above described purposes (preferences, behaviours and choice of marketing content) may be used as a basis for automated decisions leading to the identification of sales opportunities within Deloitte in Hungary under the “Maileon” platform and within Deloitte CE group of companies under the ELOQUA system. I am aware and accept that under the “Maileon” platform Deloitte in Hungary and under the ELOQUA system Deloitte CE continuously monitors and records whether the online newsletters are deleted unread or are opened, how many times I clicked on the links included and decides accordingly what other topics may be of interest to the organisation contacted through my email address.

I also have the right to initiate a court proceeding against the data controller for indemnification and to lodge a complaint with a data protection supervisory authority in the country of my residence in case I consider that the processing of my personal data infringes the applicable laws.

I understand and provide my consent that my personal data are being controlled by Deloitte in Hungary entities as joint controllers and be transferred to Wanadis Kereskedelmi és Szolgáltató Kft. (registered office: 1112 Budapest, Budaörsi út 153., company registration number: 01-09-885144) as data processor, operating the “Maileon” platform used by Deloitte in Hungary for newsletter sending. I also accept and explicitly consent that my personal data be transferred from “Maileon” platform to the ELOQUA marketing system to be used by Deloitte CE entities (including Deloitte in Hungary) for the above described marketing activities. I also accept that Deloitte in Hungary might change marketing platform and my data might be transferred to this new platform and its provider, subject to the purpose, scope of personal data and other conditions (except for a different platform and vendor that shall comply herewith) stay the same.

 

1. “Deloitte in Hungary” is the collective denomination of the following entities: Deloitte Advisory and Management Consulting Private Limited Company, Dozsa Gyorgy ut 84/C, 1068 Budapest, Hungary (company registration number: 01-10-044100); Deloitte Auditing and Consulting Ltd., Dozsa Gyorgy ut 84/C, 1068 Budapest, Hungary (vompany registration number: 01-09-071057); Deloitte CRS Limited Liability Company, Dozsa Gyorgy ut 84/C, 1068 Budapest, Hungary (company registration number: 01-09-975176); Deloitte Legal Erdős and Partners Law Firm, Dozsa Gyorgy ut 84/C, 1068 Budapest, Hungary.

2. Deloitte Central Europe is a regional organization of entities organized under the umbrella of Deloitte Central Europe Holdings Limited, the member firm in Central Europe of Deloitte Touche Tohmatsu Limited. Services are provided by the subsidiaries and affiliates of Deloitte Central Europe Holdings Limited, which are separate and independent legal entities.