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Data processing guideline - Newsletters

Budapest, 18 September 2017

Data processing guideline

Deloitte Advisory and Management Consulting Private Limited Company, Deloitte Auditing and Consulting Ltd., Deloitte CRS Ltd and Deloitte Legal Erdős and Partners Law Firm (registered office: 1068 Budapest, Dózsa György út 84/C, company registration numbers – respectively -: 01-10-044100, 01-09-071057, 01-09-975176, Deloitte Legal has no registration number, hereinafter together: Deloitte) compile a database of the details of persons (hereinafter: contact persons) providing Deloitte with their company contact data (company name, name, position, company e-mail address), and Deloitte sends regular newsletters to the companies included in the database (to the e-mail address of the contact persons) of topics that are of interest or - in Deloitte’s understanding - could be of interest to them.

By way of the newsletters, Deloitte draws attention to current regulations or amendments pertaining to issues covered by its legal, tax, financial and other advisory activity, as well as provides guidance in the practical application of certain rules, promotes related professional or marketing online and offline events, and lists direct contacts of its professionals in relation to the given topics.

Contact persons may subscribe to newsletters on Deloitte’s website providing the necessary details (name, company name, position, company e-mail address). Deloitte reserves the right to exclude any entity at any time from the newsletters. If the contact person provides an e-mail address that is not a company e-mail, Deloitte will immediately cancel his subscription and details, and will exclude the organisation and the contact person from the newsletters. The contact persons may unsubscribe from the newsletters at any time using the links provided. In this case all their details are immediately cancelled.

Deloitte stores the contact details in its own customer relationship management system -- on servers located in Poland, EU -- handles them as confidential and does not make them accessible to unauthorised third persons.

The newsletters are sent by a third party as a subcontractor to Deloitte Wanadis Kereskedelmi és Szolgáltató Kft. (registered office: 1112 Budapest, Budaörsi út 153., company registration number: 01-09-885144); therefore the contact details are delivered to them. The company sending out the newsletters handles the data as confidential and does not make them accessible to unauthorised third persons. In other issues data procession is subject to the compnay's own policy. Wanadis Kereskedelmi és Szolgáltató Kft stores contact details on its servers located in Germany.

Deloitte continuously monitors and records whether the online newsletters are deleted unread or are opened, how many times the recipients clicked on the links included and decides accordingly what other topics may be of interest to the given organisation.

When applying for online webinars through electronic media, contact details are provided (company name, name, position, company e-mail address) to a subcontractor of Deloitte, On24, Inc. (registered office: 795 Folsom Street, 3rd Floor San Francisco, CA 94107 USA). The company providing the online webinars processes the data subject to the terms of its own policy. You will only be able to attend the webinars if you provide your contact details to On24 Inc.

With regard to the fact that the newsletters and webinars are not addressed to the contact persons as private individuals but their organisations, and Deloitte stores and processes the relevant data as contact data for the given organisation rather than as personal data of the private individual, there is no processing of personal data here.

Should you have any questions or comments with respect to data processing, please write to deloitteinhungary@deloittece.com (subject: “newsletters - data processing”).

Budapest, 18 September 2017