Robecon International FZ-LLC ( Adress: FDRK 3458 Compass Building, AI Shohada Road. AI Hamra Industrial Zone – FZ , Ras AI Khaimah , United Arab Emirates ) as SERVICE PROVIDER lays down the following basic rules relating to the processing of the data obtained from the registered users of netadex.com site:
1.1. The SERVICE PROVIDER is the operator of the NETADEX SYSTEM, an electronic advertisement brokering system available via netadex.com, through which it provides advertisers placement of banner and static advertisements on the online ad spaces at its disposal as well as the collection of typical statistical data of the interactions made to those advertisements on the one hand, while organizing utilization of online ad space for its media owner users through placement of banner and static advertisements on the other hand.
1.2. The SERVICE PROVIDER shall handle all data relating to or associated with the users of the NETADEX SYSTEM as confidential and properly for its intended purpose as well as it shall not make those data accessible to unauthorized persons and shall use them only for the purposes and in the manner as specified in this Policy.
1.3. The purpose of data processing is to operate the NETADEX SYSTEM, to provide the services specified in clause 1, to fulfil the obligations undertaken by the SERVICE PROVIDER in the provisions of the contract aimed at provision of the service, and to enforce the rights of the SERVICE PROVIDER.
1.4. The SERVICE PROVIDER declares that the log data recorded on the interactions made to those advertisements are anonymized data and are not suitable for identifying the individual users or visitors and for deriving conclusions therefrom as to personal information.
2.1. Further controller in addition to the SERVICE PROVIDER:
| a.) Name | Web Hosting Kft |
| Registered office | 9700 Szombathely, Semmelweis Ignác utca 2. |
| Place of business | 9700 Szombathely, Semmelweis Ignác utca 2. |
| Company Registration No | 18-09-113921 |
| VAT No | 24954013-2-18 |
| E-mail address | info@webshark.hu |
3.1. The legal ground for data processing is the user’s consent expressed during registration. Registration on netadex.com shall be deemed as a request for use of the service. A precondition for conclusion of the contract with the SERVICE PROVIDER and provision of the service shall be the user’s consent to the processing by the SERVICE PROVIDER of the data provided by the user for performance of the service. Should registration not occur, the data that might have been given by the visitor of the site by completing the registration form will not be recorded. The SERVICE PROVIDER shall record and store the data provided by the user by completing the registration form by electronic means.
3.2. During the effect of the legal relationship between the parties the SERVICE PROVIDER shall carry out mandatory data processing for the purposes of compliance with the tax liabilities connected with the service.
3.3. The user shall be entitled to withdraw his consent expressed upon registration at any time, without giving the reasons. By accepting this Data Processing Policy, the user acknowledges that withdrawal of the authorization for data processing will render provision of the service impossible, so the SERVICE PROVIDER will consider such withdrawal as termination of their legal relationship by the user. .
3.4. By accepting this Data Processing Policy, the user gives his consent to being informed by the SERVICE PROVIDER by electronic means, via direct mail on the further opportunities and novelties connected with use of the service. The user shall be entitled to withdraw his consent to be given under this clause at any time, by a verbal or written statement, without giving the reasons. Withdrawal of the consent will not render provision of the service impossible and the SERVICE PROVIDER will not consider it as termination of the legal relationship between the parties by the user. .
4.1. The SERVICE PROVIDER shall process the data that might be associated with the user and that are indispensable for provision of the service in technical terms. Accordingly, for the purposes of establishing the contractual relationship, it shall record the following data upon registration in respect of all users (general mandatory data to be provided): name/description, home address/registered seat, electronic mail address, account-keeping bank, payment account number, tax identification code/VAT number, for users other than natural persons, registration number. As regards media owner users, provision of the data connected with the website to be provided by it, the relevant authorizations and, in respect of advertising users, the data containing the advertisement is a technical condition for use of the service (special mandatory data to be provided).
4.2. The service may be used on the condition that the data provided by the user are true, correct and accurate and always correspond to the data included in the certified public registers. The SERVICE PROVIDER undertakes to ensure that the data provided by the user are accurate, complete and up-to-date.
4.3. The SERVICE PROVIDER undertakes to create and maintain a password-protected virtual storage (PROFILE) granting individual access to the service for the ADVERTISER as long as the contract is in force. The SERVICE PROVIDER shall inform the user of all material circumstances, so in particular all data provided by the user and all information relating to performance of the service and accounting, through the personal profile. So all the data processed by the SERVICE PROVIDER shall be accessible to the user at any time, free of any restriction. The user shall be entitled to change all data he has provided at any time unilaterally, by modifying appropriately the information stored on the profile space.
4.4. In addition to the mandatory data, the user may provide additional, non-mandatory data rendering individualization of the service possible and making it more effective using the profile space. As regards the additional data provided by the user in this way, the SERVICE PROVIDER presumes that the user has granted authorization for data processing.
5.1. Data processing shall start at the time of registration (creation of the profile) and shall last until the service is provided. After termination of the legal relationship between the parties, the SERVICE PROVIDER shall irrevocably destroy the personal user profile.
6.1. The SERVICE PROVIDER undertakes to take all reasonable efforts to protect the data at its disposal from all hazards (natural disasters, technical system failures, human errors, etc.) .
6.2. The SERVICE PROVIDER shall ensure that the user’s data at its disposal are accessible only by its employees who need to know them for performing their job and that such employees observe the relevant data protection regulations.
7.1. The SERVICE PROVIDER shall handle all facts, information, solutions or data at its disposal that relate to the user’s identity, data, business activities and contracts connected with the service as confidential. The SERVICE PROVIDER shall publish, or share with any other unauthorized person(s), the user's data only in the cases defined in this Policy or law (at an official or judicial request or for the purposes of fulfilment of its obligations stipulated in law) or shall transfer them to any third party with the user’s consent only.
Furthermore, the user acknowledges that the SERVICE PROVIDER shall be entitled to share with its partners the anonymized, summarized and statistical data unsuitable for identification of the user that are important for its partners from business perspective.
7.3. The user acknowledges that the SERVICE PROVIDER shall have the right to refer to the user as its contractual partner in the documents intended to popularize the service.
8.1. RIGHT TO INFORMATION
The user shall have the right to request information from the SERVICE PROVIDER about the processing of his personal data, which right includes the right to know the related documents. At the user’s request, the SERVICE PROVIDER shall provide information, within not more than 30 days, in writing about the data it processed and those processed by the data processor assigned by it, the sources thereof, the purpose of, the legal ground for and the duration of data processing, their transfer (as the case may be), as well as the data processor’s name, address and processing-related activities. By accepting this Data Processing Policy the user acknowledges that the SERVICE PROVIDER’s obligation to protect and retain the data of other persons might limit his right to information. The information shall be provided free of charge if the individual requesting the information has not yet submitted a request for information in connection with the same range of data in the same year. Otherwise the user shall refund the costs of compliance with the request. In the cases defined in law the SERVICE PROVIDER may refuse to provide information to the user and shall inform the user thereof in writing.
8.2. RIGHT TO RECTIFICATION
The user may request rectification of his data if such data are not true and correct. If the true and correct data are at the SERVICE PROVIDER’s disposal, it shall be entitled to rectify them ex officio and/or at anyone’s initiative. Should the SERVICE PROVIDER fail to meet the user's request for rectification, it shall disclose the factual and legal reasons for such refusal in writing within 30 days.
8.3. RIGHT TO ERASURE
The user may request erasure or blocking of his data if the purpose of data processing has ceased to exist. Should the SERVICE PROVIDER fail to meet the user's request for blocking or erasure, it shall disclose the factual and legal reasons for such refusal in writing within 30 days.
8.4. RIGHT TO OBJECT
The user may object to the processing of his data. The SERVICE PROVIDER shall examine the objection as soon as possible but not later than within 15 days after submission of the request and will decide on whether it is justified or not and will inform the applicant thereof in writing.
8.5. RIGHT TO REMEDY
The SERVICE PROVIDER is committed to solve all formal written requests or any complaint on data processing directly with the relevant user. The user may initiate judicial proceedings against the SERVICE PROVIDER if his rights are infringed. The case shall be considered within the jurisdiction of the Court or Authority competent at the SERVICE PROVIDER’s registered seat.
9.1. The provisions of this Data Processing Policy shall take effect on 01 Juny 2022 and shall be valid until withdrawal. This Policy shall apply to all information, data and facts that are suitable for identification of or that can be associated with the users registering on netadex.com. This Policy shall apply to the service described in clause 1.1 and provided on netadex.com and shall not apply to the information practices of users who advertise a website, service or product or utilize a web space using the NETADEX SYSTEM
9.2. The SERVICE PROVIDER reserves the right to amend this Data Processing Policy, in which case the consolidated text of the Policy including amendments shall take effect on the day when it is published so that it will apply also to the contracts already in effect. Without an express approval, amendment to this Policy (if any) shall not result in restriction of or prejudice to the user's rights granted in this Policy.
01.06.2022
ROBECON International FZ-LLC
FDRK 3458 Compass Building, AI Shohada Road. AI Hamra Industrial Zone – FZ Ras AI Khaimah , United Arab Emirates