Personal Data and General Confidentiality Agreement

Privacy and Data Management Policy

1. Definitions

Madarász László, sole proprietor trading as PixelLegion (hereinafter referred to as the "Data Controller"), operates the websites accessible at https://pixellegion.org (hereinafter referred to as the "Website") and manages the personal data of visitors to the Website, registrants, users of services available on the Website, and purchasers (hereinafter collectively referred to as the "Data Subject").

All personal data is collected and managed solely in compliance with applicable laws and regulations.

System notifications may be sent without separate consent; however, direct marketing (DM) messages are sent only with the Data Subject's explicit consent. The Data Controller stores the Data Subject's information with the highest level of security and only transfers it to third parties with their consent.

Data Subjects can request information about their personal data or its deletion by contacting info@pixellegion.org or using the online customer service platform available on the Website.

2. Name and Contact Information of the Data Controller

Name of the Data Controller: Madarász László, sole proprietor trading as PixelLegion
Registered Address: 2040 Budaörs, Hajnal utca 4.
Email: info@pixellegion.org
Phone: +36-70-720-4884
Registry Number: 15934478
Tax Number: 65489426-1-51
VIES – EU VAT Number: HU65489426
Data Processing Registry Number: As of the GDPR's entry into force on May 25, 2018, it is no longer mandatory to obtain or maintain such a number.

3. Parties Involved in Data Processing

3.1. Data Processing Related to Accounting
Name of Data Processor: Empire Numbers Kft.
Address: 3580 Tiszaújváros, Árkád sor 3, 1/3
Tax Number: 32454570-1-05
Phone: +36-20-286-0497
Email: zsanrietta1231@gmail.com
Website: https://empirenumbers.hu

Accounting data is processed exclusively in compliance with the Accounting Act, for the duration stipulated by the law.

3.2. Customer Service Operations

Name of Data Processor: Madarász László, sole proprietor trading as PixelLegion
Registered Address: 2040 Budaörs, Hajnal utca 4.
Email: info@pixellegion.org
Phone: +36-70-720-4884
Registry Number: 15934478
Tax Number: 65489426-1-51
VIES – EU VAT Number: HU65489426

3.3. Technical Service Providers Supporting the Services

Facebook Ireland Limited
Address: Grand Canal Harbour, Grand Canal Square 4, Dublin 2, Ireland
Tax Number: IE9692928F
Website: https://www.facebook.com
Privacy Policy: https://www.facebook.com/privacy/explanation

TikTok Technology Limited
Address: Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland
Tax Number: IE3729252KH
Website: https://www.tiktok.com
Privacy Policy: https://www.tiktok.com/legal/privacy-policy

Rumble Inc.
Address: 444 Gulf of Mexico Drive, Longboat Key, Florida 34228, USA
Website: https://rumble.com
Privacy Policy: https://rumble.com/privacy-policy

YouTube LLC
Address: 901 Cherry Avenue, San Bruno, CA 94066, USA
Tax Number: As part of Alphabet Inc., YouTube falls under Google LLC.
Website: https://www.youtube.com
Privacy Policy: https://policies.google.com/privacy

X Corp. (formerly Twitter)
Address: 1355 Market Street, Suite 900, San Francisco, CA 94103, USA
Tax Number: Not publicly available
Website: https://www.x.com
Privacy Policy: https://x.com/privacy

Hetzner Online GmbH
Address: Industriestr. 25, 91710 Gunzenhausen, Germany
Website: https://www.hetzner.com
Privacy Policy: https://www.hetzner.com/legal/privacy-policy

PayPal Inc.
Address: 22-24 Boulevard Royal, L-2449 Luxembourg
Website: https://www.paypal.com
Privacy Policy: https://www.paypal.com/hu/webapps/mpp/ua/privacy-full

Stripe Inc.
Address: 510 Townsend Street, San Francisco, CA 94103, USA
Website: https://stripe.com
Privacy Policy: https://stripe.com/privacy

4. Purpose of the Privacy Policy

This privacy policy has been created to transparently present the data processing activities carried out by the Data Controller and to ensure that Data Subjects are aware of their rights.

5. Rights of Data Subjects

Data Subjects have the following rights regarding the processing of their personal data:

• Right of Access
  The Data Subject is entitled to request information about whether the Data Controller processes their personal data and, if so, has the right to access information related to it (e.g., the purpose of data processing, categories of personal data involved).
• Right to Rectification
  The Data Subject is entitled to request that the Data Controller rectify inaccurate personal data or complete incomplete data.
• Right to Erasure (“Right to Be Forgotten”)
  The Data Subject may request the deletion of their personal data if its processing is no longer necessary, the Data Subject withdraws their consent, or unlawful data processing occurred.
• Right to Restriction of Processing
  The Data Subject is entitled to request the restriction of data processing if they dispute the accuracy of the personal data or have objections regarding the legality of the data processing.
• Right to Data Portability
  The Data Subject is entitled to request that the Data Controller provide the personal data processed in a structured, commonly used, and machine-readable format or transmit it to another data controller.
• Right to Object
  The Data Subject is entitled to object to the processing of their personal data if the legal basis for processing is a legitimate interest or a matter of public interest.

6. Exercising the Rights of Data Subjects

To exercise their rights, Data Subjects may contact the Data Controller at the following addresses:

Postal Address: Madarász László Sole Proprietor as PixelLegion, 2040 Budaörs, Hajnal utca 4.
Email: info@pixellegion.hu
Phone: +36-70-720-4884

The Data Controller will fulfill all requests as soon as possible but no later than within 25 days.

7. Data Security

The Data Controller implements technical and organizational measures to protect personal data from unauthorized access, data loss, and data breaches. Data is stored exclusively on the servers owned by Madarász László Sole Proprietor as PixelLegion or by contracted service providers located within the European Union.

7.1. Handling Data Breaches
In the event of a data breach, the Data Controller will:

• Maintain a record of incidents.
• Notify the Hungarian National Authority for Data Protection and Freedom of Information (NAIH) within 72 hours.
• Inform Data Subjects if the breach poses a high risk to their rights.
• 8. Data Transfers to Third Parties
• The Data Controller transfers personal data to third parties only under the following circumstances:
• If the Data Subject has explicitly consented to the transfer.
• To fulfill legal obligations (e.g., in response to a request by authorities).

9. Data Storage and Retention Period

• The Data Controller retains personal data for the following durations:
• Data collected during contract performance: 5 years after the termination of the contract.
• Billing-related data: At least 8 years, in accordance with accounting laws.
• Newsletter database data: Until the Data Subject withdraws their consent.

10. Complaint and Legal Remedies

The Data Subject may lodge a complaint with the Data Controller or the Hungarian National Authority for Data Protection and Freedom of Information (NAIH). In case of disputes related to data processing, legal proceedings may also be initiated. Detailed information on submitting complaints can be found in section 14.

11. Cookie Management

The websites of the Data Controller use cookies to enhance the user experience, measure site traffic, and for statistical purposes.

11.1. What Types of Cookies Do We Use?

• Essential Cookies: These enable the basic functions of the website (e.g., login, shopping cart functionality).
• Functional Cookies: These remember user preferences (e.g., language selection, font size).
• Performance Cookies: These collect information about website usage to optimize its operation.
• Third-Party Cookies: These include cookies used by Google Analytics, Facebook Pixel, and other analytical tools.

11.2. Managing Cookie Settings
Users can modify cookie settings at any time in their browser settings. Detailed instructions for managing cookie settings can be found at the following links:

• Mozilla Firefox: https://support.mozilla.org/hu/kb/S%C3%BCtik%20kezel%C3%A9se
• Google Chrome: https://support.google.com/chrome/answer/95582?hl=hu&ref_topic=3421433
• Internet Explorer: http://windows.microsoft.com/hu-hu/internet-explorer/ie-security-privacy-settings#ie=ie-9
• Opera: https://www.opera.com/terms
• Safari: http://support.apple.com/kb/PH5042

12. Newsletters and Marketing Data Processing

12.1. Newsletter Subscription
The Data Subject may voluntarily consent to receiving newsletters from the Data Controller. The personal data provided during subscription will only be used for sending newsletters.

12.2. Purpose and Duration of Data Processing

• Purpose: To provide information, promotions, and offers to Data Subjects.
• Duration: Until the consent is withdrawn.
• The Data Subject may unsubscribe from newsletters at any time using the unsubscribe link at the bottom of the newsletter or by contacting the Data Controller via email.

13. Handling Data Protection Incidents

The Data Controller is obligated to record all data protection incidents and to notify Data Subjects without undue delay if the incident is likely to adversely affect their rights or freedoms.

13.1. Notification Obligations

• Notification to Data Subjects: If the incident poses a high risk to the rights of Data Subjects, the Data Controller will inform them directly.
• Notification to NAIH: Data breaches must be reported to the NAIH within 72 hours.

13.2. Data Subjects' Rights in Case of a Data Protection Incident

• Data Subjects have the right to:
• Request information about the nature of the incident and the scope of data affected.
• File a complaint with the NAIH or initiate legal proceedings.

14. Information on Conciliation Bodies

If the Data Subject is dissatisfied with the handling of their personal data, they may lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH). The contact details of the Authority are as follows:

Address: 1024 Budapest, Szilágyi Erzsébet fasor 22/C.
Phone: +36 (1) 391-1400
Email: ugyfelszolgalat@naih.hu
Website: https://naih.hu

If it becomes necessary to resolve the dispute through legal proceedings, the Data Subject may file a claim with the competent court at their place of residence or stay. Alternatively, they may choose to file a claim with the competent court based on the registered office of Madarász László sole proprietor as PixelLegion, which is the Pest County Court (1055 Budapest, Markó utca 27.).

15. Remedies for Issues Related to Data Processing

The Data Subject has the following remedies available concerning data processing:

15.1. Submitting a Complaint to the Data Controller

• The Data Subject may submit a complaint to the Data Controller at the following contact details:
  Address: Madarász László sole proprietor as PixelLegion, 2040 Budaörs, Hajnal utca 4.
  Email: info@pixellegion.hu
• Submitting a Complaint to the NAIH:
  The Data Subject may file a complaint with the NAIH if they find the data processing practices unsatisfactory. Detailed contact information for the Authority is provided in Section 14.
• Initiating Legal Proceedings:
  The Data Subject has the right to initiate legal proceedings against the Data Controller if they believe their rights have been violated during data processing. In such cases, the Data Subject may choose to bring the case before the competent court at their place of residence or the competent court based on the registered office of the Data Controller.

16. Other Provisions

The Data Controller reserves the right to modify this Privacy and Data Management Policy at any time. The Data Controller will notify Data Subjects of the changes on the Website and via email. The effective date of the amendments will always be specified in the published policy, allowing Data Subjects to review the updates.