Privacy Policy

THE SHORT VERSION:

Before you get into the legal details of my Privacy Policy, I wanted to give you an overview in my own “legal-to-human” translation, so you can 100% understand how I handle your data when you visit data36.com.

The principles:

  1. I care about your privacy. I’m happy if someone reaches out to me in an email using their full name. But I find it just as important to respect those who want to browse, read and learn on data36.com anonymously.
  2. On course.data36.com, courses.data36.com and generally in my paid courses, I’ll have to use some of your personal data for accounting and legal purposes but even then I’ll keep your data 100% private and will use it only for accounting and legal purposes.
  3. I’m Tamás Mester (yes, “Tomi” is my nickname). This website is operated by me – more accurately by my one-person limited liable company called Adattenger Kft. (More info below.) Although I often travel, I’m currently based in Budapest, Hungary.
  4. course.data36.com is hosted on a DigitalOcean server that’s located in Frankfurt, Germany.
  5. I don’t use 3rd party analytics tools on course.data36.com. (No Google Analytics, no Facebook analytics, etc.)
  6. I use Brevo for automated course emails. These emails are meant to help you progress with your course. Brevo is a company registered in France — so within the EU. (Find their privacy policy here.)
  7. I do not use remarketing or any social media pixels on course.data36.com. No Facebook remarketing, no Google remarketing, no Twitter remarketing, nothing.
  8. I use Google captcha and re-captcha against bots.
  9. For international purchases (purchases not from Hungary), we use Paddle as our Merchant of Record. For that reason, you might see their payment form on our website.
  10. For Hungarian purchases, we use Stripe and/or Barion as our payment processors.
  11. I want to send a big thank you to SEQ Legal (https://seqlegal.com) for the Privacy Policy below.

That’s it! Let’s see the legal text.

THE FULL AND LEGALLY APPLICABLE PRIVACY POLICY OF THE DATA36.COM BLOG:

1. Introduction

1.1 We are committed to safeguarding the privacy of course.data36.com‘s visitors.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of course.data36.com‘s website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We use cookies on our website. Those cookies are not strictly necessary for the provision. More about that at Section 11.

1.4 In this policy, “we”, “us” and “our” refer to Adattenger Kft. (primary contact person: Tamas Mester). For more information about us, see Section 13.

2. Credit

2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).

3. How we use your personal data

3.1 In this Section 3 we have set out:

(a) the general categories of personal data that we may process;

(b) the purposes for which we may process personal data; and

(c) the legal bases of the processing.

3.2.1. We also use Google captcha and re-captcha against bots.

3.3 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is your consent.

3.4 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is your consent.

3.5 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

3.6 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.7 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.8 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.9 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3.10 We may process information you provide or generate while using our online forum (hosted on Slack). This includes messages, files, and other data shared within the forum. Slack’s privacy policy governs the processing of this data, and you can review their privacy policy here. The purpose of processing this data is to facilitate community interaction and improve the user experience. The legal basis for this processing is your consent and our legitimate interest in providing and maintaining a functional online forum for course participants.

3.11 If you participate in our live Q&A webinars, we may process and record the session, including your contributions such as questions, comments, or other inputs shared during the session. These recordings will only be made available internally to other students of the course. The purpose of this processing is to enhance the learning experience for all participants. The legal basis for this processing is your consent, which is deemed granted when you attend the webinar. By joining the session, you acknowledge and agree that the webinar will be recorded and that the recordings may include your audio, video, and any other contributions you make during the session. If you do not wish to be included in the recordings, you can opt to attend anonymously or refrain from active participation.

3.12 We use Zendesk, a third-party service provider, to manage and process customer support inquiries. When you contact us via email or through our priority support channels (jds {at} data36 {dot} com), Zendesk may process your communication data, including email addresses, message content, and metadata. Zendesk’s privacy policy can be reviewed here. The purpose of processing this data is to provide efficient and reliable customer support. The legal basis for this processing is our legitimate interest in maintaining high-quality customer service and your consent when submitting inquiries.

3.13 Photographs and Videos at Live Events:
During live events, photographs and/or videos may be taken for marketing purposes. By attending a live event, participants acknowledge and agree that they may appear in such photographs or videos and grant permission to us to use these materials for marketing purposes, including publication on the internet.
If a participant does not wish to appear in such photographs or videos, they are encouraged to notify us before, during or after the event. We will make reasonable efforts to accommodate such requests, including removing identifiable individuals from published materials where feasible.

3.14 Automated Decision-Making and Profiling
We do not use automated decision-making or profiling in the processing of your personal data.

4. Providing your personal data to others

4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.2 We may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.3 Data collected from Slack interactions or webinar recordings will not be disclosed to third parties or shared publicly. These materials are accessible only to enrolled students and authorized personnel, ensuring the confidentiality and integrity of your data.

4.4 We do not sell, trade, or rent students’ personal identification information to others. Your personal information will only be shared as described in this Privacy Policy and in accordance with applicable laws.

5. International transfers of your personal data

5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

5.2 We have offices and facilities in Hungary.

5.3.1 The hosting facilities for our website are situated in Frankfurt, Germany. (DPA of Digital Ocean, our hosting service provider: https://www.digitalocean.com/security/gdpr/data-processing-agreement/)

5.3.2 The hosting facilities for our newsletter service (Brevo) is a Google data storage center with its location in the European Union (France). By registering to course.data36.com you acknowledge that the information you provide will be transferred to Brevo for processing in accordance with their Privacy Policy and Terms.

5.3.3 The hosting facilities for our Merchant of Record service provider (Paddle) is located in the United States and in the United Kingdom. By buying one or more of our products you acknowledge that the information you provide might be processed by Paddle — in accordance with their Privacy Policy and Terms.

5.3.4 The hosting facilities for our payment processing service provider, Stripe is located in the United States and in Ireland. By buying one or more of our products you acknowledge that the information you provide might be processed by Stripe — in accordance with their Privacy Policy and Terms. (You can find more information in their Privacy Center document.)

5.3.4 The hosting facilities for our payment processing service provider, Barion is located in Hungary. By buying one or more of our products you acknowledge that the information you provide might be processed by Barion — in accordance with their Privacy Policy and Terms.

5.4 The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

5.5 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5.6 The hosting facilities for our online forum (Slack) are located in the United States. By using our Slack forum, you acknowledge that your data may be processed in accordance with Slack’s privacy policy.

5.7 Customer support inquiries managed through Zendesk may involve data transfers to the United States. These transfers are governed by Zendesk’s privacy policy and are protected under appropriate safeguards as required by applicable data protection laws.

6. Third-Party Websites

Students may encounter other content on course.data36.com that link to the websites and services of our partners, suppliers, advertisers, sponsors, licensors, and other third parties. We do not control the content or links that appear on these websites and are not responsible for the practices employed by websites linked to or from our website.

Additionally, these websites or services, including their content and links, may change frequently. These websites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including those linked to or from course.data36.com, are subject to that website’s own terms and policies.

7. Retaining and deleting personal data

7.1 This Section 7 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

7.2 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.

7.3 We will retain your personal data as follows:

(a) Your e-mail address will be retained for a minimum period of 1 minute following your e-mail subscription, and maximum until you ask for erasure of your data.

(b) Your name/nickname will be retained for a minimum period of 1 minute following your e-mail subscription, and maximum until you ask for erasure of your data.

7.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a) the possible shortest by the data processor service.

7.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7.6 Webinar recordings and forum contributions will be retained for the duration of the course and for a maximum of 10 years after course completion to ensure continuity for course participants and to improve course materials. These records will then be archived or deleted unless otherwise required for legal or educational purposes.

8. Amendments

8.1 We may update this policy from time to time by publishing a new version on our website.

8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

8.3 We may notify you of significant changes to this policy by email or through the private messaging system on our website.

9. Your rights

9.1 In this Section 9, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

9.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

9.3 You have the right to request confirmation as to whether we process your personal data, and if we do, to access that personal data along with certain additional information. This additional information includes details about the purposes of the processing, the categories of personal data involved, and the recipients or categories of recipients of the personal data.

Subject to the condition that the rights and freedoms of others are not adversely affected, we will provide you with a copy of your personal data upon request. The first copy will be provided free of charge; however, we may charge a reasonable fee for subsequent copies.

You can view the personal data you have provided on the invoice sent to you. Additionally, you can review and modify your email address and username by accessing your profile at: https://course.data36.com/wp-admin/profile.php.

9.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

9.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

9.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

9.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

9.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

9.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

9.10 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

9.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

9.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

9.13 You may exercise any of your rights in relation to your personal data by written notice to us at hello@data36.com or on our mailing address.

9.14 By attending live Q&A webinars, you consent to the recording of the session. If you wish to withdraw this consent, you can request the exclusion of specific content related to you from future uses of the recordings, subject to technical feasibility.

10. About cookies

10.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

10.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

10.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

10.4 Cookies that we use:

10.4.1 We use cookies for the following purposes:

(a) security – we use cookies [as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

(b) usage – we use cookies to help you use our website and services — cookies used for this purpose are:

  • wordpress_* to keep you logged in to the website and help you track your own course progress
  • wp-settings to save your wordpress settings

These cookies also help us to track your progress with the courses.

11. Cookies used by our service providers

11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

12. Managing cookies

12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

12.2 Blocking all cookies will have a negative impact upon the usability of many websites.

12.3 If you block cookies, you might not be able to use all the features on our website.

13. Our details

13.1 This website is owned and operated by Adattenger Kft. (primary contact person: Tamas Mester).

13.2 We are registered in Hungary under registration number 0109396525, and our registered office is in: Budapest, Hungary, 1118.

13.3 Our principal place of business is at Hungary, Budapest, various places.

13.4 You can contact us:

(a) by email, using hello@data36.com or tomi@data36.com.

14. The Right to Lodge a Complaint with a Supervisory Authority

You have the right to lodge a complaint with a supervisory authority — if, in their opinion, the processing of personal data related to them violates local or international data regulations. In Hungary (registered address of Adattenger Kft.), the competent supervisory authority is the National Authority for Data Protection and Freedom of Information (website: http://naih.hu/; address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c; mailing address: 1530 Budapest, P.O. Box: 5.; phone: +36-1-391-1400; fax: +36-1-391-1410; email: ugyfelszolgalat@naih.hu).

15. Your Acceptance of These Terms

By enrolling in one of our courses, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not register to our course. Your continued enrollment in course.data36.com following the posting of changes to this Privacy Policy will be deemed your acceptance of those changes.

16. Data Breach Notification
In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify the affected individuals without undue delay and report the breach to the appropriate supervisory authority as required by applicable data protection laws.

17. Children’s Data
Our courses and events are not directed at children under the age of 18. If we become aware that personal data of a child under 18 has been provided without parental consent, we will delete such data promptly. Parental or guardian consent is required for minors to participate in live events or online activities.