Privacy Policy

1. The fundamental laws of data management

Act CXII of 2011. on informational self-determination and freedom of information,

Regulation 2016/679/EU on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)

2. Data management ethics

OTP Travel Llc. takes the necessary steps with the personal data of their customers in making sure to always:

(a) handle them lawfully and ethically according to the proper lawful basis (lawfulness, fairness and transparency);

(b) collect them only for regulated, obvious and lawful purpose, and do not use them in a way that contradicts this purpose (purpose limitation);

(c) use them only for reasons that are relevant and necessary the data management’s reasons (data minimization);

(d) ensure that they are precise and make sure they are ready to be used; if possible, always delete or edit incorrect data (accuracy);

(e) store them in a way that the customer’s identification is only possible for a limited time when handling their personal data; storing them longer than that should only be for statistical purposes, with the proper technical and administrative cautions taken (storage limitations);

(f) secure that the necessary technical and administrative steps are taken to ensure the safety of the personal data stored, this includes the measures against the wrongful or unlawful use of data, accidental loss, destruction or impairment (integrity and confidentiality).

3. The data handled by OTP Travel Llc, purpose of data management, legal basis and time period

OTP Travel Llc manages data that is necessary for data management purposes, data that is indispensable for the identification of customers/partners, furthermore, manages the data needed to contact customers/partners.

The legal basis of data management is always the consent of the customer/partner. The consent to the data management is valid until the time indicated by customer/partner.

The customer/partner can request personal consultation about the personal data (about the purpose of the data management, legal basis, type of data, transmission of data, time period of data management, the profile creation’s system) that OTP Travel Llc possesses about them. This request can be done through the contact information below:

E-mail:
Phone: +36 1 354 7313
Address: 1052 Budapest, Deák Ferenc utca 7-9.

4. Client access rights

The client can access their personal data.

The client can request OTP Travel Llc to provide information on how the company handles their personal data.
The client’s right to receive information about how their personal data is being managed by OTP Travel Llc:
(a) is only valid for their own personal data;
(b) does not include anonymous data;
(c) does not include personal data that is not theirs; and
(d) includes data under incognito that can clearly be tied to the client.

5. Client’s right to correct information

The client has the right to correct their personal data. This right
(a) does not include anonymous data;
(b) is only valid for their own personal data;
(c) does not include personal data that is not theirs; and
(d) includes data under incognito that can clearly be tied to the client.

Based on the request of the client, OTP Travel Llc corrects or adds to their personal data. When this happens OTP Travel Llc notifies the recipient of the personal data (if there is such). However, if it proves to be impossible or too difficult, OTP Travel Llc will not notify the recipient.

6. Client’s right to delete information

Based on certain criterium the client can have the right to delete their personal data.

OTP Travel Llc is obligated to delete the client’s personal data without justified delay, in case:
(a) OTP Travel Llc is handling the personal data, and
(b) the client is requesting the deletion of their personal data, and
(c) the personal data is not needed for the purposes of the company’s data management.

OTP Travel Llc is obligated to delete the client’s personal data without justified delay, in case:
(d) OTP Travel Llc is handling the personal data, and
(e) the client is requesting the deletion of their personal data, and
(f) the client withdraws their consent to the management of their personal data, and
(g) there is no further legal basis for the use of the client’s data.

OTP Travel Llc is obligated to delete the client’s personal data without justified delay, in case:
(h) the data management is necessary for the validation of OTP Travel Llc or a third party’s rightful interests, and
(i) the client is against the usage of their personal data by OTP Travel Llc, and
(j) the legal purpose of the data management is not prioritized over the client’s objection.

OTP Travel Llc is obligated to delete the client’s personal data without justified delay, in case:
(k) the client is requesting the deletion of their personal data, and
(l) the management of such data by the company is not illicit, or
(m) the deletion is mandated by the operative laws, or
(n) the client’s data is being collected for informational societal services.

OTP Travel Llc notifies the recipient of the personal data (if there is such) about the deletion of their data. However, if it proves to be impossible or too difficult, OTP Travel Llc will not notify the recipient.

7. The client’s right to the limitation of data management

The client can request the limitation of the management of their personal data.

The client’s right to request the limitation of the management of their personal data
(a) does not include anonymous data;
(b) is only valid for their own personal data;
(c) does not include personal data that is not about them; and
(d) includes data under incognito that can clearly be tied to the client.

OTP Travel Llc limits the management of the client’s personal data, when the data is being checked for precision, if the client requests the limitation of the management of their personal data and the client argues the precision of their data.

OTP Travel Llc limits the management of the client’s personal data if the client requests the limitation of personal data which is illicit to manage, and the client is against the deletion of such data.

OTP Travel Llc limits the management of the client’s personal data, in case
(a) the client is requesting limitation on the management of their personal data, and
(b) OTP Travel Llc does not need this data for the purpose of data management, and
(c) needs the client’s data for the proposal, validation or protection of a legal claim.

OTP Travel Llc limits the management of the client’s personal data, in case
(a) The client objects the use of their personal data, which is necessary for the rightful interests of OTP Travel Llc, and
(b) the client is waiting for the confirmation, that there is a rightful reason for OTP Travel Llc to use their data, which does not have priority against the client’s objection.

OTP Travel Llc notifies the recipient of the personal data (if there is such) about the limitation on the management of their personal data. However, if it proves to be impossible or too difficult, OTP Travel Llc will not notify the recipient.

If OTP Travel Llc limits the management of the client’s personal data, then
(a) they can store such personal data,
(b) based on the consent of the client, they can manage such personal data,
(c) they can use the data for the proposition, validation or protection of legal claims.

OTP Travel Llc cannot use client data for direct business acquisition, including generating profit or automated decision making in special cases.

8. The client’s right to data portability

The client has the right to receive their own personal data in a structured, commonly used and machine-readable format. Furthermore, the client has the right to request that a controller transmit this data directly to another controller without the incapacitation (if technologically possible) of the controller which the personal data was consented to, if the data management is based on consent or is necessary for the completion of the contract and the data management is done automatically.

The client’s right to data portability
(a) does not include anonymous data;
(b) is only valid for their own personal data;
(c) does not include personal data that is not about them; and
(d) includes data under incognito that can clearly be tied to the client.

9. The client’s, as affected party’s, request’s processing time

OTP Travel Llc replies to the client based on the request rights above, in the following time periods.

Request of affected party Deadline to reply
Right to debriefing When the data is collected (if the affected party delivers it) or in a month (if it is not delivered by the affected party)
Right to access One month
Right to correct One month
Right to deletion Without justified delay
Right to limit data management Without justified delay
Right to data portability One month
Right to object When objection is delivered

10. Right to file a complaint

If the client believes that their rights have been breached, OTP Travel Llc recommends that the client initiates communication with the data controller, through contacting the contact person indicated above. If such communication does not lead to results, or the affected party does not wish to participate in such activity, they can turn to the court or NAIH.

The contact information of NAIH is the following: 1125 Budapest, Szilágyi Erzsébet fasor 22/C.; phone: +36 1 391 1400; fax: +36 1 391 1410; e-mail: ; website: www.naih.hu.

11. The modification of the present document

OTP Travel Llc reserves the right to modify the present document at any time. OTP Travel Llc will, in any case, notify the clients in the given measures if such modification occurs, in mail or e-mail.

12. Cookie regulations

When the visitor visits www.isic.hu, a small file “cookie” pops up on the computer, which can serve multiple purposes. Some of the “cookies” we use are indispensable for the adequate running of the website (“continuous cookies”), others collect information about the usage of the website (statistics), in order to improve the comfort, and efficiency of the site.  A few “cookies” are only temporary, and disappear with the closure of the browser, while there are some permanent ones that stay on the computer for a longer time. The purpose of the “cookies” is to facilitate the website’s usage, through observing the visitors’ setting preferences; as well as to improve the user experience, through collecting data on how visitors navigate on the website, and which tabs they use or visit most frequently. This way we can learn how to ensure a better user experience when the visitor returns to the website. Another purpose of the “cookies” is to collect statistics, which help us understand how visitors use our other online services, which we can then improve, such as: the improvement and fine-tuning of the website according to the needs of the users; targeted advertisements to showcase the most relevant offers to the visitors. It is important to note that OTP Travel Llc does not save any passwords or any other identification. The visitors can use our services with complete safety even with the acceptance of the “cookies”.

The website can use the below mentioned service providers targeted, advertising oriented, and analytical cookies:

Google

Google Analytics
The detailed information about this service can be accessed through the link below:
https://www.google.com/analytics/terms/us.html

Google Adwords
The detailed information about this service can be accessed through the link below:
https://www.google.com/intl/hu/policies/privacy

Facebook
The detailed information about this service can be accessed through the link below:
https://www.facebook.com/help/cookies/

The inspection of “cookie settings” and the blocking of “cookies”

Modern browsers allow the modification of “cookie settings”. A few browsers automatically accept “cookies”, but this setting can be changed to prevent the visitor’s automatic acceptance in the future. In case of the change of the setting, the browser will always offer the option of “cookie settings”. We bring to our visitor’s attention, that since the purpose of “cookies” is the constant improvement of our website, and its user experience, if the “cookies” are blocked, we cannot promise that the visitor will be able to use all functions of the website to the fullest extent. The website in this case, can work differently from how it was intended in the browser.

13. Data processors, the parties with the right to access the personal data

Company name: OTP Mobil Llc.
Headquarters: 1147 Budapest, Hungária körút 17-19.

The Affected parties give their consent by giving their personal data to the transfer of their data to the data processors.

I understand that my personal data stored in the user database of https://isic.hu  ran by the data manager OTP Travel Llc (1052 Budapest, Deák Ferenc utca 7-9.) are transmitted to the data processor OTP Mobil Llc.  The transmitted data by the data manager is the following: last name, first name, email, phone number, billing address, final payment sum.

The purpose and method of the data processor’s activity can be read in SimplePay’s Privacy Notice, which can be accessed through the following link:  http://simplepay.hu/vasarlo-aff