PRIVACY NOTICE

The purpose of this Privacy Notice is for SCALER Software Solutions Kft. (hereinafter: "Scaler" or"Controller") to provide data subjects with information on the processing of personal data on the website https://www.scaleragency.io/ (hereinafter: "Website”) and the data processing operations in accordance with the relevant legal requirements, in particular Regulation (EU) 2016/679 of theEuropean Parliament and of the Council (27 April 2016) (the General Data Protection Regulation, hereinafter: “GDPR”).

You can withdraw your consent without giving reasons but such withdrawal does not affect the lawfulness of processing that was carried out based on your consent before its withdrawal. In this context, we also inform you that certain data cannot be deleted even if consent is withdrawn in the case of mandatory data processing based on legislation.

In order to make this Privacy Notice easier to understand, the data protection concepts are explained in Annex No. 1 based on Article 4 of the GDPR.

1. Who does this Privacy Notice apply to?

Please be informed that the potential target group and clients of Scaler qualify as business entities pursuant Point 4 of Section 8:1(1) of Act V of 2013 on the Civil Code and, with respect to information society services, paragraph t) of Section 2 of Act CVIII of 2001 on Certain Issues of Electronic Commerce Activities and Information Society Services.

When using the Website, persons acting on behalf of businesses may disclose personal data to us during their communication with us. In such cases, as a data controller, we must ensure compliance with the data protection regulations.

We would like to inform you that if you visit us as a private entrepreneur, the data you provide as a private entrepreneur qualify as personal data.

2. Name of the Controller and the Processors

SCALER Software Solutions Kft.

Registered office: 2000 Szentendre, Deák Ferenc street 26. 5th door
Email: hello@scaleragency.io
Company register number: 13-09-186956
Registered by: the Court of Registration of Budapest Environs Regional Court
Tax number: 23597970-2-13

Hosting service: Webflow, Inc.

Registered office: 398 11th Street, Floor 2, San Francisco, CA 94103
Email: support@webflow.com

The Controller uses the following data Processors to process the personal data for the purposes of providing a service to the Controller:

Name of Processor	Registered office	Data processing activity
Webflow, Inc	398 11th Street, Floor 2, San Francisco, CA 94103	Hosting service

3. Categories of personal data being processed, purpose, legal basis and duration of data processing

3.1 Contacting Scaler

3.1.1 On the telephone number(s) listed on the website

Please note that the telephone numbers listed on the Website are handled directly by Scaler's professional colleagues, and calls are forwarded to them. These calls are not recorded.

Categories of personal data	Purpose of data processing	Legal basis for data processing	Duration of data processing
• A natural person acting on behalf of the business (data subject) • In the case of a business as a natural person private entrepreneur (data subject): name (surname and first name), telephone number, date and time of call	Identifying the data subject.	The data subject’s consent pursuant to Recital (32) and point (a) of Article 6(1) of the GDPR.	The telephone conversation will not be recorded, so the data processing lasts for the duration of the telephone conversation.
• A natural person acting on behalf of the business (data subject) • In the case of a business as a natural person private entrepreneur (data subject): the person’s voice and all data provided by the data subject during the telephone conversation	Answering phone inquiries.	The data subject’s consent	The telephone conversation will not be recorded, so the data processing lasts for the duration of the telephone conversation.
• A natural person acting on behalf of the business (data subject) • In the case of a business as a natural person private entrepreneur (data subject): name (surname and first name), address, phone number, email address, data subject request	Performing tasks related to the requests submitted by the data subject.	Compliance with a legal obligation to which the Controller is subject (point c) of Article 6(1) of the GDPR.	For the duration of the telephone conversation, or, if the Controller takes action as a result, the data provided during the telephone conversation is retained for 5 years from the date of the action pursuant to Section 6:22(1) of Act V of 2013 on the Civil Code.

3.1.2 In emails sent to the email addresses listed on the website

Categories of personal data	Purpose of data processing	Legal basis for data processing	Duration of data processing
• A natural person acting on behalf of the business (data subject) • In the case of a business as a natural person private entrepreneur (data subject): name (surname and first name), email address	Keeping contact with the data subject.	The data subject’s consent pursuant to Recital (32) and point (a) of Article 6(1) of the GDPR, provided that the data subject sends an email to the Controller’s email address. or legitimate interest pursuant to point (f) of Article 6(1) of the GDPR. If the inquiry qualifies as a data subject’s request, compliance with a legal obligation pursuant to point (c) of Article 6(1) of the GDPR, in accordance with Article 12(3) of the GDPR.	From the receipt of the email, or, if the Controller takes action as a result, for 5 years from the date of the action pursuant to Section 6:22(1) of Act V of 2013 on the Civil Code.
• A natural person acting on behalf of the business (data subject) • In the case of a business as a natural person private entrepreneur (data subject): the email address and the content of the email, as well as the personal data provided therein.	Management of inquiries, provision of information.	The data subject’s consent pursuant to Recital (32) and point (a) of Article 6(1) of the GDPR, provided that the data subject sends an email to our email address, or compliance with a legal obligation pursuant to point (c) of Article 6(1) of the GDPR, or legitimate interest pursuant to point (f) of Article 6(1) of the GDPR. If the inquiry qualifies as a data subject’s request, compliance with a legal obligation pursuant to point (c) of Article 6(1) of the GDPR, in accordance with Article 12(3) of the GDPR.	From the receipt of the email, or, if the Controller takes action as a result, for 5 years from the date of the action taken, pursuant to Section 6:22(1) of Act V of 2013 on the Civil Code.

3.1.3 Through a contact form

Categories of personal data	Purpose of data processing	Legal basis for data processing	Duration of data processing
• A natural person acting on behalf of the business (data subject) • In the case of a business as a natural person private entrepreneur (data subject): name (surname and first name), company name	Identifying the data subject.	The consent of the data subject pursuant to Recital (32) of the GDPR and point (a) of Article 6(1) of the GDPR, provided that the data subject ticks the necessary checkbox available on the Contact Form to consent to data processing and submits a Contact Form to the Data Controller. In the case of a data subject as a natural person private entrepreneur, the legal basis for data processing may also be point (b) of Article 6(1) of the GDPR. If the business is not a private entrepreneur, an additional legal basis for data processing may be the fulfilment of a legal obligation pursuant to point (c) of Article 6(1) of the GDPR.	From the receipt of the email, or, if the Controller takes action as a result, for 5 years from the date of the action pursuant to Section 6:22(1) of Act V of 2013 on the Civil Code.
• A natural person acting on behalf of the business (data subject) • In the case of a business as a natural person private entrepreneur (data subject): e-mail address, telephone number	Keeping contact with the data subject.	The consent of the data subject pursuant to Recital (32) of the GDPR and point (a) of Article 6(1) of the GDPR, provided that the data subject ticks the necessary checkbox available on the Contact Form to consent to data processing and submits a Contact Form to the Data Controller. In the case of a data subject as a natural person private entrepreneur, the legal basis for data processing may also be point (b) of Article 6(1) of the GDPR. If the business is not an individual entrepreneur, the additional legal basis for data processing may be compliance with a legal obligation pursuant to point (c) of Article 6(1) of the GDPR.	From the receipt of the email, or, if the Controller takes action as a result, for 5 years from the date of the action taken, pursuant to Section 6:22(1) of Act V of 2013 on the Civil Code.
• A natural person acting on behalf of the business (data subject) • In the case of a business as a natural person private entrepreneur (data subject): the subject of the inquiry, other information provided by the data subject in the message	Answering the question submitted by the data subject via the Contact form, informing the data subject.	The consent of the data subject pursuant to Recital (32) of the GDPR and point (a) of Article 6(1) of the GDPR, provided that the data subject ticks the necessary checkbox available on the Contact Form to consent to data processing and submits a Contact Form to the Data Controller. In the case of a data subject as a natural person private entrepreneur, the legal basis for data processing may also be point (b) of Article 6(1) of the GDPR. If the business is not a private entrepreneur, an additional legal basis for data processing may be the fulfilment of a legal obligation pursuant to point (c) of Article 6(1) of the GDPR.	From the receipt of the email, or, if the Controller takes action as a result, for 5 years from the date of the action taken, pursuant to Section 6:22(1) of Act V of 2013 on the Civil Code.

3.2 Contact for requesting an offer

Categories of personal data	Purpose of data processing	Legal basis for data processing	Duration of data processing
The natural person acting on behalf of a company requesting an offer (data subject). name (surname and first name), phone number, email address, company name, other information provided by the data subject	Sending the offer in order to conclude the contract for the specific Scaler service as soon as possible.	The data subject’s consent pursuant to paragraph a) of Article 6(1) of the GDPR, and the legitimate interest of Scaler and the person requesting an offer pursuant to point (f) of Article 6(1) of the GDPR for establishing and maintaining business contacts.	In the case of concluding a contract for the Scaler service, 8 years after its termination. If no contract is concluded, the data will be deleted immediately.
The natural person private entrepreneur requesting an offer (data subject): name (surname and first name), phone number, email address, other information provided by the data subject	Sending the offer in order to conclude the contract for the specific Scaler service as soon as possible.	The data subject’s consent pursuant to paragraph a) of Article 6(1) of the GDPR, and before concluding a lease contract, to take the steps requested by the data subject by (pursuant to point (b) of Article 6(1) of the GDPR).	In case of conclusion of a contract for the specific Scaler service, 8 years after its termination. If no contract is concluded, the data will be deleted immediately.

3.3 Conclusion and performance of a contract related to Scaler services

Categories of personal data	Purpose of data processing	Legal basis for data processing	Duration of data processing
A natural person acting on behalf of the company (data subject) as a contact person: name (surname and first name), telephone number, email address, company name	The conclusion of the contract for the specific Scaler service and its fulfilment and the related liaising.	The legitimate interest of Scaler pursuant to point (f) of Article 6(1) of the GDPR for maintaining business contacts and for performing the contract for the specific Scaler service.	8 years after terminating the contract for the specific Scaler service.
The business as a natural person private entrepreneur (data subject): name (surname and first name), telephone number, email address	The conclusion of the contract for the specific Scaler service and its fulfilment and the related liaising.	Fulfilment of the contract for the specific Scaler service (Pursuant to point (b) of Article 6(1) of the GDPR).	8 years after terminating the contract for the specific Scaler service.
The business as a natural person private entrepreneur (data subject): Billing name and address, tax number	Issuing an invoice.	Compliance with legal obligation pursuant to point (c) of Article 6(1) of the GDPR and Section 169 of Act CXXVII of 2007 on Value Added Tax (VAT Act).	For 8 years after the issue date of the invoice pursuant to Section 169(2) of Act C of 2000 on Accounting.

3.4 Making an appointment for consultation through the Website

Categories of personal data	Purpose of data processing	Legal basis for data processing	Duration of data processing
A natural person acting on behalf of the business (data subject) name (surname and first name), telephone number, email address, company name	Identifying the data subject.	Consent of a data subject pursuant to point (a) of Article 6(1) of the GDPR.	In the case of concluding a contract for the Scaler service, until the conclusion of the contract. If no contract is concluded, the data will be deleted immediately.
The natural person private entrepreneur requesting consultation (data subject): name (surname and first name), other information provided by the data subject	Identifying the data subject.	Consent of a data subject pursuant to point (a) of Article 6(1) of the GDPR.	In the case of concluding a contract for the Scaler service, until the conclusion of the contract. If no contract is concluded, the data will be deleted immediately.
Data subject’s telephone number, email address	Keeping contact and arranging for a consultation	Consent of a data subject pursuant to point (a) of Article 6(1) of the GDPR.	In the case of concluding a contract for the Scaler service, until the conclusion of the contract. If no contract is concluded, the data will be deleted after the consultation.

3.5 Subscribing to professional materials (eDM = electronic Direct Mail)

Categories of personal data	Purpose of data processing	Legal basis for data processing	Duration of data processing
- In the case of a natural person acting on behalf of the business (data subject) or a business as a natural person private entrepreneur (data subject): name (surname and first name), company name, email address	Sending messages containing advertising and other information about e.g. Scaler’s services, professional news, events, etc.	Consent of a data subject pursuant to point (a) of Article 6(1) of the GDPR and Section 6 of the Act on Business Advertising.	Until the data subject unsubscribes from eDM.

3.6 Job advertisements and selection process

If you visit the Website for the purpose of searching for a job, please read the privacy notice for our career page, which is available at the following link:
https://jobs.scaleragency.io/jobs

Please note that the notice available at the link above also applies to cases where you send us your CV by e-mail.

4. Data transmission

Please note that there may be a case where the data subject's personal data are used by a third party in order to present, assert or defend a legal claim, e.g. we transmit it to a legal representative, consultant or IT service provider and disclose it in order to perform these tasks.

For the purpose of complying with our legal obligations as a data controller, we are obliged to forward the personal data of the data subject to authorities and courts in the event of a relevant request.

If the consultation takes place via video call, please note that the video consultation takes place via Microsoft Teams, Zoom, Google Meet or another programme of your preference. Please read the privacy notice of the service provider carefully.

Microsoft Teams:
https://support.microsoft.com/hu-hu/office/%C3%A1ltal%C3%A1nos-adatv%C3%A9delmi-szab%C3%A1lyzat-gdpr-%C3%A9s-a-teams-ingyenes-verzi%C3%B3ja-bdf2e378-da6b-48d9-a13d-44917c6ee90a9
https://support.microsoft.com/hu-hu/office/a-teams-ingyenes-verzi%C3%B3j%C3%A1nak-t%C3%A1mogat%C3%A1si-%C3%A9s-adatv%C3%A9delmi-szab%C3%A1lyzata-9116c829-c8fa-4822-96a3-1e89b2911ba5

Zoom:
https://explore.zoom.us/en/trust/resources/#q-params?filter=%7B%22Legal%20%26%20Compliance%20Resources%22%3A%5B%22Notices%20and%20Policies%22%5D%7D&keywords=

Google Meet:
https://support.google.com/meet/?hl=hu#topic=10632347

Please note that our dedicated colleagues have access to your personal data in order to perform their duties, but they can use it exclusively for the purpose of performing their duties, and they must keep the personal data related to data subjects that they come to know confidential and treat it as a business secret.

For the avoidance of doubt, we inform you that personal data will and may be shared with the Data Processors specified in Section 2 of this Privacy Notice.

5. Remarketing activity

Please note that natural persons may be associated with online identifiers provided by their devices, applications, tools and protocols, such as IP addresses, cookie identifiers or other identifiers such as radio frequency identification tags. This may create links which, in particular when combined with unique identifiers and other information received by the servers, may be suitable for creating profiles of the data subjects and identifying them.

Our remarketing activity on the online platform is controlled by cookies and advertising technologies such as data collection signals, pixels, etc. in order to display relevant advertisements to users much more effectively. Based on these, individual advertisements and discounts can also be displayed.

There are also cookies that allow you to repeatedly display the products you are interested in. Such cookies are used e.g. by Google's system, LinkedIn and Facebook. In any case, please refer to our Cookie Notice available in the footer of our website for information on the cookies we use.

Please note that we can carry out remarketing activities only with your consent, which you are deemed to have been given by reading and accepting this Privacy Notice and the above-mentioned Cookie Notice, as well as by setting cookies. If you wish to object to this, you can do so at the email address hello@scaleragency.io.

Facebook

Our website may contain so-called plug-ins and pixels. In these cases, your browser contacts Facebook's servers directly. The content of such plug-ins is sent directly by Facebook to your browser. Facebook gets notified that your browser has accessed our website, even if you do not have a Facebook profile or are not currently logged into your Facebook profile at the given moment in time.

We would like to inform you that your IP address will be sent directly to the Facebook server by your browser program, where it will be recorded by Facebook. If you are logged in to your Facebook profile when using our website, Facebook can directly connect your browsing on our website to your Facebook profile.

Please note that Facebook is entitled to use the information collected about you for advertising purposes and for the purpose of conducting market studies. Facebook can create user accounts, define their interests, build relationships, in order to evaluate the use of certain pages, it is entitled to inform other Facebook users and offer services based on this.

If you do not want Facebook to connect the data obtained during your use of our Website with your user account, you must log out of your Facebook account before visiting our Website.

Please refer to Facebook's privacy policy for information on Facebook's data protection, which can be accessed by clicking on the link below:
https://www.facebook.com/privacy/policy

Please note that we also use the LinkedIn Insight Tag, which operates on a principle similar to Facebook, for the same purpose as above.

6. Analytical cookies

Google (Google Analytics, Google Search Console)

Our Website uses the web analytics services provided by Google LLC (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; or Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) ("Google")).

Google Analytics uses so-called "cookies", text files which are stored on your computer and which facilitate an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there.

However, due to the IP anonymisation on this website, your IP address will be shortened by Google within member states of the European Union or in other states that are party to the Agreement on the European Economic Area before transmission. The complete IP address is only transmitted to a Google server in the USA and shortened in exceptional cases.

Google will use this information on behalf of the operator of this website to evaluate your use of the Website, to compile reports on Website activities and to improve the use of the Website and the use of the services associated with the use of the Internet for the Website operator.

The IP address transmitted by your browser as part of the Google Analytics process is not merged with other data from Google.

You can block or modify the use of cookies by selecting the appropriate settings in your browser. Please note, however, that in this case you may not be able to use all functions of this website.

You can also prevent Google from processing the data generated by the cookie and your use of our Website (including your IP address) by downloading and installing the browser plugin via the following link:
https://tools.google.com/dlpage/gaoptout?hl=en

In particular, we would like to point out that Google Analytics has extended the code gat.anonymizeIp(); to enable the anonymized recording of IP addresses or so-called "IP masking".

You can prevent Google Analytics from collecting data by clicking on the link below. An opt-out cookie will be set to block any future collection of your data when you visit this website:
https://support.google.com/analytics/answer/9019185?hl=hu#zippy=%2Ca-cikk-tartalma

For the use of Google Analytics, we have an overriding legitimate interest, namely the interest in an appealing presentation of our offers as well as the analysis of visits to our Website, so that we are able to improve our presentation.

The Google Search Console helps us with statistical data to optimise our Website in the most efficient way possible.

7. Data security measures

Pursuant to Article 32 of the GDPR, the Controller endeavours to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of data subjects.

Therefore, where appropriate, we will ensure:

pseudonymisation or encryption of personal data,
the integrity of our internal systems,
that in the event of a physical or technical incident (malfunction), the installed systems can be restored.

8. What are your rights under the GDPR (data subject rights)?

8.1 Information and access to personal data

Prior to data processing, the data subject must be informed about the person, representative and contact details of the Controller, the legal basis and purpose of data processing as well as the information related to data processing defined in Article 13 of the GDPR.

The data subject shall have the right to obtain from the Controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the following information:

what personal data are being processed by the Controller,
on what legal basis,
for what data processing purpose,
how long it is processed and to whom, when, under what legislation the Controller provided access to his/her personal data or to whom it transmitted his/her personal data,
what source his/her personal data come from (if the data was not provided to the Controller by the data subject),
whether the Controller applies automated decision-making, including its logic and profiling.

At the data subject’s request, the controller shall provide the data subject with a copy of the personal data undergoing processing free of charge for the first time, and then it may charge a reasonable fee based on its administrative expenses.

In order to comply with data security requirements and protect the rights of the data subject, please note that the Controller is obliged to make sure that the data subject and the person wishing to exercise the right of access are identical. Therefore, the data subject must be identified before providing any information or giving access to the data or issuing a copy of the same.

8.2 Right to rectification or supplementation

The data subject may request the Controller via e-mail (hello@scaleragency.io) to correct his/her inaccurate or changed personal data, including requesting extension of his/her personal data by means of an additional statement, in consideration of the purpose of data processing.

8.3 Right to erasure (‘right to be forgotten’)

The data subject has the right to request the Controller to erase the personal data concerning him/her without undue delay, and the Controller is obliged to erase the personal data concerning the data subject if any of the following reasons exists:

the data subject withdraws his/her consent that constitutes the legal basis for the processing and there is no other legal basis for the processing;
the data subject objects to the processing of the data under Article 21(1) of the GDPR and there is no overriding legitimate reason for the processing; or
the data subject objects to the processing under Article 21(2) of the GDPR;
the personal data have been unlawfully processed;
the personal data has to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
the personal data have been collected in connection with the provision of information society services referred to in Article 8(1) of the GDPR.

8.4 Right to restrict processing

The data subject has the right to obtain from the Controller restriction of processing where one of the following applies:

the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
the Controller no longer needs the personal data for the purposes of the processing, but the data subject requests the same for the assertion, exercise or defence of legal claims; or
the data subject has objected to processing pursuant to Article 21(1) of the GDPR, in which case the restriction shall apply until it is verified whether the legitimate grounds of the controller override those of the data subject.

8.5 Right to data portability

The data subject concerned has the right to receive the personal data concerning him or her, which s/he has provided to a controller, in a structured, commonly used and machine-readable format and has the right to transmit those data, without hindrance by the Controller, to another controller to which the personal data were provided, if the data processing is based on consent or on a contract under point (b) of Article 6(1) of the GDPR, and the data processing is automated.

8.6 Right to object

The data subject may object to data processing at any time if in his/her opinion the Controller would not process his/her personal data properly in connection with the purpose indicated in this Privacy Notice. In this case the Controller shall demonstrate the compelling legitimate grounds for the processing of data which override the interests, rights and freedoms of the data subject or which are related to the assertion, exercise or defence of legal claims.

8.7 Exercising the data subject rights in the event of death

Based on Act CXII of 2011 on the right to informational self-determination and freedom of information (Info Act), in the event of the data subject’s unexpected death, the person authorised by the data subject through an administrative provision or a statement made to the Controller in the form of a public document or a private document with full probative value is entitled to enforce the rights that the data subject is entitled to in his/her life within 5 years after the data subject’s death.

If the data subject does not make a legal declaration in accordance with the above during their lifetime, their close relative — as such term is defined in the Civil Code — is also entitled to assert their right to rectification and the right to object to data processing in the absence of such declaration and, if the data processing was already unlawful during the data subject's lifetime or the purpose of data processing has ceased upon the death of the data subject, the close relative is entitled to assert their right to erase data or restrict data processing within 5 years of the death of the data subject.

The close relative who first exercises this right is entitled to assert the rights of the data subject in accordance with this paragraph.

The person asserting the data subject’s rights in case of the data subject’s death shall certify the fact and time of the death of the deceased data subject by a death certificate or a court decision, and their own identity — and their capacity as a close relative pursuant to the previous paragraph — with a public instrument.

8.8 Right to withdraw consent

The Controller informs the data subjects that if personal data are processed on the basis of the data subject's consent, the data subject can withdraw his/her consent at any time by sending a statement to the Controller. The withdrawal of consent shall not affect the lawfulness of processing that was carried out based on consent before its withdrawal.

9. Legal remedies

Please note that if you have any questions or requests regarding our data processing, you can contact us at the email address hello@scaleragency.io.

We are obliged to investigate the request received and inform you of our response within 1 month, taking into account the legal deadline. We may extend the deadline for processing your request by another 2 (two) months taking into account the complexity and number of the requests in progress, or if otherwise justified. However, we will inform you in advance of such extension and its reasons.

You have the right to file a complaint directly with the National Authority for Data Protection and Freedom of Information (NAIH) at the following contact details:

Address: 1055 Budapest, Falk Miksa utca 9-11.
Postal address: 1363 Budapest, Pf.: 9.
Telephone: +36 (30) 683-5969; +36 (30) 549-6838; +36 (1) 391 1400
Fax: +36 (1) 391-1410
E-mail: ugyfelszolgalat@naih.hu
Website: http://naih.hu/

Please check the NAIH website for up-to-date contact information in advance.

You can also turn to court if your rights under the GDPR have been violated during the processing of your personal data. Pursuant to Section 23(3) of the Info Act, you may choose to start action at the court that has jurisdiction according to your place of residence or your place of stay, as you may deem fit.

The contact details of Hungarian courts can be found through the following link:
http://birosag.hu/torvenyszekek

10. Final Provisions

Please note that you are solely and exclusively responsible for the correctness and accuracy of all data provided by you with regard to the purposes indicated in this Privacy Notice.

We have the right to unilaterally modify this Privacy Notice at any time without the consent of the data subject. The amendment is effective from the date of publication, which will be published on the Website.

This Privacy Notice has been drawn up in Hungarian and in English. If there is any conflict between the Hungarian and English versions, the Hungarian language version shall prevail.

‍

Budapest, 24 Apr 2025
SCALER Software Solutions Kft.

Annex 1. Privacy terms under Article 4 of the GDPR

personal data: means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

processing: means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

controller: means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

processor: means natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller.

profiling: means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

consent of the data subject: means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

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