The processing and collecting of personal data by Leopoly shall be in harmony with the directly applicable laws of the European Union and the provisions of the Hungarian laws in effect. In case of personal data processing, the Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter: “GDPR”), the Act CXII of 2011 on the Right to Informational Self-determination and Freedom of Information (hereafter: “Freedom of Information Act”), the Act XLVIII of 2008 on the Essential Conditions and Certain Limitations of Business Advertising Activity (hereinafter: “Business Advertising Act”), furthermore the recommendations and the data protection practice of the Hungarian National Authority for Data Protection and Freedom of Information (hereinafter: “NAIH”) and the recommendations of the Article 29 Data Protection Working Party (hereinafter: “WP29”) shall apply.
We will keep confidential the personal data received and take all necessary steps to secure data processing.
The following definitions are determined according to the GDPR:
As stated above, Leopoly is the data controller of any data which constitutes personal data and is uploaded and collected when using the Website or the Service or subscribing for the Newsletter.
The information we gather from users enables Leopoly to personalize and improve our services and to allow our users to set up accounts on the Website. We collect the following types of information from our users:
We receive and store any information you enter on our Website or provide to us in any other way using the Services. The types of information collected include, without limitation, email address, user name and password, avatar picture, “about” text, your 3D objects, and description about it.
We receive and store certain types of information whenever you use the Website:
When you visit our Website, Leopoly automatically receives and records information on our server logs from your browser including your IP address, unique device identifier, browser characteristics, domain and other system settings, search queries, device characteristics, operating system type, language preferences, referring URLs, actions taken on our Website, page requested and parts visited of our Website, dates and times of Website visits, and other information associated with other files stored on your device.
We receive and store certain types of information whenever you use the Application. The types of information collected include, without limitation the number of saves, the type of models saved, date of registration, date of last use.
Some users may elect to publicly post personally identifying or sensitive information about themselves in their normal use of the network. This could occur through use of the optional profile fields, in question or answer posts, or when an individual posts a job history on the careers site. Information like that, which is voluntarily posted in publicly visible parts of the network, is considered to be public, even if it would otherwise be considered to be personally identifying or sensitive. As such, it is not subject to the protocols listed below, because we don’t control it; you do. Additionally, voluntarily publicizing such information means that you lose any privacy rights you might normally have with regards to that information. It also increases your chances of receiving unwanted communications, like spam.
We do not collect any personally identifiable information from children under the age of 16. If you believe that a child has provided us with personally identifiable information without the consent of his or her parent or guardian, please contact us at firstname.lastname@example.org. If we become aware that a child under age 16 has provided us with personally identifiable information, we’ll delete it.
We collect mainly anonymous data from the Website, such as searches. The anonymized data can include user session data such as IP address, web browser type, the time spent on the page by the user, and user-clicked buttons. Leopoly processes anonymous data in order to improve the page, to bring it to perfection. During this procedure Leopoly can incorporate “cookies”, which collect the visitor’s first level domain name, the date and the exact time of access. The “cookie” alone can’t be used to reveal the identity of the visitor. The “cookie” is a file, which is sent to the browser of the visitor and stored on the hard drive of the visitor. Cookies don’t damage the computer of the visitor. The browser can be set to indicate when a cookie is received, so the visitor can decide to accept the so-called cookie or not. We do not collect or manage any information that would allow the identification of the visitor.
We may use your information, including your personal information - based on diverse purposes as well as the legal basis of the processing - as follows:
The above information you provide is used for purposes such as responding to your requests for certain products and services, customizing the content you see, communicating with you about specials, sales offers, and new features, and responding to problems with our services. It is also used to manage payments, issuing the invoice or requests for information, or to otherwise serve you, provide any requested services and administer sweepstakes and contests.
You shall always have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on your consent before your withdrawal.
We may post user testimonials on the Website to reflect the experiences and honest opinion of the users regarding the Application. These testimonials contain the name and the profile picture of the reviewers, which is considered personal data. We may only post the testimonials after the prior consent of the users. The users shall have the right to update or delete their testimonials by an email sent to the following address of the customer service: email@example.com.
Personal data collected when you visit our Website:
For collecting the above-mentioned data and making statistics and analysis we may use the following software and programs:
|Google Analytics (Google LLC.)||1600 Amphitheatre Parkway Mountain View, CA 94043||United States|
|Facebook pixel, Instagram (Facebook Inc.)||1601 Willow Road Menlo Park, CA 94025||United States|
|Mailchimp||675 Ponce de Leon Ave NE
Atlanta, GA 30308 USA
|Hubspot||25 First Street, 2nd Floor Cambridge, MA 02141 United States||United States|
|1000 W. Maude Avenue
Sunnyvale, CA 94085
|Salesforce||The Landmark @ One Market
San Francisco, CA 94105
|Crazy Egg, Inc.||16220 East Ridgeview Lane, La Mirada, CA 90638, United States||United States|
Personal data collected when you use the Application:
Leopoly uses both the above listed personal data and the derived aggregated data for statistical purposes as well.
We will retain your personal data for so long as it is needed to fulfill the purposes outlined in this Policy or until you withdraw your consent, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). When we have no longer or no legal basis to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
During the service of data process the data processor shall abide under the present Policy, the relevant legislations in force, and the provisions of the existing contracts.
We use the data process service of the following companies:
|Name||Registered seat||Country||Activity (data processing service)|
|Mailchimp||675 Ponce de Leon Ave NE
Atlanta, GA 30308 USA
|United States||Marketing automation platform, that helps us to keep connection with our customers and audience.|
|Hubspot||25 First Street, 2nd Floor Cambridge, MA 02141 United States||United States||Marketing automation and content management platform, that helps us to keep connection with our customers and audience.|
We only transfer personal data collected from individuals located within the EU to a third-party having a registered seat outside the EU or the United States of America acting as a data processor without appropriate safeguards when it is necessary for the performance of the contract. Leopoly will make every effort to ensure that the personal data transferred is safe and secure and that the personal data is processed in a manner consistent with the GDPR.
Based on the adequacy decision by the Commission of the European Union regarding third countries like United States (Privacy Shield) ensures an adequate level of data protection. Due to the fact that our service provider Mailchimp and Hubspot has his registered seat in the USA and complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework, the transfer of your personal data to the mentioned service provider can take place.
We reserve the right to change the Policy, or to modify it according to the changes in the applicable laws of the European Union law or the Hungarian law.
The present Policy shall enter into force on 25th May, 2018
If you have any questions concerning this Policy or the Services, please contact us at firstname.lastname@example.org. You can also contact us at our contact office at H-4028 Debrecen, Kassai út 26., Hungary.
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