FASTRRR INTERNATIONAL

PRIVACY POLICY

Last Updated: 1 August, 2021

GENERAL PROVISIONS

  1. The purpose of this Privacy Policy is to inform and assure our Users that the personal data we process during the provision of our services is solely for the purposes set out in this policy, with appropriate legal basis, and in accordance with the requirements of purpose limitation, data minimisation, storage limitation, accuracy, integrity, fairness and accountability, by applying solutions that are in line with the current state of the art and cost-effective technology, and by informing our Users as data subjects in advance and ensuring the enforcement of their rights.

  2. This Privacy Policy forms an integral part of FASTRRR International’s General Terms and Conditions, so the provisions pertaining to the Product, related services, and the definitions of terms used in this policy are defined in the General Terms and Conditions of Use and this Privacy Policy should be read and interpreted within the framework of these General Terms.

  3. Therefore please read this notice carefully and thoroughly before placing an order for a Product and/or registering on the Platform. By completing a purchase and/or registering on the Platform, you agree to accept the terms and conditions of this privacy policy. Therefore, if you do not agree with the provisions of our privacy policy, please do not use our Product.

  4. Our Company reserves the right to revise this Privacy Policy. We will notify our Users via the email address provided in their User Accounts 15 days prior to the changes made. The amended provisions shall apply from the day of its posting on our Website and in our App. Your continued use of the Platform or the Product following the posting of any changes to these Terms and Conditions constitutes your acceptance of those changes. 

  5. This privacy policy is always available – together with the General Terms – on our Platform. If you have any requests, questions or complaints, please write us at [email protected].

DATA CONTROLLERS

  1. The manufacturer, the distributor of the Product and in particular the owner, provider and operator of the Platform - and concerning your personal information, the data controller – is FASTRRR International LLC (registered in Hungary under the company registration number 19-09-520671; registered seat at 24 Bolgár Mihály Str., 8200 Veszprém, Hungary; VAT-number: HU27034712; email: [email protected]; hereinafter: Data Controller or Company or Service Provider).

  2. As the data controller, we make sure and warrant that the data handling performed by our Company complies with this privacy policy and any applicable national and European Union legislation, in particular the General Data Protection Regulation of the European Union (2016/679) and the Hungarian Informational Self-Determination and Freedom of Information Act (Act CXII of 2011).

  3. As the data controller, we consider it especially important to protect the personal information of our Users and to respect their right to informational self-determination. Therefore, we handle the personal information of our Users as confidential and take all the necessary and appropriate security, technical and organizational measures that guarantee the security of their data.

  4. As the data controller, we handle personal data on our Platform with appropriate legal basis specified in applicable laws, rules and regulations and only for the purposes set out in this Privacy Policy. If we wish to use the personal data on our Platform for a purpose other than the purpose of the original data collection, we will ask for our User’s prior, explicit consent.

  5. Please note that our Company is unable to fully check the reality, authenticity and accuracy of the personal information and other data provided on our Platform, therefore our Company may not be held liable for these.

  6. Please also note that the Devices do not record personal data, the data that can be traced back to the Data Subject can only be recorded and stored by the Platform in accordance with the User's subscription package.

DATA PROCESSORS, THIRD PARTY SERVICE PROVIDERS

  1. In order to provide the best possible service, our Company engages the services of third party data processors (hereinafter as ‘Third Party Service Providers’) for the following purposes:

  2. Purpose of data processing

    Name of Third Party Service Provider

    The platform webhosting

    Hostinger.hu

    to ensure the provision of the Company’s services and to improve user experience, services provided by third party businesses

    (weather forecasting, GPS based location services)

    OpenWeatherMap

    billing

    Szamlazz.hu

    online payment for subsciptions

    PayPal

    system information, emails and newsletters

    Outlook, MailChimp

    delivery services

    Webshippy

    tracking the use of the Platform

    see Cookie table

  3. In certain instances, Third Party Service Providers engaged for services to enable or to improve the Product provided by the Company, may qualify as independent data controllers. In such instances, our Company shall not be liable for the data handling performed by these Third Party Service Providers, however we will do everything in out ability to choose Third Party Service Providers who meet all requirements of data protection regulations.

  4. By completing a purchase or registering on our Platform, the User acknowledges that they have read, understood and accepted the Third Party Service Providers’ general terms and conditions of service. If you don’t agree with the policies of these Third Party Service Provider(s), please do not use our Product.

  5. If you have any questions or complaints about any Third Party Service Providers indicated on our Platform, please write to us at[email protected].

LEGAL BASIS

  1. Our data processing is based on the following legal bases:

    1. prescribed by law for a purpose based on the public interest (legal obligation)

    2. the data subject has consented to the processing of their personal data for one or more specific purposes (voluntary consent);

    3. the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to the conclusion of the contract (performance of contract);

    4. processing is necessary for compliance with a legal obligation to which the controller is subject (legal obligation of data controller);

    5. processing is necessary for the protection of the legitimate interests of the data controller or of a third party (legitimate interest).

  2. Please note that the Hungarian E-Commerce Act states that in order to sell the Product and to use, modify and monitor the performance of the services provided by the Platform, to bill subscription fees and to enforce any related claims, we may manage the personal information necessary to identify our User and their address. For the purpose of selling the Product and to invoice our subscriptions, we may also manage our Users' personal information identifying them, their address, the time and date, duration and location of our service, and data technically essential for the provision of the Platform in addition to the aforementioned personal data.

  3. Your voluntary consent to our Company’s data processing may be revoked by you as the User at any time, however having revoked your consent you will no longer be able to enjoy the services provided by our Product, and in particular by our Platform.

  4. You may complete a purchase on our Platform if you are at least 16 years old and have the legal capacity to enter into such a legal agreement.

  5. It is forbidden to provide the personal information of another natural person, and to use the Platform in their name without their knowledge and consent.

  6. If the handling, storage or transfer of a set of personal data provided on our Platform is required by law, a public authority or a court order, we will notify the User concerned directly.

THE PURPOSES AND DURATION OF DATA MANAGEMENT, CATEGORIES OF PERSONAL INFORMATION

  1. We process personal information provided to us in person or on our Platform solely for the purposes specified below, and only to the extent necessary and appropriate for these purposes and time. We do not use personal data for purposes other than those specified below. In accordance with the principle of data minimisation, we only process personal data that is essential for these purposes.

  2. Purpose(s)

    Personal information

    Duration of data processing

    To manage and maintain Platform

    technical data

    The log files are stored on the system for a reasonable period of time to ensure the operation of the system.

    Managing your Subscription:

    Product Purchase,

    Billing,

    Registering on or using Platform,

    Renewal

    Customer’s full name

    Date of birth

    Billing and/or delivery address

    Phone number

    Email

    Purchased product(s)’s name, number

    subscription package

    Banking information, access information from financial service provider

    GPS-coordinates (location of device)

    Until the termination of the user account, or until necessary by law, in compliance with regulations pertaining to data storage, or in the absence of such regulations, 5 years.

    Additional User Account information for product development and to improve user experience

    (e.g. Weather forecast)

    Gender

    Country

    City

    profile picture or avatar

    type and name of boat

    Until the termination of the user account, or until necessary by law, in compliance with regulations pertaining to data storage, or in the absence of such regulations, 5 years.

  3. The abovementioned “technical data” are data automatically generated and logged in our systems when the user’s computer/device logs into our system (such as IP address, session ID). Please note that due to the nature of the Internet, the data that is automatically recorded is automatically logged by our system without your particular consent or action – just by using the Internet - and that the Internet cannot work without these automatic server-client communications. This data may not be linked to the user’s other personal information, except in cases required by law. Only our Company, as the data controller, has access to this data.

  4. We would like to inform you that our Company does not use any personal information for business purposes (eg newsletter, direct marketing, profiling) and does not transfer data to third party recipients except for any data processors and/or Third Party Service Providers engaged by our Company.

  5. Please also note that we are entitled, by law, to use the data processed in connection with the use of our Platform for statistical purposes. The use of the data in a statistically aggregated form does not include the name of the user concerned or any other identifiable information in any form.

MEANS OF DATA MANAGEMENT

  1. Our Company only handles personal information of its Users for the purposes prescribed by this Privacy Policy, to the extent and in a manner necessary for their implementation, with an appropriate legal ground. We shall inform you of any processing that is not described in this Privacy Policy – and ask for your explicit consent - at the time of the data collection.

  2. Apart from some technical information (such as your email address), we do not verify the personal information you provide on our Platform. The person providing this personal information is solely responsible for the accuracy of the information provided. By registering an email address, the User shall be responsible for ensuring that only the User uses our service from the e-mail address provided. As a result, all responsibility for logging in to a given email address rests solely with the User who registered that email address.

  3. Only employees with an employment relationship or other legal relationship with the Company, as well as data processors or Third Party Service Providers engaged by the Company who may qualify as independent data controllers are entitled to access personal data.

  4. We kindly inform our Users that courts and other public authorities, in particular the National Data Protection and Freedom of Information Authority, or other bodies authorized by law may contact our Company to provide information, to communicate, to transfer or access documents. The Company shall provide the authorities with personal information only to the extent and to the extent strictly necessary to achieve the purpose of the request, provided that the authority has indicated the exact purpose and scope of the data required.

DATA SECURITY

  1. The Company applies IT tools used for handling personal information on our systems in such a way that the data managed:

    1. is accessible to those entitled to it (availability);

    2. is authentic and its authentication is ensured (authenticity of data management);

    3. its immutability can be justified (data integrity);

    4. is protected against unauthorized access (data confidentiality).

  2. The Company shall protect the data by appropriate measures, in particular against unauthorized access, alteration, transmission, disclosure, deletion or destruction, as well as against accidental destruction, damage and inaccessibility due to changes in the technology used.

  3. In order to protect the electronically managed data files in our records, we ensure with appropriate technical solutions that the stored data, unless permitted by law, cannot be directly linked and assigned to the data subject.

  4. Taking into account the current state of the art technology, the Company shall ensure the security of data handling with appropriate technical, management and organizational measures that provide a level of protection appropriate to the risks associated with data management.

  5. During our handling of personal information, we ensure the following:

    1. confidentiality: protects information so that only those who have access to it can access the information;

    2. integrity: protects the accuracy and completeness of the information and the method of processing;

    3. availability: ensures that when an authorized user needs it, they can actually access the information they need and have the tools to do so.

  6. The Company’s - and where possible our partners’ – IT-systems and networks are protected against computer-assisted fraud, espionage, sabotage, vandalism, fire and flood, as well as against computer viruses, computer intrusions and other attacks.

  7. The Company makes regular and ad hoc backups of the Platform - its database - and its entire content.

  8. During the automated processing of personal information, the Company also ensures the following:

    1. to prevent unauthorized data entry;

    2. to prevent the use of automatic data-processing systems by unauthorized persons using data communication equipment;

    3. to verify and trace the bodies to which personal data have been or may be transmitted using data communication equipment;

    4. to control and trace which personal data have been input into automated data-processing systems, when and by whom;

    5. the resilience of installed systems in the event of a breakdown; and

    6. that errors in automated processing be reported.

  9. We take into account the current state of the art technology when we define and apply data security measures. From several possible data management solutions, we try to choose the one that provides a higher level of protection of personal information, unless it would be a disproportionate burden on out Company.

  10. We take measures to protect the security of our data handling by technical, management and organizational measures that provide a level of protection appropriate to the risks associated with our data handling.

  11. Please note that electronic messages transmitted over the Internet, regardless of protocol (e-mail, web, ftp, etc.), are vulnerable to network threats that can lead to unfair activity or the disclosure or modification of information. We take every precaution we can to protect ourselves from such threats. We monitor the systems to record any security incidents and provide evidence of any security incidents. System monitoring also enables us to check the effectiveness of the precautions taken. However, as our Users are aware, the Internet is not known to be 100% secure. The Company shall not be liable for any damages arising from unpredictable attacks that occur despite the utmost care.

DATA TRANSFER

  1. The Operator does not transfer data to any third party recipient, except for the abovementioned data processors or Third Party Service Providers engaged by the Company.

  2. The Company, as the data controller, is entitled and obliged to transfer all personal information at its disposal and duly stored by it to the competent authorities, obliged by law or a final decision. The Data Controller cannot be held liable for such transfer of data and the consequences thereof.

  3. If you find any link to an external page on the Platform (External Link), after clicking on the External Link and leaving our Platform, the Company shall not be liable for any data handling performed on an external website outside the Platform. The Company does not transfer personal data to the website on the External Link, save for a data processor or a Third Party Service Provider engaged by the Company. To learn more information about the data handling performed by the service provisers of these External Link, please read their privacy policy posted on their own website.

  4. The Company shall transfer the data not indicated above only with the prior and informed consent of the User.

COOKIE POLICY

  1. The Company uses cookies and other, similar technology (collectively: Cookies) to distinguish our Users on the Platform. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

  2. A cookie is a package of information (file) of variable content, letters and numbers, sent by a web server, which is recorded on the User's browser or on the computer's hard drive and stored for a predetermined period of validity. Cookies allow us to retrieve certain data of our Users and Visitors and monitor their use of the Internet. Cookies help to track the interests, internet usage habits and website visit history of the User and the Visitor in order to optimize the User's and the Visitor’s experience. Because Cookies act as a kind of tag that allows the Platform to recognize the User returning to the site and their browser can also store a valid username and password on that site. If the User's browser returns a previously saved Cookie, we have the opportunity to link the current visit of the User concerned with the previous ones, but only with regard to its own content. The information sent by Cookies makes it easier for Internet browsers to recognize, so that Users receive relevant and “personalized” content. Cookies make browsing more convenient, including online data security needs and relevant / targeted advertising. With the help of Cookies, the Company can also create anonymous statistics about the habits of page visitors, so we can further personalize the look and content of the page.

  3. When the User first visits and registers on the Platform, the User will see a call to cookies at the bottom of the page. Clicking the 'I accept cookies' button will install Cookies that record your preferences for Cookies. If you do not agree with the provisions of our cookie policy, please do not use our Platform.

  4. We use the following types of Cookies on the Platform:

    1. Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.

    2. Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

    3. Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

    4. Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

  5. You can find more information about each of the Cookies used by our Company, their purposes and expiration date in the table below:

  6. Cookie name

    Purpose

    Source

    Validity

    laravel_cookie_consent

    Recording user consent data.

    Laravel

    Until deleted by the User.

    User identification.

    Laravel

    Until deleted by the User.

    XSRF_TOKEN

    Anti-fraud.

    Laravel

    minutes

  7. Please note that we may allow third party service providers to place Cookies on our Users' devices. The Company is not responsible for the Cookies used by the third party service providers. More information about the Cookie policies of these third party service providers we use is available here:

  8. Purpose of Cookie

    Third Party and their Cookie policy

    Measuring Platform Utilization

    Google Analytics

    Notices and newsletter management

    MailChimp

    Weather forecast

    OpenWeatherMap

  9. The User may use the browser program to set or disable certain cookies or all cookies. Cookies can usually be managed in the browsers' Tools / Settings menu under Privacy / History / Custom Settings under the name cookie or trace.

  10. Please note that if you choose to disable all cookies through your browser - including strictly necessary cookies - you may not be able to access the Platform or certain parts of it.

THE RIGHTS OF DATA SUBJECTS (USERS)

  1. The Data Controller receives questions, requests and complaints related to our cookie management at the email address[email protected].

  2. Your query per email will only be considered authentic, if you send it to us via the email address you registered on our Platform, unless you credibly identify yourself in another way. We will process your query within maximum one month from the submission.

  3. The User may request information on the handling of the User’s own personal information, as well as request the correction of the User’s personal data, or – except for mandatory data processing – request to delete, revoke their consent, exercise their right to data portability and objection.

  4. Changes in personal data or requests for deletion of personal data should be submitted to us via the User’s registered e-mail address. The data subject may request the correction of inaccurate personal information and to complete incomplete personal information. If the personal information in our system is incorrect and the correct data is available to our Company, we will correct the personal data. Otherwise, you may change your personal information on your User’s Account.

  5. As the User, you are entitled to receive information from the data controller as to whether the processing of your personal information is in progress. If such data processing is in progress, you are entitled to access personal data as well as the following information: the purposes of data processing; the categories of personal data concerned; the recipients or categories of recipients to whom the personal data have been or will be communicated, including in particular third country recipients or international organizations; the intended duration of the storage of personal data; the right to rectify, erase or restrict data processing and to protest; the right to lodge a complaint with the supervisory authority; information on data sources; whether the Company uses automated decision-making, including profiling, and comprehensible information on the logic used and the significance of such data management and the expected consequences for the data subject. In the case of transfers of personal data to a third country or to an international organization, the data subject shall be entitled to be informed of the appropriate guarantees regarding the transfer.

  6. The Company shall make a copy of the personal information processed by the Company on the data subject concerned. Additional copies requested by the data subject may be subject to a reasonable fee based on our administrative costs. At the request of the data subject, the information will be provided in electronic form.

  7. As the data subject, you shall have the right to have your personal information deleted without undue delay upon your request for one of the following reasons:

    1. your personal data are no longer required for the purpose for which they were collected or otherwise processed;

    2. you withdraw your consent on which the processing is based and there is no other legal ground for the processing;

    3. you object to the processing and there is no overriding legitimate reason for the processing;

    4. your personal information was processed unlawfully;

    5. your personal data must be deleted in order to fulfill a legal obligation under EU law or domestic law applicable to the controller;

    6. your personal information was collected in connection with the provision of information society services.

  8. Please note that once the request for deletion or modification of personal data has been fulfilled, the previous (deleted) data can no longer be recovered. Please note that the deletion of data may not be initiated if the data processing is necessary for one of the following reasons: fulfillment of the obligation under EU or domestic law applicable to the data controller, or to submit, enforce or protect the Company’s legal claims so require.

  9. At the request of the data subject, we restrict the data processing if one of the following conditions is met:

    1. the data subject disputes the accuracy of the personal data, in which case the restriction shall apply for a period which allows the accuracy of the personal data to be verified;

    2. the processing is unlawful and the data subject opposes the deletion of the data and instead requests that their use be restricted;

    3. the Company no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;

    4. the data subject has objected to the processing; in this case, the restriction shall apply for the period until it is determined whether the legitimate reasons of the Company take precedence over the legitimate reasons of the data subject.

  10. If the processing is subject to a restriction, personal data may be processed, with the exception of storage, only with the consent of the data subject or for the purpose of making, enforcing or protecting legal claims or protecting the rights of another natural or legal person. The Company shall inform the data subject in advance of the lifting of processing restriction.

  11. As the data subject, you have the right to request and receive all your personal information provided to us, in a structured, widely used, machine-readable format and to transmit this data to another data controller (data portability).

  12. As the data subject, you shall have the right to object at any time, on grounds related to your particular situation, to the processing of your personal data, including profiling. If and when the User objects, personal data may no longer be processed unless justified by compelling legitimate reasons of the Company which take precedence over the interests, rights and freedoms of the data subject or which relate to the submission, enforcement or protection of legal claims. Where personal data are processed for the purposes of direct marketing, as the data subject, you shall have the right to object at any time to the processing of personal data concerning you for that purpose, including profiling, in so far as it relates to direct marketing. If and when the User objects to the processing of personal data for direct marketing purposes, the data in question may not be processed for this purpose.

  13. As the data subject, you have the right not to be subject to a decision based solely on automated data processing, including profiling, which would produce legal effects concerning you or you would be significantly affected. This does not apply if the decision is:

    1. necessary for the conclusion or performance of the contract between the data subject and the controller;

    2. authorised by EU law or domestic law applicable to the controller, which also lays down appropriate measures to protect the rights and freedoms and legitimate interests of the data subject;

    3. based on the express consent of the data subject.

  14. As the data subject, you have the right to withdraw your consent at any time. Withdrawal of consent shall not affect the lawfulness of the data processing prior to withdrawal.

  15. The Company shall, without undue delay, but in any case within one month of receipt of the request, inform the data subject of the action taken on the request. If necessary, taking into account the complexity of the application and the number of applications, this time limit may be extended by a further two months. The person concerned shall be informed of the extension of the time limit, stating the reasons for the delay, within one month of receipt of the request. If the data subject has submitted the request electronically, the information shall be provided electronically, unless the data subject requests otherwise. If the Company fails to start processing the data subject's request, it shall inform the data subject without delay, but no later than one month from the receipt of the request, and shall inform them of the reasons and of the possibility of complaint to a supervisory authority.

  16. The Company shall provide the requested information and information free of charge. If the data subject's request is clearly unfounded or, in particular due to its repetitive nature, excessive, the Company may charge a reasonable fee or refuse to act on the request, taking into account the administrative costs of providing the requested information or the requested action to be taken.

  17. We will inform all recipients to whom the personal information have been communicated, of any rectification, erasure or restriction on the processing of data, unless this proves impossible or requires a disproportionate effort. At the explicit request of the data subject, the Company shall inform these recipients.

  18. Any person who has suffered damage as a result of a breach of data protection provisions is entitled to compensation for the damage suffered from the Company as the data controller. The data processor shall be liable for damages caused by the data processing only if it has not complied with the obligations specified in the law, which are specifically imposed on the data processors, or if it has disregarded or acted contrary to the data controller's lawful instructions. Where several controllers or processors or both controllers and processors are involved in the same processing and are liable for damages caused by the processing, each controller or processor shall be jointly and severally liable for the total damage. The Company, as the data controller, is released from liability if it proves that it is not liable in any way for the event that caused the damage.

DISPUTE SETTLEMENT

  1. In the event of a breach of their rights, the data subject may, as a general rule, apply to the court of the Company’s registered seat against the data controller.

  2. Complaints can be lodged with the National Data Protection and Freedom of Information Authority:

  3. National Data Protection and Freedom of Information Authority
    H-1125 Budapest, Szilágyi Erzsébet fasor 22/C.

    Mailing address: PO BOX 5, 1530 Budapest, Hungary
    Phone: 06-1-391-1400 Fax: 06-1-391-1410
    E-mail: [email protected]
    Website: http://www.naih.hu

  4. If you have any questions or comments, please contact us at the following contact details: [email protected]

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