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:
- 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.
- 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.
- Data36.com is hosted on a DigitalOcean server that’s located in Frankfurt, Germany.
- I use two 3rd party analytics tools on data36.com: Google Analytics and Hotjar. (More info about them is available here.) Both show aggregate data, meaning I don’t see your personal data. In Google Analytics your IP address is anonymized, too. I also use cookies for these tools. (You can block the cookie usage via your browser.)
- I use Mailerlite for email marketing. MailerLite uses Google data storage center with its location in the European Union. Subscribing to my Newsletter list is 100% optional. If you subscribe, you have to accept the detailed privacy policy below. In short, you accept that I send emails to the email address you provided on a regular basis, usually weekly, and I promise that I use your email address only for sending you these emails. Most importantly, I don’t give out or sell your email address (or any other personal information) to any third party. Also, I do not upload it to Facebook (or similar services) for remarketing. When you subscribe, I ask your “Nickname,” too. I’m not looking to find out your full name; I just want to know how I should address you when I start my newsletter with “Hi XY!”
- I do not use remarketing pixels on data36.com. No Facebook remarketing, no Google remarketing, no Twitter remarketing, nothing.
- If you register for one of my workshops (SQL, Python, CRO) via the contact form, I ask for 3 information that are considered “personal data:” your full name, your e-mail address and (optionally) your phone number. This information is emailed to me (via Gmail) and not stored anywhere else but in my email account (Gmail) and in an Excel Spreadsheet. I use it only to communicate with you regarding the workshop you signed up for. (e.g. It isn’t considered a subscription to my weekly newsletters.)
- I occasionally do A/B tests, using Google Optimize.
- I use Google captcha and re-captcha against bots.
- I use my own analytics tool (the Data36 analytics system), as well. It works like Google Analytics, except that its 100% anonymized and it’s 100% on my own servers (so it’s not shared with Google, Facebook, or any other vendors…)
- We use Paddle as our Merchant of Record. For that reason, you might see their payment form on our website.
- 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 data36.com‘s visitors.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of 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 We may process data about your use of our website and services (“usage data“). The usage data may include your approximate geographical location (city level), browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics (analytics.google.com), Hotjar (hotjar.com) and Data36’s own analytics system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services. While you are browsing our website, we do not collect personal data – so we don’t know your name, address, IP address, email address, etc.
3.2.2 Addition about Hotjar: We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.
3.2.3 Addition about Data36’s own analytics system:
It places 1st party a cookie in your browser — which is not shared with Facebook, Google or any 3rd party tools thus it’s more secure from the perspective of your privacy than any other analytics tool. The cookie is called ‘d36ct‘ and you can delete it any time by removing your cookies (or this individual cookie) — and you can block the creation of it with any JavaScript blocker.
When you browse the website, the Data36 analytics system sends this data about your browsing history to a private server (hosted on DigitalOcean, accessible only by the owner of Data36 — Tamas Mester): d36ct cookie ID, the linking page (if there is any), the currently visited page, your screen resolution.
Your privacy is 100% respected, your data is anonymized. I don’t see or use your name, address, gender or any sensitive information that I could use to identify you.
3.2.4. 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.
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.
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 (Mailerlite) is a Google data storage center with its location in the European Union. By subscribing to our mailing lists you acknowledge that the information you provide will be transferred to Mailerlite 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 will be processed by Paddle — in accordance with their Privacy Policy and Terms.
5.3.4. The hosting facilities for our marketing software (Deadline Funnel) is located in the United States. By subscribing to our mailing lists you acknowledge that the information you provide will be transferred to Deadline Funnel for processing 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.
6. Retaining and deleting personal data
6.1 This Section 6 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.
6.2 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.
6.3 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 unsubscribe.
(b) Your name/nickname will be retained for a minimum period of 1 minute following your e-mail subscription, and maximum until you unsubscribe.
(c) Your phone number will be retained for a minimum period of 1 minute following your application to the workshop, and maximum 2 months.
6.4 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.
6.5 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. Amendments
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of significant changes to this policy by email or through the private messaging system on our website.
8. Your rights
8.1 In this Section 8, 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.
8.2 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.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by visiting the URL of any Newsletter email we send to you.
8.4 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.
8.5 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.
8.6 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.
8.7 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.
8.8 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.
8.9 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.
8.10 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.
8.11 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.
8.12 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.
8.13 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. About cookies
9.1 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.
9.2 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.
9.3 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. Cookies that we use
10.1 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) analysis – we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose are:
- _hjIncludedInSample for Hotjar,
- _gid, _ga and _gat_UA-63850749-1 for Google Analytics,
- _fbp for tracking Facebook/Meta paid campaigns
- df-: to generate personalized offers using DeadlineFunnel.com
- __unam and __stid for the ShareThis plugin.
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.
11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are: _gid, _gat_UA-63850749-1 and _ga.
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
