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Privacy policy

Thank you for visiting our website, which has been developed for DOSS, an EU-funded Horizon Europe project in the call topic “HORIZON-CL3-2022-CS-01 – Trustworthy methodologies, tools and data security “by design” for dynamic testing of potentially vulnerable, insecure hardware and software components”, GAP: 101120270; comprising of 12 partners across industry, academia and the research fora. For more information on all partners please visit our ‘Partners’ section.

SafePay Systems Ltd is responsible for the hosting and management of the website of DOSS.

This privacy policy applies between you, the User of the Website and SafePay Systems Ltd, the owner and provider of the Website. SafePay Systems Ltd takes the privacy of your information very seriously. This Privacy Policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

 

Please read this privacy policy carefully.

Definitions and interpretation

  1. In this privacy policy, the following definitions are used:
Data collectively all information that you submit to SafePay Systems Ltd via the Website. This definition incorporates, where applicable, the definitions provided in the GDPR ;
Cookies a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);
Data Protection Laws any applicable law relating to the processing of personal Data, including but not limited the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;
GDPR the General Data Protection Regulation (EU) 2016/679;
SafePay Systems Ltd,
we or us
SafePay Systems Ltd, a company with registered office at 27/A Endrodi Sandor Street, Budapest, Hungary; is in charge of communication and dissemination activities for the DOSS project as a data controller;
EU Cookie Law the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;
User or you any third party that accesses the Website.
Website the website that you are currently using, dossproject.eu, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

 

  1. In this privacy policy, unless the context requires a different interpretation:
  • the singular includes the plural and vice versa;
  • references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
  • a reference to a person includes firms, companies, government entities, trusts and partnerships;
  • “including” is understood to mean “including without limitation”;
  • reference to any statutory provision includes any modification or amendment of it;
  • the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

  1. This privacy policy applies only to the actions of SafePay Systems Ltd, the DOSS Consortium partners and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.
  2. For purposes of the applicable Data Protection Laws, SafePay Systems Ltd is the “data controller”. This means that SafePay Systems Ltd determines the purposes for which, and the manner in which, your Data is processed.

Data processors

  1. ISP/Webhosting services:

ININET Internet Ltd.

EU Tax Id: HU23537646

Account number: 10404065-50526648-88711003 (K&H bank)

Address: 1063 Budapest Szinyei Merse street 10.

Registration No.: 01-09-970252

Data storage (place and time)

  1. Data storage place

Your data will be stored both on premises and in cloud, utilising a hybrid approach.

Where data is not stored on local secure company device, it is either stored on Mailchimp’s servers or Ininet servers.

While Mailchimp’s servers are located in the US, where all data is being exported to and stored at, Mailchimp’s Data Processing Addendum has been drafted to meet the requirements of the GDPR in order to enable us to transfer EEA personal data to Mailchimp in the United States, and to permit Mailchimp to lawfully process that data on our behalf. Mailchimp participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework so all data received and exported from EEA member countries is subjected to each Framework’s applicable Principles.

Ininet’s servers are located in Hungary. The servers are SSL encrypted and Ininet takes reasonable steps to protect the data against unauthorized access, alteration, transmission, deletion and destruction; as well as against accidental destruction and damage, and from becoming inaccessible as a result of changes in the technology used.

  1. Data storage time

Data will be held for no longer than the duration of the project. For your rights see “Your rights”.

Data collected

  1. We may collect the following Data, which includes personal Data, from you:
  • name;
  • company;
  • industry;
  • job role;
  • contact information such as email addresses and telephone numbers;
  • demographic information such as postcode, preferences and interests;
  • IP address (automatically collected);
  • web browser type and version (automatically collected);
  • operating system (automatically collected);
  • technical data from analytics providers;
  • cookies that allow third party review or interaction with our website that have been saved on your computer from other websites you have visited;
  • identity and contact data from selected business partners, data brokers or aggregators.
  • we may also collect, use and share aggregated data such as statistical or demographic data for any purpose if you cannot be identified in any way. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
  • we do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences;

in each case, in accordance with this privacy policy.

How we collect Data

  1. We collect Data in the following ways:
  • data is given to us by you;
  • data is received from other sources; and
  • data is collected automatically.

Data that is given to us by you

  1. SafePay System Ltd will collect your Data in a number of ways, for example:
  • when you contact us through the Website, by telephone, post, e-mail or through any other means;
  • when you create an account with us;
  • when you download documents from the website;
  • when you elect to receive marketing communications from us;
  • when you use our services;

in each case, in accordance with this privacy policy.

Data that is collected automatically

  1. To the extent that you access the Website, we will collect your Data automatically, for example:
  • we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
  • we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section ‘Cookies’.

Our use of Data

  1. Legitimate reasons for lawful processing your personal information is the legitime interest of the DOSS consortium to promote the DOSS project outcomes as more specifically described in the Introduction, in order to meet contractual obligations in that context.
  2. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
  • internal record keeping;
  • improvement of our products / services;
  • transmission by email of marketing materials that may be of interest to you;

in each case, in accordance with this privacy policy.

  1. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).
  2. For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft-opt-in:
  • soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.
  • for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide.
  • if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.
  1. We may use your Data to show you adverts and other content on other third-party websites. If you do not want us to use your data to show you adverts and other content on other third-party websites, please turn off the relevant cookies (please refer to the section headed ‘Cookies’).

Who we share Data with

  1. We may share your Data with the following groups of people for the following reasons:
  • our employees, agents and/or professional advisors – to improve site functionality, to obtain advice from professional advisors, to perform analytics on the website;
  • partners of the DOSS Consortium for
  • internal record keeping;
  • improvement of our products / services;
  • transmission by email of marketing materials that may be of interest to you;

in each case, in accordance with this privacy policy.

Keeping Data secure

  1. We will use technical and organisational measures to safeguard your Data, for example:
  • access to your account is controlled by a password and a user name that is unique to you.
  • we store your Data on secure servers.
  1. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address info@dossproject.eu.

Data retention

  1. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.
  2. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

 Your rights

  1. You have the following rights in relation to your Data:
  • Right to be informed: You have the right to be informed about the processing and use of your personal information, including the purpose for which we are processing this information, the period that we will retain it and with whom we will share it.
  • Right of access: You have the right to ask from us to confirm whether or not we are processing personal information concerning you. Where that is the case, you can access your personal information that we are processing and relevant supplementary information.
  • Right to rectification: You have the right to request from us modifications, corrections or update to your personal information in case you believe that it is not up to date, complete or accurate.
  • Right to erasure (“right to be forgotten”): You have the right to ask us to erase your personal information that we are processing, subject to specific restrictions.
  • Right to restrict processing: You have the right to request from us to restrict the processing of your personal information, with a view to limiting the way that we use this information.
  • Right to data portability: You have the right to ask for your personal information to be provided back to you or transferred to a third party.
  • Right to object: You have the right to object to us processing your personal information at any time for reasons related to your particular situation.
  • Right not to be subject to a decision based solely on automated processing (including profiling), which produces legal effects concerning you or similarly significantly affects you.
  1. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: info@dossproject.eu.
  2. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority.
  3. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

 Third-Party Websites

  1. Our website may contain links to or the ability for you to access third-party websites. We are not responsible for the privacy practices employed by those third parties, nor are we responsible for the information or content their websites contain. This Privacy Policy applies solely to information collected by us. We encourage you to read the privacy policies of any third parties before proceeding to use their websites.

Children

  1. We do not knowingly process, use, or disclose information from children under 16. If we learn that we have collected the personal information of a child under 16 we will take steps to delete the information as soon as possible. Please immediately contact us if you become aware that a child under 16 has provided us with personal information.

Cookies

  1. This Website may place and access certain Cookies on your computer. Safepay Systems Ltd uses Cookies to improve your experience of using the Website; to improve our range of services and to disseminate information of legitimate interest.  SafePay Systems Ltd has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
  2. All Cookies used by this Website are used in accordance with current EU Cookie Law.
  3. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling SafePay Systems Ltd to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
  4. This Website may place the following Cookies:
Type of Cookie Purpose
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, use a shopping cart or make use of e-billing services.
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.
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).
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.
  1. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
  2. You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
  3. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

General

  1. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
  2. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
  3. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
  4. This Agreement will be governed by and interpreted according to the law of Hungary. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the Hungarian courts.
    Competent authority:

    National Authority for Data Protection and Freedom of Information

    Address: 1055 Budapest, Falk Miksa street 9-11.

    E-mail: ugyfelszolgalat@naih.hu

    Website: http://www.naih.hu/

    Changes to this privacy policy

  5. SafePay Systems Ltd reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.