DATA PROTECTION AND DATA MANAGEMENT POLICY

1. Purpose of Data Protection and Data Management Policy

The purpose of this Policy is to record Loxtrade Ltd’s (registered office: 1077 Budapest, Wesselényi utca 13, 1st floor, registration number: 01-09-933554, registration authority: Budapest City Court as Registry Court, tax number: 13128890-2-42 ) data protection and data management policy.

Loxtrade Ltd. (hereinafter referred to as "Service Provider") manages the data of the visitors and the registrants (collectively, the Affected Person) on the website www.vizdom.eu (hereinafter referred to as the "Website").

Loxtrade Ltd. is obliged to acknowledge the content of this legal notice. It commits to ensure that all data management related to business complies with the requirements of this policy, the applicable national legislation and the legal acts of the European Union.
Loxtrade Ltd. is committed to protect the privacy of its clients' self-determination of information by protecting the privacy of its customers and partners. Loxtrade Ltd. treats personal information confidentially and will take all security, technical and organizational measures that guarantee the security of the data.

2. The data controller
name: Loxtrade Kft.
data protection registration number: NAIH-146467/2018
seat and mailing address: 1077 Budapest- Hungary, 13 1/3. Wesselényi str.
telephone number: +36 1 699 9110

email address: info@vizdom.eu
website: www.vizdom.eu

3. Legal Basis, Purpose, and Method of Data Management

3.1. The web content included on www.vizdom.eu website (hereinafter referred to as "the Website") is based on the Relevant Disclosure Statement of the Affected Person, which includes the expressed consent of the Affected Person to use their personal data provided during use of the Website. The legal basis for data
management is the CXII 2011 Law on Information Self-determination and Freedom of Information. TV. Section 5 (1) (a), on the basis of the voluntary contribution of the person concerned, and in accordance with Section CVIII of 2001 on certain aspects of electronic commerce services and information society services.

3.2. Cookies

During visits to the Website one or more cookies – a small files containing a string of characters – will be sent to the visitor's computer, which will allow its browser to be uniquely identified.

Applied cookies:
- session cookie: session cookies will be automatically deleted after the visiting of the Affected Person. These cookies are designed to make the Service Provider's website more efficient and secure, so it is essential that some features of the Website or some applications work properly.
- permanent cookie: a permanent cookie is also used by the Service Provider for a better user experience (eg providing optimized navigation). These cookies are stored for a longer period in the browser cookie file. The duration depends on the settings applied by your web browser.

The "Help" feature in most browser's menubar provides information on how to disable cookies in your browser, how to accept new cookies, or how instruct your browser to set a new cookie or how to turn off other cookies.

3.3. You agree to the use of the Website for any particular data management by signing up for training or subscribing to a newsletter voluntarily. In connection with the use of this option, the subscriber will hand over the following personal information to the Service Provider in the form of voluntary data supply:

- name
- company name
- email address
- telephone number

3.4. The purpose of the data management is that the Service Provider can get in touch with the contact via email, newsletter or telephone, inform the partners about its products and delivery, and arrange the dates and details of the training sessions.


3.5. The Service Provider shall not use the personal data for purposes other than those set out in these points. Issuance of personal data to a third party or authorities may, unless expressly provided for by law, be subject to prior consent by the Participant. The Service Provider protects the data with appropriate measures against unauthorized access, alteration, transmission, disclosure, deletion or destruction and against accidental destruction.

3.6. The Service Provider during the data handling retains
- secrecy: it protects the information so that it can only access the person who is entitled to it
- integrity: it protects the accuracy of the information and the method of processing
- availability: ensures that if the user needs it they  can actually access the information they need and they can have access to the related tools

3.7The Service Provider does not check any Personal Information the user have entered. The correctness of the data given is solely the responsibility of the person giving it. When you give your email addresses, you agree to be solely responsible for the service provided by the specified email address. With respect to this responsibility, any liability associated with an entry in a given email address shall be borne exclusively by the Person who has registered the email address.


4. Duration of data management


4.1. The personal data provided during the subscription will begin with registration and will be canceled on request. In case of non-mandatory data, data processing will last from the date of the data entry to the deletion of the data in question. The cancellation of the registration by the User and the cancellation by the Service Provider at the request may take place at any time. The Affiliate has to have the opportunity to unsubscribe from the newsletter.


4.2. The above provisions do not affect the fulfillment of the retention obligations laid down in the law (eg accounting law) and the processing of data based on any other additional contributions.

4.3. In case of newsletter, personal data will be processed until you unsubscribe from the newsletter or delete the relevant data (see point 7.5).

5. Data transmission, data processing, data collections

5.1. Data is known primarily the Service Provider and Service Provider's
internal staff, but they are not disclosed to third parties.

5.2. During trainings, execution of orders, billing and accounting, the Service Provider may use the following data processors:

ACCOUNTING
Gold Medal Kft.
1061 Budapest, Andrássy út 46.

COURIER SERVICES
Hajtás Pajtás Kerékpáros Futárszolgálat
1074 Budapest, Vörösmarty u. 20.

COURIER SERVICES
Magyar Posta Zrt.
1138 Budapest, Dunavirág utca 2-6.

COURIER SERVICES
UPS Magyarország Kft.
2020 Vecsés, Lőrinci u. 154.
Airport City Logistic Park G. épület

OPERATOR OF ELECTRONIC ACCOUNTING SYSTEM
Dupplak Kft.
3327 Novaj, Bajcsy-Zsilinszky E. u. 2/a

OPERATOR OF MAILING SYSTEM
Eworx Network & Internet GmbH
A-4150 Rohrbach-Berg, Hanriederstraße 25, Austria

REGISTRATION OF TRAININGS
Acuity Scheduling, Inc.
450 W 17th Street
New York, NY 10011

REGISTRATION OF ONLINE TRAININGS
Genesis Digital LLC
7660 Fay Ave #H184, La Jolla, CA 92037

6. Affected Persons’ rights and possibilities of enforcement

6.1. At any time you may request information about the handling of your personal data by the Service Provider and you may request correction, revocation, exercise and discretion of your personal data, except for mandatory data, from the Service Provider via contact details listed in point 2.

The deletion does not apply to data processing required by law (eg accounting rules), which the Service Provider maintains for the required period of time.

If the Service Provider fails to comply with the relevant correction, lockout or cancellation, it will give written and factual reasons for refusal of the request for rectification, blocking or cancellation within 30 days of receipt of the request.

You may object to handling your personal information. The Service Provider shall examine the protest within the shortest possible time but not later than 15 days from the submission of the request, and shall make a decision on its validity and shall inform the applicant in writing.

6.2. The Service Provider shall provide information about the data it manages, the data it processes, the source, the purpose, the legal basis, the duration of the data handling, the activity related to data management, the circumstances, effects and measures taken to remedy the data incident.

6.3. The Service Provider's data management principles are in line with current data protection legislation, in particular:
- 2011 CXII. Act on Information Self-Destruction and Freedom of Information
- Regulation (EU) No 2016/679 of the European Parliament and
of the Council of 27 April 2016 on the protection of individuals with regard to
the processing of personal data and on the free movement of such data and
repealing Regulation (EC) No 95/46 / general data protection regulation, GDPR)
- Act V of 2013 - Civil Code (Civil Code); Act C of 2000 on Accounting
(Accounting);
- 2013 CCXXXVII. Act on Credit Institutions and Financial Enterprises

7. Newsletter

7.1. The Service Provider shall pay particular attention to the legality of the use of the e-mail addresses it manages and so use it only as specified below (information or advertisement) to send an email.

7.2. E-mail addresses are primarily used to identify the Customer, to execute orders, to access the services and to communicate and provide information, so this is primarily done to send an email.

7.3. In some cases, the Service Provider provides information about the changes in products or services or changes regarding General Terms and Conditions in electronic form via e-mail to the Affiliates. Such notifications, however, are not used by the Service Provider for advertising purposes.

7.4.  Letters of advertising or newsletters sent to the e-mail addresses specified in the subscription will be sent by the Service Provider only with the expressed consent of the Affiliate, in the cases and in the manner prescribed by law. The newsletter contains direct marketing elements and promotional items. The Service Provider handles the information provided by the Affected Person during the use of the newsletter.

7.5. In case of a newsletter, the Service Provider will handle the information provided by Affected Person until the Relevant has subscribed to the newsletter by clicking on the "Unsubscribe" button at the bottom of the newsletter or requesting it to be removed from the subscribers list by email or by post. In the event of unsubscribe, the Service Provider will not contact the Affiliate with any further newsletters or offers. You can unsubscribe at any time from the newsletter and revoke your consent.

8. Other provisions

8.1. The Service Provider reserves the right to unilaterally modify these Terms and Conditions without prior notice to the Website of the Affected. Upon the entry into force of the amendment, the User shall accept the changes to continue to use the
Website, in the manner provided by the Service Provider as provided on the
Website.

8.2. The Service Provider provides the authorities, if the authority indicates the exact purpose and the scope of the data, only to the extent and to the extent that it is indispensable to achieve the purpose of the request.