The operator of www.somosmedia.hu and somosmedia.co hereby informs visitors of the Website about its practices for processing personal data, the organisational and technical measures taken to protect that data, and visitors' related rights and how to exercise them.
The data controller is Somos Media Bt. (hereinafter: Operator) (company registration number: 03-06-102991; registered office and place of business: 6000 Kecskemét, Klapka utca 19. 2/2, Hungary).
Whenever the Operator asks a visitor of the Website (hereinafter: User) for personal data for any purpose, the following provisions apply.
This Privacy Policy contains the basic information on the processing, handling and recording of personal data that the User may provide while using the Operator's Website. If you have any questions about how your data is processed, please contact us before using the Website.
This Privacy Policy may be amended at any time; the User should check the Website from time to time to stay informed of any changes. This Privacy Policy entered into force on 1 January 2019. The Operator is responsible for processing the personal data provided on the Website.
Data requests and cookies
In general, the User does not need to provide any data to use the Website. However, certain services may require the User to provide specific personal data to the Operator.
Depending on the service, the Operator may need the following personal data:
- information about personal and professional interests;
- demographic data;
- cookies may store information about the parameters of the device used for browsing, its browser, your settings and previous visits, so that we can offer you a better user experience.
In addition, the Website may place cookies on the User's device if you expressly approve this when you first visit the Website. These cookies are stored on the User's own device, not with the Operator, so the User remains in full control of them.
Session recording
To improve the user experience and develop the Website, we use session recording technology. It anonymously records the visitor's interactions on the Website, such as mouse movements, clicks, scrolling and the pages visited, so that we can analyse user behaviour by replaying it and identify usability problems.
Recording is anonymised and cannot be used to identify the visitor. Sensitive data typed into input fields (e.g. name, email address, message, password) is automatically masked; we do not record or replay it. Session recording is activated only with the User's explicit consent (acceptance of the cookie notice).
The legal basis for this processing is the User's voluntary consent (GDPR Article 6(1)(a)). You can withdraw your consent at any time by changing your browser's cookie settings or by writing to info@somosmedia.hu. Withdrawal does not affect the lawfulness of processing carried out before it.
Business outreach (B2B)
From time to time we contact businesses by email that may benefit from our services (websites, SEO, AI automation). For this we only use publicly available business contact details: the name, address, website, phone number and general company email address published on the business's own website or its Google Maps (Google Business Profile) listing. We do not send outreach to private individuals' personal email addresses.
The purpose of this processing is to establish a business relationship with the company and to keep a record of the correspondence; the legal basis is the Operator's legitimate interest (GDPR Article 6(1)(f)). We send a business no more than four emails; if there is no reply, we close the outreach. We keep the data for 12 months after closing so that we do not contact the same business again, then delete it.
You can object to this outreach at any time without giving a reason: via the unsubscribe link at the bottom of every email, by replying to the email, or at info@somosmedia.hu. After an objection we send no further emails, and we keep the email address only to the extent needed to avoid contacting you again (suppression list).
1. Data processed
When the Website is viewed, cookies placed on the User's device may automatically record the start and end time of the visit, the IP address and, in some cases depending on the User's computer settings, the browser and operating system type and language, device parameters, settings made on the Website, the pages visited and the time spent on them. The Operator does not and cannot link this data to personal data; you decide whether to share it through the explicit authorisation you give us and through your browser's cookie settings.
Other data provided for using the Website is also processed on the basis of the User's voluntary consent.
The Operator asks persons under 16 not to enter into legal transactions (purchases or any other transaction) without the permission of a parent or legal guardian, as defined by applicable local law.
2. Purpose of processing
Processing serves continuous contact between registered Users of the Website's services and the Operator, the improvement of the user experience, and opinion research. Through cookies, the system automatically generates statistics on the length of visits and the pages visited, so that the Operator can further develop and optimise the Website's services and tailor them to Users' needs.
The Operator uses and processes other data provided by the User solely to provide a higher level of service, in particular:
- to answer questions asked on the Website;
- to send our newsletters;
- for internal record-keeping;
- to develop the Website's content;
- to inform about updates to the Website;
- to personalise the Website's content;
- to deliver publications the User orders on our website.
The Operator may contact the User by email, phone, fax or post, unless the User has indicated a preference. The Operator does not use personal data for purposes other than those stated. Such data is processed on the basis of the User's voluntary consent.
The Operator treats all data and facts relating to Users confidentially and uses them only to develop its services and for its own statistics. Reports based on them are published only in a form that does not allow individual Users to be identified.
The Operator does not transfer, publish, sell, rent or make your personal data available to third parties without your consent, unless this is necessary for the purposes set out in this Privacy Policy or required by law.
3. Duration of processing
Session IDs are deleted automatically when the User leaves the Website. Other cookies help the Operator remember the User's previous settings, the data and information provided and other characteristics of Website use. Their expiry varies, but they typically remain on the User's device until the User deletes them.
The Operator classifies the content of messages sent to it at its own discretion. If it considers the content necessary to protect or enforce the legitimate interests of the Operator or a third party, it stores the message for 5 years. Otherwise the message is deleted within 30 days of receipt.
4. Who has access to the data, data processors
The personal data provided by Users can be accessed by the Operator's staff. Apart from those indicated, the Operator does not pass personal data to third parties. This does not apply to any mandatory data transfers required by law, which may occur only in exceptional cases. Before fulfilling any request from an authority, the Operator examines for each item of data whether there is a legal basis for the transfer.
5. Users' rights, deletion of data
The legal basis for processing is the Users' voluntary consent. Users may request information about the processing of their personal data. On request, the Operator informs the data subject about the data it processes, the purpose, legal basis and duration of processing, its processing activities, and who has received or receives the data and for what purpose.
Information can be requested at the Operator's postal address (6000 Kecskemét, Klapka utca 19. 2/2, Hungary) or at info@somosmedia.hu. The User can also request the correction or deletion of their personal data through these contacts.
If the Website's services are used improperly, or at the User's own request, we delete the related data. Deletion takes place within 24 hours after the working day following the deletion request.
The Operator places great emphasis on the security of personal data. To prevent unauthorised access, we apply appropriate physical and electronic procedures to protect data received online.
6. Data subjects' rights
Data subjects may at any time request written information from the Controller about how their personal data is processed, request deletion or correction, and withdraw consent previously given.
Right to information: at the data subject's request, the Controller provides the information listed in Articles 13 and 14 of the GDPR and the notices under Articles 15–22 and 34 in a concise, easily understandable form.
Right of access: at the data subject's request, the Controller confirms whether data relating to them is being processed and, if so, provides access to the data, the purpose, legal basis and duration of processing, and information on the data subject's rights.
Right to rectification: the data subject may request the correction of inaccurate data about them held by the Controller.
Right to erasure: at the data subject's request, the Controller deletes the data relating to them within 5 working days if the processing is unlawful or unnecessary, or consent has been withdrawn and there is no other legal basis for processing.
Right to restriction of processing: the data subject may request restriction of processing if they contest the accuracy of the data, if processing is unlawful but they request restriction instead of deletion, or if the data is no longer needed but must be kept for legal claims.
Right to withdraw consent: the data subject may withdraw consent given to the Controller at any time, in writing. Withdrawal does not affect the lawfulness of processing before it.
Right to data portability: the data subject may request that their data be transferred to another controller in a commonly used, machine-readable format.
7. Remedies
Data subjects may lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH), or with the data protection authority of their own EU country of residence:
- Address: 1055 Budapest, Falk Miksa utca 9-11, Hungary
- Postal address: 1363 Budapest, Pf.: 9, Hungary
- Phone: +36 (1) 391-1400
- Email: ugyfelszolgalat@naih.hu
- Website: naih.hu
If their rights are infringed, data subjects may also go to court. The case falls within the jurisdiction of the regional court (törvényszék) and, at the data subject's choice, may be brought before the court of their place of residence or stay.
Contact
Data controller: Somos Media Bt.
Registered office / place of business: 6000 Kecskemét, Klapka utca 19. 2/2, Hungary
Email: info@somosmedia.hu
Phone: +36 30 845 5044