Last updated: 2020-07-27
This Policy may change from time to time. Your continued visit or use of the Website or the Services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.
1. DATA CONTROLLER
The Data Controller, who determines the purpose and manner in which your personal data is used, is GBD Consulting and Services Private Limited Company a company incorporated under the laws of Hungary, seated: 12. Határ út, Újlengyel, 2724, Tax number: 27325162-2-13, Company Reg. Number: 13-10-042025 (hereinafter referred to as: “Data Controller”, „Provider”, „Service Provider”, „we”, or „us”).
“ColdCampaigns”: service provided by Provider.
“Data Protection Officer (DPO)” ensures, in an independent manner, that Provider applies the laws protecting individuals’ Personal Data. The designation, position and tasks of a DPO within an organization are described in Articles 37, 38 and 39 of the European Union (EU) General Data Protection Regulation (GDPR)
“GDPR” – Regulation (EU) 2016/679 of The European Parliament and of The Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
“Personal Data” – any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. Personal Data regarding to the Service is data of our Website Visitors, our Users and our Customers, data entrusted to us by our Users and our Customers for processing and processed in relation to the use of the Service.
"Service" or "Services": services available at, or through the Website, including, but not limited to management of emailing campaigns with real-time monitoring of sent email delivery, sending and managing marketing emails and our other covered services.
“Website": coldcampaigns.com and any of its subdomains. Website is operated by Provider.
"Website Visitor ": any individuals or company who visit our website and who may communicate with.
"User": Website Visitor who on behalf of themselves on our website subscribe to receive communications and information from our Website or subscribe to use any of the service offered on the Website.
"Customer": User who on behalf of themselves use paid services offered on the Website.
3. Information we collect about you and why we collect it
Information you provide voluntarily to us:
Information we collect automatically:
The legal basis for processing Usage Data is our legitimate interests (Art. 6 sec. 1 (f) of GDPR), namely:
We may process Data based on our legitimate interest to exercise legal claims. We believe we have a legitimate interest in processing your Data if it’s necessary to exercise claims concerning the use of the Service that’s unlawful or incompatible with the Terms of Service or to defend ourselves against such claims.
If you are our Website Visitor to provide you with our Service, we process the following Personal Data:
If you are our User to provide you with our Service, we process the following Personal Data:
If you are our Customer to provide you with our Service, we process the following Personal Data:
4. How we protect your personal data
In order to avoid unauthorized use of personal data and to avoid misuse of such data, Provider has taken comprehensive technical and operational safety measures. Our safety procedures have regularly been controlled and improved in harmony with technological development, such as:
Please be aware, though, that despite our efforts, no security measures are perfect or impenetrable. We cannot ensure, and do not warrant or guarantee, that the information you transmit to the Provider will remain secure, nor do we guarantee that this information will not be accessed, disclosed, altered, destroyed or used in an unauthorized manner.
If we learn of a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. If you have any questions about the security of your personal information, please contact us as indicated in the ‘Contact Us’ section below.
5. How long we use personal data for
In case we process your Personal Data based on your consent Provider will keep your personal data until you withdraw your consent given to the data processing. Once you withdraw your consent, we will delete your data permanently.
Without withdrawing your consent we will keep your Personal Data for up to 1 year following we stopped providing you with our services.
In case we process your Personal Data based on our legitimate interest, we will terminate the processing and delete your Personal Data as soon as we have no further legitimate interest for the processing.
In most circumstances this means we will not keep your Correspondence Data for more than 10 years after our last conversation and we will not keep your Usage Data for more than 50 months after the end of your relationship with us.
7. Sensitive Data
We ask that you not send us, and you not disclose, on or through the Services or otherwise to us, any Sensitive Personal Data (e.g., any government-issued identification number; credit or debit card details or financial account number, with or without any code or password that would permit access to the account; or information on race, religion, ethnicity, sex life or practices or sexual orientation, medical or health information, genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, or information on any judicial or administrative proceedings).
Use of Services by Minors
The Services are not directed to individuals under the age of eighteen (18), and we request that they not provide Personal Data through the Services.
8. Sharing information with others
In certain situations, Provider may share your personal data with third parties.
Third parties that provide services:
We use service providers to process your personal data on our behalf including, such as:
Company that provide server hosting:
Companies that provide email delivery, help to contact our Users:
Companies that provide information technology and help to operate and improve our Service:
Companies that provide data analysis and advertising solutions:
Specifically, we do not permit these companies to use any personal information we share with them for their own marketing purposes or for any other purpose than in connection with the services they provide to us.
Other Uses and Disclosures:
We will use and disclose Personal Data as we believe to be necessary or appropriate:
We may use and disclose Other Data for any purpose, except where we are not allowed to under applicable law.
9. What are your data protection rights?
Provider would like to make sure you are fully aware of all of your data protection rights. Every Customer is entitled to the following:
The right to express and withdraw your consent - If we ask for consent to process your Data, you can always choose to give it or not. We inform you about the right to withdraw your consent before giving consent. In our Service, we never ask for one consent for different Personal Data processing operations.
Withdrawal of your consent is effective upon execution, and it does not affect the lawfulness of processing based on the consent before you withdraw it. You can always withdraw your consent without detriment. It may, however, render you unable to use some of the features of the Service.
If you no longer wish to receive emails from us, you can use the unsubscribe link at the bottom of any of our communications, or by sending a letter to: GBD Consulting and Services Private Limited Company at 12. Határ út, Újlengyel, 2724 Hungary.
In addition push notification you can delete your information stored with us by unsubscribing from notifications by following the instructions here.
The right to access – You have the right to request Provider for copies of your Personal Data. We may charge you a small fee for this service.
The right to rectification – You have the right to request that Provider correct any information you believe is inaccurate. You also have the right to request Provider to complete the information you believe is incomplete.
The right to erasure – You have the right to request that Provider erase your Personal Data, under certain conditions.
The right to restrict processing – You have the right to request that Provider restrict the processing of your Personal Data, under certain conditions.
The right to object to processing – You have the right to object to Provider’s processing of your Personal Data, under certain conditions.
The right to data portability – You have the right to request that Provider transfer the data that we have collected to another organization, or directly to you, under certain conditions.
The right to apply and right to lodge a complaint with a supervisory authority - You have the right to complain to a supervisory authority concerning the processing of your Personal Data. In Hungary the supervisory authority is The National Authority for Data Protection and Freedom of Information, contact details:
10. How to contact Us
We have designated a Data Protection Officer – dr. Hám Boglárka Barbara (DPO), who you can reach out to about anything related to your Personal Data processing. You can easily contact our DPO: