Data handling regulations

Protecting the personal data made available by registered players, other users and visitors (hereafter: users) to its website and safeguarding their rights of autonomy with regard to information are important priorities for M3W project partners. We are committed to handling personal data in a way which complies fully with applicable legal provisions and contributes to ensuring the secure use of the internet by visitors. We handle  personal data confidentially, in accordance with valid legal provisions, provide for their security, take the technical and organizational measures and establish the procedural rules required to enforce applicable legal provisions and other recommendations.

These regulations specify the principles which define our policy and daily practices relating to the protection of personal data. In it we present our services for which we request personal data from website users, our declaration on how and for what purposes such data are used, as well as how we provide for their security and protection.

If you have questions or problems in connection with the contents of these regulations, or would like to make observations on something that is not clear or requires further explanation, please contact our colleague responsible for the protection of personal data at: dr. Katalin Breuer, breuer@gaudiopolis.hu Hungary 1038 Budapest Mezo str. 12. (Gaudiopolis Evangelical Elderly Home)

Please note this website contains links to other websites which are provided for your convenience. We are only responsible for the privacy practices and security of this site. We recommend that you check the privacy and security policies and procedures of each and every other website that you visit.

If and when requested by users, we provide detailed information on the personal data handled by M3W project, the purpose, the legal basis and the duration of data handling and activities relating to data handling.

By using this website and giving your information to us, you indicate your consent to us collecting and using your personal information in accordance with the terms set out in these regulations.

Personal data may be handled if:

1. the user consents to it, or
2. this is prescribed by an act issued on the basis of statutory authorization, for a pre-defined scope. An act may prescribe the publication of personal data for reasons of public interest, with an exact specification of the scope of the data affected. In all other cases, publication requires the consent of the affected person, which must be given written in the case of special data. In case of any doubt, it must be presumed that consent has been refused. Consent shall be considered to have been granted with respect to data disclosed by the affected person during public appearances or handed over by him or her for the purpose of disclosure.

The most important principles relating to the handling of personal data are the following:

• Data handling must be consistent with its objective during all of its phases.
• During data handling only those personal data may be handled which are indispensable for the objective of the data handling, and are suitable for attaining that objective.
• Data may only be handled to the extent and for the time necessary to attain the given objective.
• In the absence of statutory regulations, personal data may only be handled with the consent of the user in question.
• The nature of the data provision, whether it is voluntary or mandatory, must be specified prior to the recording of the data.
• In the course of data handling data may only be used for the objective specified.
• In addition to the objective of data handling, clear information must be provided as to who will handle and process the data.
• Data must be stored securely, in a manner proportionate with the objective of data handling, for the time necessary to attain the objective of data handling. The data handler is obliged to provide for the security of the data, and is obliged to take the technical and organizational measures and to establish the procedural rules necessary for the enforcement of applicable legal provisions.
• Data must be protected, especially against unauthorized access, alteration, publication and deletion, as well as damage and destruction.
• Users may request information at any time during data handling, may check the contents of their data and may request their correction, modification, alteration or deletion at any time.
• Users may modify or revoke their consent to data handling at any time.
• Data is usually processed in a mechanical way.
• Data must be deleted concurrently with the attaining of the goal of data handling, in accordance with legal provisions.
• Data may be forwarded and different cases of data handling may be linked if the affected user has consented to this, or if an act permits this, and if the conditions of data handling are fulfilled for all personal data. Prior to implementing data handling, the service provider must provide clear and understandable information about the manner and the objective of data recording, and in the case of voluntary data provisions, about the indication of the voluntary basis.

We affirm as a general principle that in all cases when we request personal data1 from users, they can decide freely on whether to provide it or not, after reading and interpreting the relevant information. It must be noted however, that if users decide not to provide their personal data, they may in some cases be unable to use some of the services requiring this. Under no circumstances does M3W website collect any special information relating to race, nationality, minority and ethnic origin, political views or affiliation, religious or other conviction, state of health, pathological addictions, sexual activity or criminal history.

We also request basic demographic data (age, gender, qualification, place of residence) from users during registration for certain services. Such data is used for analytical purposes, to improve and develop the quality of our services and to ensure that the services we provide fully satisfy visitors’ needs, but are not disclosed to third parties.

If we request users to register on certain subpages of our website, we display in all cases which data is requested to be provided as “mandatory”. In this case the use of the word “mandatory” does not refer to the mandatory nature of data provision, but to the fact that there are some data fields which must be filled out for successful registration, and that failure to complete certain fields, or inappropriate completion could lead to the rejection of registration.

Registration

In order to have use of the services of our website we request our users to register. Through registration the users shall provide at least the following data: name, gender, age, location, education, email address. During registration, only that data can be requested from the user, which is necessary for the executing of the service (using the M3W online games), and is suitable for achieving the purpose. Upon registering, the user gives their consent for his/her personal data to be stored freely, and to the efficient process of the M3W project’s current regulations. During registration the mandatory fields does not need to be filled with proper data. Although in case of fictional registration, the conclusions gained from the games’ evaluations may be inadequate.

Personal and other data provided by users are not amended or linked with data or information originating from other sources. If such linking of data originating from different sources were to occur in the future, this would only be done based on prior consent from users, with the relevant information having been provided.

In compliance with its statutory obligation, M3W project hands over requested and available information to the competent authorities if it is requested to hand over personal data in a manner consistent with legal provisions (received in a resolution seizing official data in connection with the suspicion of a criminal act).

If users make personal data available to us, we will take all necessary measures to provide for the security of such data, both during network communication (online data handling) and data storage (offline data handling). If the services in question require users to send personal data online to be able to use the service, we provide a channel ensuring appropriate protection for such messages. As soon as the personal data are inside the IT infrastructure used by M3W project, only persons working in relevant positions may have access to personal data, with the application of high level access control measures.

The modification and deletion of personal data

If any of our users requests the deletion of their personal data from our system (of course in some cases accepting that from then on they will not be able to use the service linked to the data, or at least not in the same way), such a request will be fulfilled immediately by deleting from our database the appropriate records specified by the user.

We inform users that their data needs to be deleted in the following cases:

1. if the processing of the data is illegitimate;
2. if the user requests as such;
3. if the data is incomplete or inaccurate and the situation cannot be rectified legally;
4. if the purpose of data processing has ceased;
5. if the court or the Hungarian National Authority for Data Protection and Freedom of Information enacts it.

The placement of anonymous visitor identifiers (cookies)

An anonymous visitor identifier (cookie) is a unique series of signals suitable for identification and the storage of profile information, which service providers place on visitors’ computers. It is important to know that the complete IP address is not stored during the use of such signal series; they are therefore not able to identify the client, i.e. the user in any way whatsoever on their own, they are only suitable for recognizing the visitor’s computer. If you do not want such an identifier signal to be placed on your computer, you can adjust the settings of your browser in such a way that it will not allow the placement of such a unique identifier signal on your computer (in the case of most browsers this can be done in the settings / internet settings tab under the tools menu). In this case you will be able to use some of our services, but we will not be able to serve you fully in some cases.

The analysis of log files

The analysis of log files generated during the use of web-based services provides information for service providers which is useful in several respects. In the log files the servers providing the service record data about the requests sent by users, such as the dynamic IP address of the computer sending the request, the type of browser used, the time of the request, the address of the requested page, etc. M3W project uses such information for technical purposes (analyzing the secure operation of servers, subsequent checks) only. The data queues thus generated are not linked with information suitable for identification, originating from other sources.

Legal Statement

The information appearing on our website can be viewed free of charge by the general public as part of the website, with the frequency of updating specified on the website. However, the information displayed on the website may not be sold, published, handed over to third parties or be used for business purposes.

Data handling relating to opinions received

Complaints may be sent to our colleague responsible for data protection at M3W project by mail or email. Data handling to opinions received are performed by the employees of M3W project partners in strict compliance with the provisions of act CXII of 2011 on information self-determination and the freedom of information. Persons specifying their opinions have the right to request that the M3W project partners discontinue the handling of their data, and also to refuse cooperation with the M3W project partners at any time, without justification. To request legal remedy or to make a complaint, persons specifying their opinions may contact the competent court or the Hungarian National Authority for Data Protection and Freedom of Information at Hungary 1024 Budapest, Szilagyi Erzsebet fasor 22/C. (www.naih.hu).

M3W project partners:

• BME EMT (Hungary)
• Actimage Ltd. (Luxembourg)
• Frontida Zois Ltd. (Greece)
• Gaudiopolis (Hungary)
• Semmelweis University (Hungary)
• Silver Kiadó Ltd. (Hungary)
• Zurich University of Applied Sciences (Switzerland)

• 1. Data or information suitable for personal identification (personal data of natural persons) including without limitation: name, address, mailing address, telephone number, fax number, email address, bank credit rating, social security number, tax number, credit card information, customer profiles, biometric identifiers.