may also include collecting personal data about you from a third
party who is authorized to act on your behalf or from third party
services that you use to interact with our services. We may also
collect your personal data from other sources such as public
databases, joint marketing partners, and social media platforms, to
the extent permitted by applicable laws.
you provide Us with any personal data relating to other individuals,
you represent that you have the authority to do so and, where
required, you have obtained any necessary consent. You acknowledge
that this personal data may be used in accordance with this Privacy
using a Mobile App published by STS,
in addition to contact information, We or Our service providers (such
as mobile operating system and platform providers) may also collect
information relating to your device, including your device model,
operating system, browser type, unique device identifier, IP address,
mobile phone number, mobile network carrier, location, and the way
you are using the Mobile App. The information collected will depend
on the functionality of the specific Mobile App you are using. If any
other information is collected relating to your use of a Mobile App,
such information will be specified in the Mobile App.
do We process your personal data?
process your personal data for specified and lawful purposes only and
in accordance with the applicable data protection laws.
personal data will be processed by STS
for the purposes
listed in the above table.
long do We retain your personal data?
retain your personal data for as long as it is necessary to fulfil
the purposes for which it was collected, or longer if required to
fulfil our legal and contractual obligations. After expiration of the
retention period, your personal data will be deleted. If We are
unable to completely delete the personal data from our systems, We
will ensure that there are appropriate measures in place to secure
the information and protect it from further use.
are your rights and how can you exercise them?
on your relationship with STS
and in line with data protection laws
applicable in Hungary,
you may have several rights in relation to your Personal Data such as
access, rectification, erasure, restriction of processing, objection,
withdrawal of consent, not to be subject to decisions based on
automated processing, opt out of marketing communications, etc.
Please note, these rights are subject to exemptions and may not apply
in all circumstances. If you wish to exercise these rights, STS
will provide you with the requested information or will action your
request within one month after receipt of your verified request,
subject to any extensions that may be required and communicated to
can use the following channels to exercise your rights or request
more information about your rights:
you have any request,
or inquiries, you may contact STS
may opt out of marketing communications by clicking on the
“unsubscribe” link located on the bottom of all STS
marketing emails, or by replying ‘STOP’ if you receive any STS
SMS communications. Please note that you may continue to receive
transactional or other business communications that are associated
with our business relationship with you.
whom do We share your personal data?
may transfer or share your Personal Data with third parties such as
our service providers and vendors, business partners, professional
and corporate advisors, public or government authorities including
law enforcement, network providers, third party websites, and our
affiliates or subsidiaries.
may also transfer your personal data to any of its global affiliated
entities or subsidiaries
within the HCL Group.
Unless you are otherwise notified, any transfers of your personal
data from within the European Economic Area (EEA) to third parties
outside the EEA will be based on an adequacy decision or as governed
by the standard contractual clauses (a copy of which can be obtained
through the contact information included below). Any other non-EEA
related transfers of your personal data will take place in accordance
with the appropriate international data transfer mechanisms and
may disclose your Personal Data to external law enforcement bodies or
regulatory authorities, in order to comply with legal obligations. We
may also disclose your personal data where mandated by law and as
further required when We believe in good faith that disclosure is
necessary to protect our rights, protect your safety or the safety of
others, investigate fraud, or respond to a government request.
We are involved in a merger, reorganization, dissolution or other
fundamental corporate change, We may need to share your information
with a third party, in compliance with applicable laws.
do We safeguard your personal data?
use a range of security measures to protect your personal data from
unauthorized or unlawful access, loss, disclosure, or alteration,
including technical, organizational and physical measures. We have
sufficient controls, policies, procedures and guidance to ensure
security of personal data is maintained at all stages of its
lifecycle. The current security measures are as follows:
data is stored on separate password-protected systems.
to systems storing personal data is strictly limited to essential
personnel with a need to know.
intrusion detection measures are in place to detect and avert
storing personal data are segregated from other systems and have
been inspected against data leakage.
can you contact Us if you have any questions?
you have any questions about this Privacy Statement, you can contact
will We update this Privacy Statement?
may amend this Privacy Statement from time to time. If We materially
change our Privacy Statement, We will update the “Effective Date”
at the top of the Privacy Statement and We may provide notice prior
to the update taking effect by posting a notice on our website or,
where required by law, by providing you with notice of such updates.
of a personal data breach to the data subject
the personal data breach is likely to result in a high risk to the
rights and freedoms of natural persons, STS will communicate the
personal data breach to the data subject without undue delay after
taken notice of such personal data breach.
of a personal data breach to the supervisory authority
the case of a personal data breach, STS will without undue delay but,
where feasible, not later than 72 hours after having become aware of
it, notify the personal data breach to the supervisory authority
competent, unless the personal data breach is unlikely to result in a
risk to the rights and freedoms of natural persons. Where the
notification to the supervisory authority is not made within 72
hours, it shall be accompanied by reasons for the delay.
want to address any concerns you may have in relation to the
management of your personal data, therefore, please contact us in the
first instance. You have a right to lodge a complaint with a data
protection supervisory authority in particular in the jurisdiction of
your habitual residence, place of work or place of the alleged
relating to STS’s use of personal data may be sent by email - with
the details of your complaint to firstname.lastname@example.org. We will look
into and respond to any complaints we receive within 30 days.
also have the right to file a complaint with the National Authority
for Data Protection and Freedom of Information or seek remedy at
court if you are of the view that your rights relating to personal
data have been violated. For further information on your rights and
how to complain to the Authority, please refer to
Nemzeti Adatvédelmi és Információszabadság Hatóság
1055 Budapest, Falk Miksa utca 9-11. / 1363 Budapest, Pf. 9.
the event of a breach of your rights relating to personal data, or if
you disagree with STS's decision, within 30 days of the receipt of
the decision, you may initiate a claim against the Data Controller
directly at the ordinary courts having competence to such cases on
the basis of STS’s seat (registered address) or other applicable
court will have to act in an expedited procedure in such cases.