P R I V A C Y   P O L I C Y

I. Name of the Data Controller

1.	Name of the Data Controller:	Rail Navigator Kft.
2.	Data Controller’s corporate registration number:	Cg. 13-09-191022
3.	Data Controller’s registered seat:	2011 Budakalász Hegyalja utca 7.
4.	Data Controller’s registered e-mail address:	privacyrailnavigator.hu
5.	Data Controller’s representative:	Mr. Tibor Kardos (CEO)
6.	Data Controller’s Data Protection Officer:	Mr. Tibor Kardos

 

II. Rules of data processing

Rail Navigator Ltd. processes the personal data of its customers and other natural persons based on its Privacy and Data Security Policy. The scope of the policy covers all processes of the Company’s organizational units where personal data are processed under Article 3 (2) of Act CXII of 2011 on Informational Self-Determination and Freedom of Information („Info Act”) or Regulation 2016/679 of the European Parliament and the Council („GDPR”).

The terminology of this policy is identical to the terms defined in the Info Act and the GDPR.

Rail Navigator Kft. processes personal data only for the previously defined, lawful and specific purpose, to exercise rights and fulfil obligations, to the minimum extent and for the minimum period required for fulfilling its purpose. 

Data processing complies with the purpose at all stages – Rail Navigator Kft. shall erase the data should the purpose of data processing cease to exist or data processing is otherwise unlawful.

Prior to collecting data, Rail Navigator Kft. shall, in all cases notify the data subject about the purpose and the legal ground for data processing.

Rail Navigator Kft. employees processing data at the organizational units and the employees of organizations taking part in, or carrying out a part of data processing upon order by the Company shall handle the accessed personal data as business secrets. The persons accessing and processing personal data have made / shall make a Confidentiality Declaration.

Should anyone processing data in the name of the Company find that the personal data processed by the Company are erroneous, deficient or untimely, they shall correct them, or initiate correction by the colleague responsible for data recording.

Rail Navigator Kft. cooperates with data processors within specific processes, who cooperate in data processing in the name of, and under control by Rail Navigator Kft., subject to the Rail Navigator Kft.’s full liability as controller. Rail Navigator Kft. shall enforce the privacy obligations of the data processors - laid down in the Info Act and the GDPR - in the service contract signed with the data processors.

Rail Navigator Kft.’s leading official shall at all times specify the data protection organization in consideration of the Company’s specific features as well as the tasks and scopes of data protection and the related activities, and appoints a person to supervise data processing.

Rail Navigator Kft.’s associates shall ensure during their work that unauthorized persons do not access personal data, and personal data are placed and stored in a manner that they cannot be accessed, learned, changed or destroyed by unauthorized persons.

Rail Navigator Kft. takes efforts – in order to comply with the GDPR – to minimize personal data processing, to pseudonymise personal data as soon as possible, to provide for the transparency of the functions and processing of personal data, to enable the data subjects to track data processing and to enable the Company to create and improve security features.

Rail Navigator Kft. does not engage in any sort of automated data processing nor profiling.

The oversight of Rail Navigator Kft.’s data protection system is supervised by the Chief Executive Officer.

 

III. Enforcing the rights of Data Subjects

Those involved with the handling of personal data may request the deletion of processed personal data or restriction of their use if they believe that the personal data are no longer required for the purpose of collection or other manner of processing, or they believe that the personal data are processed unlawfully.

In addition, those who are concerned may at any time protest against data processing for any reason related to their own situation. In the case of protest, Rail Navigator Kft. may no longer process the personal data for marketing purposes, and for other purposes only if it is proven that data processing is justified by compelling legitimate grounds which override their interests, rights and freedoms or they are related to submitting, enforcing or defending legal claims. The limitation of data processing may also be requested simultaneously with the protest.

Lastly, those involved with the handling of personal data may also request the limitation of data processing if they dispute the accuracy of the personal data, and in this case, the limitation shall refer to the period that enables the controller to verify the accuracy of the personal data.

Those involved with the handling of personal data may request information from us about what personal data we process, for what purpose, in what manner and they may also request copies of the data stored by the employer. Such requests are fulfilled free of charge on the first occasion for each data.

For the sake of data protection, your rights of disposal and access can only be exercised after previous personal identification. In case of such a request, please get in touch with us at the following contacts:

• By e-mail: privacyrailnavigator.hu
• By postal mail: Rail Navigator Kft., H-2011 Budakalász, Hegyalja utca 7. , Hungary

Complaints about the lawfulness of data processing and proposals for actions regarding data processing are also received at these contacts. 

In those cases, where Rail Navigator Kft. acts as a data processor, the data processing-related rights of the data subjects are provided based on the controller’s decisions. At the same time, Rail Navigator Kft. immediately forwards to the controller the legal declarations and instructions received in this regard.

Complaints may be submitted to, and legal remedy is available at the National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság, 1055 Budapest, Falk Miksa utca 9-11.; mailing address: 1374 Budapest, Pf.: 603.) or at the court competent at your address or residence.

 

IV. Data Processors and Additional Data Processors

Our Company uses data processors – as well as sub-data processors if we act as a data processor – for the following activities:

• Processing service-related customer data
• Online tracking, anti-theft service: remote monitoring
• Online tracking-related services, such as shift- and crew scheduling, working time accounting
• In-house customer service: recording telephone calls
• Data processing related to arrearage management

 

V. Data processing related to service activities

 

Processing customer data stemming from GPS tracking service - Driver application

 

1.	Purpose of data processing:	Processing customer data – based on the service contract – for GPS tracking and forwarding them to the data processor for invoicing (invoice processing, printing and mailing)
2.	Scope of data processed:	Invoice-related data: Buyer’s customer number Buyer’s name Buyer’s address Buyer’s VAT no. All data of the buyer invoice: ordered product/service, its VTSZ/SZJ (customs tariff no./service register) number, quantity, unit price, net and gross value.
3.	Legal ground for data processing:	Contractual fulfilment
4.	Data storage deadline:	2 years after the termination of the service contract, for invoicing data: the termination of the right to charge rates and taxes
5.	Data storage method:	Electronically and in print

 

Online tracking 

Tracking contracting partners and their employees based on the service contract. The contracting partners can register on Rail Navigator Kft.’s internet platform by downloading the customer programme and entering the username and the password. Data are processed on the Rail Navigator Kft. platform, the process involves Rail Navigator Kft. as data processor, accessing the given vehicles’ registration number, positioning data and – if provided by the registered user (not obligatory) – the name of the vehicle’s driver and additional essential personal data.

Private-corporate switch

In the event of service contracts with companies, the customers register on Rail Navigator Kft.’s platform similarly to the previous paragraph. Rail Navigator Kft. can access the same data as in the case of online tracking. The purpose of tracking is that the customer can check the company car usage by the driver for private purposes in a manner that the driver’s rights to privacy and personal data are not infringed.

 

Other, GPS-tracking related services - Driver application

Tracking work time, fuel consumption, work time usage and temperature, as well as commodity protection. The procedure is the same as in both cases above.

 

In the data processing activities above, Rail Navigator Kft. acts as a data processor, whereby personal data are processed for customers as controllers based on the service contract signed with the customers.

 

 

1.	Purpose of data processingPurpose of data processing:	GPS tracking for the customers based on a service contract, after registration in Rail Navigator Kft.’s system
2.	Scope of the processed data:	Vehicle registration number, GPS-equipped vehicle and the name of its driver, who has been issued with a mobile device, locational data
3.	Legal ground for data processing:	Contractual fulfilment
4.	Deadline of data storage:	2 years after the termination of the service contract, for invoicing data: the termination of the right to charge rates and taxes
5.	Method of data processing:	Electronic

 

Protection against theft

Similarly to online tracking, a service contract is signed with the customers. In these cases, Rail Navigator Kft. acts as a controller.

1.	Purpose of data processing:	GPS tracking of customers for protection against theft, based on a service contract, after registration at Rail Navigator Kft.’s system
2.	Scope of the processed data:	Vehicle registration number, GPS-equipped vehicle and the name of its driver, who has been issued with a mobile device, locational data
3.	Legal ground for data processing:	Contractual fulfilment
4.	Deadline of data storage:	2 years after the termination of the service contract, for invoicing data: the termination of the right to charge rates and taxes
5.	Method of data processing:	Electronically and in print

 

Data processing for customer service

Upon providing services, Rail Navigator Kft. intends to make sure that its customers can enforce their rights to receive information and legal remedy under the provisions of the Consumer Protection Act.

At the customer service, the customers can manage their matters and submit complaints regarding services of Rail Navigator Kft. Issues may be managed personally, on the telephone and in writing. Written contracts can be made both by mail and electronically.

 

Management of complaints

The following methods are available for clients to file a complaint: 

Oral complaint: 

a.) On the telephone. 

Customers may also mandate a representative to manage their affairs, which only requires a written authorization under Act V of 2013 on the Civil Code. In this case, the representative’s data are also processed by Rail Navigator Kft.

Should the data subject disagree with the complaint management or the complaint cannot be investigated immediately, minutes are taken and printed from the customer registration. Rail Navigator Kft. shall deliver a copy of the minutes to the consumer.

 

The minutes taken about the complaint shall contain the following: 

• Customer’s name; 
• Customer’s address/registered office, if necessary, mail address; 
• Place, date and method of submitting the complaint; 
• Detailed description of the complaint, by recording the complaint-related objections separately so that all objections laid down in the customer’s complaint are fully investigated; 
• Number of contracts affected by the complaint, customer number depending on the case; 
• List of documents and other evidence presented by the customer; 
• Signature of the person taking the minutes and the customer (the latter is required if the complaint is made personally); 
• Place and date of drawing up the minutes.

 

Written complaint:

a) By mail; 

b) By e-mail to the following address: privacyrailnavigator.hu;

c) or on the on-line Helpdesk: https://safetysped.com/ugyfelszolgalat/

Rail Navigator Kft. shall store the minutes taken about the complaint and a copy of the response for 5 years and present them to controlling authority if requested.

Common rules

The customer service shall always lay down in writing the opinion of Rail Navigator Kft. about the complaint and shall notify the consumer about the actions taken, together with reasons, within 15 days after receiving the complaint, except where the customer notifies Rail Navigator Kft. about the complaint in writing and Rail Navigator Kft. takes actions without delay.

1.	Purpose of data processing:	Complaint management related to services
2.	Scope of the processed data:	The customer’s name; address / registered seat, if necessary, mail address; the place, date and method of submitting the complaint; detailed description of the customer’s complaint by separately recording the objections affected by the complaint to ensure that all objections mentioned in the customer’s complaint are fully investigated; number of the contract affected by the complaint, customer number, depending on the case; list of papers, documents and other evidence presented by the customer; signature of the person taking the minutes and the customer (the latter is required for personally made oral complaints); place and date of taking the minutes
3.	Legal ground for data processing:	Consent by the data subject under article 5 (1) a) of the Info Act, with the legal ground set forth in article 17/A-C of the Consumer Protection Act and article 6 (1) a)-c) of Regulation 2016/679 of the European Parliament and the Council.
4.	Deadline of data storage:	Rail Navigator Kft. shall store the minutes taken about the complaint, a copy of the response and the recording supplied with an individual ID number for 5 years [article 17/A (7) and 17/B (3) of the Consumer Protection Act].
5.	Method of data processing:	Electronically and in print

 

VI. Data processing for arrears management

Users who are late with payment receive a payment demand specifying the legal consequences. The demand is sent in mail with a return receipt. Should this be unsuccessful (failure to pay, absence of request for permission to pay in instalments) Rail Navigator Kft. sends another payment demand with a notice receipt, indicating the payable amount.

After, or parallel with the unsuccessful demands, the Company starts a collection procedure, by considering the expected result, consisting of a payment demand stage and, if necessary, a collection stage. The data on customers in arrears are forwarded to lawyers, notaries public and court executors.

 

1.	Purpose of data processing:	Handling customer data for arrears management in the controller’s service field
2.	Scope of the processed data:	name; name at birth; mother’s name; place and date of birth; permanent address; telephone number; mail address; e-mail address; legal title and the amount of the arrears.
3.	Legal ground for data processing:	article 6 (1) b) of Act CXII of 2011 and article 6 (1) b) of Regulation 2016/679 of the European Parliament and the Council.
4.	Deadline of data storage:	Payment of the arrears or lapse of the arrears-related civil law claims (5 years)
5.	Method of data processing:	Electronically and in print

 

Budakalász, May, 2021.■