Privacy Policy

Data Controller

Spartacus Advertising KFT
Szent Istvan Korut 27 2/2
CAP 1055 - Budapest City – Hungary

Email address of the Controller:
[email protected]

Types of Data collected

The Personal Data collected by the website either independently or through third parties includes: first name; surname; telephone number; email; various types of Data; Usage Data; Tracking Tools; unique identifiers of advertising devices; Data communicated during the use of the service.

Comprehensive details about each type of Data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the collection of Data.

Personal Data may be freely provided by the User or, in the case of Usage Data, automatically collected.

Unless otherwise specified, all the Data requested is mandatory. If the User refuses to communicate it, it may be impossible for the website to provide the Service. In cases where the website indicates certain Data as optional, Users are at liberty to refrain from communicating such Data, without this having any consequences on the availability of the Service or its operation.

Should Users have any doubts as to which Data is mandatory, they are invited to contact the Controller at the addresses indicated in this document.

The possible use of Cookies – or of other Tracking Tools – by the website or by the owners of third-party services used, unless otherwise specified, has the purpose of providing the Service requested by the User, as well as the additional purposes described in this document and in the Cookie Policy.

The User assumes responsibility for third-party Personal Data obtained, published or shared through the website and warrants that it has the right to communicate or disclose it, releasing the Controller from any liability towards third parties.

Methods of processing

The Controller takes appropriate security measures to prevent unauthorised access, disclosure, modification or destruction of Personal Data.

The processing is carried out using computer and/or web tools, with organisational arrangements and reasons that are strictly related to the purposes indicated. In addition to the Controller, in some cases other subjects involved in the Controller's organisation (administrative, sales, marketing and legal staff and system administrators) or external subjects (such as third-party technical service providers, hosting providers, IT companies or communication agencies) appointed as external Data Processors by the Controller may have access to the Data. The updated list of external Data Processors can always be requested from the Data Controller through the contacts indicated in this document.

Legal basis of processing

The Controller processes Personal Data relating to the User if one of the following conditions is met:

  • processing is necessary for the execution of a contract to which the Data Subject is party or for the execution of pre-contractual measures taken at the request of the Data Subject;
  • the User has given consent for one or more specific purposes; please note that in some jurisdictions, the Controller may be authorised to process Personal Data without the User's consent or another of the legal bases specified below, until the User objects ("opts-out") to such processing. However, this is not applicable if the processing of Personal Data is governed by European Personal Data protection legislation;
  • processing is necessary to comply with a legal obligation to which the Controller is subject;
  • processing is necessary for the pursuit of the legitimate interest of the Controller or a third party.

However, it is always possible to ask the Controller to clarify the factual legal basis of each processing operation.

Place

The Data is processed at the Controller's operating offices and at any other place where the parties involved in the processing are located. For further information, please contact the Controller.

The User's Personal Data may be transferred to a country other than the one where the User is located. For further information on the location of the processing, the User may refer to the section concerning details on the processing of Personal Data.

The User is entitled to obtain information about the legal basis for transferring Data outside the European Union, but also about the security measures adopted by the Controller to protect Data.

The User may verify whether a Data transfer outside the European Union takes place by examining the section of this document concerning Personal Data processing details or request information from the Controller by contacting it at the addresses indicated in this document.

Storage period

Data is processed and stored for as long as is necessary to fulfil the purposes for which it was collected.

Therefore:

  • Personal Data collected for purposes related to the legitimate interest of the Controller will be retained until such interest is met. The User may obtain further information regarding the legitimate interest pursued by the Controller in the relevant sections of this document or by contacting the Controller.

Where the processing is based on the User's consent, the Controller may keep the Personal Data for longer until such consent is revoked. Moreover, the Controller may be obliged to retain Personal Data longer in compliance with a legal obligation or by order of an authority.

At the end of the storage period the Personal Data will be deleted. Therefore, at the end of this period, the right of access, deletion, rectification and the right to Data portability can no longer be exercised.

Purpose of Processing of Data collected

The User's Data is collected to enable the Controller to provide the Service, comply with legal obligations, respond to requests, safeguard its rights and interests (or those of Users or third parties), but also for the following purposes: contacting the User, transferring Data to third parties, statistics, tag management, contact management and message sending, traffic optimisation and distribution, advertising, collecting privacy preferences and transferring Data outside the EU where necessary.

To obtain detailed information on the purposes of the processing and the Personal Data processed for each purpose, the User may refer to the section "Details on the Processing of Personal Data".

Details on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

  • Contact the User

Telephone contact

Users who have provided their telephone number may be contacted for commercial or promotional purposes lined to the website, as well as to fulfil support requests.

Personal Data processed: telephone number.

Contact form

By filling in the contact form with its Data, the User agrees for it to be used to respond to requests for information or of any other nature indicated in the form header.

Personal Data processed: name, surname, email; telephone number, various types of Data.

Mailing list 

By registering to the mailing list, subject to consent, the User's email address is automatically included in a list of contacts to whom email messages containing commercial and promotional information may be sent.

Personal Data processed: email.

  • Managing tags

This type of service is used for the centralised management of tags or scripts used. Where these services are used User Data flows through them and, where appropriate, it is stored.

Google Tag Manager (Google Ireland Limited)

Google Tag Manager is a tag management service provided by Google Ireland Limited.

Personal Data processed: Usage Data.

Place of processing: Ireland – Privacy Policy.

  • Traffic optimisation and distribution

This type of service makes it possible to distribute content via servers located throughout the territory and to optimise the performance thereof.

The Personal Data processed depends on the characteristics and implementation methods of these services, which by their nature filter communications between the website and the User's browser.

Cloudflare (Cloudflare Inc.)

Cloudflare is a traffic optimisation and distribution service provided by Cloudflare Inc.

The way Cloudflare is integrated means that it filters all traffic, i.e. communications between the website and the User's browser, also allowing the collection of statistical Data concerning it.

Personal Data processed: Cookies; various types of Data as specified by the privacy policy of the service.

Place of processing: United States – Privacy Policy.

  • Statistics

The services contained in this section allow the Data Controller to monitor and analyse traffic Data and serve to keep track of the User's behaviour.

Google Analytics (Google Ireland Limited)

Google Analytics is a web analytics service provided by Google Ireland Limited ("Google"). Google uses the Personal Data collected to track and examine the use of the website, compile reports and share them with other services developed by Google.

Google may use Personal Data to contextualise and personalise ads in its advertising network.

Personal Data processed: Usage Data; Tracking Tools.

Place of processing: Ireland – Privacy Policy.

Facebook Ads conversion tracking (Facebook pixel) (Meta Platforms Ireland Limited

The Facebook Ads conversion tracking (Facebook pixel) is a statistics service provided by Meta Platforms Ireland Limited that links Data deriving from the Meta ad network with actions taken within the website. Facebook pixel monitors conversions that can be attributed to Facebook Ads, Instagram and the Audience Network.

Personal Data Processed: Usage Data; Tracking Tools.

Place of processing: Ireland – Privacy Policy.

Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)

Hotjar is a statistics service provided by Hotjar Ltd. Hotjar respects generic "Do Not Track" headers. This means that the browser can instruct the script not to collect any User Data. This is a setting that is available in all major browsers. More information on opting out of Hotjar is available here.

Personal Data Processed: Usage Data; Tracking Tools.

Place of processing: Malta – Privacy Policy.

TikTok conversion tracking (TikTok Technology Limited)

TikTok conversion tracking is a statistics service provided by TikTok Technology Limited that links Data deriving from the TikTok ad network with actions taken within the website. TikTok Pixel tracks conversions that can be attributed to TikTok ads and allows groups of Users to be identified as targets based on their previous use of the website.

Personal Data processed: Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example); device information; Tracking Tools.

Place of processing: Ireland – Privacy Policy.

  • Advertising

This type of service allows the User's Data to be used for commercial communication purposes. These communications are displayed on the website in the form of banners and other forms of advertising, also in relation to the User's interests.

This does not mean that all Personal Data is used for this purpose. Data and conditions of use are set out below.

Some of the services mentioned below may use Tracking Tools to identify the User or use the behavioural retargeting technique, i.e. display advertisements tailored to the User's interests and behaviour, also observed outside the website. For more information in this regard, we suggest you check the privacy policies of the respective services.

Generally, services of this type offer the option of disabling such tracking. In addition to any opt-out function provided by any of the services listed in this document, the User can read more about how to disable interest-based advertising in the special section "How to disable interest-based advertising" in this document.

Voluum DSP (Codewise Sp. z o.o. Sp. k)

Voluum DSP is an advertising service provided by Codewise Sp. z o.o. Sp. k.

Personal Data Processed: Usage Data; Tracking Tools.

Place of processing: Poland – Privacy Policy.

Outbrain (Outbrain Inc.)

Outbrain is an advertising service provided by Outbrain Inc.

Personal Data processed: Tracking Tools; various types of Data as specified by the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Taboola (Taboola Inc.)

Taboola is an advertising service provided by Taboola Inc.

Personal Data Processed: Usage Data; Tracking Tools.

Place of processing: United States – Privacy Policy.

Further information on the processing of Personal Data

Transfer of Data to third parties - Commodity Categories

The Controller, subject to specific consent, may transfer Users' Personal Data to third-party companies in the following categories:

  • Internet platforms and services;
  • Technological products;
  • Information services;
  • Advertising services;
  • Computer services;
  • Financial services;
  • Investment services;
  • Household services;
  • Personal care services.

Transfer of Data outside the EU

The Controller may only transfer Personal Data collected within the EU to third countries (i.e. all countries outside the EU) on a specific legal basis. Therefore, such Data transfers are carried out on one of the legal bases described below.

The User may request information from the Controller regarding the applicable legal basis applicable in practice to each individual service.

Transfers to third countries based on standard contractual clauses

Where this is the legal basis, the transfer of Personal Data from the EU to third countries takes place based on standard Personal Data protection clauses adopted by the European Commission.

In such cases, the Data recipients have agreed to process the Personal Data in accordance with the levels of protection provided by EU law. Users may request further information by contacting the Controller using the contact details provided in this document.

Personal Data processed: various types of Data.

Rights of the User

Users may exercise certain rights with regard to the Data processed by the Controller.

In particular, the User has the right to:

  • withdraw consent at any time. The User may withdraw its consent to the processing of its Personal Data given previously;
  • object to the processing of its Data. The User may object to the processing of its Data where it takes place on a legal basis other than consent. Further details on the right to object are set out in the section below;
  • access to its Data. The User has the right to obtain information on the Data processed by the Controller, on certain aspects of the processing and to receive a copy of the Data processed;
  • verify and request rectification. The User may verify the correctness of its Data and request that it be updated or corrected;
  • have processing restricted. Where certain conditions are met, the User may request the restriction of the processing of its Data. In such case, the Controller will not process the Data for any purpose other than to store it;
  • have its Personal Data deleted or removed. Where certain conditions are met, the User may request for the Controller to delete its Data;
  • receive its Data or have it transferred to another data controller. The User has the right to receive its Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred unhindered to another controller. This provision is applicable where the Data is processed by automated means and the processing is based on the User's consent, on a contract to which the User is party or on contractual measures related thereto;
  • lodge a complaint. The User may lodge a complaint with the relevant data protection supervisory authority or take legal action.

Details on the right of opposition

Where Personal Data is processed in the public interest, in the exercise of public authority vested in the Controller or in pursuit of a legitimate interest of the Controller, Users have the right to object to the processing for reasons related to their particular circumstances.

Users are reminded that if their Data is processed for direct marketing purposes, they may object to the processing without giving any reason. To establish whether the Controller processes Data for direct marketing purposes, Users may refer to the respective sections of this document..

How to exercise one's rights

To exercise their rights, Users may send a request to the Controller using the contact details provided in this document. Requests are filed free of charge and processed by the Controller as quickly as possible, in any case within one month.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on the website, as well as, if technically and legally feasible, by sending a notification to Users using any of the contact details in its possession. Therefore, please consult this page frequently, referring to the date of last change indicated at the bottom.

If the changes affect processing the legal basis of which is consent, the Controller will collect the User's consent again, if necessary.

Last change: 30 December 2022