INFORMATION ON THE PROCESSING OF PERSONAL DATA
- air traffic information service -
(last updated: November 2024)
Please be informed that HungaroControl Pte. Ltd. Co. (headquarters: 1185 Budapest, Igló u. 33-35; E-mail: info@hungarocontrol.hu, hereinafter referred to as “the Controller” or “HungaroControl”) processes your personal data in connection with the provision of the air traffic information service provided under Commission Implementing Regulation (EU) 2017/373 laying down common requirements for providers of air traffic management/air navigation services and other air traffic management network functions and their oversight, repealing Regulations (EC) No 482/2008, Implementing Regulations (EU) No 1034/2011, (EU) No 1035/2011 and (EU) 2016/1377 and amending Regulation (EU) No 677/2011 (hereinafter referred to as “the Regulation”) as follows:
1. DETAILED DESCRIPTION OF THE PROCESSING
I. Reporting discrepancies in air traffic information publications (AIP, AIC, SUP, NOTAM, air traffic chart, VFR Manual) and processing personal data provided in response to requests for air traffic information
a) Data processed: name, e-mail address; name, telephone number and other personal data provided in an electronic or postal letter or on the website of HungaroControl;
b) Source of data: Data Subject (letter, e-mail, “Message” posted on the HungaroControl websites);
c) Purpose of data processing: notification of discrepancies in air traffic information service publications and handling and substantiating requests for air traffic information requests;
d) Legal basis for data processing:
- with regard to the recording, organisation and use of data: compliance with the legal obligation set out in points AIS.OR.235 and AIS.TR.235 of Annex VI to the Regulation (pursuant to Article 6(1)(c) of the GDPR);
- with regard to the storage and erasure of data: compliance with the legal obligation set out in points AIS.OR.235 and AIS.TR.235 of Annex VI to the Regulation (pursuant to Article 6(1)(c) of the GDPR);
e) Retention period: 5 years after the notification or request for information.
II. Processing of personal data provided in a message sent in connection with the provision of an air traffic information service (other than as referred to in point I)
a) Data processed: name, e-mail address; name, phone number, the subject of the message and other personal data that may have been provided in the message;
b) Source of data: Data Subject (letter, e-mail, “Message” posted on the HungaroControl websites);
c) Purpose of data processing: identifying, contacting and replying to the sender;
d) Legal basis for data processing: consent (on the basis of Article 6(1)(a) of the GDPR);
e) Retention period: until consent to processing is withdrawn, but no later than 1 year after providing the data.
The consent to the processing set out in point II may be withdrawn at any time without giving reasons by sending an e-mail to the Data Protection Officer at the e-mail address indicated below. The withdrawal of consent will not affect the lawfulness of processing based on consent prior to its withdrawal.
2. WHAT IS THE PROCESS AND METHOD OF DATA PROCESSING?
a) the collection, recording and use of data;
b) storage of data by electronic means;
c) erasure of data after the expiry of the data processing period.
3. RECIPIENTS AND DATA PROCESSORS
Please be informed that HungaroControl will treat your personal data confidentially and, except for the mandatory disclosure to authorities and other bodies based on law, will disclose it without prior information to you only as described in this notice.
Please also note that HungaroControl uses the services of data processors to store your personal data. In the processing of personal data, in accordance with the applicable legal requirements, it applies risk-proportionate organisational and technical security measures to prevent unauthorised access to personal data, unauthorised modification, transmission, disclosure or deletion of data, and to ensure controllability in both manual and automated data processing. HungaroControl also ensures that data contained in different records cannot be directly linked and attributed to the Data Subject.
The data processors used by HungaroControl: With regard to the data stored on the server of the HungaroControl website, it is the operator of the website, BigFish Internet-technológiai Kft. during the period it operates the website (Address: 1066 Budapest, Nyugati tér 1-2; Website: www.bigfish.hu; E-mail: cafe@bigfish.hu).
4. WHAT ENTITLEMENTS DO YOU HAVE?
a) Right to transparent information – With this notice, the Controller provides information on the circumstances of data processing, including who processes your personal data, for what purposes, on what grounds and for how long, as well as on your rights in relation to the data processing and who you can contact with questions or complaints about the data processing;
b) Right to the withdrawal of your consent – Consent may be withdrawn at any time without giving reasons by unsubscribing using the “Unsubscribe” button at the bottom of the notifications. However, the withdrawal of consent does not affect the lawfulness of processing based on consent prior to its withdrawal;
c) Right of access to your personal data – You may at any time ask the Controller whether your personal data are being processed, request full information about the processing and request a copy of your personal data. At the first time you request a copy, it will be free of charge, and for each subsequent copy HungaroControl may charge a fee based on the administrative costs;
d) Right to the rectification of your personal data – You may request the Controller to correct your inaccurate personal data or, to complete it if incomplete;
e) Right to the erasure of your personal data – You may request the erasure of your personal data by the Controller. HungaroControl or its data processor will erase the processed personal data at your request if:
• the processing is unlawful;
• the purpose of the processing has ceased to exist or the processing is no longer necessary to achieve that purpose;
• you withdraw your consent and there is no other legal ground for the processing;
• the legally permitted period of data retention has expired;
• the erasure of the data has been ordered by law, public authority or court.
f) Right to the restriction of processing – You may request (e.g. in order to submit, exercise or defend legal claims) that the Controller only stores your personal data and does not process it in any other way;
g) Information on the identity of the recipients informed of the rectification, erasure or restriction of processing – upon your request, the Controller will inform you of the recipients referred to;
h) Right to data portability – You may request that the personal data you have provided to the Controller is provided to you in a structured, commonly used, machine-readable format or transferred by the Controller to another controller. This right is only available to you in relation to data processed on the basis of consent or contract, provided that the processing is carried out by automated means;
i) Right to lodge a complaint – You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of your personal data infringes the applicable data protection laws;
j) Compensation or damages – Please be informed that you may claim compensation or damages for loss or damage suffered as a result of unlawful processing or personality right related damage;
k) Notification – HungaroControl will examine the request submitted by the Data Subject for the exercise of the rights to which he or she is entitled within the shortest possible time from the date of submission, but not later than one month, and will notify the Data Subject of its decision in writing or, electronically if the request was submitted electronically;
l) Costs – If you make a repeated request for the same set of data in a given year, for a reason other than the need to rectify, erase or restrict the data due to HungaroControl’s default, HungaroControl may claim the reimbursement of the costs incurred in complying with the request.
5. WHERE CAN YOU GO IF YOU HAVE QUESTIONS ABOUT EXERCISING YOUR RIGHTS OR IF YOU WANT TO SEEK LEGAL REMEDY?
a) If you have any questions, you can contact HungaroControl’s Data Protection Officer:
Dr. Anikó Fazekas
Phone: +36-30-851-2515
E-mail address: dpo@hungarocontrol.hu
b) Legal remedy:
Hungarian National Authority for Data Protection and Freedom of Information (NAIH)
Mailing address: 1363 Budapest, Pf.: 9.
Website: www.naih.hu
Phone: +36-1-391-1400
Court:
In Hungary, the competent court for the action will be the competent court at the location where the Controller has its registered office is, but the Data Subject may also choose to bring the action before the court of the place of his or her residence or domicile.