What we do with your data.

This English text is a translation of the official Hungarian privacy notice, provided for convenience. In case of any discrepancy, the Hungarian version prevails.

1.1. About the data controller

The EgyüttÉrzés Pastoral Care Association (hereinafter the Association or the Controller) has prepared this notice so that you, as a data subject, can learn everything important about how the Association processes your personal data.

Our contact details:

E-mail: adatvedelem@eletrehivunk.hu

Registered address: 2600 Vác, Karcsu Antal Arzén utca 5. 2/7., Hungary

1.2. About data processing

1.2.1. The purpose of the Association

The Association’s purpose is to help people who find it hard, or impossible, to access mental health support for financial or other reasons. The Association also aims to support beginning pastoral carers who take their vocation seriously and truly devote their lives to the helping professions. The founding members give room to working together, and open the way towards clients. The founders also aim to bring the pastoral care profession into view as an accessible and possible form of help and support.

We process personal data only in order to achieve these purposes.

1.2.2. Data processing in brief

When you get in touch with the Association, for example by visiting our website (www.eletrehivunk.hu, hereinafter the Website), by using one of our services as a client, or by applying for membership as a pastoral carer and then being registered as a member during our cooperation, we process your personal data in connection with all of these.

In processing data we act as we would expect others to act with our own data. We respect the right to informational self-determination of the people we come into contact with, our partners, supporters and members; we treat their personal data confidentially, and we take every reasonable technical and organisational measure to guarantee its security.

2.1. Processing related to getting in touch

When you contact us through any of our channels (e-mail, phone, postal address, website), for example to ask about our activities or to apply as a helper or volunteer, we process your personal data for the purpose of communicating with you and answering your enquiry.

The legal basis for processing is our legitimate interest in keeping in touch and in answering your enquiry [GDPR Article 6(1)(f)].

Depending on the form of contact and the content of the enquiry, we process different types of data. These may be: your name, e-mail address, phone number or address, and any personal data you share with us in the enquiry or bring to our attention in any other way.

We use the data solely to be able to contact you and answer your enquiry.

By providing your data when getting in touch, you can reasonably expect the processing. You may nevertheless object to it. In case of an objection we stop the processing and delete your data.

You can read more about your rights in chapter 4 of this notice.

The data are stored on our hosting provider’s servers and, depending on the form of contact, forwarded to the relevant partner, for example in the case of e-mail they are handled by the e-mail provider.

We delete your data three years after the last contact with you.

2.2. Processing related to our clients

If you apply to us as a client and use one of the Association’s services, processing your personal data is essential. The purpose of the processing is our cooperation with you and providing pro bono support to you.

During our cooperation we process your name and contact details, the data you voluntarily share as a client with the Association or one of its members, the professional documentation of our cooperation, and your declaration that the conditions of participation are met. We provide our services to clients pro bono, for a symbolic contribution that shows commitment, so we also record that fact. You may decide to pay more than the minimum contribution in order to support the operation of the Association, if your financial circumstances allow. We always issue an invoice for the payment; you can read about the related processing in the Invoicing chapter.

We process identification and contact data to identify you, and the information you share with us during our cooperation and the professional documentation to document that cooperation, on the legal basis of preparing and performing a contract [GDPR Article 6(1)(b)]. We do not ask for special categories of data, such as health data; we process them only if you decide to share them with us and give your separate, explicit, written consent to the processing [GDPR Article 9(2)(a)].

You may withdraw your consent at any time, in which case we delete the data processed on that basis. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

In connection with our cooperation, your data are processed by the member who keeps in touch with you; data created electronically are stored on our protected servers, and paper documentation in a central, secure place designated by the Association.

We store your personal data for five (5) years after the last contact with you, then delete them; we do not share them with third parties or international organisations.

If, after your pro bono cooperation with the Association, you wish to continue using the pastoral care service as a client, you can do so outside the framework of the Association’s support. The related processing is carried out by the chosen pastoral carer as an independent controller.

2.3. Processing related to membership of the Association

In connection with keeping the register of members, we process the personal data of the Association’s members.

The processing is necessary to establish membership, identify the member, keep in touch with them and carry out the administrative tasks related to membership (for example convening the general assembly, recording membership fee payments, etc.).

In connection with membership we collect and process the following personal data of the member:

• identification data (name, address, for keeping the register of members, the minutes of the general assembly and attendance sheets) in order to fulfil our legal obligation [GDPR Article 6(1)(c); Civil Code Section 3:75(1)],
• contact details (e-mail address, phone number) and data related to membership (for example records of membership fee payments or arrears) on the basis of the Association’s legitimate interest in keeping in touch and in the operation and running of the Association [GDPR Article 6(1)(f)].

In connection with the operation of the Association and maintaining membership you can reasonably expect the processing. You may nevertheless object to processing based on our legitimate interest. In case of an objection we stop processing the data handled on that basis and delete them, unless they are needed to enforce our legal claims (for example in the case of membership fee arrears).

You can read more about your rights in chapter 4 of this notice.

The data are stored on our hosting provider’s servers and, depending on the form of communication, forwarded to the relevant partner, for example in the case of e-mail they are handled by the e-mail provider.

We store identification data and data related to membership fee payments for 5 years after membership ends; we delete contact details when membership ends.

2.4. Invoicing and processing related to donations

If you support our Association as a one-off or regular donor, or pay for services, we process your personal data in connection with the related administration, including issuing invoices. The processing takes place in order to comply with accounting obligations, that is, to fulfil a legal obligation [GDPR Article 6(1)(c)].

In connection with donations we process the data shown on the invoice: the name of the donation and of the donor, their address, the date, amount and type of the donation.

In the case of regular donations we also process the data of the related contract, for the purpose of preparing and performing the contract and on the corresponding legal basis [GDPR Article 6(1)(b)].

You can read about your rights in chapter 4 of this notice.

The data are also processed by our invoicing partner and our accountant.

We keep invoicing data for the period set by accounting rules (currently 8 years). We process contract data for five (5) years after the end of the given contract.

2.5. Processing the contact details of service providers we use

To run our Association and provide our services we use contracted partners, and in doing so we process the data of their representatives, contact persons and, where applicable, employees. If any of these applies to you, we process your name, contact details, the name of your employer and your position, and all information brought to our attention in connection with these during our cooperation.

This processing is based on our legitimate interest in performing the given contract and keeping in touch [GDPR Article 6(1)(f)]. As a data subject you may object to processing based on legitimate interest.

You can read more about your rights in chapter 4 of this notice.

We delete the personal data processed if they are no longer needed six months after the end of the given contract, or on request (for example if we are informed that a contact person no longer works for the contracted company, or you object to the processing).

2.6. Exercising data subject rights

When you exercise your rights as a data subject (chapter 4 of this notice), for example when you request access to your personal data, their rectification, erasure or the restriction of their processing, or object to the processing of such data, we process your personal data in order to fulfil your request.

The legal basis for the processing is the fulfilment of the legal obligation under the data protection regulation to respond to such requests [GDPR Article 6(1)(c)].

Depending on the form and content of the request we process different types of data. This may be your name, e-mail address, phone number or address, etc., and any personal data you share with us in the request or bring to our attention in any other way.

We respond to your request within one month of receiving it at the latest, primarily electronically or in the form you requested. Fulfilling reasonable requests is free of charge.

If there is doubt about the identity of the person submitting the request, we may ask for further information necessary to confirm the identity of the data subject.

The data are stored on our hosting provider’s servers. We delete your data 5 years after the last contact with you.

2.7. Processing related to enforcing the Association’s claims

If you fail to fulfil a contractual obligation towards the Association, we process your personal data for the purpose of enforcing our claims. This processing is based on our legitimate interest in enforcing legal claims [GDPR Article 6(1)(f)].

As a data subject you may object to processing based on legitimate interest. You can read more about your rights in chapter 4 of this notice.

Depending on the form of enforcement we process different data: the data already available to the Association and further data arising in connection with the claim. For example identification and contact data, the fact and nature of the outstanding obligation and the circumstances of its origin, and the content of messages exchanged during the contact.

We process the data until the successful enforcement of the claim, then delete them. If we cannot enforce the obligation ourselves, we hand the data over to a debt collection company or to the competent authority.

2.8. Processing related to our social media pages

Social media providers (Facebook, Instagram, etc.) interpret the processing carried out through the so-called “fan pages” created on their platforms in different ways. This affects you in that this interpretation determines, with regard to these pages, who is the primary source of information about the activities concerning your data, and towards whom you can exercise your rights.

The logic behind the difference is not easy to understand, either as a data subject or as a controller. In order to be present on these platforms, we can only accept the providers’ differing approaches; given the size and economic weight of the providers, these are not negotiable questions.

The essence of the differences is summarised below.

2.8.1. Social media pages where we act as joint controllers

• Facebook (https://www.facebook.com/[…])
• Instagram (https://www.instagram.com/[…])
• LinkedIn (https://www.linkedin.com/[…])

With regard to our pages on these platforms, we are jointly responsible with the given provider for the lawful processing of personal data generated as a result of visiting or interacting with our pages.

The details of the processing we carry out can be learnt from this privacy notice. Further information about the providers’ contact details and the details of joint processing can be found here:

• Facebook Page Insights (provider: Meta Platforms) https://www.facebook.com/legal/terms/page_controller_addendum
• Instagram (provider: Meta Platforms) https://www.facebook.com/legal/terms/page_controller_addendum
• LinkedIn Page Insights (provider: LinkedIn Ireland Unlimited Company) https://legal.linkedin.com/pages-joint-controller-addendum

As a data subject you may contact either us or the given provider with questions about the processing of your personal data; however, information about the technical side of the processing can primarily be given by the provider. On the Association’s side, as a controller, beyond the visible activities related to these pages (reactions, comments, shares, etc.) we have no access to the user data processed by the provider in connection with the page, only to aggregated, anonymised statistical analyses derived from them.

We process the statistical data on the basis of our legitimate interest in maintaining a social media presence [GDPR Article 6(1)(f)].

The data are processed as long as you remain a user of the given social network and interact with our page in any way.

3.1. Access to data

Your personal data can be accessed by the Association’s officers and by those of our members who come into a supporting relationship with you. Every person carrying out processing is entitled to learn only those data, and only to the extent, strictly necessary for performing their task.

Everyone entitled to access data is obliged to treat them confidentially; to this end, our fellow members and the third parties with access to the data (processors and their employees) are bound by a duty of confidentiality regarding the personal data they learn.

3.2. Data processors

The Association’s subcontractors may occasionally access personal data in the course of technical operation. Our subcontractors therefore work under full confidentiality and, within contractual guarantees, undertake to fully comply with our instructions and the applicable data protection rules. The data remain under our supervision even when a processor is used.

Within our activities we use the following processors:

• Hosting provider
• E-mail provider
• Social media platforms
• Accounting
• Invoicing

3.3. Data transfers

We transfer your personal data to third parties only in the manner and for the purposes set out in this notice. Beyond this, data may only be transferred in special cases, in order to fulfil a legal obligation applying to the Association, typically at the request of a court or other authority, or if you expressly consent to the transfer.

We keep a separate register of ad hoc data transfers, which we make available to data subjects on request.

3.4. Transfer of personal data to third countries or international organisations

As a controller we transfer personal data to third countries on the basis of your consent or our legitimate interest, but only if we have received appropriate guarantees from our contributors that enforceable rights and effective remedies are actually available regarding your data in the third country.

We do not transfer your personal data to international organisations.

Your right to control your personal data remains during the processing. As a data subject you have the right to access your personal data, to request their rectification, erasure or the restriction of their processing, to object to the processing of your data, and in certain cases the right to data portability.

4.1. Right to information

It is your right as a data subject that we provide concise, transparent, intelligible and easily accessible information about the processing of your personal data, in clear and plain language. We have prepared this notice for this purpose and with this intention.

If we have not been clear or unambiguous enough about the processing of your data, or you have further questions, please contact us with confidence through our contact details.

4.2. Right of access

On request we inform you whether we process your personal data.

After identifying you as a data subject we inform you about the details of the processing.

4.3. Right to rectification

The source of the data we process is primarily you, so please inform us as soon as possible if the data you provided change. If any data we process is inaccurate or incomplete, we rectify it on your request or complete it on the basis of your statement.

After fulfilling the request, where possible, we inform those with whom we shared your personal data. On request we inform you about the recipients with whom the data were shared.

4.4. Right to erasure (“right to be forgotten”)

On the data subject’s request we erase personal data if:

• the personal data are no longer needed for the purpose for which we processed them;
• in the case of processing based on consent, you withdraw your consent and there is no other legal basis for the processing;
• in the case of processing based on legitimate interest or public interest, or for direct marketing, you object to the processing and there are no overriding legitimate grounds for it;
• we processed them unlawfully;
• they have to be erased in order to comply with an applicable legal obligation.

As a controller, after fulfilling an erasure request, where possible, we inform those with whom we shared your personal data about the erasure. On request we inform you about the recipients with whom your data were shared.

4.5. Withdrawal of consent

If we process your personal data on the basis of your consent, you may withdraw your consent at any time without giving reasons. In case of withdrawal, if there is no other legal basis for the processing, we erase the personal data. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.

4.6. Right to restriction of processing

On your request, if one of the following applies, we restrict the processing; accordingly we mark the data and process them separately:

• You contest the accuracy of the personal data. In this case the restriction applies for the period during which we verify the accuracy of the data.
• The processing is unlawful and you oppose the erasure of the data, requesting the restriction of their use instead.
• We no longer need the personal data for the purpose of processing, but you require them for the establishment, exercise or defence of legal claims.
• You object to the processing. The restriction then lasts until it is verified whether our legitimate grounds override yours.

After fulfilling a restriction request, where possible, we inform those with whom we shared the data subject’s personal data. On request we inform you about the recipients with whom your data were shared.

We inform you in advance before lifting a restriction of processing requested by you.

4.7. Right to object

As a data subject you are entitled to object at any time to the processing of your personal data based on the Controller’s legitimate interest.

If, as a controller, we cannot demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, we no longer process the personal data for that purpose.

4.8. Right to data portability

If the processing is based on your consent or on the performance of a contract, and the processing is carried out by automated means, you are entitled to receive the personal data concerning you in a structured, commonly used and machine-readable format, and to have these data transmitted to another controller.

4.9. Exercising rights related to personal data after the death of the data subject

Within five years after the death of the data subject, the rights that belonged to the deceased in their lifetime may be exercised by the person authorised by the data subject through an appropriate declaration made to the Controller. If the data subject made no such declaration, their close relative under the Civil Code is entitled, even in its absence, to request the rectification of the personal data and to object to processing based on legitimate interest.

The person exercising the data subject’s rights must prove the fact and date of the data subject’s death, their own identity and, where applicable, their status as a close relative, with appropriate documents.

If you have a question, comment or complaint about the processing of your personal data, please contact us with confidence through any of our contact details, and we will do everything to answer it or offer you a solution.

As a data subject you may also lodge a complaint directly with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH; contact details at https://naih.hu/) if you consider that your rights have been infringed in connection with the processing of your personal data. To enforce your rights you may also turn to the courts.

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