ODCR Privacy Policy EN
PRIVACY POLICY
of the ODCR smartphone application
When we talk about data and personal data in this Privacy Policy, we mean personal data which identify you or which could be used to identify you such as your name and contact details.
1. Who is responsible for your data?
MILMED COE is responsible for your data. MILMED COE is accredited as a NATO centre of excellence and activated as an international military organization by the North Atlantic Council. We are the data controller of the data which we collect from you, and as such we control the ways your personal data are collected and the purposes for which your personal data are used.
Our contact information is:
Headquarters: 44 Róbert Károly körút, H-1134 Budapest, Hungary;
Postal address: H-1555 Budapest, P.O. Box: 66, Hungary;
Email address: info@coemed.org
Website: www.coemed.org
Phone: +361 8830100
Fax: +36-1-8830127
2. Data we collect about you
Automatically collected non-personal data about your device, your location and how you use our software. This data cannot be allocated to a specific person.
enquiring IP address exact date and time of download name of the downloaded file message whether the download was successful transferred data volume used operating system and version number description of the used web browser type | whenever you install and use our ODCR software and whenever you download a file in a log file |
We will not collect any other personal data unless you provide this data on a strictly voluntary basis. This can be the case, for example, during a registration requested by you and installation of our ODCR software
your name and contact detail (email address) (required) | when you install our software and when you fill in the personal information form |
your NATO rank, service and command/organization (optional) | when you install our software and when you fill in the personal information form |
Sensitive personal data
We do not collect and process any sensitive personal data.
We would like to draw your attention that in the event you submit an observation it cannot contain any personal data of an natural person, with particular attention to sensitive data such as health related data.
3. How we use your personal data and legal grounds
We can only use your personal data if we have a proper reason for doing so. According to the law, we can only use your data for one or more of these reasons:
• When you consent to it, or
• To fulfil a contract we have with you, or
• If we have a legal duty to use your data for a particular reason, or
• When it is in our legitimate interests.
We do not collect and process any sensitive personal data.
We would like to draw your attention that in the event you submit an observation it cannot contain any personal data of an natural person, with particular attention to sensitive data such as health related data.
3. How we use your personal data and legal grounds
We can only use your personal data if we have a proper reason for doing so. According to the law, we can only use your data for one or more of these reasons:
• When you consent to it, or
• To fulfil a contract we have with you, or
• If we have a legal duty to use your data for a particular reason, or
• When it is in our legitimate interests.
In the table below, we have set out the different ways in which we use your personal data and the reasons we rely on for using that data. If we rely on our legitimate interests for using your personal data, we will explain that to you.
What we use your personal data for | Legal grounds for using it | Our legitimate interests |
Communicating with you regarding your observation | Our legitimate interests With your consent | Keeping our records up to date Developing products and services |
4. How long we keep your data
We keep your data only for as long as we need it. How long we need data depends on what we are using it for, for our own legitimate interests (described above) or so that we can comply with the law.
We will actively review the information we hold and when there is no longer a customer, legal or business need for us to hold it, we will either delete it securely or in some cases anonymize it.
5. How we protect your data
We protect your personal data against unauthorized access, unlawful use, accidental loss, corruption or destruction.
We use technical measures such as encryption and password protection to protect your data and the systems they are held in. We also use operational measures to protect the data, for example by limiting the number of people who have access to our databases.
We keep these security measures under review and refer to industry security standards to keep up to date with current best practice.
6. Sharing your data
We DO NOT share your personal data with, or obtain personal data from, the following category of third parties:
6.1. Suppliers who provide services to us:
We will share your data with
a) the company which provides IT development for us.
We will make sure that our suppliers respect your personal data and comply with data protection laws.
7. Your rights
You are entitled to see copies of all personal data held by us and to amend, correct or delete such data. You can also limit, restrict or object to the processing of your data.
We keep your data only for as long as we need it. How long we need data depends on what we are using it for, for our own legitimate interests (described above) or so that we can comply with the law.
We will actively review the information we hold and when there is no longer a customer, legal or business need for us to hold it, we will either delete it securely or in some cases anonymize it.
5. How we protect your data
We protect your personal data against unauthorized access, unlawful use, accidental loss, corruption or destruction.
We use technical measures such as encryption and password protection to protect your data and the systems they are held in. We also use operational measures to protect the data, for example by limiting the number of people who have access to our databases.
We keep these security measures under review and refer to industry security standards to keep up to date with current best practice.
6. Sharing your data
We DO NOT share your personal data with, or obtain personal data from, the following category of third parties:
6.1. Suppliers who provide services to us:
We will share your data with
a) the company which provides IT development for us.
We will make sure that our suppliers respect your personal data and comply with data protection laws.
7. Your rights
You are entitled to see copies of all personal data held by us and to amend, correct or delete such data. You can also limit, restrict or object to the processing of your data.
If you gave us your consent to use your data you can withdraw your consent. Please note that even if you withdraw your consent, we can still rely on the consent you gave as the lawful basis for processing your data before you withdrew your consent.
You can object to our use of your data where we rely on our legitimate interests to do so. We explained the legitimate interests we rely in the table above under the heading ‘How we use your personal data’.
To raise any objections or to exercise any of your rights, you can send an email to us. Our contact information can be found above.
When you get in touch, we will come back to you as soon as possible and where possible within one month. There is no charge for such requests. We may also ask you to verify your identity before we provide any information to you.
The detailed list of your rights list:
7.1. Right of access: it means a.) you have the right to know whether your data (and what kind of personal data) are being processed and b) if so, access it with loads of additional stipulations;
7.2. Right to rectification: when your personal data are inaccurate, then we need to correct them indeed, upon your request;
7.3. Right to erasure or right to be forgotten includes erasing your personal data whenever you request so and there are no legitimate ground for retaining it;
7.4. Right to restriction of processing: you can to limit the processing of your personal data
7.5. Right to be informed:
7.5.1. you are entitled to be provided with all the following information:
a) person and contact info of data controller and data processor
b) purpose and legal ground of data processing
c) if the legal ground of data processing is someone’s legitimate interest description of such interest
d) addressees of personal data if data are shared
e) if your persona data are sent outside of the European Economic Area.
7.5.2. Furthermore, you are entitled to be informed about
a) duration of data processing
b) your rights concerning the data processing, such as right to access, erase, ask for correction, limit the data processing, object, and right to data portability
c) your right to withdraw your consent to data processing
d) your right to complain
e) whether the legal ground of data processing is contractual obligation or based on laws
f) decisions based solely on automated processing, if any
7.6. Right to data portability: you ask the data processor to give back the personal data as required and allow the transfer to another data processor.
7.7. Right to object: you can object to the processing pf special conditions apply. Also, quickly respond and demonstrate legitimate grounds. Simply said, you can say you do not want the personal data processing to be done or going on.
7.8. Right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
8. Complaints
If you have any complaints concerning our data processing please contact us by using one of our contact details written above.
Please note that you have the right to lodge a complaint with the supervisory authority which is responsible for the protection of personal data in the country where you live or work, or in which you think a breach of data protection laws might have taken place.
In Hungary the supervisory authority is
Hungarian National Authority for Data Protection and Freedom of Information
(Nemzeti Adatvédelmi és Információvédelmi Hatóság)
H-1125 Budapest, Szilágyi Erzsébet fasor 22/C.
Phone: +36 -1-391-1400
Fax: +36-1-391-1410
E-mail: privacy@naih.hu
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