Privacy Policy

Haris Digital Engineering Limited Liability Company (registered seat: H-8790 Zalaszentgrót, Ady E. u. 13.,
company registration number: 20-06-039575, tax number: 20654498-2-20) (“we,” “us”, “our” or “Data controller”)
as the owner of Haris General Manager (“GM”) and Haris Project Manager (“PM”) as website applications (“Web App”)
available at www.harisdigital.com as main domain and at its subdomains, including,
but not limited to https://www.gm.harisdigital.com,
as well as www.pm.haris-engineering.com (the main domains and
their subdomains hereinafter collectively referred to as “Website”)
and Haris OEE Operator as smart device application (“Smart Device App” or “Operator”)
(Web Apps and Smart Device App hereinafter jointly as “Apps”, individually as “App”) hereby informs you as the user of the Apps (“you”)
that Data controller shall process your personal data in accordance with the provisions of this Privacy Policy (“Privacy Policy”).

1. Name and contact details of the Data controller

   Name of the Data controller:	Haris Digital Engineering Limited Liability Company
   Seat of the Data controller:	H-8790 Zalaszentgrót, Ady E. u. 13.
   Representatives of the Data controller:	Managing Director: Zoltán Péter Perecz
   Phone number of the Data controller:	+36 30 824 7816
   E-mail address of the Data controller:	peter.perecz@haris-engineering.com
   Mailing address of the Data controller:	8790 Zalaszentgrót, Ady E. u. 13.

2. Definitions

   Data processing means any operation or set of operations which is performed on personal data or on sets of personal data,
   whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration,
   retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination,
   restriction, erasure or destruction.

   Data processor means a natural or legal person, public authority, agency or
   other body which processes personal data on behalf of the Data controller.

   Personal data means any information relating to an identified or identifiable natural person (“data subject”); an identifiable
   natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a
   name, an identification number, location data, an online identifier or to one or more factors specific to the physical,
   physiological, genetic, mental, economic, cultural or social identity of that natural person.

   Your company means the company of which devices you are going to take the measurements with our Apps, or the company you represent.

3. Procedure of the Data Processing

   You may use three different versions of the Apps specified in our Terms and Conditions (“TC”) available here.

   If you download the Smart Device App, you are entitled to use the PROJECT Version without authentication;
   therefore you may not provide us with any personal data of yours.

   If you subscribe to BASIC Version or PRO Version, you must create an Account as specified in our TC and you
   shall provide the personal data of yours specified in Section 5 of this Privacy Policy.

   In order to pay the price of the chosen services, you must provide the billing information of
   yours or your company depending on who will perform the payment.

4. Data Processing Obligations of the Data Controller

   We explicitly declare that we are going to process your personal data in accordance with the EU and Hungarian legislation in force,
   in particular, REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection
   of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing
   Directive 95/46/EC (General Data Protection Regulation, “GDPR”) and Act CXII of 2011 on the Right of Informational
   Self-Determination and on Freedom of Information (hereinafter: “DP Act”).

   We explicitly declare that the Data processors involved in our data processing meet the requirements specified as Section 11.

   We explicitly declare that we will not use your personal data for purposes other than specified in Section 8 of this Privacy Policy.

   We explicitly declare that we will delete all your personal data at the end of the term specified in Section 10.

5. Scope of Data Processed

   In case you use PROJECT Version, we do not process any personal data of yours.

   In case you use BASIC Version or PRO Version, we process the following personal data of yours:

   • username,
   • name of your company,
   • e-mail address,
   • password.

   Furthermore, if you (and not your company) pay for your subscription, we process your

   • name,
   • address and
   • credit card information, in particular:
     • credit card number;
     • name of the credit card owner;
     • expiration date of the credit card;
     • CVC.

6. Cookie technology

   We inform you that the operational and maintenance tasks relating to the Website are carried out
   by WebAndMore (company name: Web & More Kft., registered seat: 8912 Hungary, Nagypáli,
   Kisfaludy Stróbl Zsigmond utca 8., company registration number: 20-09-074303, tax identification number: 24985901-2-20)
   and BOOM MARKETING Kft. (company name: BOOM MARKETING Kft., registered seat: 4400 Hungary Nyíregyháza, Kinizsi Pál u. 3.,
   company registration number: 15-09-085107, tax identification number: 26262196-2-15).

   If you visit our Website, we record data which are generated during you visit our Website,
   in particular data relating to your use of our Website and your browsing habits (e. g. time of your visit,
   visited pages, used browser programme; “session details”).

   Data specified in the previous paragraph may reach the Data controller by means of so-called
   “cookie technology” which works as follows: if you allow cookies by ticking the box next to the declaration
   “Allow cookies”, small text files (“cookies”) are sent to and placed on your electronic device, and as a result,
   your browser becomes individually identifiable.

   You may delete cookies from your electronic device and disable their use in your browser.
   Generally, cookies may be managed in Tools / Settings / Privacy Settings in browsers.
   We draw your attention that if you do not allow cookies or you disable their use, the functionality
   of our Website and in particular, the services available on the Website may be limited.

7. Legal basis for the Data Processing

   In principal, the legal basis for the data processing is that the processing is necessary
   for the performance of the contracts – Subscription agreement and EULA available here – to which you are a party [Article 6 (1) b) of GDPR].

8. Purpose of the Data Processing

   We process your e-mail address and password in order to perform the services in accordance with our TC and EULA.

   If your subscription is paid by you, we process your address and credit card information in order to issue our invoice and to receive your payment.

   We explicitly declare that we will not use your personal data for purposes other than the purposes specified in this Section.

9. Means of Data Processing

   We process your personal data by electronic means.

   Your personal data specified in Section 11 of this Privacy Policy are sent to and
   stored in our server operated by Hetzner Online GmbH (company name: Hetzner Online
   GmbH, registered seat: Industriestr. 25, 91710 Gunzenhausen, Tel.: +49 9831 505-0, managing
   directors: Martin Hetzner, Stephan Konvickova, Günther Müller, Court of registry: Ansbach, company
   registration number: HRB 6089, tax identification number: DE812871812, which is accessible only by the employees of Hetzner Online GmbH.

   Your personal data specified in Section 11 of this Privacy Policy are sent to and stored
   in our server operated by HubSpot INC. (registered seat: 02141 Cambridge, USA, 25 First Street,
   2nd Floor, CEO: Brian Halligan) which is accessible only by the employees of HubSpot Inc.

10. Term of Data Processing

    We are obliged to store the invoices for 8 (eight) years in accordance with the provisions
    of Act C of 2000 on Accounting. The invoices shall be linked to the Account; therefore
    we must store all relating personal data for 8 (eight) years from the issuance of the last invoice.

    We declare that after the expiry of the Subscription, we only store your personal data, and we do not process them otherwise.

11. Data processor

    We involve the following entities as Data processors in the data processing for the following purposes:

    Name	Data processed	Purpose
    HETZNER Online GmbH	Username (entered by the user in form of a valid email address), password (generated by the user), sensor data (data collected by the Haris OEE Operator smart device App)	Stores and manages user data as well as sensor data collected by smart devices (the Haris OEE Operator App) Storing these information is necessary for the users to be able to regularly upload, access and manage efficiency related data. This service is provided by the Haris GM web application.
    WebAndMore	Session details via HotJar, Google Analytics and Facebook Pixel	Performing operational and maintenance tasks relating to the Website
    BOOM MARKETING Kft.	Session details via HotJar, Google Analytics and Facebook Pixel. User data vie HubSpot.	Performing of operational and maintenance tasks relating to the Website. Use data for marketing and remarking purposes.
    HubSpot	name, email, phone number,company, address	In order to perform the services (e.g. keep contact with customers, post hardware elements, contact customers for support) information uploaded by the users are stored and managed in HubSpot.
    Hotjar	session details	To be able to enhance the user experience. Registers a unique ID that is used to generate statistical data on how the visitor uses the https://www.hotjar.com/legal/policies/cookie-information
    Google Analytics	session details	To be able to enhance the user experience. Used to send data to Google Analytics about the visitor’s device and behavior. Tracks the visitor across devices and marketing channels.
    Facebook PIxel	session details The Facebook pixel receives these types of data: Http Headers Pixel-specific Data – Includes Pixel ID and the Facebook Cookie. Button Click Data – Includes any buttons clicked by site visitors, the labels of those buttons and any pages visited as a result of the button clicks. Form Field Names – Includes website field names like ‘email’, ‘address’, ‘quantity’ for when you purchase a product or service. We don’t capture field values unless you include them as part of Advanced Matching, conversion tracking, or user properties.	To be able to enhance the user experience, also for marketing purposes. Used to send data to Facebook about the visitor’s device and behavior. Tracks the visitor across devices and marketing channels.

    We may involve other Data processors in the data processing if it is necessary for the achievement of the purposes set out in Section 8.

    We ensure that Data processors provide sufficient guarantees to implement appropriate technical and organisational measures in such a
    manner that processing will meet the requirements of the regulations and ensure the protection of your rights.

    We ensure that the agreements concerning the data processing activities carried out by the Data processors are concluded in writing.

    We ensure that the Data processors:

    • process the personal data only on documented instructions from us as Data controller;
    • ensure that persons authorised to process the personal data have committed themselves to
      confidentiality or are under an appropriate statutory obligation of confidentiality;
    • take appropriate technical and organizational measures regulated by the legislation,
      in order to ensure the security of data processing;
    • at our choice, delete or return all the personal data to us after the end of the provision
      of services relating to processing, and delete existing copies unless Union or
      Hungarian law or any other applicable Member State law requires storage of the personal data.

    Data processors may not make any substantive decision concerning the data processing, Data processors may
    only process the personal data they acquired according to our requests, Data processors may not
    process personal data for their own account, and Data processors shall store and retain personal data
    according to our instructions. In case of any request concerning the acquaintance or transmission of the data,
    we are liable and entitled to make the decision on the merits.

    Data processors may involve further processors only upon our written authorisation.

12. Your Rights Concerning the Data Processing

    We explicitly inform you that

    • you may request from us
      • information on your personal data;
      • access to your personal data;
      • the rectification of your personal data;
      • the erasure of your personal data;
      • the restriction of the processing of your personal data; and
    • you may exercise your right to data portability against us,
    • you are entitled at any time to revoke your declaration of consent to the data processing.

    Based on the right to information, you are entitled to receive information from us in such detail as specified in this Privacy Policy.

    Based on the right to access, you are entitled to get feedback from us on whether the processing of your personal data
    is in progress, and if so, you are entitled to get access to personal data and information concerning data processing
    (the categories of personal data concerned and further data and information concerning the data processing included in this Privacy Policy).

    Based on the right to rectification of personal data, you are entitled to that,
    at your request, we rectify the inaccurate data concerning you without undue delay, and that we complete your incomplete personal data.

    Based on the right to erasure of personal data, you are entitled to that, at
    your request, we erase the personal data concerning you without undue delay, should any of the following conditions exist:

    • the personal data are no longer needed for a purpose specified in Section 8;
    • you revoke your consent to the data processing and the data processing has no other legal basis;
    • you protest against the data processing and there is no high-priority right to process the data;
    • the personal data have been unlawfully processed;
    • the personal data have to be erased for compliance with an obligation in Union or Hungarian law to which we are subject.

    Based on the right to the restriction of the processing of personal data, you may request that personal data,
    with the exception of storage, only be processed with your consent or for the establishment, exercise or defence
    of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public
    interest of the European Union or an EU member state.

    You shall have the right to receive the personal data concerning you,
    which you have provided to us, in a structured, commonly used and machine-readable
    format and have the right to transmit those data to another data controller without hindrance
    from us, considering that the data processing is based on the your consent.

    You are entitled to revoke the declaration of consent any time provided that the legal basis of the data processing is your consent.

13. Your Right to Legal Remedy

    If you wish to enter complaints against the data processing, you may do it at the contact possibilities of us included in Section 1 of this Privacy Policy.

    You may enter your complaint concerning the data processing directly to the National Authority for
    Data Protection and Freedom of Information (address: H-1125 Budapest, Szilágyi Erzsébet fasor 22/c.;
    phone: +36-1-391-1400; e-mail address: ugyfelszolgalat@naih.hu;
    website: www.naih.hu) or another supervisory authority competent by your nationality.

    In case of the infringement of your rights concerning the data processing, you may seize the court.
    The action shall be heard by the competent general court. If you request that, the action may be
    brought before the general court in whose jurisdiction your home address or your temporary residence is located.

14. Miscellaneous

    You explicitly declare that you have read and acknowledged this Privacy Policy by ticking the box next to the declaration specified in our TC.

    This Privacy Policy is valid as of 16 April 2019.

    Haris Digital Engineering Ltd.