PRIVACY POLICY

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I. GENERAL INFORMATION, DATA MANAGER

1.1. Identity and Activities of the Data Controller For the purposes of the data processing specified in
this Prospectus (the “Prospectus” ), the Data Controller shall be Trump Center Ltd. (registered office: 6800 Hódmezővásárhely, Bajcsy-Zs. E. u. 18-22; -mail: info@trump.hu (the "Data Controller" ).

1.2. Governing Law
The Data Controller shall carry out its activities under the laws of the European Union and Hungary. Data processing is primarily governed by the General Data Protection Regulation of the European Union (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. Repealing Regulation (EC) No 46/2006 , hereinafter referred to as "GDPR" ).
In addition, the relevant legislation shall:

• Act XLVIII of 2008 on the Basic Terms and Certain Limitations of Economic Advertising Activities law;
• In the case of potential prize games, the tax liability on winnings is governed by Act CXVII of 1995 on Personal Income Tax. and Taxation Act CL of 2017 law;
• In the case of services rendered against payment of fees, Article 169 of Accounting Act 2000 (concerning the keeping of supporting documents, "Accounting Act" ).

The relevant legislation is available at http://net.jogtar.hu .

1.3. Activities of the Data Controller, Websites
The Data Controller is a company engaged in the development and maintenance of web pages. The Data Controller develops Websites that provide a service to those affected by registration. Services are subject to registration and information. The registration and use of the basic services of each web site is free of charge, however, the Data Controller may make certain services subject to payment of a fee. The Data Controller shall draw the attention of the data subjects to this in all cases.
The services of each website are different (eg news portal, dating, social networking site, etc.). The services of each web site are always accurately represented on that web site.
The Controller operates the following web sites (hereinafter referred to as "Web Site" or "Websites" ):

• Gentleman.hu

1.4. The scope of the Prospectus, the scope of the
present Prospectus, applies solely to the Data Controller's activities in which the processing of personal data is carried out. The scope of this Prospectus covers the data management related to the Websites.
GDPR personal information means any information relating to an identified or identifiable natural person ( "data subject" ); identifiable by a natural person who, directly or indirectly, in particular by reference to one or more factors such as name, number, position, online identification or to one or more factors relating to the physical, physiological, genetic, intellectual, economic, cultural or social identity of the natural person identified.
In the case of data processing covered by this Prospectus, the person contacting the Data Controller, providing his or her data and consenting to the processing of his or her data is concerned.
As a result, information that is not related to natural persons (eg company data) or that is not related to natural persons (eg statistical data, data that is anonymised) is not covered by the scope of this Prospectus.
The scope of this Prospectus is limited to the data management of the Data Controller. Unless otherwise stated, the Prospectus does not apply to the services and data management related to the promotion, prize games, services, other campaigns of third parties who advertise on the Websites or otherwise appear on the Websites, their content. Unless otherwise stated, the Terms and Conditions do not apply to the services and data management of the Website, the Service Providers referred to on the Website.


II. PRINCIPLES, PURPOSE AND LEGAL BASIS OF DATA MANAGEMENT

2.1. Principles of data management
The Data Controller shall treat the data in a lawful, fair and transparent manner. The Data Controller strives to ensure that the data it processes is accurate and up-to-date. The Data Controller shall ensure the rights of the data subject and shall take the necessary measures to ensure that the data processing is lawful at all stages.

2.2. Purpose of Data Management The purpose of Data Management is to maintain Websites, provide services, and carry on advertising activities:

• identification of the person concerned, contact with and communication with the data subject;
• registration, recording of data provided by the data subject;
• providing Web site services, making Web pages available;
• sending advertisements to stakeholders, market research;
• in the case of services rendered against payment of fees, calculation and payment of fees;
• organization, operation and drawing of lotteries;
• notification of winners, distribution of winnings to winners;
• managing and validating claims related to the lottery;
• exercising legal rights and fulfilling obligations;
• fulfillment of legal obligations.

2.3. Legal basis for data processing
Consent of the data subject (Article 6 (1) (a) GDPR)
The legal basis for data processing is primarily the data subject's consent. The Data Controller shall process the data of the data subjects solely on the basis of the data provision of the data subject and with the consent of the data subject. The consent is voluntary, the subject gives his / her consent by registering, giving his / her data and accepting this information. The data subject may withdraw his consent at any time.
Agreement between Data Controller and Data Subject (Article 6 (1) (b) GDPR)
If the data subject uses the fee-based service of the Data Controller, the purpose of the data management is the payment of the fee, collection and provision of the service. In this case, a contract is entered into between the parties, which is governed by the rules of the Civil Code. In this case, the management of the data is carried out in order to perform the contract and to take action at the initiative of the data subject, as referred to in the GDPR.
Compliance with a statutory obligation (Article 6 (1) (c) of the GDPR)
If the winner of the lottery wins, there is a tax liability on the winnings. For the purposes of the declaration and payment referred to in paragraph 1.2. the legislation specified in point.


III. RECORDING OF DATA, SCOPE OF PROCESSED DATA, PROCESS OF DATA MANAGEMENT, PROFILING

3.1. Recording of data
The Data Controller shall collect the data primarily from the data subject. From other sources, Data Controller only records data if the data subject has consented.
Some Websites allow you to register with the profile of another Web site (eg Facebook, Google). In this case, data management is always voluntary. If the data subject connects his or her facebook profile to his or her registration, or registers with his or her facebook profile, the data of the profile is managed by the Data Controller for the purpose of identifying the data subject and ensuring access.
If the referral system operates on the given Website, the data subject may recommend the Website to his / her acquaintances, and the Data Controller will send the relevant link to the data subject. The link may be sent by the data subject to his or her friends, and if the contact clicks on it and then registers, the Data Controller will record that the registration was made by the data subject's recommendation.

3.2. Scope
of the data handled The Data Controller manages the following data about the data subject:
Data necessary to identify the data subject and to maintain contact. The managed data is a username, name, email address. The purpose of data management is to identify the data subject, to keep in touch, and in the case of a draw, to draw lots. The provision of data is always voluntary.
Other information provided in the data sheet.The Data Controller shall use a data sheet on the Website which contains the personal data of the data subject. The information contained in this Datasheet may vary for each Web Site, depending on the services provided by that Web Site. The purpose of data management is primarily to develop the profile of the data subject in order to use the services of the Website effectively. In addition, the purpose of data management is to enable the Data Controller to send to the data subject an advertisement which may be of interest to the data subject, which advertising is the "target group" of the data subject. The provision of data is voluntary and the data subject is not obliged to provide all data.
Gambling data.If the Controller organizes a lottery, it manages the lottery data, the data of the winners, the data on the winnings, the distribution of winnings and the fulfillment of tax obligations. Registration, so participation in the sweepstakes is voluntary. If the data subject wins and accepts his / her winnings, which results in his or her tax liability, tax-related data management is a statutory, mandatory data management.
Data relating to advertisements sent.The Data Controller manages the data which advertisers open and click on in connection with the advertisements sent to the data subject. Data management is related to advertising. Data is used by the Data Controller to send further advertisements to determine which advertisements to send to the data subject. during profiling.
Data relating to fee-based services. In the case of services subject to a fee, the Data Controller shall manage the data related to the given service, the fee payable and the method of payment for the purpose of providing the service and settlement.

3.3. The process of data management
The data subject may register voluntarily on the Website, registration is not compulsory, and failure to register does not cause any disadvantage to the data subject. If the data subject registers and provides his or her data, the data controller will manage the data and will subsequently send advertising to the data subject. The Controller draws lotteries during the Sweepstakes as defined in the Game Rules and notifies the winners.
Stakeholders shall have the right at any time to prohibit the sending of further advertisements or to request the deletion of their data.

3.4. Profiling for advertising purposes
Profiling is any form of automated processing of personal data under the GDPR whereby personal data is used to evaluate certain personal attributes of a natural person, in particular work performance, financial status, health, personal preferences, interest, reliability, behavior, location or is used to analyze or predict motion-related characteristics.
The Data Controller creates profiling on the Website in the course of advertising.
If the data subject registers, the Data Controller is entitled to send advertising to the data subject until his / her consent is withdrawn. In determining the content of the advertisements, the Data Controller shall use the data provided by the data subject. What offers appear in the advertisement is the result of profiling. In doing so, the computer program conducting the advertisement evaluates the data available to the Data Controller in a closed manner, without human intervention. Based on this data, the program determines whether the data subject is the target audience for the advertisement to be sent. After sending the advertisement, the Data Manager will delete the entire profile creation.
The purpose of profiling is solely to decide what kind of advertising to send to the data subject.
The legal basis for profiling is the consent of the data subject.
The data subject has the right to request information about profiling. The data subject shall have the right to be heard. The data subject may prohibit profiling.


ARC. SOME DATA MANAGEMENTS

4.1. Provision of Services
Description of Data Management : The Data Controller manages data related to the services of the Website and the use of the Services. The Data Manager manages the data subject's registration and profile, ensures access to the Websites and the use of the services.
Scope of Data Management : All data of the data subject required to use the Website.
Purpose of data management :

• identification of the person concerned, contact with and communication with the data subject;
• registration, recording of data provided by the data subject;
• providing Web site services, making Web pages available;
• sending advertisements to stakeholders, market research;
• in the case of services rendered against payment of fees, calculation and payment of fees;
• organization, operation and drawing of lotteries;
• notification of winners, distribution of winnings to winners;
• managing and validating claims related to the lottery;
• exercising legal rights and fulfilling obligations;
• fulfillment of legal obligations.

Legal basis for the data management : The legal basis for the data management is the consent of the data subject.
Duration of Data Management: Data will be deleted by the Data Controller if the data subject so requests or objects.

4.2. Data management for advertising purposes
Description of data management : The primary activity of the data controller is advertising. The Data Controller builds its database for the purpose of sending advertising to those concerned. Participation in the prize games organized by the Data Controller is free of charge, so participation is subject to registration and consent to the sending of advertisements. The data subject may withdraw his consent at any time.
The Data Controller shall regularly send advertising to the data subject until the data subject has withdrawn his or her consent.
In the course of advertising, profiling takes place, as described in section 3.4. as defined in point.
Scope of data handled : The e-mail address of the data subject, in the case of postal mail, the e-mail address of the data subject, the data provided by the data subject on the Website.
Purpose of data management : The purpose of data management is advertising.
Legal basis for the data management : The legal basis for the data management is the consent of the data subject.
Duration of Data Management: Data will be deleted by the Data Controller if the data subject so requests or objects.

4.3. Gambling Data
Management Description of data management: The Data Controller organizes sweepstakes. Participation in the Sweepstakes is not subject to wagering or purchase, so the Sweepstakes is not considered as a Sweepstakes Required for License or Notification. In the context of the Sweepstakes, the Controller manages the participant data necessary for the draw. During the draw, the Controller draws on the basis of the e-mail addresses as defined in the rules of the game and then notifies the winners. The prizes will be distributed in accordance with the rules of the game. The Data Controller shall comply with the tax obligations relating to the winnings.
The Controller shall publish the names of the winners on the relevant web site, unless prohibited by the data subject. If the data subject submits his / her photo to the Data Controller, the Data Controller will publish the photo.
Scope of data handled : Data provided by the data subject: gender, last name, first name, email address. If the winner of the prize wins, he or she must also provide the other details needed to receive the prize.
Purpose of data management : The purpose of data management is to conduct the lottery, draw lots, inform the winners and distribute the winnings.
Legal basis for the data management : The legal basis for the data management is the consent of the data subject. During registration, the data subject declares that they consent to the processing of their data as set out in this Notice. The statement of acceptance and the provision of data shall constitute consent.
Duration of data management: Data Controller deletes data when the purpose of data management has ceased to exist. The Data Controller will always delete the data if the data subject so requests.

4.4. Data Management for Fee-
Based Services Description of Data Management : If the data subject is using a fee-based service, the Data Controller will manage the data related to that service, the fee payable and the payment of the fee.
Scope of data managed : The user name, name, email address of the data subject, service and fee details.
Purpose of data management :

• in the case of services rendered against payment of fees, calculation and payment of fees;
• exercising legal rights and fulfilling obligations;
• fulfillment of legal obligations.

Legal basis for data management : The legal basis for data management is the consent of the data subject and, in the case of payment, the Accounting Act.
Duration of Data Management: Data will be deleted by the Data Controller if the data subject so requests or objects. According to the Accounting Act, the data related to the vouchers shall be processed by the Data Controller for eight years.


V. OTHER INFORMATION CONCERNING DATA MANAGEMENT

5.1. Transmission
The Data Controller shall transfer personal data to a third party only if the data subject has expressly consented to the transfer of data and the recipient of the data transfer or if the Data Controller has an appropriate legal basis for the transfer.

5.2. Data security, access to data
The Data Controller ensures the security of the data, takes the technical and organizational measures and establishes the rules of procedure that ensure the fulfillment of the data security requirement. The Data Controller shall keep records of the data handled by it in accordance with the applicable laws and regulations, ensuring that the data are accessible only to employees and other persons acting in the interest of the Data Controller who need them in order to perform their duties and duties. All persons acting in the interest of the Data Controller shall be entitled only to access the data necessary for the performance of the duties of the named person. The named persons are obliged to keep the data confidential.
In particular, in the context of his IT security responsibilities, the Data Controller shall ensure:

• Measures to protect against unauthorized access, including protection of software and hardware devices, and physical protection (access protection, network protection);
• Measures to ensure that data files can be restored, including regular backup and separate secure management of copies (mirroring, backup);
• Protection of data files against viruses (virus protection);
• Physical protection of data files and their storage media, including protection against fire, water damage, lightning, and other material damage, and recoverability of such events (archiving, fire protection).

The Data Controller shall take the necessary measures to protect the paper records, particularly as regards physical security and fire protection.
Employees, agents and other persons acting on behalf of the Data Controller, irrespective of the way in which the data are recorded, are required to keep and protect the data media which they use or possess.

5.3. Technical data and cookies
When a person visits the Website, the system associated with the Website automatically records the user's computer IP address, the time of the visit, and in some cases, depending on the configuration of the computer, the type of browser and operating system. The data recorded in this way cannot be linked to any other personal data. Data management is for statistical purposes only.
Cookies allow the Website to recognize previous visitors. Cookies help Data Controller, as the operator of the Website, to optimize the Website in order to tailor the services of the Website to the users' habits. Cookies are also suitable for

• remember the settings so you don't have to re-record them when you go to a new page,
• they remember previously entered data, so they don't have to be typed again,
• analyzing the use of the website to ensure that the results obtained by using the information obtained so function as much as possible in accordance with the user's expectations, and that the user can easily find the information he or she is seeking, and
• monitor the effectiveness of our ads.

If the Data Controller displays various content on the Website using external web services, it may result in the storage of some cookies that are not managed by the Data Controller, and thus have no control over what data these web sites or external domains collect. These cookies are described in the policies for that service.
Data Manager uses the Google Analytics cookie to collect website traffic statistics.
The Data Controller employs a Facebook remarketing code that can be used to visit website visitors with Facebook remarketing ads later. The remarketing code uses cookies to identify to Facebook that a visitor has visited the Website.
Data Controller employs the Google Adwords Remarketing cookie, which, like the Facebook remarketing cookie above, allows visitors to the Website to serve ads later on the Google Network.
A user can configure their web search engine to accept all cookies, reject all cookies, or notify the user when a cookie is received on their machine. Configuration options are usually found in the "Options" or "Settings" menu of your browser.
The detailed information at www.aboutcookies.org also helps you to configure different browsers.

5.4. Data processing
The Data Controller is entitled to use a data processor to carry out its activities. The data processors do not make any independent decision, they are only entitled to act according to the contract concluded with the Data Controller and the instructions received. The Data Controller controls the work of the data processors. Data processors are only entitled to use additional data processors with the consent of the Data Controller. The Data Controller shall publish the data of the data processors it uses. Data Controller uses the following data processors:

• World Web Data Kft. (1043 Budapest, Árpád út 56. I. floor 2.), IT services, development;
• Marco Polo Magyarország Kft. (1042 Budapest, Árpád út 56. I. floor 2.), advertising and marketing services;
• Balance International Ltd. (1111 Budapest, Lágymányosi utca 12 st. 2), operation of payment systems.

5.5. Duration
of Data Management The Data Controller shall ensure, by establishing and complying with the deletion rules, that the duration of the processing of personal data does not exceed what is necessary and lawful. Data will be deleted in the following cases:

1. Personal data are no longer needed for the purpose for which they were collected or otherwise processed. If the purpose of data management has ceased to exist and the data management is not required by law, the Data Controller shall delete the data.
2. The data subject shall withdraw his consent. If the data subject withdraws his consent or requests the deletion of the data, the Data Controller shall delete the data in each case. Deletion can only be denied if prohibited by law or official regulations. If the winnings are subject to tax, the Data Manager will only delete the tax information if the statutory deadline has expired.
3. The data subject protests against the data management. If the data subject objects to the data management for advertising purposes, the Data Controller shall delete the data related to it.
4. It becomes clear that the processing of the data is unlawful. If the processing of the data is unlawful, the Data Controller shall delete it in any case as soon as the fact of unlawful processing becomes apparent.
5. The deletion of the data is required to fulfill a legal obligation, or has been ordered by a court or the National Data Protection and Freedom of Information Authority. If deletion is mandatory by law, or ordered by a court or Authority, and the order is final, the Data Controller shall delete the data.

5.6. Managing privacy incidents
A privacy incident is a security breach that results in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or unauthorized access to personal data transmitted, stored or otherwise processed. The Data Controller shall immediately notify the Data Protection Incident to the National Data Protection and Freedom Authority, unless the Data Incident is unlikely to endanger the rights and freedoms of the data subject. The Data Controller shall keep records of data protection incidents, together with the measures related to that incident. If the incident is serious (ie, it is likely to pose a high risk to the data subject's rights and freedoms), the Data Controller will inform the data subject about the data protection incident without undue delay.


VI. RIGHTS AND ENFORCEMENT OF STAKEHOLDERS

6.1. Stakeholders' rights
Information (access). The data subject has the right to be informed about the management of his or her data. The Data Controller informs the data subject about the data processing when collecting the data, and this Information is available to the data subject at any time. The data subject may at any time during the processing of the data request full information on the management of his or her data. The data subject may request the Data Controller to provide a copy of the data.
Correction. The data subject may request the Data Controller to correct inaccurate data concerning him or her, to supplement the incomplete data.
Cancellation, withdrawal of consent.The data subject may, at any time, withdraw his / her consent to the processing of his / her data and request the deletion of his / her data. The Data Controller shall only refuse deletion if the data processing is based on law or the data processing is necessary for the filing, enforcement or protection of legal claims.
Restriction. The data subject shall have the right to request a restriction of data processing in the following cases:

1. the data subject disputes the accuracy of the personal data, in which case the limitation relates to the period during which the controller can verify the accuracy of the personal data;
2. the processing is unlawful and the data subject opposes the deletion of the data and calls instead for a restriction on their use;
3. the controller no longer needs personal data for the purpose of processing, but the data subject requires them to make, assert or defend a legal claim;
4. the data subject objected to the processing; in this case, the restriction shall apply for a period until it is established whether the legitimate grounds of the data controller prevail over those of the data subject.

Where personal data processing is subject to restrictions, such personal data may only be processed with the consent of the data subject, except for storage purposes, or for the purpose of making, enforcing or defending legal claims or protecting the rights of other natural or legal persons .
Protest.If the data management is based on the legitimate interests of the Data Controller or a third party, the data subject shall have the right to object at any time to the processing of his / her personal data for reasons related to his / her situation. In this case, the controller may not further process the personal data unless the controller proves that the processing is justified by compelling legitimate reasons, which take precedence over the interests, rights and freedoms of the data subject, or which are necessary for the establishment, exercise or defense of legal claims. related. Where personal data are processed for the purposes of direct business, the data subject shall have the right to object at any time to the processing of personal data relating to him for that purpose.
Data Portability.The data subject shall have the right to receive his or her personal data in a structured, widely used, machine-readable format and to transfer such data to another data controller provided that the data are processed in an automated manner. The data subject shall have the right to request the transfer of personal data directly to another controller, where technically feasible.

6.2. Safeguarding the rights of the data subject, processing the data subject's requests
The Data Controller shall inform the data subject about the handling of the data at the time of contact. Upon request, the Data Controller shall make this Prospectus available to the data subject and make it available on the Company's website. The Controller also has access to the present Detailed Information, of which the Controller shall draw the attention of the Controller to the fact and availability thereof. The Data Controller shall make available to you a notice prepared on the basis of this Prospectus and containing the main data protection rules.
The request for exercise of rights by the data subject shall be made in accordance with point 1.1. You may submit it to the Data Controller by means of one of the contact details set out in point. The Data Controller shall promptly review the request, decide whether to comply with the request and take the necessary measures. The Data Controller shall inform the data subject of the measures taken within one month. In all cases, the information shall include the action taken by the Data Controller or the information requested by the data subject. If the Data Controller refuses to comply with the request (failing to take the necessary steps to comply with the request), the information shall include the grounds for refusal, the reasons for such refusal and the remedies available.
The Data Controller is not bound by the fulfillment of the application to the payment of a fee or the reimbursement of costs.
If, due to the circumstances and the manner in which the application is submitted, it is not certain that the application originates from the data subject, the Data Controller may request the applicant to prove its eligibility or to present the application in such a way that eligibility is clearly established.
Unless it proves impossible or requires a disproportionate effort, the Data Controller shall inform any recipient to whom the personal data have been communicated or rectified, deleted or restricted. At the request of the data subject, the controller shall inform those addressees.

6.3. remedy
In case of violation of his / her rights, the data subject may request that the Data Controller terminate the unlawful data processing, investigate the data processing and the rejection of the data subject's application. The Data Controller shall always investigate the complaint of the data subject and inform the data subject of the result.
Stakeholders may submit their complaints under section 1.1. .
The complainant may contact the National Data Protection and Freedom of Information Authority directly (address: 1125 Budapest, Szilágyi Erzsébet fasor 22 / c; phone: + 36-1-391-1400; e-mail: ugyfelszolgalat@naih.hu; website: www. naih.hu ).
The data subject is entitled to take legal action in case of violation of his rights. The Data Controller shall, upon request, inform the data subject in detail of the court having jurisdiction and jurisdiction to file a lawsuit and of the possibility of legal action.