DATA MANAGEMENT INFORMATION

Cookie (cookie) management

(Effective: 2024.03.08)

Introducion

For VIG Asset Management Hungar (hereinafter: Asset Management or Controller) the protection of the personal data of its clients and those interested in its products is a priority, and so is the provision of sufficient information to data subjects on the processing of their data.

In light of the above and with a view to relevant legal regulations, in this Policy we provide you with the information you need to make decisions about allowing/rejecting the storage of cookies when visiting the websites we operate.

General information on cookies (http cookies)

What are cookies?

When you visit websites under the scope of this policy, cookies, i.e. small data files are stored on your computer. A cookie may have several purposes, but the general point is that stored cookies provide us with information on your activity when visiting the website. The main purpose of cookies is to make the use of the website easier and more convenient. Cookies may also be used to collect information on the purchasing habits of the user of the website to allow for customised marketing messages. Cookies are created by the web server using the browser of the user (you), where they are stored in a dedicated folder. If the browser sends back a cookie, the web server can link the current information with previous information.

Reading cookies previously downloaded and saved from the website allows us to link your current browsing session with information from a previous browsing session. By linking browsing history and analysing browsing habits we can provide customised user experience to you.

Types of cookies used?

It is important to note that cookies may be our own (first-party) cookies or third-party cookies. First-party cookies are set on the site you visit by the operator of the website, and third-party cookies are set by an external service provider.

Links to other websites

The page may contain links to other websites. Please note that the Controller is not responsible for the cookies/tracking technology solutions used by other websites and the present Policy does not apply to such websites.

Privacy policy regarding cookies (http cookies):

With regard to the processing of personal data in the context of the management of cookies on the websites operated by the Controller, with a view to Regulation (EU) 2016/679 of the European Parliament and of the Council 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 (hereinafter: GDPR), Controller provides the following preliminary information.

Data of the controller:

Name: VIG Asset Management Hungary

Located at: 1091 Budapest Üllői út 1.

Contact: alapkezelo@am.vig

Contact details of the Data Protection Officer:

E-mail: adatvedelem.alapkezelo@am.vig

Purposes of data processing:

Processing purposes under this Privacy Policy:

(1) Cookies essential for the website to function: these cookies are strictly necessary for the functioning or full functionality or the expected quality of the website.

(2) Performance cookies directly help the optimisation of the functioning of the website (e.g. cookies monitoring the customer journey). The latter are used to measure the traffic of the website and the activities of the website’s visitors so that we can keep improving the efficiency of the website.

(3) Marketing cookies are used to track the activities of the visitors on the website. The aim is to display ads that are relevant to the individual users and to engage them, which will make our website more valuable to content publishers and third-party advertisers.

To achieve our data processing purposes, we use our own, first-party cookies and third-party cookies from external service providers. For further details please consult the table.

Legal basic for processing of data:

The legal basis for processing in the case of cookies processed for purpose (1) is the legitimate interest of the controller, such as fulfilling its obligation to provide information to users and the proper functioning of the website; users have the right to object to this type of processing.

The legal basis for processing in the case of cookies processed for purposes (2) and (3) is always the freely given consent of the user/visitor of the website.

Data subjects:

Visitors and users of the publicly available website concerned.

Scope of data processed:

By storing and reading cookies we process visitors’ data related to their use and browsing of the website and related information, in accordance with the data processing purposes.

Source of personal data:

The source of the personal data processed is the data subject user.

Duration of the processing of data:

There are cookies that are stored until the end of a session and other cookies, stored for longer periods. The various cookies are only stored for a period sufficient for achieving their purpose.

Please consult the table for the details.

Third parties, processors, recipients of data

Only personal data of the users that are connected to the management of cookies and are necessary for the purpose are transferred to the service provider of the third-party cookie. For the list of such service providers please consult the table.

Google

Information on the service is available at the following link: https://developers.google.com/analytics/devguides/collection/gtagjs/cookie-usage

https://policies.google.com/privacy?hl=hu

CookieFirst

Information on the service is available at the following link:

https://cookiefirst.com/legal/privacy-policy/

https://cookiefirst.com/legal/cookie-declaration/

Meta:

https://www.meta.com/privacy/policies/cookies/?entry_point=cookie_policy_redirect&entry=0

TikTok:

https://www.tiktok.com/legal/cookie-policy?lang=en

Personal data are not transferred to any other recipient.

Automated decision-making and profiling

During the use of cookies, automated decision-making may be used in certain processes, but these are only processed based on the consent of the data subjects. Please note that in such cases the GDPR exempts the controller from the data subject’s right to request not to be subject to automated decision-making. You have the right to obtain human intervention on the part of the controller, to express your point of view and to contest the decision.

Review, modification and deletion of previous cookie settings:

As a visitor please note that as the primary purpose of cookies is to optimise the usability and processes of a given website, if you disable cookies we cannot guarantee that you can fully use all functions of the website. In such a case the website may not function as intended in the given browser. If, in spite of this, you decide not to use cookies, please delete them from the cookie folder in your browser.

Please note that most web browsers allow the storage and enable the use of cookies as a default. Adjusting the settings of the browser, you may reject cookies, limit their use or disable them, and you can delete previously stored cookies.

We inform our visitors that previous cookie settings may be withdrawn or deleted anytime free of charge. Also, you can set your browser to block cookies or send a notification before cookies are stored. Usually you can access these settings in the “Settings” or “Preferences” menu item of your browser. Please note, however, that if you use an ad blocker, the information about the cookie policy may not always appear. If you wish to read it, please turn off your ad blocker.

If you have further questions, please consult the website ‘All About Cookies’: http://www.allaboutcookies.org

Detailed information on the cookie settings of the following browsers:

Chrome, Firefox, Internet Explorer, Microsoft Edge.

Rights of data subjects in relation to data processing:

Where processing is based on consent, you have to right to withdraw your consent any time, but it shall not affect the lawfulness of processing based on consent before its withdrawal.

Where processing is based on the legitimate interest of the Controller, you have the right to object. In this case your data shall no longer be processed, except when the controller is able to demonstrate legitimate grounds, on the Controller’s side, for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

In the case of processing of personal data for direct marketing purposes, where the Data Subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

Please visit the following link for the detailed content of other rights: https://www.vigam.hu/gdpr/

Legal remedies:

You may file a complaint regarding our data processing with our company at alapkezelo@am.vig, with the Hungarian National Authority for Data Protection and Freedom of Information or with a court of law.

Right to file a complaint with a supervisory authority

Address of the authority: 1055 Budapest, Falk Miksa utca 9–11.

Postal address of the authority: 1363 Budapest PO: 9

Website of the authority: www.naih.hu

For further information on the rights of data subjects please consult the Data Protection section of the www.vigam.hu website.

VIG Asset Management Hungary