Privacy Policy

Introduction

The purpose of this Privacy Policy (“Policy”) is to explain how, when and why WALLZ Csoport Kft. (hereinafter referred to as “Wallz”) collects information about individuals, how, for what purposes and on what grounds these ‘personal data’ are subsequently processed, who processes them and what rights the individuals have in connection with their personal data. The Policy also explains Wallz’s practices in using cookies and other technologies for storing information on others’ devices and retrieving information from such devices.

When we refer to “Wallz” or use the word “we”, “our” or “us”, we mean the Wallz entity that acts as the ‘controller’ of the information we hold about you or the ‘processor’ of the information that a customer has entrusted to us, as explained in more detail under the “Identifying the data controller” part of this Policy. The contact details are set out at the end of this Policy.

By “you” we mean the individual reading this text, i.e., you as a natural person (and not any company or other organisation that you may be associated with).

Some words and phrases in this Policy are in single quotation marks (e.g., ‘controller’, ‘processor’ and ‘data subject’). These are legal terms, having the same meanings as given to them in the EU General Data Protection Regulation, i.e., Regulation (EU) 2016/679 (“GDPR”).

Principles

We adhere to the following principles when processing personal data:

a) We process personal data lawfully, fairly, and transparently
b) We collect personal data for specified, explicit, and legitimate purposes and do not further process the data in a manner that is incompatible with those purposes
c) The personal data we collect and process is adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed
d) We take reasonable steps to ensure that personal data is accurate and, where necessary, kept up to date. We also take prompt action to rectify or erase any inaccurate or incomplete personal data.
e) We store personal data in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
f) We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage.

We process your personal data:

a) Based on your consent, which is freely given, specific, informed, and unambiguous, in accordance. We process your data only to the extent necessary for the purposes for which you have given your consent.
b) In certain cases, processing your personal data is necessary for compliance with a legal obligation to which we are subject.
c) In some cases, the processing of your personal data is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms. We will provide you with further information about such legitimate interests when we process your data.

Application

This Policy applies to the data processing that takes place through or in connection with: (a) your use of the service of Wallz. We shall use the word “Service” in this Policy to designate any service, resource or other benefit that Wallz offers; (b) your visiting, or accessing resources that form part of the website of Wallz (www.wallz.io); or (c) your communication or interaction with Wallz; insofar as the above activities are not subject to another privacy policy or similar document.
The Policy does not apply in relation to other parties’ products, services, websites, resources or activities.
When we speak of “Personal Data”, we mean any information about a living individual from which that person can be identified (the proper legal definition of ‘personal data’ is “any information relating to an identified or identifiable natural person”, with the person to whom the information relates being referred to as the ‘data subject’). Personal Data do not include information from which no individual can reasonably be identified, that is to say, anonymous information or personal data rendered anonymous in such a manner that the individual is not, or no longer is, identifiable (de-identified or anonymised information). The Policy does not apply to such information.
The Policy supplements our other terms and policies and is not intended to override them.

Identifying the data controller

We are a technology company and our service involves data processing in one way or another. Data need to be processed in a number of ways in order for us to carry on our business, including provide, maintain and develop the Service and Website, and to communicate with you.
Wallz is the ‘controller’ of the Personal Data that are collected by us or on our behalf through the activities listed in section 1 of this Policy, or which are otherwise processed for the purposes of our business. Specifically, it is Wallz that acts as the ‘controller’ of the said Personal Data. The following sections explain the collection and subsequent processing of these data in more detail.
Wallz is using sub-processors to provide service development, service delivery, and customer support services for all our products.

Sub-processor	Resource/service provided	Location of entity
Amazon Web Services, Inc.	Cloud infrastructure (IaaS)	US
Apple, Inc.	Cloud-based email services	US
GitHub, Inc.	Issue management	US
Google, Inc.	Analysis services	US
PandaDoc, Inc.	Contract creation and electronic signatures	US

You can read more information about third-party cookies here:

https://policies.google.com/technologies/cookies?hl=en#types-of-cookies

https://www.apple.com/legal/privacy/en-ww/

https://www.pandadoc.com/privacy-notice/#thirdparty

The information we collect and receive

Wallz collects, generates and receives information in a variety of ways. Some of this information constitutes Personal Data and the rest does not. We shall use the word “Information” to designate any and all of the data that are collected, generated or otherwise processed by us or on our behalf. This part of the Policy describes which Information and how is collected or generated through the activities listed in section 1.

9. Profile Information

We collect Information about you in the course of negotiating, preparing, concluding and amending agreements between you and Wallz. The Information collected may include the data provided in such agreements and any data that you furnish for the purposes of negotiating, concluding or amending those agreements.

Usage Information

As with most websites, certain data are automatically collected when you visit a Website. For example, accessing resources on our Website, result in the following Information being collected: your IP address, approximate location, Website entry and exit pages, referral sites and keywords, session time and duration, activities on the Website (e.g., pages viewed, links followed, clicks made), web browser type, version and settings (including, e.g., language preferences), device type, name and settings as well as the type and version of its operating system, and your internet service provider or mobile network operator. Some of this Information is collected by the use of cookies, as described in the next section.

Cookie Information

When you visit our Website or retrieve resources (e.g., files or other information) that form part of our Website, certain pieces of data known as cookies are sent to the device you are using and will be stored there. Your web browser stores them either at our request or the request of a third party whose services we use. Each cookie, in one way or another, distinguishes you from other Users and Website visitors. There are also other techniques, such as using web beacons or pixels, whose purpose can be similar to that of some cookies. In this Policy, the word “cookie” designates the objects delivered by those techniques as well.

Cookies vary by nature and purpose. For instance, a “session cookie” only exists in the temporary memory of your device, i.e., while your Service session or visit to a Website lasts, and is usually deleted when your web browser is closed. A “persistent cookie”, on the other hand, has a longer lifespan: it remains on your device until you delete it (i.e., instruct your browser to do so) or until it expires. A “secure cookie” can only be sent over a “secure” (encrypted) connection, making it harder for others to intercept information. A “first-party cookie” belongs to us and a “third-party cookie” belongs to someone other than Wallz, e.g., a company providing us with Service or Website analysis services or delivering our messages (such as advertisements) across the internet.

Some of the above cookies allow us (or third parties we have engaged) to recognise and count the number of visitors to a Website, see how they move around the site when using it, which links they follow and who reads what, or to selectively record and analyse how and by what means Users are interacting with us (only specific pieces of information are collected, and without identifying the Users). Certain cookies are used to recognise you when you return to a Website, enabling us to personalise our content for you and remember your preferences, e.g., your choice of language. And, quite importantly from the privacy aspect, there are some third-party cookies that gather information about your browsing activities over time and across different websites following your use of ours (in other words, track your online behaviour), which may result in advertisements or other messages being displayed to you based on your browsing history.

You will encounter all of these cookies when interacting with our Website or web resources. Cookies are vital to the Service and Website. You can, however, remove them (individually, in selections or all in one sweep) and it is possible to disallow their use altogether or refuse certain types of them (your browser tools or support pages will tell you how to do that). But, if you disallow first-party cookies, your copy or instance of the Service will not operate properly or may not operate at all and your experience at our Website will be notably poorer or at least not as we intended.

Third-party cookies can usually be managed by the tools provided by those parties. Contact us, using the details at the end of this Policy, to learn which third-party cookies may currently be in use on our Website or use your browser tools to get an overview about cookies we use.

Our Website do not respond to web browsers’ “do not track” signals and our data processing practices are not altered upon our receipt of such a signal.

In order to use non-strictly necessary cookies, we must obtain your consent, in accordance with GDPR regulations. By continuing to use our Website, you are giving your consent to our use of cookies as described in this Policy. If the device you are using is not your own, we expect you to have the owner’s authorisation to agree on their behalf with our storing cookies on the device and retrieving information from it as described in this Policy. By using the device you are confirming to us that you are authorized to give such consent.

You have the right to withdraw your consent at any time by disabling cookies or adjusting your cookie settings. Please note that disabling certain cookies may impact the functionality and performance of our Website.

If you have any questions or concerns regarding our use of cookies or this Policy, please contact us using the contact details provided at the end of this Policy.

We may update this Policy from time to time. Any changes we make will be posted on this page, and if significant, we will notify you via email or a notice on our Website. Please check this page regularly to stay informed about our use of cookies and related policies.

Cookie Type	Consent Required	Description	Purpose
Strictly necessary cookies	No	These cookies are essential for the website to function properly.	To provide basic website functionality.
Performance cookies	Yes	These cookies collect information about how visitors use the website, such as which pages are visited most often, and if they receive error messages from web pages.	To analyze and improve the performance of the website.
Functionality cookies	Yes	These cookies allow the website to remember choices you make (such as your language or the region you are in) and provide enhanced, more personal features.	To personalize the user experience and remember user preferences.
Targeting/Advertising cookies	Yes	These cookies are used to deliver advertisements that are relevant to you and your interests. They may also be used to limit the number of times you see an advertisement and help measure the effectiveness of advertising campaigns.	To deliver targeted advertising and measure ad campaign effectiveness.

“Third-Party Information”

A User can choose to permit third-party services. Typically, a third-party service is software that integrates with the Service and a User can enable or disable this integration. Once enabled, the relevant third-party service provider may share certain information with us. You should check the privacy settings of these third-party services to understand what data may be disclosed to us.

“Other Information”

We receive from you such Information as you provide us when filling in our form on our Website or when you participate in our Service-related campaigns or programmes, sign up to receive notifications, newsletters or other communications from us, request support for the Service, interact with our social media accounts or correspond or otherwise communicate with Wallz. If you email us or send us a letter or a message, we may retain a record of such communication, including your name and address, email address or telephone number (as applicable), the content of your communication and our response. We may complement these data with other Information.

Purposes and grounds for Information processing

The purposes for which Information is processed and the legal grounds for such processing are varied and depend on the nature of the Information. If Information is anonymous or de-identified, we may collect, use, disclose and otherwise process it for any purpose. Our processing of Personal Data, however, is limited to the purposes set out in this Policy.
Most commonly, we will process your Personal Data in the following circumstances: (a) if we need to perform an agreement you have with us or it is necessary to take pre-contractual steps at your request before entering into such an agreement (we shall refer to these grounds as “Contractual”); (b) where we need to comply with a legal obligation, e.g., one arising from a law or regulation concerning taxation, accounting, financial reporting, prevention of terrorism or money laundering, or judicial or administrative process (this would be a “Legal” ground); (c) if it is warranted by our legitimate interests or those of a third party and such interests are not overridden by yours or your fundamental rights and freedoms (here, the processing would be based on “Interest”); (d) where we have your unambiguous consent before processing your Personal Data in that specific situation (thus allowing us to process these data on the grounds of “Consent”).
Each of the categories of Information described under sections 9 – 13 may include your Personal Data but not all those categories may apply to you. The table below sets out the purposes for which your Personal Data in the specified category of Information will or may be stored, used, disclosed or otherwise processed, and which of the above grounds we rely on when doing so. Where the processing is based on Interest, we have also identified what the legitimate interest in that particular case is. Please note that we may be processing the same pieces of your Personal Data for several purposes simultaneously and, respectively, on more than one legal ground (e.g., on a Contractual basis as well as based on Interest, and perhaps also on a Legal ground). Contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been listed. Note also that not each piece of Personal Data in a particular category of Information is processed for all the purposes specified in connection with that category (and on the grounds corresponding to those purposes). Contact us if you wish to know which of the said purposes precisely and in what circumstances applies to the processing of a specific piece of your Personal Data. Our contact details are provided at the end of this Policy.

Profile information

Purpose	Grounds
Negotiating, preparing, concluding, performing, amending and enforcing our agreements with you (incl. particularly agreements concerning the Service) and exercising our rights under such agreements	Contractual, Legal, Interest (recovering debts due to us, enjoying and defending our rights, negotiating new terms or amending existing ones to reflect changes in circumstances or to better suit our interests and/or yours)
Keeping our records updated	Legal
Contacting you on matters relating to the Service or your agreements with us or in connection with matters that may affect you, and replying to your communications	Contractual, Legal
Delivering messages to you, invitations to become a User	Interest (performing our agreements with the Users)
Sending you communications you have subscribed or otherwise agreed to receive	Interest (providing you with information we find relevant and reasonably believe is of interest to you)
Investigating Service-related illegal conduct, violations of contract and (actual or suspected) infringements of legal rights or freedoms (yours, ours or those of third parties)	Legal, Interest (enjoying and enforcing our rights and freedoms)
Disclosing if and as required by law	Legal

Usage Information and Cookie Information

Purpose	Grounds
Providing the Service	Contractual
Ensuring an appropriate level of security as respects the Service and Website, incl. particularly in terms of data processing	Contractual, Legal, Interest (keeping our products and services competitive)
Customising the content, layout and other properties of the Service and Website for you	Contractual, Interest (keeping our products and services relevant and enjoyable)
Improving your Service user experience	Interest (keeping the Service enjoyable)
Gaining a better understanding of how you interact with the Service or a Website	Interest (keeping our products and services competitive)
Investigating and preventing Service- or Website-related errors, defects, performance and security issues, illegal conduct, violations of contract and (actual or suspected) infringements of legal rights or freedoms (yours, ours or those of third parties)	Contractual, Legal, Interest (enjoying and enforcing our rights and freedoms)
Maintaining, improving, otherwise developing and protecting the Service and Website	Contractual, Interest (furthering our business, enjoying our rights and freedoms)
Creating new products and services	Interest (growing our business)
Making our communications to you more relevant	Interest (being relevant to you, thereby contributing to the success of our business)
Measuring the effectiveness of the messages we address to you	Interest (making our marketing more effective)
Learning where our customers come from and where to focus our marketing efforts	Interest (informing and shaping our business decisions)
Having our messages delivered across the internet	Interest (being visible and remembered)
Disclosing if and as required by law	Legal
Managing and executing our sales to you	Interest (operating our business)

Third-Party Information

Purpose	Grounds
Providing the Service	Contractual
Performing our agreements with the third parties concerned	Interest (adhering to contracts)
Disclosing if and as required by law	Legal

Other Information

Purpose	Grounds
Providing the Service	Contractual
Responding to your requests, comments and questions	Contractual, Legal, Interest (being responsive)
Keeping our records updated	Legal
Sending you communications you have subscribed or otherwise agreed to receive	Consent, Interest (providing you with information we find relevant and reasonably believe is of interest to you)
Offering you the Service or other products or services	Interest (growing our business)
Improving or otherwise developing the Service, our other products and services and the Website	Interest (keeping our products and services competitive)
Creating new products and services	Interest (growing our business)
Improving customer relationships and experiences	Interest (growing our business)
Disclosing if and as required by law	Legal

The communications that we initiate with you can broadly be classified as: (a) Service-related technical, administrative, business, legal and subscribed-to promotional messages that we address to Users and which you only receive if you are one (“Service Messages”); and (b) messages about products, services, events and other matters you have shown interest in or which we believe may be of interest to you (“Marketing Messages”).
You can unsubscribe from certain Service Messages by adjusting your User Account settings and from others by following the instructions provided in the message. There are, however, some Service Messages that form part of the Service and which you cannot opt out of receiving unless you unsubscribe from the Service. As for Marketing Messages, you can always opt out of receiving these, but the variety of procedures for doing so may depend on the nature of the message and whether you have a User Account. If you do, try adjusting your User Account settings, and whether you have an account or not, there should always be opt-out instructions in the message itself. If you have trouble unsubscribing, contact us and we shall opt you out. Our details, as noted, are at the end of this Policy.

Failure to provide Information

Generally, no one is obliged to give us her Personal Data but failure to do so may, or, depending on the circumstances, will or is likely to, result in our not being able to achieve the data processing purpose(s) specified for the occasion in question and the particular ‘data subject’ may, or, respectively, will or is likely to, miss the benefits corresponding to that purpose (or those purposes).
Where we need to collect your Personal Data by law or under the terms of a contract we have with you, or in order to enter into such a contract, and you fail to provide those data when requested, we may not be able to perform or enter into the relevant contract (which may be a contract for the provision of the Service or some other benefit). Should that be the case, we may have to cancel a product or service you have with us, but we shall let you know at the time if that applies.
If you limit the ability of a Service or Website to set cookies, you may, and in some cases most definitely will, prevent yourself from using that site or certain of its features, or may worsen your user experience as the item in question will not be personalised to you. It may also stop you from saving customised settings and you may need to validate your access to the Service or the Website more frequently during your browsing session.

Duration of Personal Data storage

We only store your Personal Data for as long as necessary in the light of, or compatible with, the purposes for which the data were collected (e.g., enjoying our rights and performing our obligations under the contract you have with us, if that was the sole purpose) and such additional period as may be required by law.
Legal retention periods vary depending on the type of Information concerned, and they can be quite long. For instance, Personal Data relevant to our accounting or taxation (which is likely to be the case upon some of the Personal Data under the Profile Information category, and may also apply to some other Personal Data) must be retained for at least seven years after the primary purpose for their processing ceases to apply.

Disclosure of Personal Data

This part of the Policy describes the circumstances in which we may disclose or transmit your Personal Data to third parties. Please note that the sections below only address the disclosures and transmissions of Personal Data and not, for example, anonymous or de-identified Information (which we may transmit and disclose at any time to anyone anywhere, in any manner and for any purpose).
Your Profile Information may also be shared when integrating third-party services. You can control which data are shared when enabling and/or while enjoying the integration (depending on the third-party service). At any rate, do check your privacy settings for both the Service as well as the third-party service prior to integration as well as during to determine which data may be shared. And please note that we are not responsible for the privacy practices (or other acts or omissions) of such third-party service providers, so it would be advisable for you to make sure, before the integration, that you trust the service and the provider in question and are satisfied with the provider’s policies.
We have engaged and will continue to use third-party service providers to assist us in providing, maintaining, developing, protecting and promoting the Service and Website. We may, for example, use such parties for hosting the Service or Website, sending out Service Messages or Marketing Messages, providing or hosting customer support services, performing analyses related to the Service or a Website, or for processing payments. We may also store Personal Data in locations outside our direct control, e.g., on third-party cloud infrastructure or platforms (IaaS/PaaS) or cloud infrastructure whose operation we have entrusted to other parties. These service providers may have access to your Personal Data for the limited purpose of providing the service we have engaged them to provide. Importantly for you as a ‘data subject’, our use of such service providers may involve transmitting your Personal Data to jurisdictions other than the one you reside in.
We may share your Personal Data with our corporate subsidiaries and outside accountants, legal counsels and auditors.
If we engage in or are subject to a merger, acquisition, division, transformation, public offering of our securities, obtaining financing, divestiture of all or substantially all of our assets or a significant part of such assets, transfer of the enterprise or a part of the enterprise to which your agreement with us pertains, or a similar transaction or proceeding, or if we take steps in contemplation of such activities (e.g., submit to due diligence), your Personal Data may, subject to standard confidentiality arrangements, be shared with, or transferred to, our counterparties or other relevant participants in the respective transaction or proceeding.
We may find ourselves in a situation where we are legally obliged to disclose some or all of your Personal Data or where we reasonably believe that we are so obliged. This may be the case if we receive an Information request from an authority or there is a law or regulation that requires us to make a disclosure without specific request (e.g., to comply with national or international measures against terrorism or money laundering). We may also be compelled to disclose your Personal Data by a judicial, arbitral, administrative or otherwise mandatory order or judgment. Where any of the foregoing applies, we shall make the disclosure, and we may not be permitted to tell you that your Personal Data have been disclosed.
There may also be situations where we find the disclosure of your Personal Data to be necessary in order to exercise, enforce or defend our rights, freedoms or legitimate interests or to protect the rights, freedoms or legitimate interests of a third party (e.g., a ‘data subject’ or an intellectual property owner).
We shall disclose your Personal Data at your request (unless legally prohibited, impracticable or involving unreasonable effort or expense) or may do so upon your Consent.

International transfers of Personal Data

We may transfer your Personal Data to jurisdictions other than the one you reside in.
We shall not transfer your Personal Data from countries participating in the European Economic Area (“EEA”) to those which do not, or from the EEA to international organisations, unless the recipient country or the particular person or entity receiving the data ensures an adequate level of protection for the data received, or, if it does not, then without applying such safeguards as legally required and/or without the transfer being subject to such other conditions as the law provides for these kinds of transfers.

Personal Data Security

We shall maintain adequate technical and organisational measures to ensure such level of security in our processing of Personal Data as appropriate in the given circumstances. Upon assessing whether a measure is adequate and which level of security is appropriate we consider the nature of the Personal Data we are processing and the nature of the processing operations we perform, the risks to which you are exposed by our processing of your Personal Data, the state of the art, the costs of implementation and such other matters as may be relevant in the particular circumstances. Certain of these measures have been described in the Data Protection Policy.
The measures referenced in the preceding section particularly address the following: (a) the protection of Personal Data against unauthorised or unlawful processing and against accidental loss, alteration or destruction; (b) the integrity and confidentiality of Personal Data; (c) the availability and resilience of the Service features pertinent to the processing of Personal Data; and (d) our ability to restore the availability and access to Personal Data in a timely manner after a Service failure.
However, please be aware that no security measure is perfect. Our efforts notwithstanding, we cannot guarantee that your Personal Data, during transmission over the internet or while stored in our systems or those of our service providers or while otherwise in our care, will be absolutely safe from unauthorised or unlawful processing or accidental loss, alteration or destruction, or that they will indeed be intact and confidential at all times or shortly available after any Service incident. Note also that we cannot control, and are not responsible for, the actions of other parties with whom you share (or instruct us to share) your Personal Data.

Your rights as a Data subject

‘Data subjects’ in the EEA have certain statutory rights under the GDPR concerning the Personal Data that we have on them. This part of the Policy aims to give you a general understanding of these rights and we encourage you to deepen this understanding by studying the GDPR yourself. To facilitate this, we have, in relation to each of the rights noted below, provided a reference to the specific provision of the GDPR from which that right arises.
Specifically then, and subject to such statutory exceptions as may apply in your particular case, your ‘data subject’ rights include the following:

Right of access / GDPR Article 15

You have the right to enquire and get a confirmation from us as to whether or not we process any of your Personal Data. Where we do, you may request access to those data and have us give you a copy of them. Please use the contact details at the end of this Policy to exercise your ‘right of access’.

Right to rectification / GDPR Article 16

If the Personal Data we have about you is incorrect, you have the right to request that we correct those data, and, in some circumstances, you may have the right to require that your incomplete Personal Data be completed (but in each of these cases we may need to verify the accuracy of the information you provide to us). Please use the contact details at the end of this Policy to exercise your ‘right to rectification’.

Right to erasure (right to be forgotten) / GDPR Article 17

You have the right to request that we delete or remove the Personal Data we have on you where there is no good reason for us continuing to process them. Please note that we may not always be able to comply with your request as there may be specific legal reasons which warrant the processing. Should this be the case, we shall inform you accordingly at the time of your request.

Right to object / GDPR Article 21

You have the right to object to our processing of your Personal Data where the processing is based on Interest and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts your interests or fundamental rights and freedoms. There may, however, be occasions where we demonstrate that we have compelling legitimate grounds to process your Personal Data (i.e., that our legitimate interests or those of a third party override yours and your fundamental rights and freedoms) and thus dismiss your objection. In case we are processing your Personal Data for direct marketing purposes, you may object to that processing at any time and we shall no longer process your Personal Data for such purposes.

Right to restriction of processing / GDPR Article 18

You have the right to request that we suspend the processing of your Personal Data where any of the following applies: (a) you have contested the accuracy of the data and the same needs to be verified; (b) the processing is unlawful but you do not want us to erase the data that we are processing; (c) you need us to maintain the data even though we no longer require them as they are necessary for your establishment, exercise or defence of legal claims; or (d) you have objected to processing but we need to verify whether we have overriding legitimate grounds for processing.

Right to data portability / GDPR Article 20

If our processing of your Personal Data which you have provided us is based on a Contractual ground or on Consent and the processing is carried out by automated means, you are entitled to have us make those data available to you in a structured, commonly used and machine-readable format so that you could transmit them to someone else (another ‘controller’). You may also ask us to transmit these data to that other ‘controller’ directly, and we shall do so, if technically feasible.

Right to withdraw consent / GDPR subsection 13(2)(c)

If we are processing your Personal Data based on Consent, you may withdraw that consent at any time (but this will not affect the lawfulness of any processing activities carried out based on your consent before its withdrawal).

We aim to respond to any legitimate request within a month of its receipt but it may take us longer if your request is particularly complex or you have made several requests. If that is the case, we shall let you know and keep you updated.
We shall not charge you any fee for exercising the above rights unless your requests are clearly unfounded or excessive (e.g., because of their repetitive character), in which case we may charge a reasonable fee. Alternatively, we may decline your request in such circumstances.

Your rights under Californian law

The rights in sections 41-43 of this Policy are applicable to residents of California.

California consumers have a right to knowledge, access, and deletion of their personal information under the California Consumer Privacy Act. California consumers also have a right to opt out of the sale of their personal information by a business and a right not to be discriminated against for exercising one of their California privacy rights. We do not sell the personal information of California consumers and does not discriminate in response to privacy rights requests.
Third party Cookies. Third parties that have content embedded on the Website may set cookies on a user’s browser and/or obtain information about the fact that a web browser visited a Website from a certain IP address. Please read third party cookie policies to get more information about their use of cookies.
How “Do Not Track” requests are handled. Our Website do not support “Do Not Track” requests. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked. If you want to opt-out of this online behavioural advertising, visit the following sites:http://www.aboutads.info/consumers.

Right to lodge a complaint with a supervisory authority

In case you believe that we are processing your Personal Data in violation of the GDPR, you have the right to lodge a complaint with the ‘supervisory authority’ located in the EEA country where you reside or work or where the alleged infringement took place or you can lodge the complaint with our ‘supervisory authority’ whose details are below.

Hungarian National Authority for Data Protection and Freedom of Information
1055 Budapest, Falk Miksa utca 9-11
Tel: +36 (30) 683-5969
Email: ugyfelszolgalat@naih.hu
Web: www.naih.hu

Changes to this Policy

We may revise this Policy from time to time to reflect changes to the Service, Website, applicable laws, regulations or standards or other changes that may occur in our business. We shall post the revised Policy (or, as the case may be, our new privacy policy) on the same webpage where we published this Policy or on such other webpage as we then may habitually use for publishing materials such as the Policy. We may also use the Service, email or other means for notifying Users of such policy changes. The revised Policy (or, as applicable, the new one) will be effective when posted as described unless the document itself specifies a later time for its entry into force.

Contact details

Feel free to get in touch with us if you have any questions about this Policy or our data processing practices or if you would like to exercise any of your ‘data subject’ rights with respect to the Personal Data we maintain on you.

WALLZ Csoport Korlátolt Felelősségű Társaság
Website: www.wallz.io
Email: info@wallz.io
Mailing address: 1047 Budapest, Wolfner utca 4/713.
Tax ID: 32405215-2-41
Company registration number: 01-09-422416

Last revised: November 6, 2023

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