For the Users visiting the Website of the Franz Liszt Chamber Orchestra, recipients of its Newsletter, participants in its Loyalty Programme and members of its Circle of Friends
1. The Data Controller
The Data Controller is the Franz Liszt Chamber Orchestra Foundation, the maintainer of the Website www.lfkz.hu (“Website”), registered at 7 Kiskorona str., Budapest 1037, Hungary.
Registering authority: the Metropolitan Court of Budapest
Registration number: 01-01-0001477
Tax number: 19667087-2-41
Telephone number: +36 1 250 4938
Email address: email@example.com
2. The processing of data
Personal Data is processed with regards to the following activities:
- distribution of email newsletters among the Users who specifically requested it;
- marketing purposes within the framework of our Loyalty Programme designed for our regular ticket holders;
- the operation of our Circle of Friends, the Friends of the Franz Liszt Chamber Orchestra;
- cookie usage on our Website.
The processing of Personal Data is carried out only in accordance with the applicable data protection regulation of the European Union, the GDPR and the applicable domestic laws, as outlined in this Privacy Notice.
3. Processing of data with regards to the distribution of newsletters
3.1 Our Newsletter
Our Foundation compiles and distributes a newsletter among the interested parties, in which they can find information, news and updates about classical music and especially about the Franz Liszt Chamber Orchestra. The Newsletter in which we advertise our concerts and provide information on ticket sales along other commercial information is part of our PR activities. Our Newsletter is distributed in an email form among those who have subscribed to it.
3.2 Subscription to the Newsletter and the processing of Personal Data
Users may subscribe to our Newsletter by entering their names and email addresses on our Website. The provision of names and email addresses is not mandatory, however, we will not be able to send newsletters if the email address is not provided .
In order to subscribe to our Newsletter, Users are asked to familiarize themselves with the contents of the present Privacy Notice, accepting its provisions on the Website at the time of their subscription. Upon their subscription, by ticking the checkbox, Users are providing their consent to the processing of data in accordance with the present Privacy Notice.
3.3 Purpose, legal basis and duration of data processing in relation to our Newsletter
The characteristics of data processing in relation to our Newsletter are as follows:
3.4 Unsubscription from the Newsletter
Users may unsubscribe at any time by sending an email to firstname.lastname@example.org. Upon unsubscribing, the processing of the Users’ Personal Data will be terminated.
4. Processing of data with regards to the Loyalty Programme designed for our regular ticket holders
4.1 The Loyalty Programme
The purpose of our Loyalty Programme is that of direct marketing: from time to time we get in touch with our regular ticket and season ticket holders sharing relevant, personalised commercial information and marketing offers regarding our programmes and concerts that are relevant to their interests.
For customers who provide their Personal Data as described in Section 4.3 of the present Privacy Notice, we provide specific discounts (link) pertaining to the purchase of tickets or season tickets.
4.2 Registration for the Loyalty Programme
Users may register for our Loyalty Programme on our Website by providing their Personal Data as outlined in Section 4.3. The provision of Personal Data is not mandatory, however, we will not be able to send marketing offers or grant the related discounts if those are not provided.
Registration for our Loyalty Programme is subject to the Users’ understanding and acceptance of the present Privacy Notice, which fact is brought to their attention on the Website at the time of registration. By subscribing (by ticking the checkbox), Users consent to the processing of data in accordance with this Privacy Notice.
4.3 Purpose, legal basis and duration of data processing in relation to our Loyalty Programme
The characteristics of data processing in relation to our Loyalty Programme are as follows:
While processing the Users’ Personal Data for marketing (direct marketing) purposes, we analyse and evaluate the Users’ purchasing transactions in order to send them useful and relevant offers about our concerts and events. According to the GDPR, this constitutes profiling. Profiling has no legal effect on the Data Subject and no decisions are based on it affecting any natural persons to a similar extent.
Users have the right to object to such processing of Personal Data at any time, free of charge.
4.4 Opting out
Users may opt out of the Loyalty Programme at any time by sending an email to email@example.com.
After opting out or in the event of the Users’ explicit objection to the processing of Personal Data for marketing purposes or profiling, the processing of the Users’ Personal Data as part of the Loyalty Programme will be terminated and the Personal Data will be deleted.
It is important to note, however, that neither the opting out nor the objection to data processing or profiling for marketing purposes will affect the registration for the Circle of Friends or the subscription to our Newsletter. Unsubscription from the Newsletter is be handled separately, as described in subsection 3.4; deregistration from the Circle of Friends is also be handled separately, as described in subsection 5.4.
5. Processing of data with regards to the Circle of Friends, Friends of the Franz Liszt Chamber Orchestra
5.1 Friends of the Franz Liszt Chamber Orchestra
Our Circle of Friends, Friends of the Franz Liszt Chamber Orchestra consists of those who have provided financial assistance to the operation of the Franz Liszt Chamber Orchestra in excess of HUF 5,000 through the electronic payment solution available on our Website.
5.2 Registration for the Circle of Friends
In order to join our Circle of Friends, we ask for the Users’ last name, first name, email address and telephone number. It is not obligatory to provide any data (our Foundation will be happy to receive the donation without knowing these), however, in case the contact details are missing, we will not be able to contact our Sponsors, thus we cannot ensure their membership in our Circle of Friends.
Sponsors may join our Circle of Friends through our Website by visiting the Support/Circle of Friends subpage where registration and data collection happens.
Registration for our Circle of Friends is subject to the Users’ understanding and acceptance of the present Privacy Notice, which fact is brought to their attention on the Website at the time of registration. By subscribing (by ticking the checkbox), Users consent to the processing of data in accordance with this Privacy Notice.
Sponsors are also given the opportunity to subscribe to our Newsletter by checking a separate checkbox at the time of registering for the Circle of Friends. In all cases we will process the data related to our Newsletter as described in Section 3 above.
5.3 Purpose, legal basis and duration of data processing in relation to our Circle of Friends
The characteristics of data processing in relation to our Newsletter are as follows:
5.4 Termination of the registration for the Circle of Friends
Users may terminate their registration for the Circle of Friends at any time. The cancellation of their registration shall be done by sending an email to firstname.lastname@example.org which will be confirmed in the form of another email. Parallel to the termination of the membership, data management activities shall also be terminated.
It is important to note, however, that the termination of the membership will not affect the subscription to our Newsletter or the participation in our Loyalty Programme as these are handled separately. Unsubscription from the Newsletter shall be carried out separately, as described in subsection 3.4 above. Opting out of the Loyalty Programme shall also be handled separately, as described in subsection 4.4.
6. Processing of data with regards to cookie usage
Cookies are small data packages that are installed on a computer when the User is visiting websites. Some Cookies are essential for the proper functioning of the websites, while others make them more convenient to use. Again others serve statistical or marketing purposes (we do not use any of the latter kind). Further information on the types of Cookies and their functioning are available here:
6.2 Options of the User to accept or reject Cookies
Cookies are stored in the browser of the users. Through the settings of the given browser, the users have the option to control cookie usage, while Cookies that have been installed earlier can also be deleted. Further information about browsers can be found here:
6.3 Types of Cookies we use
We use three types of Cookies on our Website:
- Session Cookies;
- Functional Cookies;
- Analytical Cookies.
6.4 Session Cookies
Session Cookies enable the use of our Website’s functions. Without them, our Website may not be fully accessible. Session Cookies are stored on the devices of the Users for the duration of the browsing activities, and are automatically deleted when the browser is closed.
We use the following Session Cookies on our Website:
6.5 Functional Cookies
Functional Cookies (also known as “Usage Cookies”) are used to store the preferences saved by the Users (e.g. if they are using accessibility functions, whether they are using the website in Hungarian or a foreign language, if they want to log in automatically etc.). The purpose of Functional Cookies is to save the Users from having to repeat such and similar settings every time they visit the website. Without the acceptance of Functional Cookies, the website may still be used, however, its performance will be less smooth. Such Cookies are stored on the devices of the Users beyond the duration of the visit.
6.6 Analytical Cookies
The purpose of Analytical Cookies is to provide information about how our visitors use our Website (e.g. which pages have been viewed, how much time was spent on our Website, which parts of our Website have triggered interaction, have any error messages been encountered etc.). These pieces of information are needed so that we can develop our Website in a user-friendly way, providing our visitors the simplest and the most enjoyable experience.
We use the following Analytical Cookies on our Website:
6.7 Involvement of Third Parties in the data processing activities related to Cookies
Some of our Cookies may provide data to the following external service providers:
- Web analytics and ad serving: we provide information to Google Inc. through the use of Google Analytics and Google AdWords in order to measure the success of our campaigns and to analyse how the visitors interact with our Website.
- Social media: our Facebook, YouTube and Instagram pages as well as contacts are embedded in our Website. The data forwarded to the relevant service providers help our Users stay in touch, while enabling the Third Parties to display ads relevant to them..
Disabling Cookies from these third-party providers will not affect the operation of our Website. We do not display third-party content on our pages.
7. Laws and legislations governing our data processing activities
Personal Data provided to us and our data processing activities are subject to the applicable laws and regulations, in particular:
a) 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); and
b) Act CXII of 2011 on Informational Self-Determination and Freedom of Information (“Privacy Act”),
in accordance with the following principles:
a) lawfulness, fairness, transparency: Personal Data are processed lawfully, fairly and in a transparent manner in relation to the Data Subject;
b) purpose limitation: Personal Data are collected only for the hereby specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
c) data minimisation: the scope of Personal Data collected is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d) accuracy: Personal Data we collect are accurate and, where necessary, kept up to date. We guarantee that every reasonable step is taken to ensure that Personal Data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
e) storage limitation: Personal Data are kept in a form which permits the identification of Data Subjects for no longer than is necessary for the purposes for which the Personal Data are processed;
f) integrity and confidentiality: applying the appropriate technical and organizational measures, Personal Data are processed in a manner that ensures appropriate security of the Personal Data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage;
8. The Data Processor
In relation to the data processing activities with regards to our Newsletter and the donations received, Crane Ltd. acts as a Data Processor, whose
registered office is at: 14-24 Horvát str., Budapest 1027, Hungary;
registrability is linked to: Budapest-Capital Regional Court as the Court of Registration;
company registration number is: 01 09 862008;
tax number is: 13567257-2-41;
phone number is: +36 1 236 5530;
email address is: email@example.com.
In addition to Crane Ltd., INTERTICKET Ltd. also participates as a Data Processor in the data processing within the framework of our Loyalty Programme, whose
registered office is at: 99 Váci str., Budapest 1139, Hungary;
registrability is linked to: Budapest-Capital Regional Court as the Court of Registration;
company registration number is: 01 09 736766;
tax number is: 10384709-2-41;
email address is: firstname.lastname@example.org
9. Rights of the Data Subjects
Based on the GDPR and the Privacy Act, the Data Subjects of the Personal Data we manage or process may contact us using the contact details outlined in Section 1 to request information regarding the data management processes and may request
- access to their Personal Data;
- corrections made to their Personal Data;
- the deletion of their Personal Data;
- restrictions imposed on the processing of their Personal Data; or
- object to the processing of their Personal Data.
In case of consent-based data processing, Data Subjects have the right to withdraw their consent at any time, however, the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
Please note that any request for information sent by email can only be considered authentic if it is sent from the Users’ registered email addresses, but this does not preclude us from identifying the senders in another way before providing the information.
We are obliged to disclose Personal Data provided by our Users and processed by automated means in a structured, commonly used, machine-readable format and/or to transfer them to another controller at the request of the Data Subject (right to data portability).
Transfers of data to third countries for the purposes of data processing and handling will only be made in accordance with the GDPR.
We shall not share any Personal Data with Third Parties, unless we are required to do so by law or pursuant to legal process or to comply with any applicable rules or regulations, or in response to a legitimate request from a law enforcement authority or other government official.
10. Supervision of data management activities
Our data management activities are supervised by the National Authority for Data Protection and Freedom of Information (“NAIH”), whose contact details are as follows:
- headquarters: 9-11 Falk Miksa str., Budapest 1055, Hungary;
- postal address: PO Box 9, Budapest 1363, Hungary;
- phone number: +36 30 683 5969; +36 30 549 6838; +36 1 391 1400;
- email address: email@example.com;
- website: http://www.naih.hu.
Based on Section 22 of the Privacy Act, Data Subjects may also turn to the relevant courts in relation to violations observed with regards to the management or processing of their Personal Data.
11. Possibilities of change
The solutions and conditions related to our data management activities may change from time to time. For this reason, we reserve the right to change the present Privacy Notice at any time. We shall provide information about such changes on our Website, or, in case of substantial changes, in the form of an email sent to those subscribed to our Newsletter, members of our Loyalty Programme, as well as members of our Circle of Friends.
Annex to the Privacy Notice of the Franz Liszt Chamber Orchestra Foundation
As described in Chapter 4 of the Privacy Notice, the data processing, including the profiling activities, carried out as part of the Loyalty Programme designed for our regular ticket holders with the aim of personalising marketing (direct marketing) enquiries and distributing them among the Users is performed by the Data Controller pursuant to Article 6(1)(f) of the GDPR. According to the GDPR, “processing shall be lawful only if and to the extent that at least one of the following applies: [...] (f) processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject which require protection of Personal Data [...].”
On the basis of the above provision, the Data Controller has carried out an assessment of the legitimate interests involved in the processing (balancing of interests test) and has come to the following conclusions:
1) The Data Controller, as an organiser of classical music concerts, has a legitimate interest in informing the public about its activities, concerts and programmes, as well as carrying out marketing activities among those interested.
2) Data Subjects have a legitimate interest in the protection of their privacy. They also have a legitimate interest in exercising their right to informational self-determination, which includes the access to the information they request.
3) The processing of Personal Data is subject to the system of guarantees laid down in the GDPR. Data Subjects have been informed in detail about the processing of their Personal Data in the Privacy Notice. In addition, Data Subjects have the possibility, if they feel that the processing is unlawful for any reason, to terminate the activities at any time, without any conditions and without giving any reason, by withdrawing from the Loyalty Programme or by objecting under the GDPR. In this way, the Data Controller may process their Personal Data only for as long as they themselves consider it useful and appropriate from their own point of view.
4) The legitimate interest of Data Subjects in the protection of their privacy is undiminished by the processing of their data. The processing of their data also ensures that they receive relevant and useful information through marketing enquiries.
Overall, it can be stated that there are no interests, fundamental rights and freedoms on the part of the Data Subjects that would take precedence over the legitimate interest of the Data Controller indicated in point 1). This is confirmed by the last sentence of recital 47 of the GDPR, which explicitly states that “the processing of Personal Data for direct marketing purposes may be regarded as carried out for a legitimate interest”.