Privacy Policy and Notice

 

This document provides information from Enabler Ltd. (hereinafter referred to as „Service Provider„), as the operator of the website www.motimore.com and its subwebsites, like app.motimore.com (hereinafter referred to as „Website„), regarding the processing of personal data provided by individuals (hereinafter referred to as „Data Subjects„) on the Website.

Our contact details:

Name: Enabler Ltd.

Registered Address: 1022 Budapest, Bogár utca 29/B 1.a., Hungary

Email Address: info@motimore.com

This privacy notice has been prepared in accordance with Regulation (EU) 2016/679, the General Data Protection Regulation (hereinafter referred to as „GDPR„).

Scope of Processed Data, Legal Basis, Purpose, and Duration of Data Processing

 

1.1. Data Processed for Registration

Description of Data Processing Scenario, Purpose of Data Processing, and Scope of Processed Data

To complete the registration on the Website, it is necessary to provide your full name, email address, password, and indicate whether you wish to use the service as a teacher or a student.

Legal Basis for Data Processing

The legal basis for data processing is your consent, based on Article 6(1)(a) of the GDPR.

Duration of Data Processing

We will process the data until the registration is deleted or until the withdrawal of your deletion request is realized through other means.

 

1.2. Data Processed for User Account

Description of Data Processing Scenario, Purpose of Data Processing, and Scope of Processed Data

After registration and login on the Website, you have the opportunity to provide additional information in your user account.

In your user account, you can provide the following data:

  • Billing information, including:
  • Billing name
  • Billing address
  • Phone number

Legal Basis for Data Processing

The legal basis for data processing is your consent, based on Article 6(1)(a) of the GDPR.

Duration of Data Processing

We will process the data for a period of 15 days from the date of registration deletion or from the date of withdrawal of your deletion request through other means.

 

1.3. Data Processed for Course Ordering and Subscription

Description of Data Processing Scenario, Purpose of Data Processing, and Scope of Processed Data

If you place an order or subscribe to the educational system on the Website, we need to process your name, billing information, phone number, and email address to fulfill the resulting contract.

During the ordering or subscription process, we will send you information related to the order or subscription to your email address, and we will issue an invoice based on the provided data.

Legal Basis for Data Processing

The legal basis for data processing is the performance of a contract with you, based on Article 6(1)(b) of the GDPR.

Regarding invoices, according to Section 159(1) of Act CXXVII of 2007 on Value Added Tax, issuing an invoice is mandatory, and it must be kept for 8 years in accordance with Section 169(2) of Act C of 2000 on Accounting [data processing under Article 6(1)(c) of the GDPR].

All accounting laws are in accordance with the law of country where the Service Provider is resident, in this case: Hungary.

Providing the data is a requirement for entering into a contract and is essential for the fulfillment of the purchase.

Duration of Data Processing

Your data, including the information on the invoice, will be kept for 8 years based on Section 169(2) of Act C of 2000 on Accounting.

All accounting laws are in accordance with the law of country where the Service Provider is resident, in this case: Hungary.

 

1.4. Data Processed for Newsletter Subscriptions

Description of Data Processing Scenario, Purpose of Data Processing, and Scope of Processed Data

Our aim is to provide you with information regarding available educational materials and special offers on the Website, provided that you give your consent.

For newsletter subscriptions, we process your last name, first name, and email address.

Legal Basis for Data Processing

The legal basis for data processing is your consent, based on Article 6(1)(a) of the GDPR.

Duration of Data Processing

We will process the data until the Data Subject unsubscribes from the newsletter by clicking the unsubscribe link provided in the newsletter or requests the deletion of their data through other means.

 

1.5. Handling of Data Recorded in Groups Created within the Educational System

Description of Data Processing Scenario, Purpose of Data Processing, and Scope of Processed Data

In the group (digital classroom) created by the Professional User, we process the last name, first name, and email address of the Professional User and the User.

Legal Basis for Data Processing

The legal basis for data processing is your consent, based on Article 6(1)(a) of the GDPR.

Duration of Data Processing

We will process the data for a period of 15 days from the deletion of the registration or from the date of another request for deletion.

 

1.6. Handling of Data within the Gamification Functionality

Description of Data Processing Scenario, Purpose of Data Processing, and Scope of Processed Data

Within this scope, we handle the points and achievements given by Professional Users to Users, which are considered as personal data of the Users.

Legal Basis for Data Processing

The legal basis for data processing is your consent, based on Article 6(1)(a) of the GDPR.

Duration of Data Processing

We will process the data for a period of 15 days from the deletion of the registration or from the date of another request for deletion.

 

1.7. Handling of Data within „Other Functionalities“

Description of Data Processing Scenario, Purpose of Data Processing, and Scope of Processed Data

We handle the data of calendar entries available in the educational system, data uploaded to the message board, and personal data contained in messages (private conversations).

Legal Basis for Data Processing

The legal basis for data processing is your consent, based on Article 6(1)(a) of the GDPR.

Duration of Data Processing

We will process the data for a period of 15 days from the deletion of the registration or from the date of another request for deletion.

 

1.8. Handling of Data within the Complaint Management Process

Description of Data Processing Scenario, Purpose of Data Processing, and Scope of Processed Data

In case of any customer service or complaint handling related to the purchased service, we also process personal data during the process.

Regarding complaint management, we handle your name, contact information (email address, phone number, postal address), and the details of your complaint.

The purpose of data processing is to fulfill the warranty and complaint handling obligations in accordance with legal requirements.

Legal Basis for Data Processing

It is your voluntary decision whether you approach us with a complaint. However, if you do approach us, we are obliged to keep the complaint for 3 years, based on Section 17/A(7) of Act CLV of 1997 on Consumer Protection. Therefore, the legal basis for data processing is a legal obligation under Article 6(1)(c) of the GDPR.

All accounting laws are in accordance with the law of country where the Service Provider is resident, in this case: Hungary.

Duration of Data Processing

Under consumer protection laws, we are required to retain the data for 3 years following the complaint management process.

 

Data Processors

During the data processing, we engage the following data processors:

Rackforest Information Technology Trading and Consulting Ltd. (Registered office: 1132 Budapest, Victor Hugo utca 11., 5th floor), who provides hosting services.

OTP Mobil Ltd. (Registered office: 1143 Budapest, Hungária krt. 17-19.), who operates the Simple Pay payment system.

KBOSS.hu Ltd. (Registered office), who operates the invoicing system.

 

Data Transfer Statement

I acknowledge that my personal data stored in the user database of www.motimore.com by Enabler Ltd. (registered office: 1022 Budapest, Bogár utca 29/B 1.a.) will be transferred to OTP Mobil Ltd., as a data processor. The scope of data transferred by the data controller includes the following: name, email address, billing address, and tax identification number.

The nature and purpose of the data processing activities performed by the data processor, OTP Mobil Ltd., can be found in the SimplePay Privacy Policy at the following link: https://simplepay.hu/vasarlo-aff

I acknowledge that my personal data stored in the user database of www.motimore.com by Enabler Ltd. (registered office: 1022 Budapest, Bogár utca 29/B 1.a.) will be transferred to KBOSS.hu Ltd. (szamlazz.hu), as a data processor. The scope of data transferred by the data controller includes the following: name, email address, billing address, and tax identification number.

The nature and purpose of the data processing activities performed by the data processor, KBOSS.hu Ltd. (szamlazz.hu), can be found in the szamlazz.hu Privacy Policy at the following link: https://www.szamlazz.hu/adatvedelem/

 

Cookie Data Management

Certain parts of the website use small data files (cookies) for the purpose of identifying the user. By visiting the website and using its functions, you give your consent to the storage of these cookies on your computer and allow the data controller to access them.

You can configure and prevent cookie-related activities through your browser settings. However, please note that without the use of cookies, you may not be able to access all the services provided by the website.

As a technical intermediary, the Service Provider ensures that during visits to the websites, third parties cooperating with the Service Provider, especially Google Inc., store cookies to display advertisements to the user based on their previous visits to the Service Provider’s website.

You can also delete cookies from your computer or configure your browser to disable the use of cookies. Additionally, Google provides a service to disable Google-placed cookies for personalized ads on the following page: (https://www.google.com/policies/technologies/ads/). Disabling or deleting cookies may make the use of websites less convenient for you.

 

What are cookies and how are they managed?

Cookies are small data files that are downloaded and stored on the user’s computer through the website and saved by the user’s internet browser.

The general tasks of cookies are as follows:

  • Collect information about visitors and their devices.
  • Remember visitors‘ individual settings, which may be used, for example, when using online transactions, so there is no need to re-enter them.
  • Facilitate the use of the website.
  • Provide a quality user experience.

For personalized service, a small data package, called a cookie, is placed on the user’s computer and read during subsequent visits. If the browser sends back a previously stored cookie, the service provider managing the cookie has the ability to link the user’s current visit with previous ones, but only in relation to its own content.

Most commonly used internet browsers (Chrome, Firefox, Edge, Explorer, Opera, Safari, etc.) accept and allow the download and use of cookies by default. However, it is up to the user to modify the browser settings to reject or disable cookies, as well as to delete stored cookies on the computer.

For more information on using cookies, you can refer to the „Help“ section of each browser.

 

Disabling cookies in specific browsers:

  • Chrome: https://support.google.com/accounts/answer/61416?hl=en
  • Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
  • Internet Explorer: https://support.microsoft.com/en-us/topic/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d
  • Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
  • Edge: https://support.microsoft.com/en-us/microsoft-edge/view-and-delete-browser-history-in-microsoft-edge-00cf7943-a9e1-975a-a33d-ac10ce454ca4
  • Opera: https://help.opera.com/en/latest/web-preferences/#cookies

 

Rights of the Data Subject Regarding Data Processing

During the duration of data processing, you have the following rights in accordance with the provisions of the Regulation:

  • Right to access personal data and information related to data processing.
  • Right to rectification.
  • Right to restrict data processing.
  • Right to erasure.
  • Right to data portability.
  • Right to object.
  • Right to withdraw consent.

If you wish to exercise your rights, it requires your identification, and we need to communicate with you accordingly. Therefore, providing personal data will be necessary for identification purposes (although identification can be based on data we already hold about you). Additionally, your complaints related to data processing will be available in our email account within the timeframe specified in this notice for handling complaints.

Complaints related to data processing will be responded to within a maximum of 30 days.

 

5.1. Right to Withdraw Consent

You have the right to withdraw your consent to data processing at any time, in which case the provided data will be deleted from our systems.

 

5.2. Right to Access Personal Data and Information

You have the right to receive feedback on whether your personal data is being processed and, if so, you are entitled to:

  • Access the processed personal data.
  • Be informed about the following:
  • Purposes of the data processing.
  • Categories of personal data being processed.
  • Recipients or categories of recipients to whom the personal data has been or will be disclosed.
  • The planned duration of storage of the personal data or, if not possible, the criteria used to determine that duration.
  • Your right to request rectification, erasure, or restriction of processing of your personal data and to object to such processing based on legitimate interests.
  • Your right to lodge a complaint with a supervisory authority.
  • If the data was not collected from you, any available information about its source.
  • The existence of automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for you.

The exercise of this right may aim to establish and verify the lawfulness of data processing. Therefore, if multiple requests for information are made, we may charge a reasonable fee for fulfilling the request.

Access to personal data is provided by sending the processed personal data and information to you via email after your identification.

Please specify in your request whether you are seeking access to personal data or information related to data processing.

 

5.3. Right to Rectification

You have the right to request the correction of inaccurate personal data concerning you without undue delay upon your request.

 

5.4. Right to Restrict Processing

You have the right to request the restriction of processing if one of the following applies:

  • You contest the accuracy of your personal data, in which case the restriction will apply for a period that allows us to verify the accuracy of the personal data. If no such verification is necessary, the restriction will not be applied.
  • The processing is unlawful, and you oppose the erasure of the data and instead request the restriction of their use.
  • We no longer need the personal data for the purposes of the processing, but you require them for the establishment, exercise, or defense of legal claims.
  • You have objected to the processing pending the verification of whether our legitimate grounds override your rights, in which case the processing will be restricted until it is determined whether our legitimate grounds prevail over yours.

If the processing is restricted, such personal data, except for storage, will only be processed with your consent or for the establishment, exercise, or defense of legal claims, for the protection of the rights of another natural or legal person, or for reasons of important public interest of the Union or a Member State.

You will be informed in advance (at least 3 working days before the lifting of the restriction) regarding the lifting of the restriction on processing.

 

5.5. Right to Erasure (Right to be Forgotten)

You have the right to request the erasure of your personal data without undue delay if one of the following grounds applies:

  • The personal data is no longer necessary for the purposes for which it was collected or processed.
  • You withdraw your consent, and there is no other legal basis for the processing.
  • You object to the processing based on legitimate interests, and there are no overriding legitimate grounds for the processing.
  • The personal data has been unlawfully processed.
  • The erasure of personal data is required to fulfill a legal obligation under the applicable EU or Member State law.

If we have made the personal data concerning you public and we are obliged to erase it for any of the reasons mentioned above, taking into account available technology and the cost of implementation, we will take reasonable steps, including technical measures, to inform other data controllers who are processing the personal data that you have requested the erasure of any links to, or copies or replications of, that personal data. However, this does not apply if the processing is necessary for:

  • Exercising the right of freedom of expression and information,
  • Compliance with a legal obligation that requires processing by us (such as data retention obligations for invoicing purposes) or the performance of a task carried out in the public interest or in the exercise of official authority vested in us, or
  • The establishment, exercise, or defense of legal claims.
  • As a general rule, we do not make your personal data publicly available.
5.6. Right to Object

You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data based on legitimate interests. In such cases, we will no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or unless the processing is necessary for the establishment, exercise, or defense of legal claims.

 

5.7. Right to Data Portability

If the processing of your data is necessary for the performance of a contract or is based on your voluntary consent, you have the right to request that the data you have provided to us be provided to you in a machine-readable format, such as XML, JSON, or CSV, if technically feasible. You may also request that we transmit the data in this format to another data controller.

 

5.8. Remedies

If you believe that we have violated any provisions of data processing legislation or have failed to fulfill any of your requests, you have the right to initiate an investigation by the Hungarian National Authority for Data Protection and Freedom of Information (address: Hungary, 1363 Budapest, Pf.: 9., email: ugyfelszolgalat@naih.hu) in order to cease the presumed unlawful data processing.

We also inform you that you have the right to file a lawsuit before a court.

 

Data Security

During the operation of our information systems, we ensure the necessary authorization management, internal organization, and technical solutions to prevent unauthorized access, deletion, extraction, or modification of your data by unauthorized individuals. We also enforce data protection and data security requirements with our data processors.

We maintain a record of any potential data protection incidents, and if necessary, we will inform you about any incidents that arise.

 

Other Provisions

We reserve the right to modify this data processing notice in a manner that does not affect the purpose and legal basis of the data processing.

However, if we intend to perform further data processing for purposes other than the original collection purpose, we will inform you before any additional data processing takes place, providing you with the following information:

  • the storage period of personal data or, if not possible, the criteria used to determine the storage period;
  • your right to request access, rectification, erasure, or restriction of processing of your personal data, as well as your right to object to processing based on legitimate interests and your right to data portability in cases of processing based on consent or contract;
  • your right to withdraw consent if the processing is based on consent;
  • your right to lodge a complaint with the supervisory authority;
  • whether the provision of personal data is based on a statutory or contractual requirement or is necessary for entering into a contract, as well as the possible consequences of not providing the data;
  • the existence of automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and expected consequences of such processing for you.

Data processing can only commence after this information has been provided, and if the legal basis for data processing is consent, you must also provide your consent in addition to being informed.

This Data Processing Notice is effective from May 10, 2022, translated into EN: 2023.07.10.