MYDRONESPACE
PROCESSING OF PERSONAL DATA AND DISCLAIMER

Notice on the processing of personal data in the course of mydronespace mobile application usage

I. Please be informed that creating a user account is required for the usage of the mydronespace mobile application by providing your personal data specified under paragraph (1). The data will be handled under the following terms and conditions:

1. Processed data
a) birth name;
b) marriage name;
c) address;
d) place and date of birth;
e) e-mail address;
f) phone number;
g) picture of an identity document according to Act LXVI of 1992 on the Registration of Personal Data and Addresses of Citizens under section 29.§ (2)-(3);
h) passport data page image;
i) the bank transaction code related to the payment made in connection with the use of the website and the mobile application;

2. People involved in data processing

Drone users using the mydronespace mobile application in Hungary;

3. Data controller

HungaroControl Pte. Ltd. Co. (registered office: 1185 Budapest, Igló u. 33-35., website: www.hungarocontrol.hu, e-mail: szemelyesadat@hungarocontrol.hu);

4. Source of processed data

By using the mydronespace mobile application by creating a user account;

5. Purpose of data processing

a) to ensure the legitimate use of airspace;
b) to facilitate the control of the legitimate use of airspace;
c) fulfilment of the obligation to provide information to the bodies performing law enforcement, national security and crime prevention tasks, investigative bodies, the counter-terrorism body, the aviation authority and the court;

6. Legal basis of data processing

Recording and processing personal data pursuant to Article 61 / A. § (8) - (9) of the Act on Aviation XCVII of 1995;

7. The method of data processing

a) Recording and use of the data: during the identification and registration of remote pilots;
b) Storage of the data: takes place in the server platform infrastructure (private cloud) operated by the Company, to which only those employees of HungaroControl have access, whose data management is absolutely necessary for their job tasks;
c) Transfer of the data: to the bodies performing law enforcement, national security and crime prevention tasks, investigative bodies, the counter-terrorism body, the aviation authority and the court to ensure the lawful use of airspace and to facilitate the control of lawful airspace use, as well as to fulfill the obligation to provide data, in order to fulfil the reporting obligation (pursuant to Article 61 / A. § (8) - (9) of the Act on Aviation XCVII of 1995.) by providing direct access from the data file or on the basis of an ad hoc request, indicating the purpose of data processing;
d) Erasure of data: 60 days after the expiration of the user account;

8. Data retention time

For 60 days from the end of the user account validity period. (The user account is valid for 13 months, unless the user renews their account.);

9. Data processor

Regarding the personal data provided in relation to the GoodID system, the operator of the application is ID & TRUST KFT. (1117 Budapest, Infopark, Gábor Dénes Street 2/D. 1. floor).
Application maintenance as well as error correction is performed by the data processing subcontractor (Rybárska, 7389 911 01 TRENČÍN SLOVAK REPUBLIC, Website: https://r-sys.eu/, E-mail: info@r-sys.sk).

II. Please be informed that the provided personal data shall be handled confidentially by HungaroControl. Only those who are involved in the performance of these tasks can be recognized the data. The personal data shall not be transferred to third parties without your consent and without providing prior notice thereof to you, except for the statutory data provision to authorities and other bodies based on legislation.

III. Please be informed that the data recorded during the use of the mobile application is stored in the server platform infrastructure (private cloud) operated by the Company. In the course of processing of personal data, HungaroControl – in accordance with the applicable legislation – takes such risk proportionate administrative and technical measures that prevents unauthorized and unlawful access to the personal data and modification of the personal data. Moreover, these measures ensure the transmission, disclosure and cancellation of personal data as well as ensuring the control over data processing.

IV. Please informed that you have the right to ask HungaroControl to provide your personal data and the information related to processing thereof to you. You may ask for copies of the personal data as long as requesting such copies does not adversely affect the rights and freedoms of others. Requesting of copies shall be free of charge on the first occasion, whereas the Company may charge a fee based on administrative costs for every further copy.

V. Please be informed that you have the right to request the clarification, correction or supplementation of your personal data by sending a declaration, as long as the data are inaccurate, incorrect or incomplete.

VI. Please be informed that HungaroControl shall restrict processing upon your request, if you contest the accuracy of data, if processing is unlawful, but instead of deletion, you request the restriction of processing, if the purpose of processing has been terminated, but you claim the data for the establishment, exercise or defence of legal claims, and if you filed an objection against the processing and the assessment of such objection is currently in progress. If HungaroControl unblocks the restriction of data processing, you shall be informed in advance.

VII. Please be informed that HungaroControl or its processor shall erase the processed personal data upon your request, if:
a) processing is unlawful;
b) the purpose of processing has been terminated or no further processing of data is required for attainment of the purpose;
c) the statutory data retention period has expired;
d) the erasure of data was ordered by law, authority or court.

VIII. Please be informed that you may claim damages or aggravated damages (compensation for injury to feelings) for the damages incurred as a result of unlawful processing or for personality right related damages.

IX. HungaroControl shall assess the request submitted by the data subject for enforcement of their rights, as soon as possible, but within one month the latest, and shall inform the data subject about its decision in writing or – if the data subject submitted their request electronically – in an electronic way.

X. If you submit a repeated request in the same year for the same scope of data, and the underlying reason is not that the data are required to be corrected, deleted or restricted due to the omission or failure of HungaroControl, the Company may ask for reimbursement of its costs incurred in relation to the fulfilment of the request.

XI. If you are of the opinion that your rights have been violated in connection with the processing of your personal data, you may initiate an investigation at the Hungarian National Authority for Data Protection and Freedom of Information (1055 Budapest, Falk Miksa Street 9-11., ugyfelszolgalat@naih.hu, +36-1-3911400, www.naih.hu) or you may turn to the court of competent jurisdiction. The regional court having competence according to the registered office of the data controller shall conduct the legal action, with the provision that at your discretion, the legal action can also be started at the regional court having competence according to your domicile or habitual residence as well.

XII. Please be informed that the following person acts as the Data Protection Officer of HungaroControl: dr. Fazekas Anikó (+36-30-851-2515, dpo@hungarocontrol.hu).

Disclaimer

This statement lays down the terms and conditions of using the mydronespace mobile application.

This statement is issued by HungaroControl Pte. Ltd. Co. (a business association having its registered office at 1185 Budapest, Igló utca 33-35 and registered by the Metropolitan Court of Budapest, acting as the Court of Registry under registration number 01-10-045570).

This statement is addressed to the user of mydronespace application (hereinafter referred to as User).

Using the mydronespace application shall be subject to the condition that the User accepts the terms and conditions laid down in this statement.

By accepting this statement, the User acknowledges that the User has been familiar with the terms and conditions laid down in this statement and accepts them as binding upon himself or herself.

This statement shall be considered to be accepted by the User by pushing the “Accept” button at the bottom of this statement.

Mydronespace application is a mobile application, which supports the UAS operations and contains the actual airspace information and other restrictions, being operated by HungaroControl Pte. Ltd. Co. pursuant to point p) of subsection (3) of section 61/A of Act XCVII of 1995 on Aviation.

In respect of this statement the unmanned aircraft, if appropriate, shall be understood as unmanned state aircraft as well.

The User agrees that using the mydronespace application shall not exempt the User from fulfilling any statutory obligations related to UAS operations, and – if UAS operation requires the use of segregated airspace – related to applying for and the use of segregated airspace.

The User cannot apply for segregated airspace through the mydronespace application; the designation of the flight area in the mydronespace application does not constitute the reservation of any airspace; the designation of the flight area shall not be considered to be any application submission.

The User acknowledges that if the flight area designated by the User in the mydronespace application overlaps with restriction-related airspace, UAS operations in the restriction-related airspace can be conducted only when the conditions related to UAS operations in the restriction-related airspace set out by law have been complied with. Complying with the conditions related to UAS operations in the restriction-related airspace set out by law shall be the obligation of the User. The User acknowledges that the mydronespace application does not check the legal use of the restriction-related airspace used by the User. In respect of using the mydronespace application the restriction-related airspace involves, in particular, controlled airspace, restricted areas, temporary restricted areas (TRA), danger areas, prohibited areas, Drop Zones, traffic information zones (TIZ), RMZ, TMZ set out by Joint Decree 26/2007. (III. 1.) of the Ministry of Economy and Transport, the Ministry of Defence, the Ministry of Environment and Water on the designation of the Hungarian airspace for aviation, and also airspace, areas and zones set out in points j)-l) and n)-o) of section 4/A, in section 8, in point b) of subsection (2) of section 8/C and by subsection (5)-(6) of section 8/C of Government Decree 4/1998. (I. 16.) on the use of the Hungarian airspace, and segregated airspace as well which is not used for UAS operations. In respect of using the mydronespace application the use of restriction-related airspace shall be considered to be legal when the conditions related to UAS operations in the restriction-related airspace set out by law have been complied with.

HungaroControl Pte. Ltd. Co. reserves the right to make the mydronespace application available to the users against payment.

The User shall use the mydronespace application only at his own responsibility.

Only the User shall be responsible for ensuring that the mydronespace application is compatible with the User’s device, including any other applications installed on that device.

HungaroControl Pte. Ltd. Co. does not warrant that the mydronespace application is free of errors, and accessible continuously and without any disturbance, the contents of the mydronespace apllications are accurate or complete, or any error will be fixed.

The User acknowledges that HungaroControl Pte. Ltd. Co. is not liable for any damage, cost, or loss that may arise in relation to using the mydronespace application, including, but not exclusively, any defect, malfunction, loss of functionality, loss of data, change of data, data transmission delay affecting the User’s device running the mydronespace application, or any damage caused by computer malware.

HungaroControl Pte. Ltd. Co. reserves the right to modify the mydronespace application, or any of its parts, at any time, particularly but not exclusively in line with any change in applicable law.

Impressum

HungaroControl Hungarian Air Navigation Services Pte. Ltd. Co.

Company registration number: Cg. 01-10-045570

Seat: H-1185 Budapest, Igló u. 33-35., Hungary

Postal address: H-1675 Budapest, P.O. Box 80

Tel: (+36 1) 293-4444

Fax: (+36 1) 293-4343

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