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) pilot qualification ID
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
The drone user 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;
d) In relation to point 1 i): to facilitate official controls on the lawful use of airspace;
6. Legal basis of data processing
a) In relation to point 5 a), b) and c): legal obligations of Article 61 / A. § (8) - (9) of the Act XCVII of 1995 on Aviation (pursuant to Article 6 (1) c) of the GDPR.)
b) In relation to point 5 d): the data subject's consent (pursuant to Article 6 (1) a) of the GDPR);
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
a) 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.);
b) In relation to pilot qualification, the period specified in point 8 (a), unless the consent has previously been withdrawn;
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).
The ID & TRUST KFT. shall be considered data controller related other GoodID application using but mydronespace application.
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. Data security measures
1. 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.
2. 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.
III. Rights and possibilities for legal remedy
1. Please be informed that giving your consent to the data processing specified in point 5. d) is not a condition in order to use the mydronespace mobile application. Please note that you may withdraw your consent at any time, but the withdrawal of your consent does not affect the lawfulness of the pre-withdrawal data processing based on the consent.
2. Please be 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 data controller may charge a fee based on administrative costs for every further copy.
3. 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.
4. 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.
5. Please be informed that upon your request, HungaroControl will transfer your personal data to you in a structured, commonly used and machine-readable format, or – if it is technically feasible – will transmit these data to another data controller or ensure to you the option of transmission.
6. Please be informed that HungaroControl or its processor shall erase the processed personal data upon your request, if:
a) processing is unlawful;
b) you withdraw your consent;
c) the purpose of processing has been terminated or no further processing of data is required for attainment of the purpose;
d) the statutory data retention period has expired;
e) the erasure of data was ordered by law, authority or court.
7. Please be informed that you have the right to demand compensation or restitution for any damages or invasion of your personal privacy you suffered as a result of unlawful processing of your personal data.
8. 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 – via email.
9. 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 data controller may ask for reimbursement of its costs incurred in relation to the fulfilment of the request.
10. 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.
IV. Please be informed that the following person acts as the Data Protection Officer of HungaroControl: Anikó Fazekas, dr. (+36-30-851-2515, dpo@hungarocontrol.hu).