Data Privacy Notice

1.What is this notice about?

During the operation of the business simulation software available at edu.ecosim.hu ("Ecosim EDU", "business simulation system" or "system") EcoSim Business Simulations Ltd. ("EcoSim" or "Operator") handles personal data. Respecting the rights of data subjects, and in compliance with its legal obligation, the operator describes the most important features of its data management activities in this notice.

This notice is valid from 2018.04.10.

The operator is entitled to modify this Data Privacy Notice by notifying users in advance. The amended provisions will become effective the first time you use the system after receiving the notification and it being posted on the Website.

This statement complies with the principles and provisions of the GDPR.

2.What is personal data, what is a data controller and a data processor?

What is considered to be personal data?  Any information about an identified or identifiable natural person - e.g. the name, email address, student code, IP address of the person concerned.

Who is considered to be a data controller?  Who alone or together with others determines the purpose and means of data management.

What does data management mean?  Regardless of the method used, it is any operation or set of operations which is performed on the data (in particular collecting, recording, organization, storing, altering, using, retrieving, transmitting, disclosing, coordinating or combining, blocking, deleting or destroying, as well as preventing further use of the data, etc.).

Who is considered to be a data processor? Who handles personal data on behalf of the data controller (which usually means technical operations such as storage).

3.Who is the data controller of the personal data provided during the use of the business simulation system?

Ecosim EDU system data controller:

EcoSim Business Simulations Ltd.

Seat: 1094 Budapest, Páva utca 13. 5. / 1.

Company Registry number: 01-09-714023

e-mail: support@ecosim.hu

data management registration number: NAIH-65429/2013., NAIH-65428/2013.

https://www.ecosim.hu/

Data controller for each course / training: with regards to the business simulations the companies, organizations and educational institutions that organize the courses are also considered data controllers. The representative of these data controllers within the system is the user with Teacher / Admin rights, who are the owners of the courses. EcoSim provides storage and software for conducting courses / trainings.

4.How can I register, take part in a course / training?

The system can be used by users with two types of user rights: Teacher / Trainer user right and Student / Training participant user right.

To gain access to a Teacher / Trainer user right, it is nessary to enter a license agreement with the operator and pay a license fee. If you would like to become a Teacher / Trainer user, contact us, become our business partner or initiate the purchase of a license through your organization. Based on the contract with the operator, the contracting partner initiates the Teacher / Trainer user by providing your e-mail address to the operator. The Teacher / Trainer user authority level is approved by the operator.

As a Student / Training participant user, the service can be used free of charge. You can register to the system through the registration platform. To finalize the registration, you also need to confirm it, which you can do via the activation link sent to your email address. You have 72 hours to complete the registration.

You can join the courses / trainings in the system by entering the course name and password. The Teacher user will provide you with the required course name and password. After joining the course / training, you can create your own team as a team captain or join an existing team.

If you already have an EcoSim MyAccount profile and you register with the e-mail address you've entered there, it will be paired with the data stored there.

Each registration also creates an EcoSim MyAccount account where you can change your personal information.

5.What information do I need to provide to register?

Registration requires that you provide your last name, first name, email address and password. You cannot attend courses / trainings without providing this information. This data is needed for identification in the system so that you can use it. Your name and email address are also required because the Teacher / Trainer and Team Captain Student users will only be able to identify you within the course / training based on this.

The system does not know your password, it encrypts it and only keeps an imprint of it, from which the password cannot be reset, so the system is only suitable for verifying the correctness of the password. Therefore, noone can learn your password from us. Please make sure that unauthorized people don't get know your password.

The system logs the IP address you register from and deletes this information after 10 days.

In the Profile menu you can also enter your university student code (e.g. ETR code, Neptune code). This provides additional help to the Teacher user to identify you especially in a case of identical names. In case you are a student we recommend filling this field out.

We will process your profile data on the basis of your voluntary consent until your registration is canceled, which you can read about in section 9.

6.What is an invitation?

An invitation is needed to make it easier for you to find the course / training that your fellow student / training partner would like you to attend. Upon invitation, the team captain will record in the system that he / she wants you to join his / her team by entering your email address. After registration, you will find the invitation(s) at the given course / training. You can easily join the team by clicking on the link in the invitation.

Prior to your registration, the system records your email address in the team captain's profile so that the team can be easily formed. This is in the legitimate interest of the Teacher / Trainer user initiating the course / training (together with the business partner he / she represents), the team captain (your acquaintance), and ultimately the operator as it aims to make the system more user-friendly.

7.When using the system, who sees and what of my personal data?

The Teacher / Trainer user sees the name and e-mail address of each user with Student / Training participant rights in the system for identification purposes.

Teacher / Trainer users also see the school / university code of the Student / Training participant users (e.g. Neptune code, ETR code), which is required to identify the student when participating in a business simulation related to the educational institution's lesson / course.

Student / Training participants see the names and email addresses of the users in their team, however, they don't see the details of the members of other teams, only their team names.

Only the Teacher / Trainer user and the team members have access to the user content uploaded during the simulation, the members of the other teams only see the result achieved by your team.

All Student / Training participants know the name and email address of the user with Teacher / Trainer rights who is hosting the business simulation competition.

8.How can I change my registration information?

You can change your data in the Profile menu.

9.How can I cancel my registration?

If you want to cancel your registration, write an email to support@ecosim.hu or log in and request to cancel your registration in the Profile menu. You will then receive an email from us giving you the option to withdraw the cancellation initiative within 72 hours. If you do not withdraw it, your registration will be canceled after 72 hours. Before terminating your account, be sure to back up the content you uploaded to the system during the simulations and download your results from the business simulations.

You can also decide to request the cancellation of your registration in the case of an ongoing Course / Training. In this case, a robot user will take your place, keeping your results achieved until this point.

You might not use the system every year during your studies / work, so we will temporarily maintain your registration. However, after 2 years inactivity from the last entry, we will delete your data. You can re-register at any time, we look forward to hearing from you.

In case of the cancellation of your registration, our business partner hosting the competition / event can further process your data as a data controller in its own right, for which Ecosim provides storage in the system due to a contractual obligation. It is in Ecosim's legitimate business interest to meet its storage hosting obligations to business partners. In the case of educational institutions, this information is essential for the grading and its certification, so it is in the legitimate interest of our partner to store it. Therefore, during the validity period of the contract with the business partner - or if the business partner deletes it earlier, until deletion - the results of the already completed business simulations will be stored including data about the participants in the given business simulation course (name, email address, student code, result, uploaded user content). In our consideration of interests, we have taken into account that only information that you have previously consented to the handling of remains in the system during storage, they remain in a suitable data security environment, they are only available to the company or organization organizing the simulation course, their disclosure should not result in your derogatory judgment.

If by cancelling your registration you want to delete data made available during business simulations other than your user account, please contact the company, institution or organization organizing the simulation course as a data controller via the Teacher / Trainer user or other direct contacts of our business partner. If you find us with your request, we will forward the request to our business partner. If our business partner cannot provide a legal basis for the further processing of your data, we will also delete this data from the system.

10.Does the operator record my grade?

No. We only store your results in the business simulation, the grade given by the Teacher user related to your result is not recorded in the system. The system calculates your results in the business simulation based on mathematical operations, however, the evaluation of these results can be based on other factors considered by the Teacher / Trainer user.

11.What data does the operator store about me?

In addition to your profile information (name, e-mail address, student code), the operator will record whether you have subscribed to any of its newsletters. The system can show which courses / trainings you participated in, in which team, with what user rights (Teacher / Trainer, Student / Training participant, team captain) and who invited you to participate in the team. Your user content uploaded to the business simulation and the result of the course / training will be kept until the license of the Teacher / Trainer who created the given simulation is valid or deleted from the system by the Teacher / Trainer.

12.What is a newsletter, a career newsletter?#_

You can subscribe to two types of newsletters, which are sent out at irregular intervals. You can unsubscribe at any time.

In the general EcoSim newsletter, we recommend you our own or our business partner’s business simulation competitions with great prizes.

In the career newsletter we provide information about career opportunities and job offers of our advertising partner.

General and career newsletters can only be sent to you by the operator, your email address will not be passed on to third parties for marketing or job advertising purposes.

How can I subscribe to the newsletters?

During the registration process, you can voluntarily subscribe to the general and / or career newsletter by checking the empty check-box or you can subscribe to it later in the Profile menu. You do not need to confirm the subscription.

We will use your name and email address to send the newsletter due to the obligation prescribed in the Advertising Act (Grt.6.§). If you also subscribed to the career newsletter, we will filter the database on our advertiser's request and only send the offer only to those for whom the advertisement may be relevant based on the geographical or higher education based narrowing or business simulation topic, so you won't receive unrelevant opportunities. To narrow download the database, we examine which business simulation you participated in, and from this we extract information about which country you study / work in or which university you study at, what topic simulation you are interested in, this information is not recorded separately. The advertiser will not receive your information!

How can I unsubscribe from the newsletters?

You can unsubscribe from the general and the career newsletters via the link at the bottom of the newsletter or in your profile. You do not have to confirm the unsubscription. Unsubscribing doesn't affect system usage and the lawfulness of any previous data processing.

13.What data does the business simulation system log and why?

In order to debug, prevent abuse and check the operation of the system, we continuously log and after 10 days delete the following data: IP address, date, time, browser, operating system data, which sub-pages you visit, where you came from.

Logging is done in our legitimate interest to be able to ensure the IT security of the website, its resilience to offensive, illegal activities against the website (e.g. unauthorized access). Logging is absolutely necessary and proportionate to achieve the goals detailed above.

14.How does EcoSim protect my data? What data security steps does it take?

We take all necessary steps to the best of our ability to ensure the security of the personal data provided and detected during network communication, data storage and preservation.

We are constantly developing our IT system and network in order to maintain and further strengthen data security and protect the system from possible attacks. We try to protect your data with automatic data backup (to a separate server), mirroring, firewall and intrusion monitoring, our server works with an active and passive protection system. We use secure SSL access to prevent unauthorized access. 

The personal data stored in the system is stored on a dedicated server installed in the territory of the Republic of Hungary, protected by a 24-hour guard at the data processor operating the system. EcoSim uses a hosting provider (data processor) to store your personal data, which uses CXS web FTP hacker protection and a virus filter to protect your data:

AB PLUSZ Számítástechnikai és Szolgáltató Betéti Társaság

Seat: 2049 Diósd, IV. Béla király utca 48.

Company Registry Number: 13-06-068037

https://www.abplusz.hu/

15.What is a cookie? What cookies are installed when using the business simulation system?

What is a cookie?

The EcoSim EDU system can be used by enabling cookies placed by the operator.

A "cookie" is a small data packet that collects or stores information defined by the server, thus facilitating the operation of the website and the user's system use. Several types of cookies can be installed on your machine when using the system. We only use secure cookies that work over an SSL connection. We need cookies in order to increase the efficiency of the service, to analyze the visits and use of the system.

To facilitate the use of the system, we use a cookie for a "session". If you log in, close the page and then return to the page, you will find yourself logged in again. The session cookie does not store personal information for this.

The permanently placed browser cookie is stored on the hard disk of the device and remains even after the Internet browser is closed until the cookie is deleted manually or until the expiration of the cookie period specified below. Browser cookies can be deleted from the device at any time, and you can refuse the use of cookies by selecting the appropriate browser settings. However, if you disable the Ecosim cookies we place, you will not be able to use the business simulation system to its full potential. For each browser (Explorer, Mozilla, Chrome, Safari, etc.) and end-user device (if you use more than one machine, you can delete or disable cookies one by one. You can find a detailed description of the cookie settings on the following pages:

Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies#

Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer

Chrome: https://support.google.com/accounts/answer/61416?hl=en&co=GENIE.Platform%3DDesktop

Safari: https://www.apple.com/legal/privacy/en-ww/cookies/ https://support.apple.com/en-us/HT201265

The following table lists the cookies provided by the operator.  

What other third-party cookies can still be installed on my device?

We use external web analytics companies (Google Inc., Facebook Inc.) to measure website traffic and other web analytics data, as well as to increase the effectiveness of Ecosim’s advertising activities. These companies operate independently from the operator providing these services:

Google Analytics (https://www.google.hu/analytics/),

Google Ads (https://ads.google.com/intl/en_uk/home/),

Facebook Pixel (https://www.facebook.com/business/help/742478679120153?id=1205376682832142)

Google Inc. uses cookies or similar technologies to identify your browser or device in order to collect and store information. To learn more about what Google Inc. collects, how, and how long your data is used in Google Analytics and Google Adws, read the Google Privacy Policy: https://policies.google.com/privacy?hl=en&gl=hu

You can find out more about Facebook Inc.'s Facebook Pixel data management and cookie usage at: https://www.facebook.com/privacy/explanation

These so-called third party cookies are downloaded by your browser from Google's or Facebook's domain, not from the operator's (sub)domain. With these cookies, Google and Facebook can even track your use of the web, identify you on other websites, and even make ads based on your interests available to you on other websites. Disabling or deleting cookies placed by these external service providers does not affect the usability of the business simulation system.

16.How do I access my user data and content (data portability)?

You can copy the list of courses / trainings you have attended from the since you've registred, or upon your request from your registration email address, we will send it to you or to a third party designated by you in a widely used readable format. We can only list simulations that have not yet been deleted by a user with Teacher / Trainer user rights.#_ms

You can later save the user content uploaded to your system as long as our business partner requests that the simulation be stored (typically until the contract between EcoSim and our partner organizing the business simulation course expires, but the Teacher user has the right to delete it earlier). Your results in the simulations will also be available in the system for as long as it is requested by our business partner, so please make sure to copy them after the course / training is over.

17.Who can I contact with my privacy question, request, complaint?

You can request information about EcoSim's data management at any time. Write to us from your registration email address to support@ecosim.hu. We will respond via email within a maximum of 1 month.

You can request information about the data management we carry out concerning you, in connection with which we will inform you within 1 month at the latest.

1. the purposes of data management;
2. the categories of personal data stored;
3. the recipients or categories of recipients to whom the personal data have been or will be communicated;
4. the intended period of storage of the personal data or the criteria for determining that period;
5. about your rights as a data subject;
6. the right to lodge a complaint with the data protection supervisory authority;
7. if you did not provide the information, all available information about their source;
8. whether we make automated decision-making or not, and if so, what the logic is, what the significance of such data management is, and what the expected consequences are for you.

In an email from your registration email address, you can request that we restrict your data management if any of the following are true:

1. you dispute the accuracy of your personal information (in this case, the restriction applies to the period of time that allows us to verify the accuracy of your personal information);
2. in your opinion, the data processing is illegal and instead of deleting it, you ask to restrict its use;
3. we no longer need the data, we would delete it, but you are asking for it to make, enforce or defend legal claims.

In case of an alleged violation of the law related to the processing of your personal data, write us an e-mail to support@ecosim.hu. Your complaint will be investigated within 1 month at the latest.

If you have any questions about a business simulation, please contact the Teacher in charge of the simulation, who will also help you find your way in using the system; you can inquire about programs and events, at the e-mail addresses in the contact menu on the website advertising the given program.

If, in your opinion, we have violated the provisions of a data protection law, you should first contact us at support@ecosim.hu.

You can file a lawsuit with the competent court (Fővárosi Törvényszék or the court competent according to your place of residence) or initiate an investigation with the National Authority for Data Protection and Freedom of Information (NAIH)(1024 Budapest, Szilágyi Erzsébet fasor 22/C., 

ugyfelszolgalat@naih.hu

, +36-1-3911400, president: dr. Péterfalvi Attila, www.naih.hu).