Under the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council, hereinafter referred to as ‘GDPR’), MEDI-RADIOPHARMA Egészségügyi Szervező, Tanácsadó, Szolgáltató és Kereskedelmi Kft., registered in Hungary under trade registry number Cg. 13-09-119709, and having a registered seat at 10-12 Szamos utca, ÉRD, H-2030, Hungary (hereinafter referred to as the ’Controller’) herewith provides the following information on its processing of personal data at https://www.mediradiopharma.com website (hereinafter referred to as ‘Website’) used with the online order form operated by the Controller (hereinafter referred to as ‘Fast Track Order’).
By using the Website and/or the Fast Track Order function you declare and affirm that you are at least 16 years old, that you are capable of legal acts without any limitation and that you are duly authorized to represent the institute or company you are representing with regards to requests for quotations and placement of orders.
Persons under the age of 16 years may not register, or place orders for products or services, request for quotation, since Article 8, Section 1 requires consent given or authorized by the holder of parental responsibility for the consent given by the Data Subject in order to lawfully process personal data. As the Controller has no reliable means to verify the Data Subject’s age, unlimited legal capacity, power of representation, the Data Subject warrants and is responsible for the veracity of the supplied data.
By using the Website and/or the Fast Track Order function you declare and affirm that you have read and accepted our Pharmacovigilance Clause for ad-hoc delivery Contracts for the compliance with the legal pharmacovigilance obligations the Controller is subject to. Please note that in order to use the Website and/or the Fast Track Order function, the ‘Pharmacovigilance Clause for ad-hoc delivery Contracts’ and its Appendix 1, 2 and 3 must be accepted first by the Data Subject and/or by the represented institute or company, and that it is a pre-requisite to any request for quotation or placement of orders.
The Controller hereby informs the Data Subject, that in order to use the Website’s Fast Track Order functions, as well as to keep records and perform orders, providing of Business Contact Data is required, as well as consent by the Data Subject to the handing of the Business Contact Data and the Pharmacovigilance Data by the Data Controller.
Consent by the Data Subject to the handling of IT Data to use the Website is not required.
II. Processing personal data - aim, scope, legal basis, and duration
1. Aim of processing data
A) Business Contact Data
The purpose of processing Business Contact Data on the Fast Track Order is to establish and maintain business relationship with future and existing partners interested in the Controller’s products and services, in order to provide unique offers and to make and perform contract(s); in addition these facilitate access by business partners to informative materials published by the Controller from time to time. The processing of Business Contact Data is justified by the fact that in absence of such data, the Controller may not be able to make contact with the business partner represented by the Data Subject, provide offers suitable for specific requirements, prepare and perform the contract(s).
To achieve the purpose of data processing, voluntary provision of the necessary contact information through the Website (or via any other communication channel) is required prior to establishing Business Contact.
No provision of personal data of the Data Subject is required to download the informative materials published on the Website.
B) IT Data processed for the use and technical operation of the Website
The processing of IT Data is justified by future improvement and development of the Website, which may provide you with more pleasant, simpler, and efficient use.
During the visit of our Website, small text files, called cookies (hereinafter referred to as ’Cookies’) may be stored temporarily or permanently by the web browser on your, i.e. the Data Subject’s computer (on a desktop PC, smartphone or on a tablet, should you use the web browser on such devices).
The purpose of the web analytics measurements is to assess searching and browsing habits of visitors of our Website, map keywords used in search engines, and to use this information to expand and improve our Website to make your browsing experience better, simpler and more efficient in the future.
These Cookies cannot be used for personal identification the Data Subject.
With the help of the Cookies, you may take advantage of all functions of the Website, however using the Cookies is not a prerequisite to using the Website, nor it is required for requests for quotations or for making contracts.
Furthermore, with the proper technical settings you may refuse, block, or delete the Cookies used on our Website, or you may revoke any consent you have provided. Revoking your consent does not affect the legality of using data prior to the revoking of the given consent.
C) Pharmacovigilance Data
The processing of Pharmacovigilance Data is justified by the Controller’s legal obligation to comply with the pharmacovigilance laws the Controller is subject to, including Article 32, Section 5, subsection t) of Hungary’s Medicine Act XCV of 2005, with the obligations further detailed in Decree 15/2012 (VIII.22) by the Hungarian Ministry of Human Resources (EMMI), as well as Directive 2001/83/EC of the European Parliament and of the Council on the Community code relating to medicinal products for human use and by various other legal acts of the European Union, and also by the legitimate individual and public interests related to maintain public health and to prevent and mitigate any possible damages.
These laws oblige the Controller to receive, record and to keep records of for the duration set by laws (i.e. for five years after the validity of the distribution permit has lapsed) any pharmacovigilance report related to medicine product, and, if necessary, to hand them over to the authorities.
Pharmacovigilance report means that if the consumer placing the order (either through the Fast Track Order Website, or via another channel) becomes aware of any adverse events (AE) or medical information queries, product technical/quality complaints that may be connected to medicine products ordered from the Controller, then – regardless of the severity of the adverse event – the consumer is obliged by law to report that adverse event to the Controller or its contracted qualified professional for pharmacovigilance (QPPV) at their respective contact addresses within three (3) calendar days by using a CIOMS form or equivalent report form.
The so-called CIOMS forms is used to provide pharmacovigilance reports that contain sensitive data (i.e. medical data) which – in the event that the person submitted the pharmacovigilance report would submit it directly to the Controller for any reason - we shall process with due care under Article 9, Paragraph 2, subsection h) of the GDPR and forward it to the qualified professional for pharmacovigilance reports.
Wherever the Controller receives a pharmacovigilance report, the Pharmacovigilance Data shall be transferred to the qualified professional for pharmacovigilance, who shall be controlling the data under strict professional rules and medical confidentiality.
Where the consumer notifies by e-mail the Controller’s QPPV of the following cases, whether or not an AE is present within 3 business days as required by Module VI of the GVP guideline: a) Overdose, b) Off-label use, c) Misuse/Abuse, d) Accidental and Occupational Exposure Reports, e) Pregnancy or Breastfeeding Exposure Reports, f) Falsified Medicine Reports, g) Suspected adverse reactions related to quality defect h) drug-to-drug interactions, i) Lack of Efficacy Reports, j) transmission of an infectious agent and k) medication errors.
Business Contact Data handled by the Controller may be received by the Controller’s decisionmakers and employees involved in making and performing contracts prepared via the Controller’s Fast Track Order Website, and – to the extent necessary to the rightful interests, enforcing of lawful claims and complying with legal obligations – may be also received by financial and legal professional consultants engaged to support business operations of the Controller, to the extent necessary and sufficient to achieve the purpose of controlling the data, while observing strict professional rules and confidentiality.
IT Data handled by the Controller may be received by the Controller’s decisionmakers and employees involved in making and performing contracts prepared via the Controller’s Fast Track Order Website, and – to the extent necessary for developing and performing web analytics on the Website and creation of reports on business operations – may be also received by information technology individuals and companies, data processors engaged to support the business operations of the Controller, to the extent necessary and sufficient to achieve the purpose of controlling the data.
Pharmacovigilance Data, since it contains sensitive (medical) personal data shall be controlled exceptionally, on a case by case basis by a responsible, qualified professional engaged by the Controller to comply with pharmacovigilance obligations (QPPV), who shall observe strict professional confidentiality.
The Qualified professional for pharmacovigilance (QPPV) and his contact information is:
Name: Dr. Kunos László
Reg. seat at: 10-12 Szamos utca, ÉRD, H-2030, Hungary
Phone: +36 30 643 6850
3. Duration of processing of the Personal Data
The duration of processing the Personal data is detailed in the table found in Section 4 below.
The Controller shall store the personal data in a manner and for a duration described below which permits identification of Data Subjects for no longer than it is necessary for the purposes for which the Personal Data is processed; the Controller shall also review the necessity of processing the Personal Data from time to time.
Personal data may be stored for longer periods than stated insofar as the personal data is processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with GDPR regulations and subject to implementation of the appropriate technical and organizational measures required by the GDPR in order to safeguard the rights and freedoms of the data subject (‘storage limitation’).
4. Processing of Personal Data - Overview
With the following table, you may easily review how the Controller’s Fast Track Order Website processes specific personal data, on what legal basis, with what purpose and for what duration.
Business Contact Data
Legal basis for processing Personal Data:
processing is necessary for the performance of a contract to which the Data Subject is party or to take steps at the request of the Data Subject prior to making a contract.
GDPR, Article 6. Paragraph 1. b).
Personal Data being processed:
a) First and last name(s), position, phone number, e-mail address of the Data Subject responsible for maintaining contact.
b) Data required to identify the consumer (or the entity requesting quotation), i.e. company or institute and its contact information: country, city, name of the company/institute, corporate data or equivalent (registered seat, tax number, trade registry number, license identification, website URL, phone number, e-mail address.
c) Ordered products and their quantities.
Purpose of Data Processing:
a) Preparing contracts and initiating business contact; identification of the entity requesting quotation and the establishing the identity rights of its representative authorized for maintaining contact and placing orders.
b) Preparing and performing of contracts; assessing delivery costs and relevant legal framework, maintaining confidential business communication, providing of unique offers prior to making contract.
c) Preparing, making, and performing contracts.
Duration of processing Personal Data:
a) Until request by the Data Subject to erase personal data, or until the final termination of the contractual relationship, at which point the personal data shall be immediately erased.
b) Country, City, the company/institute name of the consumer, corporate/institutional data, website URL shall be stored for 8 years from the termination of contractual relationship, under Sections 168-169 of the Hungarian Act no. C of 2000 on Accounting; the phone number, e-mail address, position of the contact person shall be immediately erased at the final termination of the contractual relationship.
c) Following the lapse of the generic civil law forfeit period (5 years), as defined in the Hungarian Civil Code; after five years from the emergence of the civil law claim.
Legal basis for processing Personal Data:
Consent given by the Data Subject to the processing of personal data for specific purposes.
GDPR, Article 6. Paragraph 1. a).
Personal Data being processed:
Purpose of Data Processing:
Operating functions of the Website, providing web analytics report
Duration of processing Personal Data:
Legal basis for processing Personal Data:
Complying with the Data Controller’s legal obligations:
GDPR, Article 6. Paragraph 1. c) GDPR, Article 9. Paragraph 2. h) the Hungarian Medical Act XCV, Section 32, paragraph 5. t), detail regulations by Decree 15/2012 (VIII.22). the Hungarian Ministry of Human Resources
Personal Data being processed:
As per CIOMS form, including reaction information, Suspect Drugs information, Concomitant drugs and history, manufacturer’s information Name, position, phone, and e-mail of the patient’s initials, Place where the adverse events have occurred (country), and its description (start, end, results) Reaction information: patient initials, country, date of birth, age, sex, reaction onset, medical data on the result of adverse reaction. Suspect drug(s) information, including generic name of drug, daily doses, route(s) of administration, reactions to taking and stopping taking drugs, indications for use, therapy dates, duration, Concomitant drug(s) and history, dates of their administration, other relevant medical history
Purpose of Data Processing:
Questions and quality issues related to the delivered products, compliance with legal obligations related to side effects, adverse events, and other pharmacovigilance obligations
Duration of processing Personal Data:
Until the date set in legal regulations; stored until 5 years following the lapse of validity of the distribution license
1. Profiling, automated decision making
The Controller shall not use the Personal Data for profiling or for automated decision-making and shall not perform profiling or automated decision-making process on the processed data.
The Controller shall use the personal data solely for the purpose of sending unique business offers that were requested by the Data Subject and shall not them for the purpose of sending newsletters, nor relay them to third parties.
3. Data transfer
All data provided by the Data Subject shall be transferred by the Website to the e-mail address firstname.lastname@example.org.
4. Third Parties
The Controller shall not transfer the Personal Data to any other third person other than those designated to process the date; transfer of Personal Data shall be performed exclusively by order of the courts and authorities or to comply with obligations set by laws.
5. Data Security
Personal Data shall be processed by the Controller in a manner that ensures appropriate security of the Personal Data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage. The Controller shall protect the data with state-of-the-art information technology solutions, taking into account in particular accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, and furthermore from inaccessibility resulting from the applied technological solutions.
6. Data Integrity
The Data Subject is responsible to ensure that the Personal Data provided is up-to-date and accurate. If the provided Personal Data was inaccurate or obsolete, or becomes such, the Data Subject shall notify the Controller thereof through the channels used to maintain Business Contact, and the Controller shall correct or erase the inaccurate or obsolete Personal Data without any undue delay; the Controller however is not obliged to check whether the Personal Data is up-to-date or if it is accurate.
IV. Data Processors
The Controller may transfer the Personal Data to the following Data Processors for the purpose of complying with pharmacovigilance obligations, to the create web analytics reports, maintain business contacts via e-mail and or to host the Website via third party webhosting services.
- Data Processor: 3Gteam Kereskedelmi és Szolgáltató Kft.
- Address of Data Processor: 23 Horánszky utca Budapest, H-1085 Hungary
- Data Processing Activity: Webhosting
- Data involved in the Data Processing: IT Data
- Data Processor: Microsoft Corporation
- Address of Data Processor: One Microsoft Way, Redmond, Washington 98052 USA
- Data Processing Activity: Emails
- Data involved in the Data Processing: Business Contact Data
- Data Processor: Google LLC
- Address of Data Processor: 1600 Amphitheatre Parkway Mountain View, CA 94043 USA
- Data Processing Activity: Web Analytics
- Data involved in the Data Processing: IT Data Cookie
- Data Processor: Dr. Kunos László
- Address of Data Processor: 10-12 Szamos utca Érd, H-2030, Hungary
- Data Processing Activity: Qualified professional for pharmacovigilance
- Data involved in the Data Processing: Pharmacovigilance Data
The Data Processor(s) shall process the data according to the instructions received from the Controller, and shall store, analyze, forward, protect and erase the Personal Data according to the instructions received from the Controller.
The Data Processor(s) may not make independent or relevant decisions on their own and may not process the data for their own purposes.
Designated employees of the Data Processor(s) may access the data during the data processing activities.
V. Your Rights as the Data Subject
The Controller shall take appropriate measures to provide any information and access to Personal Data and shall provide information where Personal Data have not been obtained from the Data Subject referred and any communication on the Right of access by the Data subject, Automated individual decision-making, including profiling and on Communication of a personal data breach to the Data Subject relating to processing to the Data Subject in a concise, transparent, intelligible and easily accessible form, using clear and plain language, in particular for any information addressed specifically to a child.
The information shall be provided in writing, or by other means, including, where appropriate, by electronic means. When requested by the Data Subject, the information may be provided orally, provided that the identity of the Data Subject is proven by other means.
The Controller shall facilitate the exercise of Data Subject rights regarding the Right of Access by the Data Subject and on Automated individual decision-making, including profiling. The Controller shall not refuse to act on the request of the Data Subject for exercising his or her rights, unless the Controller demonstrates that it is not in a position to identify the Data Subject.
The Controller shall provide information on action taken on a request concerning the Rights of the Data Subject to the Data Subject without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. The Controller shall inform the Data Subject of any such extension within one month of receipt of the request, together with the reasons for the delay.
Where the Data Subject makes the request by electronic form means, the information shall be provided by electronic means where possible, unless otherwise requested by the data subject. If the Controller does not take action on the request of the Data Subject, the Controller shall inform the Data Subject without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.
Information provided where Personal data are collected from the Data Subject and where Personal Data have not been obtained from the Data Subject and any communication and any actions taken under exercising the Right of access, rectification, erasure, restriction of processing or notification thereof, data portability, the Right to object or rights concerning automated individual decision-making, or Communication of a personal data breach to the Data Subject shall be provided free of charge. Where requests from a Data Subject are manifestly unfounded or excessive, in particular because of their repetitive character, the Controller may either charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or refuse to act on the request. The Controller shall bear the burden of demonstrating the manifestly unfounded or excessive character of the request.
Where the Controller has reasonable doubts concerning the identity of the natural person making the request concerning the Right of access, rectification, erasure, restriction of processing, notification obligation regarding rectification, erasure of personal data, restriction of processing, data portability or the Right to object, the Controller may request the provision of additional information necessary to confirm the identity of the Data Subject.
Right to access
The Data Subject shall have the right to obtain from the Controller confirmation as to whether or not Personal Data concerning him or her are being processed, and, where that is the case, access to the Personal data and the following information:
(a) the purposes of the processing.
(b) the categories of personal data concerned.
(c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations.
(d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period.
(e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing.
(f) the right to lodge a complaint with a supervisory authority.
(g) where the personal data are not collected from the data subject, any available information as to their source.
(h) the existence of automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
Where Personal Data are transferred to a third country or to an international organization, the Data Subject shall have the right to be informed of the appropriate safeguards pursuant to the GDPR relating to the transfer. The Controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the Controller may charge a reasonable fee based on administrative costs. Where the Data Subject makes the request by electronic means, and unless otherwise requested by the Data Subject, the information shall be provided in a commonly used electronic form.
The right to obtain a copy shall not adversely affect the rights and freedoms of others.
Right to rectification
The Data Subject shall have the right to obtain from the Controller without undue delay the rectification of inaccurate personal data concerning him or her. The Data Subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Right to erasure (‘right to be forgotten’)
The Data Subject shall have the right to obtain from the Controller the erasure of Personal Data concerning him or her without undue delay and the Controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
(a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
(b) the data subject withdraws consent on which the processing is based on the Data Subject’s consent, or on exceptions from the general prohibition of processing of special categories of personal data, provided that there is no other legal ground for the processing;
(c) the Data subject objects the processing and there are no overriding legitimate grounds for the processing, or the Data Subject objects to the processing for direct marketing purposes.
(d) the Personal Data have been unlawfully processed.
(e) the Personal Data must be erased for compliance with a legal obligation of the European Union or the laws of Hungary to which the Controller is subject
(f) the Personal data have been collected in relation to the offer of information society services.
Where the Controller has made the personal data public and is obliged to erase the personal data, the Controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform Controllers which are processing the Personal Data that the Data Subject has requested the erasure by such controllers of any links to, or copy or replication of, those Personal Data.
The Right to erasure shall not apply to the extent that processing is necessary:
(a) for exercising the right of freedom of expression and information.
(b) for compliance with a legal obligation which requires processing by Union or by Hungarian law to which the Controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
(c) for reasons of public interest in the area of public health where processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Hungarian law or pursuant to contract with a health professional and when those data are processed by or under the responsibility of a professional subject to the obligation of professional secrecy under Union or Hungarian law or rules established by national competent bodies or by another person also subject to an obligation of secrecy under Union or Hungarian law or rules established by national competent bodies; or when processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of Union or Hungarian law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject, in particular professional secrecy; or for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in so far as the right would likely to render impossible or seriously impair the achievement of the objectives of that processing; or for the establishment, exercise or defense of legal claims.
Right to restriction of processing
The Data Subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
(a) the accuracy of the Personal Data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
(b) the processing is unlawful, and the Data Subject opposes the erasure of the Personal Data and requests the restriction of their use instead.
(c) the Controller no longer needs the Personal Data for the purposes of the processing, but they are required by the Data Subject for the establishment, exercise, or defense of legal claims.
(d) the Data Subject has objected to processing, pending the verification whether the legitimate grounds of the
Controller override those of the data subject.
2. Where processing has been restricted, such Personal Data shall, with the exception of storage, only be processed with the Data Subject's consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
A Data Subject who has obtained restriction of processing shall be informed by the Controller before the restriction of processing is lifted.
Right to data portability
The Data Subject shall have the right to receive the Personal Data concerning him or her, which he or she has provided to a Controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent or where the Data subject has given explicit consent to the processing of special categories of Personal Data for one or more specified purposes, except where Union or Hungarian law provide that the prohibition for processing of special categories of Personal Data may not be lifted by the data subject; or where processing is necessary for the performance of a contract; and where processing is carried out by automated means. In exercising his or her Right to data portability, the Data Subject shall have the right to have the Personal Data transmitted directly from one controller to another, where technically feasible.
The exercise of the Right to data portability shall be without prejudice to the Right to erasure. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller.
The Right to data portability shall not adversely affect the rights and freedoms of others.
Right to object
The Data Subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of Personal Data concerning him or her which is based on necessity for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; or where 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, in particular where the data subject is a child, including profiling based on those provisions. The Controller shall no longer process the Personal Data unless the Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the Data Subject or for the establishment, exercise or defense of legal claims. Where Personal Data are processed for direct marketing purposes, the Data Subject shall have the right to object at any time to processing of Personal Data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where the Data Subject objects to processing for direct marketing purposes, the Personal Data shall no longer be processed for such purposes. Where Personal Data are processed for scientific or historical research purposes or statistical purposes, the Data Subject, on grounds relating to his or her particular situation, shall have the right to object to processing of Personal Data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
VI. Legal remedies
The Data Subject may exercise these rights in connection to processing of his/her Personal Data at the following contacts of the Controller:
MEDI-RADIOPHARMA Egészségügyi Szervező, Tanácsadó, Szolgáltató és Kereskedelmi Kft.
Registered / Postal Address: 10-12 Szamos utca, ÉRD, H-2030, Hungary
Trade Registry no.: 13-09-119709
Tax no.: 12090503-4-13
Representatives: Managing directors dr. Jánoki Győző Aladár and Jánoki Gergely
The Data Subject may request legal remedies from the Hungarian Data Protection and Freedom of Information Authority (Nemzeti Adatvédelmi és Információszabadság Hatóság, registered seat: 22/c Szilágyi Erzsébet fasor, BUDAPEST, H-1125, Hungary, P.O. Box: 1530 Budapest, P.f. 5., URL: www.naih.hu, phone: +36 (1) 391-1400, fax: +36 (1) 391-1410, e-mail: email@example.com)
The Data Subject may request legal remedy from the competent Court of jurisdiction, based on the registered seat of the Controller (Budapest Környéki Törvényszék, 179-187 Hungária körút, BUDAPEST, H-1146 Budapest, Hungary), or, depending on your choice, competent Court of jurisdiction based of the registered address of the Data Subject.