Data protection statement

1 Purpose of this privacy notice

Innate code Ltd (Address: 24 Goldcrest Rise, Worksop, S81 8UG, United Kingdom, hereinafter referred to as the data controller) as data controller, acknowledges the contents of this legal notice as binding on her. It undertakes to ensure that any processing of data relating to its activities complies with the requirements of this policy and of applicable national law and European Union law. The privacy policy relating to the processing of data by the controller is permanently available to view at https://innatecode.com/privacypolicy.

The controller reserves the right to change this policy at any time. If or when this change commences, the audience has the right to know of any changes made in due time.

If you have any questions regarding this notice, please contact us (the Innate code team) and we will answer them as soon as possible.

The data controller is committed to protecting the personal data of its customers and partners, and attaches the utmost importance to respecting the right to information self-determination of its customers. The data controller treats personal data confidentially and takes all security, technical and organisational measures to ensure the security of the data.

The data management practices are described below.

2 Data controller's data

If you wish to contact the company, you can contact the controller using the following contact details.

Company name: Innate code Ltd.
24 Goldcrest rise, Worksop, S81 8UG, United Kingdom
Email: info@innatecode.com
Phone:+447403899942 (UK)

3. Scope of personal data processed

3.1 Personal data to be provided during registration

Fields to be filled in during registration:

User's first name (required)
e-mail address (required)
date of birth (required).

The data controller disclaims any liability for any damage or error in the service or the performance of the service resulting from incorrect or inaccurate data provided during registration. 3.3.1.1.

As a condition of registration, you must read the Privacy Statement, thereby familiarising yourself with it and accepting it as binding on you, and you must give your consent to the processing of your personal data, which you can confirm by ticking the appropriate box. The Data Controller ensures that the Privacy Statement is accessible and available on the Website at any time to any individual.

Registration is done by duly completing the available registration form. A confirmation email will then be sent to your email address. Once confirmed, you will be able to log in with the email address and password provided.

By registering, you will be automatically subscribed to the innatecode.com Newsletter. You can unsubscribe at any given time from the Newsletter, through https://innatecode.com/profile.

The data controller disclaims any liability for any damage or error in the service or the performance of the service resulting from incorrect or inaccurate data provided during registration. 3.3.1.1.

3.2 Technical data

The data controller selects and operates the IT tools used to process personal data in the provision of the service in such a way that the processed data is:

Accessible to those authorised to access it (availability);
Its authenticity is ensured (authenticity of processing);
Its integrity can be verified (data integrity);
Is protected against unauthorised access (data confidentiality).

The controller shall take appropriate measures to protect the data against unauthorised access, alteration, disclosure, erasure and against accidental destruction.

The controller shall ensure the security of the data processing, by implementing technical and organisational measures that provide a level of protection appropriate to the risks associated with the processing.

The controller shall retain during processing:

Confidentiality: it shall protect information so that only those who are entitled to access it have access to it;
Integrity: to protect the accuracy and completeness of the information and the method of processing;
Availability: it ensures that when the authorised user needs it, he has effective access to the information and the means to obtain it.

3.3 Cookies (Cookies)

3.3.1 What cookies do

Cookies collect information about visitors and their devices; remember visitors' individual preferences, which are used, for example, when making online transactions, so that their information does not have to be re-entered; to facilitate the use of the website; and to provide a quality user experience.

In order to provide a personalised service, a small piece of data, called a cookie, is placed on the user's computer and read back during a subsequent visit. If the browser returns a previously saved cookie, the cookie provider has the possibility to link the user's current visit to previous visits, but only in relation to their own content.

3.3.2 Strictly necessary session cookies

The purpose of these cookies is to enable visitors to browse the www.innatecode.com website, use its functions and services without interruption. This type of cookie is valid until the end of the session (browsing) and is automatically deleted from the computer or other browsing device when the browser is closed. The use of cookies is strictly necessary for the technical functioning of the website (e.g. for the correct display of graphical content), therefore it is not possible to disable them, but they do not collect any information that could be considered as personal data. The name of the token.

By accepting this privacy statement, the visitor acknowledges this.

3.3.3 Third party cookies (analytics)

The www.innatecode.com website also uses Google Analytics as a third party cookie. By using Google Analytics for statistical purposes, www.innatecode.com collects information about how visitors use the website. The data is used to improve the website and the user experience. These cookies will also remain on the visitor's computer or their other browsing devices until they expire or until they are deleted by the visitor.

3.4 Newsletter-related data

The newsletter is a weekly e-mail containing notifications related to the content of the website, information about courses, articles and special offers. Only with given consent (checkbox ticked) and by clicking on the confirmation link in your email (double opt-in) will your username, email address, and date of birth be stored in the database of the data processor (innatecode.com development team).

During the process, the customer can unsubscribe from the newsletter at any time.

The unsubscription is done by clicking on the link https://innatecode.com/profile and navigating to unsubscribe from the newsletter.

4. Intended use and retention period of the data processed.

The data will be used on the site for the purpose of calculating the user’s Innate code, Amoura, Biorhythm and for any future required contact with the user.

The legal basis for the processing is legitimate interest.

Retention period: the duration of the business relationship or untill the request for deletion.

4.1 List of cookies on the controller's websites

token: used to identify users
rememberMe: used to indicate whether or not the user remains logged in

4.2 Data related to online transactions

Personal data requested during contact:

Name (required field)
Email address (required field)

Purpose of the processing, intended use of the data processed: online administration,

Legal basis for the processing is voluntary consent.

Retention period: duration of the business relationship or request for deletion.

4.3 Newsletter / eDM related data

Newsletter subscription is done during registration or later by ticking the "Request newsletter" box on the User profile page. To subscribe to the Newsletter, you will need to provide the following information:

Name (required field)
Email address (required field)
Date of birth (required field)

The newsletter can be subscribed to after reading and accepting the Privacy Policy.

Acceptance of the privacy policy is done by accepting the mandatory checkbox that has not been filled in beforehand.

In all related processes, the customer will still have the possibility to unsubscribe, which can be done through User profile.

As the newsletter contains the name of the company and the contact details of its website, it is considered as an advertisement, eDM.

Purpose of the processing, intended use of the data processed: the data will be used to send a newsletter including advertising.

The legal basis for the processing is voluntary consent.

Retention period: duration of business relationship, request for cancellation or unsubscription.

4.4 Customer contact details

The personal data and contact details of customers are stored by the data controller and are as follows:

Name
Email address
Date of birth

Purpose of the processing, intended use of the data processed: contacting

Legal basis for processing is voluntary consent.

Retention period: duration of the business relationship or untill the request for deletion.

4.5 Data related to billing

The Data Controller invoices its customers for the services ordered, whereby the following data is stored:

Name
E-mail address
Address

Purpose of the processing, intended use of the processed data: invoicing.

Legal basis for processing: legal requirement.

Retention period: statutory retention period includes the current year + 5 years.

4.6 Data related to the order of a detailed analysis:

Name:
Date of birth, (person for whom the detailed analysis is made):

Purpose of the processing, intended use of the data processed: detailed analysis as ordered. Legal basis for the processing is voluntary consent. Retention period: duration of business relationship, request for deletion

5. Purpose, method and legal basis of data processing

5.1 General data processing policy

The data processing of the data controller's activities is based on voluntary consent and on legal authorisation. For processing based on voluntary consent, data subjects may withdraw their consent at any stage of the processing.

In certain cases, the processing, storage and transmission of some of the data provided is required by law and we will inform our customers separately.

We remind data controllers that, where data subjects do not provide their own personal data, it is the data subject's responsibility to obtain the data subject's consent.

Our data management principles are in accordance with the applicable data protection legislation, in particular the following:

Act CXII of 2011 - on the Right to Informational Self-Determination and Freedom of Information (Infotv.);
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Regulation (EC) No 95/46/EC (General Data Protection Regulation, GDPR);
Act V of 2013 - on the Civil Code (Civil Code);
Act C of 2000 - on Accounting (Accounting Act);
Act LIII of 2017 - on the Prevention and Combating of Money Laundering and Terrorist Financing (PMT);
Act CCXXXVII of 2013 - on Credit Institutions and Financial Undertakings (Hpt.).

6. Physical storage locations of data

Your personal data (i.e. the data that can be associated with you personally) may be processed by us in the following ways: in one way, the technical data relating to the computer, browser program, Internet address and pages visited are automatically generated in our computer system in connection with the maintenance of the Internet connection, and in addition, you may provide your name, contact details or other data if you wish to contact us personally when using the website or if you wish to use our website services - for the purpose of our analysis tools.

The website stores user data in an encrypted database. Users' passwords are stored further encrypted using bcrypt encryption, which guarantees that the website operators do not have access to the user's unique passwords.

Communication between the database and the website is also encrypted to prevent port traffic being read.

Data technically recorded during the operation of the system: the data of the computer of the logged-in person concerned, generated during the counting process and recorded by the https://innatecode.com/ system as an automatic result of technical processes. The automatically recorded data are automatically logged by the system on log-in and log-out without any specific declaration or action by the data subject. This data cannot be linked to other personal user data, except in cases required by law. The data is only accessible by https://innatecode.com/.

7 . Data transfer, data processing, data subjects

Database:

Scope of data accessed:

Amazon SES - email sending, user name and email address are stored.
https://www.mongodb.com/company - stores other data about users.
https://innatecode.com/ website content, emails sent to email addresses based on this domain.
Amazon S3 - content serving, video, image

Email and hosting provider:

https://aws.amazon.com

Website:

https://www.salesforce.com/company/privacy/

https://innatecode.com/

Payment:

https://stripe.com/en-gb-hu/about

Email and hosting provider:

https://aws.amazon.com

Amazon SES - we will publish the user's name and email address for email sending.

Amazon S3 - where we store users' profile picture

8. Data subject's rights and means of redress

The data subject may request information about the processing of their personal data, and may request the rectification, erasure or withdrawal of their personal data, except for mandatory data processing, and may exercise their right to data portability and objection as indicated when the data were collected, or by contacting the controller at the above contact details.

8.1 Right to information

The controller shall take appropriate measures to provide data subjects with all the information referred to in Articles 13 and 14 of the GDPR and each of the notifications referred to in Articles 15 to 22 and 34 of the GDPR concerning the processing of personal data in a concise, transparent, intelligible and easily accessible form, in clear and plain language.

8.2 Right of access of the data subject

The data subject shall have the right to obtain from the controller feedback as to whether or not their personal data are being processed and, where such processing is taking place, the right to access to the personal data and the following information:

The purposes of the processing;the purposes for which the personal data are being processed;
The categories of personal data concerned;
The recipients or categories of recipients to whom or with whom the personal data have been or will be disclosed, including in particular recipients in third countries or international organisations;
The envisaged period of storage of the personal data;the right to rectification, erasure or restriction of processing and the right to object;
The right to lodge a complaint with a supervisory authority;
Information on the data sources; the fact of automated decision-making, including profiling, and clear information on the logic used and the significance of such processing and its likely consequences for the data subject.

The controller shall provide the information within a maximum of one month from the date of the request.

8.3 Right of rectification

The data subject may request the correction of inaccurate personal data relating to them processed by the controller and the completion of incomplete data.

8.4 Right to erasure

The data subject shall have the right to obtain, upon their request and without undue delay, the erasure of personal data relating to them by the controller on one of the following grounds:

The personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
The data subject withdraws the consent on the basis of which the processing was carried out and there is no other legal basis for the processing;
The data subject objects to the processing and there are no overriding legitimate grounds for the processing;
The personal data have been unlawfully processed;
The personal data must be erased in order to comply with a legal obligation under Union or Member State law to which the controller is subject;
The personal data have been collected in connection with the provision of information society services.

The erasure of the data may not be initiated if the processing is necessary: for the exercise of the right to freedom of expression and information; for compliance with an obligation under Union or Member State law to process personal data or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; for public health purposes or for archiving, scientific or historical research purposes or statistical purposes in the public interest; or for the establishment, exercise or defence of legal claims.

8.5 Right to restriction of processing

At the request of the data subject, the controller shall restrict processing if one of the following conditions is met:

The data subject contests the accuracy of the personal data, in which case the restriction shall apply for a period of time which allows the accuracy of the personal data to be verified;
The processing is unlawful and the data subject opposes the erasure of the data and requests instead the restriction of their use;
the controller no longer needs the personal data for the purposes of the processing but the data subject requires them for the establishment, exercise or defence of legal claims; or:
the data subject has objected to the processing; in which case the restriction shall apply for a period of time until it is established whether the legitimate grounds of the controller override the legitimate grounds of the data subject.

Where processing is restricted, personal data, other than storage, may be processed only with the consent of the data subject or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or of an important public interest of the Union or of a Member State.

8.6 Right to data portability

The data subject has the right to receive personal data relating to them which they have provided to the controller in a structured, commonly used, machine-readable format and to transmit such data to another controller.

8.7 Right to object

The data subject shall have the right to object at any time, on grounds relating to their particular situation, to processing of their personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, or necessary for the purposes of the legitimate interests pursued by the controller or by a third party, including profiling based on those provisions. In the event of an objection, the controller may no longer process the personal data, unless there are compelling legitimate grounds for doing so which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

8.8 Automated decision-making in individual cases, including profiling

The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or significantly affects them.

8.9 Right of withdrawal

The data subject has the right to withdraw their consent at any time.

8.10 Right to apply to the courts

The data subject may take legal action against the controller in the event of a breach of their rights. The court shall rule on the matter out of turn.

8.11 Data protection authority procedure

Complaints may be lodged with the National Authority for Data Protection and Freedom of Information: Name: Nemzeti Adatvédelmi és Információszabadság Hatóság Székhely: 1125 Budapest, Szilágyi Erzsébet fasor 22/C. Postal address: 1530 Budapest, Pf.: 5. Phone number: 0613911400 Fax: 0613911410 E-mail: ugyfelszolgalat@naih.hu Website: https://www.naih.hu

9. Other provisions

Information on data processing not listed in this information notice will be provided at the time of data collection.

We inform our customers that the court, the prosecutor, the investigating authority, the law enforcement authority, the administrative authority, the National Authority for Data Protection and Freedom of Information, the Hungarian National Bank or other bodies authorised by law may contact the data controller to provide information, to communicate or transfer data or to make documents available.

The controller shall disclose to the authorities - if the authority has indicated the precise purpose and scope of the data - personal data only to the extent and to the extent strictly necessary for the purpose of the request.

(This Privacy Notice is based on the recommendation of the Budapest Chamber of Commerce and Industry.)

COPYRIGHT

By accessing any of the pages of https://innatecode.com, you accept the following terms and conditions, even if you are not a registered user or subscriber of any of the services of the system: all content published on the site, including its structure, analysis tools, descriptions, DEMO versions, live versions, documentation, graphics, the terms of use, privacy policy and this copyright notice, is the intellectual property of Innate code Ltd, and is protected by copyright.

Any unauthorised use, copying or publication of the contents of this website is prohibited. No part of the content of the site may be freely quoted, unless the author has given their written consent and the author of the article indicates the web address www.innatecode.com in the source.

You may save or print out parts of the content of the site for your own personal use only. You are not entitled to use, distribute, store in a database, download or commercialise the reproduced parts of the site.

Links to any part of the pages may be included in other online content without prior request. We may; however, request that the link be removed at any time in circumstances not appropriate to our site. Unauthorised use will result in criminal and civil penalties. The author may demand the cessation of the infringement and compensation for damages. The reproduction of all or part of the calculations, technical solutions, ideas, texts and materials related to the calculations contained in the main and related sub-pages of the Innate code is prohibited and illegal under copyright and intellectual property laws.

In addition, decompilation of calculations, analysis of database structure, and manipulation from external programs is strictly prohibited. Our team will take legal action in any case of violation of the above, based on notarized evidence.