Privacy

PRIVACY NOTICE AND INFORMATION ON THE PROCESSING OF PERSONAL DATA

1 April, 2022

What is this notice about?

The purpose of this notice is to inform you about the most important features of the processing activities, the data processing via our aceadvisory.eu and footballbenchmark.com websites and the way we ensure your personal data’s protection.

Our principle

We manage your personal data solely in light of the provisions of the applicable data protection law, and our data processing policies, including this notice, are in accordance with Act CXII of 2011 on Freedom of Information (Info tv.) and Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter: GDPR).

Your personal data – what does it mean?

By personal data we mean any information related to an identified or identificable natural person („data subject”); a natural person is identificable when they can be identified directly or indirectly, especially by reference to an identification such as a name, number, location data, an online identifier or to one or more factors of the physical, physiological, genetic mental, economic, cultural or social identity of the natural person

Who are we?

Ace Advisory Zrt. provides business advisory services to international and national private and public sector clients in the areas related to sports and leisure.

Our clients are owners of football clubs and golf courses, developers and operators of sports and leisure facilities, sports federations, governmental bodies and investors.

Our services are: market research, market and financial feasibility studies. strategy framing, business and investment plans, valuations of business, making economic impact assessments.

Moreover, we also create analyses and publicly available studies in the field of sport and leisure business and provide access to an interactive data-visualisation platform built by our company and operated on footballbenchmark.com in a subscription-based model.

Contact details in relation to questions about data process:

If there is any question about the content of this notice or the procesing of your personal data already given, you can contact Ace Advisory Zrt:

Ace Advisory Zrt.

legal seat: HU-Budapest 1052, Haris köz 4. 1/1.

postal address: HU-Budapest 1052, Haris köz 4. 1/1.

e-mail address: gdpr@aceadvisory.eu

telephone: +36 70 333 1541

The controller does not have a data protection officer.

For what purposes do we process personal data?

Personal data is processed for the following purposes:

How to contact us: via website form, e-mail, telephone;
Registration on the website
Sending newsletters
Cookies

We provide specific information about our data processing activities not covered by this notice, subject to the provisions of our procedures for guaranteeing data subjects’ rights, security of personal data and contact details of controllers.

I. Processing of data Related to Contact, Call for proposals, Communication and registration

Scope of processed data: The personal data given in a message (including especially the contact details of the enquirer or another data subject and the circumstancesof the matter with which the enquirer has contacted us)

If you contact us with a question or request, we process the personal data you give in a message, e-mail, postal letter or telephone call for the purpose of communicating with you, and responding to your request.

The legal ground for processing data is your voluntary consent based on appropriate information for using your personal data for the above mentioned purposes [Article 6 GDPR (1) (a)].

You may recant your consent anytime, without any justification and limitation, free of charge by sending a request to the e-mail address gdpr@aceadvisory.eu, via telephone on the number +36 70 333 1541 or by postal letter (postal address: HU-Budapest 1052, Haris köz 4. 1/1.).

Through the ’Connect with us’ menu item, we process the personal data given in the message (including especially the contact details of the enquirer or other data subject and the circumstances of the matter with which the enquirer has contacted us). Your message will come to the e-mail address info@aceadvisory.eu, to which the access is limited.

If you contact us by telephone, we will process your personal data if further communication, respond to your enquiry or complaint is needed, and in this case we also register your name and telephone number, if necessary, the date and time of the conversation and any other personal data you give us for feedback.

In case of a letter sent by post, we also register the sender’s name, address, the subject of the letter and the date of the delivery and in case of outgoing letters we also register the name of the recipient, the settlement and the postal code.

We delete personal data processed in connection with requests for further administration and claims after the termination of the purpose of data processing, but no later than 5 years after the date of disclosure.

II. DATA PROCESSING IN CONNECTION WITH REGISTRATION ON THE WEBSITE

Interactive dashboard access

By registering on our website, you automatically get access to our interactive data-platform, which you can use according to your preferences, free of charge and without time limits. The data given during the registration is used exclusively to be able to access the platform, it is not used for any other purpose and is not transmitted to third parties.

Scope of the data processed: Surname, forename, e-mail address, telephone number, name of the company, legal seat of the company

The legal ground for processing data is your voluntary consent given in the contact form based on appropriate information for using your personal data for the above mentioned purposes [Article 6 GDPR (1) (a)].

Duration of data processing: until consent is recant.

III. SENDING NEWSLETTERS

Subscribing to professional content

Once you have subscribed to our newsletter, that is, with your consent, we will contact you using the contact details you have given (e-mail address), in accordance with our efforts in marketing and communication, to inform you about the following:

• our publicly available professional matter (studies, articles, news),

• our events and services,

• development related to our operation, including websites and social channels.

Scope of the data processed: Surname, forename, e-mail address, telephone number, name of the company, legal seat of the company

IV. THE USE OF COOKIES

Your Privacy
When you visit any website, it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience. Because we respect your right to privacy, you can choose not to allow some types of cookies. Click on the different category headings to find out more and change our default settings. However, blocking some types of cookies may impact your experience of the site and the services we are able to offer. More information

Strictly Necessary Cookies - Always Active
These cookies are essential to ensure that the visitor can navigate and use certain functions of the website. Without them, essential parts of the website cannot be used. Accordingly, these cookies are always activated. They are only used when you visit our website and are usually deleted when you close your browser. They are also used to call up the optimised website display when accessed with a mobile device so that, for example, your data volume is not unnecessarily consumed. The cookies also facilitate the page change from http to https, so that the security of the transferred data remains guaranteed.

Performance Cookies
These cookies collect data on user behaviour. On this basis, the website is adjusted to the general user behaviour in terms of content and functionality. The information collected is generally processed in aggregated form, unless a visitor has expressly consented to a personal evaluation. Performance cookies are only used to improve the performance of the website and to tailor the online experience to the needs of the users.

Functional Cookies
Functional cookies enable the website to store information such as the user name or language selection and to offer the user improved and personalised functions based on this information. The information collected is only evaluated in aggregated form. Since we would like to offer you a website that is designed for optimum user-friendliness, we recommend that you activate these cookies. Functional cookies are also used, for example, to activate the functions you desire, such as the playback of videos.

Targeting Cookies
Marketing cookies are used to offer content that is more relevant to the user and adapted to his interests. They are also used to measure and control the effectiveness of campaigns. For example, they register whether a website has been visited or not, as well as which content has been used. This information is used to create an interest profile so that only content that is interesting for you is displayed. If you withdraw your consent to marketing cookies, this does not mean that you will see or receive less content as a result. Rather, it means that the content you see and receive is not tailored to your individual needs.

V. ACE ADVISORY ZRT. SOCIAL MEDIA SITES

The use of Ace Advisory Zrt.’s social media platforms (e.g: Facebook, Instagram, Linkedin, Twitter, Youtube) is subject to the terms of use of the exact social media. The processing of data through the use of social media is governed mainly by the data processing policies of the exact social media type. By liking, commenting, following, you consent (legal ground of data process: Article 6 (1) a) GDPR) to the disclosure of your name/user name and to become it aware for Ace Advisory Zrt. in accordance with the social media policy and your account settings. You have the possibility to unlike, delete your comments, or unfollow others according to the rules of the social media. Please contact your social media service provider primarily with any data protection issues related to your use of social media.

By collecting data for statistical purposes about the visits to our Facebook page (Facebook Insights), we can understand better who visits our page, how many people or accounts have viewed, reacted to or commented on our posts, and we also get integrated demographics to get to know easier the interactions and types of visitors of our Facebook page. In the processing of data for statistical purposes on the Facebook page of Ace Advisory Zrt. the joint controllers are Ace Advisory Zrt. and Facebook Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, D2 Dublin, Ireland), (legal ground of data process: Article 6 (1) (f) GDPR). You can find detailed information of the joint controllership agreement by visiting the Facebook Insights (Page Analytics) feature's data process appendix: https://www.facebook.com/legal/terms/page_controller_addendum, which states that Facebook is obliged to inform you of the details of Facebook's data processing method for this purpose and that you can exercise your rights as a data subject with Facebook.

Visitor data is collected by using cookie technology placed by Facebook, which all contain a unique user identification. The expiration-date of the cookie is 2 years. If you visit our Facebook page with a registered Facebook account, Facebook recognises and monitors your behaviour on our Facebook page at the moment you open it and processes the information obtained. We use anonymised statistical visitor data to make our Facebook page news, posts and our all of our activity on Facebook as attractive as possible to our users and to carry out our marketing activities targeted. It is also the legitimate economic interest of Facebook and Ace Advisory Zrt. to find you with offers that match your needs and interests the best (legal ground for data processing: Article 6 (1) (f) GDPR). In this way we will be able to serve the interests of our customers/clients the best and to continuously adapt our services to the constantly changing needs. Facebook can provide information for you about the methods of objection (they are: blocking cookies or changing your profile settings).

Detailed information about Facebook's data process and collecting activities can be found here: https://www.facebook.com/privacy/explanation

Who can get access to your personal data?

We inform you that the Court, the Prosecution Service, the investigating authority, the administrative authorities, the Hungarian National Authority for Data Protection and Freedom of Information, or other bodies with statutory authorisation may contact our Company to provide information, disclose data, transfer data or provide documents. To the authorities - if the authority has indicated the exact purpose and the scope of the data - we disclose personal data only to the extent which is strictly necessary to fulfil the purpose of the request.

In order to carry out certain data processing operations related to the processing of data detailed in this Policy, our Company may engage processors, who act on our behalf and under our instructions.

The data processors used by our company and their tasks:

The data processor	Activity of the processor in relation to the data processing
Arteries Studio Kft. (1139 Budapest, Forgách u. 9/b)	webdesign
SMP Solutions Zrt. (1139 Budapest, Fiastyúk u. 71.)	webhosting service provider
KBOSS.hu Kft. (1031 Budapest, Záhony utca 7.)	Számlázz.hu invoicing program
The Rocket Science Group, LLC (675 Ponce de Leon Ave NESuite 5000, Atlanta, GA 30308 USA)	MailChimp newsletter sending program
ITL Group Kft. (1056 Budapest, Váci utca 81. IV.emelet)	Accountant

Ace Advisory Zrt. reserves the right to involve other data processors in the future, which will be communicated to you by amending this notice.

PROTECTION OF DATA

Is my data safe?

Yes. In order to maintain the security and confidentiality of the data processed by us and to prevent the destruction, unauthorized use or alteration of the data, our Company applies especially the following IT and other data protection and organizational measures. In addition, we keep an eye on the development of technology, the available technical, technological and organisational solutions, and we apply those solutions that are appropriate to the level of protection justified by our data processing.

During storing documents on paper which contain personal data, we ensure their confidentiality by storing them in a lockable cabinet in an office building protected by a 0-24 hour receptionist.

Only employees of the exact department (e.g. HR, sales, office management, data protection specialists) who have access to your personal data provided by e-mail or other electronic means are entitled to access it.

We use backups to ensure that the data remains authentic and unchanged, and that the original data can be restored in the event of destruction or alteration.

We use password-protected access systems and activity logging.

INCIDENT MANAGEMENT

The Ace Advisory Zrt., as the data controller, keeps a record of the data protection incidents that have already occurred and takes measures to remedy and prevent them in the future. The incident of data-protection will be evaluated under the Company's Incident Policy and the incident of data-protection will be reported to the Hungarian National Authority for Data Protection and Freedom of Information without delay, but no later than 72 hours after becoming aware of the incident of data-protection. A data-protection incident will not need to be notified if it is unlikely to pose a risk to the rights of data subjects.

THE EXERCISE OF RIGHTS OF DATA SUBJECTS

How can you make a claim? Who can you turn to?

1./ Right to information / Right of access

2./ Right to correct data

3./ Possibility to withdraw consent / Right to erasure / "right to be forgotten"

4./ Right to object to data processing based on legitimate interest

5./ Right to restriction of data-process

6./ Right to data portability

7./ Right to make a complaint

Requesting information / Right of access

You can request information at any time about whether we are processing your personal data. You have the right to request clear, transparent and comprehensible information about how we process your personal data and what your rights are in relation to this. This Privacy Notice also serves this purpose. Upon your request, we will provide information about the data we process about you, the purpose of the data-process, the legal ground and duration of the processing, moreover about the question, who receives or has received your data and for what purposes (the guarantees in case of data transfers to third countries which ensure the appropriate protection of data), your data subject rights if we have not received your data from you, the source of the data, the circumstances of a data-protection incident, its effects and the measures taken to remedy it.

We will also provide you a copy of the personal data we hold about you upon your request. The first copy is free of charge, but we may charge a reasonable fee for each additional copy. The amount of this charge will be communicated to you in advance.

Right to rectification or amendment of data

If you become aware that any of your personal data is incorrect, inaccurate or incomplete, or if your personal data has changed in the meantime (e.g. you have changed your name), please tell us the correct, amended or additional data so that we can make the correction or amendment and ensure that the data is up to date.

Right to erasure of your personal data ("right to be forgotten") You may notify us at any time, without giving any reason, that you wish to have your personal data erased. After that, we will delete your personal data unless there is a valid reason (legal ground) for refusal. Please note that we may refuse to erase your personal data in particular if the data is or may be necessary for compliance with a legal obligation or for the exercise of your right to freedom of expression and information.

The withdrawal of consent does not affect the legality of the prior processing of data regarding to the data-processes based on consent.

Objection to processing data based on legitimate interests, you may object to the data processing we are carrying out if you consider that the processing is prejudicial to you. If you object, we will delete your personal data unless the processing is justified by compelling legitimate grounds which override your interests, rights and freedom or for the establishment, exercise or defence of legal claims.

Restriction of processing of data You may request that we designate your personal data for the purpose of restricting its future processing if one of the following is comes true: a) you contest the accuracy of the personal data: in this case, the restriction applies for the period of time that allows us to check out the accuracy of the personal data; b) the processing of data is illegal and you oppose the erasure of the data and requests instead the use to be restricted; c) Ace Advisory Zrt. no longer needs the personal data for the purposes for which they were originally processed, but you require them for the establishment, exercise or defense of legal claims; d) you have objected to the processing of data and time is needed to verify whether there are other causes for the erasure.

During the period of restriction, the data will only be stored and no other data processing operations will be carried out, unless you consent to further processing or unless such further processing is necessary to protect your rights, the rights of a third party or is in the public interest. In case of restriction of data-process, you will be informed in advance of the removal of the restriction.

Right to data portability

In the case of automated data processing based on consent or a contract, you may request that the personal data you have given us be provided to you or - if technically feasible - to a third party designated by you in a commonly known and easily usable electronic format (e.g. Word, Excel).

Remedies, complaints In the event of a perceived infringement of your rights in relation to the processing of your personal data, please contact us first at gdpr@aceadvisory.eu. We will investigate the request to enforce the rights of the data subject within 25 days at the latest. You have the right to take legal action on court or lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (1055 Budapest, Falk Miksa utca 9-11., ugyfelszolgalatKUKACnaih.hu, +36-1-391-1400, President: dr. Attila Péterfalvi, www.naih.hu).

How to make a claim You can send your request or complaint by email to gdpr@aceadvisory.eu or by post to the following address: 1052 Budapest, Haris köz 4. 1/1. In your letter, please include your identification details and, if you request a postal reply, your postal address. If we have any doubts about your identity or if the information given is not sufficient to identify you, we are entitled to ask you for additional identification data.

A request for the exercise of the rights to which the data subject is entitled, submitted by you as the data subject, will be dealt with as soon as possible after its submission, but not later than 25 days, and the decision will be notified to you in writing or if you have submitted the request electronically, electronically (by e-mail).

1 April, 2022