1. Who are we and what do we do?
We organize the only human rights film festival held in Hungary every year since 2004, consistently advocating human dignity and common social causes. We do that through Hungarian and international documentaries, as well as numerous relevant accompanying programs: round table discussions, meet-and-greets, open debates, exhibitions etc. We strive to contribute to the development of a joint international forum for our social causes and the film industry by organizing workshops and master courses led by internationally renown professionals, through which Hungarian documentary filmmakers gain a unique opportunity to enter the international scene.
2. Contact details of Verzió
Address: 1051 Budapest, Arany János u. 32.
Contact person: Enikő Gyureskó
3. Who does the Policy apply to?
The scope of the Policy covers every individual—including those under 18 or 14—who enters a submission to the competition of Verzió International Human Rights Documentary Film Festival or attends any of its events.
4. Key terms and principles
4.1. Key terms
“Data processing”: Any automated or non-automated operation or set of operations which is performed on personal data or data sets, such as collecting, recording, organizing, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, dissemination or otherwise making the data available, aligning or combining data, or blocking, erasing or destroying data;
“Data processor”: A natural or legal person, body of public authority, agency or any other organization that has the authority over the processing of personal data on behalf of the data controller (in the present case, Verzió);
“Data controller”: A natural or legal person, body of public authority, agency or any other organization that alone or jointly with others has the authority to determine the purposes for which, and the way in which personal data is processed (in the present case, Verzió);
“Personal data breach”: A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed (e.g. unauthorized access to the account created on the website);
“Personal data”: Any information relating to an identified or identifiable individual (“data subject”);
„Data subject”: An identified or identifiable individual. An identified or identifiable individual is one who can be identified, directly or indirectly, in particular, by reference to an identification detail, for example name, identification number, geographical information, online identity or to one or more factors specific to the individual’s physical, physiological, genetic, mental, economic, cultural or social identity.
4.2 Key data protection principles of Verzió relevant to data processing
As data controller ,Verzió is responsible for assuring the following:
- that personal data are processed in a lawful, fair and transparent manner in relation to data subjects (“lawfulness, fairness and transparency”);
- that personal data are collected only for specified, explicit and legitimate purposes and they are not processed further in a way that is not compatible with those purposes (“purpose limitation”);
- that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (“data minimization”);
- that personal data are accurate and are kept up to date where it is necessary, and that Verzió takes every reasonable measure to delete or rectify personal data that are inaccurate considering the purposes for their processing without any delay (“accuracy”);
- that personal data are kept in a form that makes it possible to identify data subjects for no longer than is necessary for the purposes of the processing (“storage limitation”);
- that in the processing of personal data appropriate security of personal data—including protection against unauthorized or unlawful processing, accidental loss, destruction and damage of data—is ensured by taking appropriate technical or organizational measures (“integrity and confidentiality”).
5. Purpose of data processing
5.1. Communication and sending information about events organized by us. The purpose of data processing is to notify subscribed visitors about our similar, future events via e-mail.
5.2. Taking photographs and recording video
Photographs and video recordings may be taken at our events. Video recordings may be published on the festival website (http://www.verzio.org/) and shared on social media platforms. Photographs may be published in our annual report, on the festival website and on social media platforms. Photographs and video recordings are used to promote events related to our future programs, and may be published on our website and social media platforms.
5.3. Collecting necessary information about the films entered in our open call and about the filmmakers submitting them, the purpose of which activity is to formulate the competition sections of Verzió Film Festival.
Applicants of Verzió Film Festival shall be notified about the result of their application via the contact details provided by them.
5.4. Collecting necessary information about the films of the Festival program and its expert guests, the purpose of which activity is to promote and communicate the programs of Verzió Film Festival to the target audience.
With consent from the rightholders of the films, we publish information about the films selected into the festival program on the festival website, social media platforms and in our printed publications: posters, catalogues, program guides.
With consent from the expert guests of the festival, we publish a short professional biography and portrait photograph of them on our website.
By social media platforms, we refer to the following:
Data processing policy
of social medium
6. What personal data do we collect?
For the purposes specified in Point 5 of the present Policy, Verzió may process the following personal data of the data subjects:
- E-mail address
- Picture (photo, video)
- Audio recording (video)
7. The basis of data processing
The legal basis of data processing in case of any data processing under Point 5 of the present Policy is the consent of the data subject pursuant to Article 6(1)(a) GDPR.
Verzió collects personal data from the data subject, but the data subject is not obliged to provide personal data, and not providing data does not lead to any legal disadvantages for them.
The data subject provides their informed consent to the processing of their personal data according to the present Policy by checking the consent boxes found on the online registration form.
Data subjects under 14 years of age: If the data subject is under 14 years of age, any of their legal guardians (parents) may give their consent to the processing of their personal data, so the declaration of consent to the processing of the data subject’s personal data has to be submitted by their legal guardian.
Data subjects between 14 and 16 years of age: If the data subject is between 14 and 16 years of age, any of their legal guardians (parents) must also give their consent to the processing of their personal data besides their own consent, so the declaration of consent to the processing of the data subject’s personal data has to be signed by both the data subject and their legal guardian.
Data subjects over 16 years of age: If the data subject is over 16 years of age, the permission or posterior consent of their legal guardian is not required for the legal declaration of consent to the processing of their personal data to be valid, they may sign the consent themselves.
8. With whom do we share your personal data?
Personal data are processed by Verzió, and we use the services of data processors. Data processors are contractors hired by the Central European University and Verzió: the provider of the online form filler (Google LLC), the guest coordinator, the volunteer coordinator, the coordinator of professional programs, camera persons, photographers, the communications manager and the social media manager. Data processors are bound by contracts in all cases, ensuring secure data processing. The current list of data processors can be accessed in the Team menu, and you will find their list retrospectively in the Previous Festivals / Crew menu.
9. Duration of data processing
9.1. Communication and sending information about events organized by us
In terms of the purpose of data processing defined in Point 5.1., until the data subject’s withdrawal of consent, or in the absence of it, a maximum of 5 (five) years.
9.2. Photographs and video recordings
In case of the purpose of data processing defined in Point 5.2., until the data subject’s withdrawal of consent, or in the absence of it, a maximum of 5 (five) years.
9.3. Information about films entered in the competition
In case of the purpose of data processing defined in Point 5.3., until the data subject’s withdrawal of consent, or in the absence of it, a maximum of 5 (five) years.
9.4. Information of the Festival program
In case of the purpose of data processing defined in Point 5.4., until the data subject’s withdrawal of consent.
In case of the data subject’s withdrawal of consent, we continue to process their personal data for a maximum of 25 (twenty five) days following the time of withdrawal—provided there is no other legal basis for data processing—, in order to be able to carry out the necessary technical operations.
After the duration of time defined above has passed, we delete your personal data.
10. Your rights relevant to data processing
In terms of Articles 15–20 GDPR, regarding your personal data processed by Verzió, you have the right to
- access your personal data;
- request that your personal data be corrected;
- request that your personal data be erased;
- request that the processing of your personal data be restricted;
- object to the processing of your personal data;
- receive your personal data and forward them to another controller, provided the legal prerequisites of this are present (the right of data portability, see Point 10.6 below);
- if the basis for processing your personal data is your consent, you may withdraw it at any time.
You may send your request to exercise your rights listed above to the contacts defined in Point 2. Verzió shall inform you about the measures taken in response to your request without undue delay, and on average, within 1 month after receiving your request. If Verzió does not take any measures, we shall inform you about the reasons why no measures were taken in response to your request without undue delay, but within 1 month after having received your request. If you do not agree with Verzió’s response or the measures taken by us, you may seek legal remedy. Verzió shall inform every recipient of every correction, erasure of data or restriction of data processing to whom or to which the personal data were disclosed, except in cases where it proves to be impossible or would require a disproportionally large effort.
10.1. Access rights
You have the right to receive feedback from Verzió about whether the processing of your personal data is underway, and if your personal data is being processed, you have the right to get access to such personal data and receive information about the circumstances of their processing. The requested information may include the following, among other things: the purposes of data processing; the categories of personal data; the recipients or categories of recipients to whom, or to which Verzió has disclosed or will disclose your personal data; the planned duration of storing your personal data; and if your personal data was not provided by you directly, any information available regarding their source.
You have the right to obtain the correction of your inaccurate personal data from Verzió without undue delay upon your request, and to request the completion of incomplete personal data.
10.3. Right to erasure (“right to be forgotten”)
You have the right obtain the erasure of your personal data from Verzió without undue delay, if any of the following grounds apply:
- your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- you withdraw your consent on which the processing is based and there is no other legal ground for the processing;
- you object to the processing pursuant to Article 21 GDPR and there are no overriding legitimate grounds for the data processing;
- your personal data have been unlawfully processed by Verzió;
- the personal data have to be erased for compliance with a legal obligation.
Verzió shall refrain from erasing the personal data if the applicable legislations allow it, such as in case the data processing is necessary for the establishment, exercise or defense of legal claims.
10.4. Right to restriction of data processing
You have the right to obtain restriction of processing from Verzió when any of the following apply:
- you contest the accuracy of your personal data—in this case, the restriction applies for a period enabling Verzió to verify the accuracy of the personal data;
- the processing is unlawful and you oppose the erasure of your personal data, and you request the restriction of their use instead;
- Verzió no longer needs your personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims; or
- you objected to data processing—in this case, the restriction applies for the period while the verification whether the legitimate grounds of Verzió override your legitimate grounds is pending.
Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with your 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 European Union or of a Member State. You shall be informed by Verzió before the restriction of processing is lifted.
10.5. Right to object
You have the right to object, on grounds relating to your own particular situation, at any time to the processing of your personal data based on Verzió’s legitimate grounds. In this case, Verzió shall no longer process your personal data unless the data controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
10.6. Right to data portability
If it does not infringe the rights and freedoms of others, you have the right to receive your personal data in a structured, commonly used and machine-readable format and have the right to obtain from Verzió the direct transmission of said data to another controller, if
- the processing is based on your consent or it is necessary in order to complete a contract where you are one of the parties, or in order to take the steps requested by you before signing the contract; and
- the processing is carried out by automated means, i.e. the personal data is processed in IT systems rather than on paper.
10.7. Available legal remedies
If you do not agree with the response of or the measures taken by Verzió, you have the right to lodge a complaint with the national authority for data protection and freedom of information (Nemzeti Adatvédelmi és Információszabadság Hatóság) (address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c; phone: +36-1-391-1400; e-mail: firstname.lastname@example.org), or any other GDPR compliant supervisory authority, or you may seek remedies at court.
11. Secure data processing
We are committed to processing your personal data securely and carefully. We process and store all data securely, in compliance with relevant data protection laws and our internal data protection regulations. We do not sell your data to third parties.
12. Possible changes in the Policy
Verzió reserves the right to amend the present Policy and its annexes. If that happens, Verzió shall publish the updated version. Significant changes shall always be properly communicated by Verzió.
Dated: Budapest, March 12, 2020