Effective as of 10 May, 2019

 

1. Introduction 

Our website address is: https://havefun.travel

 

 https://havefun.travel (“Have Fun Travel“, “we“, “our“, “us” , “Site”) is a website that provides users (“you“) with recommendations for travel and travel planning, including hotels, holiday rentals and other accommodations, travel guides, attractions and experiences, restaurants, cruises and a lot more fun. It also provides those businesses with a means of engaging with travellers.

 

Our website, mobile phone and tablet apps (“Mobile App”) and related applications (collectively, our “Website“) are owned and operated by Have Fun Kft. (a company seated at Halom utca 8/B., Csomád 2161, Hungary).

 

At Have Fun Travel, we want to give you the best possible experience to ensure that you enjoy our service today, tomorrow, and in the future.

 

We understand that providing information online involves a great deal of trust on your part. We take this trust very seriously, and make it a high priority to ensure the security and confidentiality of the personal data you provide us when you visit our Website or use our services.

 

We undertake to comply with all relevant legislation in force relating to data processing and data protection in the course of the operation of the Site, in particular with the provisions of Act CXII of 2011 on Information Self-Determination and Freedom of Information (“Privacy Act”), Act VI of 1998 on the Enactment of Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data, Act CIV of 2010 on the Freedom of the Press and the Fundamental Rules of Media Content, Act CLXXXV of 2010 on Media Services and Mass Media, with the recommendations and opinions of the Hungarian National Authority for Data Protection and Freedom of Information. Furthermore, we shall comply with relevant legislation of the European Union, in particular Directive 95/46/EC of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data and on the free movement of such data, in case they are directly applicable.

2. About this Privacy Policy 

This Privacy Policy explains how and why we gather, store, share and use your personal data – as well as outline the controls and choices you have around when and how you choose to share your personal data.

 

From time to time, we may develop new or offer additional services. If the introduction of these new or additional services results in any change to the way we collect or process your personal data we will provide you with more information and additional terms or policies. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Privacy Policy.

 

By accessing our Websites and utilising our services, you acknowledge that you have read and understood this Privacy Policy and the information collection and handling practices outlined in it.

 

3. Your rights and preferences

You may be aware that a new European Union law, called the General Data Protection Regulation or “GDPR” gives certain rights to individuals in relation to their personal data. As available and except as limited under applicable law, the rights afforded to you are:

 

  • The right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • The right to request to correct your personal data if it is inaccurate. You may also supplement any incomplete personal data we have, taking into account the purposes of the processing.

 

  • The right to request deletion of your personal data if:
    • your personal data is no longer necessary for the purposes for which we collected or processed them; or
    • you withdraw your consent if the processing of your personal data is based on consent and no other legal ground exists; or
    • you object to the processing of your personal data and we do not have an overriding legitimate ground for processing; or
    • your personal data is unlawfully processed; or
    • your personal data has to be deleted for compliance with a legal obligation.
  • The right to restrict the processing of personal data, if:
    • the accuracy of your personal data is contested by you, for the period in which we have to verify the accuracy of the personal data; or
    • the processing is unlawful and you oppose the deletion of your personal data and request restriction; or
    • we no longer need your personal data for the purposes of processing, but your personal data is required by you for legal claims; or
    • you have objected to the processing, for the period in which we have to verify overriding legitimate grounds.

 

  • The right to data portability. You may request us to receive the personal data that concern you. You may also request us to send this personal data to a third party, where feasible. You only have this right if it regards personal data you have provided us, the processing is based on consent or necessary for the performance of a contract between you and us, and the processing is done by automated means.

 

  • The right to object to the processing of your personal data. We will comply with your request, unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal data to establish, exercise or defend a legal claim.

 

  • The right not to be subject to automated decision-making – You have the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

 

Your references are as follows:

 

 

  • If you decide to close your account, we will deactivate it, and remove your personal data. Remember that once your account is closed, you will no longer be able to login, access your personal information. You can however, open a new account at any time.

 

  • If we send you electronic marketing messages based on your consent or as otherwise permitted by applicable law, you may, at any time, respectively withdraw such consent or declare your objection (“opt-out”) at no cost. The electronic marketing messages you receive from Have Fun Travel (e.g. those sent via email) also will include an opt-out mechanism within the message itself (e.g. an unsubscribe link in the emails we send to you).

 

 

You can exercise several of your rights through the personal information section of your account. To exercise your other rights you can file a request by email to info@havefunbudapest.com.

 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights described in this Privacy Policy). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In an effort to speed up our response, we may also contact you to ask you for further information in relation to your request.

 

Marketing/Push notifications

 

You will receive marketing messages from us if you have given your consent, if you have requested or if you have not opted out of receiving marketing messages.

 

Each time you receive an email of this type, you will be able to tell us if you no longer wish to receive them,  or change the settings of your mobile device to do so for that type of marketing message or notification. You will be able to unsubscribe from each of those marketing communications at any time by clicking on the unsubscribe link that you will find at the bottom of each communication you receive from us or by visiting the email preference centre on the Website.

 

Please note that we may continue to send you service communications, such as service and administrative messages about your account. It is not possible to unsubscribe from these service communications.

4. How do we collect your personal data?

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed or otherwise anonymized (anonymous data).

 

We collect your personal data in the following ways:

 

  • When you sign up for Have Fun Travel- when you sign up to Have Fun Travel, we collect certain personal data so you can use Have Fun Travel such as your name, gender, birth date (year), nationality, email address, accommodation (in general such as hotel/hostel/airbnb, not the exact place of residence).

 

  • Through your use of Have Fun Travel- when you use Have Fun Travel, we may collect personal data about your use of our services, such as what are your favourite restaurants.

 

  • Personal data collected that enables us to provide you with additional features/functionality – from time to time, you also may provide us with additional personal data or give us your permission to collect additional personal data e.g. to provide you with more features or functionality. We will not collect photos, voice data, or contacts from your device without your prior consent. You always will have the option to change your mind and withdraw your consent at any time.

 

  • From third parties – we will receive personal data about you and your activity from third parties, including advertisers and partners we work with in order to provide you with our services. We will use this personal data either where you have provided your consent to the third party or to Have Fun Travel to that data sharing taking place or where Have Fun Travel has a legitimate interest to use the personal data in order to provide you with our services.

 

  • Information from Other Sources – we also may periodically obtain information about you from affiliated entities, business partners and other independent third-party sources and add it to other information about you. For example, if you visit Have Fun Travel by “clicking through” from a site operated by one of our business partners, and you have registered with that partner, then information about you that you have provided to that partner may be shared with us, such as contact information and demographic information. As another example, if you access third party services, such as social media services, through our Websites or before coming to our Websites, we may collect information such as your username and other information made available to us through those services in accordance with the referring third party’s privacy policy. We will work with our existing partners and potential future partners to improve and personalise your use of our Websites in accordance with the practices outlined in this Privacy Policy.

 

  • Automatic collection of information – we automatically collect some information from your computer or mobile device when you visit Have Fun Travel. For example, we collect your session data, including your IP address, the navigation software used and the reference site. We may also collect information about your online to try to better understand your interests and preferences and to better personalise your experience activity, such as reviewed content, pages visited and searches. We automatically collect this type of information.  We also collect personal data in order to help protect our Website and other users from misuse.

 

  • Location information and other information from devices – we may collect certain information about your location if you have instructed your device to send such information to the application via the privacy settings on that device. For example, we may use your location to show you reviews of hotels, experiences or restaurants near you when you are travelling. You can change the privacy settings of your device at any time in order to turn off the functionality to share location information with the application and/or the functionality to tag your photos with location information. Please note that turning off location sharing may affect certain features of our Mobile App or mobile experience. If you have any queries about the privacy settings of your device, we suggest you contact the manufacturer of your device or your mobile service provider for help.

 

We have partnered with Facebook and Google to enable you to register yourself in the Site using your Facebook and Google (Gmail) account. In order to provide you with this possibility, Facebook and Goggle may provide us with information that you have chosen to make available pursuant to your Facebook and Gmail privacy settings. That information may include your name, profile picture, gender any other information you have chosen to make available.

 

In addition, some information is also required in order for you to ask us a question or initiate other transactions on our Websites. We also collect personal data for security purposes.

5. What personal data do we collect from you?

 

We have set out in the tables below the categories of personal data we collect and use about you:

 

Personal data collected when you sign up for Have Fun Travel:

 

Categories of personal data Description of category

 

Purpose of the data using
 

Account Registration Data

 

This is the personal data that is provided by you or collected by us to enable you to sign up for and use Have Fun Travel. This includes your name, gender, birth date (year), nationality, email address, accommodation (in general such as hotel/hostel/airbnb, not the exact place of residence).

Some of the personal data we will ask you to provide is required in order to create your account. You also have the option to provide us with some additional personal data in order to make your account more personalized such as …

 

 

To manage your registration and account

 

To offer our services to you

 

To communicate with you about your account or use of our Websites and services, to respond to, or follow up on, your comments and questions and otherwise provide customer service

 

To notify you about changes to our terms and conditions or privacy policy

 

To ask you to leave a review or take a survey, operate and improve our Websites and services

 

To protect, investigate and deter against fraudulent or illicit activity, unauthorised or illegal activity, administer and protect our business and to resolve disputes or troubleshoot problems

 

 

 

Personal data collected through your use of Have Fun Travel:

 

Categories of personal data

 

Description of category

 

Purpose of the data using
 

Have Fun Travel Service Usage Data

 

This is the personal data that is collected about you when you are using Have Fun Travel – this may include:

 

●      Information about your interactions with Have Fun Travel which includes the date and time of any requests you make, places you have visited

 

●      User Content you post to Have Fun Travel including messages you send and/or receive via Have Fun Travel and your interactions with the Have Fun Travel Customer Service team.

 

●      Technical Data which may include URL information, cookie data, crash report data, your IP address, the types of devices you are using to access or connect to Have Fun Travel, unique device IDs, device attributes, network connection type) and provider, network and device performance, browser type, language, information enabling digital rights management and operating system.

 

To offer our services to you

 

To personalise your experience on our Websites, measure interest in and improve our Websites and services

 

Personal data collected with your permission that enables us to provide you with additional features/functionality:

 

Categories of personal data

 

Description of category

 

Purpose of the data using
 

Voluntary Mobile Data

 

In addition to the mobile data we collect to provide you with Have Fun Travel, you also have the option to give us your consent to collect additional personal data from your mobile device to provide you with features/functionality that will enhance your Have Fun Travel experience.

Your precise mobile device location – If you give us permission to access your precise location, this enables us to access your GPS or Bluetooth to provide location-aware functionality in the Mobile App. Please note that this does not include your IP address. We use your IP address to determine non-precise location, for example, what country you are in to comply with our licensing agreements.

 

 

To offer our services to you

 

To personalise your experience on our Websites, measure interest in and improve our Websites and services

 

Contests, Surveys and Sweepstakes Data

 

This personal data is used to allow you to sign up and participate in these types of promotions. The exact personal data collected will vary depending on the promotion.

 

 

To notify you about promotions and special offers

 

To let you partake in a prize draw, competition or complete a survey

 

 

Marketing data

 

This personal data is used to enable Have Fun Travel and our partners / service providers to send you marketing communications either:

●        Via email;

●        Whilst using the Have Fun Travel Service; and/or

●        Direct from the third party.

 

 

To serve you with relevant advertising

 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

 

  • Performance of contract – where we need to perform the contract we are about to enter into or have entered into with you.
  • Legitimate interests – where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Consent – with your consent.
  • Compliance with legal obligations – where we need to comply with a legal or regulatory obligation.

 

6. How we use your personal data?

We have set out in the table below the reasons why we process your personal data, the associated legal bases we rely upon to legally permit us to process your personal data, and the categories of personal data used for these purposes:

 

 

Description of why we processes your personal data (‘processing purpose’)

 

 

Legal Basis for the processing purpose

 

Categories of personal data used by Have Fun Travel for the processing purpose

To provide, personalize, and improve your experience with Have Fun Travel for example by providing customized, personalized, or localized content, recommendations, features

 

Performance of a Contract

 

Account Registration Data

Service Usage Data

To understand how you access and use Have Fun Travel to ensure technical functionality of the Mobile App, develop new products and services, and analyze your use of Have Fun Travel

 

Performance of a Contract

 

Account Registration Data

Service Usage Data

To communicate with you for Have Fun Travel-related purposes

 

Performance of a Contract

 

Account Registration Data

Service Usage Data

 

To communicate with you, either directly or through one of our partners, for marketing, research, participation in contests, surveys and sweepstakes, promotional purposes

 

 

Consent

Legitimate Interest

 

Contests, Surveys and Sweepstakes Data

Marketing Data

To provide you with features, information, advertising, or other content which is based on your specific location Consent Voluntary Mobile Data

7. Profiling and automated decision making

 You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning your or similarly significantly affects you. This rule shall not apply if the decision:

 

  • is necessary for entering into, or performance of the contract we have entered into with you;
  • is authorised by the European Union or the Hungarian State law which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
  • is based on the your explicit consent.

 

Profiling is any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict certain aspects concerning that natural person’s performance at work, economic situations, health, personal preferences, interests, reliability, behaviour, location or movement.

 

In the course of our services, we will analyse your information to build your individual profile and account. These profiles will be used to help us customize the content and advertisement provided to you on the Website and on the Mobile App. The profiling is based on your answers provided to us during your registration process.

 

8. With whom we share your personal data?

We have set out the categories of recipients of the personal data collected or generated through your use of Have Fun Travel:

 

Categories of Recipients

 

Reason for sharing
 

Service Providers and Others

We use technical service providers which may operate the technical infrastructure that we need to provide our services, in particular providers which host, store, manage, and maintain the Mobile App, its content and the data we process.

We use marketing and advertising partners to show you more tailored content, or to help us understand your use of Have Fun Travel, to provide you with a better service.

 

We also may share personal data with certain marketing and advertising partners to send you promotional communications about Have Fun Travel.

 

Law Enforcement and Data Protection Authority We will share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena.

We also will share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.

 

Other Have Fun Group Companies We will share your personal data with other Have Fun Group companies to carry out our daily business operations and to enable us to maintain and provide our services to you.

 

 

Other than as set out above, you will be notified when personal data about you will be shared with third parties, and you will have an opportunity to choose not to have us share such information.

 

We also may share aggregate or anonymous information with third parties, including advertisers and investors. For example, we may tell our advertisers the number of visitors our Website receives or the most popular restaurants and other destinations. This information does not contain any personal data and is used to develop content and services we hope you will find of interest.

9. How long we keep your personal data?

 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or statutory reporting requirements.

 

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure or your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.

 

If you request, we will delete or anonymise your personal data so that it no longer identifies you, unless, we are legally allowed or required to maintain certain personal data, including situations such as the following:

 

  • if there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved
  • Where we are required to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or
  • where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users

 

10. How we protect your personal data?

We want you to feel confident about using Have Fun Travel, and we are committed to protecting the personal data we collect. While no website can guarantee perfect security, we have implemented and maintain appropriate physical, administrative, technical, and organisational measures to protect the personal data you provide us against unauthorised or unlawful access, use of disclosure and against accidental loss, damage, alteration or destruction.

 

For example, only authorised employees are permitted to access personal data, and they may do so for permitted business functions. In addition, we use encryption when transmitting your personal data between your system and ours, and between our system and those of the parties with whom we share sensitive information, and we employ firewalls and intrusion detection systems to help prevent unauthorised persons from gaining access to your personal data.

 

Your password protects your user account, so we encourage you to use a unique and strong password, limit access to your computer, browser and other devices, and log out after having used Have Fun Travel.

11. International transfers

Your personal data may be stored or transferred to countries outside the European Economic Area for the purposes described in this Privacy Policy. When we store or transfer your personal data outside the European Economic Area, we take the following precautions to ensure that your personal data is properly protected.

 

Whenever we store or transfer your personal data outside the European Economic Area, we will do so in accordance with applicable law and we will ensure a similar degree of protection is afforded to it by implementing appropriate safeguards. Transfers of personal data are made:

 

  • to a country recognised by the European Commission as providing an adequate level of protection; or

 

  • to a country which does not offer adequate protection but whose transfer has been governed by the standard contractual clauses of the European Commission or by implementing other appropriate cross-border transfer solutions to provide adequate protection.

 

By using our services, you understand that your personal data may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.

 

Our cloud server provider is DigitalOcean LLC whose services – provided to us – are fulfilled only within the European Economic Area.

 

12. Children’s privacy

Have Fun Travel is a general audience site and does not offer services directed to children. We do not knowingly collect data relating to children.

 

Should a child whom we know to be under 12 send personal information to us, we will use that information only to respond directly to that child to inform him or her that we must have parental consent before receiving his or her personal information.

 

13.  External links

Our Website may include links to third party websites, plug-ins and applications. If you access other websites from the links provided on our Website, the operators of those websites may collect or share information about you. This information will be used by them in accordance with their privacy policy, which may differ from our Privacy Policy.

 

We cannot control or be held responsible for third parties’ privacy practices and content that is why we recommend that you examine the privacy statements posted on those other websites to understand their procedures for collecting, using and disclosing personal data.

14. Cookies and other web technologies

Cookies are small data text files and can be stored on your computer’s hard drive (if your Web browser permits). This website uses cookies for the following general purposes:

 

  • To help us recognize your browser as a previous visitor and save and remember any preferences that may have been set while your browser was visiting our site. For example, if you register on our site, we may use cookies to remember your registration information, so you do not need to log into our site each time you visit. We also may record your password in a cookie, if you checked the box entitled “Sign me in automatically next time.” Please note that member IDs, passwords, and any other account-related data included in such cookies are encrypted for security purposes. Unless you register with us, these cookies will not contain any personal information.

 

  • To help us customize the content and advertisements provided to you on this website and on other sites across the Internet. For example, when you access a page on our website, a cookie is automatically set by us, our service providers, or our partners to recognize your browser as you navigate on the Internet and to present you with information and advertising based on your apparent interests

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

 

15. Changes to this Privacy Policy

We may change or modify this Privacy Policy from time to time. We will note the date that revisions were last made to this Privacy Policy at the first page of this Privacy Policy, and any revisions will take effect upon posting.

 

We will notify our members of material changes to this Privacy Policy by either sending a notice to the email address you provided us or by placing a notice on our Website. We encourage you to check this Privacy Policy from time to time to review the most current version.

 

16. How you can contact us

If you have any further questions or complaints about the processing of your personal data by us, please contact us at info@havefunbudapest.com.

 

You may also have the right to lodge a complaint to the supervisory authority about the way we process your personal data. We would, however, appreciate the chance to address your concerns before you approach the supervisory authority, so please contact us in the first instance.

 

Our full details are:

 

Name: Have Fun Korlátolt Felelősségű Társaság

Seat/Postal address: Halom utca 8/B., Csomád 2161, Hungary

Email: info@havefunbudapest.com

Phone: +36 20 492 1435

 

The supervisory board’s full details are:

 

Name: Nemzeti Adatvédelmi és Információszabadság Hatóság

Seat: Erzsébet fasor 22/C., Budapest 1125, Hungary

Postal address: Pf. 5., Budapest 1530, Hungary

Phone: +36 (1) 391-1400

E-mail: ugyfelszolgalat@naih.hu

URL: http://naih.hu.

 

17. Jurisdiction and governing law

The Website and the Mobile App are operated by a Hungarian entity and this Privacy Policy is governed by the laws of Hungary. You hereby consent to the exclusive jurisdiction and venue of courts Hungary and stipulate to the fairness and convenience of proceedings in such courts for all disputes arising out of or relating to the use of this Website/Mobile App. You agree that all claims you may have against us arising from or relating to this Website/Mobile App must be heard and resolved in a court of competent subject matter jurisdiction located in Hungary. The foregoing shall not apply to the extent that applicable law in your country of residence requires application of another law and/or jurisdiction and this cannot be excluded by contract.

 

©2019 Have Fun Travel. All rights reserved.

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