Privacy policy
PRIVACY NOTICE
I. Introduction
Diverzum Europe Ltd. a company registered under the laws of Hungary (hereinafter referred as "Data Controller"), in accordance with 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 Directive 95/46/EC (hereinafter: "GDPR"), as well as Act CXII of 2011 on the Right of Informational Self-Determination and Freedom of Information, hereby publishes this Privacy Notice in order to fulfil its information obligation contained therein.
The Data Controller pays particular attention to the lawful processing of personal data shared with it. The Data Controller processes personal data in accordance with applicable data protection legislation, in particular the provisions of the GDPR, and with respect to the principles of data processing. The Data Controller takes all necessary security steps, organizational and technical measures to ensure the highest level of security of personal data and to protect them against unauthorized access, alteration, destruction, use, disclosure and erasure, as well as against accidental destruction and damage, and to ensure accessibility resulting from changes in applied technology.
II. The Data Controller
- Name: Diverzum Europe Limited Liability Company
- Registered seat: 34. II. em. 12. Ajtó, Teréz körút, 1066 Budapest, Hungary
- Registering authority: Company Registry Court of Főváros
- Company registry number: 01-09-458243
- Tax number: 32000504-2-42
- Represented by: Bende Bence and Molnár-Bognár Szabolcs
- Contact: info@diverzum.hu
III. What data do we process?
1. Registration on the website www.diverzum.hu or in the DIVERZUM application
- Categories of data subjects: persons participating in the registration process on the website www.diverzum.hu or in the DIVERZUM application
- Categories of personal data: name, email address, date of birth
- Purpose of processing: verification of eligibility for student discounts provided by the Data Controller and therefore ensuring access to the Data Controller’s services
- Legal basis of processing: Article 6(1)(b) GDPR, performance of a contract to be concluded with the data subject
- Storage period: The Data Controller will process the data for the duration of the registration, i.e., until the contract is concluded with the data subject terminates. Pursuant to Article 13(2)(e) GDPR, the Data Controller informs the data subject that the provision of the data specified in this section is a prerequisite for the conclusion of the contract. Accordingly, the consequence of failure to provide data is that the Data Controller does not conclude a contract with the data subject, who therefore is not entitled to use its services.
2. Verification of student status during the verification following registration and thereafter annually
- Categories of data subjects: Users registered on the website www.diverzum.hu or in the DIVERZUM application
- Categories of personal data: copy of both sides of the student ID OR student ID number
- Purpose of processing: verification of eligibility for student discounts provided by the Data Controller and thereby ensuring the use of the Data Controller’s services in accordance with the General Terms and Conditions of the Data Controller
- Legal basis of processing: Article 6(1)(b) GDPR, performance of a contract concluded with the data subject
- Storage period of the data:
- student ID number: until the deletion of the registration
- copy of the student ID: for 30 days from the date of collection
Pursuant to Article 13(2)(e) GDPR, the Data Controller informs the data subject that the provision of this data is mandatory for maintaining its registration. Accordingly, the consequence of failure to provide data is that the Data Controller deletes the registration of the data subject, i.e. terminates the contract concluded between them.
3. Communication
- Categories of data subjects: Users registered on the website www.diverzum.hu or in the DIVERZUM application
- Categories of personal data: email address
- Purpose of processing: ensuring communication between the Data Controller and the Users; smooth provision of information regarding the redemption of discounts provided by the Data Controller and the validity period of the User’s student status
- Legal basis of processing: Article 6(1)(b) GDPR, performance of a contract concluded with the data subject
- Storage period: until termination of the registration
4. Subscription to electronic newsletter, marketing mail
- Categories of data subjects: Users subscribing to the electronic newsletter
- Categories of personal data: email address
- Purpose of processing: sending information about services provided by the Data Controller, notifications about newly available and expiring discounts, other marketing communications (notifications about giveaways, events, etc.)
- Legal basis of processing: Article 6(1)(a) GDPR, consent of the data subject
- Storage period: until withdrawal of consent, or in absence thereof until termination of registration
5. Display of personalized advertisements (push notification)
- Categories of data subjects: Users who have consented to personalized advertisements
- Categories of personal data: activity of the data subject in the DIVERZUM application
- Purpose of processing: sending information about services tailored to the interests of the data subject, notifications about new, expiring and other discounts, other marketing communications
- Legal basis of processing: Article 6(1)(a) GDPR, consent given in the device settings of the data subject
- Storage period: until withdrawal of consent, or in absence thereof until termination of registration
6. Giveaway
- Categories of data subjects: Users participating in the giveaway
- Categories of personal data: email address; if necessary for delivery of the prize: name, phone number, address, tax identification number of the winner
- Purpose of processing: conducting the giveaway (draw) organized by the Data Controller and delivering the prize
- Legal basis of processing: Article 6(1)(b) GDPR, performance of a contract concluded with the data subject
- Storage period: until the end of the giveaway
- Data transfer: the Data Controller transfers exclusively the email address of the winner to the third party providing the prize, and only if necessary for delivery. The exact identification of the partner is contained in the applicable rules of the giveaway.
7. Profiling
- Categories of data subjects: Users of the DIVERZUM application
- Categories of personal data: activity of the data subject in the application: number and frequency of logins, activity, purchases using student discounts, use of referral system, spending of points in gamification
- Purpose of processing: personalized display of student discounts within the application; analysis of economic indicators related to Users
- Legal basis of processing: Article 6(1)(f) GDPR, legitimate interest of the Data Controller. The legitimate interest of the Data Controller is to optimize the operation of the application, display relevant content, increase user experience, and monitor economic performance.
- Impact on the data subject: the processing does not have a significant effect; no automated decision-making takes place; monitoring results only in prioritization of previously viewed or used discounts.
- Storage period: until termination of registration
8. Gamification
- Categories of data subjects: Users participating in the gamification feature of the DIVERZUM application
- Categories of personal data: data related to participation: points earned, time spent using the application, activity, if necessary for the delivery of the prize to the winner: the winner’s name, phone number, address, and tax identification number
- Purpose of processing: operation of games available in the application to increase user activity
- Legal basis of processing: Article 6(1)(f) GDPR, the legitimate interest of Data Controller
- Storage period: until termination of registration
IV. Data Processors
- Nethely Kft. (seat: 1115 Budapest, Halmi utca 29.) – hosting provider
- Rackforest Informatikai Kereskedelmi Szolgáltató és Tanácsadó Zrt. (seat: 1132 Budapest, Victor Hugo utca 11. 5. em. B05001.) – hosting provider
- Google LLC (seat: 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.) – Firebase and Bigquery services, Looker Studio
- Amazon Web Services, Inc. (seat: 410 Terry Ave. N., Seattle, WA 98109-5210, United States) – hosting provider
- Segment.io Inc. (seat: 100 California St, Suite 700, San Francisco, CA 94111, USA) – customer data platform
V. Other provisions
The Data Controller informs the Data Subject that, pursuant to Article 13 of the GDPR, the Data Subject may request information regarding the processing of their personal data; pursuant to Article 15, they have the right to access their personal data and the information listed in the referenced Article; pursuant to Article 16, they may request the rectification of their personal data; and pursuant to Article 17, the erasure thereof, or pursuant to Article 18, the restriction of processing. Furthermore, pursuant to Article 21, they may object to the processing of their personal data, and in the cases specified in Article 20, they are entitled to the right to data portability. These rights are not absolute; therefore, requests may only be fulfilled under the conditions set out in the legal provisions. Requests to exercise these rights must be submitted by email to info@diverzum.hu, to which the Data Controller will respond within one month.
The Data Controller further informs the Data Subject that, pursuant to Article 7(3) of the GDPR, they may withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
The Data Subject may initiate an investigation with the National Authority for Data Protection and Freedom of Information (registered office: H-1055 Budapest, Falk Miksa utca 9–11; mailing address: H-1530 Budapest, P.O. Box 5; email: ugyfelszolgalat@naih.hu), claiming that a violation of rights has occurred in connection with the processing of personal data or that there is an imminent risk thereof. Furthermore, in the event of a violation of their rights, Data Subject is entitled to bring a case before the court competent according to their place of residence or habitual residence. The regional court has jurisdiction to adjudicate the dispute.
Cookie Policy
In accordance with the Electronic Communications Privacy Directive (2002/58/EC) and Act C of 2003 on Electronic Communications, the operator of the www.diverzum.hu and www.diverzum.ro websites, Diverzum Europe KFt., publishes the following Cookie Policy.
What are cookies?
Cookies are small files that visited websites install on a visitor's computer, where they are stored. Cookies are located in the browser's file directory. The next time the site is visited, the browser reads the cookie and sends the information back to the website or element that originally set the cookie. For more information on how these technologies work, visit, for example, the allaboutcookies.org website.
Cookies used by diverzum.hu
The diverzum.hu website and its subpages use cookies for various purposes. These include "strictly necessary" cookies for technical reasons, as well as those that provide a personalized experience for visitors. Some cookies are set when a page loads, or when a visitor performs a unique action, such as clicking a specific button.
Strictly necessary cookies
These are the cookies that are essential for the diverzum.hu website's basic functions.
| Name | Purpose | Storage time | Provider |
|---|---|---|---|
| diverzum_cookie_consent | Saving cookie consent | ~1 year | Diverzum |
| _hjSession_3887991 | Session management (Hotjar) | session | Hotjar |
| _hjSessionUser_3887991 | User identification (Hotjar) | 1 year | Hotjar |
| tt_enable_cookie | TikTok consent flag | ~1 year | TikTok |
| __dc_gtm_UA-246529092-1 | Required for Tag Manager operation | session | |
| ar_debug | DoubleClick debug cookie | session | |
| DSID | Google security / session cookie | ~2 weeks | |
| IDE | DoubleClick advertising infrastructure base cookie | ~1 year | |
| datr | Facebook security and fraud prevention | ~2 years | Meta |
Preference cookies
These cookies are used to store preferences set by users, such as language or geographical location. They are not used to track the visitor on pages other than diverzum.hu.
| Name | Purpose | Storage time | Provider |
|---|---|---|---|
| _ga | User identification | 2 years | Google Analytics |
| _gid | Session tracking | 24 hours | |
| _ga_DWRRTY8XPPB | GA4 property measurement | 2 years | |
| _gcl_au | Google Ads conversion tracking | 3 months | |
| _mgcpg_ | Google Ads / DoubleClick measurement | ~1 year |
Performance and analytics cookies
Performance-related cookies collect information about the interaction between users and the diverzum.hu website, such as which pages are most visited and other analytical data. These details only serve to improve the operation of the website.
| Name | Purpose | Storage time | Provider |
|---|---|---|---|
| _fbp | Facebook tracking / remarketing | 3 months | Meta |
| _ttp (diverzum.hu) | TikTok attribution | ~1 year | TikTok |
| _ttp (tiktok.com) | Cross-site tracking | ~1 year | TikTok |
| ttcsid | Session ID | ~3 months | TikTok |
| ttcsid_CBL7C5BC77U9VOS1N9L0 | Campaign tracking | ~3 months | TikTok |
Other tracking / ads
| Name | Purpose | Storage time | Provider |
|---|---|---|---|
| __gads / _gcl_* / IDE | Google Ads / DoubleClick | variable |
Diverzum.hu does not use behavioral advertising. The website's functions require registration. During and after registration, we handle personal data, which you can read more about in our Privacy Policy.
Managing cookies
Visitors may demand that the use of cookies be restricted, or they may even completely prevent their setting, with the exception of cookies strictly essential for the website's operation. Most browsers offer options to control cookie behavior, as well as to determine their storage time – either through built-in functionality or by using third-party extensions. To learn more about how to manage and delete cookies, visit aboutcookies.org. It is important to note that restricting or eliminating the use of cookies may limit the functionality of the page or prevent them from working flawlessly.
By pressing the "I Consent" button, you give your express consent to the use of cookies on this website.