• Personal data is only collected and processed in accordance with applicable laws and EU regulations.
• DM letters (newsletters) are only sent out if a special consent is provided. However, system messages can be sent without a consent.
• Data is stored as safely as possible.
• Personal data is transferred to third parties only in accordance with a prior consent.
• Information on the data stored on persons can be requested by the Data subjects in writing by e-mail:
• The erasure of personal data can be requested any time at .

For more detailed information, please read the Privacy Policy carefully.

Privacy Policy

Az Akriel Mathematics Korlátolt Felelősségű Társaság (registered seat: H-2000 Szentendre, Szmolnyica sétány 14. fszt. 6.; company registration number: 13-09-182127; Tax No.: 25709830-2-13; "Akriel")as Data controller recognizes the content of this Privacy Policy as binding and covenants to comply with all undertakings of this Policy and the prevailing laws in the course of its data processing activities related to the site it operates in particular the Hungarian requirements laid down in Regulation (EU) No 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 referred to as ("GDPR"), Act CXII of 2011 CXII on Informational Self-Determination and Freedom of Information (hereinafter referred to as ("Privacy Act"), Act CVIII of 2001 on certain issues of electronic commerce services and information society services (hereinafter referred to as ("e-Commerce Act") and Act XLVIII of 2008 on the Basic Requirements and Certain Restrictions of Commercial ("Commercial Act").

Akriel specifies its data processing principles and presents its expectations for itself as a Data controller herebelow.

Akriel maintains and operates a web portal (hereinafter referred to as: “Website”) under the commercial name of Akriel: https://akriel.io and processes personal data in order to:

• provide a service to its users through the Website to ensure that registered users (hereinafter referred to as "Users") can improve their mathematical skills, provide their relevant data and register themselves in a database (hereinafter referred to as "User database") for the purpose of future orders, but without the obligation to place an order, and if they have any questions related to the website or the lessons, they can contact the Data controller (hereinafter referred to as "Customer Service"), directly, and
• send newsletters with information on the benefits of the services and promotions offered on the Website, as well as the new functions and other relevant information on the Website, to visitors who have registered for the newsletter on the Website (hereinafter referred to as ("Subscribers") if such visitors, pursuant to Section 6, paragraph (1) of Act XLVIII of 2008 on Essential Conditions of and Certain Limitations to Business Advertising Activity, provided their separate consent during the registration process or registered into the designated database (hereinafter referred to as “Newsletter database”) of Akriel including advertising in electronic or other form (hereinafter referred to as "Direct marketing").

Subscribers, Users or any other Visitors to the Website are collectively referred to as "Data subjects" while related databases are referred to as "Databases on data subjects" in this Privacy Policy.

Pursuant to Article 8, paragraph (1) of the GDPR, the consent and approval of the legal representative or guardian is required for the registration and subscription of a User who has not reached the age of 16 or has a limited capacity to act, or, in the absence thereof, the registration of the minor or limited capacity User cannot be accepted by the Data controller and will be deleted. The Data controller shall make reasonable efforts to verify in such cases that consent is given or authorized by the holder of parental responsibility over the child, taking into consideration available technology. To this end, in the case of a comprehensive school subscription, Akriel will always inform the subscriber school of the need for the consent of the legal representatives, and will promptly investigate any request on data processing by the practitioner of parental responsibility, and settle the case according to the request of the legal representative.

Data recorded in the Databases of Data subjects is processed by Akriel solely in accordance with this Privacy Policy, and is not transferred or disclosed to any third party, except in cases where such access or transfer is required by law, authority or court, or referred to in this Privacy Policy.

Data subjects explicitly accept the terms of this Privacy Policy by using or registering on the Website, and voluntarily consent to the processing of their personal data in accordance with this Privacy Policy.

The legal ground for processing the data provided by Data subjects to the Databases accessible on the Website, unless otherwise mentioned in the present Privacy Policy, is the Data subject's voluntary consent.

Where personal data have been recorded with the consent of the data subject, the controller shall, in the absence of a provision to the contrary in law, process the data provided for the purpose of fulfilling his/her legal obligation or the legitimate interests of the data controller, or a third party, if the enforcement of that interest is proportionate to the restriction of the right to the protection of personal data without further consent, and may also process the personal data after the withdrawal of the consent by the data subject.

Akriel declares that pursuant to Article 9 of the GDPR, its processing of personal data does not include special categories of personal data, such personal data is not being processed.

3.1. User Database

The User Database is only accessible through the Website after registration. Akriel processes the following data of the User after a successful registration.

[Registration] Mandatory information to be provided by the User:

• name,
• e-mail address,
• date of birth,
• user type (student / teacher / parent / interested).

Optional data provided by the User at its sole discretion:

• gender,
• school class,
• school name.

[Subscription] Further information to be provided for Subscriptions:

• billing name or business name
• billing address,
• city of residence or of registered seat (if other than the billing address),
• Tax number (applicable to companies only),
• group name for group subscriptions.

[Use] Other automatically processed data related to the use of the Website:

• [Awards] Awards granted through the use of the Website, such as stars, medals, cups, group cups, etc.
  • number,
  • date
  • and further relevant details.
• [Problem solving] about solving a problem on the Website
  • the date when the task was started,
  • ID of the problem to be solved
  • the mathematical formulas entered by the User in the course of the solution,
  • the date and ID of the correctly solved and failed solutions,
• [Student group] during the operation of the student groups of the Website,
  • in the case of the leader of the student group, the date of the establishment of the student group, the name of the student group, the date of renaming, the date of acceptance or rejection of the user joining the student group, or the ID of the User concerned;
  • student group membership,
  • date of accession,
  • the full content and date of the message sent in the student group,
  • designation of a new topic in the student group, the content and date of the related message,
  • the fact and date of the likes of a message posted in the student group,
  • the content and date of a comment to a post in a student group,
• the date and time of registration, placing an order and logins on the Website.

The processing of this data is based on the voluntary consent of the Users under Article 6, paragraph (1) of the GDPR, compulsory data required for the performance of a contract concluded between Akriel and the User, the legal grounds of the data processing in this respect are the provisions of Article 6, paragraph (1), item b) of the GDPR. The provision of data by the User is essential for registering on the Website or placing an order, so the provision of data is a prerequisite for the conclusion of a contract. Participation in a student group is optional for the Users, so the processing of the related data is neither a prerequisite for the use of the Website, nor for the conclusion of the contract.

3.2. Transmission of user data

In the course of processing data of the User's Database, Akriel shall have the right to transfer or disclose data of the Users recorded during the miscellaneous use of the Website, specified under this item to the other Users of the Website or the public.

The Users shall be obliged to keep the personal data transferred to them confidential, they shall not be entitled to transfer it to third parties, nor shall they be entitled to process them for their own purposes.

All the data accessible to the User on the Website, the data of the student group concerned, is called data disclosed in the student group, whereas the data made accessible to another User is called transferred data.

[Data disclosed in a student group]

When the User joins any student groups, all of his/her personal data recorded in the User Database under Registration and Usage categories will be disclosed as a main rule. The leader of the student group is entitled to restrict the disclosure of the data in the Usage category of the User Database by properly configuring the Website.

[Transfer of Data]

If the leader of the student group restricts disclosure of any personal data categories listed in the Usage Category of the User Database, the User's data will only be transferred to the leader of the student group and will not be disclosed.

The disclosure or transfer of the aforementioned data of the User shall remain in effect as long as he/she is a member of the student group concerned. The User may leave the student group any time, in which case his/her personal data will no longer be accessible to the members of the student group.

3.3. Newsletter database

Data subjects can subscribe to the Newsletter Database on the Website by providing a separate consent during user registration, and any other forms intended for newsletter sign-up (no User registration is required for subscribing to the Newsletter Database), Akriel processes the following data of the User after the successful subscription.

Mandatory information to be provided by the Subscriber:

• name
• e-mail address

Other automatically processed data related to the Newsletter subscription:

• the date and time of the subscription.

The processing of this data is based on the voluntary consent of the Subscriber pursuant to Section 6, paragraph (1) of Act XLVIII of 2008 on Essential Conditions of and Certain Limitations to Business Advertising Activity and Article 6, paragraph (1), item a) of the GDPR. The provision of data by the Subscriber is not essential for registering on the Website or placing an order, so the provision of data is not a prerequisite for the conclusion of a contract.

3.4. The legal grounds of data processing

Akriel processes the data uploaded by the Data subject during or after the registration on the Website for the period of the purpose of the data processing, by automatically deleting the data subject's registration as well as any related data and documents uploaded upon the receipt of a relevant request from the Data subject in accordance with this item on the rights of the Data subject related to the data processing and optional remedies contained herein.

Data recorded in connection with unconfirmed or interrupted registration user requests will be deleted at the latest after fifteen (15) days.

If the User does not access the Website for two (2) years, he/she will be sent a warning message and after thirty (30) days of the message his/her personal data will be automatically deleted if the User fails to login during this period.

The processing and retention of invoices issued by Akriel and related billing information is governed by Section 169, paragraph (2) of Act C of 2000 on Accounting and is mandatory for 8 years.

Data on failed transactions will be deleted by the Website after three (3) months. Data on successful transactions is processed by Akriel for eight (8) years to prove the existence of the contract.

In respect of data that is automatically recorded and processed in connection with the use of the Website, Akriel processes the data as long as the User's legal relationship exists, but upon termination of the user relationship, such data will also be erased.

3.5. Visitor Information and Application of "cookies"

During the visit of the Website, the website places and retrieves small data packets, so-called “cookies” on the IT device of the Data subject.

Google Analytics

The following types of Google Analytics cookies will be applied on the Website: "utma", "utmb", "utmc", "utmt” and "utmz" (for detailed information on cookies used by Google Analytics on this web site, please visit: https://developers.google.com/analytics / devguides / collection / analyticsjs / cookie usage).

The listed cookies are used for the purpose of identifying and collecting the following statistical data on the visitors the Website:

• search engine, keyword, or link used to land on the Website ("utmz cookie"),
• how many times the Data subject visited the website ("utmb" cookie),
• how long the Data subject stayed on the website ("utma cookie"),
• when the Data subject first visited the website ("utmc" cookie).

In addition to the foregoing, some cookies protect the website from overload ("utmt" cookie), and some cookies used by Google Analytics capture the IP address of the IT tool used by the data subject for analytical, statistical and security purposes. Data is stored on the IT tool of the Data subject.

Therefore, independent measurement and auditing of website traffic and other web analytics data is provided by Google Analytics servers as external providers using the cookies listed above. For more information on the measurement of data, go to www.google-analytics.com for detailed information. Google's privacy policy can be found at: http://www.google.com/intl/en/policies/privacy. Data transmitted from the web portal to Google Analytics servers are not suitable for the direct identification of the User concerned, only the IP address of the IT device can be identified.

Google Adwords and Facebook remarketing

The Website uses Akriel Google Adwords and Facebook remarketing codes. Remarketing codes use cookies to tag site visitors.

The installed cookie will allow Akriel to display product and service-related advertisements to the Data subjects, and later on other websites in the Google Display network or on Facebook.

These cookies may be disabled at any time and the advertisements can be customized on the Google Ad Settings interface.

The Data subject provides his/her consent to the use of cookies by clicking on the “Accept” button on the pop-up window or by proceeding within the website (by clicking on any link or menu item).

Name: Akriel Mathematics Korlátolt Felelősségű Társaság

Represented by: Gergely Nagy, Managing Director

Address: H-2000 Szentendre, Szmolnyica sétány 14. fszt. 6.

E-mail:

Company registration number: 13-09-182127

Tax number: 25709830-2-13

In respect of the data provided by the Data subjects on the Website, the representatives and employees of Akriel are entitled to process such data, whose duties are related to the fulfillment of any purposes of data processing.

Website server Amazon Web Services EMEA SARL (Privacy Policy: https://aws.amazon.com/privacy/).

FPlease note that your data is processed electronically in online databases. The technical background of the databases is provided by Akriel in cooperation with the following providers as data processors:

• a The Rocket Science Group, LLC (Privacy Policy: http://mailchimp.com/legal/privacy/), as the provider of the newsletter sending system;
• a Functional Software Inc. (Privacy Policy: https://sentry.io/privacy/), as the provider of the troubleshooting system;
• a Barion Payment Zrt. (Privacy Notice: https://www.barion.com/en/privacy-notice/)
• az Octonull Korlátolt Felelősségű Társaság (Privacy Policy: https://www.billingo.hu/adatvedelmi-nyilatkozat), as the provider of the electronic billing system;
• a Amazon Web Services EMEA SARL (Privacy Policy: https://aws.amazon.com/privacy/), as the provider of AWS cloud computing platform;
• a Mixpanel Inc. (Privacy Policy: https://mixpanel.com/privacy/), as the provider of the product analysis system;
• a Hotjar Limited (Privacy Policy: https://www.hotjar.com/privacy), as the provider of the product analysis system;
• a Google Inc. (Privacy Policy: https://www.google.com/intl/hu/policies/privacy/), as the provider of the Google Analitics system; as well as
• a Facebook Inc. (Privacy Policy: https://www.Facebook.com/privacy/explanation#), as the provider of Facebook Custom Audiences advertising platform.

The Data controller warrants that data processing will be carried out in full compliance with applicable data protection laws and that the data controller shall take all necessary measures to ensure data security and data protection, the data processing activities it performs meets all the legal requirements for data security.

Some data controllers may transfer data towards third countries. In such cases the data transfer is subject to the effective data protection laws, which means it takes place in the framework of the EU-US Privacy Shield or by data transfer agreements approved by the European Commission.

Taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for rights and freedoms of natural persons posed by the processing, the controller shall, both at the time of the determination of the means for processing and at the time of the processing itself, implement appropriate technical and organisational measures, such as pseudonymisation, which are designed to implement data-protection principles, such as data minimisation, in an effective manner and to integrate the necessary safeguards into the processing in order to meet the requirements of this Regulation and protect the rights of data subjects.

The Data controller and Data processor shall implement appropriate technical and organisational measures for ensuring that, by default, only personal data which are necessary for each specific purpose of the processing are processed. That obligation applies to the amount of personal data collected, the extent of their processing, the period of their storage and their accessibility. In particular, such measures shall ensure that by default personal data are not made accessible without the individual's intervention to an indefinite number of natural persons.

The controller shall designate a data protection officer in any case where the core activities of the controller consist of processing operations which, by virtue of their nature, their scope and/or their purposes, require regular and systematic monitoring of data subjects on a large scale; or the core activities of the controller or the processor consist of processing on a large scale of special categories of data pursuant to Article 9 and Article 10.

Akriel informs all Data subjects that it does not process data under Articles 9 and 10 of the GDPR, and that the core activity of the Data controller is to operate the User and Newsletter databases. These activities do not require regular and large-scale monitoring of the Data subjects.

Therefore, Akriel as Data controller does not appoint a Data Protection Officer, but its decision is reviewed every calendar year according to the current state of data processing.

Akriel shall notify the competent supervisory authority of all personal data breach cases without undue delay, and, if possible, at the latest 72 hours after receipt of information thereof, unless the personal data breach is unlikely to pose a risk to the rights and freedoms of natural persons.

If a personal data breach is likely to pose a high risk to the rights and freedoms of natural persons, Akriel shall inform the Data Subject of the personal data breach without undue delay.

In the notification provided to the Data Subject, Akriel will explain the nature of the personal data breach in a clear and comprehensible manner, and shall provide at least the information and measures provided for in Article 34, paragraph (2) of the GDPR.

The Data subject does not need to be notified by Akriel of the personal data breach if any of the following conditions are satisfied:

• the Data Controller has implemented appropriate technical and organizational protection measures and those measures were applied to the data concerned by the personal data breach, in particular measures, which make data impossible to interpret for persons with unauthorized access to personal data;
• the Data Controller has taken measures after the personal data breach that ensure that the high risk posed to the rights and freedoms of the Data subject is no longer likely to be realized;
• the notification would require a disproportionate effort. In such cases, the Data subjects shall be informed by means of publicly disclosed information, or similar measures shall be taken to ensure the notification of Data subjects with equal efficiency.

The Data Subject shall have

• the right to access as set forth in Articles 12 to 22 of the GDPR and the right to notification, under which Akriel is obliged to inform the Data subject of its rights under GDPR, of personal data breach cases and of the information contained in Articles 13 and 15 of the GDPR.; and
• the right to data portability, the right to rectification and erasure, and the right to object.

Accordingly, the Data controller

• informs the Data subject about the processing of its personal data, including the data processed by the data subject or the data processor he or she has authorized, their source, the purpose, legal grounds, the duration of the data processing, the name and address of the data processor and its activities related to data processing, the circumstances, effects and measures taken to prevent the personal data breach (if any) and, in the case of transfer of the personal data of the Data subject, the legal grounds and the recipient of the transfer; and
• rectifies, erases or locks the personal data provided by the Data subject (the Data subject may also perform the erasure of its data as indicated during the registration, and may also request the erasure through the Customer Service of the Data controller).

Notification on rights

The controller shall take appropriate measures to provide any information related to the completion of the tasks referred to above in a concise, transparent, intelligible and easily accessible form, using clear and plain language, in particular for any information addressed specifically to a child. The information shall be provided in writing, or by other means, including, where appropriate, by electronic means. Oral information may be provided upon the request of the Data subject, provided that his or her identity has been verified.

The Data controller shall facilitate the exercise of data subject rights. The Data controller shall provide information on action taken on a request under Articles 15 to 22 to the Data subject without undue delay and in any event within one month of receipt of the request.

That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. The Data controller shall inform the data subject of any such extension within one month of receipt of the request, together with the reasons for the delay.

If the Data controller does not take action on the request of the data subject, the controller shall inform the data subject without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of filling a complaint with a supervisory authority and seeking a judicial remedy.

The controller shall provide the aforementioned information, notification and measures specified in Article 13 of the GDPR free of charge. Where requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character, the controller may either charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or refuse to act on the request. The controller shall bear the burden of demonstrating the manifestly unfounded or excessive character of the request.

Information and access to personal data

The controller shall make the information referred to in Article 13, paragraph (1) to (2) of the GDPR available to the Data subject upon receipt of the personal data.

The Data subject shall have the right to obtain from the Data controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the information set forth in Article 15, paragraphs (1) to (2) of the GDPR (right of access by the data subject).

The Data controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the Data subject, the controller may charge a reasonable fee based on administrative costs. Where the Data subject makes the request by electronic means, and unless otherwise requested by the Data subject, the information shall be provided in a commonly used electronic form.

Right to data migration

Pursuant to Article 20 of the GDPR, the Data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller (right to data portability).

Right to rectification, erasure and object

The Data Subject has the right to withdraw his/her consent to data processing without any justification for the future. Pursuant to Articles 16 to 18 of the GDPR, the Data subject shall have the right to rectification, to be forgotten (erasure) and to restrict data processing.

The Data subject shall have the right to obtain from the Data controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; the data subject withdraws consent on which the processing is based according to Article 6, paragraph (1), item a) of the GDPR, and where there is no other legal ground 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 have to be erased for compliance with a legal obligation in European Union or Hungarian law to which the controller is subject.

Pursuant to Article 21 of the GDPR, the Data subject shall have the right to object to processing of personal data concerning him or her. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her.

The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.

Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing.

Right to remedy

The Data subject shall send its requests and notifications via e-mail to Akriel to or via mail to H-2000 Szentendre, Szmolnyica sétány 14. fszt.6.

In case of exercising his/her rights related to the processing of his/her personal data, in case of refusal of the request or notification sent to the data controller or the Data controller’s failure to act upon them, the Data subject may turn to the National Authority for Data Protection and Freedom of Information (NAIH) or to court pursuant to the provisions of the GDPR and the Privacy Act.

In addition, the Data subject

• shall have the right to turn to court in order to enforce its rights in the case of violation of the processing of his/her personal data,
• shall receive compensation for the for damage caused by unlawful processing of his/her personal data or the breach of data security requirements, and
• may claim a grievance fee due to the infringement of his/her privacy rights by the unlawful processing of his/her data or violation of data security requirements

Pursuant to Articles 77 to 82 of the GDPR.

The Data subject is entitled to all rights, remedies and other claims provided by law, set forth in the GDPR and the Privacy Act.

Akriel Mathematics Kft.