The scope of this information includes both the natural person users of the RECASH
application as well as the natural and legal persons and organisations without legal personality using
the RECASH application as an advertiser.
The operator of the RECASH application shall manage the data, facts and
information obtained during or in connection with the use of the RECASH application in accordance with
At the same time as the registration for the RECASH application as a user or an
advertiser, the user or advertiser shall accept the provisions contained in this Information and
voluntarily consent to the processing of their data and information in accordance with this
If you do not agree with the content of this Information, please do not register
and do not use the services of the application.
The provisions of this Information under Sections 2-9 about data processing and
the protection of personal data are exclusively related to natural persons, i.e. users using the
service, who are regarded as consumers, as well as the natural persons or natural person employees of
companies publishing an advertisement via the application.
The provisions of this Information under Section 10 below about the protection
of commercial secrets shall only be relevant for advertisers in terms of the fact that commercial
secrets may only be interpreted in relation with a business activity on the basis of Section 2:47 of the
Civil Code. Therefore, Section 10 of this Information shall only prevail regarding the commercial
secrets of advertisers.
Identification of the data controller
The controller of the user and natural person advertiser personal data entered
into or generated by the RECASH application is Recash Ltd. (hereinafter: “Operator”).
During the performance of its activity, the Operator uses the cloud-based Azure
service of the Microsoft Corporation (One Microsoft Way, Redmond, Washington, U.S.) to operate the
application and the system, thereby the Microsoft Corporation may be considered to be the data
The identification of the data protection officer and the data owner
Name and contact details of the Data Protection Officer: Dr. Máté
Tóth, e-mail: email@example.com
In accordance with paragraph e) of Section 4 (1) of Government Decree No.
42/2015 (III.12.) on the protection of the IT system of financial institutions, insurance and
reinsurance companies as well as investment firms and commodity exchange service providers, the Operator
specifies the following person/organisation as the data owner:
The legal basis for data processing
Data processing by the Operator is based on the consent of the data subject.
Data subjects expressly accept this Information during registration and, by accepting the Information,
they give their express and voluntary consent to their data being processed in accordance with this
Information. In the absence of the consent of the data subject, the data subject may not use the
Data processing by the Operator is also made possible in accordance with Section
13/A of Act CVIII of 2001 on certain issues of electronic commerce services and information society
services for the purpose specified therein.
Purpose of data processing
Operator processes the personal data of users primarily in order to deliver the
special offers of advertisers who have registered in the RECASH application to users.
The Operator processes the personal data of natural person advertisers or
natural person employees of company advertisers primarily to deliver the special offers of advertisers
Description of data processing
Operator processes the personal data of users in the following ways and for the
Displaying the special offers of advertisers who have registered in the RECASH
application on the lock screen of the smartphones of users if the specific offer pertains to the living
space and – if specified by the user in their individual settings – areas of
Displaying the living space-independent special offers of advertisers who have
registered on the RECASH application on the lock screen of the smartphones of users;
Using and validating the special offers that have been added to favourites for
the relevant advertiser;
Sending newsletters to the email addresses of users specified upon registration
about new services and developments of the RECASH application, as well as other useful information about
the use of the RECASH application;
Ensuring the efficient operation of the services of the RECASH application at the
highest possible standard;
Creating statistics about user habits regarding the use of the RECASH
The application works on the principle that it classifies advertiser user
locations per category into circular geographical zones of different radii covering the entire territory
of the given city, and determines the living space of a particular user, taking into account their
current and regular locations. In order to achieve this, the application identifies the location of the
smartphone of registered users and stores the GPS coordinates of geographical locations where the user
steps out of an assigned circle and into the geographical zone of another advertiser.
Users have the option to specify their interests in the settings of their
personal account, in which case only those special offers that are in their living space or that are
living space-independent are displayed on the lock screen of their smartphone which pertain to the
specified areas of interest. If the user does not specify areas of interest, all special offers that are
in the user’s living space or that are living-space independent may be displayed on the lock
screen of the user device.
The Operator processes the personal data of natural person advertisers or
natural person employees of company advertisers in the following ways and for the following
Creating the cooperation agreement to be concluded with the advertisers and
defining the content thereof;
Following up the performance of cooperation agreements concluded with the
advertisers as a result of the registration, invoicing the relevant fees and enforcing any other
Amending the cooperation agreements concluded with the advertisers as a result
of the registration;
Sending newsletters to the email addresses of advertisers specified upon
registration about new services and developments of the RECASH application, as well as other useful
information about use of the RECASH application;
Ensuring the efficient operation of the services of the RECASH application at the
highest possible standard;
Creating statistics about user habits regarding the use of the RECASH application
as well as user interest in the advertiser’s special offers.
Scope of the processed data
The Operator processes the following personal data of users:
areas of interest (if voluntarily specified by the user);
current and regular locations of the user based on GPS coordinates,
special offers that have been added to favourites by the user and/or have been
new offers based on the evaluation of user data and preferences specified in
sections a)-f) above in an automated manner.
The Operator processes the following personal data of natural person
scope of activities;
location of sites and business premises of the company with GPS
bank account number;
name, email address and telephone number of contact person.
In accordance with the above, the Operator performs “profiling” of
users, i.e. evaluates the personal characteristics of users in an automated manner to deliver relevant
advertisements to the user. This profiling is based on the relevant user’s consent. If the user
does not wish to enable the Operator to perform this activity, the user may not use the application,
since the purpose of the application is to deliver relevant advertisements to the user based on their
continuously changing preferences. In the absence of consent, withdrawal of the registration for the
application as well as of consent after registration makes it impossible for the user to use the
application. If the user objects to the management of their personal data and preferences for profiling
purposes, we suggest that the user should not download the application and should not register, or if it
has already taken place, the user should delete the registration and the application from the device.
After this point, all personal data for profiling and about the user are deleted from all systems of the
Operator, so the duration of data processing lasts only until the deletion of the application or
If, during use of the RECASH application, the user or the natural person
advertiser specifies additional personal data on the mobile or web interface of the application, by
specifying those personal data, the user or advertiser also consents to the processing of such data by
the Operator in accordance with this Information.
The Operator does not process sensitive payment data within the scope of the
data processing activity. Pursuant to paragraph 5a of Section 2 of Act LXXXV of 2009 on the provision of
payment services, sensitive payment data are data that can be used to commit fraud, including personal
credentials, with the provision that the name of the account holder and the payment account number are
not considered to be sensitive payment data with regard to the payment initiation service or account
information service. In relation to the account information service, the Operator processes the name and
payment account number of the account holder, which are not regarded as sensitive payment data in
accordance with the above.
Duration of data processing
Data processing starts upon the registration of the user or advertiser (by
providing the consent of the data subject) and lasts until the deletion of the registration or
application (withdrawal of the consent of the data subject).
If the user or advertiser deletes the registration and the application, the
Operator ends data processing and deletes the data of the user or advertiser concerned without delay,
except if fee-related or other claims exist against the advertiser, in which case the Operator may
maintain the processing of data required for the enforcement thereof, for the purpose of enforcing the
Data transfer to third persons
The Operator may make available (traffic) data related to the use of the
application in a manner unsuitable for identifying individual users and organised or grouped according
to different aspects in order to demonstrate the effectiveness and efficiency of the RECASH application
and to enable advertisers to develop their services in accordance with the interests of users. The
Operator may make available certain information in a statistical form in order to inform interested
parties about the effectiveness and efficiency of its services.
The court, the public prosecutor and the authorities may contact the Operator
for the purpose of seeking the provision of information, disclosure of data and issue of
The Operator shall provide personal data to the court, the public prosecutor and
the authorities – if the specific purpose and the scope of data have been specified by the court,
the public prosecutor or the authorities – only to the extent that is indispensable for the
achievement of the purpose of their request.
The Operator may use the data of the data subject that have been lawfully
recorded and registered in order to settle any legal disputes between them, either during the
negotiations for avoiding a legal dispute and/or the official litigation or non-litigation proceedings
for settling the legal dispute.
Besides the content of this information, the Operator is entitled to transfer
the personal data to third persons exclusively based on legal authority.
Rights and remedies of the data subject regarding data processing
The data subject may request information from the Operator about the processing
of their personal data and may request the correction, deletion or blocking of their personal data and
may object to data processing by the Operator.
Upon the request of the data subject, the Operator shall provide information
about the data processed by them and – if any – the data processed by any data processor
commissioned by them, the source of such data, the purpose of data processing, the legal basis, duration
thereof, the name, address (registered office) and data processing-relevant activity of the data
processor (if any), and to whom the data of the data subject are or have been transferred for what
purpose and on what legal basis.
The Operator shall provide the information to the data subject in a clear manner
in writing within the shortest possible time after the submission of the request, but within 30 days at
the latest. This information provision is free of charge if the requester has not submitted any
information requests to the data controller for the same data scope in the same year. In other cases,
the Operator may set a fee.
The Operator shall delete the personal data of the data subject if its
processing is unlawful, if it is requested by the data subject, if the purpose of data processing has
ceased to exist, or if the legally defined deadline for data storage has expired, or if it has been
ordered by the courts or the Hungarian National Authority for Data Protection and Freedom of Information
(the “Authority”). The Operator solely and exclusively manages data that are absolutely
necessary for providing the services to the users and advertisers. This means that if any data subject
requests the deletion of their data, in accordance with Section 1.4 above, the data subject will not be
able to use the application thereafter and the registration will be deleted.
The Operator shall inform the data subject and anyone who the data have been
transferred to for the purpose of data management or data processing about the correction, deletion or
blocking of the personal data. The notification can be omitted if it does not violate the legitimate
interest of the data subject with regard to the purpose of data processing.
In the event of a violation of law or a direct risk thereof, the data subject
may report it to the Authority and initiate an investigation.
Upon the violation of the rights of the data subject, the data subject may turn
to the courts against the Operator. The court shall give priority to the case.
The Operator shall reimburse any damage caused to others by unlawful management
of the data of the data subject or by the breach of data security requirements. The Operator shall be
liable to the data subject for any damage caused by the data processor as well. The Operator shall be
exempt from liability if the damage was caused by an unavoidable cause outside the scope of data
processing. The damage shall not be reimbursed if it was due to the intentional or gross negligent
conduct of the injured party.
Regarding the management of personal data, the data subject is entitled to
contact the Operator’s Data Protection Officer. Name and contact details of the Data Protection
Officer: Dr. Máté Tóth, e-mail: firstname.lastname@example.org
Confidential management of commercial secrets
During the performance of cooperation agreements with advertisers, the Operator
may obtain information about the advertisers that are regarded as commercial secrets. In each case, the
advertiser shall inform the Operator if any information is to be regarded as a commercial secret and
shall request the confidential management thereof. If no such information is provided, the Operator
shall not be liable if the information concerned is made public or learnt of by third parties.
The Operator shall ensure the confidential management of information specified
as a commercial secret.
The Operator shall store the data of advertisers and users as well as relevant
information in electronic format on the server of the RECASH application.
The Operator shall select and operate the IT devices applied during the
provision of the service for the management of personal data so that
the data processed are available to the persons authorised to access them
their authenticity and authentication (authenticity of data processing) are
it can be proven that the data have not been changed (data integrity),
the data processed are protected against unauthorised access (data
The Operator ensures the protection of the security of data processing through
technical and organisational measures that provide a sufficient level of protection against the risks of
data processing. The Operator shall ensure security through server-level and application-level
However, users and advertisers acknowledge that no Internet-based data transfer
can guarantee 100% security. Therefore, even though the Operator takes all commercially reasonable
security steps to protect the data of users and advertisers, and seeks to contract partners who perform
their activity in a similar manner, the Operator cannot guarantee the security of data arriving to or
leaving the mobile or Internet interface of the application.
The Operator’s servers automatically register the habits of registered
users regarding what special offers are added to their favourites, what offers they view from the list
of offers, which offers that have been added to favourites they validate at the advertiser and certain
other information. This information is used exclusively in an aggregated and processed form for the
purpose of increasing the efficiency of our services and correcting any possible errors, for improving
quality and for statistical purposes. The data are not linked to other data provided by users and
advertisers in any form.
The Operator may place a unique identifier, a so-called cookie, on the devices
of users and advertisers. Blocking cookies does not prevent the user from using our services. An
exception to this is if the Operator informs the user of the contrary in advance.
A cookie is a small text file placed on the devices of users and advertisers for
data tracking purposes and containing data about the specific user or advertiser. Cookies support us in
developing and personalising the mobile and web interfaces of the RECASH application according to user or
advertiser needs. Cookies track the interests of the user or advertiser and enable us to collect data
that are not suitable for identifying the person about the user or advertiser, e.g. what pages they have
visited, which links they have clicked.
Other data tracking tools
The Operator may also use other, professionally accepted techniques, e.g. pixel
tag and web beacon to track how the user or advertiser uses the mobile and web interfaces of the
application and how the users use the special offers of advertisers. In addition, the Operator may allow
third party service providers to use these tools as assigned by the Operator.
Pixel tags and web beacons are small graphic elements that are placed on the
mobile and web interfaces of the application or in our email messages, making it possible to see whether
the user or advertiser performs a certain activity or not. Pixel tag makes it possible to measure and
improve the visitor traffic and behaviour of the application and to measure the success of the special
offers of advertisers as well as our operations.
Data protection regulation of third party websites
Third party mobile apps or websites may also be available from the mobile or web
interfaces of the RECASH application. This information does not cover the management of data disclosed
through a mobile app or website operated by third parties. Such third party mobile apps and websites
have their own data protection regulations. The Operator does not take responsibility for the data
protection practice of third parties.
Amendment of the Data Processing Information
The Operator reserves the right to unilaterally amend this Information. The
Operator shall inform registered users and advertisers about the amendment via email or
The amended data processing information shall automatically enter into force at
the time specified therein. If, after the entry into force of the amended data processing information,
the user or advertiser uses the services of the application and does not object to data processing
according to the amendment, this shall mean that the data subject accepts the amended data processing
information and agrees to be bound by its provisions.
RECASH is authorised by the Financial Conduct Authority (United Kingdom).