Data Privacy Policy

In order to comply with Regulation 2016/679 of the European Union and the Council (the Regulation), Guide.me Limited Liability Company (registered office: 1078 Budapest, István utca 45. III. em. 42., company registration number: 01-09-322949, „Guide.me”) informs you about the data processing performed during the use of the Guide.ME application in this data processing guide:

This privacy policy describes how the Guide.ME application accesses, collects, uses and discloses user data and what types of personal and confidential data the Guide.ME application accesses, collects, uses and discloses, as well as what parties the personal or confidential user data are disclosed to.

In case of iOS devices, the Guide.ME application processes your geolocation data collected in the background and your location data used for ads as described in Section 2, especially Section 2.1 below.

In case of Android devices, the Guide.ME application processes your personal data as described in Section 2, especially 2.2 below.

The data controller and the data protection officer

Regarding the processing of your personal data, the data controller is Guide.me Limited Liability Company (registered office: 1078 Budapest, István utca 45. III. em. 42., company registration number: 01-09-322949).

Guide.me has not appointed a data protection officer.

The purpose and legal basis of data processing

You do not need to register or provide any other personal data in order to use the Guide.ME application, and the Guide.ME application does not have access to the personal data stored on your device.

The provision of personal data necessary for the use of the Guide.ME application is not based on any law or contractual obligation and it is not a precondition for contracting. You are not obliged to provide the personal data and in case you fail to provide your personal data, it will not constitute a breach of law or breach of contract.

No automated decision-making and profiling are performed during the use of the Guide.ME application.

If Guide.ME wishes to perform further personal data processing for a purpose other than the purpose for which the data were collected, it will inform you of this different purpose and any relevant additional information before further data processing.

Collection of statistical data

During the usage of the Guide.ME application, Guide.me only processes statistical data (including, for example, the number of downloads of the application, the age and gender of the user downloading the application, the country where the application was downloaded, the language running on the device and the operating system of the device); no personal data suitable to identify you are processed.

Access to the phonebook entries

With your consent, the Guide.ME application reviews whether the emergency contact information have already been stored in the phonebook of your device and if not, the Guide.ME application saves the emergency telephone numbers listed in the Guide.ME application in the phonebook of your device. The Guide.ME application can be used without giving your consent to saving the emergency telephone numbers in your phonebook.

Collection of personal data (geolocation data and data required to send advertisements) in case of iOS devices:

The Guide.ME application accesses, collects and uses the following personal data in the following ways in case of iOS devices:

Personal data	Source of personal data	Purpose of collecting personal data	Use of personal data
Device identifier data	Automatically read from the device on which you install the application	To ensure the development of the operation and of the functions of the Guide.ME application	Statistical data collection for Google Firebase service
Geolocation data of the device	Automatically read from the device on which you install the application	To ensure the use and the operation of the functions of the Guide.ME application	Tracking the location of your device by following the geolocation data in the background Indicating your device’s location on the map If you get less than 5,000 metres away from certain points placed on the map, it will draw your attention to significant places/attractions nearby or send you advertisements edited by third parties in connection with the important places/attractions nearby by using the Geofence API
Motion & Fitness data in case of iOS operational system	Automatically read from the device on which you install the application	To ensure the use and the operation of the functions of the Guide.ME application	Optimisation of position retrieval in the background, avoiding continuous GPS use, calculating position change from the motion data

Given your consent, the Guide.ME application constantly monitors the location of the iOS device on which you installed the application while the application is running. Guide.me automatically monitors the data related to the location of the device while the application is running; it does not save or store these data or perform any other data processing apart from real-time monitoring.

Guide.me sends the information on the significant places/attractions placed by Guide.me on the map to your iOS device and your iOS device processes the information provided by Guide.me while the Guide.ME application is running. When you approach the points placed on the map by Guide.me within 5,000 metres, you will be notified of the significant places/attractions near you in push messages sent through the Guide.ME application and you will receive advertisements edited by third parties in connection with the significant places/attractions nearby. Guide.me uses the Geofence API to provide you with such notification.

The Guide.ME application can also be used without enabling the monitoring of the location data and push messages. In this case, you can see the places/attractions marked on the map, as well as read the articles related to such places/attractions; however, you cannot see your own position on the map, nor will you be notified about the given place/attraction.

The legal basis for the above data processing is your consent (Article 6 (1) a) of the Regulation).

The legal basis for processing the personal data needed to send the push messages (including the advertisements) is your consent (Article 6 (1) a) of the Regulation).

Collection of personal data in case of Android devices:

The Guide.ME application accesses, collects and uses the following personal data in the following ways in case of Android devices:

Personal data	Source of personal data	Purpose of collecting personal data	Use of personal data
Device identifier data	Automatically read from the device on which you install the application	To ensure the development of the operation and of the functions of the Guide.ME application	Statistical data collection for Google Firebase service
Geolocation data of the device	Automatically read from the device on which you install the application	To ensure the use and the operation of the functions of the Guide.ME application	Indicating your Android device’s location on the map If the Guide.ME application is running in the foreground and you get less than 200 metres away from certain points placed on the map, it will draw your attention to significant places/attractions nearby or send you advertisements edited by third parties in connection with the important places/attractions nearby by using the Geofence API

Personal data

Source of personal data

Purpose of collecting personal data

Use of personal data

Device identifier data

Automatically read from the device on which you install the application

To ensure the development of the operation and of the functions of the Guide.ME application

Statistical data collection for Google Firebase service

Geolocation data of the device

Automatically read from the device on which you install the application

To ensure the use and the operation of the functions of the Guide.ME application

Indicating your Android device’s location on the map

If the Guide.ME application is running in the foreground and you get less than 200 metres away from certain points placed on the map, it will draw your attention to significant places/attractions nearby or send you advertisements edited by third parties in connection with the important places/attractions nearby by using the Geofence API

Guide.me sends the information on the significant places/attractions placed by Guide.me on the map to your Android device and your Android device processes the information provided by Guide.me while the Guide.ME application is running. If the Guide.ME application is running in the foreground and you approach the points placed on the map by Guide.me within 5,000 metres, you will be notified of the significant places/attractions near you in push messages sent through the Guide.ME application and you will receive advertisements edited by third parties in connection with the significant places/attractions nearby. Guide.me uses the Geofence API to provide you with such notification.

The Guide.ME application can also be used without enabling the processing of the geolocation data of your Android device. In this case, you can see the places/attractions marked on the map, as well as read the articles related to such places/attractions; however, you cannot see your own position on the map, nor will you be notified about the given place/attraction.

The legal basis for the above data processing is your consent (Article 6 (1) a) of the Regulation).

The legal basis for processing the personal data needed to send the push messages (including the advertisements) is your consent (Article 6 (1) a) of the Regulation).

Recipients of the personal data

Guide.me sends the information on the significant places/attractions placed by Guide.me on the map to your device and your device processes the information provided by Guide.me while the Guide.ME application is running, the IT professionals of Guide.me do not have any access to your data.

Guide.me does not give access to any other person to your personal data and Guide.me does not sell or hand over your personal data to any third party. However, Guide.ME application sends anonym application usage data through Google Analytics for Firebase and Firebase Crashlytics. The usage data sent by the Guide.ME application is not connected to any of your personal data.

No personal data will be transferred outside the countries of the European Economic Area or to international organisations.

The source of personal data

Guide.me automatically collects the device identification data from the device on which you installed the Guide.ME application and automatically processes the data related to your location from the geolocation data of the device on which you installed the Guide.ME application.

Guide.me collects the statistical data from Google Ireland Limited (Gordon House, Barrow Street, 4 Dublin, Ireland).

The duration of data processing

Guide.me processes the personal data while the application is running, the data processing is real-time. Guide.me does not save or store such data or process any personal data.

Your rights related to data processing

In order to exercise your rights related to data processing, you can contact Guide.me via email at hello@guideme.hu.

Guide.me will execute your request related to exercising your rights as the data subject within a maximum of one month after receiving it. The date of the receipt of the request does not count towards the deadline.

Considering the complexity of the request and the number of requests, Guide.me may extend this deadline as necessary by a further two months. Guide.me will inform you of the extension of the deadline within one month of receiving the request, stating the reasons for the delay.

You may exercise the following rights regarding the processing of your personal data:

Right to withdraw your consent

You are entitled to withdraw your consent to manage your location, your consent to send push messages, and your consent to save emergency phone numbers in your phonebook at any time under the settings menu of the application on the device on which you have installed the Guide.ME application. You can access the interface needed to manage consents under the settings menu point for the Guide.ME application of the operating system running on your device.

Further, you are entitled to notify Guide.me of the withdrawal of your consent to the processing of your personal data by sending an e-mail to hello@guideme.hu.

If you withdraw your consent to the processing of your personal data, this shall not affect the lawfulness of the processing of personal data based on your content during the period between granting your consent and the withdrawal of the consent.

Right of access

You have the right to get feedback from Guide.me regarding whether Guide.me processes your personal data and you may request a copy of your processed personal data.

If Guide.me processes your personal data, you have the right to know

which of your personal data Guide.me processes based on what legal basis and for how long,
to whom, when and based on what legal regulation Guide.me provided access to which of your personal data or to whom it forwarded your personal data,
from what source your personal data are received,
whether Guide.me applies automated decision-making, as well as its logic, inclusive of profiling.

Guide.me will make a copy of the personal data subject to data processing available to you free of charge for the first time at your request; subsequently, it may charge you a reasonable fee based on administrative costs.

In order to comply with data security requirements and to protect your rights, Guide.me must make sure that the data subject and your identity match; to this end, the provision of information, access to the data and the issuance of a copy of the data are subject to the identification of the person of the data subject.

Right to rectification

You are entitled to request Guide.me to correct your inaccurate personal data or supplement your incomplete personal data without unreasonable delay.

If you can satisfactorily prove the accuracy of the rectified data, Guide.me will satisfy your request within a maximum of one month and notify you using the contact details you provided.

Right of restriction of processing

You may request that Guide.me should restrict the processing of your personal data if

you challenge the accuracy of your personal data (in this case, Guide.me restricts your data processing to the duration while it verifies the accuracy of your personal data),
data processing is illegal, you object to the deletion of personal data and request a restriction on their use instead,
me does not need the personal data for the purposes of data processing; however, you request the restriction of the personal data in order to submit, enforce or protect your legal claims, or
you objected to the data processing (in this case, the restriction applies for the duration while it is determined whether the legitimate reasons of Guide.me take precedence over the data subject’s legitimate reasons).

Right to erasure

You may request that Guide.me should erase your personal data.

Guide.me will delete your personal data without unreasonable delay if (i) Guide.me does not need your personal data for the purpose for which it collected or processed them, (ii) Guide.me processed your personal data unlawfully, (iii) Guide.me is obliged to delete personal data in order to fulfil its legal obligation.

Data security

Guide.me does not give access to any other person to your personal data and Guide.me does not sell or hand over your personal data to any third party.

However, Guide.ME application sends anonym application usage data through Google Analytics for Firebase and Firebase Crashlytics. The usage data sent by the Guide.ME application is not connected to any of your personal data.

Steps you can take in case of infringement

If you believe that Guide.me has infringed your rights while processing your personal data, you may contact the School at hello@guideme.hu.
If your rights related to your personal data are infringed, you may file a complaint with the National Authority of Data Protection and Freedom of Information (email address: ugyfelszolgalat@naih.hu, postal address: 1363 Budapest, Pf. 9., address: 1055 Budapest, Falk Miksa utca 9-11., phone: +36 (1) 391-1400, website: naih.hu).
In the event your rights related to your personal data are infringed, you have the opportunity to turn to the court to protect your data, which will with priority. In this case, you are free to decide if you initiate an action before the court with jurisdiction over your permanent place of residence (permanent address) or temporary place of residence (temporary address) or the registered office of Guide.me.

In effect from 25th January 2023