Customer Panel Privacy and Customer Feedback Handling Policy
This privacy and customer feedback handling policy (hereinafter referred to as the „Policy”) is effective as of 17th March, 2025 regarding the data processing activities related to the Commsignia Customer Panel.
- Terms used in this Policy with an initial capital letter have the meanings ascribed to them in Section 1 (Definitions), unless expressly set forth otherwise (for the avoidance of doubt the definitions set forth in Section 1 are also applicable to the fully capitalized sections of this Policy).
- The purpose of the Customer Panel is to utilize feedback (and other received Communication) to improve the Products, offers, strategy, marketing and/or overall operations of Commsignia and its company group, and to better understand Your and the Organizations’ preferences and needs. To this end, You can provide Communication to Commsignia, to help achieving this goal.
- COMMSIGNIA MAY FREELY USE, COPY, TRANSFER, DISCLOSE, LICENSE, DISTRIBUTE, MODIFY, AND EXPLOIT ANY COMMUNICATION IN CONNECTION WITH ITS PRODUCTS. THIS INCLUDES – WITHOUT LIMITATION – CREATING NEW OR MODIFIED PRODUCTS, SOLUTIONS, TECHNOLOGY, INTELLECTUAL PROPERTY, KNOW-HOW, OR OTHER PROPRIETARY INFORMATION USING, BASED ON, OR DERIVED FROM ANY COMMUNICATION. SUCH USE SHALL BE WITHOUT OBLIGATION, ROYALTY, OR RESTRICTION TOWARDS YOU OR ANY THIRD PARTY, BASED ON INTELLECTUAL PROPERTY RIGHTS OR OTHERWISE. YOU SHALL TRANSFER TO COMMSIGNIA ALL RIGHTS IN AND/OR TO ANY INTELLECTUAL PROPERTY, KNOW-HOW OR ANY OTHER INFORMATION INCORPORATED IN THE COMMUNICATION (OR IN CASE SUCH TRANSFER IS PROHIBITED BY APPLICABLE LAW, YOU SHALL GRANT LICENSE TO COMMSIGNIA TO USE THEM AS SET FORTH IN THIS CLAUSE). NO COMMUNICATION WILL BE CONSIDERED YOUR (OR ANY THIRD PARTY’S) CONFIDENTIAL INFORMATION, AND NOTHING SHALL LIMIT COMMSIGNIA’S RIGHT TO INDEPENDENTLY USE, DEVELOP, EVALUATE, OR MARKET PRODUCTS, WHETHER INCORPORATING COMMUNICATION OR OTHERWISE. COMMUNICATION (INCLUDING THE RIGHTS TRANSFERRED AND/OR GRANTED) IS PROVIDED BY YOU FREE OF CHARGE.
- WE ASK YOU TO ONLY SHARE COMMUNICATION WITH COMMSIGNIA IF AND TO THE EXTENT YOU HAVE THE RIGHT TO DO SO. BY SHARING A PIECE OF INFORMATION (INCLUDING ANY COMMUNICATION) WITH COMMSIGNIA, YOU REPRESENT AND WARRANT THAT YOU ARE ENTITLED TO PROVIDE COMMSIGNIA WITH THAT PIECE OF INFORMATION, AND THAT YOU ARE ENTITLED TRANSFER AND GRANT US THE RIGHTS SET FORTH IN SECTION C. ABOVE, AND IT DOES NOT BREACH THE RIGHTS OF ANY THIRD PARTY.
1. DEFINITIONS
Communication means any comment, feedback, information or document provided by Data Subject to Commsignia via any channel.
General Data Protection Regulation or GDPR means the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th 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.
Commsignia or “we” means Commsignia Ltd.
Registered office: 14 Széchenyi utca, 7252 Attala, Hungary
Postal address: 4-20 Irinyi József utca, 1117 Budapest, Hungary, ATTN: Commsignia Legal
Tax No.: 23874664-2-17
Registration No.: 17-09-010377
Email address: [email protected]
Website: www.commsignia.com
Organization means the entity (including, but not limited to companies, NGOs, government agencies) the Data Subject employed by, represents, affiliated with, or otherwise in a similar contractual relationship with.
Product means hardware, software products and connected services marketed and sold by Commsignia, whether manufactured by Commsignia or a third party.
Customer Panel means a structured initiative designed by Commsignia to gain a deeper understanding of customer needs, preferences and the current state and foreseeable future of the ITS industry by conducting interviews and other discussions with customers and other industry stakeholders. The purpose of the Customer Panel is to utilize feedback (and other received Communication) to improve the Products, offers, strategy, marketing and/or overall operations of Commsignia and its company group, and to better understand Data Subjects’ and the Organizations’ preferences and needs.
Data Subject or “You” means a natural person registered to the Customer Panel.
2. PRIVACY POLICY
2.1. Purpose of this document
This Policy sets out the terms and conditions of how the Data Subject’s personal data is processed in connection with the Customer Panel. Please read this Policy carefully.
2.2. Availability and updating of this document
The current version of this document is available here. Commsignia reserves the right to amend this Policy unilaterally at any time. You will be informed of any amendment of this Policy in advance, provided that You have provided Commsignia with Your email address.
2.3. Data controller
2.3.1. The Data Subject’s personal data provided or generated in relation of the Customer Panel is processed by Commsignia as data controller.
2.3.2. The provided or generated personal data of the Data Subject is accessible to the following persons within Commsignia:
Commsignia’s employees involved in the data processing (including support staff, product team, sales and account specialists who are in contact with the Data Subject) as part of their role within Commsignia in connection with performing their duties associated with the Customer Panel.
2.4. Data processing activities
2.4.1. Processing of Data Subject’s personal data in relation to the Customer Panel.
2.4.1.1. Personal data is processed for the following purposes:
- registration of the Data Subject in the Customer Panel,
- contacting the Data Subject to conduct interviews related to the Customer Panel,
- conducting the interviews,
- sending emails containing forms that allow the Data Subject to provide Communication,
- storing and processing the information obtained (especially Communication) for the purposes of the Customer Panel.
Commsignia does not conduct profiling of the Data Subject or make automated decisions based on their personal data.
2.4.1.2. Scope of the Data Subject’s processed personal data:
The data processing activity covers primarily the following categories of personal data.
- You will have to provide Commsignia with Your work email address to register to the Customer Panel.
- In connection with the Communication you provide during the interviews or otherwise related to the Customer Panel, we may also process further information regarding You [e.g.: full name, job title / role, work phone number, location (country, city), area(s) of expertise, years of experience in your current industry] and the Organization related to You [e.g. Organization name, Organization type, public or private sector, size of Organization (employee count / annual budget / revenue bracket)].
Please note that participation in the Customer Panel and providing us with any information is voluntary, but taking part in the Customer Panel requires the processing of personal data listed in point a. of this Section 2.4.1.2.
A more detailed list of personal data processed by Commsignia is attached hereto as ANNEX 1.
Certain persona data may already be available to Commsignia with regards to its previous relationship with You or the Organization, which – upon Your consent to the data processing detailed in this Section 2.4.1. can also be processed for this this purpose.
2.4.1.3. Legal basis of data processing
The legal basis of data processing is the Data Subject’s express consent [given pursuant to point a) of Article 6(1) of the GDPR].
2.4.1.4. Duration of data processing
We process Your personal data for this purpose (set forth in Section 2.4.1.1. above) until You withdraw the consent given by You regarding the processing of Your personal data, or 5 years have passed since the last time You have communicated with Commsignia (whichever is earlier).
Notwithstanding the above, Commsignia shall immediately delete Your personal data if You specifically request the deletion thereof and there is no valid legal ground for data processing.
2.5. Data processor and joint data controller
In order to fulfil its purposes as a data controller Commsignia cooperates with the data processors listed below. Commsignia reserves the right to change the data processors at any time.
Name of the data processor (including sub processors), or other data controllers | Data processing activity |
Commsignia, Inc. Company name: Commsignia, Inc.Address: 5201 Great America Parkway, Suite 320, Santa Clara, CA 95054, United States of America Website: www.commsignia.comContact: [email protected] mail: 5201 Great America Parkway, Suite 320, Santa Clara, CA 95054, United States of America | To the extent the data processing is related to the North American market, Commsignia, Inc. may be involved in the conducting of the interviews and the processing of the content of the Communication.Commsignia, Inc. is a data processor of Commsignia. |
Google Cloud EMEA Limited Company name: Google Cloud EMEA LimitedAddress: 70 Sir John Rogerson’s Quay, Dublin 2, Ireland Website: https://workspace.google.com/Contact: https://support.google.com/policies/contact/general_privacy_formBy mail: 70 Sir John Rogerson’s Quay, Dublin 2, Ireland | Data Subjects can register to the Customer Panel by providing Commsignia with the necessary information using Google Form, personal data is stored in a Google Drive folder, and interviews are generally conducted using the Google Meet service. As a result of the entirety of these activities, the data processor may access the full scope of the processed data on a need-to-know basis.Google Cloud EMEA Limited is a data processor if Commsignia. More information regarding privacy and regulatory compliance:https://cloud.google.com/privacy/gdpr |
Calendly LLC Company name: Calendly LLCAddress: 15 East Main Street, Suite A1B, Buford, GA 30518, United States Website: https://calendly.com/Contact: https://calendly.com/contact-us | The Calendly platform is used to schedule and book appointments with the Data Subjects. The platform works with calendars and customizes schedules based on availability preferences and time zone detection.Calendly LLC is a data processor of Commsignia. |
LinkedIn Corp Company name: LinkedIn CorpAddress: 1000 West Maude, Sunnyvale, California, 94085 Website: https://www.linkedin.com/Contact: https://www.linkedin.com/help/linkedin | Commsignia may engage the Data Subjects using the LinkedIn social media site and platform, using the so called InMail service. Commsignia will at all times comply with the relevant LinkedIn terms and conditions and other (e.g. privacy related) documentation. In this case, depending on the type of service used, LinkedIn Corp and Commsignia may be independent or joint data controllers.More information regarding privacy and regulatory compliance:https://privacy.linkedin.com/ |
2.6. Data security
Commsignia observes all applicable regulations regarding the security of personal data, therefore both Commsignia and its authorized data processors implement appropriate technical and organizational measures to protect personal data, and establish adequate procedural rules to enforce the provisions of the GDPR and all relevant local laws concerning confidentiality and the security of data processing.
2.7. Measures to ensure data security
2.7.1. Data Controller is obliged to ensure data security, it must take technical and organizational measures and establish procedural rules which ensure that the recorded, stored and processed data are protected, and which prevent their destruction, unauthorized use or unauthorized alteration. Data Controller also draws the attention of third parties – which the Data Subject’s data have been transferred to – to the fact that they have to comply with the data security requirements.
2.7.2. Data Controller shall ensure that the processed data cannot be accessed, disclosed, transmitted, modified or deleted by unauthorized persons. Data Controller shall make its best efforts to ensure that the data cannot be damaged or destroyed. The above obligation is also prescribed by Data Controller for the employees participating in its data processing activities and for the data processors acting on its behalf.
2.7.3. The Data Controller stores personal data in its own systems and the systems of the data processors in the course of the processing of the data, and the employees of the Data Controller access and download the data on a case-by-case basis, if data processing is needed.
2.7.4. In order to prevent unauthorized access to the data, Data Controller ensures the protection of personal data and prevents unauthorized access to them on its tools as follows: the access to the server and to the computers is protected by passwords and a firewall and antivirus software is applied.
2.8 Communication of a personal data breach to the Data Subject
2.8.1. In the following, the regulation of some general issues shall be presented. Thus, the procedure used to ensure the security of the data, the action to be taken in the event of a personal data breach, as well as the rights of the Data Subject and the means of redress.
2.8.2. Personal data breach: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored or otherwise processed.
2.8.3. If the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, Data Controller shall communicate the personal data breach to the Data Subject without undue delay in clear and plain language.
2.8.4. The communication to the Data Subject shall not be required if any of the following conditions are met:
- Data Controller has implemented appropriate technical and organizational protection measures, and those measures were applied to the personal data affected by the personal data breach, in particular those that render the personal data unintelligible to any person who is not authorized to access it, such as encryption;
- Data Controller has taken subsequent measures which ensure that the high risk to the rights and freedoms of the Data Subject is no longer likely to materialize;
- it would involve disproportionate effort. In such a case, there shall instead be a public communication or similar measure whereby the Data Subjects are informed in an equally effective manner.
2.9. Rights of the Data Subjects
In addition to the rights defined above, the Data Subjects may exercise the following rights in relation to the data processing set forth in the present Policy:
2.9.1. Right to get information and to have access to personal data being processed:
The Data Subject has the right to obtain confirmation from Data Controller as to whether or not personal data concerning him or her are being processed, and, if that is the case, to have access to the personal data and the following information:
- the purposes of the data processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
- if possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the Data Subject’s right to request the personal data’s rectification from Data Controller, erasure or the restriction of their processing if these personal data are related to the Data Subject or the Data Subject’s right to object to such data processing;
- the right to lodge a complaint with a supervisory authority;
- if the personal data are not collected from the Data Subject, any available information as to their source;
- the existence of automated decision-making, including profiling, and at least in these cases meaningful information about the logic involved, as well as the significance and the envisaged consequences of such data processing for the Data Subject.
If personal data are transferred to a third country or to an international organization, the Data Subject has the right to be informed of the appropriate safeguards relating to the data transfer.
Data Controller shall provide the Data Subject with a copy of his or her personal data undergoing the data processing. For any further copies requested by the Data Subject, Data Controller may charge a reasonable fee based on administrative costs. If the Data Subject submits the request by electronic means, the information shall be provided in a commonly used electronic form, unless otherwise requested by the Data Subject.
The right to obtain a copy referred to in the previous paragraph shall not adversely affect the rights and freedoms of others.
The rights mentioned above can be exercised through the Data Controller’s contact details indicated above.
2.9.2. Right to rectification:
Based on the Data Subject’s request, Data Controller shall without undue delay rectify any inaccurate personal data related to the Data Subject. Taking into account the purposes of the data processing, the Data Subject has the right to have his or her incomplete personal data completed, including by providing a supplementary statement.
2.9.3. Right to erasure („Right to be forgotten”):
The Data Subject has the right to obtain the erasure of personal data concerning him or her from the Data Controller without undue delay if any of the following reasons exists:
- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- the Data Subject withdraws his or her consent on which the data processing is based, and if there is no other legal ground for the data processing;
- the Data Subject objects to the data processing and there are no overriding legitimate grounds for the data processing, or if the personal data are processed for direct marketing purposes;
- the personal data have been unlawfully processed;
- the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which Data Controller is subject;
- the personal data have been collected in relation to the offer of information society services.
Erasure of data cannot be initiated if data processing is necessary:
- for exercising the right of freedom of expression and information;
- for compliance with a legal obligation which requires processing by Union or Member State law to which Data Controller is subject or for the performance of a task carried out in the public interest;
- for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, for medical diagnosis, for the provision of health or social care or treatment or for the management of health or social care systems and services, on the basis of Union or Member State law or pursuant to contract with a health professional and if those data are processed by or under the responsibility of a professional subject to the obligation of professional secrecy under Union or Member State law or rules established by national competent bodies or by another person also subject to an obligation of secrecy under Union or Member State law or rules established by national competent bodies;
- for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of Union or Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the Data Subject, in particular as for professional secrecy;
- for reasons of public interest in the area of public health and if those data are processed by or under the responsibility of a professional subject to the obligation of professional secrecy under Union or Member State law or rules established by national competent bodies or by another person also subject to an obligation of secrecy under Union or Member State law or rules established by national competent bodies;
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, if the right of erasure would make such data processing impossible or the right of erasure would such data processing seriously jeopardize[3]; or
- for the establishment, exercise or defense of legal claims.
2.9.4. Right to restrict data processing:
The Data Subject has the right to obtain the restriction of data processing from Data Controller if one of the following conditions applies:
- the accuracy of the personal data is contested by the Data Subject, in this case restriction is related to a period enabling Data Controller to verify the accuracy of the personal data;
- the data processing is unlawful and the Data Subject opposes the erasure of the personal data and requests the restriction of their use instead;
- Data Controller no longer needs the personal data for the purposes of the data processing, but they are required by the Data Subject for the establishment, exercise or defense of legal claims;
- the Data Subject has objected to data processing based on public interest or legitimate interest, in this case restriction is related to a period in the course of which it can be verified whether the legitimate grounds of Data Controller override those of the Data Subject.
If processing has been restricted according to the above, such personal data shall, with the exception of storage, only be processed with the Data Subject’s consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
A Data Subject who has obtained restriction of data processing according to the above shall be informed by Data Controller before the restriction of data processing is lifted.
2.9.5. Right to data portability:
The Data Subject has the right to receive the personal data concerning him or her, which he or she has provided to Data Controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another data controller without hindrance from Data Controller to which the personal data have been provided, if the data processing is based on consent or on a contract and the processing is carried out by automated means.
In exercising his or her right to data portability defined above, the Data Subject has the right to have the personal data transmitted directly from one controller to another, if it is technically feasible.
The exercise of the right referred to data portability shall be without prejudice to the right to erasure („right to be forgotten”). That right shall not apply to data processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Data Controller.
The right to data portability shall not adversely affect the rights and freedoms of others.
2.9.6. Right to object:
The Data Subject has 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, if the legal ground of data processing is to perform a task carried out in the public interest or in the exercise of official authority vested in Data Controller, or the data processing is necessary for the purposes of the legitimate interests pursued by Data Controller or by a third party, including profiling based on these provisions. Data Controller shall no longer process the personal data unless it demonstrates compelling legitimate grounds for the data processing which override the interests, rights and freedoms of the Data Subject or for the establishment, exercise or defense of legal claims.
If personal data are processed for direct marketing purposes, the Data Subject has the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing. If the Data Subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
If personal data are processed for scientific or historical research purposes or statistical purposes, the Data Subject, on grounds relating to his or her particular situation, has the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
2.9.7. Right to withdraw the given consent:
If the data processing of Data Controller is based on the Data Subject’s consent, the Data Subject has the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of data processing based on consent before its withdrawal.
2.9.8. Procedure in the event of a request submitted by the Data Subject concerning the exercise of the above rights:
Data Controller shall provide information to the Data Subject on action taken on the Data Subject’s request related to the rights defined in the present Policy without undue delay and in any event within one month of receipt of the request. This period may be extended by two further months where necessary, taking into account the complexity and number of the requests.
Data Controller shall inform the Data Subject of any such extension within one month of receipt of the request, with the reasons for the delay. If the Data Subject makes the request by electronic means, the information shall be provided by electronic means where possible, unless otherwise requested by the Data Subject.
If Data Controller does not act on Data Subject’s request, Data 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 lodging a complaint with a supervisory authority and seeking a judicial remedy.
Any information and communication requested by Data Subject shall be provided by Data Controller free of charge, unless requests from the Data Subject are manifestly unfounded or excessive, in particular because of their repetitive character. In this case, Data Controller may either charge a reasonable fee taking into account the administrative costs of providing the information or communication requested or refuse to act on the request.
Data Controller shall communicate any rectification or erasure of personal data or restriction of data processing carried out by Data Controller to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. Data Controller shall inform the Data Subject about those recipients if the Data Subject requests it.
2.11. Personal data related to children and third parties
Persons under the age of 16 may not provide their personal data unless consent is given by the holder of parental responsibility. By making the personal data available to Data Controller, the parent, as a Data Subject, declares and guarantees that he or she will act in accordance with the above, and his or her capacity to act is not limited in connection with the provision of these information.
If You are not legally entitled to make any personal data available on Your own, You must obtain the consent of the third parties concerned (e.g. legal representative, guardian, other person acting as representative of the consumer) or provide another legal ground for making the data available. In this context, You must consider whether the consent of a third party is required in connection with the provision of the personal data in question. It can happen that Data Controller does not get into personal contact with You, so You are obliged to ensure compliance with the present section and Data Controller is not liable in this aspect. Regardless of this, Data Controller is always entitled to check whether the appropriate legal ground for the processing of any personal data is available. For example, if You are acting on behalf of a third party, such as a consumer, we are entitled to request Your authorization and / or the Data Subject’s appropriate consent to the data processing in question.
Data Controller makes its best effort to delete any personal data which has been made available to Data Controller without authorization. Data Controller ensures that if it becomes aware of the non-authorized availability of any personal data, this personal data shall not be transferred to another person or used by Data Controller. Please, let Data Controller know immediately by any of the contacts indicated in the Contact Details section if You become aware of the fact that a third party has unauthorizedly provided any personal data to Data Controller.
3. Contact Details
Any questions or requests related to our data processing and to your personal data stored in the system should be sent to the [email protected] e-mail address, or in writing to the address of 4-20 Irinyi József utca, Budapest 1117, Hungary. Please note that – in your own interest – concerning the data processing related to your personal data we are only able to provide information or take any action if you have credibly proven your identity.
4. Judicial remedy
You can contact Commsignia with any questions or remarks related to data processing by any of the contact details indicated in this Policy.
You can initiate the procedure of the Hungarian National Authority for Data Protection and Freedom of Information [postal address: 1530 Budapest, Pf.: 5., phone: +36 (1) 391-1400, email: [email protected], website: www.naih.hu], referring that there is an infringement or imminent threat of an infringement of rights related to the processing of a personal data.
If Your rights have been breached, You may also initiate a procedure against Data Controller at the competent court. The court acts immediately in this case (these actions have priority), and Data Controller is obliged to prove that the data processing complies with the provisions of the law. The trial generally falls into the jurisdiction of the Regional Courts of Hungary. At the discretion of the Data Subject, the action may be brought before the regional courts having jurisdiction based on the place of residence or the place of stay of the Data Subject.
ANNEX 1
List of processed personal data for the purpose of the Customer Panel
Commsignia will process the following information to register and contact the Data Subjects, send questionnaires and surveys:
- Work Email Address
During (or in connection with) the participation of the Data Subject in interviews, surveys and similar activities related to the Customer Panel, the Data Subject may provide Communications to Commsignia which may contain personal data. Such information may include one or more of the following categories (without limitation):
- Full Name
- Job Title / Role
- Organization Name
- Work phone number
- Location (country, city)
- Area(s) of expertise
- Years of experience (in your current industry)
- Past participation history (in research)
- Information regarding the Organization the data subject is connected to, e.g.:
-
- Organization type
- Sector
- Size of Organization
- Industry segment
- Primary business function
- Geographic jurisdiction service area
- Technology adoption level
- Existing relationship with Commsignia
- Commsignia product usage
- Current satisfaction (for users of Commsignia products only)
- Competitor products used (if any)
WE ASK YOU TO ONLY SHARE COMMUNICATION WITH COMMSIGNIA IF AND TO THE EXTENT YOU HAVE THE RIGHT TO DO SO.