Description of Privacy Policy

The processing of personal data, such as the name, address, e-mail address or telephone
number shall always be in line with the General Data Protection Regulation (GDPR), and in
accordance with the country-specific data protection regulations applicable to Mediflexible.
This privacy policy specifies the type, scope and purpose of the collection, processing and use
of the personal data you choose to share when you visit and/or can be transferred via
Mediflexible’s website https://mediflexible.com. Please note that you are not required to
provide personal information in order to use our website.
Any natural person whose personal identifiable information is collected, registered or used by
Mediflexible, has the right to know how the information is stored, used and transferred and is
entitled to access and control the use of this information (according to the General Data
Protection Regulation, hereinafter “GDPR”). Personal identifiable information means any
information that may be directly or indirectly attributed to a natural person in life such as
name, e-mail address, telephone number or the like. More information about your right of
access, correction and deletion of personal data that we process, how to safeguard your rights,
and our contact information, please see below.
Personally responsible under the law is Mediflexible Bt. (hereinafter “Mediflexible”, “we” or
“us”).
Our supervisory authority is the Hungarian National Authority for Data Protection and
Freedom of Information (https://www.naih.hu/). If you believe we have processed your
personal information in violation of this privacy policy or applicable laws and regulations,
you are entitled to file a complaint with this authority.
This privacy policy does not apply to other websites. We therefore encourage you to read the
privacy policies that apply to other websites you visit.
By visiting our website, you consent to the treatment and procedures described in this policy.

Table of Contents

1. Who is responsible for the processing of you personal data?
2. Data we collect
3. Period for which the personal data will be stored
4. Existence of Automated Decision-making
5. Legal basis for the Data Processing
6. Your rights and choices
7. Protection and disclosure of your data
8. Data protection provisions about the application and use of social plugins

1. Who is responsible for the processing of your personal data?
Controller: Mediflexible Bt.
Address: H7629 Pécs, 4 Papkert str., Hungary

Company register number: 02-06-065122
Phone: +36 30 350 84 59
Email: office@mediflexible.com
Website: mediflexible.com
2. Data we collect
2.1 General Data and Information
The website of Mediflexible collects a series of general data and information when you visit
our website. This general data and information are stored in the server log files.
What information do we collect from you?
The information we collect may include the following:
 the browser types and versions used,
 the operating system used by the accessing system,
 the website from which an accessing system reaches our website (so-called referrers),
the sub-websites,
 the date and time of access to our website,
 an Internet protocol address (IP address),
 the Internet service provider of the accessing system, and
 any other similar data and information that may be used in the event of attacks on our
information technology systems.
Why do we collect your information and what do we use it for?
When using these general data and information, Mediflexible does not draw any conclusions
about you as a data subject. Rather, this information is needed to:
 deliver the content of our website correctly,
 optimize the content of our website as well as its advertisement,
 ensure the long-term viability of our information technology systems and website
technology, and
 provide law enforcement authorities with the information necessary for criminal
prosecution in case of a cyber-attack.
Therefore, Mediflexible analyses anonymously collected data and information statistically,
with the aim of increasing the data protection and data security of our enterprise and to ensure
an optimal level of protection for the personal data we process. The anonymous data of the
server log files are stored separately from all personal data provided by you.
2.2 Data you provide to us
Contacting us through our website

You have the possibility to send a message on Mediflexible’s website and when you do we
will ask for some personal information.
What information do we collect from you?
When you send a message we will ask for person information, such as your name, e-mail
address and phone number. In general, which personal data are transmitted to us is determined
by the respective input mask used for the registration. By registering on our website, the IP
address – assigned by the Internet service provider (ISP) and used by you as a data subject –
date, and time of the registration are also stored.
Why do we collect your information and what do we use it for?
The personal data entered by you when you send a message to us are collected and stored
exclusively for our internal use and for our own purposes. As controllers, we may request
transfer to one or more processors (e.g. a parcel service) that also uses personal data for an
internal purpose which is attributable to Mediflexible.
The storage of the IP address, date, and time of registration data takes place against the
background that this is the only way to prevent the misuse of our services, and, if necessary,
to make it possible to investigate committed offenses. Insofar, the storage of this data is
necessary to secure Mediflexible. This data is not passed on to third parties unless there is a
statutory obligation to pass on the data, or if the transfer serves the aim of criminal
prosecution.
Your voluntary indication of your personal data is intended to enable us at Mediflexible to
offer you contents or services that may only be offered due to the nature of the matter in
question. Persons whose personal data is saved in our database are free to change them any
time, or to have them completely deleted from our data stock.
2.3 Cookies
The website of Mediflexible uses cookies. Cookies are text files that are stored in a computer
system via an Internet browser. Many Internet sites and servers use cookies. Many cookies
contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a
character string through which Internet pages and servers can be assigned to the specific
Internet browser in which the cookie was stored. This allows visited Internet sites and servers
to differentiate the individual browser of the data subject from other Internet browsers that
contain other cookies. A specific Internet browser can be recognized and identified using the
unique cookie ID.
Through the use of cookies, Mediflexible can provide the users of this website with more
user-friendly services that would not be possible without the cookie setting.
By means of a cookie, the information and offers on our website can be optimized with the
user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The
purpose of this recognition is to make it easier for users to utilize our website. The website
user that uses cookies e.g. does not have to enter access data each time the website is

accessed, because this is taken over by the website, and the cookie is thus stored on the user’s
computer system.
You may, at any time, prevent the setting of cookies through our website by means of a
corresponding setting of the internet browser used, and may thus permanently deny the setting
of cookies. Furthermore, already set cookies may be deleted at any time via an internet
browser or other software programs. This is possible in all popular internet browsers. If you
deactivate the setting of cookies in the Internet browser used, not all functions of our website
may be entirely usable.
3. Period for which the personal data will be stored
We inform you that we will keep your personal information for the period necessary to fulfil
the purposes described in this privacy policy unless a longer retention period is legally
permitted or required.
The criteria used to determine the period of storage of personal data is the respective statutory
retention period. After expiration of that period, the corresponding data is routinely deleted, as
long as it is no longer necessary for the fulfilment of the contract or the initiation of a
contract.
4. The existence of Automated Decision-making
As a responsible company, we do not use automatic decision-making or profiling.
5. Legal Basis for the Data Processing
The processing of your data with respect to the purposes described above is allowed by GDPR
in accordance with the following legal bases: consent, contract, and “legitimate interests”.
 Where we process data based on consent, we will ask for your explicit consent – that
is, you have authorized, through an automated form and/or paper, your express
consent to the processing of your data for certain purposes. You may withdraw your
consent at any time, but that will not affect the lawfulness of the processing of your
personal data prior to such withdrawal.
 The legal basis for dealing with any contractual relationship is the legitimation by
execution of a contract signed with you. We will ask that you agree to the processing
of personal data that is necessary for entering into or performance of your contract
with us.
 In some cases, treatment will be necessary to comply with the corresponding legal
obligations. We will rely on legitimate interests as a basis for data processing where
the processing of your data is not overridden by your interests or fundamental rights
and freedoms. In this case, where we rely on legitimate interests, you have the right to
object.
6. Your Rights and Choices
6.1 Right of confirmation

You have the right to obtain a confirmation from Mediflexible as to whether or not we are
treating personal data that concerns you. Should you wish to avail yourself of this right of
confirmation, you are welcome, at any time, to contact any employee at Mediflexible.
6.2 Right of access
At any time you have the right to ask for information about your stored personal data and to
obtain a copy of this information. Furthermore, the European directives and regulations grant
you subject access to the following information:
 the purposes of the 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 organisations;
 where possible, the envisaged period for which the personal data will be stored, or, if
not possible, the criteria used to determine that period;
 the existence of the right to request from Mediflexible rectification or erasure of
personal data, or restriction of processing of personal data, or to object to such
processing;
 the existence of the right to lodge a complaint with a supervisory authority;
 where 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, referred to in Article
22(1) and (4) of the GDPR and, at least in those cases, meaningful information about
the logic involved, as well as the significance and envisaged consequences of such
processing for you.
Moreover, you have a right to obtain information as to whether personal data are transferred
to a third country or to an international organisation. Where this is the case, you have the right
to be informed of the appropriate safeguards relating to the transfer.
If you wish to avail himself of this right of access, you may, at any time, contact any
employee at Mediflexible.
6.3 Right to rectification
You can ask us to change, update or fix your data if it’s inaccurate.  Taking into account the
purposes of the data processing, you have the right to have incomplete personal data
completed, including by means of providing a supplementary statement.
If you wish to exercise this right to rectification, you may, at any time, contact any employee
of Mediflexible.
6.4 Right to erasure and right to be forgotten
You can ask us to erase or delete all or some of your personal data, e.g. if the data processing
is no longer necessary. More specifically, Mediflexible has the obligation to without undue
delay erase your personal data where one of the following grounds applies, and as long as the
processing is not necessary:

 The personal data are no longer necessary in relation to the purposes for which they
were collected or otherwise processed.
 You as a data subject withdraw consent to which the processing is based according to
point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and
where there is no other legal ground for the processing.
 You object to the processing pursuant to Article 21(1) of the GDPR and there are no
overriding legitimate grounds for the processing, or you object to the processing
pursuant to Article 21(2) of the GDPR.
 The personal data have been unlawfully processed.
The personal data must be erased for compliance with a legal obligation in Union or
Member State law to which the Mediflexible is subject.
 The personal data have been collected in relation to the offer of information society
services referred to in Article 8(1) of the GDPR.
 If one of the aforementioned reasons applies and you wish to request the erasure of
personal data stored by the Mediflexible, you, at any time, contact any of our
employees. An employee of Mediflexible shall promptly ensure that the erasure
request is complied with immediately.
Where Mediflexible has made personal data public and is obliged pursuant to Article 17(1) to
erase the personal data, we, taking account of available technology and the cost of
implementation, shall take reasonable steps, including technical measures, to inform other
responsible controllers processing the personal data that you have requested erasure by such
controllers of any links to, or copy or replication of, those personal data, as far as processing
is not required. An employee of Mediflexible will arrange the necessary measures in
individual cases.
6.5 Right of restriction of processing
You have the right to ask us to restrict the processing of your personal data where one of the
following applies:
 Your personal data is inaccurate, for a period enabling the us to verify the accuracy of
your personal data.
 The processing is unlawful and you are opposed the erasure of the personal data and
instead request the restriction of their use.
 We no longer need the personal data for the purposes of the processing, but they are
required by you for the establishment, exercise or defence of legal claims.
 You have objected to processing pursuant to Article 21(1) of the GDPR pending the
verification whether the legitimate grounds of Mediflexible override those of you as
data subject.
 If one of the aforementioned conditions is met, and you wish to request the restriction
of the processing of personal data stored by Mediflexible, you may at any time contact
any of our employees. The employees of Mediflexible will arrange the restriction of
the processing.
6.6 Right to data portability
You have the right to receive your personal data which was provided to Mediflexible in a
structured, commonly used and machine-readable format. You have the right to transmit those
data to another controller without the hindrance from us, as long as the processing is based on

consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the
GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing
is carried out by automated means, as long as the processing is not necessary for the
performance of a task carried out in the public interest or in the exercise of official authority
vested in the controller.
Furthermore, in exercising your right to data portability pursuant to Article 20(1) of the
GDPR, you shall have the right to have personal data transmitted directly from one controller
(Mediflexible) to another, where technically feasible and when doing so does not adversely
affect the rights and freedoms of others.
In order to assert the right to data portability, you may at any time contact any employee of
Mediflexible.
6.7 Right to object
You have the right, at any time, to object to the processing of your personal data, which is
based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on
these provisions.
Mediflexible shall no longer process the personal data in the event of the objection, unless we
can demonstrate compelling legitimate grounds for the processing which override your
interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.
If Mediflexible processes personal data for direct marketing purposes, you have the right to
object at any time to processing of your personal data for such marketing. This applies to
profiling to the extent that it is related to such direct marketing. If you object to Mediflexible
to the processing for direct marketing purposes, Mediflexible will no longer process the
personal data for these purposes. In addition, you have the right to object to processing of
your personal data by Mediflexible for scientific or historical research purposes, or for
statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary
for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, you may contact any employee of Mediflexible. In
addition, you are free in the context of the use of information society services, and
notwithstanding Directive 2002/58/EC, to use your right to object by automated means using
technical specifications.
6.8 Automated individual decision-making, including profiling
Similarly of point 4 none of your data will be used for automated individual decision-making,
profiling at Mediflexible.
6.9 Right to withdraw data protection consent
You have the right to withdraw your consent to processing of your personal data at any time.
If you wish to exercise this right, you may, at any time, contact any employee of
Mediflexible.
6.10 Right to appeal

You have the right to file a claim with the Control Authority (Hungarian Data Protection
Agency) for any failure to comply with the regulations on data protection, which information
can be found in this link: https://www.naih.hu/data-protection/rights-of-data-subjects
7. Protection and Disclosure of Your Data
7.1 Protection of Data
With the aim of safeguarding the security of your personal data, Mediflexible has
implemented numerous technical and organizational measures to guarantee the security of the
personal data provided and protect it from its alteration, loss, misuse, disclosure, and
treatments or access not authorized, as required by the regulations on the protection of
personal data. However, Internet-based data transmissions may in principle have security
gaps, so absolute protection may not be guaranteed.
7.2 Data Protection for Applications and the Application Procedures
Mediflexible shall collect and process the personal data of applicants for the purpose of the
processing of the application procedure. The processing may also be carried out
electronically. This is the case, in particular, if an applicant submits corresponding application
documents by e-mail or by means of a web form on Mediflexible’s website. If Mediflexible
concludes an employment contract with an applicant, the submitted data will be stored for the
purpose of processing the employment relationship in compliance with legal requirements. If
no employment contract is concluded with the applicant by Mediflexible, the application
documents shall be automatically erased two months after notification of the refusal decision,
provided that no other legitimate interests of Mediflexible are opposed to the erasure. Other
legitimate interest in this relation is, e.g. a burden of proof in a procedure under the General
Equal Treatment Act (AGG).
7.3 Disclosure to third parties
We may share or send your CV and related information to prospective employers and our
clients.
Such employers and clients will usually be located inside the European Economic Area (EEA)
but may be outside of the EEA.  Personal data shall not be transferred to a country or territory
outside the EEA unless that country or territory ensures an adequate level of protection or the
appropriate safeguards are in place for your rights and freedoms. Before such a transfer takes
place outside of the EEA, we will provide you with further information concerning this.
We will respect and protect your privacy as set out in this privacy policy. We will share your
personal information with third parties only in the ways that are described in this privacy
policy, and won’t sell individual information. You agree that Mediflexible may share your
personal information with third parties with your consent (express, constructive of implied),
or as required by law such as to comply with subpoena, bankruptcy proceedings, or similar
legal process when we believe in good faith that disclosure is necessary to protect
Mediflexible, the public, investigate fraud, or respond to a government request. You agree
that Mediflexible may share your personal information with organizations or persons that help
us fulfil our obligations or provide our services to you. Mediflexible will make efforts to

ensure these parties have appropriate measures in place to protect your information and meet
our obligations under the applicable privacy rules.
We reserve the right to disclose any information that we obtain through our website to
appropriate governmental or regulatory authorities if required by law or any governmental
agency.
8. Data Protection Provisions about the Application and Use of Social Plugins
8.1 Google Analytics (with anonymization function)
On this website, Mediflexible has integrated the component of Google Analytics (with the
anonymizer function). Google Analytics is a web analytics service. Web analytics is the
collection, gathering, and analysis of data about the behaviour of visitors to websites. A web
analysis service collects, inter alia, data about the website from which a person has come (the
so-called referrer), which subpages were visited, or how often and for what duration a
subpage was viewed. Web analytics are mainly used for the optimization of a website and in
order to carry out a cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy,
Mountain View, CA 94043-1351, United States.
For the web analytics through Google Analytics Mediflexible uses the application “_gat.
_anonymizeIp”. By means of this application your IP address of your Internet connection is
abridged by Google and anonymised when accessing our websites from a Member State of
the European Union or another Contracting State to the Agreement on the European
Economic Area.
The purpose of the Google Analytics component is to analyse the traffic on our website.
Google uses the collected data and information, inter alia, to evaluate the use of our website
and to provide online reports, which show the activities on our websites, and to provide other
services concerning the use of our Internet site for us. Google Analytics places a cookie on
your information technology system. The definition of cookies is explained above (section
1.3). With the setting of the cookie, Google is enabled to analyse the use of our website. With
each call-up to one of the individual pages of this Internet site, which is operated by
Mediflexible and into which a Google Analytics component was integrated, the Internet
browser on your information technology system will automatically submit data through the
Google Analytics component for the purpose of online advertising and the settlement of
commissions to Google. During the course of this technical procedure, the Google gains
knowledge of personal information, such as your IP address, which serves Google, inter alia,
to understand the origin of visitors and clicks, and subsequently create commission
settlements.
The cookie is used to store personal information, such as the access time, the location from
which the access was made, and the frequency of your visits of our website. With each visit to
our Internet site, such personal data, including your IP address of the Internet access, will be
transmitted to Google in the United States of America. These personal data are stored by
Google in the United States of America. Google may pass these personal data collected
through the technical procedure to third parties.

You may, as stated above, prevent the setting of cookies through our website at any time by
means of a corresponding adjustment of the web browser used and thus permanently deny the
setting of cookies. Such an adjustment to the Internet browser used would also prevent
Google Analytics from setting a cookie on the information technology system of the data
subject. In addition, cookies already in use by Google Analytics may be deleted at any time
via a web browser or other software programs.
In addition, you have the possibility of objecting to a collection of data that are generated by
Google Analytics, which is related to the use of this website, as well as the processing of this
data by Google and the chance to preclude any such. For this purpose, you must download a
browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This
browser add-on tells Google Analytics through a JavaScript that any data and information
about the visits of Internet pages may not be transmitted to Google Analytics. The installation
of the browser add-ons is considered an objection by Google. If your information technology
system is later deleted, formatted, or newly installed, then you must reinstall the browser add-
ons to disable Google Analytics. If you uninstalled, or disabled, the browser add-on, it is
possible to execute the re-installation or reactivation of the browser add-ons.
Further information and the applicable data protection provisions of Google may be retrieved
under https://www.google.com/intl/en/policies/privacy/ and under
http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under
the following Link https://www.google.com/analytics/.
8.2 Google Remarketing
On this website, the Mediflexible has also integrated Google Remarketing services. Google
Remarketing is a feature of Google AdWords, which allows an enterprise to display
advertising to Internet users who have previously visited the enterprise’s Internet site. The
integration of Google Remarketing therefore allows Mediflexible to create user-based
advertising and thus show relevant advertisements to interested Internet users.
The operating company of the Google Remarketing services is the Google Inc., 1600
Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
The purpose of Google Remarketing is the insertion of interest-relevant advertising. Google
Remarketing allows us to display ads on the Google network or on other websites which are
based on individual needs and matched to the interests of Internet users. Google Remarketing
sets a cookie on your information technology system. The definition of cookies is explained
above (section 1.3). With the setting of the cookie, Google enables a recognition of the visitor
of our website if he calls up consecutive web pages, which are also a member of the Google
advertising network. With each call-up to an Internet site on which the service has been
integrated by Google Remarketing, your web browser identifies automatically with Google.
During the course of this technical procedure, Google receives personal information, such as
the IP address or the surfing behaviour of the user, which Google uses, inter alia, for the
insertion of interest relevant advertising.
The cookie is used to store personal information, e.g. the Internet pages that you visited. Each
time you visit our Internet pages, personal data, including the IP address of the Internet access
used, is transmitted to Google in the United States of America. These personal data are stored

by Google in the United States of America. Google may pass these personal data collected
through the technical procedure to third parties.
You may, as stated before, prevent the setting of cookies through our website at any time by
means of a corresponding adjustment of the web browser used and thus permanently deny the
setting of cookies. Such an adjustment to the Internet browser used would also prevent
Google from setting a cookie on the information technology system of the data subject. In
addition, cookies already in use by Google may be deleted at any time via a web browser or
other software programs.
In addition, you have the possibility of objecting to the interest-based advertising by Google.
For this purpose, you must visit the link to www.google.com/settings/ads and make the
desired settings on your Internet browser.
Further information and the actual data protection provisions of Google may be retrieved
under https://www.google.com/intl/en/policies/privacy/.
8.4 Google AdWords
On this website, Mediflexible has integrated Google AdWords. Google AdWords is a service
for Internet advertising that allows the advertiser to place ads in Google search engine results
and the Google advertising network. Google AdWords allows an advertiser to pre-define
specific keywords with the help of which an ad on Google’s search results only then
displayed, when the user utilizes the search engine to retrieve a keyword-relevant search
result. In the Google Advertising Network, the ads are distributed on relevant web pages
using an automatic algorithm, taking into account the previously defined keywords.
The operating company of Google AdWords is Google Inc., 1600 Amphitheatre Pkwy,
Mountain View, CA 94043-1351, UNITED STATES.
The purpose of Google AdWords is the promotion of our website by the inclusion of relevant
advertising on the websites of third parties and in the search engine results of the search
engine Google and an insertion of third-party advertising on our website.
If you reach our website via a Google ad, a conversion cookie is filed on the information
technology system of the data subject through Google. The definition of cookies is explained
above (section 1.3). A conversion cookie loses its validity after 30 days and is not used to
identify you. If the cookie has not expired, the conversion cookie is used to check whether
certain sub-pages were visited from our website. Through the conversion cookie, both Google
and Mediflexible can understand whether a person who reached an AdWords ad on our
website generated a conversion.
The data and information collected through the use of the conversion cookie is used by
Google to create visit statistics for our website. These visit statistics are used in order to
determine the total number of users who have been served through AdWords ads to ascertain
the success or failure of each AdWords ad and to optimize our AdWords ads in the future.
Neither our company nor other Google AdWords advertisers receive information from Google
that could identify you.

The conversion cookie stores personal information, e.g. the Internet pages that you visited.
Each time you visit our Internet pages, personal data, including your IP address of your
Internet access, is transmitted to Google in the United States of America. These personal data
are stored by Google in the United States of America. Google may pass these personal data
collected through the technical procedure to third parties.
You may, at any time, prevent the setting of cookies by our website, as stated above, by
means of a corresponding setting of the Internet browser used and thus permanently deny the
setting of cookies. Such a setting of the Internet browser used would also prevent Google
from placing a conversion cookie on your information technology system. In addition, a
cookie set by Google AdWords may be deleted at any time via the Internet browser or other
software programs.
You have a possibility of objecting to the interest based advertisement of Google. Therefore,
you must access from each of the browsers in use the link www.google.com/settings/ads and
set the desired settings.
Further information and the applicable data protection provisions of Google may be retrieved
under https://www.google.com/intl/en/policies/privacy/.

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