kogni tiv tesz tek .hu
(Last updated: march 01, 2024)

Privacy policy and legal disclaimer

Data protection guidelines for costumers, suppliers, business partners, website and application visitors, employees, and job applicants.

  1. Overview

Information regarding the PREDEMPLATFORM.COM (International) and the KOGNITIVTESZTEK.HU (Hungarian website and the PreDEM – Neurological Preventive Screening and Therapeutic Platform application and usage.

Welcome to the https://predemplatform.com and the https://www.kognitivtesztek.hu  websites (hereinafter referred to collectively with its subdomains, content, trademarks, and services as the "website")!

Who we are

The PreDEM - Neurological Preventive Screening and Therapeutic Platform Web-based application (Accessible at: https://app.predemplatform.com or https://app.kognitivtesztek.hu ; hereinafter referred to as 'PreDEM' and/or 'application'), along with the websites and its content, are owned and managed by NETIS Ltd., as the product owner, holding ownership and other rights, including operation and maintenance.

We prioritize the security and protection of personal data and privacy. Therefore, Netis Ltd. handles personal data in compliance with applicable data protection and security laws in accordance with the European Parliament and Council Regulation (EU) 2016/679 (GDPR) and the provisions of Act CXII of 2011 on informational self-determination and freedom of information (hereinafter: Infotv.).


Introduction of data controller

Name of Data Controller: Netis Ltd.
Company Registration Number of Data Controller: 01-10-046495
VAT Number of Data Controller: 14945375-2-41
Community tax number (or EU tax number): HU14945375
European Unique Identifier: HUOCCSZ.01-10-046495
Registered Office of Data Controller: 45 Váci Street, Budapest, 1134
Email Address of Data Controller:predem@netis.hu
Representative of Data Controller: László Varga, CEO
Data Protection Officer: Zoltán Máthé, DPO

  1. Definitions and Meanings

Data Processing

Any operation or set of operations performed on personal data or datasets, whether by automated means or not, including collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.

Data Controller

Any natural or legal person, public authority, agency, or any other body that determines the purposes and means of the processing of personal data, either alone or jointly with others. Where the purposes and means of data processing are determined by Union or Member State law, the specific criteria for determining the Data Controller or the appointment of a Data Controller may also be provided by Union or Member State law.

Data Processor

Any natural or legal person, public authority, agency, or other body that processes personal data on behalf of the Data Controller.

Data Subject

The individual who provides personal data on the PREDEMPLATFORM.COM or the KOGNITIVTESZTEK.HU websites and the PreDEM - Neurological Preventive Screening and Therapeutic Platform Web-based application (APP.PREDEMPLATFORM.COM or APP.KOGNITIVTESZTEK.HU).

Third Party

Any natural or legal person, public authority, agency, or other body that is not the Data Subject, Data Controller, Data Processor, or individuals authorized by the Data Controller or Data Processor under their direct authority to process personal data.

Personal Data

Any information relating to an identified or identifiable natural person; an identifiable person is someone who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, online identifier, or by factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.

Data Breach

The security breach resulting in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to personal data transmitted, stored, or otherwise processed.

Key Legislation on Data Processing and Their Abbreviations

The data processing activities of Netis Ltd. are based on voluntary consent and legal authorization. Its data processing principles comply with the applicable data protection laws, including, in particular, the following:

  • Act CXII of 2011 on the Right of Informational Self-Determination and Freedom of Information (Infotv.);
  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons concerning the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, GDPR);
  • Act V of 2013 - the Civil Code (Ptk.);
  • Act C of 2000 on Accounting (Számv. tv.);
  • Act LIII of 2017 on the Prevention and Combating of Money Laundering and Terrorist Financing (Pmt.);
  • Act CCXXXVII of 2013 on Credit Institutions and Financial Enterprises (Hpt.).
  1. The Subject of the Privacy Policy

This Privacy Policy pertains to all personal information collected about you when you engage with us through the website, our application, or other forms of communication.

These interactions occur when you:

  • Visit the website.
  • Use our web application.
  • Use or purchase any of our products or services.
  • Subscribe to our newsletters, participate in our online communities, contests, or other competitions.
  • Contact our customer service.
  • Request information according to your interests.
  • Offer products or services to us.
  • Engage with us as an employee or job applicant.
  1. Information we may collect about you

Depending on your activities, we may process various types of personal information about you, such as your status as a consumer, buyer, or business partner, as well as information about how you interact with us.

If you choose not to provide us with your personal data, please note that we may not be able to guarantee the provision of the requested product, service, solution, or respond to your inquiries.

The information we may request from you includes:

Contact details (name, address, email, phone, etc.).

Login details: username, displayed name, passwords.

General business information such as address, contact person, billing, and other payment information, shipping information.

Opinions, feedback, comments.

Audiovisual information, such as images or videos.

Recruitment data: resumes, application forms, recommendation letters, languages, qualifications, certificates, training, and other professional permits, etc.

Talent development information, such as employment and educational backgrounds, other details in resumes; qualifications and experience, performance and development programs, reviews, and career development plans, etc.

Health-related information, health purposes, health measurements, laboratory data, allergies, activity levels, favorite foods, diet, exercise, sleep, and other voluntarily provided information.

Information on the voluntary health tests provided through the application, including answers related to age, date of birth, gender, ethnic background, dietary and health history, family health history, exercise, and body measurements.

Information you provide to us through our application, including but not limited to feedback on recommended foods, menus, recipes, packaged foods, and restaurant meals, as well as responses related to food purchases and/or reservations at restaurants.

Automatically collected information about you may include:

Traffic information, such as the time and/or duration of your interaction with us.

IP addresses, MAC addresses of devices used to connect with us.

Location data (i.e., actual location determined based on the aforementioned information).

Information related to your areas of interest (products or services visited on the website).

Cookie preferences.

  1. Why do we collect personal data?

Depending on the purpose of your visit to the website or application, we may collect personal information for various reasons:

Services: Your data may be required to provide the requested products or services and fulfill other purposes requested from us, as well as for the enhancement and customization of our services.

Support: Providing customer service, responding to inquiries or requests, maintaining account security, and other website or application maintenance reasons.

Marketing: Facilitating direct marketing, promotions, newsletters, and website analytics.

Legal: Fulfillment of contracts, compliance review, and meeting legal obligations.

  1. Why do we need your data?

According to Article 6(1) of the GDPR, your data can only be processed if there's a lawful basis. The legal basis for data processing arises when one or more of the following conditions are met:

  • You have consented to the processing, regardless of whether it is required by applicable data protection laws.
  • Processing is necessary for the performance of contractual obligations stemming from your employment contract.
  • Compliance with legal obligations.
  • Processing is necessary for the legitimate interests pursued by Netis Ltd. or a third party, except where your interests or fundamental rights and freedoms requiring the protection of personal data override these interests.
  • Processing is necessary to protect the vital interests of any individual.
  1. How long do we store your data?

We retain your personal data for as long as necessary to achieve the specified purposes outlined in the "Why do we collect your personal data" section. In specific cases, legal obligations may require the extended retention of personal data. Data will be kept until the expiration of the limitation, storage, or retention periods set forth in civil law, tax law, and accounting regulations.

In all other cases, we delete your personal data once the purpose of data processing has been fulfilled or ceased.

  1. Third party and online links to other websites

This Privacy Policy exclusively pertains to the website, application, and related products or services of Netis Ltd., excluding other websites or applications operated by third parties.

We do not integrate any social media plugins directly into the website. Therefore, your data is only transmitted to the extent provided in our Cookie Policy, which offers further details. Our website may contain links to social media platforms or other third-party websites or applications. Netis Ltd. does not bear responsibility for the privacy practices of such websites or applications. We recommend reviewing the privacy policies of websites operated by third parties or linked within our site for additional information.

Additional information regarding third parties

Our services can be connected to applications or devices developed by third parties. If you use your social media account or third-party applications/devices to log in or connect to our services, we may collect personal information about you from such social networks, third-party applications, and/or devices, including health, lifestyle, and exercise-related data.

Please refer to the guidelines of these social networks, third-party applications, and/or devices to understand the information we might receive.

In case you choose direct payment options through our services, we collect and store the billing and credit card information provided for this purpose.

We also utilize third-party providers and business partners in the healthcare, medical, and/or fitness domains to recommend additional products and services. If you opt to use these products or services, we may share your personal data with them if required for product recommendations or service provisions. Therefore, we recommend reviewing the privacy policies of these third parties for further information.

  1. Cookies

When you visit our websites or generally interact with our digital platforms, cookies may be stored within the web browser on your devices. Cookies are small text files that store information for a certain period and identify your device. We use cookies to ensure that you can easily use the platform according to your interests and preferences.

Please read our cookie policies to understand how we use cookies or other tracking technologies.

  1. Data security

We take reasonable steps to protect your personal data by implementing appropriate technical and organizational measures. These measures comply with applicable data protection and security laws, aiming to prevent risks such as accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to your personal data.

Among the measures we take to safeguard your data are:

  • Restricting physical access to our premises.
  • Limiting access to personal data.
  • Implementing acceptable security measures required from third-party service providers to maintain the security of personal data.
  • Introducing physical, electronic, and procedural safeguards in accordance with industry standards.
  1. Sharing data with third parties

Netis Ltd. does not sell or permit access to your personal data by third parties.

We do not share your personal data with third parties, except in unique cases where there is an appropriate legal basis.

We may share your personal data with the following:

  • Netis Ltd.'s parent and subsidiary companies. As an international corporation, Netis Ltd. may share your personal data with various Netis Ltd. subsidiary, affiliated, and related companies.
  • External service providers, such as consultants and auditors. Your data may be shared with reliable service providers assisting us in areas such as IT services, marketing, finance, advertising, archiving, and document storage.
  • Other contractual partners.
  • Governmental or state authorities as required by applicable laws.

In cases where the law or regulations necessitate it, the sharing of your data may be mandatory.

  1. Transfer of data outside the European Union

In certain cases, personal data may be transmitted to our parent company, subsidiaries, service providers, or partners in third countries outside the EU. Despite the laws applicable in these countries, we handle the protection of your data in accordance with this Privacy Policy.

We ensure that the level of data protection complies with European standards, as per Article 46 of the GDPR, regardless of the laws in these countries.

Consent for Worldwide Transfer and Processing of Personal Data

By providing your personal data through the website and the application, you consent to Netis Ltd. and its contractual partners using them for the purposes described here. You also acknowledge and consent to the collection, maintenance, and processing of this information.

By transmitting your personal data to this website, you agree that your data may be transferred and processed under any jurisdiction, in line with these privacy guidelines.

  1. The assignment, modification and transfer of control

The User acknowledges that all rights and obligations stated in our privacy policy are freely transferable to our parent company and/or any of our subsidiaries through merger, asset acquisition, restructuring, or asset sales, as well as through other means compliant with the law. Consequently, any data held by us concerning you may be transferred to any of our subsidiaries, successor entities, or new owners, associated, or affiliated businesses.

  1. Minors

As outlined in the Terms of Use, the websites and applications are only accessible and usable for individuals aged 14 or above. The use of the website is not permitted for minors who lack legal capacity (those under 14 years of age or under guardianship excluding legal competence), and therefore, we do not process the data of such individuals.

If you are between 14-18 years old (a minor with limited legal capacity), visiting and using the website requires prior consent from your legal representative (parent, guardian, or trustee).

If you are between 14-18 years old, please speak to your parents or legal guardians and obtain their consent before sharing your personal information with us.

If you are a parent or legal guardian of a child aged between 14-18, please monitor how your child uses our products or services (including websites and other digital platforms) and ensure that your child does not share any personal information with us now or in the future without your permission.

  1. Your EU data protection rights

As a data subject, you have certain rights regarding the processing of your personal data. These rights include the right to request:

  • Access to and modification of your personal data
  • Deletion of your personal data (except if the law obligates us to retain the information)
  • Restriction or refusal of the processing of your data
  • Obtain a copy of your personal data in a structured, commonly used, and machine-readable format

You can exercise these rights by contacting us directly. For any questions or requests related to personal data, please send them to the following address:

Address: 45 Váci Street, 1134 Budapest

Central phone number: +36 (1) 878-1653

Email: predem@netis.hu

Upon receipt of your request or query, you will be asked to confirm your identity and specify precisely what information you require.

Netis Ltd.'s aim is to ensure that you receive a response to your request within one month free of charge, except if fulfilling the request requires disproportionate effort.

You have the right to request from Netis Ltd. access to personal data, their correction, deletion, restriction of processing, objection to the processing of personal data, the right to data portability, the right to object to direct marketing, and the right to withdraw consent at any time. You may lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (address: 22/c Szilágyi Erzsébet fasor, Budapest 1125; email: ugyfelszolgalat@naih.hu).

Our Data Protection Officer

You have the right to contact our Data Protection Officer.

The contact details of our Data Protection Officer are as follows:

Zoltán Máthé, DPO
Tel.: +36 (1) 878-1653
Email: dpo@netis.hu
Web: www.netis.hu