EFFECTIVE 20 February 2020


Első Magyar Egészségügyi Marketing Korlátolt Felelősségű Társaság First Healthcare Marketing(“FHM”) provides “community and activity analysis in social networks” services to its customers.

For this purpose, FHM processes publicly available information on the users of certain social media platforms (e.g. LinkedIn). Some of this information is “personal data” according to General Data Protection Regulation No. 2016/679 of the EU (the “GDPR”).

As part of its services, FHM collects the following personal data about the users, in the form of answers to questions, which may be relevant to the business operations of FHM’s customers:

  1. What is the name of the user on the given social media platform?
  2. What is the link to the user’s social media profile?
  3. What company does the user work for, and in what position?
  4. How many followers does the user have?
  5. How active is the user on the platform (frequency and content of posts, comments and likes)?
  6. What kind of topics does the user react to (e.g. news, articles)?

FHM prepares an analysis for its customer using this date, for the customer’s internal use, and only for a certain period.

In each analysis, FHM primarily examines the following:

  1. In which industry does the user work, which are relevant to FHM’s customer.
  2. Are these users communicating on topics relevant to FHM’s customer?
  3. Are the relevant users an “insider” (internal, connected to FHM’s customer) audience, or an “outsider” (external) audience, who work for other companies?
  4. The relevant users of FHM’s customers are on which decision-making (seniority) level?
  5. According to the strategic goals of FHM’s customer, are the users in a target group in the B2B community or not?
  6. What kind of stakeholder roles do the users relevant for FHM’s customer hold (influencer, investor etc.)?

The legal basis of the data processing for the preparation of the analyses is Art. 6 (1) (f) of the GDPR (processing is necessary for the purposes of the legitimate interests pursued by FHM and its customers).

The legitimate interest on the side of FHM’s customer is that with the help of the analysis, the customer can better know the social media platform (B2B) which is used for its business relations and the platform’s community. For example, FHM’s customer can identify in specific industries more precisely the influencers and opinion-formers, and their followers. It can also identify new persons who can be involved in its target group. By using the results of the analysis, FHM can improve its brand and communication of its business and can develop contact with its B2B target group more efficiently. For example, with the help of visualised and written content (news, scientific articles, events, etc.) optimised for the target group, it can increase the activity and interest of the target group. Furthermore, this content makes it possible to achieve more precise content selection and ascertain the frequency of posting on social media.

FHM’s legitimate interest is that by preparing such analysis, it can become acquainted with the industries relevant to its customers. In such industries and with the acquired experiences, FHM can offer better services: it can identify what kind of communication is used in the given industry (e.g. in a given newspaper, the content shown in infographics has a greater audience), and by that FHM will be able to have better communications with the representatives of the given industries (e.g. what kind of content should be used by a company for a social media post).

With that, FHM can improve its business efficiency. On request, FHM will make available the “balancing test” prepared to determine the legitimate interest.

FHM will not make the personal data available to any entity except its customer.

While providing its services, FHM does not carry out profiling[1] or automatized data processing and does not seek to make direct offers to individuals in the analysis. If FHM contacts people concerning its services, it does this exclusively on the social media platform.

Data retention period: FHM retains the personal data for 24 months. After 24 months, all personal data is erased. The information drawn from the data, which contains no personal data, as business logic information will not be erased with the personal data.

 FHM expressly wishes to draw individuals’ attention to their right to object to the processing of their personal data for a cause related to their own situation at any time the processing is based on legitimate interest. In such case, FHM will cease to process the personal data unless it can prove that the processing has to be continued for compelling legitimate reasons which override the interests, rights and freedoms of the relevant individuals, or which relate to the submission, enforcement or he protection of legal claims.


 FHM reserves the right to modify this Notice unilaterally with effect subsequent to such modification, subject to the limitations provided for in law and with advance notification to the relevant individuals in due time, if necessary.

FHM may modify this Notice especially if required on changes in the law, the practice of the data protection authority, business needs or employees’ needs, any new activity involving personal data processing, any newly revealed security exposures, or if it is necessary due to individuals’ feedback.

When communicating regarding this Notice or privacy issues, or otherwise keeping in contact with the individuals, FHM may use the contact details of the individuals available to it to obtain or keep in contact with the individuals. On request, FHM will send the individuals a copy of the Notice in effect from time to time or certify that the individuals have reviewed the Notice.

Contact details of FHM:

Registered seat:                               H-6750, Algyő, Kastélykert utca 147., Hungary
Company registration number:   Cg. 06-09-016018
Registered by:                                 Company Registry Court of Szeged Regional Court
Phone number:                              + 36 30 894 2663
E-mail:                                             hello@FHM.hu
Website:                                          https://egeszsegugyimarketing.hu/
Represented by:                            Krisztina Horváth


 FHM ensures the protection of the personal data with the following measures:

  • The personnel of FHM who are responsible for the analytics can access the data only with their username and password. The password is refreshed every 30 days.
  • FHM logs and stores the date and time of access, which secures that access and the use of the data can be audited in a timely manner.
  • The data is contained in a database with 128-bit encryption.
  • Registers containing personal data are indicated and separated in the database in a non-editable and non-copiable format.

 The data protection rights and remedies of the individuals are set out in detail in the applicable provisions of the GDPR, especially in Arts. 15, 16., 17, 18, 19, 20, 21, 22, 77, 78, 79, 80 and 82. The summary below contains the most important provisions. FHM informs the individuals of their right to object on the first page of this Notice.

If an individual exercises his/her data protection rights under the GDPR, FHM maintains the data concerning the request, pursuant to Art. 6 (1) c) of the GDPR (to comply with a legal obligation). The purpose of this for FHM is to ensure the rights of the individuals and to document all actions concerning the requests, especially if an individual objects to the processing of his/her personal data. For example, if an individual requests the erasure of his/her personal data via email according to the GDPR, and FHM fulfils such request, then FHM keeps the email the individual sent.

  • Deadlines

 FHM must respond without unreasonable delay and in any case within one month of receipt to an individual’s request. The date of receipt of the request does not count towards the deadline.

If needed, this period may be extended by a further two months in the light of the complexity of the request and the number of requests to be processed. FHM must notify the individual of the extension, indicating its grounds for the delay, within one month of the receipt of the request.

  • Rights related to data processing

 4.2.1    The individual’s right of access

 The individual has the right to obtain confirmation from FHM whether personal data concerning him/her is being processed. If it is, then he/she is entitled to access the personal data concerned and to the following information:

  • regarding the data processing operations of FHM:
  • the personal data processed;
  • the legal basis of the data processing;
  • the purpose of the data processing;
  • the period for which the personal data will be stored;


  • to whom, when, under what law and to which data did FHM granted access or to whom did it transmit the personal data;
  • the source of his/her personal data; and
  • whether FHM applies automated decision-making and its logic, including profiling.

FHM provides a copy of the personal data undergoing processing to the individual. FHM may charge a reasonable fee based on administrative costs for further copies.

4.2.2    Right to rectification

The individual has the right to request that FHM rectify inaccurate personal data. If the individual can prove the accuracy of the corrected data in a credible manner, FHM must complete the request within one month and inform the relevant person of the contact details provided by him/her.

4.2.3    Right to the restriction of data processing

 The individual has the right to request the restriction of the processing of his/her personal data (a clear indication of the requested limitation in the data processing and the separate treatment of the data from other data) where one of the following applies:

  • the individual contests the accuracy of the personal data, for a period enabling FHM to verify the accuracy of the data;
  • the processing is unlawful, the individual objects to the erasure of the personal data and requests the restriction of its use instead;
  • FHM no longer needs the personal data for processing, but the individual requires it to establish, exercise or defend legal claims;
  • the individual has objected to the processing based on the legitimate interest of FHM (for the time of the verification whether the legitimate grounds of FHM override those of the individual).

4.2.4.   Right to erasure (‘right to be forgotten’)

 The individual has the right to request FHM to erase his/her personal data without unreasonable delay, if one of the following reasons are met:

  1. the personal data is no longer necessary for the purposes for which it was collected or otherwise processed by FHM;
  2. the individual objects to the processing and there are no overriding legitimate grounds for the processing;
  3. the personal data has been processed unlawfully;
  4. the personal data has to be erased to comply with a legal obligation in Union or Member State law to which FHM is subject;
  5. the personal data has been collected during the offering of information society services.

FHM may refuse a deletion request to the extent that processing is necessary, among other things, for:

  1. a) exercising the right of freedom of expression and information;
  2. b) compliance with a legal obligation which requires processing by Union or Member State law to which FHM is subject; or
  3. d) the establishment, exercise or defence of legal claims.

4.2.5.   Right to judicial remedy

If the individual believes that FHM has violated the applicable data protection requirements when processing his/her personal data, he/she:

  • may submit a complaint to the supervisory authority (Hungarian National Authority for Data Protection and Freedom of Information, address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c, postal adress: 1530 Budapest, Pf.: 5. e-mail: ugyfelszolgalat@naih.hu, website: naih.hu);
  • may go to court for to protect his/her data, and the court will act in extraordinary proceedings. The individual can choose to submit the claim either at his/her permanent residence, or at his/her location (temporary address), or at the general court (törvényszék) competent at the registered seat of FHM. The individual can obtain information on the competent general courts for his/her permanent residence or location at http://birosag.hu/ugyfelkapcsolati- portal/birosag-kereso.

[1] Under Art. 4 (4) of the GDPR, “profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to an individual person, in particular to analyse or predict aspects concerning that individual person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.