Network Marketing Magazine (the “Magazine”, “we”) is committed to protecting the personal data of its users. Processing is carried out in accordance with Regulation (EU) 2016/679 (GDPR) and applicable Hungarian law.
1. The data controller
The Magazine is operated by, and personal data is processed by, the following legal entity:
- Company name: 10x Akadémia Kft.
- Registered seat: 1136 Budapest, Tátra utca 5. A. ép. alagsor 2. ajtó, Magyarország
- Company registration number: 01-09-453005
- Tax number: 32987953-2-41
- Contact e-mail: [email protected]
The Magazine is not required to appoint a data protection officer and has not appointed one; enquiries regarding data processing can be addressed to the e-mail above.
2. What data we process and for what purpose
We only process data necessary to provide the service. The main purposes are:
2.1. Registration and account
- Data processed: name, e-mail address, password (stored encrypted), and the time of account creation and logins.
- Purpose: creating and maintaining the user account, authentication, and sending service-related notifications.
- Legal basis: performance of the contract (terms of use) [Art. 6(1)(b) GDPR].
2.2. Profile and public presence
- Data processed: profile details provided by the user (bio, image, contact details, professional data) and content linked to the Networker Business Card or expert profile.
- Purpose: displaying the public profile and providing the features requested by the user.
- Legal basis: performance of the contract and, for optional data shown publicly, the user’s consent [Art. 6(1)(b) and (a) GDPR].
2.3. Usage tips for the Virtual Office
- Data processed: your name and e-mail address; how many contacts, tasks, activity entries and monthly plans your Virtual Office contains; the dates on which these were created and modified, and their deadlines; how many contacts are in each stage (status), as a count aggregated per account; when you last opened the individual sections of the office; and which tip e-mail we sent you and when. We do not use the names or contact details of your contacts, your notes or the text of your tasks for this purpose, and none of these are included in the e-mails.
- Purpose: to help you use the service you subscribed to with short tips suited to your situation (no more than one e-mail every three days, without offers or prices), and to compile aggregated statistics that cannot be linked to individuals in order to develop the service. The statistics contain no names or e-mail addresses, and no breakdown is produced for any group of fewer than five persons.
- Legal basis: legitimate interest [Art. 6(1)(f) GDPR]. It is in our interest, and in yours, that you are actually able to use the service you have paid for. You may obtain the legitimate interest assessment on request.
- Objection: you can unsubscribe with one click from the bottom of any of these e-mails. By doing so you exercise your right to object [Art. 21 GDPR]; we will then send you no further e-mails of this kind and will not use your data for this measurement. Unsubscribing does not affect your subscription, and you will continue to receive notifications about invoices, payments and renewals.
- Retention: the measured values are not stored separately; they are recalculated every day. The log of e-mails sent is kept for 12 months so that we can comply with the frequency limit.
- No automated decision-making producing legal effects concerning you or similarly significantly affecting you takes place [Art. 22 GDPR]. The system only decides which tip to send.
2.4. Activity log of logged-in users
- Data processed: the time of your logins, the addresses of the pages you open, certain clicks (the label of the button or link), the fact that you exported your data, and, while a page is open in your browser, one signal per minute.
- Purpose: monitoring the operation and security of the service, investigating misuse, establishing whether you use the features you subscribed to (for the tips under Section 2.3), and indicating on the interface which features you have already tried.
- Legal basis: legitimate interest [Art. 6(1)(f) GDPR].
- Who can see it: only the Magazine's staff with administrator privileges.
- Retention: 12 months, or until the account is deleted. Entries older than 12 months are deleted automatically every day; when the account is deleted, the entire log belonging to it is deleted.
- This log is independent of the anonymous traffic measurement described in Section 6.
2.5. Sending e-mails (processors)
- System e-mails (for example notifications relating to registration, passwords, purchases, invoices and subscriptions, as well as the tips under Section 2.3) are delivered by the Resend service, operated by Plus Five Five, Inc. (registered office: San Francisco, California, United States of America).
- Newsletters are delivered by the MailerLite service, which also manages the list of newsletter subscribers. It is operated by UAB “MailerLite” (registered office: Vilnius, Lithuania).
- Data processed: the recipient's e-mail address and name, the content of the e-mail, and technical delivery data. The processors process this data solely for the purpose of delivery and in accordance with our instructions [Art. 28 GDPR].
- Transfers to third countries: Resend operates in the United States of America. Data is transferred on the basis of the adequacy decision on the EU–US Data Privacy Framework [Art. 45 GDPR] or of the standard contractual clauses adopted by the European Commission [Art. 46(2)(c) GDPR]. MailerLite has its registered office in the European Union.
3. Subscriptions (paid services)
When paid subscriptions (e.g. Knowledge Base, AI Mentor, Networker Business Card, premium content) are taken out and fulfilled, we process billing and payment data.
- Data processed: billing name and address, subscription type, amount, currency, payment and expiry dates, and the payment transaction identifier.
- Payment providers: card data is handled directly by the payment provider (Stripe, Paddle or LemonSqueezy); we neither see nor store the full card number.
- Purpose: fulfilling the subscription, invoicing, managing entitlements, and meeting statutory accounting obligations.
- Legal basis: performance of the contract [Art. 6(1)(b) GDPR]; for the retention of billing data, a legal obligation [Art. 6(1)(c) GDPR].
4. One-off advertising fees (advertisers)
When a banner or other paid placement is booked, we process the advertiser company’s data to fulfil the order.
- Data processed: the advertiser’s company name, seat, tax number, contact person’s name and e-mail, the booked placement details, the fee amount and payment data.
- Purpose: fulfilling the advertising order, invoicing, and displaying the advertisement.
- Legal basis: performance of the contract [Art. 6(1)(b) GDPR]; for invoicing, a legal obligation [Art. 6(1)(c) GDPR].
5. Internal name list / CRM (Recruitment) — third-party data
In the Recruitment (CRM) feature, the user (networker) may store their own prospects and leads — i.e. the data of third parties (data subjects). In this relationship the user is the data controller and the Magazine acts as a data processor.
Key rule — third-party data
By uploading prospect data, the user declares and certifies that they are entitled to store and process it (based on the data subject’s consent or a legitimate interest). In this case the Magazine is a DATA PROCESSOR: it processes the data solely on the user’s instructions, to operate the CRM feature. Data subjects’ rights (access, rectification, erasure) can be exercised, and the confirmation of the legal basis provided by the user is logged.
- The user is responsible for properly informing prospects about the processing and for having the necessary legal basis.
- In the event of a data subject request (e.g. erasure), the Magazine cooperates with the user to fulfil the request.
- The fact and time of the legal-basis confirmation are logged to ensure accountability.
We cannot see it — and the system enforces this
The content of a user's contact list cannot be read by the Magazine's staff, including those with administrator privileges. Access rules are configured so that these records can only be returned to the owning user account, and they do not appear in the administration interface at all. For operational and billing purposes, and for the usage tips described in Section 2.3, we process quantitative and time-related data only (how many records belong to an account, when a deadline expires), by automated means; never its content. The only exception is a legal, official or court-ordered obligation.
Users may export their own CRM data at any time, without a separate request or fee, in a machine-readable format — this also serves as the means of exercising the right to data portability.
6. Analytics
- Traffic measurement is anonymous and PII-free: we do not collect directly identifying data and do not link it to a natural person.
- We respect the browser’s “Do Not Track” (DNT) signal: if it is enabled, no analytics data is collected.
- Analytics data is collected only if cookie consent has been given.
- Legal basis: the user’s consent [Art. 6(1)(a) GDPR].
7. Cookies
The site uses cookies in the three categories below. Cookie settings can be changed or withdrawn at any time via the cookie bar.
Maintaining login, security and core functionality. These cookies are essential for the service to work and do not require consent.
Anonymous traffic measurement and improving the interface. Activated only after consent is given.
Displaying relevant advertisements and measuring ad performance. Activated only with separate consent.
The choice made in the cookie bar can be changed at any time; consent to the optional categories can be withdrawn without any consequences.
8. Data retention
- Account and profile data: for as long as the account exists, or until an erasure request is fulfilled.
- Billing data: for the period required by accounting law (typically 8 years in Hungary).
- Virtual Office data (contact list, CRM, tasks, product activities): for a further 30 calendar days after the subscription ends — by cancellation, expiry or non-payment — so that the user has time to export it or restart the subscription. We send an email warning at the start of the grace period and again 7 days before it ends. After the 30 days expire this data is permanently and irreversibly deleted.
- Third-party data stored in the CRM: as instructed by the user, until the user’s account is closed or an erasure request is made.
- Usage tips (Section 2.3): the measured values are recalculated daily and are not stored separately; the log of e-mails sent is kept for 12 months.
- Activity log (Section 2.4): for 12 months, or until the account is deleted; older entries are deleted automatically every day.
- Analytics data: in anonymous form, for a limited period, as aggregated statistics.
- Videos uploaded to the Video studio: the uploaded source video is deleted automatically after 30 days, and the captioned (rendered) video produced from it after 90 days.
In the Video studio, an uploaded video is used solely to produce its captions and to process the video (captioning, cutting out silent parts); converting the audio track to text involves an external processor located in the European Union. Once the periods above expire, both the source and the finished video are deleted from storage automatically, without any further request — and a video can also be deleted earlier at any time from the interface.
9. Data subject rights (GDPR)
Under the GDPR you have the following rights. Requests can be sent to the contact e-mail above; we respond without undue delay and within one month at the latest.
- Access: you may request information about the data we process about you.
- Rectification: you may request correction of inaccurate data.
- Erasure (“right to be forgotten”): you may request deletion of your data where no other legal basis applies.
- Restriction: you may request that processing be restricted in certain cases.
- Objection: you may object to processing, in particular where it is based on a legitimate interest.
- Data portability: you may request the data you provided in a machine-readable format.
- Withdrawal of consent: you may withdraw consent-based processing at any time, with future effect.
Complaint
If you believe the processing is unlawful, you may lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH, 1055 Budapest, Falk Miksa utca 9-11.; [email protected]) or turn to a court.
10. Data security
- Passwords are stored encrypted (hashed) and access is limited to what is necessary.
- Data is transmitted over an encrypted (HTTPS) channel.
- We apply appropriate technical and organisational measures to protect data and to prevent unauthorised access and data loss.
- In the event of a data breach, we act in the manner and within the deadlines required by law.
11. Contact
Questions, requests and notices regarding data processing can be sent to: [email protected]. We respond to enquiries without undue delay. You may also lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH, 1055 Budapest, Falk Miksa utca 9-11., [email protected]) or seek a judicial remedy.
