SERVICES PRIVACY POLICY

THIS SERVICES PRIVACY POLICY IS EFFECTIVE FROM THE DATE OF: 17/03/2025

XS MATRIX SECURITY SOLUTIONS KFT (XS HU or We), as data controller respect your (as data subject) privacy. This Privacy Policy informs you about our privacy practices including details of the personal data we collect, use, disclose and transfer as well as choices you can make and rights you can exercise in relation to your personal data.

XS HU respects and takes into account the EU General Data Protection Regulation 2016/679 (GDPR).

This Privacy Policy applies to all XS HU services, applications, and products. This Privacy Policy does not apply to personal data we collect from our employees or job applicants. 

1. How We collect and use personal data

We collect personal data only if required to provide our products or services, fulfil our legitimate business purposes and/or comply with applicable laws and regulations. Depending on your relationship with XS HU we collect and process your personal data as follows:

• XS HU products and services: contact details, login credentials and interactions with our digital assets and content, for the following main purposes: account creation and management; entering into and performing agreements with you or your organization; providing support and tools to activate licenses and request support; managing and fulfilling orders; deploying and delivering products and services; conducting quality controls; managing returns of defective media; operating and providing access to customer portals, hosted management services and mobile applications; consulting; notifications of contract expiry and renewal options; developing and improving our products and services and ensuring compliance with regulatory requirements.
• Sales and marketing: contact details, identification information, information required to purchase our products and services online, profile, role and preferences, login credentials, digital activity information and other information as may be relevant (e.g. information from publicly available sources) for the following main purposes: sales and marketing; advertising; creating and delivering targeted adverts and offers; conducting marketing campaigns; managing contacts and preferences; generating leads and opportunities; managing lead generation activities; sales engagement activities; organizing and managing events, webinars, virtual meetings; and engaging in social media interactions.
• Online Data Collection Tools: digital activity information for the following main purposes: enabling efficient use of our applications, products and services; collecting statistics to optimize the functionality of our applications, products and services; improving user experience and delivering content tailored to their interests; and improving marketing and advertising campaigns.
• Online forums and surveys: contact details, login credentials, comments and feedback for the following main purposes: engaging with partners and suppliers in online forums; conducting customer satisfaction and engagement surveys.
• Partner and supplier programs: contact details for the following main purposes: managing relations with partners and suppliers; engaging and delivering products and services to customers in which case we may receive personal data directly from you or from our partners.
• Training and education: contact details for the main purpose of conducting trainings and managing education programs for customers, partners and suppliers.
• Due diligence screening: contact details and other information as may be relevant (e.g. information from publicly available sources) for the following main purposes: conducting anti-corruption due diligence on third parties and conducting required investigations, in compliance with applicable laws.
• Brand-protection programs: contact details, login credentials and other relevant information (e.g. information from publicly available sources) for the main purpose of conducting investigations into XS HU product-related fraud, compliance, grey marketing, theft and/or counterfeit.
• Security and authentication: contact details, identification information and CCTV footage for the following main purposes: ensuring safety and security of XS HU staff and premises; login credentials, protecting XS HU’s network and other digital assets; providing access to restricted areas and information assets and protecting personal data from unauthorised access.
• Enquiries and complaints: contact details and information included in enquires and complaints for the main purpose of addressing and resolving enquiries and complaints.

2. How We share personal data

XS HU does not sell, rent or lease personal data to others. XS HU does not disclose or share personal data to others, except as described in this Privacy Policy. We may share and/or disclose your personal data as follows:

• Disclosure within the XS MATRIX group of companies. XS HU has an affiliate company in the United States of America (XS MATRIX GLOBAL CO., a company incorporated in the United States of America, State of Delaware, registered seat: 108 Lakeland Avenue, Delaware 19901, USA; registered under reg. no.: 6383902, „XS GLOBAL”). XS HU may disclose your personal data as necessary with XS GLOBAL in connection with the sale of our products (where XS GLOBAL is the IP rights owner of the products), and the provision of services related to our products (where either company act as a services provider, or the subcontractor to the other company), and the protection of our IP rights.
• Disclosure to third parties. XS HU retains suppliers and service providers to manage or support its business operations, provide professional services, deliver products, services and customer solutions and to assist XS HU with marketing and sales communication initiatives. Those third parties may receive and process your personal data under appropriate instructions, as necessary to support and facilitate how we use your personal data. Suppliers and service providers are required by contract to keep confidential and secure the information they process on behalf of XS HU and may not use it for any purpose other than to carry out the services they are performing for XS HU.
• Where XS HU engages with partners, resellers and/or distributors as part of its business operations, XS HU may disclose your personal data to them in order to facilitate sales and delivery of its products and services. Partners, resellers and/or distributors are required by contract to keep confidential and secure the information received from XS HU and may use it only for the said purposes, unless otherwise authorized by you or applicable laws and regulations.
• XS HU will not share your personal data with third parties without your permission, except of the following cases: (i) respond to duly authorized information requests of police and governmental authorities; (ii) comply with law, regulation, subpoena, or court order; (iii) enforce/protect the rights and properties of XS HU or XS GLOBAL; or (iv) protect the rights or personal safety of XS HU, our employees, and third parties on or using XS HU property when allowed and in each case in accordance with applicable law.
• Circumstances may arise where, whether for strategic or other business reasons, XS HU decides to sell, buy, merge or otherwise reorganize businesses in some countries. Such a transaction may involve the disclosure of personal data to prospective or actual purchasers, or the receipt of it from sellers. It is XS HU’s practice to seek appropriate contractual protection for personal data in these types of transactions.

3. International data transfer

XS HU transfers your personal data internationally solely to XS GLOBAL, for the purposes as described in Clause 2. of this Privacy Policy.

4. How to manage communications between you and XS HU and your preferences

XS HU may provide you with information that complements our products and services and/or communications about our new products, services and offers. If you or your organization purchased our products or services, you may receive alerts, software updates or responses to support requests that are part of our products and services. If you choose to receive XS HU communications you may also choose to subscribe to receive specific newsletters and publications. In some cases, you may also choose whether to receive the information and communication by email, telephone, or post.

Manage communication choices. You can change your choices and preferences relating to XS HU communications via email by sending an email to the email address indicated by our website (www.thefence.net). In the event your opt-out or unsubscribe request has not been resolved in a timely manner, please provide details of your name, contact information, and description of the communications you no longer wish to receive from XS HU.

Please note that these options do not apply to communications relating to the administration of orders, contracts, support, product safety warnings, or other administrative and transactional notices, where the primary purpose of these communications is not promotional in nature.

5. Automatic data collection tools

XS HU’s software and applications use cookies, web beacons, device identifiers, IP addresses, and other similar technologies (collectively, Automatic Data Collection Tools), to provide and secure XS HU software and applications, remember log-in details, collect statistics to optimize functionality, collect information on user activity in response to email communications and related to white papers, documents and other assets made available through our web sites and applications, and more generally to improve your user experience and deliver content tailored to your interests. Some of these Automatic Data Collection Tools are strictly necessary to operate the XS HU software and applications.

If you choose to receive marketing emails or newsletters from XS HU, we may track whether you’ve opened those messages and whether you’ve clicked on links contained within those messages, through the use of web beacons and personalized URLs embedded in these communications. This allows XS HU to better personalize future communications and limit these communications to subjects that are of interest to you.

6. How we protect your personal data

XS HU takes seriously the trust you place in us to protect your personal data. In order to protect your personal data from loss, or unauthorized use, access or disclosure, XS HU utilizes reasonable and appropriate physical, technical, and administrative procedures to safeguard the information we collect and process.

When collecting or transferring sensitive information we use a variety of additional security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure. The personal data you provide us is stored on computer systems locked in controlled facilities which have limited access. Access to your information is restricted to XS HU employees or authorized third parties who need to know that information in order to process it for us, and who are subject to strict confidentiality obligations.

7. How long we keep personal data

Typically, we keep personal data for the length of any contractual relationship and, to the extent permitted by applicable laws, after the end of that relationship for as long as necessary to perform purposes set out in this Privacy Policy, to protect XS HU from legal claims and administer our business. When we no longer need to use personal data, we will delete it from our systems and records or take steps to anonymize the data unless we need to keep it longer to comply with a legal or regulatory obligation.

8. Your rights in connection with your personal data handled by XS HU

• Right to information: you have the right to be informed about the handling of personal data concerning you managed by XS HU, about the essential aspects of data management – we fulfill our information obligation with this Privacy Policy.
• Right of access: you may request information on whether XS HU handles the personal data relating you and, if so, which data are processed. As part of the exercise of the right of access, you are entitled to have access to personal data and the following information:

(a) the purposes of the processing;

(b) the categories of personal data concerned;

(c) the recipients or categories of recipients to whom or with whom the personal data have been or will be communicated, including in particular third country recipients or international organizations;

(d) where applicable, the intended period for which the personal data will be stored or, if that is not possible, the criteria for determining that period;

(e) you have the right to request XS HU to rectify, erase or restrict the processing of personal data concerning you and to object to the processing of such personal data;

(f) the right to lodge a complaint with a supervisory authority;

(g) if the data were not collected from you, all available information on their source;

(h) the fact of automated decision-making, including profiling, and at least in such cases, comprehensible information on the logic used and the significance of such data processing and the expected consequences for you.

XS HU fulfills the right of access primarily with this Privacy Policy – which contains the information according to the previous sentence – however, if You contact us directly by e-mail at the e-mail address: hello@thefence.net, and requests, we shall provide the information requested in the request within 30 (thirty) days after the receipt of the request.

• The information is free of charge if the requested information has not yet submitted a request for information on the same data set in the current year. In other cases, reimbursement may be established. Reimbursement of costs already paid shall be reimbursed if the data have been processed unlawfully or if a request for information has led to a correction.
• We may refuse to inform you only if permitted by law. We are obliged to inform you of the reason for refusing to provide information. In this case, We shall inform you of the possibilities of the dispute resolution.
• Request for correction of data: you may indicate that the data managed by XS HU is inaccurate and may request what is indicated instead. You may request the correction by e-mail at the e-mail address: hello@thefence.net, and XS HU shall comply with the request for correction within 30 (thirty) days after receipt of the request.
• Right to restrict data processing: you may request a restriction on the processing of your personal data – for example in an unclear legal dispute – in this case XS HU will continue to process your personal data, but will not use it to enter to the construction site (the legal consequences of this restriction request are the same as the request to delete the personal data referred above).

You are entitled to request that XS HU restrict the data processing if one of the following is met:

(a) you dispute the accuracy of the personal data in which case the restriction shall apply to the period of time that allows XS HU to verify the accuracy of the personal data;

(b) the processing is unlawful, and you oppose the erasure of the data and instead requests that their use be restricted;

(c) XS HU no longer needs the personal data for the purpose of data processing, but you request them in order to submit, enforce or protect legal claims;

(d) you objected to the processing of data in the public interest, in order to exercise a public authority or in the legitimate interest of the controller (third party); in this case, the restriction shall apply for the period until it is determined whether the legitimate reasons of XS HU take precedence over the legitimate reasons of you.

Restrictions on data management can be requested in exactly the same way as data deletion, and XS HU will comply with this in exactly the same timeframe.

• Right to forget: If you lawfully requested the deletion of the processed personal data, XS HU shall, in parallel with the deletion – in connection with the personal data disclosed by XS HU – take into account the available technology and implementation costs, measures to inform other controllers handling the personal data requested to be deleted that you requested the deletion of the links to the personal data requested to be deleted, or of copies and duplicates of such personal data.
• Right to restrict data processing: you may request a restriction on the processing of your personal data – for example in an unclear legal dispute – in this case XS HU will continue to process your personal data but will not use it to enter the work area. You are entitled to request that XS HU restrict the data processing if one of the following is met:

(a) you dispute the accuracy of the personal data, in which case the restriction shall apply to the period of time that allows XS HU to verify the accuracy of the personal data;

(b) the processing is unlawful and you oppose the erasure of the data and instead requests that their use be restricted;

(c) XS HU no longer needs the personal data for the purpose of data processing, but you request them in order to submit, enforce or protect legal claims; obsession;

(d) you objected to the processing of data in the public interest, in order to exercise a public authority or in the legitimate interest of the controller (third party); in this case, the restriction shall apply for the period until it is determined whether the legitimate reasons of XS HU take precedence over your legitimate reasons.

Restrictions on data processing can be requested in exactly the same way as data deletion, and XS HU will comply with this within exactly the same time limit.

• Right to data transfer: you may request to receive the data processed concerning you in a structured, widely used, machine-readable format (eg .doc, .pdf, etc.) and is entitled to transfer this data to another data controller without that this would be prevented by XS HU. You can request the data transfer request by e-mail to the e-mail address: hello@thefence.net., XS HU will forward the data by e-mail to the e-mail address provided by you within 30 (thirty) days of receiving the request.
• Right to protest: you have the right to object to the processing of his / her personal data by XS HU at any time if he / she considers that XS HU does not handle them in accordance with this Privacy Policy.

If you wish to exercise the above rights (any of them), he / she must send an e-mail to: hello@thefence.net or a letter (postal letter) to the postal address specified below. If you wish to exercise any of the above rights, you must make an explicit and unambiguous request to exercise that right. Within one month from the receipt of the request, XS HU shall inform you of the action taken in relation to the contents of your request. If XS HU does not agree with your request, XS HU shall inform you of the reasons for the non-application of the requested measure and the possibilities of legal remedy within the above deadline.

Contact details of XS HU: 

Postal address: H-1023 Budapest, Frankel Leó út 45. VI. em.

E-mail: hello@thefence.net

9. Your obligations and responsibilities when providing personal data

The Data Subject is obliged to act with due care when providing his / her data. The Data Controller shall not be liable for any damage resulting from the Data Subject’s failure to adequately ensure the protection of his or her data. 

Based on the above, XS HU shall not be liable for any damages or inconveniences suffered by you as a result of your failure to exercise due diligence in providing or processing his or her personal data or in violation of these regulations. 

You are obliged to act fairly, keeping in mind the rights and interests of others. You are obliged to respect the applicable legislation and to refrain from any activity that is illegal or that harms the interests of others. In particular, You shall respect the privacy, personal rights, intellectual property rights of others, in particular copyrighted computer programs (software), literary, scientific and artistic works, inventions, designs, usage patterns, trademarks and rules on the protection of trademarks. You are obliged to refrain from committing an offense or crime, and is obliged to refrain from any obscene, or other expressions or statements that are suitable for causing outrage in others. You are obliged to refrain from any activity that impedes the activity and proper operation of XS HU.

You are obliged to refrain from any activity that violates the interests of XS HU. In particular, You shall:

• Refrain from disturbing or impeding the activities and proper operation of XS HU;
• Refrain from activities aimed at obtaining and using the Business Secrets’ business secrets and information kept secret by it;
• Refrain from any communication that contains false information about XS HU;
• Refrain from any activity that endangers the security of the IT systems operated by XS HU.

You may only provide your own personal data. Disclosure of other persons’ data constitutes unlawful data processing, which may have consequences specified in separate legislation. In case of misuse of other persons’ data, XS HU assists the acting authorities in order to detect the violation, to identify the perpetrator of the violation, and at the same time to take immediate action to initiate official proceedings proportionate to the violation. 

If, due to your conduct, an official or court proceeding is in place, XS HU may store the data necessary for your identification, as well as the data related to the violation, and transfer them to the acting bodies. If the rights of the Affected Third Party are violated and this third party has the right to initiate proceedings, XS HU may transfer the data to the third party if the third party proves its legitimate interest in this.

10. Deadline for action

XS HU shall, without undue delay, but in any case within 1 month from the receipt of the request, inform you of the measures taken following the above requests. 

If necessary, it can be extended by 2 months. XS HU shall inform you of the extension of the deadline, indicating the reasons for the delay, within 1 month from the receipt of the request, using the contact details provided by the data subject for the purpose of contact. 

If XS HU fails to take action on your request, it shall inform you without delay, but no later than one month after receipt of the request, of the reasons for the non-action and of the fact that you may lodge a complaint with a supervisory authority.

11. Actions in the event of a data protection incident

If a data protection incident occurs, and the data protection incident is likely to pose a high risk to the rights and freedoms of natural persons, XS HU shall, without undue delay, inform you of the data protection incident, if your personal data is affected by the incident. 

The information provided to you shall clearly and intelligibly describe the nature of the data protection incident and the name and contact details of the contact person for further information; the likely consequences of the data protection incident must be described; describe the measures taken or planned by XS HU to remedy the data protection incident, including, where appropriate, measures to mitigate any adverse consequences arising from the data protection incident. 

You need not be informed if any of the following conditions is met: 

• XS HU has implemented appropriate technical and organizational protection measures and these measures have been applied to the data affected by the data protection incident, in particular those measures, such as the use of encryption, which make it incomprehensible to persons not authorized to access personal data the data;
• XS HU has taken additional measures following the data protection incident to ensure that the high risk to your rights and freedoms is no longer likely to materialize;
• information would require a disproportionate effort.

In such cases, you shall be informed through publicly available information or a similar measure shall be taken to ensure that you are informed in an equally effective manner.

If XS HU has not yet notified you about the data protection incident, the supervisory authority may, after considering whether the data protection incident is likely to involve a high risk, order that you should be informed.

The data protection incident shall be notified to the Authority by XS HU without undue delay, no later than 72 hours after becoming aware of the data protection incident, unless the data protection incident is not likely to endanger the rights and freedoms of natural persons. If the notification is not made within 72 hours, it shall be accompanied by the reasons for the delay.

12. Liability limitation

XS HU’s liability to you (as data subject) is limited to the following:

(a) in the event of death, personal injury or illness, full compensation for the damage suffered;

(b) compensation for direct damage to property in total up to a maximum of HUF 100,000 (one hundred thousand forints);

(c) compensation for other direct damages caused by the XS HU’s violation of any other provision of the Regulations up to a maximum total value of HUF 50,000 (fifty thousand forints).

XS HU shall not be liable for any indirect, consequential, special damages, lost profits, lost wages, lost income or damages resulting from loss of wages or other income. The limitation clauses in points (b) to (c) above do not apply in cases where liability is not limited by a mandatory and non-derogating legal provision.

13. Complaints

Complaints against possible violations of XS HU can be lodged in Hungary with the National Data Protection and Freedom of Information Authority.

Contact details of the Authority:

Name: National Data Protection and Freedom of Information Authority

Headquarters: 1125 Budapest, Szilágyi Erzsébet avenue 22 / C.

Mailing address: 1530 Budapest, Pf .: 5.

Phone: 06.1.391.1400

Fax: 06.1.391.1410

E-mail: ugyfelszolgalat@naih.hu

Website: http://www.naih.hu

14. Changes of this Privacy Policy

XS HU retains the right to modify this Privacy Policy at any time without a specific notification to you. If XS HU modifies this Privacy Policy, XS HU will publish a revised version with an updated revision date. The privacy link on the footer of every XS HU web page will then point to that new version.