Privacy Notice

The purpose of this privacy notice is to inform you about  the processing of personal data related to the use of the PwC Global e-learning webshop website (“Site”) provided by PricewaterhouseCoopers Könyvvizsgáló Kft. (H-1055 Budapest, Bajcsy-Zsilinszky út 78. Hungary; company registration number: 01-09-063022; hereinafter: “PwC”). 

I. Characteristics of the data processing     

PwC’s Digital Learning Solutions Team integrates high level e-learning courses developed by PwC experts globally in the fields of finance, accountancy, tax, law, human resources, internal audit, controlling, management and business skills, with the commitment to help develop business leaders and experts of the future and help enterprises stay ahead of competitors.

After registering to the Site, users can browse through the e-learning courses offered by PwC and purchase the courses of their choice. Once a course is purchased, users can complete it directly on the Site, within 12 months of purchase. After completing the course, users are able to download proof of completion in the form of a certificate and in some cases, also receive credit points for completion.

In order to allow users to securely access the Site and its functions, it is necessary to process certain personal information about the user. In this regard PwC acts as a data controller in compliance with the European Union’s General Data Protection Regulation (“GDPR”) and other privacy-related laws as per the below.

II. Purposes of data processing

Purposes of PwC’s data processing:

1. Providing secure access to the Site and its functions so that users can purchase and complete e-learning courses online in accordance with the related terms and conditions governing the use of the Site;
2. Administration and invoicing of purchases made by the user on the Site;
3. In the event of a legal dispute or procedure by any court or authority, proving that PwC performed its obligations in line with the related terms and conditions provided that this, in light of the particular situation, requires any personal data.

III. Legal basis of data processing

Legal basis of data processing:

1. For the purpose of point II.1.: performance of the agreement concluded by and between PwC and the user regarding the use of the Site upon the user’s acceptance of the underlying terms and conditions;
2. For the purpose of point II.2.: fulfilment of the statutory accounting and invoicing obligations PwC is subject to;
3. For the purpose of point II.3.: PwC's legitimate interest in successfully defending its legal position in the event of any legal disputes or during any official procedure.

IV. Scope of personal data processed

The personal data (“Personal Data”) processed is the following:

• user identification data (first name, last name, email address);
• user’s username provided at registration;
• the training record of the user, including the e-learning courses purchased by the user and the answers given to the follow-up questions during their completion;
• the credit points or certificates received for completing e-learning courses;
• content of the complaints and questions of the user;
• purchase price paid, billing address (address, city, postcode), VAT registration number if applicable.

V.  Retention period for the data processed

• For the purpose set out in Section II.1 the Personal Data is stored until the account registered by the user on the Site or the associated data is deleted as a result of the exercising of the user's rights as a data subject (e.g. erasure request).
• For the purpose set out in Section II.2 the Personal Data is stored for a period in accordance with the provisions of the Hungarian Accounting Act (8 years).
• For the purpose set out in Section II.3. the Personal Data is stored during the course of the statutory limitation period under civil law (5 years as a general rule) which is calculated from the due date of the given legal claim.

VI. Data Processors

PwC transfers the Personal Data to the following data processors in the course of processing:

• Cornerstone OnDemand, Inc. (registered seat: 1601 Cloverfield Boulevard, Suite 620, Santa Monica, CA 90404, United States of America) as our data storage provider; Cornerstone EXE platform of PwC uses Amazon Web Services Equinix London Slough UK Data Center
• PayPal (Europe) S.à r.l. et Cie, S.C.A. (registered seat: 22-24 Boulevard Royal, L-2449 Luxembourg) as our payment facility provider

Whenever the transfer of Personal Data to recipients outside the European Economic Area is necessary, PwC and its partners ensure that adequate guarantee mechanisms are in place in order to ensure the appropriate level of protection of the Personal Data.

VII. Rights of the user in relation to data privacy

As per the applicable laws, you may request:

• access to your Personal Data;
• information about the data processing;
• the rectification of your Personal Data;
• in certain cases, the erasure of your Personal Data or
• in certain cases, the restriction of its processing.

You can exercise any of these rights via our contact details at the end of this privacy notice.

With regards to our data processing mentioned in point II. 1., you can exercise your right to data portability. This means have the right to receive the Personal Data concerning you that you have provided in a structured, commonly used and machine-readable format (e.g. an email attachment) or request PwC to transmit such data to another data controller of your choosing.

With regards to our data processing mentioned in point II. 3., we expressly draw your attention to your right to object to the processing of your Personal Data.

We also bring your attention to that fact that some Personal Data is required to access the functions of the Site. We explicitly exclude any and all liability for damages incurred as a result of your inability to use the Site or any of its functions because, as per your request, your personal information necessary to do so was deleted.

We inform you that there is no profiling or automated decision-making taking place in relation to your processed Personal Data. This means that we will not analyze your Personal Data in any way in order to draw any conclusions about you, further, no automated decisions (i.e. ones without human intervention) will be made using your Personal Data.

If you think that an infringement has occurred or is occurring in connection with the processing of your personal data, you can file a complaint with the National Data Protection Authority, which is the data protection regulator in Hungary (address: H-1055 Budapest, Falk Miksa utca 9-11 .; telephone: + 36 1 391 1400; e-mail: ugyfelszolgalat@naih.hu) or alternatively, the data protection regulator having competence based on your habitual residence, place of work or place of the alleged infringement in case any of these locations are not in Hungary. You also have the right to judicial remedy. You may find detailed information about the court system in Hungary here in English: https://birosag.hu/en

However, before contacting an authority or court, we kindly ask you to inform PwC of your concerns and we will do our best to resolve them in a reassuring manner.

If you have any questions or comments regarding the data processing, please contact us at the following contact details:

Data Protection Officer:  the person defined here (at present: dr. Orsolya Hosszú)

email: hu_dataprotection@pwc.com

telephone: + 36 1 461 9888

address: H-1055 Budapest, Bajcsy-Zsilinszky út 78.

We’ll respond to your questions, complaints and requests as soon as possible in all cases, but not later than within 1 month as required by the applicable laws.