Privacy Notice – FD Finder
Version: 3.6 Effective from: 3 November 2026 Last amended: 3 November 2026
One-minute summary
- What do we process? Your account data, the recorded content and the location, the vineyard, farming and laboratory data, the assessments, the data on the use of the knowledge base and of our tools, and the technical data (Section 5), on every interface.
- Who sees it? Another user sees only what is needed for his or her task; not your identity, the exact location or the exact time (Section 3.1).
- Research and AI. We also use the data for research and for the development of artificial intelligence (AI), for example for pre-screening with a vehicle-mounted camera. We may also hand over the pseudonymised dataset and the model to a partner; the dataset also contains the exact location, and is therefore not anonymous (Section 7). We always comply with an objection for research purposes (Section 15).
- Our providers also process the data outside the EU, for example the text of the question for the AI answer (Sections 8 to 9). Your rights: Sections 13 to 16.
1. The data controller
| Data | Value |
|---|---|
| Name | DrinkCycle Development Korlátolt Felelősségű Társaság (DrinkCycle Development Kft.) |
| Registered office and postal address | 1223 Budapest, Nagytétényi út 180-196. |
| Company registration number | 01-09-438666 (Fővárosi Törvényszék Cégbírósága) |
| Tax number | 32712061-2-43; EU VAT number: HU32712061 |
| Representative | Péter Mokos, managing director |
| Website | https://www.fdfinder.org |
| Data protection contact | info@fdfinder.org |
| Telephone | +36 72 200 205 |
Write by email or by post; we confirm receipt automatically, and as a general rule we reply within one month (Article 12(3) GDPR).
2. Data protection officer
We have not appointed one, because no law obliges us to do so.
3. Basic concepts
3.1 Who sees what
Principle: another user sees only what is needed for his or her task. Reviewers and labellers see the images and the descriptive data, also the wine region and the year and month of the recording, but not your identity, the exact location or the exact time.
| Level | Who can see it | What belongs here |
|---|---|---|
| Public | signed-in users, according to their task | the images and descriptive data that go to review or labelling, with the limits above |
| Private | only you | private fields, own markings, profile |
| Hidden internal | no other user, only an authorised staff member and machine processing; your own data: you and the person with whom you share them within your organisation | exact location and time, track, parcel identifier, raw original, authorisations; the laboratory result as set out in Section 5.2 |
The levels are also separated by the database’s access rules.
3.2 Image layers
- A – raw original: the uploaded file, with its metadata (including the location). Only server-side processing; it does not go into training or handover.
- B and C – clean master and thumbnail: resized, without metadata; whoever can see the Content.
- D – research master: the raw original at full resolution, without metadata; nobody in the interface, only research and AI training.
3.3 ‘Pseudonymised’, not ‘anonymous’
From the exact location the land parcel and its owner can be ascertained; the data are therefore personal even if we do not link them.
4. General characteristics
- No machine decisions about you (Article 22 GDPR): the AI estimate is about the vine, not about you. There is simple profiling only in the selection of supporter content (Section 22 of the Terms and Conditions); you may switch it off.
- No special categories of personal data, no advertising or social-media tracking, not in the app either. We produce visitor statistics only without cookies, in aggregated form, not linked to any person.
- We have carried out a data protection impact assessment, and we supplement it when the operation changes.
5. The data processed
We list data categories, not fields. We do not yet collect all of them; as long as a function is not available, the processing belonging to it does not start either; if it starts later, no new acceptance is needed for it (Section 3.3 of the Terms and Conditions). We provide the field-level list on request.
Mandatory: the account data (email address, password, name used to address you), because they are a condition of the contract, and, for Content, the image and the location. Other data are voluntary, unless a function requests them, as indicated in the interface.
Where from? Mostly from you; certain data from another user, a laboratory, an authority, a partner or a public source (Section 5.10).
5.1 Account and profile
| Data | Note |
|---|---|
| account identifier, email address, the hash of the password, times, tokens | for signing in; we do not know the password |
| name used to address you | mandatory, private, may also be a nickname |
| public handle | voluntary; the only item of profile data that others can also see (leaderboard) |
| farming and contact data (for example grower category, wine region, vineyard area, telephone number) | voluntary, private |
| professional identifier | voluntary, private (for example the number of the HNT Gazdasági Akta); we hand it over to a sector system only after separate information and with your consent |
| organisation account | the organisation, membership, role, invitation (the name and email address of the invitee are provided by the inviter), logs |
| settings | for example newsletter, offers, hiding the help; the setting and its log |
We provide separate information about the data of a purchase and of a paid service at the time of ordering.
5.2 Content
| Data category | What belongs here | Who sees it |
|---|---|---|
| image and recording | photograph, video, other sensor data (for example multispectral or vehicle-mounted camera), audio and text note | you; as set out in Section 3.1, the reviewers and the labellers |
| observation and descriptive data | the data of the vine and of the vineyard, the observation (symptoms, touch, condition, the neighbouring vines), the vine code | you; as set out in Section 3.1, the reviewers, the labellers and the Surveyors |
| vineyard and farming data | the data and condition of the vineyard (for example quarantine), the data of farming and of treatments, trap catches | you, and the person with whom you share them; the parcel identifier is hidden internal |
| laboratory and sampling data | sample reference, laboratory result, the order for the testing; may be recorded by the Surveyor, the laboratory, the authority or our staff member | the person who recorded it, the keeper of the vine (the person who manages the vineyard in his or her account) and the person who ordered the testing; no other user (the laboratory feedback: row 6.13) |
| private detail | own marking, private note | only you; it does not go into training or handover |
| the row and vine number of a Survey vine | for finding the vine | the Surveyors; it does not go into review, training or handover |
| the data of the recording | the version of the documents in force at that time, the times (including those of data supplied later), the measured image quality, the source of the image (camera or gallery) and its selected crop, the hash of the file (so that the same image does not get in twice) | you |
Do not write or record any identifying data (name, address, telephone number, number plate, inscription, recognisable person). On the recordings of the vehicle-mounted camera, we mask accidentally recorded faces and number plates by machine means, or delete the image.
5.3 Location and recording position – hidden internal level
| Data | Note |
|---|---|
| coordinate, accuracy, time, the source of the location | from the device’s location measurement, from the photograph’s data or from the settlement you enter; we determine the settlement and the wine region from it ourselves, and the location is not passed to anyone for this |
| the location of the vineyard | automatically from the locations of the vines, or you enter it; only you see it, and you may delete it |
| track | if the recording records it (for example with a vehicle-mounted camera) |
| the position of the device, camera setting | for the image geometry |
We measure the location only during recording, never in the background. The location is our most sensitive data. Other users see it only if you share it within your organisation; of the time, others see only the year and the month (Section 3.1). The location does not go into layers B, C and D.
5.4 Assessments
| Data | Note |
|---|---|
| review, reviewer flag, comment | tied to the reviewer’s identifier; final |
| label | tied to the labeller’s identifier; only the role goes into handover |
| reviewer reliability, training and exam; laboratory feedback (row 6.13) | for weighting and for training; it does not go into handover, and the exam is deleted together with the account |
| moderation log | the intervention, the reason, the person acting; cannot be modified subsequently |
| community content | post, reaction, following, message, opinion and estimate (for example about the risk index); the direct message is private, it does not go into training or handover; we use the estimates only in aggregated form, in the published index too |
| AI output | estimates for vines, rows and areas, and their condition history; not a diagnosis |
5.5 Authorisations
The surveyor application (the acceptance of the briefing, the trial survey, the decision), the roles (for example surveyor, labeller), the acknowledgements of briefings, the authorisation relating to an area (who, for what, until when), the suspensions and the locking of the account, with the reason. At the hidden internal level.
5.6 Legal registers
Which document version you accepted, when and how, the registration declarations, the licence arising per item of Content, the legal notices. These are the evidence of acceptance, and cannot be modified.
5.7 Technical data
Server logs (IP address, time, path, browser), own diagnostic and error log (without location, image, private note and email address), email-sending data (we do not track delivery), the technical data of the recording (for example exposure, resolution, the manufacturer and model of the device), the identifier and log of the sensor, the vehicle or the drone, the version of the app and when you used the account from the app, the notification identifier, the aggregated number of errors, and the counters and locks against overload and double processing (for at most 2 days).
5.8 Contact and cooperation
The data from the public forms (name, email address, message, attached file, and whatever else the form asks for) arrive as an email; the email provider also keeps the email, according to its own retention period. If it leads to cooperation (for example press, a winery, a professional partner), we keep a record of the contact data, the application and the decision. After the agreement, we may publish the name and website of the winery or the partner on a public list. The abuse-prevention counter deletes the keyed hash of the IP address within 24 hours.
5.9 The Android app: on the device
In the Local archive (in the folder you have chosen), the raw images remain without encryption together with the location, even after upload, sign-out and deletion of the app; only you can delete them, and they may also appear in the gallery or in the cloud. The sign-in token is encrypted. The app sends data only to our servers.
5.10 External data
Satellite and drone imagery, weather, soil, terrain, official zones, registers and laboratory results, linked to the location. Their source is a public database, a laboratory, an authority, a partner or (with your consent) a sector system. They may relate to the land user (Section 19.1).
For the knowledge base and for research, we also collect public professional sources, the knowledge material sent in to us and public social-media posts; the name of the author may also appear in these. The raw material remains internal. We do not mention the authors of social-media posts by name; for a professional source, we indicate the author in the reference.
5.11 Knowledge base and AI answer
The form requested for access (for example country, settlement or wine region, role, the size of the farm), the log of downloads and questions (time, quantity, cost), the partner application (name, organisation, role, work contact details, professional registration number, the purpose of the application) and the decision, the waiting list. We do not store the text of the question; for the answer, it is processed by the AI provider, which may keep it for a short time at most, to filter out abuse (Section 8).
5.12 Simulator leaderboard
Without an account: the nickname, the wine region (if you enter it), the score and the steps of the simulation. The nickname, the wine region and the score are public. Deletion with the deletion code you receive.
6. Purposes, legal bases
Legal bases (Article 6(1) GDPR): a) consent, b) contract, c) legal obligation, f) legitimate interest. The safeguards of research (Article 89): data minimisation, pseudonymisation, access restriction.
| Purpose | Legal basis; our legitimate interest |
|---|---|
| 6.1 Provision of the Service: account, recording and display, vineyard and farming records, the app, organisation account | b) |
| 6.2 Review and labelling | b) |
| 6.3 Plant-health observation and spread research from the location and the Content, compared with external data | f), Article 89; understanding the spread of FD, assisting the control measures |
| 6.4 Research dataset and AI development, including for pre-screening systems | f), Article 89, subject to the conditions of Section 7.3; research, AI development and the products built on it, free of charge or for consideration |
| 6.5 Handover of the dataset and the model to a partner, joint research | f), Article 89, with a separate balancing of interests; so that the collection does not have to be repeated, and so that the dataset is also put to use for consideration |
| 6.6 Retention of the raw original, production of layer D | f), Article 89; so that we can reprocess the images later |
| 6.7 Security, abuse prevention, sign-in cookie | f); the protection of the accounts and of the review |
| 6.8 Legal obligation (requests from authorities, data protection and accounting obligations); legal claims | c); for the claims, f) |
| 6.9 Keeping in contact, leaderboard, prize draw, community functions (the estimate too); statistics (visitor statistics too), planning, supporter content, newsletter, forms | the first four: b); supporter offers and advertising by email: a); the rest: f), maintaining the free-of-charge Service; the accounting document of the prize: c) |
| 6.10 Transfer of the professional identifier to a sector system, retrieval of data from there | a) |
| 6.11 Assessment of the surveyor application; retention of the rejected trial survey (it does not go into AI training) | b); the retention: f), education and quality assurance |
| 6.12 Publication of certain images (mode 4 of Section 11.4 of the Terms and Conditions), without location and name | f); making the control measures known |
| 6.13 Laboratory feedback to the reviewers and labellers: aggregated and with a delay (for example a monthly hit rate), per image only at the end of the season; without the vine, the location and the persons | f); their training |
| 6.14 Sharing the laboratory result with the recorder, the keeper of the vine and the person who ordered the testing; data exchange with laboratories; results recorded with us by an authority (for example NÉBIH) | f); so that the result reaches those concerned and assists the control measures. To an authority only under a statutory obligation, with the data required by law: c) |
| 6.15 Ordering laboratory testing | b), under the conditions accepted when ordering |
| 6.16 Access to the knowledge base, the AI answer, the restriction of use; collection of public sources for the knowledge base | b); the log and the collection: f), the prevention of abuse, keeping the cost under control and building the knowledge base |
| 6.17 Simulator leaderboard | a), may be withdrawn with the deletion code |
| 6.18 Cooperation application and agreement (press, winery, partner); the public list | b); the public list: a) |
The location is mandatory, because the spread cannot be researched without it; we keep it locked away, and we communicate results only in aggregated form. We do not use the parcel identifier and the external data for searching for the owner. Before publication, we check that the image identifies no one. We do not hand over the telephone number and the farm data to third parties at individual level, and we comply with an objection to them without any balancing of interests. We provide the balancings of interests on request. Consent (6.10) may be withdrawn at any time, without affecting the earlier processing.
7. Key section – research and artificial intelligence
7.1 What we do
From the data we build machine-learning models for the recognition of FD and other plant-health risks and for viticultural purposes, including for pre-screening systems (for example a vehicle-mounted camera moving along the rows), and a research dataset for examining the spread. We may also hand over the pseudonymised dataset and the model to a partner, including for joint research, free of charge or for consideration. We may hand over an aggregated result that cannot be traced back to any single vineyard (for example a wine-region statistic) to anyone, including an authority.
What do we use? Layers B, C and D; the descriptive, vineyard, farming, laboratory and external data; the technical data of the recording (the device model only for our own training); the reviews and labels, as an impression, not as a diagnosis. Not the text of the reviewer comments.
What do we remove before handover? The account identifier, the name, the contact details, the private fields and markings, the parcel identifier, the reviewer and labeller identifiers, the device model and every identifier capable of retrieval. Layer A is never handed over.
What remains in it? The exact location and the time, because the spread cannot be researched without them. Therefore the handed-over dataset is not anonymous, and you may object to it at any time. The image model’s training set contains no exact location; the research dataset that may be handed over does.
The partner’s undertakings: Section 11.5 of the Terms and Conditions. Data handover has so far not taken place (Section 8.3).
7.2 How you accept it
You accept the research clause with a separate checkbox: at registration, and again if a new version asks for it (Section 15.4 of the Terms and Conditions). The legal basis is nevertheless our legitimate interest, not your consent; you may therefore object at any time, without giving reasons (Section 15).
7.3 Conditions of training and handover
AI training starts only if the following are met in a documented manner: 1. a written modelling task and protocol; 2. excluded from the training set: the exact location, the reviewer identifier, the private fields, own markings, layer A and every account identifier; 3. the detachment from the account tested; 4. simple objection, also in the interface; 5. prominent information at finalisation; 6. a working deletion procedure; 7. management of the risk affecting another person’s vineyard (Section 19.1); 8. an approved data protection impact assessment; 9. we do not claim the model’s anonymity.
Handover may take place only if, beyond these, the following are also met: 10. a separate balancing of interests, which states that the dataset is not anonymous; 11. the supplementation of the impact assessment with the risks of the handover; 12. prior publication of the partner’s name, country and the safeguard in Section 8.3; 13. verification of the detachment (without the data removed under Section 7.1, EXIF data and layer A images); 14. a written agreement with the clauses of Section 11.5 of the Terms and Conditions; 15. the re-evaluation of the risk affecting another person’s vineyard.
We disclose a model to the public only if, according to testing, no personal data can be extracted from it.
7.4 What we do not promise about the model
We do not claim that the model is anonymous. The effect of your data cannot be removed from a trained model; after an objection, we no longer use them in the next training. If your personal data could be extracted from the model, we give effect to your rights in respect of the model as well. The research purpose is not an obstacle to deletion.
8. Recipients and data processors
We do not hand over data for marketing, advertising, credit, insurance or profiling purposes. We hand over personal data (including the laboratory result) to an authority only on the basis of a statutory obligation. Our data processors act on the basis of a contract, on our instructions:
| Provider | Country | What it does |
|---|---|---|
| SUPABASE PTE. LTD., 65 Chulia Street #38-02/03, OCBC Centre, Singapore 049513 | Singapore (database: Frankfurt) | database, authentication, file storage: almost all of our data |
| Vercel Inc., Covina, California | USA | running the web application, server logging |
| Plus Five Five, Inc. (Resend), 2261 Market Street #5039, San Francisco, CA 94114 | USA | service emails, newsletter, contact emails |
| Anthropic, PBC, San Francisco, California | USA | AI answer from the knowledge base: the text of the question; it may not learn from it |
8.1 Where the data are
The providers’ sub-processors also operate outside the EU, so access falling under the jurisdiction of the United States is also possible.
8.2 Change
We notify you in advance of a new data processor (Section 21).
8.3 Other recipients and partners
- Other users, as set out in Sections 3.1 and 5.2 (the laboratory result: the person who recorded it, the keeper of the vine and the person who ordered the testing).
- Laboratories: for the exchange of laboratory results, with the data necessary for the testing (row 6.14). The authority (for example NÉBIH) may record laboratory results with us; we hand over data to an authority only under a statutory obligation.
- Authorities and courts, upon a lawful request.
- Legal representative, auditor, accountant, subject to confidentiality.
- The supporter delivering the prize, only with the data necessary for the delivery.
- Research, developer and business partners (universities, research institutes, viticultural and plant-health research institutions and businesses), under Section 7. The partner is an independent data controller for its own purposes; the agreement binds it to Section 11.5 of the Terms and Conditions, together with the passing on of objections and deletions. If, in a joint research project, we decide on the purposes and means jointly with the partner (joint control), we publish the essence of the arrangement here.
At present there is no partner, and as long as there is none, no data goes to one either. If this changes, we state the partner’s name, country and the safeguard here in advance. A partner outside the EEA may receive data only with appropriate safeguards.
8.4 Google Play
The app is distributed by Google Play; Google processes the download data. The app sends no data to Google.
8.5 AI-based tools
Artificial intelligence tools also help with operation. Personal data are received only by a provider that has a data processing contract with us (Section 8), and only what is necessary for the task; it may not learn from our data. The other tools receive only aggregated or anonymous data. We notify you in advance of a new provider of such tools, as set out in Section 8.2.
8.6 Our social media pages
On our social media page (for example Facebook), the platform processes the data according to its own rules; we are jointly responsible with the platform for its statistics. We do not track the users of the platform.
9. Transfer to a third country
Your data are also transferred outside the EEA. For every provider, the safeguard is the European Commission’s standard contractual clauses (SCC, Decision (EU) 2021/914), with a data processing agreement. There is no adequacy decision for Singapore; there, encryption and a database in the Union also provide protection. We provide a copy of the agreements on request.
10. How long we retain – maximums
| Data category | Retention at most |
|---|---|
| Account and profile data, the location of the vineyard, the estimates, the knowledge base form and logs | until the account ceases to exist; the data needed for legal claims, until the claims become time-barred |
| Cooperation application and agreement | until the end of the cooperation, after that at most 5 years (limitation period) |
| Simulator leaderboard | at most 2 years |
| Content (including the laboratory result), location, assessment, AI output, research data (layers A–D and the collected and sent-in sources too) | for as long as the research purpose lasts, at most 30 years from recording, reviewed every 3 years |
| Private details | for the lifecycle of the Content; always deleted on account deletion |
| Abandoned upload; deleted Content | at most 30 days |
| Authorisation register | 5 years |
| Rejected trial survey | for as long as it is needed for the purpose, at most 10 years, reviewed every 3 years, or until your deletion request |
| Moderation log | at most 5 years from the decision (limitation period) |
| Consumer complaint and the reply | 3 years (Section 17/A of the Fgytv.) |
| Paid order and invoice | 8 years under the Accounting Act |
| Leaderboard and draw log | until the account ceases to exist; after that, the draw entry remains in pseudonymised form |
| Legal register | for as long as it is needed as evidence, at most until the claims become time-barred |
| Server logs, email-sending data | at most 1 year |
| Backup | at most 6 months; on restoration we re-execute the deletions |
| Prize | the delivery details until delivery; the accounting document for 8 years (Accounting Act) |
| Contact email | until the matter is closed, deleted at least annually |
| The app’s internal storage | until sign-out or deletion of the app; the Local archive, until you delete it |
11. Data security
In the database, every item of data is protected by an access rule; the files are in closed storage and can be opened only with a short-lived link; the connection is encrypted. We test that layers B, C and D are free of metadata. There is no elevated-privilege key in the app.
11.1 The limits
- Removing the metadata does not anonymise: the location remains in the database.
- The sign-in cookie is not
httpOnly, which is why it lives for at most 30 days. - The Local archive is deliberately unencrypted.
12. Cookies and browser-side storage
We use only strictly necessary cookies, and therefore we do not ask for consent.
| Cookie | Purpose | Legal basis | Lifetime |
|---|---|---|---|
sign-in cookies (currently sb-…-auth-token and its variants) | maintaining the sign-in and its security verification | legitimate interest | at most 30 days |
We do not use any other cookie. We use browser-side storage only for purposes strictly necessary for operation (for example for a draft saved without internet), never for tracking or statistics. The web pages opened in the app also use this cookie. This is the information under Section 155(4) of the Eht.
13. Your rights
13.1 Access: you may request a copy of the data processed about you, including the hidden data; the first copy is free of charge.
13.2 Rectification: we rectify a reviewer comment by removal.
13.3 Erasure. You may also request the deletion of certain data while keeping the account. We confirm an account deletion request within 72 hours, and offer two options:
- full deletion: the account, the Content, the location, the reviews and the flags are permanently deleted;
- deletion with the research data retained: the link between the account and the data permanently ceases to exist, and the Content remains pseudonymised in the research dataset. The private details are deleted in this case too; the row and vine number recorded in a survey remain on the vine. The text of reviewer comments remains; if they refer to you, request their removal separately. After this we can find the Content only on the basis of the data you provide (for example location, time).
If you do not choose, we carry out full deletion. If you withdraw from the contract on the My account page, we close the account immediately and carry out full deletion. The legal registers (Section 10) remain. We confirm the execution. In backups the data may remain for at most six months. You must delete the Local archive yourself.
13.4 Restriction: you may request that we only store the data.
13.5 Data portability: you may request your provided data and your Content in machine-readable form, or request their transfer to another data controller.
13.6 Objection: Sections 15 and 16.
How? Write to the address given in Section 1, from your account’s email address; you do not need to give reasons. We reply within one month, free of charge.
14. No research exception
We do not restrict your rights on account of the research purpose either.
15. Objection – prominent information
⚠ YOU MAY OBJECT AT ANY TIME
You may object at any time to processing based on our legitimate interest (Article 21 GDPR), in particular to the use for research and AI purposes, the location-based observation and the handover to a partner.
How? Write to the address given in Section 1. You do not need to give reasons, and it is free of charge.
What happens next? Pending the assessment, we suspend the processing. After that, we continue processing that is not for research purposes only on compelling legitimate grounds or for a legal claim.
We always comply with an objection for research purposes (Section 15.1), as we do with an objection to direct marketing (newsletter, supporter content).
15.1 Objection for research purposes
We comply with an objection for research purposes in every case, without any balancing of interests.
16. Consequence of the objection
We remove your Content from the training and test data, we do not include it in any new handover, and we notify the earlier recipient. Every function of the Service remains available.
17. Remedies
You may lodge a complaint with the supervisory authority:
| Name | Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH) |
| Postal address | 1363 Budapest, Pf.: 9. (registered office: 1055 Budapest, Falk Miksa utca 9-11.) |
| Telephone | +36 (1) 391-1400 |
| ugyfelszolgalat@naih.hu | |
| Website | https://naih.hu/ |
You may also apply to a court, including the regional court of your place of residence, and you may be entitled to compensation for damage or to compensation for non-material harm.
18. Personal data breach
We record every breach in a register; in the event of a risk, we notify it to the NAIH within 72 hours, and in the case of a high risk we also inform the data subjects.
19. Plant health – the Service is NOT an official notification
Uploaded Content is not an official notification, and it does not release you from the obligation to notify (Section 10 of the Terms and Conditions).
A ‘suspicious’ assessment may have economic consequences, which is why we treat the location confidentially. We do not automatically forward a suspicion signal not confirmed by the authority; we hand over data to an authority, including the laboratory result, only under a statutory obligation (row 6.14).
19.1 If it is not your land that is concerned
Someone else (a user, a Surveyor, a laboratory, an authority or a partner) may also record data about your vineyard (image, location, parcel identifier, observation, laboratory result); in that case, they are the source of the data. The location may lead to the land; we process it for plant-health observation and research, on the basis of legitimate interest (row 6.3). If you manage the vineyard in your account, you also see the laboratory result of your vines (Section 5.2). If you do not manage the vineyard in your account, we typically do not know you, and tracing you would be disproportionate, so we inform you here (Article 14(5)(b) GDPR): you may ask whether there are data that can be linked to your land, you may request their deletion at info@fdfinder.org, and you may lodge a complaint with the NAIH.
20. Age limit
The Service is for persons over 18; we verify age by self-declaration. We terminate the account of a person under 18 and delete his or her data.
21. Amendment of the Notice
Every version receives a version number, an effective date and a hash. The manner of acceptance is the same as for the Terms and Conditions (Section 15.4 of the Terms and Conditions): we ask for express acceptance if the licence or the research clause is extended, or if the change is significant (a new processing operation or data transfer, or a material change in the operation); we notify you of every other amendment by email at least 15 days in advance. For a new processing operation requiring consent, we ask for separate consent. We never extend the scope of use for research and AI purposes by unilateral amendment.
22. Handover of data for marketing purposes – excluded
We do not hand over personal data to anyone for marketing purposes, not to the supporters either; the exception is the delivery of a prize (Section 8.3). The supporter may receive only aggregated figures, with the suppression of groups of fewer than 10 people.
Version 3.6 – DrinkCycle Development Kft. We keep a record of the hashes of the earlier versions.