Privacy Policy for USA Medical

INTRODUCTION

EB Partner LLC, operating as USA Medical, submits itself to the following prospectus.

This privacy statement governs the privacy of the following pages:
https://usamedicalshop.com/

DEFINITIONS

1. “personal data” shall mean any information relating to an identified or identifiable natural person (“data subject”); identifies a natural person who, directly or indirectly, in particular by reference to an identifier such as name, number, location, online identifier or one or more factors relating to the physical, physiological, genetic, mental, economic, cultural or social identity of the natural person identifiable;
2. “processing” means any operation or set of operations on personal data or files, whether automated or non-automated, such as collection, recording, systematization, sorting, storage, transformation or alteration, retrieval, consultation, use, communication, transmission or dissemination; by other means of access, coordination or interconnection, restriction, deletion or destruction;
3. “controller” means the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data; if the purposes and means of data management are determined by Union or Member State law, the controller or the specific criteria for the designation of the controller may also be determined by Union or Member State law;
4. “processor” means any natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller;
5. “recipient” means a natural or legal person, public authority, agency or any other body to whom personal data are communicated, whether a third party or not. Public authorities that may have access to personal data in the context of an individual investigation in accordance with Union or Member State law shall not be considered as recipients; the processing of such data by these public authorities must comply with the applicable data protection rules in accordance with the purposes of the processing;
6. “data subject’s consent” means the voluntary, specific and duly informed and unambiguous statement of the data subject’s intention, by means of a statement or unequivocal statement of consent, to consent to the processing of personal data concerning him or her;
7. “data protection incident” means a breach of security resulting in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or unauthorized access to, personal data which have been transmitted, stored or otherwise handled.

PRINCIPLES FOR THE PROCESSING OF PERSONAL DATA

Personal data:
(a) must be processed lawfully and fairly and in a manner which is transparent to the data subject (“lawfulness, due process and transparency”);
(b) collected for specified, explicit and legitimate purposes and not treated in a way incompatible with those purposes; further processing for data purposes for archiving in the public interest, for scientific and historical research purposes or for statistical purposes (“purpose limitation”) shall not be considered incompatible with the original purpose in accordance with Article 89 (1);
(c) be appropriate and relevant to the purposes for which the data are processed and limited to what is necessary (“data economy”);
(d) be accurate and, where necessary, kept up to date; all reasonable steps must be taken to ensure that personal data which are inaccurate for the purposes of the processing are erased or rectified without delay (“accuracy”);
(e) stored in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for a longer period only if the personal data are processed in accordance with Article 89 (1) for archiving in the public interest, for scientific and historical research purposes or for statistical purposes, in accordance with this Regulation; subject to the implementation of appropriate technical and organizational measures to protect its freedoms (“limited storage capacity”);
(f) processed in such a way as to ensure the adequate security of personal data, including protection against unauthorized or unlawful processing, accidental loss, destruction or damage to personal data (“integrity and confidentiality”), using appropriate technical or organizational measures.
The controller is responsible for compliance with the above and must be able to demonstrate such compliance (“accountability”).

DATA MANAGEMENT

WEBSHOP OPERATION-RELATED DATA MANAGEMENT
1. Fact of data collection, scope of data processed and purpose of data management:
Pesonal Data
Purpose of data management
Legal basis
Password
Provides secure access to the user account.
Name and surname
It is necessary for contacting us, making a purchase, issuing a regular invoice, exercising the right of withdrawal.
Article 6 (1) (b) of the GDPR and Elker tv. 13 / A.
§ (3).
E-mail adress
Communication
Phone number
Contact, invoicing, shipping issues coordination.
Or better communicati
on
Billing name and address
Issuance of a regular invoice, as well as creation of the contract, determination of its content, modification, monitoring of its fulfillment, invoicing of the resulting fees, and related receivables
validation.
Article 6 (1)
(c) and Act C of 2000 on Accounting
§ 169 (2)
paragraph
Delivery name and address
The IP at the time of purchase / registration
title
To make delivery to home possible
Article 6 (1) (b) of the GDPR and Elker
tv. 13 / A. § (3).
Date of purchase / registration
Technical processing
Operation
Technical processing
Operation
Email address does not need to contain personal information.
2. Stakeholders: All stakeholders registered / buyers on the web-shop website.
3. Duration of data management, deadline for deleting data: Immediately by deleting
the registration. The controller shall inform the data subject electronically pursuant to Article 19 of the GDPR of the deletion of any personal data provided by the data subject. If the data subject’s request for cancellation includes the e-mail address provided by the data subject, the data controller will also delete the e-mail address after the notification. Except in the case of accounting documents, as these data must be kept for 8 years pursuant to Section 169 (2) of Act C of 2000 on Accounting.
The accounting document (including general ledger accounts, analytical and detailed records) supporting the accounting accounts, directly and indirectly, must be kept in a legible form for at least 8 years, retrievable by reference to the accounting records.
4. Identity of potential data controllers entitled to access the data, recipients of personal data: Personal data may be processed by the data controller’s sales and marketing staff, respecting the above principles.
5. Description of data subjects’ rights in relation to data processing:
• The data subject may request from the controller access to, rectification or restriction of the processing of personal data concerning him or her, and
• The data subject has the right to data portability and to withdraw his or her consent at any time.
6. Access to, deletion, modification or restriction of the processing of personal data, portability of data, protest against data processing may be initiated by the data subject in the following ways:
– by post at 2040 Budaörs, Puskás Tivadar út 10. II. floor address,
– by e-mail to the e-mail address info@usamedical.hu,
– by phone at 70-410-2899.
7. Legal basis for data processing:
7.1. Article 6 (1) (b) of the GDPR,
7.2. Act CVIII of 2001 on certain issues of electronic commerce services and information society services. Act (hereinafter: Elker Act) 13 / A. § (3)
The service provider may process personal data that is technically necessary for the provision of the service in order to provide the service. If the other conditions are the same, the service provider must choose and in all cases operate the means used in the provision of the information society service in such a way that personal data is processed only if it is necessary for the provision of the service and other purposes specified in this Act, in this case only to the extent and for the time necessary.
7.3. Article 6 (1) (c) in the case of an invoice in accordance with accounting legislation.
7.4. In the case of enforcement of claims arising from the contract, Act V of 2013 on the Civil Code 6:21. § 5 years.
6:22. § [Limitation](1) Unless otherwise provided by this Act, claims shall lapse within five years. (2) The limitation period shall begin when the claim becomes due.
(3) An agreement to change the limitation period shall be in writing.
4. An agreement precluding limitation shall be null and void.

8. Please be informed that:
– The data management is necessary for the performance of the contract.
– Is required to provide personal information so that we can fulfill your order.
– Failure to provide information will result in the inability to process your order.
DATA PROCESSORS USED Shipping
1. Activity performed by data processor: Delivery of products, transportation
2. Name and contact details of the data processor:
GLS General Logistics Systems Hungary Csomag-Logismi Kft. 2351 Alsónémedi, Európa u. 2. info@gls-hungary.com Phone number: +36 1 802 0265
https://gls-group.eu/EN/hu/adatvedelmi-szabalyzat
3. The fact of data management, the scope of the managed data: Delivery name, delivery address, telephone number, e-mail address.
4. Stakeholders: All stakeholders requesting home delivery.
5. Purpose of data management: Home delivery of the ordered product.
6. Duration of data management, deadline for deleting data: It lasts until the home delivery is completed.
7. Legal basis for data processing: Article 6 (1) (b).

Hosting provider
1. Activity performed by data processor: Hosting service
2. Name and contact details of the data processor:
ELIN.hu Informatikai Szolgáltató és Tanácsadó Kft. Website: www.elin.hu
Head office: 9024 Győr, Déry T. u. 11. Phone: +36 70 297 4811
3. Fact of data processing, scope of data processed: All personal data provided by the data subject.
4. Stakeholders: All stakeholders who use the website.
5. The purpose of data management: To make the website available and to operate it properly.
6. Duration of data processing, deadline for deletion of data: The data processing lasts until the termination of the agreement between the data controller and the hosting provider or the data subject’s request for deletion to the hosting provider.
7. Legal basis for data processing: Article 6 (1) (c) and (f) and Article CVIII of 2001 on certain aspects of electronic commerce services and information society services. Act 13 / A. § (3). There is a legitimate interest in the proper operation of the website, protection against attacks and fraud.

MANAGING COOKIES

1. Web-shop-specific cookies are so-called “passwords used for password-protected sessions”, “shopping cart cookies” and “security cookies”, the use of which does not require the prior consent of the parties concerned.
2. The fact of data management, the scope of the managed data: Unique identification number, dates, times
3. Stakeholders: All stakeholders who visit the website.
4. Purpose of data management: To identify users, record the “shopping cart” and track visitors.
5. Duration of data processing, deadline for deleting data:
Cookie type
Session cookie
Legal basis for data management
The electronic trade
services,
and the information society
services some
on issues
2001. CVIII. law (Elkertv.) 13 / A. § (3)
Duration of data management
The period until the end of the relevant visitor session
Managed data set
connect.sid
6. Person of potential data controllers entitled to access the data: The data controller does not process personal data using cookies.
7. Description of the data subjects’ rights related to data management: The data subject has the possibility to delete cookies in the Tools / Settings menu of the browser, usually under the settings of the Privacy menu item.

8. Legal basis for data processing: The consent of the data subject is not required if the sole purpose of the use of cookies is the transmission of communications via an electronic communications network or the provision of an information society service specifically requested by the subscriber or user.
USING GOOGLE ADS CONVERSION TRACKING
1. An online advertising program called “Google Ads” is used by the data controller and uses Google’s conversion tracking service. Google Conversion Tracking is an analytics service provided by Google Inc. (1600 Amphitheater Parkway, Mountain View, CA 94043, USA; “Google”).
2. When a User accesses a website via a Google ad, a cookie to track conversion is placed on their computer. These cookies have a limited validity and do not contain any personal data, so the User cannot be identified by them.
3. When the User browses certain pages of the website and the cookie has not yet expired, both Google and the data controller may see that the User has clicked on the advertisement.
4. Each Google Ads customer receives a different cookie, so they cannot be tracked through Ads customers’ websites.
5. The information obtained through conversion tracking cookies is used to generate conversion statistics for Ads conversion tracking customers. This is how customers find out the number of users who clicked on your ad and were redirected to a page with a conversion tracking tag. However, they do not have access to information that could identify any user.
6. If you do not wish to participate in conversion tracking, you can disable it by disabling cookies in your browser. You will then not be included in your conversion tracking statistics.
7. More information and Google’s privacy statement can be found at
www.google.de/policies/privacy/

APPLYING GOOGLE ANALYTICS

1. This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses so-called “cookies”, which are text files placed on your computer, to help the website analyse how users use the site.
2. The information created by the cookie about the website used by you will normally be stored and stored on a Google server in the USA. By activating IP anonymization on the Website, Google will abbreviate the User’s IP address within the Member States of the European Union or in other States party to the Agreement on the European Economic Area.
3. The full IP address will be transmitted to and truncated to Google’s server in the United States only in exceptional cases. On behalf of the operator of this website, Google will use this information to evaluate how the user has used the website, to provide the website operator with reports on website activity and to provide additional services related to website and internet usage.
4. Within the framework of Google Analytics, the IP address transmitted by the User’s browser is not reconciled with other data of Google. The User may prevent the storage of cookies by setting the appropriate browser, however, please note that in this case, not all functions of this website may be fully available. You may also prevent Google from collecting and processing your information about your use of the Website (including your IP address) by cookies by downloading and installing the browser plugin available at the following link. https://tools.google.com/dlpage/gaoptout?hl=en_US

NEWSLETTER, DM ACTIVITY

1. Act XLVIII of 2008 on the basic conditions and certain restrictions of economic advertising activity. Pursuant to Section 6 of the Act, the User may consent in advance and expressly to contact the Service Provider with his advertising offers and other items at the contact details provided during registration.
2. Furthermore, keeping in mind the provisions of this prospectus, the Customer may consent to the Service Provider handling the personal data necessary for sending advertising offers.
3. The Service Provider does not send unsolicited advertising messages, and the User may unsubscribe from sending offers free of charge without restriction or justification. In this case, the Service Provider deletes all personal data – necessary for sending advertising messages – from its register and does not contact the User with its further advertising offers. The user can unsubscribe from the ads by clicking on the link in the message.
4. Fact of data collection, scope of data processed and purpose of data management: Personal data Purpose of data management Legal basis
Name, e-mail adress
Identification, newsletter / discount coupons possible theorem.
The consent of the data subject,
Article 6 (1) (a). Act XLVIII of 2008 on the basic conditions
and certain restrictions of economic advertising activity.
Section 6 (5) of the Act
paragraph.
The IP address at the time of subscription
Performance of technical operation
Date of subscription
Performance of technical operation.
5. Stakeholders: All stakeholders who subscribe to the newsletter.
6. The purpose of data management: to send electronic messages containing advertising (e- mail, sms, push message) to the data subject, to provide information on current information, products, promotions, new features, etc.

7. Duration of the data processing, deadline for deleting the data: the data processing lasts until the withdrawal of the consent statement, i.e. until the un-subscription.
8. Identity of potential data controllers entitled to access the data, recipients of personal data: Personal data may be processed by the data controller’s sales and marketing staff, respecting the above principles.
9. Description of data subjects’ rights in relation to data processing:
• The data subject may request from the controller access to, rectification, erasure or
restriction of the processing of personal data concerning him or her, and • Object to the processing of such personal data, and
• The data subject has the right to data portability and to withdraw his or her consent at any time.
10. Access to, deletion, modification or restriction of the processing of personal data, portability of data, protest against data processing can be initiated by the data subject in the following ways:
– by post at 2040 Budaörs, Puskás Tivadar út 10. II. floor address,
– by e-mail to the e-mail address info@usamedical.hu,
– by phone at 70-410-2899.
11. The data subject may unsubscribe from the newsletter free of charge at any time. 12. Data processor used by the data controller:
MailChimp
The Rocket Science Group, LLC 675 Ponce de Leon Ave NE Suite 5000
Atlanta, GA 30308 USA privacy@mailchimp.com
13. Please be informed that
• Data management is based on your consent.
• Must provide personal information if you wish to receive a newsletter from us. • Failure to provide this will result in us not being able to send you a newsletter.
• The withdrawal of consent does not affect the consent-based, the lawfulness of data processing prior to withdrawal.

COMPLAINT HANDLING

1. Fact of data collection, scope of data processed and purpose of data management:
Personal data Data management purpose Legal basis
e-mail adress Communication
2. Stakeholders: All stakeholders who buy on the web-shop website and complain about quality complaints.
3. Duration of data processing, deadline for deletion of data: Copies of the recorded record, transcript and response to the objection are contained in CLV Act 1997 on Consumer Protection. Act 17 / A. § (7) shall be kept for 5 years.
4. Identity of potential data controllers entitled to access the data, recipients of personal data: Personal data may be processed by the data controller’s sales and marketing staff, respecting the above principles.
5. Description of data subjects’ rights in relation to data processing:
• The data subject may request from the controller access to, rectification, erasure or restriction of the processing of personal data concerning him or her, and
• Object to the processing of such personal data, and
• The data subject has the right to data portability and to withdraw his or her consent at any time.
Name and surname
Identification, communication
Article 6 (1) (c), and a CLV of 1997 on
consumer protection. Act 17 / A. § (7).
Phone number
Communication
Billing name and adress
Identification,quality objections, questions and problems related to the ordered products
and its treatment.

6. Access to, deletion, modification or restriction of the processing of personal data, portability of data, protest against data processing may be initiated by the data subject in the following ways:
– by post at 2040 Budaörs, Puskás Tivadar út 10,
– by e-mail to the e-mail address info@usamedical.hu, – by phone at 70-410-2899.
7. Please be informed that
• The provision of personal data is based on a contractual and legal obligation.
• The processing of personal data is a precondition for concluding a contract.
• Is required to provide personal information so that we can handle your complaint. • Failure to provide information has the consequence that we are unable to handle your complaint.

COMMUNITY SITES

1. The fact of data collection, the scope of the managed data: Facebook / Google + / Twitter / Pinterest / Youtube / Instagram, etc. registered name on social networking sites and the user’s public profile picture.
2. Stakeholders: All stakeholders who have registered on Facebook / Google + / Twitter / Pinterest / Youtube / Instagram, etc. social networking sites and “liked” the website
3. Purpose of data collection: On social networking sites, to share certain content elements, products, promotions or the website itself, or “Liking,” promoting it.
4. Duration of data processing, deadline for erasure of data, identity of potential data controllers entitled to access the data and description of data subjects’ rights related to data processing: The data subject may be informed about the source of data, their processing Data management is carried out on social networking sites, so the duration and method of data management, as well as the possibilities of deleting and modifying data are regulated by the given social networking site.
5. Legal basis for data processing: the data subject’s voluntary consent to the processing of his or her personal data on social networking sites.

CUSTOMER RELATIONS AND OTHER DATA PROCESSES

1. Should the data controller have any questions or problems during the use of our data controller services, he / she may contact the data controller in the ways provided on the website (telephone, e-mail, social networking sites, etc.).
2. Data controller for incoming e-mails, messages, phone, Facebook, etc. will delete the data provided together with the name and e-mail address of the interested party, as well as other personal data voluntarily provided, no later than 2 years after the communication.
3. We provide information on data processing not listed in this prospectus at the time of data collection.
4. Upon an exceptional official request, or in case of requesting other bodies based on the authorization of legislation, the Service Provider is obliged to provide information, communicate and hand over data, or make documents available.
5. In these cases, the Service Provider shall provide the requester with personal data only to the extent and to the extent that is absolutely necessary for the realization of the purpose of the request, provided that it has indicated the exact purpose and scope of the data.

RIGHTS OF STAKEHOLDERS

1. Right of access
You have the right to receive feedback from the controller as to whether your personal data is being processed and, if such processing is in progress, you have the right to access your personal data and the information listed in the Regulation.
2. Right to rectification
You have the right, at the request of the data controller, to correct inaccurate personal data concerning you without undue delay. Taking into account the purpose of the data processing, you have the right to request that the incomplete personal data be supplemented, inter alia, by means of a supplementary statement.
3. Right of cancellation
You have the right, at the request of the controller, to delete your personal data without undue delay, and the controller is obliged to delete your personal data without undue delay under certain conditions.
4. The right to be forgotten
If the controller has disclosed the personal data and is obliged to delete it, it shall take reasonable steps, including technical measures, taking into account the available technology and the costs of implementation, to inform the controllers that you have requested the personal data in question, deleting links or copies or duplicates of such personal data.
5. Right to restrict data processing
You have the right, at the request of the controller, to restrict the processing if one of the
following conditions is met:
• You dispute the accuracy of personal data, in which case the restriction applies to the period of time that allows the data controller to verify the accuracy of the personal data;

• The processing is unlawful and you oppose the deletion of the data and instead ask for a restriction on its use;
• The data controller no longer needs the personal data for the purpose of data processing, but you request them to make, enforce or protect legal claims;
• You objected to the data processing; in this case, the restriction applies for as long as it is established whether the legitimate reasons of the controller take precedence over your legitimate reasons.
6. The right to data portability
You have the right to receive personal data about you provided by you to a data controller in a structured, widely used machine-readable format and to transfer this data to another data controller without being hindered by the data controller, who provided personal data to him (…)
7. Right to protest
You have the right to object at any time to the processing of your personal data (…),
including profiling based on these provisions, for reasons related to your own situation. 8. Protest in case of direct business acquisition
If personal data is processed for the purpose of direct business acquisition, you have the right to object at any time to the processing of personal data concerning you for this purpose, including profiling, if it is related to direct business acquisition. If you object to the processing of personal data for the purpose of direct business acquisition, the personal data may no longer be processed for this purpose.
9. Automated decision making in individual cases, including profiling You have the right not to be covered by any automated data processing
– The scope of a decision based on profiling, including profiling, which would have legal effects or would be similarly significant for it.
The preceding paragraph shall not apply if the decision:
• Necessary for the conclusion or performance of a contract between you and the data controller;
• Is governed by EU or Member State law applicable to the controller, which also lays down appropriate measures to protect your rights and freedoms and legitimate interests; obsession
• Based on your express consent.

DEADLINE FOR ACTION

The controller shall inform you without undue delay, but in any case within 1 month of
receipt of the request, of the action taken on the above requests.
If necessary, it can be extended by 2 months. The data controller shall inform you of the extension of the deadline, indicating the reasons for the delay, within 1 month from the receipt of the request.
If the controller does not take action on your request, it will 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 can lodge a complaint with a supervisory authority and have a judicial remedy.

SECURITY OF DATA PROCESSING

The controller and the processor shall take appropriate technical and organizational measures to take into account the state of science and technology and the costs of implementation, as well as the nature, scope, circumstances and purposes of the processing and the varying likelihood and severity of risks to the rights and freedoms of natural persons to guarantee a level of data security commensurate with the degree of risk, including, inter alia, where appropriate:
a) The pseudonymisation and encryption of personal data;
(b) Ensuring the continued confidentiality, integrity, availability and resilience of the systems and services used to process personal data;
(c) In the event of a physical or technical incident, the ability to restore access to and availability of personal data in a timely manner;
(d) A procedure for the regular testing, assessment and evaluation of the effectiveness of the technical and organizational measures taken to ensure the security of data processing.
The site uses SSL encryption. The data is password protected and stored encrypted.
INFORMATION OF THE STAKEHOLDER ABOUT THE DATA PROTECTION INCIDENT
If the data protection incident is likely to pose a high risk to the rights and freedoms of natural persons, the controller shall inform the data subject of the data protection incident without undue delay. The information provided to the data subject shall clearly and intelligibly describe the nature of the data protection incident and the name and contact details of the data protection officer or other contact person who provided further information; the likely consequences of the data protection incident must be described; describe the measures taken or planned by the controller to remedy the data protection incident, including, where appropriate, measures to mitigate any adverse consequences arising from the data protection incident.
The data subject need not be informed if any of the following conditions are met:
• The controller 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 measures such as the use of encryption which make it incomprehensible to persons not authorized to access personal data the data;
• The controller has taken further measures following the data protection incident to ensure that the high risk to the data subject’s rights and freedoms is no longer likely to materialize;
• Information would require a disproportionate effort. In such cases, the data subject shall be informed through publicly available information or a similar measure shall be taken to ensure that the data subject is informed in an equally effective manner.
If the data controller has not yet notified the data subject of the data protection incident, the supervisory authority may, after considering whether the data protection incident is likely to involve a high risk, order that the data subject be informed.
REPORTING A DATA PROTECTION INCIDENT TO THE AUTHORITY
The data protection incident shall be reported by the controller to the supervisory authority competent under Article 55 without undue delay and, if possible, no later than 72 hours after becoming aware of the data protection incident, unless the data protection incident is not likely to jeopardize the rights of individuals and their freedoms. If the notification is not made within 72 hours, the reasons for the delay must be provided.

REVIEW IN THE EVENT OF MANDATORY DATA PROCESSING

If the duration of the mandatory data processing or the periodic review of the need for it is not specified by law, a local government decree or a binding legal act of the European Union, the data controller shall review at least every three years whether the processing of personal data is necessary for the purpose of data processing.
The circumstances and results of this review shall be documented by the controller, which shall keep this documentation for ten years after the review and shall make it available to the Authority upon request of the National Data Protection and Freedom of Information Authority (hereinafter: the Authority).

CONCLUSION

During the preparation of the prospectus, we took into account the following legislation:
– Regulation (EU) No 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of. On the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Regulation (EC) No. April 27)
– 2011 CXII. Act – on the right to information self-determination and freedom of information (hereinafter: Infotv.)
– CVIII of 2001 Act – on certain issues of electronic commerce services and services related to the information society (mainly Section 13 / A)
– XLVII of 2008 Act on the Prohibition of Unfair Commercial Practices against Consumers;
– XLVIII of 2008 Act – on the basic conditions and certain restrictions of commercial advertising (especially § 6)
– 2005 XC. Electronic Freedom of Information Act
– Act C of 2003 on Electronic Communications (specifically Section 155)
– 16/2011. s. Opinion on the EASA / IAB Recommendation on Best Practices for Behavioral Online Advertising
– Recommendation of the National Authority for Data Protection and Freedom of Information on data protection requirements for prior information