Privacy policy

Introduction

The Neves Kor-Társ Ltd.  (1054 Budapest Hold u.15. III.floor 7., tax number: 14153211-2-41, company registration number: 01-09-891310) (hereinafter referred to as the "Service Provider" or "Controller") is subject to the following policy:

The following information is provided pursuant to REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Regulation (EC) No 95/46/EC (General Data Protection Regulation).

This Privacy Policy governs the processing of data on the following sites: https://vandorfeny.hu

The privacy policy is available at: https://vandorfeny.hu

Amendments to the Rules will enter into force upon publication at the above address.

Data controller and contact details

Name: Neves Kor-Társ Kft.

Head office: 1054 Budapest Hold u.15. III.floor 7.

E-mail: info@vandorfeny.hu

Phone: +36 20 915 60 76, +36 1 267 52 62

 

Definitions of terms

 

1. "personal data": any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
2. "data management": any operation or set of operations which is performed upon personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
3. "data controller": 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; where the purposes and means of the processing are determined by Union or Member State law, the controller or the specific criteria for the controller's designation may also be determined by Union or Member State law;
4. "data processor": a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller;
5. "addressed to": the natural or legal person, public authority, agency or any other body with whom or to which the personal data are disclosed, whether or not a third party. Public authorities which may have access to personal data in the context of an individual investigation in accordance with Union or Member State law are not recipients; the processing of those data by those public authorities must comply with the applicable data protection rules in accordance with the purposes of the processing;
6. "consent of the data subject": a freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she signifies, by a statement or by an act expressing his or her unambiguous consent, that he or she gives his or her consent to the processing of personal data concerning him or her;
7. "data breaches": a breach of security that results in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Principles governing the processing of personal data

Personal data:

1. is carried out lawfully and fairly and in a transparent manner for the data subject ("legality, fairness and transparency");
2. collected only for specified, explicit and legitimate purposes and not processed in a way incompatible with those purposes; further processing for archiving purposes in the public interest, scientific and historical research purposes or statistical purposes shall not be considered incompatible with the original purpose in accordance with Article 89(1) ("purpose limitation");
3. be adequate, relevant and limited to what is necessary for the purposes for which the data are processed ("data saving");
4. 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 for which they are processed are erased or rectified without undue delay ("Accuracy");
5. be kept 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 kept for longer periods only if the personal data are processed for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1), subject to the implementation of appropriate technical and organisational measures as provided for in this Regulation to safeguard the rights and freedoms of data subjects ("limited shelf life");
6. be carried out in such a way as to ensure adequate security of personal data, including protection against unauthorised or unlawful processing, accidental loss, destruction or damage, by using appropriate technical or organisational measures ("integrity and confidentiality").

The controller is responsible for compliance with the above and must be able to demonstrate such compliance ("accountability").

The controller declares that its processing will be carried out in accordance with the principles set out in this point.

Data processing related to the operation of the webshop/use of the service

1. The fact of collection, the scope of the data processed and the purpose of the processing:

Personal data	Purpose of data processing	Legal basis
User name	Identification, enabling registration.	Article 6(1)(b) GDPR and Section 13/A(3) of the Elker Act.
Password	It is used for secure access to the user account.
Surname and first name	It is necessary to contact you, to make a purchase, to issue a proper invoice, to exercise the right of withdrawal.
E-mail address	Staying in touch.
Phone number	Keeping in touch with you, to coordinate more efficiently on billing or delivery issues.
Billing name and address	To issue proper invoices, and to create, define, amend, monitor the performance of, invoice the fees arising from, and enforce the claims related to the contract.	Article 6(1)(c) and Article 169(2) of Act C of 2000 on Accounting
Delivery name and address	Enabling home delivery.	Article 6(1)(b) GDPR and Section 13/A(3) of the Elker Act.
Date of purchase/registration	Perform a technical operation.
IP address at the time of purchase/registration	Perform a technical operation.

Neither the username nor the e-mail address need to contain personal data.

2. Data subjects: all data subjects registered/customers of the webshop website.
3. Duration of processing, time limit for erasure of data: if one of the conditions of Article 17(1) of the GDPR is met, until the data subject's request for erasure. The controller shall inform the data subject of the erasure of any personal data provided by the data subject by electronic means pursuant to Article 19 of the GDPR. If the data subject's request for erasure also includes the e-mail address provided by him or her, the controller shall erase the e-mail address following the notification. Except in the case of accounting records, since pursuant to Article 169 (2) of Act C of 2000 on Accounting, these data must be kept for 8 years. The contractual data of the data subject may be deleted after the expiry of the civil law limitation period on the basis of a request for deletion by the data subject.

The accounting documents (including general ledger accounts, analytical or detailed records) directly and indirectly supporting the accounting accounts must be kept for at least 8 years in a legible form, retrievable by reference to the accounting records.

4. Potential controllers of the data, recipients of the personal data: personal data may be processed by the sales and marketing staff of the controller, in compliance with the above principles.
5. Description of data subjects' rights in relation to data processing:

• The data subject may request the controller to access, rectify, erase or restrict the processing of personal data relating to him or her, and
• the data subject has the right to data portability and the right to withdraw consent at any time.

6. The data subject may request access to, deletion, modification or restriction of processing of personal data, or the portability of data in the following ways:

• by post to Neves Kor-Társ Kft., 1054 Budapest Hold u.15. III.emelet 7.
• by e-mail at info@vandorfeny,
• by phone on +36 1 267 52 62, +36 20 915 60 76.

7. Legal basis for processing:
8. Article 6(1)(b) and (c) of the GDPR,
9. Paragraph 13/A (3) of Act CVIII of 2001 on certain issues of electronic commerce services and information society services (hereinafter: Elker Act):

The service provider may process personal data that are technically necessary for the provision of the service. The provider must, other conditions being equal, choose and in any case operate the means used in the provision of the information society service in such a way that personal data are processed only to the extent strictly necessary for the provision of the service and for the fulfilment of the other purposes laid down in this Act, but only to the extent and for the duration necessary.

3. If an invoice is issued in accordance with accounting legislation, Article 6(1)(c).
4. In the event of enforcement of claims arising from the contract, the period of limitation is 5 years pursuant to § 6:21 of Act V of 2013 on the Civil Code.

§ 6:22 [Limitation period]

(1) Unless otherwise provided by this Act, claims shall be barred after five years.

(2) The limitation period shall begin to run when the claim becomes due.

(3) The agreement to change the limitation period must be in writing.

(4) An agreement excluding the statute of limitations shall be null and void.

8. Please note that

• processing for the performance of a contract and necessary to make an offer.
• obligedprovide personal data so that we can fulfil your order.
• the failure to provide the data is due to with consequences means that we cannot process your order.

Data processors and recipients used

Shipping

1.  Activity performed by the data processor: delivery of products, transport
2.  Name and contact details of the data processor: Magyar Posta Zrt. Hungarian Postal Service.
3.  The fact of processing, the scope of the data processed: delivery name, delivery address, telephone number, e-mail address.
4.  Stakeholders: all stakeholders who request a home delivery.
5.  Purpose of data processing: delivery of the ordered product to your home.
6.  Duration of processing, deadline for deletion of data: until the delivery is completed.
7.  Legal basis for processing: Article 6(1)(b).

Hosting provider

1.  Activity provided by the data processor: Hosting
2.  Name and contact details of the data processor:
   • Név: MikroVPS Kft
   • Székhely: 7150
   • Bonyhád, Jókai u 3.
   • E-mail: support@mikrovps.hu
   • Telefon: +36307564514

3.  Fact of processing, scope of data processed: all personal data provided by the data subject.
4.  Data subjects: all data subjects using the website.
5.  Purpose of data processing: to make the website available and to ensure its proper operation.
6. Duration of data processing, deadline for deletion of data: until the termination of the agreement between the data controller and the hosting provider or until the data subject's request for deletion to the hosting provider.
7.  Legal basis for processing: Article 6(1)(b).

Other data processors (if any)

THE RECIPIENTS TO WHOM THE PERSONAL DATA ARE DISCLOSED (TRANSFER):

Online payment

1.  Activity provided by the Recipient: online payment
2.  Name and contact details of the addressee:

OTP Mobil Kft. (1093 Budapest, Közraktár u. 30-32.)

3.  Fact of processing, scope of data processed: billing data, name, e-mail address
4.  Data subjects: all data subjects who choose to pay on the website.
5.  Purpose of the processing: to process online payments, confirm transactions and perform fraud-monitoring to protect users.
6.  Duration of processing, deadline for deletion of data: until the online payment is completed.
7.  Legal basis for processing: article 6(1)(b) GDPR. Processing at the request of the data subject
   is required to make an online payment.
8.  Rights of the data subject:
9.  You can find out about the circumstances of data processing,
   b. You have the right to receive feedback from the controller on whether the processing of your personal data
   is in progress or has access to all information relating to the processing.
   c. You have the right to have your personal data processed in a structured, commonly used, machine-readable
   in the format.
   d. You have the right to obtain, at your request and without undue delay, the rectification by the controller of inaccurate or incomplete
   your personal data.

Cookie management (cookies)

1. The use of the so-called "password-protected session cookies", "shopping cart cookies", "security cookies", "essential cookies", "functional cookies" and "cookies responsible for the management of website statistics" does not require prior consent from the data subject.
2. Fact of processing, scope of data processed: unique identifier, dates, times
3. Data subjects: all data subjects visiting the website.
4. Purpose of processing: to identify users and track visitors.
5. Duration of data processing, deadline for deletion of data:

Type of cake	Legal basis for data processing	Data management Duration
Session cookies (session)	Act CVIII of 2001 on certain issues of electronic commerce services and information society services (Elkertv.), Section 13/A (3)	The relevant until the end of the visitor session lasting period
Permanent or saved cookies	Act CVIII of 2001 on certain issues of electronic commerce services and information society services (Elkertv.), Section 13/A (3)	until the deletion of the data subject
Statistical cookies	Act CVIII of 2001 on certain issues of electronic commerce services and information society services (Elkertv.), Section 13/A (3)	1 month - 2 years

6. Identity of the potential data controllers who may access the data: no personal data is processed by the data controller through the use of cookies.
7. Description of data subjects' rights in relation to data processing: data subjects have the possibility to delete cookies in the Tools/Preferences menu of their browsers, usually under the Privacy settings.
8. Legal basis for processing: no consent is required from the data subject where the sole purpose of the use of cookies is to provide a communication over an electronic communications network or where the service provider strictly needs the cookies to provide an information society service explicitly requested by the subscriber or user.
9. Most browsers used by our users allow you to set which cookies should be saved and allow (certain) cookies to be deleted again. If you restrict the saving of cookies on specific websites or do not allow third party cookies, this may in certain circumstances lead to our website no longer being fully usable. Here you will find information on how to customise your cookie settings for standard browsers:

Google Chrome (https://support.google.com/chrome/answer/95647?hl=hu)

Internet Explorer (https://support.microsoft.com/hu-hu/help/17442/windows-internet-explorer-delete-manage-cookies)

Firefox (https://support.mozilla.org/hu/kb/sutik-engedelyezese-es-tiltasa-amit-weboldak-haszn

Safari (https://support.apple.com/kb/PH21411?locale=hu_HU)

Using Google Ads conversion tracking

1. The data controller uses the online advertising program "Google Ads" and makes use of Google's conversion tracking service within its framework. Google Conversion Tracking is an analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; "Google").
2. When you visit a website through a Google ad, a cookie is placed on your computer for conversion tracking. These cookies have a limited validity and do not contain any personal data, so they do not identify the User.
3. When the User browses certain pages of the website and the cookie has not expired, Google and the data controller may see that the User has clicked on the advertisement.
4. Each Google Ads client receives a different cookie, so they cannot be tracked through Ads clients' websites.
5. The information, which is obtained through the use of conversion tracking cookies, is used to provide conversion statistics for Ads' customers who choose to track conversions. Customers are then informed of the number of users who click on their ad and are referred to a page with a conversion tracking tag. However, they do not have access to information that would allow them to identify any user.
6. If you do not wish to participate in conversion tracking, you can opt-out by disabling the option to set cookies in your browser. You will then not be included in the conversion tracking statistics.
7. Further information and Google's privacy statement can be found on the following page:  google.com/policies/privacy/

 

Using Google Analytics

1. This website uses Google Analytics, a web analytics service provided by Google Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site you have visited.
2. The information generated by the cookies on the website used by the User is usually transferred to a Google server in the USA and stored there. By activating the IP anonymisation on the website, Google will previously shorten the IP address of the User 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 a Google server in the USA and shortened there only in exceptional cases. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity for the website operator and to provide other services relating to website activity and internet usage.
4. The IP address transmitted by the User's browser within the framework of Google Analytics will not be merged with other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You may also prevent Google from collecting and processing information about your use of this website (including your IP address) by means of cookies by downloading and installing the browser plug-in available at the following link. https://tools.google.com/dlpage/gaoptout?hl=hu

Newsletter, DM activity

1. Pursuant to Article 6 of Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Economic Advertising Activity, the User may expressly consent in advance to the Service Provider contacting him/her with advertising offers and other mailings at the contact details provided at the time of registration.
2. In addition, the Customer may, subject to the provisions of this notice, consent to the processing of personal data by the Service Provider necessary for the sending of advertising offers.
3. The Service Provider will not send unsolicited commercial messages and the User may unsubscribe from receiving offers without any restriction and without giving any reason, free of charge. In this case, the Service Provider will delete all personal data necessary for sending advertising messages from its records and will not contact the User with further advertising offers. The User may unsubscribe from advertising by clicking on the link in the message.
4. The fact of data collection, the scope of the data processed and the purpose of processing:

Personal data	Purpose of data processing	Legal basis
Name, e-mail address.	Identification, to enable subscription to the newsletter/special offers.	Consent of the data subject, Article 6(1)(a). Article 6 (5) of Act XLVIII of 2008 on the Basic Conditions and Certain Limitations of Economic Advertising Activities.
Date of subscription	Perform a technical operation.
IP address at the time of subscription	Perform a technical operation.

5. Data subjects: all data subjects who subscribe to the newsletter.
6. Purpose of processing: sending electronic messages (e-mail, SMS, push messages) containing advertising to the data subject, providing information about current information, products, promotions, new features, etc.
7. Duration of data processing, deadline for deletion of data: data processing lasts until the consent is withdrawn, i.e. until unsubscription.
8. Potential controllers of the data, recipients of the personal data: personal data may be processed by the sales and marketing staff of the controller, in compliance with the above principles.
9. Description of data subjects' rights in relation to data processing:

• The data subject may request the controller to access, rectify, erase or restrict the processing of personal data relating to him or her, and
• object to the processing of your personal data; and
• the data subject has the right to data portability and the right to withdraw consent at any time.

10. The data subject may request access to, erasure, modification or restriction of processing of personal data, portability of data or objection to the processing of personal data by:

• by post to 1054 Budapest Hold u. 15. III.floor 7,
• by e-mail to info@vandorfeny.hu by e-mail,
• by phone on +36 1 267 52 62, +36 20 915 60 76.

11. The person concerned at any time,subscribe free of chargeabout the newsletter.
12. Please note that

• the processing is based on your consent and the legitimate interest of the service provider 
• obligedprovide personal data if you wish to receive newsletters from us.
• the failure to provide the data is due to with consequences we are unable to send you a newsletter.
• please note that you can withdraw your consent at any time by clicking on the unsubscribe button.
• withdrawal of consent does not affect the lawfulness of processing based on consent prior to withdrawal.

Complaints handling

1. The fact of data collection, the scope of the data processed and the purpose of processing:

Personal data	Purpose of data processing	Legal basis
Surname and first name	Identification, contact.	Article 6(1)(c) and Article 17/A(7) of Act CLV of 1997 on Consumer Protection.
E-mail address	Staying in touch.
Phone number	Staying in touch.
Billing name and address	Identifying, handling quality complaints, questions and problems with the products ordered.

2. Data subjects: all data subjects who shop on the website and complain about quality.
3. Duration of data processing, deadline for deletion of data: copies of the record, transcript and reply to the objection shall be kept for 5 years pursuant to Article 17/A (7) of Act CLV of 1997 on Consumer Protection.
4. Potential controllers of the data, recipients of the personal data: personal data may be processed by the sales and marketing staff of the controller, in compliance with the above principles.
5. Description of data subjects' rights in relation to data processing:

• The data subject may request the controller to access, rectify, erase or restrict the processing of personal data relating to him or her, and
• the right to data portability and the right to withdraw consent at any time

6. The data subject may request access to, deletion, modification or restriction of processing of personal data, or the portability of data in the following ways:

• by post to 1054 Budapest Hold u. 15. III.floor 7,
• by e-mail to info@vandorfeny.hu,
• by phone on +36 267 52 62, +36 20 915 60 76.

7. Please note that

• the provision of personal data legal obligations
• the conclusion of the contract prerequisitethe processing of personal data.
• obligedprovide personal data so that we can handle your complaint.
• the failure to provide the data is due to with consequences we are unable to deal with the complaint you have received.

 

Community sites

1. The fact of data collection, the scope of data processed: the name registered on Facebook/Twitter/Pinterest/Youtube/Instagram, etc. social networking sites, and the user's public profile picture.
2. The data subjects are: all data subjects who have registered on Facebook/Twitter/Pinterest/Youtube/Instagram etc. social networking sites and have "liked" the Service Provider's social networking site or contacted the data controller via the social networking site.
3. Purpose of data collection: to share, "like", follow or promote certain content, products, promotions or the website itself on social networking sites.
4. Duration of data processing, time limit for deletion of data, the identity of the possible controllers entitled to access the data and the rights of the data subjects in relation to data processing: the data subject can find out about the source of the data, the processing of the data and the method and legal basis of the transfer on the relevant Community site. The data are processed on the social networking sites, so the duration of the processing, the way in which the data are processed and the possibilities for deleting and modifying the data are governed by the rules of the social networking site concerned.
5. Legal basis for 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 management

1. If the data subject has any questions or problems when using our services, he or she can contact the data controller using the methods provided on the website (telephone, e-mail, social networking sites, etc.).
2. The Data Controller will delete the data provided in e-mails, messages, telephone, Facebook, etc., together with the name and e-mail address of the interested party and other personal data voluntarily provided by the interested party, after a maximum of 2 years from the date of the communication.
3. We will provide information on data processing not listed in this notice at the time of collection.
4. In exceptional cases, the Service Provider shall be obliged to provide information, disclose data, hand over data or make documents available upon request of a public authority or other bodies authorised by law.
5. In such cases, the Service Provider will disclose personal data to the requesting party only to the extent and to the extent strictly necessary for the purpose of the request, provided that the requesting party has indicated the exact purpose and scope of the data.

Rights of data subjects

1. Right of access

You have the right to receive feedback from the controller as to whether or not your personal data are being processed and, if such processing is taking place, you have the right to access your personal data and the information listed in the Regulation.

2. The right to rectification

You have the right to have inaccurate personal data relating to you corrected by the controller without undue delay at your request. Taking into account the purpose of the processing, you have the right to request the completion of incomplete personal data, including by means of a supplementary declaration.

3. The right to erasure

You have the right to have personal data concerning you erased by the controller without undue delay at your request, and the controller is obliged to erase personal data concerning you without undue delay under certain conditions.

4. The right to be forgotten

If the controller has disclosed the personal data and is required to delete it, it will take reasonable steps, including technical measures, taking into account the available technology and the cost of implementation, to inform the controllers that process the data that you have requested the deletion of the links to or copies of the personal data in question.

 

5. Right to restriction of processing

You have the right to have the controller restrict processing at your request if one of the following conditions is met:

• You contest the accuracy of the personal data, in which case the restriction applies for the period of time that allows the controller to verify the accuracy of the personal data;
• the processing is unlawful and you object to the deletion of the data and instead request the restriction of their use;
• the controller no longer needs the personal data for the purposes of processing, but you require them for the establishment, exercise or defence of legal claims;
• you have objected to the processing; in this case, the restriction applies for the period until it is established whether the controller's legitimate grounds prevail over your legitimate grounds.

6. The right to data portability

You have the right to receive the personal data concerning you that you have provided to a controller in a structured, commonly used, machine-readable format and the right to transmit these data to another controller without hindrance from the controller to whom you have provided the personal data (...)

7. The right to protest

In the case of processing based on legitimate interest or public authority as legal grounds, you have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data by (...), including profiling based on these provisions.

8. Objection in the case of direct acquisition

Where personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such purposes, including profiling, where it is related to direct marketing. If you object to the processing of your personal data for direct marketing purposes, your personal data may no longer be processed for those purposes.

 

 

9. Automated decision-making on individual cases, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which would have legal effects concerning you or similarly significantly affect you.

The preceding paragraph shall not apply in the case where the decision:

• necessary for the conclusion or performance of a contract between you and the controller;
• is permitted by Union or Member State law applicable to the controller which also lays down appropriate measures to protect your rights and freedoms and legitimate interests; or
• Based on your explicit consent.

Deadline for action

The controller shall, without undue delay and in any event from the date of receipt of the request. within 1 month inform you of the action taken on these requests.

If necessary, this may be extended by 2 months. The data controller shall inform the applicant of the extension of the time limit, stating the reasons for the delay, within within 1 month will inform you.

If the controller does not act on your request, inform you of the reasons for non-action without delay and at the latest within one month of receipt of the request, and that you can lodge a complaint with a supervisory authority and exercise your right to judicial redress.

Security of data processing

The controller and the processor shall implement appropriate technical and organisational measures, taking into account the state of the art and the cost of implementation, the nature, scope, context and purposes of the processing and the varying degrees of probability and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of data security appropriate to the level of risk, including, where appropriate:

1. the pseudonymisation and encryption of personal data;
2. the continued confidentiality, integrity, availability and resilience of the systems and services used to process personal data;
3. in the event of a physical or technical incident, the ability to restore access to and availability of personal data in a timely manner;
4. a procedure to test, assess and evaluate regularly the effectiveness of the technical and organisational measures taken to ensure the security of processing.
5. Processed data must be stored in a way that does not allow unauthorised access. In the case of paper-based data carriers, by establishing physical storage and filing arrangements, and in the case of data in electronic form, by using a centralised access management system.
6. The method of storing the data by computerised means must be chosen in such a way that they can be erased, also taking into account any different erasure deadline, at the end of the erasure deadline or if otherwise necessary. Erasure shall be irreversible.
7. Paper-based data media should be destroyed by shredding or by using an external organisation specialised in shredding. In the case of electronic data media, physical destruction and, where necessary, prior secure and irretrievable deletion of the data shall be ensured in accordance with the rules on the disposal of electronic data media.
8. The controller will take the following specific data security measures:

In order to ensure the security of personal data processed on paper, the Service Provider applies the following measures (physical protection):

1. Store the documents in a secure, lockable, dry place.
2. Where personal data processed on paper are digitised, the rules applicable to digitally stored documents apply
3. The Service Provider's employee performing data processing may leave the premises where data processing is taking place only by locking the data carriers entrusted to him or by locking the given premises.
4. Personal data can only be accessed by authorised persons and cannot be accessed by third parties.
5. The Service Provider's building and premises are equipped with fire and property protection equipment.

IT security

1. Computers and mobile devices (other data carriers) used in the course of data processing are the property of the Service Provider.
2. The computer system containing personal data used by the Service Provider is protected against viruses.
3. To ensure the security of digitally stored data, the Service Provider uses data backups and archiving.
4. Access to the central server machine is only allowed to authorised and designated persons.
5. Access to data on computers is only possible with a username and password.

Informing the data subject about the personal data breach

If the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, the controller shall inform the data subject without undue delay.

In the information given to the data subject in a clear and understandable way describe the nature of the personal data breach and provide the name and contact details of the Data Protection Officer or other contact person who can provide further information; describe the likely consequences of the personal data breach; describe the measures taken or envisaged by the controller to remedy the personal data breach, including, where appropriate, measures to mitigate any adverse consequences of the personal data breach.

The data subject need not be informed if any of the following conditions are met:

• the data controller has implemented appropriate technical and organisational protection measures and these measures have been applied to the data affected by the personal data breach, in particular measures, such as the use of encryption, which render the data unintelligible to persons not authorised to access the personal data;
• the controller has taken additional measures following the personal data breach to ensure that the high risk to the rights and freedoms of the data subject is no longer likely to materialise;
• information would require a disproportionate effort. In such cases, the data subjects should be informed by means of publicly disclosed information or a similar measure should be taken to ensure that the data subjects are informed in an equally effective manner.

If the controller has not yet notified the data subject of the personal data breach, the supervisory authority may, after having considered whether the personal data breach is likely to present a high risk, order the data subject to be informed.

Reporting a data protection incident to the authority

The data protection incident shall be notified by the controller to the supervisory authority competent under Article 55 without undue delay and, where possible, no later than 72 hours after the data protection incident has come to its attention, unless the data protection incident is unlikely to pose a risk to the rights and freedoms of natural persons. If the notification is not made within 72 hours, it shall be accompanied by the reasons justifying the delay.

Review in case of mandatory data processing

If the duration of the mandatory processing or the periodic review of its necessity is not specified by law, local government regulation or a binding legal act of the European Union, the controller shall review, at least every three years from the start of processing, whether the processing of personal data processed by the controller or by a processor acting on its behalf or under its instructions is necessary for the purposes of the processing.

The controller shall document the circumstances and the results of this review and keep this documentation for ten years after the review has been carried out. and shall make it available to the Authority upon request by the National Authority for Data Protection and Freedom of Information (hereinafter "the Authority").

Complaint possibility

Complaints against possible infringements by the data controller can be lodged with the National Authority for Data Protection and Freedom of Information:

National Authority for Data Protection and Freedom of Information

1125 Budapest, Szilágyi Erzsébet fasor 22/C.

Postal address: 1530 Budapest, P.O. Box 5.

Phone: +36 -1-391-1400

Fax: +36-1-391-1410

E-mail: ugyfelszolgalat@naih.hu

 

Closing words

In preparing this information, we have taken into account the following legislation:

• REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Regulation (EC) No 95/46/EC (General Data Protection Regulation) (GDPR) (27 April 2016)
• Act CXII of 2007 on the Right to Informational Self-Determination and Freedom of Information (hereinafter: Infotv.)
• Act CVIII of 2007 - on certain aspects of electronic commerce services and information society services (in particular § 13/A)
• Act XLVII of 2007 - on the prohibition of unfair commercial practices against consumers;
• Act XLVIII of 2007 - on the basic conditions and certain restrictions on economic advertising (in particular § 6)
• Act XC of 2007 on the freedom of electronic information
• Act C of 2006 on electronic communications (specifically § 155)
• Opinion No 16/2011 on the EASA/IA Recommendation on best practice on behavioural online advertising
• Recommendation of the National Authority for Data Protection and Freedom of Information on the data protection requirements for prior information