Privacy notice

 

Introduction

The COMPANY (hereinafter referred to as the “Service Provider” or “Controller”) is subject to the following information. The following information is provided in accordance with REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 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 95/46/EC (General Data Protection Regulation). This Privacy Notice governs the processing of data on the following pages: www.sapka-kalap-bolt.hu, The Privacy Notice is available at www.sapka-kalap-bolt.hu/adatvedelmi-nyilatkozat.

 

The controller and contact details:

Name: Barett Budapest Kft. Head office: 4024 Debrecen, Csapó utca 18. fsz1. Location/address for correspondence: 4024 Debrecen, Csapó utca 18. fsz1. Phone: +36302185252

Definitions of terms

  1. “personal data” means 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. “processing” means 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, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
  3. ‘controller’ means a 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 specific criteria for the designation of the controller may also be determined by Union or Member State law;
  4. “processor” means a 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 or with which personal data is 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. “the data subject’s consent” means a freely given, specific, informed and unambiguous indication of his or her wishes by which the data subject signifies, by a statement or by an act expressing his or her unambiguous consent, that he or she signifies his or her agreement to the processing of personal data concerning him or her;
  7. “data breach” means a breach of security that results in the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Principles governing the processing of personal data

Personal data:

  1. (a) be processed lawfully and fairly and in a transparent manner for the data subject (“lawfulness, fairness and transparency”);
  2. (b) be 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. (c) be adequate, relevant and limited to what is necessary for the purposes for which the data are processed (“data minimisation”);
  4. (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 undue delay (“accuracy”);
  5. (e) 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 will be 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 storage’);
  6. (f) 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 (“integrity and confidentiality”), by implementing appropriate technical or organisational measures.

The controller is responsible for compliance with the above and must be able to demonstrate such compliance (“accountability”). The controller declares that its processing is in accordance with the principles set out in this point.

Data management

Data processing related to the operation of the webshop

  1. The fact of collection, the scope of the data processed and the purpose of the processing:
Personal data Purpose of processing
Surname and first name Required for contact, purchase and proper invoicing.
E-mail address How to contact.
Phone number Contact us to discuss billing or delivery issues more efficiently.
Billing name and address To issue a proper invoice and to create, define the content, modify, monitor the performance of the contract, invoice the fees arising therefrom and enforce the claims related thereto.
Delivery name and address To enable door-to-door delivery.
Date of purchase/registration Performing 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.

  1. Data subjects: all data subjects registered/customers of the webshop website.
  2. Duration of data processing, deadline for deletion of data: immediately upon cancellation of registration. 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 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.

  1. 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.
  2. 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 such personal data; and
  • the data subject has the right to data portability and the right to withdraw consent at any time.
  1. The data subject may initiate the access to, deletion, modification or restriction of processing of personal data, data portability and objection to processing in the following ways:

– by post to Barett Budapest Kft., 4042 Debrecen, Csapó utca 18 fsz1., – by e-mail to barettsapkakalap@gmail.com, – by telephone to +36302185252.

  1. Legal basis for data processing:7.1. article 6 (1) (b) and (c) of the GDPR,7.2. article 13/A (3) of Act CVIII of 2001 on certain issues of electronic commerce services and information society services (hereinafter: Elker tv.):The service provider may process personal data that are technically necessary for the provision of the service. The service provider must, other things being equal, choose and in any case operate the means used in the provision of information society services 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 specified in this Act, but even in this case only to the extent and for the duration necessary.7.3. in the case of the issue of an invoice in accordance with accounting legislation, Article 6(1)(c).7.4. in the case of the enforcement of claims arising from the contract, 5 years pursuant to Section 6:21 of Act V of 2013 on the Civil Code.6:22. [Elévülés]
    (1) Unless otherwise provided by this Act, claims shall be time-barred after five years. (2) The limitation period shall begin to run when the claim becomes due. (3) An agreement to change the limitation period shall be in writing. (4) An agreement excluding the limitation period shall be null and void.

  1. Please note that
  • the processing is based on your consent .
  • you must provide personal information so that we can fulfil your order.
  • failure to provide the data will result in our inability to process your order.

The data processors used

Shipping

  1. Activity performed by the data processor: delivery of products, transport
  2. Name and contact details of the data processor: GLS general Logistics Systems Hungary Csomag-Logisztikai Kft. 2351 Alsónémedi, GLS Európa utca 2.
  3. The fact of processing, the scope of the data processed: delivery name, delivery address, telephone number.
  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: the User’s consent, Article 6 (1) (a), the Infotv. Article 6(6)(a), Paragraph 5(1) of the Personal Data Protection Act.

 

Hosting provider

  1. Activity provided by the data processor: Hosting
  2. Name and contact details of the data processor:

Hosting provider name: Endurance India Hosting provider location: Unit No. 501, 5th Floor & Unit IT Building No. 3, Nesco IT Park, Nesco Complex, Western Express Highway, Goregaon (East), Mumbai Maharashtra 400063, India Hosting provider email address: sales@resellerclub.com Hosting provider privacy statement: https://www.resellerclub.com/legal-agreements#privacy

  1. Fact of processing, scope of data processed: all personal data provided by the data subject.
  2. Data subjects: all data subjects using the website.
  3. Purpose of data processing: to make the website available and to ensure its proper operation.
  4. Duration of 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.
  5. The legal basis for data processing: the User’s consent, the Infotv. Article 5(1), Article 6(1)(a), and Article 13/A(3) of Act CVIII of 2001 on Certain Aspects of Electronic Commerce Services and Information Society Services.
  6. Rights of the data subject:a. You can find out about the circumstances of data processing,
    b. You have the right to receive feedback from the controller on whether your personal data are being processed and to access all information relating to the processing.
    c. You have the right to receive your personal data in a structured, commonly used, machine-readable format.
    d. You have the right to have inaccurate personal data corrected by the controller without undue delay upon your request.
    e. You may object to the processing of your personal data.

Website operation

  1. Activity performed by the data processor: website maintenance (monitoring, technical updates, security system development, other developments, repair tasks)
  2. Name and contact details of the data processor:

Name: Barett Budapest Kft., who is also the data controller of this website
Address: 4024 Debrecen, Csapó utca 18. fsz1.
E-mail: barettsapkakalap@gmail.com
Phone: +36302185252

  1. Fact of processing, scope of data processed: all personal data provided by the data subject.
  2. Data subjects: all data subjects who use the services of the website or who have registered/ordered on the website.
  3. Purpose of processing: operation of the website (development, monitoring, bug fixes)
  4. Duration of data processing, deadline for deletion of data: until the termination of the agreement between the Service Provider and the website operator or until the data subject’s request for deletion to the website operator.
  5. The legal basis for the processing of data is Article 6(1)(f) of the GDPR and Article 13/A(3) of Act CVIII of 2001 on certain aspects of electronic commerce services and information society services.
  6. Rights of the data subject:
  7. You can find out more about the conditions of data processing at
    b. You have the right to receive feedback from the controller on whether your personal data are being processed and to access all information relating to the processing.
    c. You have the right to receive your personal data in a structured, commonly used, machine-readable format.
    d. You have the right to have inaccurate personal data corrected by the controller without undue delay upon your request.
    e. You may object to the processing of your personal data.

Accounting tasks, invoicing

  1. Activity carried out by the data processor: accounting and invoicing
  2. Name and contact details of the data processor:

Name: Ms. Hanuscsák Éva Kulcsár
Address: 4553 Apagy, Vöröszászló utca 8..
Tax number: 65691713-1-35
E-mail: kulcsarevi@gmail.com

  1. Fact of processing, scope of data processed: name, billing name, billing address.
  2. Data subjects: all data subjects who place an order on the website.
  3. Purpose of processing: issuing of electronic invoices/accounting tasks
  4. Duration of data processing, deadline for deletion of data: 8 years pursuant to Section 169 (2) of Act C of 2000 on Accounting.
  5. The legal basis for the processing of data is Article 6(1)(c) of the GDPR and Article 13/A(3) of Act CVIII of 2001 on certain aspects of electronic commerce services and information society services.
  6. Rights of the data subject:
  7. You can find out more about the conditions of data processing at
    b. You have the right to receive feedback from the controller on whether your personal data are being processed and to access all information relating to the processing.
    c. You have the right to receive your personal data in a structured, commonly used, machine-readable format.
    d. You have the right to have inaccurate personal data corrected by the controller without undue delay at your request.

Online marketing services

  1. Activity performed by the data processor: online marketing
  2. Name and contact details of the data processor:

Name: Genius Marketing Management Ltd.
Registered office: HovaHouse 1 HovaVillas, Brighton&hove BN3 3DH, England
Web: www.geniusmm.co.uk
Customer Service: info@geniusmm.hu

  1. The fact of data processing, the scope of the data processed: name, e-mail address, visitor data
  2. Data subjects: all data subjects who use the website and subscribe to the newsletter.
  3. Purpose of the data processing: to promote and advertise the products available on the website, to increase the number of visitors to the website.
  4. Duration of data processing, deadline for deletion of data: until the termination of the agreement between the Service Provider and the data processor referred to in this point or until the data subject’s request for deletion to this data processor.
  5. The legal basis for data processing: the User’s consent, the Infotv. Article 5(1), Article 6(1)(a), and Article 13/A(3) of Act CVIII of 2001 on Certain Aspects of Electronic Commerce Services and Information Society Services.
  6. Rights of the data subject:
  7. You can find out more about the conditions of data processing at
    b. You have the right to receive feedback from the controller on whether your personal data are being processed and to access all information relating to the processing.
    c. You have the right to receive your personal data in a structured, commonly used, machine-readable format.
    d. You have the right to have inaccurate personal data corrected by the controller without undue delay at your request.

Cookie management (cookies)

  1. Typical cookies for web shops are so-called “password-protected session cookies”, “shopping cart cookies” and “security cookies”, which do 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 data processing: to identify users, to register the “shopping cart” and to track visitors.
  5. Duration of processing, deadline for deletion of data:

Cookies for basic functionality

Legal basis for processing Purpose of data processing Duration of processing Data processed
Legitimate interest To ensure the proper functioning of the website Session cookies:
until end of visitor session		 Webshop shopping cart

wc_cart_hash_#
wc_fragments_#

Cookies for statistical purposes

Legal basis for processing Purpose of data processing Duration of processing Data processed
Your consent Collecting information about how our visitors use our website Depending on the cookie:

– until end of session
– 2 years
– 24 hours
– 1 minute
– 90 days

 Google Analytics code

_ga
_gid
_gat
_gac_<property-id>

For a description of each cookie , click here.

Targeting and advertising cookies

Legal basis for processing Purpose of data processing Duration of processing Data processed
Your consent Display relevant ads, create and store an identifier Depending on the cookie:

– 90 days
– 18 months
– or 2 years

 – Google Adwords conversion code

– Google Adwords remarketing code

– Google Analytics remarketing feature

– Facebook conversion code

– Facebook remarketing code

– DoubleClick Floodlight code
  1. 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.
  2. 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.
  3. 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.

 

Use Google Adwords conversion tracking

  1. The data controller uses the online advertising program “Google AdWords” and makes use of Google’s conversion tracking service within its framework. Google Conversion Tracking is an analytics service of 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 AdWords client receives a different cookie, so they cannot be tracked through AdWords clients’ websites.
  5. The information, which is obtained through the use of conversion tracking cookies, is used to provide conversion statistics to AdWords customers who choose to track conversions. Clients 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 want 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 at: https://policies.google.com/privacy?gl=hu

 

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 the website (including your IP address) by means of cookies by downloading and installing the browser plug-in available at https://tools.google.com/dlpage/gaoptout?hl=hu

 

FACEBOOK PIXEL

  1. A Facebook account is code that allows the website to report conversions, create audiences and provide the site owner with detailed analytics on how visitors use the site. The Facebook remarketing pixel tracking code can be used to display personalised offers and ads to website visitors on Facebook. The Facebook remarketing list is not personally identifiable. For more information about the Facebook Pixel / Facebook Account, please visit: https://www.facebook.com/business/help/651294705016616

 

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 collection, the scope of the data processed and the purpose of the processing:
Personal data Purpose of processing
Name, e-mail address. Identification, to enable subscription to the newsletter.
Date of subscription Perform a technical operation.
IP address at the time of subscription Perform a technical operation.
  1. Data subjects: all data subjects who subscribe to the newsletter.
  2. Purpose of data 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.
  3. Duration of data processing, deadline for deletion of data: data processing lasts until the consent is withdrawn, i.e. until unsubscription.
  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
  • object to the processing of such personal data; and
  • the data subject has the right to data portability and the right to withdraw consent at any time.
  1. The data subject may initiate the access to, deletion, modification or restriction of processing of personal data, data portability and objection to processing in the following ways:

– by post to Barett Budapest Kft. 4024 Debrecen, Csapó utca 18 fsz1. door mailing address, – by e-mail to barettsapkakalap@gmail.com e-mail address, – by telephone to +36302185252.

  1. The data subject may unsubscribe from the newsletter at any time, free of charge.
  2. Legal basis for processing: the data subject’s consent, Article 6 (1) (a), the Infotv. Article 5 (1), and Article 6 (5) of Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Economic Advertising Activities:

The advertiser, the advertising service provider or the publisher of the advertisement shall keep a record of the personal data of the persons who have given their consent within the scope specified in the consent. The data recorded in this register, relating to the recipient of the advertising, may be processed only in accordance with the consent given in the consent form, until it is withdrawn, and may be disclosed to third parties only with the prior consent of the person concerned.

  1. Please note that
  • the processing is based on your consent .
  • must provide personal data if you wish to receive newsletters from us.
  • failure to provide this information will result in us not being able to send you a newsletter.

 

Complaints handling

  1. The fact of collection, the scope of the data processed and the purpose of the processing:
Personal data Purpose of processing
Surname and first name Identification, contact details.
E-mail address How to contact.
Telefonszám Kapcsolattartás.
Billing name and address Identification, handling of quality complaints, questions and problems regarding the products ordered.
  1. Data subjects: all data subjects who shop on the website of the webshop and all data subjects who complain about quality.
  2. Duration of data processing, deadline for deletion of data: copies of the record, transcript and reply to the recorded objection shall be kept for 5 years pursuant to Article 17/A (7) of Act CLV of 1997 on Consumer Protection.
  3. 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.
  4. 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 such personal data; and
  • the data subject has the right to data portability and the right to withdraw consent at any time.
  1. The data subject may initiate the access to, deletion, modification or restriction of processing of personal data, data portability and objection to processing in the following ways:

– by post to Barett Budapest Kft., 4024 Debrecen, Csapó utca 18 fsz1. door mailing address, – by e-mail to barettsapkakalap@gmail.com, – by telephone to +36302185252.

  1. Legal basis for data processing: the data subject’s consent, Article 6 (1) (a), of the Infotv. Article 5(1), and Article 17/A(7) of Act CLV of 1997 on Consumer Protection.
  2. Please note that
  • the provision of personal data is based on a contractual obligation.
  • the processing of personal data is a precondition for the conclusion of the contract.
  • must provide personal data in order for us to handle your complaint.
  • failure to provide the data will result in our not being able to deal with your complaint.

Community sites

  1. The fact of data collection, the scope of data processed: the name registered on Facebook/Google+/Twitter/Pinterest/Youtube/Instagram, etc. social networking sites, and the user’s public profile picture.
  2. Data subjects: all data subjects who are registered on Facebook/Google+/Twitter/Pinterest/Youtube/Instagram etc. and have “liked” the website.
  3. Purpose of the data collection: to share or “like” 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 by the means indicated 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. Information about data processing not listed in this notice is provided 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 shall 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.

  1. 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 purposes of the processing, you have the right to request the completion of incomplete personal data, including by means of a supplementary declaration.

  1. The right to erasure

You have the right to obtain from the controller the erasure of personal data relating to you without undue delay and the controller is obliged to erase personal data relating to you without undue delay under certain conditions.

  1. 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.

  1. 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.
  1. The right to data portability

You have the right to receive the personal data concerning you which 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 (…)

  1. The right to protest

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.

  1. Objection in the case of direct acquisition

Where personal data are 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.

  1. 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 previous paragraph shall not apply 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 inform you of the action taken on such requests without undue delay and in any event within 1 month of receipt of the request. If necessary, this may be extended by 2 months. The controller shall inform you of the extension, stating the reasons for the delay, within 1 month of receipt of the request. If the controller does not take action on your request, it shall inform you without delay and at the latest within one month of receipt of the request of the reasons for its failure to act and of the possibility to lodge a complaint with a supervisory authority and exercise your right to judicial remedy.

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. a) the pseudonymisation and encryption of personal data;
  2. (b) the continued confidentiality, integrity, availability and resilience of the systems and services used to process personal data;
  3. 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;
  4. (d) a procedure for the regular testing, evaluation and assessment of the effectiveness of the technical and organisational measures taken to ensure the security of processing.

Informing the data subject about the personal data breach

Where 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 of the personal data breach without undue delay. The information given to the data subject shall clearly and prominently 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 by a similar measure which ensures 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, if 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.

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 1055 Budapest, Falk Miksa u 9-11 Postal address: 1363 Budapest, Pf.: 9. 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 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) – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 – Act CXII of 2011 on the protection of individuals with regard to the processing of personal data (General Data Protection Regulation). Act on the Right of Informational Self-Determination and Freedom of Information (hereinafter: “Infotv”) – Act CVIII of 2001 on certain aspects of electronic commerce services and information society services (in particular Article 13/A) – Act XLVII of 2008 on the prohibition of unfair commercial practices vis-à-vis consumers; – Act XLVII of 2008 on the prohibition of unfair commercial practices vis-à-vis consumers (hereinafter: “Act XLVII of 2008 on the prohibition of unfair commercial practices vis-à-vis consumers”). évi XLVIII. törvény – a gazdasági reklámtevékenység alapvető feltételeiről és egyes korlátairól (különösen a 6.§-a) – 2005. évi XC. törvény az elektronikus információszabadságról – 2003. évi C. törvény az elektronikus hírközlésről (kifejezetten a 155.§-a) – 16/2011. sz. Opinion No 16/2011 on the EASA/IAB Recommendation on best practices for behavioural online advertising – Recommendation of the National Authority for Data Protection and Freedom of Information on data protection requirements for prior information – 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 25 May 2018.

Barett Budapest Ltd..

Data Controller

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