Privacy policy

Privacy policy

on data processing in connection with sales and services provided through the bpfight.com website operated by Progép-Goldex Ltd.

1. NAME AND DETAILS OF THE DATA CONTROLLER

Name: PROGÉP-GOLDEX Food Industry Machinery Trading and Services Limited Liability Company (hereinafter referred to as "the Company")

Headquarters.

Company registration number: 01-09-716485

Tax number: 13054171-2-42

Electronic contact: info@bpfight.com

Website: www.bpfightshop.hu; www.bpfight.com

 

1. TERMS
2. Contact

Data subject is an identified or identifiable natural person. 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.

1. Personal data

Personal data is any data relating to a data subject.

1. Data management

Processing of Personal Data means any operation or set of operations which is performed on Personal Data or on data files, whether or not by automated means. Processing means the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of Personal Data.

1. 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, in this case the Company; where the purposes and means of the processing 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.

1. Data Processor

A person who processes personal data on behalf of a controller. The Notice lists the purposes and means by which other persons process personal data on behalf of the Company.

1. Data Protection Incident

The unlawful processing or handling of personal data, including in particular unauthorised access, alteration, disclosure, disclosure, erasure or destruction, and accidental destruction or damage.

1. THE LAW ON WHICH THE PROCESSING IS BASED

The following legislation applies to the processing of data relating to the services provided by the Company:

• Act CXII of 2003 on the Right of Informational Self-Determination and Freedom of Information (hereinafter referred to as the "Infotv.");
• 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) (hereinafter: GDPR);
• Act V of 2013 on the Civil Code (hereinafter: );
• Act CVIII of 2001 on certain aspects of electronic commerce services and information society services (hereinafter: Eker tv.);
• Government Decree No. 45/2014 (II. 26.) on the detailed rules of contracts between consumers and businesses;
• Act C of 2000 on Accounting (Accounting Act), Act CXXVII of 2007 on Value Added Tax (VAT Act);
• Act No VI of 1998 on the proclamation of the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data, signed at Strasbourg on 28 January 1981 (hereinafter referred to as the Convention).

 

1. GENERAL INFORMATION

Your data will be processed solely for the purposes of the processing as set out below.

Your data will be processed by our Company through the voluntary provision of your data when you purchase our products on our website or through the logging of your activity in your user profile when you use our online services.

Please note that you have the right to request information about the data we process at any time and without charge, the right to rectification, erasure, restriction of processing, the right to object and, if you believe that your personal data is not being processed in accordance with the GDPR, the right to lodge a complaint with the National Authority for Data Protection and Freedom of Information (hereinafter referred to as "the NPAI").

 

Personal Data of Data Subjects

1. by registering on the Website and providing a user account;
2. By placing an order for products;
3. by payment of the purchase price of the product by the User;
4. by billing;
5. by requesting information;
6. visiting the Website (and cookie settings);
7. subscribing to newsletters and other direct marketing communications;
8. delivery of the ordered product; or
9. complaint handling

in connection with the following: 

 

1. DATA PROCESSING BY THE COMPANY

 

5.1. DATA PROCESSING IN CONNECTION WITH REGISTRATION ON THE WEBSITE AND THE PROVISION OF USER ACCOUNTS

Data processing related to the operation of the Website. By storing the data provided during registration, the Company can provide you with a more convenient service (e.g. the data concerned on do not need to be re-entered for new purchases, the status of orders is available). Registration is not a condition for the conclusion of a contract.

Scope of personal data	Purpose of processing	Legal basis for processing
Surname and forename	to enable and facilitate the conclusion and performance of the contract, to enable the User concerned to use the services of the Website.	Your voluntary consent, which you provide to the Company by registering [processing under Article 6(1)(a) of the Regulation]
e-mail address
password
telephone number
username
delivery address
activities logged in the user account

 

Persons entitled to know

Duration of data processing

the Company's sales staff (or data processors, see below)

In the case of registered Users, the duration of data processing lasts until the deletion of the data at the request of the registered User. The processing may also cease when the registration is deleted by the User or when the User's registration is deleted by the Data Controller. The User may delete his/her registration or request its deletion from the Data Controller at any time, which request shall be executed by the Data Controller without delay, but no later than 10 working days after receipt of the request.

 

5.2. PROCESSING OF DATA IN CONNECTION WITH THE ORDERING OF PRODUCTS

The purpose of the processing of the personal data and contact details voluntarily provided by the User placing an order on the Website is to enable the fulfilment of the order and to provide the related services of the Website to the User concerned.

 

Scope of personal data	Purpose of processing	Legal basis for processing
Surname and forename	conclusion of the contract	The legal basis for the processing is Article 6(b) of the GDPR, i.e. the performance of our obligations under the contract between our Company and you.
e-mail address
telephone (optional)
billing name, Country, postal code, city, address
Bank account number (in case of payment by bank transfer)
delivery address
order details

 

Persons entitled to be informed	Duration of data processing
Company employees (or data processors, see below).	Our Company shall process personal data in accordance with the provisions of the Civil Code. 6:22 (1) of the Personal Data Protection Act, in order to deal with possible legal claims.

 

5.3. DATA PROCESSING IN CONNECTION WITH THE PAYMENT OF THE PURCHASE PRICE OF THE PRODUCTS

Our Company carries out the following processing when the purchase price of the product is paid by bank transfer or credit card.

Scope of personal data	Purpose of processing	Legal basis for processing
Surname and forename	To make the consideration for the service provided by the Company available	The legal basis for the processing is Article 6(1)(b) of the GDPR, i.e. the performance of our obligations under the contract between our Company and you
Name of the bank holding the account (in the case of bank transfer)
bank account number (in the case of bank transfer) or payment-related data provided to the Company by the payment service provider (in the case of online payment by credit card)

 

Persons entitled to be informed	Duration of processing
The Company's employees responsible for financial transactions and transfers (or data processors, see below).	Our Company will delete the personal data immediately after 3 years. This period of data processing is necessary to ensure a quality service for potential returning customers.

 

5.4. PROCESSING OF BILLING DATA

After the purchase of the Product, our Company issues an invoice to the customer, which is sent to the customer.

Personal Data Processed   Personal Data:	Purpose of Processing:	Legal basis for processing:
Name, address of the customer	Purpose of processing: Accounting documents.	Legal obligation   [Article 6 (1) (c) GDPR, § 159 VAT Act, § 169 (2) Accounting Act]

 

Purpose, duration, method of processing:

Persons entitled to be informed.	Duration of processing
Persons to whom the data are disclosed	If the Data Subject has requested an accounting document containing his/her personal data (name, address), the period of processing is 8 (eight) years.

 

5.5. PROCESSING OF DATA RELATED TO A REQUEST FOR INFORMATION

If you contact us via our contact details on the Website in order to provide information, we will process your personal data in the following process:

Scope of personal data	Purpose of processing	Legal basis for processing
Surname and forename	Your name is essential for our Company to provide you with information. If you do not provide your name, our Company will inform you that without knowing your name, we will not be able to carry out the procedure and provide the information as we will not be able to identify you.	Consent pursuant to Article 6(a) GDPR.
E-mail address	To this address we will forward our Company's reply.	Consent pursuant to Article 6(a) GDPR.
Address (postal address) (optional)	You do not need to provide your postal address. If you wish to receive our reply by post, please provide your postal address.	Consent according to Article 6(a) GDPR.
Phone number (optional)	You do not need to provide your telephone number. Please note that if you provide only your telephone number, our Company will not be able to provide you with the information, as we will need to provide it in writing in a verifiable manner. If you do provide a telephone number, our Company may contact you to clarify the information request.	Consent pursuant to Article 6(a) GDPR.
personal message	You may send us your questions or comments.	Article 6(a) GDPR.

 

Persons entitled to be informed	Duration of processing
The Company's employees responsible for providing information (or data processors, see below).	1 year from the date of the reply to the request for information or from the date of the end of the related procedure.

 

5.6. PROCESSING OF WEBSITE VISITS AND COOKIES

The processing of data related to the provision of the information technology service - the functioning of the website - concerns all Users who visit the website, regardless of their use of the services available on the website.

Cookies store unique computer or device identifiers, profile information. Cookies cannot be used to identify the identity of visitors to the Webshop, but they can be used to identify and recognise the computer or device used by the visitor to visit the website.

The data technically recorded during the operation of the system are the following. The data that is automatically recorded is automatically logged by the system at the time of log-in or log-out without any specific declaration or action by the data subject. This data cannot be linked to other personal user data, except in cases required by law.

The website places a cookie on visitors' computers for the purpose of personalised service and reads it back during subsequent visits. If the browser returns a previously saved cookie, the cookie management service provider may link the visitor's current and previous browsing of the website, but only in relation to its own content.

The website sends a pop-up requesting permission to set cookies, which the user can accept or reject by clicking on the "accept all cookies" button, or set a custom setting based on their preferences.

Cookies used on the Webshop can be categorised as System, Analytics, Advertising/Marketing

The table below shows exactly which cookies are used by the Company on the Website and their main characteristics:

Cookie	Name	Purpose	Purpose Purpose and purpose	Duration	Legal basis
policy	Cookies used for the functioning of the website.	To ensure the user-friendly operation of the Website for the User concerned and to collect anonymous data   about your use of the website.	- the websites visited during your visit to and the order in which they are opened;     - IP address of the device used by the User.   The data are recorded anonymously and cannot be linked to a specific person. Data processed to verify access to the website:   - user name and password ,(may be stored at the User's choice ) - User's e-mail address, - IP address of the device used by the User.	- The data are recorded for the duration of the browsing session (i.e. the duration of the browsing session) and are deleted when the session is finished.   - The data required to verify access rights and to grant usage rights are recorded for the duration of the browsing session (i.e. the duration of browsing the website) and are deleted when the session is terminated. - The user name and password may be stored permanently at the User's discretion, by cookies on the User's device, and the User may delete them in his browser settings, thus controlling the period of data storage.	Article 6 (1) of the GDPR   (a) of Article 6(a) of the GDPR, the User's consent is required
analytics	- Google Analytics	The purpose of setting this type of cookie is to collect anonymous statistics about the users and the use of the site and to tailor the site to the needs of the users the Company.	- Measuring the number of visits to the site,     - Measure the frequency of viewing of each page of the Site and Measure the browsing time of each page of the Site,   - Determining the location of the user (browsing device),   - Data Controller mapping of the degree of interest in its services.   - Identification of the website from which the User came to this website. The data are recorded anonymously, they cannot be linked to an individual:	This data is stored by the Data Controller on a permanent basis, but for a maximum of 2 years, using cookies   Cookies are stored on the browsing device of the User . These cookies are used to store data on  for a period of up to six months. The User can delete these cookies at any time in the settings of his browser.	In accordance with Article 6(1) of the GDPR   a) of Article 6(6)(a) of the GDPR
	Googlemaps	for the purpose of the processing of the data indicated by the user   preferences and information provided by the user, which is also used to measure and and to map browsing habits.			Article 6(1) of the GDPR   (a) of Article 6(6)(a) of the GDPR
advertisement	Cookies from various advertising platforms on the Website.	The Company uses various advertising platforms that may place cookies on the Website (Facebook, Google).	- To measure the traffic on the site and to   - anonymous data processed to map browsing habits.		Article 6(1) of the GDPR   a) the consent of the User

 

The Company draws the attention of the users to the fact that the website may contain links to other websites which are not operated by the Company and are only intended to provide information to visitors. The Company has no control over the content and security of the websites operated by its partners. The Company hereby requests the data subjects to review the privacy policy of the sites they visit before providing any form of Personal Data on the site that does not belong to the Company.

 

5.7.DATA PROCESSING IN RELATION TO NEWSLETTER SERVICES, ENQUIRIES CONSTITUTING DIRECT MARKETING

The user may subscribe to the newsletter on the Website, provided that the Company makes this available.

Scope of Personal Data processed in connection with the newsletter service, enquiries constituting direct marketing, legal basis for processing, categories of data subjects and recipients

 

Personal Data processed   Personal Data:	Legal basis for processing:	Data subjects   Categories of data subjects:	Categories of recipients:
Name, e-mail address	Consent of the Data Subject [Article 6(1)(a) GDPR]	The Data Subject who subscribes to receive newsletters on the Website.	The Company's employees (or data processors) responsible for newsletters.

 

Purpose, duration and methods of processing

 

Purpose of processing:	Duration of processing:	Purpose of data processing:
Direct marketing, promotion of services.	The Company will process Personal Data until consent is withdrawn.	For direct marketing and direct marketing purposes.

 

5.8.

For the purpose of the delivery of the product you have ordered, our Company processes the following data and transfers them to the selected carrier or data controller based on the delivery method you have chosen.

 

Personal Data Processed   Personal Data:	Legal basis for processing:	Data subjects   Categories of data subjects:	Categories of recipients:
Name of the recipient (to whom the product is delivered),   e-mail address, address, the package number of the shipment, the value of the package, the payment and delivery method chosen, the amount of cash on delivery to be collected, the billing name and address, and any additional information voluntarily provided to the service provider in connection with the stay at the address provided, as well as any other information included in the comment to the order (e.g. different name on the doorbell, twin house page, description of the specific door numbering).	Performance of the contract [Article 6(1)(b) GDPR].	The recipient to whom the product is delivered.	The employees of the Company responsible for sales , invoicing (or data processors).

 

Purpose of processing:	Duration of processing:	Processing method:
Fulfilling orders, documenting purchases and payments, fulfilling accounting obligations.	The Company processes personal data until the data is transferred to the data processor carrying out the delivery.	Electronically.

 

5.9. PROCESSING OF DATA RELATING TO COMPLAINTS

When you make a complaint about our products and services, the following personal data will be processed:

Scope of personal data	Purpose of processing	Legal basis for processing
Surname and given name	The purpose of the service or service you have received is the processing of your complaint.	To fulfil a legal obligation on the controller under Article 6(c) GDPR
E-mail address
address
telephone number (optional)
personal message

 

Persons entitled to be informed	Duration of processing
The Company's staff responsible for complaint handling (or data processors, see below).	Pursuant to Article 17/A (7) of Act CLV of 1997 on Consumer Protection, we are obliged to keep the complaint for 3 years. In the event of judicial or administrative proceedings, we will keep the complaint until the end of such proceedings.

 

 

1. ACCESS TO DATA AND DATA PROCESSORS

6.1.

Personal data provided by you will be accessed by the Company's employees in the performance of their duties.

In addition, your data may be accessed by third parties acting on behalf of the Company, in particular by IT service providers under contract with the Company.

 

6.2.

Please note that we may transfer your Personal Data to third countries based on a business decision taken in the ordinary course of our business.

Where the Service Provider engages the services of a third party for certain aspects of the processing of Personal Data, it will only contract with data processors in accordance with Article 28 of the GDPR who

provide the same guarantees as our company's data processing, in particular in terms of expertise, reliability and resources, to ensure processing in compliance with data protection legislation and to ensure and implement appropriate technical and organisational measures to safeguard the rights of data subjects.

Transfers to processors shall only concern personal data which are strictly necessary for the purpose of the processing.

.

The States of the European Union and Norway, Liechtenstein and Iceland, which are parties to the Agreement on the European Economic Area, grant the same rights to data subjects under the GDPR to protect their personal data and to safeguard the exercise of their rights and freedoms.

Pursuant to Article 45 of the GDPR, the European Commission shall identify those States outside the European Union and the EEA Member States which have an adequacy decision pursuant to Article 43(3) of the GDPR and adequate safeguards pursuant to Article 46 of the GDPR with respect to the processing of personal data and the exercise of the rights of data subjects, i.e. which provide for the same level of protection of personal data of data subjects as the GDPR and adequate safeguards to ensure the exercise and protection of the rights of data subjects.

In accordance with Article 45 of the GDPR, the Commission of the European Union has published a list of the following countries as having adequacy under Article 43(3) and safeguards under Article 46 of the GDPR: Andorra, Argentina, Canada, Faroe, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Uruguay, Switzerland, the Isle of Man, Uruguay, the United Kingdom, the United States of America and the United States of America. The list is available at : https://ec.europa.eu/info/law/law-topic/dataprotection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eucountries_en

Please note that in the event of a transfer to such a country, your data protection rights under the GDPR may not apply, and you are hereby advised of the risks involved.

When transferring data to a third country, in order to ensure that your data is protected in the same way as it is domestically, the contractual safeguards applied by the Service Provider-

in the absence of an adequacy decision with the country of destination, will be based on the European Commission's decision on standard contractual clauses for the transfer of personal data to processors in third countries, pursuant to Article 46(2)(c) of the GDPR.

 

The Company will only transfer your personal data to public bodies and authorities, in particular courts, prosecutors' offices, investigative authorities and law enforcement authorities, the National Authority for Data Protection and Freedom of Information, in exceptional cases and on the basis of a legal obligation. For example, if the National Authority for Data Protection and Freedom of Information contacts our Company and requests information about the processing of your personal data.

 

6.3 List of data processors

	Name	Location	Type of data processing
1.	Webeditor Ltd.	1184 Budapest, Hársfa utca 24.	Web development and maintenance
2.	Website Doc   Varga Norbert sole proprietor	6000 Kecskemét, Fecske u. 30. fsz. 6.	Web development and maintenance
3.	Tárhely.Eu Service Provider Ltd.	1097 Budapest, Könyves Kálmán körút 12-14.	hosting provider, newsletter sending software operator
4.	Szamlazz.hu   KBOSS.hu Kft.	1031 Budapest, Záhony utca 7.	billing
5.	Lap Consulting Kft.	1134 Budapest, Csángó utca 4. b. building. 2. floor. 11	accounting
6.	Stripe Payments Europe Limited	The One Building, 1, Lower Grand Canal Street, Dublin 2, Ireland	payment service provider
7.	Magyar Posta Zrt.	1138 Budapest, Dunavirág utca 2-6.	delivery of ordered products
8.	FoxPost Zrt.	3300 Eger, Pacsirta utca 35/A.	Delivery of the ordered product
9.	DHL Global Shipping Ltd.	1185 Budapest, BUD International Airport DHL building (264).	Delivery of ordered products
10.	DPD Hungary Kft.	1134 Budapest, Váci út 33. 2nd floor	delivery of ordered products
11.	UPS Hungary Kft.	Hungary, 2220 Vecsés, Lőrinci utca 154., Airport City Logistic Park, Building G	Delivery of the ordered product
12.	FedEx Express International B.V.	Taurusavenue 111 2132 LS Hoofddorp Netherlands	delivery of ordered product
13.	GLS General Logistics Systems Hungary Kft.	H - 2351 Alsónémedi - Northern Industrial Estate, GLS Európa u 2.	Delivery of ordered product
14.	Branding Brewery Ltd.	Hova House 1 Hova Villas Brighton & Hove BN3 3DH United Kingdom	Marketing
15.	Shopify International Ltd	c/o Intertrust Ireland 2nd Floor 1-2 Victoria Buildings Haddington Road Dublin 4, D04 XN32 Ireland	webshop operation
16.	UAB MailerLite	Jono Basanavičiaus g. 15, LT-03108 Vilnius   Address for correspondence: 1013 Budapest Attila út 33.	Send newsletter
17.	GOOGLE INC.	1600 Amphitheatre Parkway Mountain View CA 94043 US	Data processing related to the use of cookies
18.	Facebook Inc.	1601 Willow Road, Menlo Park, CA   94025, USA	Processing of data related to the use of cookies
19.	Kasnyik & Társa Ltd.	2131 Göd, Rozmaring utca 7.	Auditor
20.	Cégmenedzser Szoftver Kft.	H- 1081 Budapest, Rákóczi út 61. 1.	Business management system and invoicing
21.	SMART24 SOFTWARE Ltd.	H-1081 Budapest, Rákóczi út 61. 1.	business management system and invoicing

 

We declare that the Company will only use data processors that provide adequate guarantees for compliance with the data processing requirements of the GDPR and the Info law and for the implementation of appropriate technical and organisational measures to ensure the protection of your rights.

A written contract between our company and the processors sets out the rights and obligations in relation to the processing of data under the GDPR.

 

1. DATA SECURITY MEASURES

Please be informed that our Company will take all necessary measures to protect your personal data, in particular against unauthorized access, alteration, disclosure, transmission, disclosure, erasure or destruction, accidental destruction or accidental damage, and against inaccessibility due to changes in the technology used.

In the event of a data breach, we will notify the NAIH without undue delay, no later than 72 hours after the data breach comes to our attention, unless the data breach is unlikely to pose a risk to your rights and freedoms through the personal data we process.

We will inform you of a data breach without delay if it poses a high risk to your rights and freedoms. We will consider the risk to be high, for example, if we detect an unauthorised intrusion into the IT network or the data processor detects and reports to us an unauthorised intrusion and we specifically detect an unauthorised theft of personal data.

A data breach is when data stored by our Company is damaged, accidentally or unlawfully destroyed, lost, unauthorized disclosure to others or unauthorized access by anyone, despite a duty to preserve it.

 

1. YOUR RIGHTS IN RELATION TO DATA PROCESSING

8.1 Right of access or request for information

You may request information from the Company in writing, using the contact details provided in section 1, so that the Company can inform you:

• what personal data,
• on what legal basis and for what purposes the Company processes your personal data,
• if the data have not been collected from you by our Company, the source of the data,
• for how long the personal data will be processed by the Company or, if this is not possible, on the basis of what criteria our Company will determine this period,
• to which supervisory authority you may lodge a complaint in the event of a possible infringement of the data processing,
• your right to request the Company to correct, delete or restrict the processing of your personal data and to object to the processing of such personal data,
• the circumstances of the personal data breach, its effects and the measures taken to remedy it,
• the name, address and activities of the data processor in relation to the processing,
• the recipients or categories of recipients to whom or with whom your personal data have been disclosed by the Company, and when, under which law, to which of your personal data it has been disclosed or to whom it has been disclosed.

 

The Company will comply with your request within a maximum of 1 month, free of charge, by sending a letter or e-mail to the contact details you have provided.

If your request is clearly unfounded or excessive, our Company may:

• refuse to act on your request; or
• charge a fee to cover postage and administrative costs incurred by us.

Your request will be considered excessive if it is of a recurrent nature and we have already informed you of the above data and facts at least twice within a period of one year, and the scope of our Company's activities and the data processed have not changed, so that there has been no change in the lawfulness, grounds and methods of our processing.

Please be informed that in the event of a request from you, exclusively by telephone, for information, we can only provide general information. Our company can only accept requests for information in writing (by email), otherwise we cannot be sure that the request has actually been made by you.

 

8.2 Right to rectification of data

You may request in writing, using the contact details provided in section 1, that the Company amend any of your personal data (for example, if you change your e-mail address or change your address). The Company will comply with your request within a maximum of 1 month and will notify you by letter or e-mail to the contact details you have provided.

You may also request in writing, via the contact details provided in point 1, that the Company correct inaccurate personal data relating to you. The Company will comply with your request without undue delay and will notify you by letter or e-mail to the contact details you have provided.

If you become aware that the incomplete personal data needs to be completed for the purposes of the Company's data processing and thus to pursue your legitimate interest, you may request that the Company completes your records with the missing data. To this end, please kindly send us your consent to the processing of your missing data to the contact details provided in point 1. On the basis of the supplementary declaration, our Company will without delay supplement your personal data with the data corresponding to the request.

The rectification and the corrected data will be communicated to the person to whom the personal data concerned by the rectification was communicated. If you request it, we will provide you with the names and contact details of the persons to whom we have previously disclosed the data to be corrected, as recipients, and to whom we have disclosed the data.

 

8.3 Right to erasure

You may request the Company to delete your personal data in writing via the contact details provided in section 1, if:

1. the personal data is no longer necessary for the purposes for which it was collected or otherwise processed by the Data Controller,
2. You have withdrawn your consent to the processing and there is no other legal basis for the processing,

• you object to the processing and there are no overriding legitimate grounds for the processing,

1. the Controller has unlawfully processed your personal data,
2. the personal data must be erased in order to comply with a legal obligation under Union or Member State law to which the Controller is subject

The Company will comply with your request within a maximum of 1 month and will notify you by letter or e-mail to the contact details you have provided.

With regard to data processing on the Internet, we inform you that our Company will make every effort to delete your data stored in search engines at all possible access or storage points, even if you have recorded it in connection with our Company's services.

We will also inform the person to whom we have disclosed the personal data subject to deletion. If you request it, we will provide you with the names and contact details of the recipients to whom we have previously disclosed the data subject to erasure and to whom we have disclosed the data.

 

8.4 Right to restriction of processing

You may request the Company, in writing, to restrict the processing of your personal data using the contact details provided in section 1.

This means that during the period of restriction, we may only store your personal data, but we may not transfer it to any recipient, access it, retrieve it, make it available to any recipient, delete it or destroy it.

An exception to this restriction is if the processing of the personal data subject to the restriction is necessary for the exercise of legal claims or for important public interests. If the restriction is lifted for such a reason, we will inform you in writing in advance.

We will inform the person to whom the personal data subject to the restriction has been disclosed of the restriction. If you request it, we will provide you with the names and contact details of the persons to whom we have previously disclosed the restricted data as recipients and to whom we have disclosed the data.

 

8.5 Right to data portability

You have the right to receive the personal data you have provided to us in a format that is suitable for transmission in machine-readable form.

Please note that under the GDPR and the Data Protection Commissioner's 2017 report, data controllers are not obliged to develop formats that allow data portability and to implement or maintain technically compatible data management systems. The data subject has the right to have data transmitted directly between controllers if this is technically feasible!

 

8.6 Right to object

Please be informed that your personal data will not be used by our Company for commercial purposes, public opinion polls or scientific research and will not be transmitted for such purposes.

Nevertheless, we inform you that you may object in writing to the processing of your personal data via the contact details provided in section 1 if you believe that our Company would transfer or use your personal data for these purposes.

 

1. MEANS OF REDRESS IN RELATION TO DATA PROCESSING

Before initiating any procedure, please contact our Company using the contact details provided in section 1 and send us your complaint. Our Company will cooperate with you as the complainant and, if we find it justified on the basis of the complaint, we will promptly restore the lawful situation!

You also have the right to initiate proceedings before the NAIH and lodge a complaint if you believe that our Company is in breach of the GDPR in the processing of your personal data.

For this purpose, we provide the contact details of the NAIH as set out below:

Name: National Authority for Data Protection and Freedom of Information

Headquarters.

Central e-mail address: ugyfelszolgalat@naih.hu   

Website: www.naih.hu  

Telephone number: +36 (1) 391-1400 Fax number: +36 (1) 391-1410

Start of online administration: http://naih.hu/online-uegyinditas.html  

 

You may also bring a civil action against our Company in the event of unlawful processing of your personal data. The court has jurisdiction to decide on the action. You can also bring the case before the court of your domicile or residence (for a list of courts and their contact details, please visit the following link: http://birosag.hu/torvenyszekek).

 

1. CONTACT DETAILS OF OUR PRIVACY NOTICE

Our privacy notice is available and can be consulted in electronic form on our website, as set out in point 1 of this notice.

If you contact us in writing - by post or by e-mail - we will inform you in writing of the material circumstances of the processing, i.e. that:

• we will process data in the course of our activities, in the course of which
• what data,
• for how long,
• the purposes for which we are storing it, and
• how the data will be processed, for what purpose, for what purpose, for how long, for what purpose and for how long, and how the data will be processed.

 

1. REVIEW OF THE PRIVACY NOTICE

Our Company reviews the Privacy Notice annually to ensure that it complies with all legal requirements and the expectations and practical guidelines published by the NAIH.

This Privacy Notice will enter into force on 15 November 2024.

Next review date. 15 November 2025.