Privacy Policy - Swami Ayurveda Ltd.

Introduction

Swami Ayurveda Kft. (Head office: 1136 Budapest, Raoul Wallenberg u. 12. 5th floor. 3rd door, tax number: 32625918-1-41, hereinafter: Service provider, data controller) submits to the following information.

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 flow of such data and on the repeal of Regulation 95/46/EC (General Data Protection Regulation) (April 2016) 27.), we provide the following information. CXII of 2011 on the right to information self-determination and freedom of information. law (Infotv.) Recommendation of the National Data Protection and Freedom of Information Authority (NAIH) entitled "on the data protection requirements of prior information" (hereinafter: Recommendation).

This Privacy Policy regulates the data management of https://swamiayurveda.hu website.

ThePrivacy Policy is available from the following page: https://swamiayurveda.hu/privacy-policy

Amendments to the policy will take effect upon publication at the above address. 

THE DATA MANAGER AND ITS CONTACTS:

Name: Swami Ayurveda Ltd.
Headquarter: 1136 Budapest, 12 Raoul Wallenberg str. 5/3
E-mail:  swamiayurvedakft@gmail.com
Phone: +36-30-444-6010

CONTACT INFORMATION OF THE DATA PROTECTION OFFICER:

Name: Szilvia Farkas
Headquarter: 1136 Budapest, 12 Raoul Wallenberg str. 5/3
E-mail: swamiayurvedakft@gmail.com
Phone: +36-30-444-6010

TERM DEFINITIONS

1. "personal data": any information relating to an identified or identifiable natural person ("data subject"); a natural person can be identified directly or indirectly, in particular on the basis of an identifier such as name, number, location data, online identifier or one or more factors relating to the physical, physiological, genetic, mental, economic, cultural or social identity of the natural person identifiable;
2. "data management": any operation or set of operations performed on personal data or data files in an automated or non-automated manner, such as collection, recording, organization, segmentation, storage, transformation or change, query, insight, use, communication, transmission, distribution or otherwise by making available, coordinating or connecting, limiting, deleting or destroying;
3. "data controller": the natural or legal person, public authority, agency or any other body that determines the purposes and means of processing personal data independently or together with others; if the purposes and means of data management are determined by EU or member state law, the data controller or the special aspects regarding the designation of the data controller may also be determined by EU or member state law;
4. "data processor": the natural or legal person, public authority, agency or any other body that processes personal data on behalf of the data controller;
5. "recipient": the natural or legal person, public authority, agency or any other body to whom or with which the personal data is communicated, regardless of whether it is a third party. Public authorities that have access to personal data in accordance with EU or Member State law in the context of an individual investigation are not considered recipients; the handling of said data by these public authorities must comply with the applicable data protection rules in accordance with the purposes of the data management;
6. "consent of the data subject": the voluntary, specific and clear declaration of the will of the data subject based on adequate information, with which the data subject indicates by means of a statement or an act clearly expressing the confirmation that he gives his consent to the processing of personal data concerning him;
7. "data protection incident": a breach of security that results in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or unauthorized access to, personal data transmitted, stored or otherwise handled.
8. Special data

Special data: Personal data referring to racial or ethnic origin, political opinion, religious or worldview beliefs or trade union membership, personal data relating to your sex life or sexual orientation.

Genetic data: All personal data relating to the inherited or acquired genetic characteristics of a natural person, which carries unique information about the physiology or state of health of that person, and which primarily results from the analysis of a biological sample taken from said natural person.

Biometric data: All personal data related to the physical, physiological or behavioral characteristics of a natural person obtained by specific technical procedures that enable or confirm the unique identification of the natural person (e.g. facial image or dactyloscopic data).

Health data: Personal data relating to the physical or mental health of a natural person, including data relating to the health services provided to the natural person, which carries information about the natural person's health.

Profiling, automated decision-making

Any form of automated processing of personal data, during which personal data is used to evaluate, analyze or predict certain personal characteristics of a natural person (in particular, e.g.: work performance, economic situation, state of health, interests, behavior).

Automated decision-making: Decisions based solely on automated data management.

Pseudonymization

If it can no longer be determined which specific natural person the personal data refers to (provided that it is ensured that the natural person cannot be linked again).

PRINCIPLES REGARDING THE HANDLING OF PERSONAL DATA

Personal data:

1. a) it must be handled lawfully and fairly, as well as in a transparent manner for the data subject ("legality, fair procedure and transparency");
2. b) it is collected only for specific, clear and legitimate purposes, and they are not handled in a way that is incompatible with these purposes; in accordance with Article 89 (1), further data processing for the purpose of archiving in the public interest, for scientific and historical research purposes, or for statistical purposes is not considered incompatible with the original purpose ("purpose limitation");
3. c) they must be appropriate and relevant from the point of view of the purposes of data management, and must be limited to what is necessary ("data economy");
4. d) they must be accurate and, if necessary, up-to-date; all reasonable measures must be taken to promptly delete or correct personal data that is inaccurate for the purposes of data processing ("accuracy");
5. e) it must be stored in a form that allows the identification of the data subjects only for the time necessary to achieve the goals of personal data management; personal data may be stored for a longer period only if the personal data will be processed in accordance with Article 89 (1) for the purpose of archiving in the public interest, for scientific and historical research purposes or for statistical purposes, the rights of the data subjects and subject to the implementation of appropriate technical and organizational measures required to protect your freedoms ("limited storage capacity");
6. f) must be handled in such a way that adequate security of personal data is ensured by the application of appropriate technical or organizational measures, including protection against unauthorized or illegal processing, accidental loss, destruction or damage of data ("integrity and confidentiality").

The data controller is responsible for compliance with the above, and must also be able to prove this compliance ("accountability").

DATA MANAGEMENT

DATA MANAGEMENT RELATED TO WEBSITE OPERATION

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

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

2. Scope of stakeholders: All stakeholders registered/purchased on the website.
3. Duration of data management, deadline for deletion of data: Immediately upon cancellation of registration. Based on Article 19 of the GDPR, the data controller will inform the data subject electronically of the deletion of any personal data provided by the data subject. If the data subject's request for deletion also covers the e-mail address he provided, the data controller will also delete the e-mail address after the information has been provided. Except in the case of accounting documents, as these data must be kept for 8 years based on Section 169 (2) of Act C of 2000 on accounting. In the case of a customer who does not require registration, the data will be deleted 30 days after the purchase.

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

4. The person of the possible data controllers entitled to access the data, the recipients of the personal data: The personal data may be processed by the authorized employees of the data controller based on the provisions of this information. 
5. Description of the rights of data subjects related to data management: 

• The data subject may request from the data controller access to personal data relating to him, their correction, deletion or restriction of processing, and
  • you can object to the processing of such personal data, as well as 
  • the data subject has the right to data portability and to withdraw consent at any time.

6. The data subject can initiate access to personal data, its deletion, modification or restriction of processing, portability of data, objection to data processing in the following ways:

- by post to 1136 Budapest, Raoul Wallenberg u. 12. 5. em. at door 3,
- via e-mail a swamiayurvedakft@gmail.com by e-mail, 
– by phone at +36-20-482-2677.

7. Legal basis for data management: 

7.1. Article 6 (1) point (b) of the GDPR, 

7.2. CVIII of 2001 on certain issues of electronic commerce services and services related to the information society. Act (hereinafter: Elker Law) 13/A. Section (3): 

For the purpose of providing the service, the service provider may process the personal data that is technically absolutely necessary for the provision of the service. If the other conditions are the same, the service provider must choose and in all cases operate the tools used in the provision of services related to the information society in such a way that personal data is only processed if this is absolutely necessary for the provision of the service and the fulfillment of other objectives defined in this law necessary, but also in this case only to the extent and for the necessary time.

7.3. In case of issuing an invoice in accordance with the accounting legislation, point c) of Article 6 (1).

7.4. In case of enforcement of claims arising from the contract, Act V of 2013 on the Civil Code 6:21. according to § 5 years.

Ptk. 6:22 a.m. § [Prescription]
(1) If this law does not provide otherwise, claims become time-barred within five years.
(2) The statute of limitations begins when the claim becomes due.
(3) The agreement to change the limitation period must be in writing.
(4) An agreement excluding the limitation period is void.

8. We inform you that 

• data management is necessary to fulfill the contract.
  • you must provide personal data so that we can fulfill your order.
  • failure to provide data will result in us not being able to process your order.

DATA PROCESSORS REQUIRED

Delivery

1. Activity provided by data processor: Delivery of products, transport
2. Name and contact information of the data processor: 

– Magyar Posta Zrt. (MPL courier service and postal delivery)
Address: 1138 Budapest, Dunavirág utca 2-6. 
Post address: Budapest 1540 
E-mail: ugyfelszolgalat@posta.hu 
Privacy policy https://posta.hu/adatkezelesi_tajekoztato

– SPRINTER Courier Service Limited Liability Company – courier service
Address: 1097 Budapest, Táblás utca 39.
Privacy policy http://sprinter.hu/wp-content/uploads/2018/05/Sprinter-Adatkezelesi-Tajekoztato.pdf

Magyar Lapterjesztő Zrt. - PickPack delivery 
Address: 1097 Budapest, Táblás utca 32.
Privacy policy http://www.pickpackpont.hu/wp-content/uploads/2018/05/Sprinter-Adatkezelesi-Tajekoztato.pdf

– GLS General Logistics Systems Hungary Csomag-Logisztikai Kft. – courier service 
Address: 2351 Alsónémedi, GLS Európa u. 2.
Contact: https://gls-group.eu/HU/hu/gls-elerhetoseg?subject=98.806 
E-mail: info@gls-hungary.com 
Privacy policy https://gls-group.eu/HU/hu/adatvedelmi-szabalyzat

– FoxPost Zrt. – courier service, FoxPost parcel machines 
Address: 3200 Gyöngyös, Batsányi János u. 9.
More information: http://www.foxpost.hu/altalanos-szerzodesi-feltetelek/

3. The fact of the data management, the scope of the managed data: Delivery name, delivery address, telephone number, e-mail address.
4. Scope of stakeholders: All stakeholders requesting home delivery.
5. Purpose of data management: Delivery of the ordered product to your home.
6. Duration of data management, deadline for data deletion: It lasts until the home delivery is completed.
7. Legal basis for data processing: Article 6, paragraph 1, point b).

Implementation rules related to the management of special personal data: The company does not record, collect or manage special personal data. As a result, special personal data may only be handled exceptionally, under the supervision of the data protection officer. Special personal data may be collected from the data subject only after the data subject has been informed in advance, which information specifically covers the rules regarding special personal data. The consent of the data subject can only be specific and expressed, it must also be clear from the consent that the data subject has been provided with the above information and that the data subject has given his consent with this in mind. The recorded special personal data must be handled separately and closed.

Hosting provider

1. Activity provided by data processor: Storage service
2. Name and contact information of the data processor: 

– RACKFOREST ZRT.
Address: 1132 Budapest,
Victor Hugo utca 11. 5. em. B05001.
E-mail: info@rackforest.com

3. The fact of the data management, the scope of the managed data: All personal data provided by the data subject.
4. Scope of stakeholders: All stakeholders who use the website.
5. Purpose of data management: Making the website available and operating it properly.
6. Duration of data management, deadline for data deletion: Data management lasts until the termination of the agreement between the data controller and the storage provider, or until the deletion request addressed to the storage provider by the data subject.
7. The legal basis for data processing: points c) and f) of Article 6 (1) and CVIII of 2001 on certain issues of electronic commerce services and services related to the information society. Act 13/A. (3) of § 

Customer service, accounting tasks, invoicing

1. Activities performed by the data processor: Customer service, accounting tasks, invoicing
2. Name and contact information of the data processor: 

– Szilvia Farkas – customer service, invoicing
Address: 1136 Budapest, 12 Raoul Wallenberg str. 5/3
Information on data management, contact information: https://swamiayurveda.hu/privacy-policy

– KBOSS.hu Kft. – invoicing system
Cím, levelezési cím: 1031 Budapest, Záhony u. 7.
Internet contact: Számlázz.hu – Customer service (szamlazz.hu)
Privacy policy https://www.szamlazz.hu/adatvedelem/

3. The fact of the data management, the scope of the managed data: Billing name, Billing address, Delivery name, delivery address, telephone number, e-mail address, data related to invoicing and payment.
4. Scope of stakeholders: All stakeholders who place an order on the website. 
5. Purpose of data management: Performing customer service work related to website services, as well as issuing invoices/bookkeeping tasks based on legal regulations.
6. Duration of data management, deadline for deletion of data: Immediately upon cancellation of registration. Based on Article 19 of the GDPR, the data controller will inform the data subject electronically of the deletion of any personal data provided by the data subject. If the data subject's request for deletion also covers the e-mail address he provided, the data controller will also delete the e-mail address after the information has been provided. Except in the case of accounting documents, as these data must be kept for 8 years based on Section 169 (2) of Act C of 2000 on accounting. In the case of a customer who does not require registration, the data will be deleted 30 days after the purchase.

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

7. The legal basis for data processing: point c of Article 6 (1) of the GDPR, and CVIII of 2001 on certain issues of electronic commerce services and services related to the information society. Act 13/A. (3) of §

8.
The rights of the data subject: 
a. You can find out about the conditions of data management,  
b. You are entitled to receive feedback from the data controller as to whether your personal data is being processed, or to access all information related to data processing. 
c. You have the right to receive your personal data in a segmented, widely used, machine-readable format.  
d. You are entitled to have your inaccurate personal data corrected without undue delay upon your request. 

ADDRESSES WITH WHOM PERSONAL DATA IS COMMUNICATED (DATA TRANSFER):

Online payment

1. Activity performed by the Recipient: Comprehensive management and processing of online payments
2. Recipient's name and contact information: 

– OTP Bank Nyrt., contact: https://www.otpbank.hu/portal/hu/Kapcsolat

– OTP Bank Nyrt., contact: https://otpmobil.hu/kapcsolat/ and https://otpmobil.hu/adatkezelesi-tajekoztato/

– PayPal (Europe) S.à.r.l. et Cie, S.C.A., contact: https://www.paypal.com/hu/webapps/mpp/ua/privacy-full

3. The fact of the data management, the scope of the managed data: Billing data, name, e-mail address
4. Scope of stakeholders: All stakeholders who choose to pay on the website.
5. Purpose of data management: Online payment processing, transaction confirmation and fraud monitoring to protect users
6. Duration of data management, deadline for deleting data: Lasts until the online payment is completed. 
7. Legal basis for data processing: Article 6, paragraph 1, point b) of the GDPR. Data processing is necessary for online payment at the request of the data subject.
8. The rights of the data subject: 
9. You can find out about the conditions of data management, 
   b. You have the right to receive feedback from the data controller as to whether your personal data is being processed, and to have access to all information related to data management.
   c. You have the right to receive your personal data in a segmented, widely used, machine-readable format. 
   d. You are entitled to have your inaccurate personal data corrected without undue delay upon your request.

MANAGEMENT OF COOKIES

1. Cookies typical for online stores are the so-called "cookie used for a password-protected session", "cookies required for the shopping cart" and "security cookies", the use of which does not require prior consent from the data subjects.
2. The fact of the data management, the scope of the managed data: Unique identification number, dates, times
3. Scope of stakeholders: All stakeholders visiting the website.
4. Purpose of data management: Identification of users, registration of the "shopping basket" and tracking of visitors.
5. Duration of data management, deadline for data deletion: 

Type of cookie: Session cookies
Legal basis for data management: Electronic commercial services and information
CVIII of 2001 on certain issues of social services. Act (Elkertv.) 13/A. (3) of §
Duration of data management: The period until the end of the relevant visitor session
Managed data circle: connect.sid

6. The person of the possible data controllers entitled to access the data: The data controller does not manage personal data through the use of cookies.
7. Description of the rights of data subjects related to data management: The data subject has the option to delete cookies in the Tools/Settings menu of browsers, usually under the settings of the Data Protection menu item.
8. Legal basis for data management: Consent from the data subject is not required if the sole purpose of using cookies is the transmission of information via an electronic communication network or if the service provider absolutely needs it to provide a service related to the information society specifically requested by the subscriber or user.
9. Description of the rights of data subjects related to data management: The data subject has the option to delete cookies in the Tools/Settings menu of browsers, usually under the settings of the Data Protection menu item.

Delete cookies in the case of the following browsers according to the information on the link marked next to them.
Attention: the browsers listed below - in addition to those that are even less well-known or even coming to the market in the future - are constantly updated, so it is recommended to visit the service provider to assess the current setting options and to learn about their data protection guidelines! 

Mozilla: https://support.mozilla.org/hu/kb/weboldalak-altal-elhelyezett-sutik-torlese-szamito

Google Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.PlatformDesktop&hl=hu

Internet Explorer: https://support.microsoft.com/hu-hu/help/278835/how-to-delete-cookie-files-in-internet-explorer

Microsoft Edge: https://support.microsoft.com/hu-hu/help/4027947/windows-delete-cookies

Opera: http://help.opera.com/Windows/10.20/hu/cookies.html

Safari (iOS systems): https://support.apple.com/hu-hu/HT201265

Cookies are also managed by:

Google: https://policies.google.com/technologies/cookies

Facebook: https://hu-hu.facebook.com/policies/cookies/

USE OF GOOGLE ADWORDS CONVERSION TRACKING

1. The data controller uses the online advertising program called "Google AdWords", and also uses Google's conversion tracking service within its framework. Google conversion tracking is an analytics service of Google Inc. (1600 Amphitheater Parkway, Mountain View, CA 94043, USA; "Google").
2. When a User accesses a website through a Google ad, a cookie required for conversion tracking is placed on their computer. The validity of these cookies is limited and they do not contain any personal data, so the User cannot be identified by them.
3. When the User browses certain pages of the website and the cookie has not yet expired, both Google and the data controller can see that the User has clicked on the ad.
4. Each Google AdWords customer receives a different cookie, so they cannot be tracked through the websites of AdWords customers.
5. The information - obtained with the help of conversion tracking cookies - serves the purpose of creating conversion statistics for customers who choose AdWords conversion tracking. In this way, clients are informed about the number of users who click on their ad and are redirected to a page with a conversion tracking tag. However, they do not get access to information that could identify any user.
6. If you do not wish to participate in conversion tracking, you can decline this by disabling the installation of cookies in your browser. After that, you will not be included in the conversion tracking statistics.
7. Further information, as well as Google's privacy statement, is available on the following page:  http://www.google.de/policies/privacy/

USE OF GOOGLE ANALYTICS

1. This website uses Google Analytics, a web analytics service provided by Google Inc. ("Google"). Google Analytics uses so-called "cookies", text files that are saved on your computer, thus facilitating the analysis of the use of the website visited by the User. 
2. The information created by cookies related to the website used by the User is usually sent to and stored on one of Google's servers in the USA. By activating IP anonymization on the website, Google shortens the User's IP address beforehand within the member states of the European Union or in other states that are parties to the Agreement on the European Economic Area. 
3. The full IP address is 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 how the User used the website, to prepare reports related to website activity for the website operator, and to provide additional services related to website and Internet use. 
4. Within the scope of Google Analytics, the IP address transmitted by the User's browser is not combined with other Google data. The User can prevent the storage of cookies by setting their browser accordingly, but please note that in this case, not all functions of this website may be fully usable. You can also prevent Google from collecting and processing the User's website usage data (including IP address) through cookies by downloading and installing the browser plugin available at the following link. https://tools.google.com/dlpage/gaoptout?hl=hu

NEWSLETTER, DM ACTIVITY

1. XLVIII of 2008 on the basic conditions and certain limitations of economic advertising activity. Pursuant to § 6 of the Act, the User may give prior and express consent to contact the Service Provider with its advertising offers and other mailings at the contact details provided during registration.
2. In addition, the Customer may, bearing in mind the provisions of this information, consent to the Service Provider managing his personal data necessary for sending advertising offers.
3. The Service Provider does not send unsolicited advertising messages, and the User can unsubscribe from the sending of offers free of charge without limitation or justification. In this case, the Service Provider deletes all personal data necessary for sending advertising messages from its records and does not contact the User with further advertising offers. User can unsubscribe from advertisements by clicking on the link in the message.
4. The fact of data collection, the scope of processed data and the purpose of data management: 

5. Scope of stakeholders: All stakeholders who subscribe to the newsletter.
6. Purpose of data management: sending electronic messages containing advertising (e-mail, sms, push message) to the person concerned, providing information about current information, products, promotions, new functions, etc. 
7. Duration of data management, deadline for deletion of data: data management lasts until withdrawal of consent, i.e. until unsubscription.
8. Data management registration number: NAIH-79928/2014.
9. The person of the possible data controllers entitled to access the data, the recipients of the personal data: The personal data can be handled by the sales and marketing staff of the data controller, in compliance with the above principles.
10. Description of the rights of data subjects related to data management: 

• The data subject may request from the data controller access to personal data relating to him, their correction, deletion or restriction of processing, and
  • you can object to the processing of such personal data, as well as 
  • the data subject has the right to data portability and to withdraw consent at any time.

11. The data subject can initiate access to personal data, their deletion, modification or restriction of processing, portability of data, objection to data processing in the following ways:
    - by post to 1136 Budapest, Raoul Wallenberg u. 12. 5. em. at door 3,
    - via e-mail a swamiayurvedakft@gmail.com by e-mail, 
    – by phone at +36-20-482-2677.
12. The person concerned can unsubscribe from the newsletter at any time, free of charge.
13. Legal basis for data management: the consent of the data subject, Article 6 (1) points a) and f) and XLVIII of 2008 on the basic conditions and certain limitations of economic advertising activities. Section 6 (5) of the Act:

The advertiser, the advertising service provider, or the publisher of the advertisement - within the scope specified in the consent - keeps a record of the personal data of the persons who have given their consent. The data recorded in this register - relating to the recipient of the advertisement - can only be handled in accordance with the consent statement, until it is revoked, and can only be transferred to third parties with the prior consent of the person concerned.

14. We inform you that 

• data management is based on your consent.
  • you must provide personal data if you want to receive a newsletter from us.
  • failure to provide data will result in us not being able to send you a newsletter.

COMPLAINT HANDLING

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

2. Scope of stakeholders: All stakeholders who purchase on the website and complain about quality issues.
3. The duration of the data management, the deadline for the deletion of the data: Copies of the minutes, transcripts and the response to the objection taken in the CLV of 1997 on consumer protection. Act 17/A. § (7) must be kept for 5 years.
4. The person of the possible data controllers entitled to access the data, the recipients of the personal data: The personal data can be handled by the sales and marketing staff of the data controller, in compliance with the above principles.
5. Description of the rights of data subjects related to data management: 

• The data subject may request from the data controller access to personal data relating to him, their correction, deletion or restriction of processing, and
  • you can object to the processing of such personal data, as well as 
  • the data subject has the right to data portability and to withdraw consent at any time.

6. The data subject can initiate access to personal data, its deletion, modification or restriction of processing, portability of data, objection to data processing in the following ways:
   - by post to 1136 Budapest, Raoul Wallenberg u. 12. 5. em. at door 3,
   - via e-mail a swamiayurvedakft@gmail.com by e-mail, 
   – by phone at +36-20-482-2677.
7. Legal basis for data management: Article 6 (1) point c) and CLV of 1997 on consumer protection. Act 17/A. (7) of §
8. We inform you that 

• the provision of personal data is based on a contractual obligation.
  • the processing of personal data is a prerequisite for the conclusion of the contract.
  • you must provide personal data so that we can handle your complaint.
  • failure to provide data will result in us not being able to handle your complaint.

SOCIAL MEDIA

1. The fact of data collection, the scope of the processed data: Facebook/Google+/TikTok/Youtube/Instagram, etc. the name registered on social networking sites and the user's public profile picture.
2. Scope of stakeholders: All stakeholders who have registered on Facebook/Google+/TikTok/Pinterest/Youtube/Instagram, etc. on social networking sites and “liked” the website.
3. Purpose of data collection: Sharing, "liking" and popularizing certain content elements, products, promotions or the website itself on social networks.
4. The duration of the data management, the deadline for the deletion of the data, the identity of the possible data controllers entitled to access the data and the description of the rights of the data subjects in relation to data management: The data subject can find out about the source of the data, its management, the method of transfer and its legal basis on the given social site. Data management takes place on social media sites, so the duration and method of data management, as well as the options for deleting and modifying data, are governed by the regulations of the given social media site.
5. The legal basis for data management: the voluntary consent of the concerned person to the processing of her personal data on social networking sites.

CUSTOMER RELATIONS AND OTHER DATA MANAGEMENT

1. If a question arises during the use of our data management services, or if the data subject has a problem, you can contact the data manager using the methods provided on the website (telephone, e-mail, social media, etc.).
2. The data controller processes received e-mails, messages, on the phone, on Facebook, etc. data provided, together with the name and e-mail address of the interested party, as well as other voluntarily provided personal data, will be deleted after a maximum of 2 years from the date of data disclosure.
3. We provide information on data management not listed in this information when the data is collected.
4. The Service Provider is obliged to provide information, communicate and hand over data, and make documents available in response to an exceptional official request, or in the case of requests from other bodies based on the authorization of the law.
5. In these cases, the Service Provider only releases personal data to the requester - if she has indicated the exact purpose and the scope of the data - to the extent and to the extent that is absolutely necessary to achieve the purpose of the request.

RIGHTS OF THE DATA PARTIES

1. Right of access

You have the right to receive feedback from the data controller as to whether your personal data is being processed, and if such data is being processed, you are entitled to access the personal data and the information listed in the regulation.

2. Right to rectification

You have the right to request that the data controller correct inaccurate personal data concerning you without undue delay. Taking into account the purpose of data management, you are entitled to request the completion of incomplete personal data, including by means of a supplementary statement.

3. The right to erasure

You have the right to request that the data manager delete your personal data without undue delay, and the data manager is obliged to delete your personal data without undue delay under certain conditions.

4. The right to be forgotten

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

5. The right to restrict data processing 

You have the right to have the data controller restrict data processing at your request if one of the following conditions is met:
• You dispute the accuracy of the personal data, in which case the limitation applies to the period that allows the data controller to check the accuracy of the personal data; 
• the data processing is illegal and you object to the deletion of the data and instead request the restriction of its use; 
• the data controller no longer needs the personal data for the purpose of data management, but you require them to present, enforce or defend legal claims; 
• You objected to data processing; in this case, the limitation applies to the period until it is established whether the legitimate reasons of the data controller take precedence over your legitimate reasons.

6. The right to data portability 

You have the right to receive the personal data about you that you have provided to a data controller in a segmented, widely used, machine-readable format, and you have the right to transmit this data to another data controller without being hindered by the data controller whose provided the personal data to you (...)

7. The right to protest 

You have the right to object at any time to the processing of your personal data by (…), including profiling based on the aforementioned provisions, for reasons related to your own situation. 

8. Protest on the evening of direct business acquisition

If personal data is processed for direct business acquisition, you have the right to object at any time to the processing of your personal data for this purpose, including profiling, if it is related to direct business acquisition. If you object to the processing of personal data for the purpose of direct business acquisition, then the personal data may no longer be processed for this purpose.

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

You have the right not to be subject to the scope of a decision based solely on automated data management, including profiling, which would have legal effects on you or would similarly significantly affect you.
The previous paragraph does not apply if the decision:
• Necessary to conclude or fulfill the contract between you and the data controller;
• it is made possible by EU or member state law applicable to the data controller, which also establishes appropriate measures for the protection of your rights and freedoms, as well as your legitimate interests; or
• Based on your express consent.

ACTION DEADLINE

The data controller will inform you of the measures taken following the above requests without undue delay, but in any case within 1 month from the receipt of the request. 

If necessary, this can be extended by 2 months. The data controller will inform you of the extension of the deadline, indicating the reasons for the delay, within 1 month of receiving the request. 

If the data controller does not take measures following your request, it will inform you without delay, but at the latest within one month of the receipt of the request, of the reasons for the failure to take action, as well as the fact that you can file a complaint with a supervisory authority and exercise your right to judicial redress.

SECURITY OF DATA MANAGEMENT

The data controller and the data processor implement appropriate technical and organizational measures, taking into account the state of science and technology and the costs of implementation, as well as the nature, scope, circumstances and purposes of data management, as well as the variable probability and severity of the risk to the rights and freedoms of natural persons. , to guarantee a level of data security appropriate to the degree of risk, including, among others, where applicable:

1. a) pseudonymization and encryption of personal data;
2. b) ensuring the continuous confidentiality, integrity, availability and resilience of the systems and services used to manage personal data;
3. c) in the event of a physical or technical incident, the ability to restore access to personal data and the availability of data in a timely manner;
4. d) a procedure for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures taken to guarantee the security of data management.

NOTIFICATION OF THE DATA PROTECTION INCIDENT

If the data protection incident is likely to involve a high risk for the rights and freedoms of natural persons, the data controller shall inform the data subject of the data protection incident without undue delay.

In the information provided to the data subject, the nature of the data protection incident must be clearly and comprehensibly described, and the name and contact information of the data protection officer or other contact person providing additional information must be provided; the likely consequences of the data protection incident must be described; the measures taken or planned by the data controller to remedy the data protection incident must be described, including, where appropriate, measures aimed at mitigating any adverse consequences resulting from the data protection incident.

The data subject need not be informed if any of the following conditions are met:
• the data controller has implemented appropriate technical and organizational protection measures and these measures have been applied to the data affected by the data protection incident, in particular those measures - such as the use of encryption - that make them unintelligible to persons not authorized to access personal data the data;
• after the data protection incident, the data controller has taken additional measures to ensure that the high risk to the rights and freedoms of the data subject is unlikely to materialize in the future;
• providing information would require a disproportionate effort. In such cases, the data subjects must be informed through publicly published information, or a similar measure must be taken that ensures similarly effective information to the data subjects.

If the data controller has not yet notified the data subject of the data protection incident, the supervisory authority, after considering whether the data protection incident is likely to involve a high risk, may order the data subject to be informed.

REPORTING A DATA PROTECTION INCIDENT TO THE AUTHORITY

The data controller shall report the data protection incident to the competent supervisory authority pursuant to Article 55 without undue delay and, if possible, no later than 72 hours after becoming aware of the data protection incident, unless the data protection incident is likely to pose no risk to the rights of natural persons and freedoms. If the notification is not made within 72 hours, the reasons justifying the delay must also be attached.

OPPORTUNITY TO COMPLAINT

You can file a complaint with the National Data Protection and Freedom of Information Authority against possible violations of the data controller: 

National Data Protection and Freedom of Information Authority
1055 Budapest, Falk Miksa utca 9-11.
Post address: 1363 Budapest, Pf. 9.
Phone: +36 -1-391-1400
Fax: +36-1-391-1410
E-mail: ugyfelszolgalat@naih.hu

CLOSING WORD

During the preparation of the policy, we paid attention to 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 flow of such data, as well as on the repeal of Regulation 95/46/EC (general data protection regulation) (2016 April 27)
– CXII of 2011 Act - on the right to self-determination of information and freedom of information (hereinafter: Infotv.)
– CVIII of 2001 Act - on certain issues of electronic commercial services and services related to the information society (mainly § 13/A)
– XLVII of 2008 law - on the prohibition of unfair commercial practices towards consumers;
– XLVIII of 2008 Act - on the basic conditions and certain limitations of economic advertising (especially § 6.a)
– 2005 XC. Act on Electronic Freedom of Information
– Act C of 2003 on electronic communications (specifically § 155.a)
– 16/2011. no. Opinion on the EASA/IAB Recommendation on Best Practices for Behavioral Online Advertising
– The recommendation of the National Data Protection and Freedom of Information Authority on the data protection requirements of prior information
– Regulation (EU) 2016/679 of the European Parliament and of the Council (April 27, 2016) on the protection of natural persons with regard to the processing of personal data and on the free flow of such data, and on the repeal of Regulation 95/46/EC