Privacy policy

Privacy policy

MAGreen Kft.

Agribiotica.eu Privacy policy

 

MAGreen Kft.

Privacy policy

Introduction

The MAGreen Kft. (8648 Balatonkeresztúr, Kerti utca 6., taxpayer’s identification number: 14359998-2-14, Companies Register/registration number: 14-09-320074) (hereinafter referred to as Service provider, data controller) agrees to be bound by the following rules:

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

This Privacy Policy governs the processing of data on the following sites/mobile applications: https://agribiotica.eu/hu/, http://agribiotica.eu/, http://agribiotica.uk/, http://agribiotica.co.uk/, http://agribiotica.es/, http://agribiotica.pl/, http://agribiotica.ch/,  http://agribiotica.at/

The privacy policy is available here: https://agribiotica.eu/en/privacy-policy/

Modifications to the policy shall enter into force upon publication at the above address.

Data controller and contact details

Name: MAGreen Kft.

Registered seat: 8648 Balatonkeresztúr, Kerti utca 6.

E-mail: iroda@magreen.hu

Phone number: +36 1 445 0101

Definitions

  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, an identification 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 on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction;
  3. “controller” means the natural or legal person, public authority, agency or 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 such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
  4. “processor” means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller;
  5. “recipient” means a natural or legal person, public authority, agency, or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;
  6. “consent” of the data subject means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
  7. “personal data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored, or otherwise processed;

Principles relating to processing of personal data

Personal data shall be:

  1. processed lawfully, fairly and in a transparent manner in relation to the data subject (“lawfulness, fairness and transparency”);
  2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (“purpose limitation”);
  3. adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed (“data minimisation”);
  4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased, or rectified without delay (“accuracy”);
  5. 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 stored for longer periods insofar as the personal data shall be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (“storage limitation”);
  6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures (“integrity and confidentiality”).

The controller shall be responsible for and be able to demonstrate compliance with the above (“accountability”).                                                                                                                                              

The data controller declares that its processing will be conducted in accordance with the principles set out in this Section.

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

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

Personal data

Purpose of processing

Legal basis

Username

Identification,

enabling registration.

 Article 6 Section (1) (b) of the GDPR and Section 13/A (3) of Act CVIII of 2001 on Electronic Commerce and on Information Society Services

   

Password

Provides secure access to the user’s account.

   
   

Surname and first name

It is necessary for contacting, making a purchase, issuing a proper invoice, exercising the right of withdrawal.

 

E-mail address:

 Contact

Phone number:

Contact, more effective coordination of delivery or invoicing

 

Invoicing name and address

Issuing regular invoices, and

entering into a contract,

determining the content of the contract,

amendment of the contract,

monitoring the fulfilment of the contract,

invoicing fees arising thereof, and

enforcing the related claims.

Article 6 (1) (c)

and Section 169 (2) of Act C of 2000 on Accounting

Delivery name and address

Enabling home delivery.

Article 6 Section (1) (b) of the GDPR and Section 13/A (3) of Act CVIII of 2001 on Electronic Commerce and on Information Society Services

Date of Purchase/registration

Execution of technical operation

 
   

IP address at the time of purchase/registration

Execution of technical operation

 
   
  1. Data subjects: All registered persons/customers on the webshop website shall be deemed data subjects. Neither the username nor the e-mail address need to contain personal data.
  1. Duration of data processing, deadline for deletion of data: If one of the conditions set out in Article 17(1) of the GDPR is met, data procession shall continue until the data subject’s request for erasure. The controller shall communicate the erasure of any personal data provided by the data subject to the data subject by electronic means pursuant to Article 19 of the GDPR. If the data subject’s request for erasure also includes the e-mail address provided by the data subject, the controller shall erase the e-mail address after the information is provided. Except in the case of accounting documents, since according to Article 169 (2) of Act C of 2000 on Accounting, these data must be kept for 8 years. The contractual data of the data subject may be erased after the expiry of the civil limitation period on the basis of a request for erasure by the data subject.

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

 

  • The identity of the potential controllers of the data, the recipients of the personal data: Personal data may be processed by the controller and its authorised staff, 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 concerning him or her, and

    the data subject has the right to data portability and the right to withdraw consent at any time.

6.  The data subject may request access to, deletion, modification, restriction of processing or portability of

personal data in the following ways:

  • by post at 8648 Balatonkeresztúr, Kerti utca 6.,
  • by e-mail at iroda@magreen.hu,
  • by telephone at +36 1 445 0101.

7. Legal basis for processing:

  1. Article 6 (1) (b) and (c) of the GDPR,
  1. Article 13/A (3) of Act CVIII of 2001 on electronic commerce and on 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 conditions being identical, 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 laid down in this Act, but only to the extent and for the duration necessary.

 

  1. In the case of invoices issued in accordance with accounting legislation, Article 6 (1) (c) shall apply.
  1. In the event of enforcement of claims arising from the contract, 5 years pursuant to Section 6:22 of Act V of 2013 on the Civil Code.

Section 6:22 [Statute of limitations]

 

  • Unless otherwise provided for in this Act, claims shall lapse after five years.

 

  • The period of limitation commences upon the due date of the claim.

 

  • An agreement for changing the limitation period shall be executed in writing.

 

  • Any agreement excluding prescription shall be null and void.

 

8. Please be informed that

 

the processing is necessary for the performance of the contract and to provide you with an offer. you are required to provide personal information to enable us to fulfil your order.

failure to provide the data shall result in our inability to process your order.

Cookie management (cookies)

  1. The use of so-called “password-protected session cookies”, “shopping cart cookies”,

“security cookies”, “essential cookies”, “functional cookies” and “cookies responsible for the management of website statistics” does not require prior consent from the data subject.

  1. The fact of processing, the scope of the data processed: Unique identification number, dates, times.
  1. Data subjects: All data subjects visiting the website.
  1. Purpose of processing: Identifying users, tracking visitors, ensuring tailored functionality.
  1. Duration of processing, deadline for erasure of data:

Cookie type

Legal basis for processing:

Duration of

  

processing

Session cookies or other cookies strictly necessary for the functioning of the website           

Article 6(1)(f) of the GDPR                             

The data controller has a legitimate interest in the operation of the website, to ensure the functionality and essential functions of the website and the security of the computer system.           

Period until the end of the relevant visitor session

Permanent or saved cookies 

Article 6 (1) (f) of the GDPR

The data controller has a legitimate interest in the operation of the website, to ensure the functionality and essential functions of the website and the security of the computer system.           

Data is processed until the data subject erases them, or cookies with an exact expiry date (permanent, saved) are stored on the computer until they are erased, but at the latest until their expiry date.

Statistical, marketing cookies

Article 6 (1) (a) of the GDPR

1 month – 2 years

  1. The identity of the potential controllers entitled to access the data: Only the controller can access the personal data.
  1. 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.
  1. Most browsers used by our users allow you to set which cookies should be saved and allow (certain) cookies to be deleted again. If you restrict the saving of cookies on certain websites or do not allow third-party cookies, this may, under certain circumstances, lead to our website no longer being fully usable. Here you will find information on how to customise your cookie settings for common browsers:

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

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

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

Safari (https://support.apple.com/hu-hu/guide/safari/sfri11471/mac)

Facebook pixel

The Facebook pixel is code with the help of which the website can report on conversions, create audiences, and provide the site owner with detailed analytics on how visitors use the site. Facebook remarketing pixel tracking code enables the website visitors to see personalised offers and ads on Facebook. Facebook remarketing list is not suitable for personal identification. For more information about the Facebook Pixel, please visit: https://www.facebook.com/business/help/651294705016616

Using Google Ads conversion tracking

  1. The data controller uses the online advertising program “Google Ads” and makes use of Google’s conversion tracking service within its framework. Google Conversion Tracking is an analytics service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”).
  2. When the user visits a website through a Google ad, a cookie is placed on your computer for conversion tracking. 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 expired, Google and the data controller can see that the User has clicked on the advertisement.
  4. Each Google Ads client receives a different cookie, so they cannot be tracked through Ads clients’ websites.
  5. The information – obtained through the use of conversion tracking cookies – is used to generate conversion statistics for Ads customers who choose to track conversions. Customers are then 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 have access to information that could 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 are available on the following page: https://policies.google.com/privacy

Using Google Analytics

  1. This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”) Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users use the website.
  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 IP anonymisation on the website, Google will first shorten the User’s IP address within the Member States of the European Union or in other states party to the Agreement on the European Economic Area.
  3. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate how the user used the website, to compile reports on website activity for the website operator and to provide other services relating to the website and internet usage.
  4. Within the framework of Google Analytics, the IP address transmitted by the User’s browser will not be merged with other data held by Google. You can prevent the storage of cookies by selecting the appropriate settings on your browser, however, please note that if you do so, you may not be able to use all the functions of this website. You may also prevent Google from collecting and processing information about your use of the website (including your IP address) through cookies by downloading and installing the browser plug-in available at the following link https://tools.google.com/dlpage/gaoptout?hl=hu

Newsletter, DM activity

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

Personal data

Purpose of processing

Legal basis

Name, e-mail address.

Identification, enabling subscription to newsletter/exclusive offers.                             

Consent of the data subject,

Article 6 (1) (a).

Article 6 (5) of Act XLVIII of 2008 on the Basic Conditions and Certain Limitations of Economic Advertising Activities.

Date of subscription

Performing a technical operation.

IP address at the time of subscription

Performing a technical operation.

  1. Data subjects: All data subjects who subscribe to the newsletter.
  1. Purpose of processing: sending electronic messages containing advertising (e-mail, SMS, push messages) to notify the data subject about current information, products, promotions, new features, etc.
  1. Duration of data processing, deadline for erasure of data: data processing lasts until the consent is withdrawn, i.e., until unsubscription.
  • The identity of the potential controllers of the data, the recipients of the personal data: Personal data may be processed by the data controller and its sales and marketing staff, in compliance with the above principles.

9.  Description of data subjects’ rights in relation to data processing:

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

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

  • by post at 8648 Balatonkeresztúr, Kerti utca 6.,
  • by e-mail at iroda@magreen.hu,
  • by telephone at +36 1 445 0101.
  1. The data subject may unsubscribe from the newsletter at any time, free of charge.

Please note that

  • the processing is based on your consent and the legitimate interest of the service provider.
  • you must provide personal data if you wish to receive newsletters from us.
  • failure to provide this information shall result in us not being able to send you newsletters.
  • you can withdraw your consent at any time by clicking on the unsubscribe button.
  • the withdrawal of consent shall not affect the lawfulness of processing based on consent prior to withdrawal.

 

Complaint management

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

Personal data

Purpose of processing

Legal basis

Surname and first name

Identification, contact.

Article 6 (1) (c) and Section 17/A (7) of Act CLV of 1997 on Consumer Protection.                              

E-mail address:

Contact

Phone number:

Contact

Invoicing name and address

Identifying, managing quality complaints, questions and problems with the products/services ordered.                                       

  1. Data subjects: All data subjects who shop on the website and complain about quality.
  1. Duration of processing, deadline for erasure of data: Copies of the record of the objection, the transcript and the reply to the objection shall be kept for 3 years pursuant to Article 17/A (7) of Act CLV of 1997 on Consumer Protection.
  1. The identity of the potential data controllers entitled to access the data, the recipients of the personal data: Personal data may be processed by the controller and its authorised staff, 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 concerning him or her, and
  • the right to data portability and the right to withdraw consent at any time.

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

  • by post at 8648 Balatonkeresztúr, Kerti utca 6.,
  • by e-mail at iroda@magreen.hu,
  • by telephone at +36 1 445 0101.
  1. Please be informed that

 the provision of personal data is based on a legal obligation.

 the processing of personal data is a precondition for the conclusion of the contract.

you must provide personal data so that we can deal with your complaint.

failure to provide the data shall result in us being unable to deal with your complaint.

Recipients to whom personal data are disclosed

“recipient” means a natural or legal person, public authority, agency, or another body, to which the personal data are disclosed, whether a third party or not.

1.  Processors (who conduct processing on behalf of the controller)

 

The controller uses data processors to facilitate its own data processing activities and to fulfil its contractual and legal obligations with data subjects.

The controller places great emphasis on using only processors that provide adequate guarantees to implement appropriate technical and organisational measures to ensure compliance with the requirements of the GDPR and to protect the rights of data subjects.

The processor and any person acting under the control of the controller or the processor who has access to the personal data shall process the personal data covered by this Policy only in accordance with the instructions of the controller.

The controller is legally responsible for the activities of the processor. A processor is only liable for damage caused during processing if it has failed to comply with the obligations specifically imposed on processors by the GDPR or if it has disregarded or acted contrary to lawful instructions from the controller.

The processor has no substantive decision-making power with regard to the processing of the data.

The data controller may use a hosting service provider to provide the IT background and a courier service as a data processor for the delivery of the ordered products.

2.  A list of data processors

 

Data processing activities

Name, address, contact details

Hosting service

 

Name: Hetzner Online GmbH

 

Registered seat: Industriestr. 25, 91710 Gunzenhausen, Deutschland

 

Contact: Tel.: +49 (0)9831 505-0 E-Mail: info@hetzner.com

Other data processing (e.g., online billing, web development, marketing)

 

Számlázz.hu

Company: KBOSS.hu Kft.

Website: https//www.szamlazz.hu Email: info@szamlazz.hu        Phone number: 06 30 35 44 789

 

MailChimp

The Rocket Science Group, LLC 675 Ponce de Leon Ave NE Suite 5000

Atlanta, GA 30308 USA privacy@mailchimp.com

 

“third party” means a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorised to process personal data;

3.  Transfer of data to third parties

 

Third party data controllers process the personal data we provide on their own behalf and in accordance with their own privacy policies.

Data processing activities

Name, address, contact details

Transport

 
 

DHL Express Magyarország Ltd.

 

1097 Budapest, Fehérakác utca 3.

 

Privacy policy: http://www.dhl.hu/hu/jo

 

 gi informaciok.html#privacy

 

Phone number: +36 1 2 45 45 45

 

Gebrüder Weiss Ltd.

 

2330 Dunaharaszti, Raktár u. 2.

 

T +36.24.506.700

 

F +36.24.506.705

 

gw.hungary@gw-world.com

 

www.gw-world.hu

 

CARGOSTAR International Transport and Logistics Ltd.

  
 

1214 Budapest, Rákóczi Ferenc út

 

195-197.

 

Global Project Sped International and Domestic

 

 Trade, Transport and Logistics

 

Limited Liability Company,

1025 Budapest

 

 Vöröstorony u   3. 2.   em. 3.,

Phone number:

 

 +36(23)523500,               

Email address:

 

globalproject@globalproject.hu

Online payments

Cib Bank Zrt.

Address: 1027 BUDAPEST, MEDVE U. 4-14.

Mailing address: 1537 Budapest, P.O. Box: 394.

 

Phone number: (36-1) 423-1000 E-mail address: cib@cib.hu Website: www.cib.hu

Privacy policy:                                

http://www.cib.hu/jogi_nyilatkozat/index

Social media sites

  1. The fact of data collection, the scope of the data processed: The name registered on Meta/Twitter/Pinterest/YouTube/Instagram, etc. social networking sites, as well as the user’s public profile picture.
  2. Data subjects: All data subjects who have registered on the social networking sites Meta/Twitter/Pinterest/YouTube/Instagram etc. and have “liked” the Service Provider’s social networking site or contacted the data controller via the social networking site.
  3. The purpose of the data collection: On social networking sites, sharing or “liking”, following, or promoting certain content, products, promotions, or the website itself.
  4. The duration of the processing, the deadline for erasure of the data, the identity of the potential controllers who have access to the data and the rights of the data subjects with regard to the processing: The data subject can find information about the source of the data, its processing, and the method and legal basis of the transfer on the relevant community site. Data processing is conducted on social community sites, so the duration of data processing, the method of data processing and the possibility to delete and modify data are governed by the rules of the social networking site concerned.
  5. Legal basis of processing: the data subjects’ voluntary consent to the processing of their personal data on social networking sites.

Customer relations and other data processing

  1. If the data subject has any questions or problems when using our data processing services, he can contact the data controller using the methods provided on the website (telephone, e-mail, social networking sites, etc.).
  2. The Data Controller shall delete the received e-mails, messages, data provided by telephone, Meta, etc., along 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 on data processing not listed in this privacy policy shall be provided at the time of collecting the data.
  4. The Service Provider shall be obliged to provide information, disclose data, hand over data, or make documents available in response to exceptional requests from public authorities or other bodies authorised by law.
  5. In such cases, the Service Provider shall disclose personal data to the requesting party only to the degree and to the extent strictly necessary for the purpose of the request, provided that the requesting party has indicated the exact purpose and scope of the data.

Rights of data subjects

1.  Right of access

 

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

2.  The right to rectification

 

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

3.  The right to erasure

 

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

4.  The right to be forgotten

 

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

5.  Right to restriction of processing

 

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

You contest the accuracy of the personal data; in which case the restriction applies for the period of time that allows the controller to verify the accuracy of the personal data;

the processing is unlawful and you object to the erasure of the data and instead request the restriction of their use;

the data 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 interests prevail over your legitimate interests.

6.  Right to data portability

 

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

7.  The right to object

 

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

8.  Objection in case of direct marketing

 

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

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

 

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

The preceding paragraph shall not apply where the decision:

is 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

Without undue delay, and in any event within 1 month of receipt of the request, the controller shall inform you of the action taken on those requests.

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

If the controller fails to act 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 the failure to act, of the possibility to lodge a complaint with a supervisory authority and of 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. the pseudonymisation and encryption of personal data;
  2. the continued confidentiality, integrity, availability and resilience of the systems and services used to process personal data;
  3. in the event of a physical or technical incident, the ability to restore access to and availability of personal data in a timely manner;
  4. a procedure to regularly test, assess and evaluate the effectiveness of the technical and organisational measures taken to ensure the security of processing.
  5. Processed data must be stored in a way that does not allow unauthorised access. In the case of paper-based data carriers, by establishing a system of physical storage and archiving, and in the case of data managed in electronic form, by applying a centralised access management system.
  6. The method of storing the data by computerised means must be chosen in such a way that their deletion can be conducted at the end of the period for erasure or if otherwise necessary, also considering the different erasure deadline. The erasure must be irreversible.
  7. Paper-based data carriers must be deprived of personal data by shredding or by using an external organisation specialised in shredding. In the case of electronic data media, physical destruction and, where necessary, prior secure and irretrievable deletion of the data must be ensured in accordance with the rules on the disposal of electronic data media.
  8. The controller shall take the following specific data security measures:

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

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

IT security

 

  1. The computers and mobile devices (other data carriers) used during data processing are the property of the Service Provider.
  2. The computer system containing personal data used by the Service Provider is protected against viruses.
  3. To ensure the security of digitally stored data, the Service Provider uses data backups and archiving.
  4. The central server machine can only be accessed with the appropriate authorisation and only by designated persons.
  5. Data on computers can only be accessed with a username and password.

Informing the data subject about the personal data breach

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

The information provided to the data subject shall clearly and prominently state 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 controller has implemented appropriate technical and organisational security 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 who are not authorised to access the personal data;

the controller has taken additional measures following the personal data breach to ensure that the considerable risk to the rights and freedoms of the data subject is no longer likely to materialise;

information would require a disproportionate effort. In such cases, the data subjects should be informed by means of publicly disclosed information or a similar measure should be taken to ensure that the data subjects are informed in an equally effective manner.

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

Reporting a data protection incident to the authority

The data protection incident shall be announced by the controller to the supervisory authority competent pursuant to Article 55 without undue delay and, where possible, not 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 must be accompanied by the reasons justifying the delay.

Review in case of mandatory data processing

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

The data controller shall document the circumstances and results of this review, keep this documentation for ten years after the review is completed and submit it to the National Authority for Data Protection and Freedom of Information (hereinafter: Authority) at its request.

Making a complaint

A complaint against a possible infringement 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 utca 9-11.

Mailing address: 1363 Budapest, P.O. BOX: 9.

Phone number: +36 -1-391-1400

Fax: +36-1-391-1410

E-mail: ugyfelszolgalat@naih.hu

Final provisions

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

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

Act CXII of 2011 on the Right to 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 Section 13/A);

Act XLVII of 2008 – on the prohibition of unfair commercial practices against consumers;

Act XLVIII of 2008 – on the basic conditions and certain restrictions of economic advertising activities (in particular Section 6);

Act XC of 2005 on Electronic Freedom of Information;

Act C of 2003 on Electronic Communications (specifically Section 155);

  • Opinion 16/2011 on EASA/IAB Best Practice Recommendation on Online Behavioural Advertising
  • Recommendation of the National Authority for Data Protection and Freedom of Information on the data protection requirements for prior information.