Privacy Policy

SIKLOJEGY.HU

Teletrend Kft.

  

Introduction

Teletrend Kft. (1118 Budapest, Dayka Gábor utca 32/C., tax number: 10800399-2-43, company registration number/registry number: 01-09-260147) (hereinafter: Service Provider, data controller) is subject to the following policy:

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 27, 2016), we provide the following information.

This data protection policy governs the data management of the following websites/mobile applications: https://siklojegy.hu 

The data protection policy is available from the following page: https://siklojegy.hu/en/privacy-policy

Changes to the policy come into effect upon publication at the above address.

Data controller and contact details

Name: Teletrend Kft.

Headquarters: 1118 Budapest, Dayka Gábor utca 32/C.

E-mail: [email protected]

Phone: +36 20 987 3000

 

Concept 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 to 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 management of said data by these public authorities must comply with the applicable data protection rules in accordance with the purposes of 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.

Principles for handling

personal data Personal data:

  1. must be handled legally and fairly, as well as transparently for the data subject ("legality, fair procedure and transparency");

  2. be collected only for specific, clear and legitimate purposes, and they should not be 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. they must be appropriate and relevant in terms of the purposes of data management and must be limited to what is necessary ("data economy");

  4. they must be accurate and, where 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. its storage must take place 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. must be handled in such a way that adequate security of personal data is ensured through the application of appropriate technical or organizational measures, including protection against unauthorized or unlawful 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").

The data controller declares that its data management is carried out in accordance with the basic principles contained in this point.



Data management related to the use of sales/services

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

Personal data

Purpose of data management

Legal basis

Surname and first name

Necessary for making contact, making purchases, and issuing regular invoices.

Article 6 (1) point b) of the GDPR and Elker tv. 13/A. (3) of §

E-mail address

Contact.

Phone

number Keeping in touch, more efficient negotiation of billing-related questions.

Billing name and address Issuance

of the regular invoice, as well as the creation of the contract, definition of its content, modification, monitoring of its performance, invoicing of the resulting fees, and enforcement of related claims.

Article 6 (1) point c) and § 169 (2) of Act C of 2000 on accounting

Date of order / purchase Execution of

technical operation.

Article 6 (1) point b) of the GDPR and Elker tv. 13/A. (3) of §

The IP address of the order / purchase

Execution of a technical operation.

2. Scope of stakeholders: All stakeholders who shop on the website.

3. Duration of data management, deadline for data deletion: If one of the conditions set out in Article 17 (1) of the GDPR exists, it lasts until the data subject's request for deletion. Based on Article 19 of the GDPR, the data controller informs the data subject electronically of the deletion of any personal data provided by the data subject. If the data subject's deletion request also covers the e-mail address he/she has 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 this data must be kept for 8 years based on § 169 (2) of Act C of 2000 on accounting. The data subject's contractual data can be deleted after the expiration of the civil law limitation period based on the deletion request of the data subject.

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. Person of possible data controllers entitled to access the data, recipients of personal data: Personal data can be handled by the data controller's sales and marketing staff, 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 the personal data relating to him, their correction, deletion or restriction of processing, and

  • the data subject has the right to data portability, as well as the right to withdraw consent at any time.

6. The person concerned can initiate access to personal data, its deletion, modification, or restriction of processing, as well as data portability, in the following ways: by

  • post to 1118 Budapest, Dayka Gábor utca 32/C. address,

  • by e-mail at [email protected],

  • by phone at +36 20 987 3000.

7. The legal basis for data management:

1. GDPR Article 6 (1) points b) and c),

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 any case 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.

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

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.

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 would like to inform you that

  • data management is necessary to fulfill the contract.

  • 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.



Management of cookies

1. The so-called "cookie used for a password-protected session", "cookies required for the shopping cart", "security cookies", "necessary cookies", "functional cookies" and the The use of "cookies responsible for managing website statistics" 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. The scope of the stakeholders: All stakeholders visiting the website.

4. Purpose of data management: Identification of users and tracking of visitors.

5. Duration of data management, deadline for deleting data:

Type of cookie

basis

management

Duration

Session cookies (session)

 

CVIII of 2001 on certain issues of electronic commercial services and information society services. Act (Elkertv.) 13/A. Section (3) Period until the end of

relevant

visitor session

the

 

Persistent or saved cookies

 

CVIII of 2001 on certain issues of electronic commercial services and information society services. Act (Elkertv.) 13/A. Section (3)

until the data subject is deleted

Statistical and marketing cookies

CVIII of 2001 on certain issues of electronic commercial services and information society services. Act (Elkertv.) 13/A. Paragraph (3) of §

1 month - 2 years

6. Person of 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. Most browsers used by our users allow you to set which cookies are saved and allow (certain) cookies to be deleted again. If you limit the saving of cookies on certain websites or do not allow third-party cookies, this may lead to the fact that our website can no longer be used in its entirety under certain circumstances. Here you can find information on how you can customize cookie settings for standard browsers:

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

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

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

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



Cookies in detail: 

Google Analytics: _utma, _utmb; _utmt; _utmz - expiration date 2 years; _utmc - not durable; _atuvc, _atuvs; ASP.NET_SessionId: ASP.NET_SessionId; Nop.customer: Nop.customer; NOPCOMMERCE.AUTH: NOPCOMMERCE.AUTH; Anti-Forgery-Form: __RequestVerificationToken; Google Analytics: _ga, _gat, _gid Use

Google Ads conversion

  1. tracking. 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 Ads customer receives a different cookie, so they cannot be tracked through the websites of Ads customers.

  5. The information - obtained with the help of conversion tracking cookies - serves the purpose of creating conversion statistics for Ads' customers who choose 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 want to participate in conversion tracking, you can refuse this by disabling the installation of cookies in your browser. After that, you will not be included in the conversion tracking statistics.

  7. More information and Google's privacy statement can be found on the following page:  https://policies.google.com/privacy



Application of Google Analytics

  1. This website uses the application Google Analytics, which is a web analysis service of 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. Furthermore, with the provisions of this information in mind, the Customer may consent to the Service Provider handling his personal data necessary for sending advertising offers.

3. The Service Provider does not send unsolicited advertising messages, and the User may 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. Users can unsubscribe from advertisements by clicking on the link in the message.

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

Personal data

The purpose of the data management

Legal basis

Name, e-mail address.

Identification, enabling subscription to the newsletter/discount coupons.

Consent of the data subject,

Article 6 (1) point a).

XLVIII of 2008 on the basic conditions and certain limitations of economic advertising activity. § 6 (5) of the Act.

Date of subscription

Technical operation performed.

The IP address at the time of registration

technical operation.

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. Person of possible data controllers entitled to access the data, recipients of personal data: Personal data can be processed by the data controller, as well as its sales and marketing staff, in compliance with the above principles.

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

  • The data subject may request from the data controller access to his/her personal data, their correction, deletion or restriction of processing, as well as

  • object to the processing of his/her personal data and

  • the data subject has the right to data portability, and consent at any time for withdrawal.

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

  • post to 1118 Budapest, Dayka Gábor utca 32/C. address,

  • by e-mail at [email protected],

  • by phone at +36 20 987 3000.

11. The person concerned can unsubscribe from the newsletter at any time, free of charge.

12. We inform you that

  • data management is based on your consent and the service provider's legitimate interest.

  • 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.

  • we inform you that you can withdraw your consent at any time by clicking on unsubscribe.

  • withdrawal of consent does not affect the legality of data processing based on consent, prior to withdrawal.



Complaint handling

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

Personal data

The purpose of the data management

Legal basis

Surname and first name

Identification, contact.

Article 6 (1) point c) and CLV of 1997 on consumer protection. Act 17/A. (7) of §

E-mail address

Contact.

Phone number

Contact.

Billing name and address

Identification, handling of quality objections, questions and problems arising in connection with the ordered products/services.

2. Scope of stakeholders: All stakeholders who purchase on the website and complain about quality.

3. Duration of data management, deadline for deletion of data: Copies of the minutes, transcripts and the response to the objection are provided in the CLV of 1997 on consumer protection. Act 17/A. § (7) must be kept for 3 years.

4. The person of the possible data controllers entitled to access the data, the recipients of the personal data: Personal data can be processed by the data controller and its employees authorized to do so, in compliance with the above principles.

5. Description of the rights of data subjects related to data processing:

  • The data subject may request from the data controller access to the personal data relating to him, their correction, deletion or restriction of processing, and

  • the data subject has the right to data portability, as well as the right to withdraw consent at any time

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

  • post to 1118 Budapest, Dayka Gábor utca 32/C. address,

  • by e-mail at [email protected],

  • by phone at +36 20 987 3000.

7. We inform you that

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

  • the processing of personal data is a prerequisite for the conclusion of the contract.

  • 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.



Recipients with whom personal data is communicated

"recipient": the natural or legal person, public authority, agency or any other body to whom or with whom personal data is communicated, regardless of whether it is a third party.

1. Data processors (those who perform data management on behalf of the data controller)

The data controller uses data processors in order to facilitate its own data management activities and to fulfill its contractual obligations with the data subject and the obligations imposed by legislation.

The data controller places great emphasis on using only data processors who provide adequate guarantees for the implementation of appropriate technical and organizational measures ensuring compliance with the requirements of the GDPR and the protection of the rights of the data subjects.

The data processor and any person acting under the control of the data processor who has access to personal data shall handle the personal data contained in these regulations exclusively in accordance with the instructions of the data controller.

The data controller is legally responsible for the activities of the data processor. The data processor is only liable for damages caused by data processing if it has not complied with the obligations specifically imposed on data processors specified in the GDPR, or if it has ignored or acted contrary to the legal instructions of the data controller.

The data processor has no meaningful decision-making regarding the management of the data.

The data controller can use a storage service provider to provide the IT background, and a courier service as a data processor to deliver the ordered products.

2. Certain data processors

Data processing activity

Name, address, contact

information Hosting service

Webshop hosting: n-tree Solutions Ticketsysteme gmbh. A-6900 Bregenz Brosswaldengasse 12, [email protected].

Correspondence: Magyar Hosting Company name: Websupport Magyarország Kft. Headquarters: 1132 Budapest, Victor Hugo utca 18-22. Tax number: 25138205-2-41 EU social tax number: HU25138205, [email protected]



Other data processor (e.g. online invoicing, web development, marketing)

AppSol Informatikai Zrt., 1122 Budapest, Goldmark Károly u 35., Hungary Company registration number 01- 10-047223 Tax number 23597389-2-43 E-mail [email protected] 

 

"third party": the natural or legal person, public authority, agency or any other body that is not the same as the data subject, the data controller, the data processor or the persons who, under the direct control of the data controller or data processor, are authorized to process personal data they got.

3. Transfer of data to third parties

The third-party data controllers manage the personal data provided by us on their own behalf, in accordance with their own data protection regulations.

Activity of the data controller

Name, address, contact

Transport



Online payment

Bank card acceptance: Novopayment Kft.; 1034 Budapest, Tímár utca 20. 4th floor; +36 1 490 0234

Bank: K&H Bank Zrt., 1095 Budapest, Lechner Ödön fasor 9. , Phone number +36 1 328 9000, E-mail: [email protected] Company registration number: 01-10-041043 Registry court: Company Court of the Metropolitan Court Tax number: 10195664-4-44





Social media

  1. The fact of data collection, the scope of the processed data: Meta/Twitter/Pinterest/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 Meta/Twitter/Pinterest/Youtube/Instagram, etc. on social media sites and "liked" the Service Provider's social media site, or contacted the data controller via the social media site.

  3. Purpose of data collection: Sharing, "liking", following and promoting certain content elements, products, promotions or the website itself on social media sites.

  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 related to data management: The data subject can find information about the source of the data, its management, the method of transfer and its legal basis on the given social media page. Data management takes place on social networking 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 respective social networking site.

  5. The legal basis for data management: the voluntary consent of the concerned person to the processing of his personal data on social networking sites.

Customer relations and other data management

  1. If a question arises during the use of our data controller services, or if the person concerned has a problem, you can contact the data controller using the methods specified on the website (telephone, e-mail, social media sites, etc.).

  2. Data manager handles received e-mails, messages, on the phone, on Meta, 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 communication.

  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, data, transfer, and documents in the event of an exceptional request from an official authority, or in the event of a request from other bodies based on the authorization of the law.

  5. In this case, the Service Provider only releases personal data to the requester - who has indicated the exact purpose and the scope of the data - as much and to the extent that is absolutely necessary for the realization of the targeted search.

Rights of data subjects

1. Right of access

You are entitled to receive feedback from the data controller as to whether your personal data is being processed, and if such data processing is underway, you are entitled 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 corrected without undue delay upon request by the data controller. 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 personal data and is obliged to delete it, taking into account the available technology and the costs of implementation, it will take reasonably expected steps - including technical measures - in order to inform the data controllers handling the data that you requested the deletion of the links to the personal data in question or the copy or duplicate of this personal data.

5. The right to limit data processing 

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

  • You dispute the accuracy of your personal data, in which case the restriction applies to the period that allows the data controller to check accuracy of personal data;

  • the data processing is unlawful 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 submit, enforce or defend legal claims;

  • You have objected to data processing; in this case, the limitation applies to the period until it is determined 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 you have provided to a data controller in a segmented, widely used, machine-readable format, and you are also entitled to transfer this data to another data controller without hindrance the data controller to whom you provided the personal data (...)

7. The right to object 

In the case of data processing based on legitimate interest or public authority as legal grounds, you have the right to object to your personal data at any time for reasons related to your own situation against the handling of (...), including profiling based on the aforementioned provisions.

8. Objection in the event of direct business acquisition

If personal data is processed for the purpose of direct business acquisition, you are entitled 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 direct business purposes, 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:

  • is necessary to conclude or fulfill a 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 of the fact that you can file a complaint with a supervisory authority and exercise your right to judicial redress.

Security

The data manager 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 goals of data management, as well as the variable probability and severity of the risk to the rights and freedoms of natural persons finally in order to guarantee a level of data security commensurate with the level of risk, including, among others, where applicable:

  1. pseudonymization and encryption of personal data;

  2. ensuring the continuous confidentiality, integrity, availability and resilience of the systems and services used to manage 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 for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures taken to guarantee the security of data management.

  5. The processed data must be stored in such a way that unauthorized persons cannot access them. In the case of paper-based data carriers, by establishing the order of physical storage and filing, in the case of data handled in electronic form, by using a central rights management system.

  6. The method of data storage using IT methods must be chosen in such a way that it can be deleted - taking into account the possibly different deletion deadline - at the end of the data deletion deadline, or if necessary for other reasons. The deletion must be irreversible.

  7. Paper-based data carriers must be stripped of personal data using a document shredder or an external organization specialized in document destruction. In the case of electronic data carriers, physical destruction must be ensured in accordance with the rules for the disposal of electronic data carriers, and, if necessary, the data must be securely and irretrievably deleted in advance.

  8. The data controller takes the following specific data security measures:

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

  1. Place the documents in a safe, well-locked dry room.

  2. If personal data managed on paper is to be digitized, the rules applicable to digitally stored documents must be applied

  3. . During the course of their work, the Service Provider's employee performing data management may only leave the room where data management is taking place by locking the data carriers entrusted to him, or by leaving the given room closes it.

  4. Personal data can only be accessed by authorized persons, third parties cannot access it.

  5. The Service Provider's building and premises are equipped with fire protection and property protection equipment.

 IT protection

  1. Computers and mobile devices (other data carriers) used during data management are the property of the Service Provider.

  2. The computer system containing personal data used by the Service Provider is equipped with virus protection.

  3. In order to ensure the security of digitally stored data, the Service Provider uses data backups and archives.

  4. The central server machine can only be accessed by persons with appropriate authorization and only those designated for it.

  5. Data on computers can only be accessed with a username and password.

Informing the data subject about 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 will inform the data subject 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 applicable, 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 breach, in particular measures such as the use of encryption which make the data unintelligible to persons not authorized to access the personal 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.

Notification of 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 be with a risk to the rights and freedoms of natural persons. If the notification is not made within 72 hours, the reasons justifying the delay must also be attached.

Review in the case

If the period of mandatory data management or the periodic review of its necessity is not determined by law, local government decree, or a mandatory legal act of the European Union, the data controller shall review at least every three years from the start of data management whether it, on its behalf or on the basis of its order whether the processing of personal data managed by an acting data processor is necessary for the realization of the purpose of data processing.

The data manager documents the circumstances and results of this review, keeps this documentation for ten years after the review has been completed and makes it available to the Authority at the request of the National Data Protection and Freedom of Information Authority (hereinafter: the Authority).

Complaints

can be lodged with the National Data Protection and Information Freedom Authority against possible violations by the data controller:

National Data Protection and Information Freedom Authority

1055 Budapest, Falk Miksa utca 9-11.

Mailing address: 1363 Budapest, Pf. 9.

Phone: +36-1-391-1400

Fax: +36-1-391-1410

-mail: [email protected]

Final words

note During the preparation of this information sheet, we observed the following legislation:

  • REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (GDPR) 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) 27 April 2016);

  • 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 trade practices towards consumers;

  • XLVIII of 2008 law - on the basic conditions and certain limitations of economic advertising activity (especially § 6);

  • XC of 2005. Act on Electronic Freedom of Information;

  • Act C of 2003 on electronic communications (specifically §155);

  • 16/2011. s. opinion on the EASA/IA 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.