Nexvosolar.hu Data Management Information

Introduction

Energiakapitány Kft. (H-2090 Remeteszőlős, Patak sétány 76., tax number: 29179338-2-13, company registration number: 13-09-211838) (hereinafter referred to as: Service Provider, data controller) undertakes to comply with the following policy:

We provide the following information in accordance with REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (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 Directive 95/46/EC (General Data Protection Regulation).

This privacy policy regulates the data processing of the following sites/mobile applications: https://nexvosolar.hu

The data management information is available on the following page: https://nexvosolar.hu/pages/adatkezelesi-tajekoztato

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

The data controller and its contact details

Name: Energiakapitány Kft.

Registered office: H-2090 Remeteszőlős, Patak sétány 76.

E-mail: kapcsolat@nexvosolar.hu

Phone: +36 20 220 3049, +36 70 513 3558

Definitions

1. “personal data”: 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”: 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”: 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”: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
5. “recipient”: 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”: 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”: 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.
8. “profiling”: any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

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 will 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 principles (“accountability”).

The data controller declares that its data processing is carried out in accordance with the principles set out in this section.

Data processing related to operating a webshop / using a service

1. Fact of data collection, scope of data processed, and purpose of data processing:

Personal dataPurpose of data processingLegal basisUsernameIdentification, enabling registration.Article 6(1)(a) of the GDPR.PasswordServes for secure login to the user account.First and Last nameRequired for contact, purchasing, issuing a proper invoice, exercising the right of withdrawal.Article 6(1)(b) of the GDPR.Email addressCommunication.Phone numberCommunication, more efficient coordination of questions related to invoicing or delivery.Billing name and addressIssuing a proper invoice, furthermore, creating, defining, modifying the content of the contract, monitoring its performance, invoicing the fees arising therefrom, and enforcing related claims.

Article 6(1)(c)

(The legal obligation is Section 169 (2) of Act C of 2000 on Accounting)

Shipping name and addressEnabling home delivery.Article 6(1)(b) of the GDPR.Date of purchase/registrationExecution of technical operation.Section 13/A (3) of the Act CVIII of 2001 on certain issues of electronic commerce services.IP address at the time of purchase/registrationExecution of technical operation.

2. Scope of data subjects: All data subjects who have registered/purchased on the webshop website. Neither the username nor the email address needs to contain personal data.

3. Duration of data processing, deadline for data deletion: If any of the conditions set out in Article 17(1) of the GDPR exist, it lasts until the data subject's request for deletion. The data controller shall inform the data subject electronically, in accordance with Article 19 of the GDPR, about the deletion of any personal data provided by them. If the data subject's deletion request also extends to the email address provided by them, the data controller will also delete the email address after the notification. Except for accounting documents, as these data must be stored for 8 years according to Section 169 (2) of Act C of 2000 on Accounting. The data subject's contractual data can be deleted upon the data subject's request after the civil law limitation period expires.

Accounting documents directly and indirectly supporting bookkeeping (including general ledger accounts, analytical, or detailed records) must be stored in a readable format for at least 8 years, retrievable based on references in bookkeeping records.

4. Possible data controllers entitled to access the data, recipients of personal data: Personal data may be processed by the data controller and its authorised employees, respecting the above principles.

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

• The data subject may request from the data controller access to personal data relating to them, their rectification, erasure or restriction of processing, and
• the data subject has the right to data portability, as well as to withdraw consent at any time.

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

• by post to H-2090 Remeteszőlős, Patak sétány 76.,
• by email to kapcsolat@nexvosolar.hu,
• by phone to +36 20 220 3049, +36 70 513 3558.

7. Legal basis for data processing:

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

2. Section 13/A (3) of Act CVIII of 2001 on certain issues of electronic commerce services, and information society services (hereinafter: Elker tv.):

The service provider may process personal data that are technically indispensable for the provision of the service. The service provider must choose and operate the tools used during the provision of information society services in such a way that, if other conditions are identical, personal data are processed only when it is strictly necessary for the provision of the service and the fulfillment of other purposes specified in this Act, but even in this case only to the necessary extent and for the necessary duration.

3. Article 6(1)(c) in case of invoices issued in accordance with accounting regulations.

4. In case of enforcing claims arising from the contract, 5 years according to Section 6:22 of Act V of 2013 on the Civil Code.

Section 6:22 [Limitation]

(1) Unless otherwise provided by this Act, claims shall be time-barred in five years.

(2) The limitation period shall begin when the claim becomes due.

(3) An agreement to change the limitation period must be in writing.

(4) An agreement excluding limitation is null and void.

8. We inform you that

• data processing is necessary for contract performance and providing an offer.
• you are obliged to provide personal data so that we can fulfill your order.
• failure to provide data results in the consequence that we cannot process your order.

Handling of Cookies

1. No prior consent is required from the data subjects for the use of "password-protected session cookies," "shopping cart cookies," "security cookies," "Necessary cookies," "Functional cookies," and "cookies responsible for managing website statistics."

2. Fact of data processing, scope of data processed: Unique identification number, dates, times.

3. Scope of data subjects: All data subjects visiting the website.

4. Purpose of data processing: User identification, tracking visitors, ensuring customized operation.

5. Duration of data processing, deadline for data deletion:

Cookie type

Legal basis for data processing

Duration of data processing

Session cookies, or other cookies strictly necessary for website operation

No data processing occurs with the use of the cookie.

Until the end of the relevant visitor session, meaning it only remains on the computer until the browser is closed.

Statistical, marketing cookies

Article 6(1)(a) of the GDPR

1 day - 2 years, according to the cookie information, or until the withdrawal of the data subject's consent.

6. Possible data controllers entitled to access the data: Personal data may be accessed by the data controller.

7. Description of the data subjects' rights related to data processing: Data subjects have the option to delete cookies in the browser's Tools/Settings menu, usually under the Privacy settings.

8. Most browsers used by our users allow settings to be adjusted regarding which cookies should be saved and allow (specific) cookies to be deleted again. If you restrict cookie saving on certain websites or do not allow third-party cookies, this may, in some circumstances, mean that our website can no longer be used in its entirety. Here you can find information on how to customize 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)

Use of Google Ads conversion tracking

1. The data controller uses the online advertising program called "Google Ads" and also utilizes Google's conversion tracking service within its framework. Google conversion tracking is an analytical service provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; "Google").
2. When a User accesses a website via a Google advertisement, a cookie necessary 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 clicked on the advertisement.
4. Every Google Ads customer receives a different cookie, so they cannot be tracked across the websites of other Ads customers.
5. The information obtained through conversion tracking cookies serves the purpose of compiling conversion statistics for Ads customers who have chosen conversion tracking. Customers are informed about the number of users who clicked on their advertisement and were redirected to a page with a conversion tracking tag. However, they do not receive information that could identify any user.
6. If you do not wish to participate in conversion tracking, you can opt out by disabling the installation of cookies in your browser. After this, you will not be included in conversion tracking statistics.
7. Based on Google Consent Mode v2, Google also uses two new cookie types: ad_user_data and ad_personalization, which are based on the data subject's consent and relate to the use and sharing of data. ad_user_data is used to obtain consent for advertising purposes for Google's use of user data. ad_personalization regulates whether data can be used to personalize advertisements (e.g., remarketing). The data controller ensures that appropriate consents are obtained or withdrawn via its cookie banner/panel. The withdrawal of consent does not affect the lawfulness of data processing based on consent prior to the withdrawal.
8. Further information and Google's privacy policy are available on the following page: https://policies.google.com/privacy

Use of Google Analytics

1. This website uses Google Analytics, a web analytics service provided by Google Inc. ("Google"). Google Analytics uses "cookies," which are text files placed on your computer, to help the website analyze how users use the site.
2. The information generated by the cookie about your use of the website will generally be transmitted to and stored by Google on servers in the United States. In case of activation of IP anonymization on this website, Google will truncate your IP address within Member States of the European Union or other parties 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 truncated there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage to the website operator.
4. Google will not associate your IP address transmitted by your browser within Google Analytics with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this, you may not be able to use the full functionality of this website. You can also prevent Google's collection and use of data generated by the cookie and relating to your use of the website (including your IP address) by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=hu

Newsletter, DM activity based on consent

1. Pursuant to Section 6 of Act XLVIII of 2008 on the fundamental conditions and certain limitations of economic advertising, the User may give prior and explicit consent to the Service Provider contacting them with its advertising offers and other mailings at the contact details provided during registration.

2. Furthermore, the Client may consent to the Service Provider processing their personal data necessary for sending advertising offers, keeping in mind the provisions of this information sheet.

3. The Service Provider does not send unsolicited advertising messages, and the User can unsubscribe from receiving offers free of charge, without restriction or justification. In this case, the Service Provider will delete all personal data necessary for sending advertising messages from its records and will not contact the User with further advertising offers. The User can unsubscribe from advertisements by clicking on the link in the message.

4. Fact of data collection, scope of processed data and purpose of data processing:

Personal data

Purpose of data processing

Legal basis

Name, email address.

Identification, enabling subscription to newsletters/promotional coupons.

Consent of the data subject,

Article 6 (1) (a).

Section 6 (5) of Act XLVIII of 2008 on the fundamental conditions and certain limitations of economic advertising.

Date of subscription

Execution of a technical operation.

IP address at the time of subscription

Execution of a technical operation.

5. Categories of data subjects: All data subjects who subscribe to the newsletter.

6. Purpose of data processing: sending electronic messages (email, SMS, push message) containing advertisements to the data subject, providing information about current news, products, promotions, new features, etc.

7. Duration of data processing, deadline for data erasure: Data processing lasts until the withdrawal of consent (unsubscription, data subject's request for erasure) or until the termination of the newsletter.

8. Persons authorized to access the data, recipients of personal data: Personal data may be processed by the data controller and its sales and marketing staff, in compliance with the above principles.

9. Information on the data subjects' rights regarding data processing:

• The data subject may request from the data controller access to, rectification, erasure or restriction of processing of personal data concerning them, and
• object to the processing of their personal data, and
• the data subject has the right to data portability and to withdraw consent at any time.

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

• by post to 2090 Remeteszőlős, Patak sétány 76,
• by email to kapcsolat@nexvosolar.hu,
• by phone at +36 20 220 3049, +36 70 513 3558.

11. The data subject may unsubscribe from the newsletter at any time, free of charge.

12. We inform you that

• data processing is based on your consent.
• you are obliged to provide personal data if you wish to receive our newsletter.
• the failure to provide data will result in us being unable to send you a newsletter.
• we inform you that you can withdraw your consent at any time by clicking on the unsubscribe link.
• the withdrawal of consent does not affect the lawfulness of data processing based on consent prior to its withdrawal.

Complaint Handling

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

Personal data

Purpose of data processing

Legal basis

First and last name

Identification, contact.

Article 6 (1) (c).

(relevant legal obligation: Section 17/A (7) of Act CLV of 1997 on consumer protection)

Email address

Contact.

Phone number

Contact.

Billing name and address

Identification, handling quality complaints, questions and problems related to ordered products/services.

2. The scope of data subjects: All data subjects who purchase on the website and submit a quality complaint or grievance.

3. The duration of data processing, the deadline for data deletion: Copies of the minutes, transcripts and responses to complaints must be retained for 3 years, according to Section 17/A (7) of Act CLV of 1997 on consumer protection.

4. Potential data controllers authorized to access the data, recipients of personal data: Personal data may be processed by the data controller and its authorized employees, in compliance with the above principles.

5. Information on the data subjects' rights regarding data processing:

• The data subject may request from the data controller access to, rectification, erasure or restriction of processing of personal data concerning them, and
• the data subject has the right to data portability and to withdraw consent at any time.

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

• by post to 2090 Remeteszőlős, Patak sétány 76,
• by email to kapcsolat@nexvosolar.hu,
• by phone at +36 20 220 3049, +36 70 513 3558.

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 concluding the contract.
• you are obliged to provide personal data so that we can handle your complaint.
• the failure to provide data will result in us being unable to handle your complaint.

Recipients with whom personal data are shared

"recipient": a natural or legal person, public authority, agency or any other body to whom or to which the personal data are disclosed, whether a third party or not.

1. Data processors (who carry out data processing on behalf of the data controller)

The data controller engages data processors to facilitate its own data processing activities and to fulfil its contractual and legal obligations towards the data subject.

The data controller places great emphasis on only engaging data processors who provide adequate guarantees for compliance with the requirements of the GDPR regarding data processing and for the protection of the rights of data subjects, by implementing appropriate technical and organizational measures.

The data processor and any person acting under the direct authority of the data controller or the data processor who has access to personal data shall process the personal data specified in this policy solely in accordance with the data controller's instructions.

The data controller is legally responsible for the data processor's activities. The data processor shall only be liable for damages caused by data processing if they have not complied with the obligations specifically imposed on data processors by the GDPR, or if they have disregarded or acted contrary to the data controller's lawful instructions.

The data processor has no substantive decision-making authority regarding the handling of data.

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

2. Specific data processors

Data processing activity

Name, address, contact details

Hosting service

Shopify Inc. Registered office: 150 Elgin Street, Suite 800, Ottawa, ON, K2P 1L4, Canada European office (legal representation within the EU): Floor 1-2, Victoria Building, c/o Intertrust Ireland, 2nd Haddington Road, Dublin 4, D04 XN32, Ireland Email: support@shopify.com Phone: +1 888 746 7439 Website: https://www.shopify.com/

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

Számlázz.hu 
Company: KBOSS.hu Kft.
Website: https//www.szamlazz.hu
Email: info@szamlazz.hu
Phone: 06 30 35 44 789

"third party": a natural or legal person, public authority, agency or any other 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. Data transfer to third parties

Third-party data controllers process personal data communicated by us on their own behalf, in accordance with their own data protection policies.

Controller's activity

Name, address, contact information

Shipping

GLS General Logistics Systems Hungary Csomag-Logisztikai Kft.
2351 Alsónémedi, Európa u. 2.
info@gls-hungary.com
Phone: 06-29-88-66-94

MPL Magyar Posta Logisztika Kft.
1138 Budapest, Dunavirág utca 2-6.
ugyfelszolgalat@posta.hu 
Phone: (06-1) 767-82-82
GTC: https://www.posta.hu/ugyfelszolgalat/aszf 
Privacy policy: https://www.posta.hu/adatkezelesi_tajekoztato

Online payment

Social Media

1. Fact of data collection, scope of processed data: registered name on Twitter/Pinterest/Youtube/Instagram/TikTok/Linkedin etc. social media pages, and the user's public profile picture.
2. Categories of data subjects: All data subjects who have registered on Twitter/Pinterest/Youtube/Instagram/TikTok/Linkedin etc. social media pages, and have "liked" the Service Provider's social media page, or have contacted the data controller through the social media page.
3. Purpose of data collection: Sharing, "liking", following, promoting certain content elements, products, promotions of the website or the website itself on social media pages.
4. Duration of data processing, deadline for data deletion, identity of possible data controllers authorized to access the data, and information on the data subjects' rights regarding data processing: The data subject can obtain information about the source of the data, its processing, the method of transfer, and the legal basis on the respective social media page. Data processing takes place on social media pages, so the duration, method of data processing, and the possibilities for data deletion and modification are subject to the regulations of the respective social media page.
5. Legal basis for data processing: the data subject's voluntary consent to the processing of their personal data on social media pages.

Facebook / Meta Joint Data Processing

The Data Controller has a Facebook / Meta profile for its activities. The statistical data processing on the Facebook social media page is a joint data processing between the Data Controller and Facebook Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, D2 Dublin, Ireland). Detailed information on the joint data processing agreement is provided in the Facebook Page Insights Controller Addendum. The addendum is available at the following link: https://www.facebook.com/legal/terms/page_controller_addendum

The Data Controller will only communicate via private message on the social media page if you contact us there.

1. Categories of data subjects

• data subject who has registered on the social media page and has "liked" the Data Controller's profile page,
• data subject who contacts the Data Controller via private message on the social media page.

2. Purpose of data processing

The purpose of data processing is to share and promote the Data Controller's activities and services on the Facebook social media page. The Data Controller may use the data provided by the data subject in a private message to respond to the message; otherwise, the Data Controller does not collect or extract data from social media pages.

3. Legal basis for data processing

Data processing is based on Article 6(1)(a) of the GDPR, the legal basis for data processing is the data subject's consent to the processing of their personal data on the Facebook social media page.

4. Scope of processed data

• registered name of the data subject,
• public profile picture of the data subject user
• other public data provided or shared by the data subject on the social media page

5. Source of processed personal data: The source of the processed data is the data subject.

6. Withdrawal of consent: You can withdraw your consent to data processing at any time, and you can delete your post or comment. Data processing takes place through social media pages operated by a third party. If you withdraw your consent, the Data Controller will delete your conversation. The withdrawal of consent does not affect the lawfulness of data processing based on consent before its withdrawal.

Access to personal data, their deletion, modification, or restriction of processing, data portability can be initiated by the data subject in the following ways:

• by post to 2090 Remeteszőlős, Patak sétány 76,
• by email to kapcsolat@nexvosolar.hu,
• by phone at +36 20 220 3049, +36 70 513 3558.

7. Duration of data processing

• until the withdrawal of the data subject's consent,
• if there is an exchange of messages, then for 2 years.

8. Transfer of personal data, recipients, and categories of recipients: See GDPR Article 4(9) for the definition of recipient. The Data Controller will only transfer the Data Subject's personal data to state bodies and authorities – such as courts, prosecutors, investigative authorities and minor offence authorities, the National Authority for Data Protection and Freedom of Information – in exceptional cases and based on a legal obligation.

9. Possible consequences of not providing data

If data is not provided, the data subject will not be able to get information about the Data Controller's activities and services on the Facebook social media page, nor send messages to the Data Controller via Facebook Messenger.

10. Automated decision-making (including profiling): No automated decision-making, including profiling, occurs during data processing.

11. Joint Controller Addendum with Facebook Ireland Ltd.:

The Page Insights feature displays aggregated data that provides insights into how data subjects use the Facebook Page. Facebook Ireland Limited ("Facebook Ireland") and the Data Controller are joint controllers for the processing of analytics data. The Page Insights Addendum of Facebook provides detailed information on the responsibilities of Facebook and the Data Controller regarding the processing of analytics data. The addendum is available at the following link: https://www.facebook.com/legal/terms/page_controller_addendum

Facebook Ireland assumes primary responsibility under the GDPR for the processing of analytics data, and for complying with all relevant obligations under the GDPR concerning the processing of analytics data. Facebook Ireland also makes an extract of the Page Insights Addendum available to all data subjects. The Data Controller ensures that it has an appropriate legal basis under the GDPR for the processing of analytics data, identifies the page data controller, and complies with all other relevant legal obligations. Facebook Ireland is solely responsible for the processing of personal data in connection with the Page Insights feature, except for data falling within the scope of the Page Insights Addendum. The Page Insights Addendum does not grant the Data Controller the right to request personal data of Facebook users processed by Facebook Ireland in connection with Facebook, including Page Insights data. The Data Controller cannot act on behalf of Facebook Ireland or provide responses in fulfilling data protection requests.

Client Relations and Other Data Processing

1. If the data subject has any questions or problems during the use of the data controller's services, they can contact the data controller through the methods provided on the website (phone, email, social media, etc.).
2. The data controller deletes received emails, messages, data provided by phone, Meta, etc., together with the inquirer's name and email address, and other voluntarily provided personal data, at most 2 years after the data provision.
3. We will provide information on data processing not listed in this information at the time of data collection.
4. In exceptional cases of official requests, or at the request of other authorities based on legal authorization, the Service Provider is obliged to provide information, disclose data, transfer data, or make documents available.
5. In such cases, the Service Provider will only disclose personal data to the requesting party – if the precise purpose and scope of the data have been specified – to the extent strictly necessary to achieve the purpose of the request.

Rights of data subjects

1. Right of access

You have the right to obtain confirmation from the data controller as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the information listed in the regulation.

2. Right to rectification

You have the right to obtain from the data controller without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

3. Right to erasure ("right to be forgotten")

You have the right to obtain from the data controller the erasure of personal data concerning you without undue delay and the data controller shall have the obligation to erase personal data without undue delay where one of the specified grounds applies.

4. Right to be forgotten

If the data controller has made the personal data public and is obliged to erase it, taking into account available technology and the cost of implementation, it shall take reasonable steps, including technical measures, to inform data controllers which are processing the personal data that you have requested the erasure by such data controllers of any links to, or copy or replication of, those personal data.

5. Right to restriction of processing

You have the right to obtain from the data controller restriction of processing where one of the following applies:

• you contest the accuracy of the personal data, in which case the restriction applies for a period enabling the controller to verify the accuracy of the personal data;
• the processing is unlawful, and you oppose the erasure of the data and request the restriction of their use instead;
• the controller no longer needs the personal data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims;
• you have objected to processing; in which case the restriction applies for the period until it is verified whether the legitimate grounds of the controller override your legitimate grounds.

6. Right to data portability

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

7. Right to object

In cases of processing based on legitimate interest or public authority, you have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you, including profiling based on those provisions.

8. Objection to direct marketing

Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. If you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

9. Automated individual decision-making, including profiling

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

The preceding paragraph shall not apply if the decision:

• is necessary for entering into, or performance of, a contract between you and a data controller;
• is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
• is based on your explicit consent.

Time limit for action

The controller shall provide information on action taken on your request without undue delay and in any event within 1 month of receipt of the request.

That period may be extended by 2 further months where necessary. The controller shall inform you of any such extension within 1 month of receipt of the request, together with the reasons for the delay.

If the controller does not take action on your request, the controller shall inform you of the reasons for not taking action without undue delay and at the latest within one month of receipt of the request and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.

Data security

Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, the controller and the processor shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:

1. the pseudonymisation and encryption of personal data;
2. the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
3. the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
4. a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.
5. The processed data must be stored in such a way that unauthorised persons cannot access them. In the case of paper-based data carriers, this is achieved by establishing a system of physical storage and archiving, and in the case of electronically processed data, by using a central authorisation management system.
6. The method of storing data using IT must be chosen in such a way that their deletion - taking into account any differing deletion deadlines - can be carried out at the expiry 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 with the help of a shredder or by using an external document shredding service. In the case of electronic data carriers, physical destruction must be ensured according to the rules for scrapping electronic data carriers, or if necessary, prior secure and irreversible deletion of the data.
8. The data controller implements the following specific data security measures:

To ensure the security of personal data processed on paper, the Service Provider implements the following measures (physical protection):

1. Documents must be placed in a secure, lockable, dry room.
2. If personal data processed on paper are digitised, the rules applicable to digitally stored documents must be applied.
3. The Service Provider's staff involved in data processing may only leave the room where data processing is taking place if they lock away the data carriers entrusted to them or lock the room itself.
4. Personal data may only be accessed by authorised persons; third parties may not access them.
5. The Service Provider's building and premises are equipped with fire protection and security devices.

 IT protection

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 equipped with antivirus protection.
3. To ensure the security of digitally stored data, the Service Provider uses data backups and archiving.
4. Only authorised persons with appropriate permissions can access the central server computer.
5. Access to data on computers is only possible with a username and password.

Informing the data subject about data breaches

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

The communication to the data subject shall clearly and in plain language describe the nature of the personal data breach and shall contain the name and contact details of the data protection officer or other contact point where more information can be obtained; describe the likely consequences of the personal data breach; describe the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.

The communication to the data subject shall not be required if any of the following conditions are met:

• the controller has implemented appropriate technical and organisational protection measures, and those measures were applied to the personal data affected by the personal data breach, in particular those that render the personal data unintelligible to any person who is not authorised to access it, such as encryption;
• the controller has taken subsequent measures which ensure that the high risk to the rights and freedoms of data subjects is no longer likely to materialise;
• it would involve disproportionate effort. In such a case, there shall instead be a public communication or similar measure whereby the data subjects are informed in an equally effective manner.

If the controller has not already communicated the personal data breach to the data subject, the supervisory authority, having considered the likelihood that the personal data breach will result in a high risk, may require it to do so.

Notification of a data breach to the authority

The controller shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the supervisory authority competent in accordance with Article 55, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. Where the notification is not made within 72 hours, it shall be accompanied by reasons for the delay.

Review in case of mandatory data processing

If the duration of mandatory data processing, or the periodic review of its necessity, is not determined by law, a local government decree, or a binding legal act of the European Union, the data controller shall review at least every three years from the start of data processing whether the processing of personal data by them, or by a data processor acting on their behalf or instruction, is necessary for the fulfilment of the data processing purpose.

The data controller shall document the circumstances and results of this review, retain this documentation for ten years following the review, and make it available to the National Authority for Data Protection and Freedom of Information (hereinafter: the Authority) upon request.

Right to lodge a complaint

You can lodge a complaint against any alleged infringement by the data controller 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, Pf. 9.
Phone: +36 -1-391-1400
Fax: +36-1-391-1410
E-mail: ugyfelszolgalat@naih.hu

Conclusion

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

• 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 Directive 95/46/EC (General Data Protection Regulation) (GDPR);
• Act CXII of 2011 – on the right to informational self-determination and freedom of information (hereinafter: Infotv.);
• Act CVIII of 2001 – on certain issues of electronic commerce services and information society services (mainly 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 limitations of economic advertising activities (especially 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 the EASA/IAB recommendation on best practice in behavioural online advertising;
• Recommendation of the National Authority for Data Protection and Freedom of Information on the data protection requirements of prior information.