Data Controller and Contact Details:

Name: Beatrix Pach
Registered office: 1118 Budapest, Frankhegy u. 6.
Tax number: 91116901-1-43
E-mail: pachbeatrix84@gmail.com
Phone: +36 30 294 3440

Data Protection Officer Contact Details:

Name: Beatrix Pach
Registered office: 1118 Budapest, Frankhegy u. 6.
Tax number: 91116901-1-43
E-mail: pachbeatrix84@gmail.com
Phone: +36 30 294 3440

Definitions

“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;
“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;
“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;
“processor”: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
“recipient”: a natural or legal person, public authority, agency or other 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;
“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;
“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.

Principles relating to the processing of personal data

Processing Activities

Processors Engaged

Hosting provider

Activity carried out by the processor: Hosting service
Name and contact details of the processor:
Name: Rackhost Zrt.
Mailing address: 6722 Szeged, Tisza Lajos körút 41.
E-mail address: info@rackhost.hu
Phone number: +36 1 445 1200
The fact of processing, scope of data processed: All personal data provided by the data subject.
Scope of data subjects: All data subjects using the website.
Purpose of processing: Making the website available and ensuring its proper operation.
Duration of processing, deadline for erasure: Until the termination of the agreement between the controller and the hosting provider, or until the data subject’s erasure request addressed to the hosting provider.
Legal basis for processing: the User’s consent, Section 5(1) of the Info Act, Article 6(1)(a), and Section 13/A(3) of Act CVIII of 2001 on certain issues of electronic commerce services and information society services.

Management of Cookies

1.) Cookies typical of online stores are the so-called “cookie used for a password-protected session”, “cookies necessary for the shopping cart” and “security cookies”, the use of which does not require prior consent from the data subjects.

2.) The fact of processing, scope of data processed: Unique identification number, dates, times

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

4.) Purpose of processing: Identifying users, keeping records of the “shopping cart” and tracking visitors.

5.) Duration of processing, deadline for erasure:
Cookie type — Legal basis — Duration of processing — Scope of data processed
Session cookies — Section 13/A(3) of Act CVIII of 2001 on certain issues of electronic commerce services and information society services (E-commerce Act) — The period until the end of the relevant visitor session — connect.sid

6.) Persons entitled to access the data and possible controllers: The controller does not process personal data through the use of cookies.

7.) Description of the data subjects’ rights: Data subjects have the option to delete cookies in the Tools/Settings menu of their browsers, generally under the Privacy settings.

8.) Legal basis for processing: No consent is required from the data subject where the sole purpose of using cookies is to carry out the transmission of a communication over an electronic communications network, or where it is strictly necessary for the provider to provide an information society service explicitly requested by the subscriber or user.

Use of Google AdWords Conversion Tracking

The controller uses the online advertising program called “Google AdWords” and, within its framework, uses Google’s conversion tracking service. Google conversion tracking is an analytics service of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”).
When a User reaches a website through a Google advertisement, a cookie required for conversion tracking is placed on their computer. These cookies have a limited validity and do not contain any personal data, so the User cannot be identified through them.
When the User browses certain pages of the website and the cookie has not yet expired, both Google and the controller can see that the User clicked on the advertisement.
Each Google AdWords customer receives a different cookie, so they cannot be tracked across the websites of AdWords customers.
The information obtained with the help of the conversion tracking cookies serves to compile conversion statistics for customers who have opted for AdWords conversion tracking. In this way, customers learn the number of users who clicked on their advertisement and were forwarded to a page bearing a conversion tracking tag. However, they do not obtain information by which any user could be identified.
If you do not wish to take part in conversion tracking, you can refuse it by disabling the installation of cookies in your browser. You will then not appear in the conversion tracking statistics.
Further information and Google’s privacy statement are available at: www.google.de/policies/privacy/

Use of Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses so-called “cookies”, text files that are stored on your computer to help analyse the use of the website visited by the User.
The information generated by the cookies about the website used by the User is usually transmitted to and stored on one of Google’s servers in the USA. By activating IP anonymisation on the website, Google truncates the User’s IP address beforehand within the Member States of the European Union or in other states party to the Agreement on the European Economic Area.
Only in exceptional cases is the full IP address transmitted to a Google server in the USA and truncated 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 further services relating to website and internet use.
Within the framework 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; however, 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 data generated by the cookies relating to your use of the website (including your IP address) by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=hu

Complaint Handling

1.) The fact of data collection, scope of data processed and purpose of processing:
Personal data — Purpose of processing
Full name — Identification, keeping in contact.
E-mail address — Keeping in contact.
Phone number — Keeping in contact.

2.) Scope of data subjects: All data subjects who purchase on the webshop website and who raise a quality objection or make a complaint.

3.) Duration of processing, deadline for erasure: Copies of the record, transcript and response drawn up regarding the objection must be retained for 5 years pursuant to Section 17/A(7) of Act CLV of 1997 on Consumer Protection.

4.) Persons entitled to access the data and possible controllers, recipients of the personal data: The personal data may be processed by the controller’s sales and marketing staff, in compliance with the principles set out above.

5.) Description of the data subjects’ rights in connection with the processing:

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

6.) The data subject may initiate access to, erasure, modification or restriction of the processing of the personal data, data portability and objection to processing in the following ways:

by post at 1118 Budapest, Frankhegy u. 6.,
by e-mail at pachbeatrix84@gmail.com,
by phone at +36 30 294 3440.

7.) Legal basis for processing: consent of the data subject, Article 6(1)(c), Section 5(1) of the Info Act, and Section 17/A(7) of Act CLV of 1997 on Consumer Protection.

8.) Please note that

the provision of the personal data is based on a contractual obligation
the processing of personal data is a precondition for concluding the contract.
you are obliged to provide the personal data so that we can handle your complaint.
failure to provide the data results in us being unable to handle the complaint received from you.

Social Media Pages

The fact of data collection, scope of data processed: The name registered on social media pages such as Facebook/Google+/Twitter/Pinterest/Youtube/Instagram, etc., and the user’s public profile picture.
Scope of data subjects: All data subjects who have registered on social media pages such as Facebook/Google+/Twitter/Pinterest/Youtube/Instagram, etc., and have “liked” the website.
Purpose of data collection: Sharing, “liking” or promoting, on social media pages, certain content elements, products or promotions of the website, or the website itself.
Duration of processing, deadline for erasure, persons entitled to access the data and possible controllers, and description of the data subjects’ rights: The data subject can find information about the source of the data, their processing, the method of transfer and the legal basis on the relevant social media page. The processing takes place on the social media pages, so the duration and manner of processing, and the possibilities for erasing and modifying the data, are governed by the rules of the relevant social media page.
Legal basis for processing: the data subject’s voluntary consent to the processing of their personal data on the social media pages.

Customer Relations and Other Processing Activities

Should a question arise or the data subject have a problem during the use of the controller’s services, they may contact the controller in the ways provided on the website (phone, e-mail, social media pages, etc.).
The controller erases the received e-mails, messages, and data provided by phone, on Facebook, etc., together with the inquirer’s name and e-mail address and any other voluntarily provided personal data, no later than 2 years after the communication of the data.
We provide information about processing activities not listed in this notice at the time the data are collected.
In the event of an exceptional official request, or a request from other bodies based on statutory authorisation, the Service Provider is obliged to provide information, disclose and transfer data, and make documents available.
In such cases, the Service Provider discloses personal data to the requesting party — provided that the exact purpose and scope of the data have been indicated — only to the extent and in the amount that is absolutely necessary to achieve the purpose of the request.

Rights of the Data Subjects

Right of access
You have the right to obtain from the controller confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and to the information listed in the Regulation.
Right to rectification
You have the right to obtain from the 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.
Right to erasure
You have the right to obtain from the controller the erasure of personal data concerning you without undue delay, and the controller is obliged to erase personal data concerning you without undue delay under certain conditions.
Right to be forgotten
Where the controller has made the personal data public and is obliged to erase them, taking account of available technology and the cost of implementation, it takes reasonable steps, including technical measures, to inform controllers processing the data that you have requested the erasure of any links to, or copy or replication of, those personal data.
Right to restriction of processing
You have the right to obtain from the controller restriction of processing where one of the following applies:
– you contest the accuracy of the personal data, for a period enabling the controller to verify their accuracy;
– 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; the restriction applies for the period pending verification of whether the legitimate grounds of the controller override your legitimate grounds.
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 you have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided (…)
Right to object
You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you (…), including profiling based on those provisions.
Objection in the case of direct marketing
Where personal data are processed for direct marketing purposes, you have the right to object at any time to the 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 may no longer be processed for such purposes.
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 previous paragraph does not apply where the decision:

is necessary for entering into, or performance of, a contract between you and the 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.

Deadline for Taking Action

The controller informs you without undue delay, and in any case within 1 month of receipt of the request, of the action taken on the above requests.

If necessary, this may be extended by 2 months. The controller informs 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, it informs you without delay, and at the latest within one month of receipt of the request, of the reasons for not taking action and of the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.

Security of Processing

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

the pseudonymisation and encryption of personal data;
the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
the ability to restore the availability of and access to personal data in a timely manner in the event of a physical or technical incident;
a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.

Communication of a Personal Data Breach to the Data Subject

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

The communication to the data subject must describe in clear and plain language the nature of the personal data breach and 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 breach; and describe the measures taken or proposed to be taken by the controller to address it, including, where appropriate, measures to mitigate its possible adverse effects.

The data subject need not be informed if any of the following conditions is met:

the controller has implemented appropriate technical and organisational protection measures, and those measures were applied to the data affected by the breach, in particular measures — such as encryption — that render the data unintelligible to any person not authorised to access them;
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 breach to the data subject, the supervisory authority, having considered the likelihood of the breach resulting in a high risk, may require it to do so.

Notification of a Personal Data Breach to the Authority

The controller notifies the personal data breach to the supervisory authority competent under Article 55 without undue delay and, where feasible, not later than 72 hours after having become aware of it, unless the 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 must be accompanied by the reasons for the delay.

Possibility to Lodge a Complaint

A complaint against a possible infringement by the controller may be lodged with the Hungarian National Authority for Data Protection and Freedom of Information:

Hungarian National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság)
1055 Budapest, Falk Miksa u. 9-11.
Mailing address: 1363 Budapest, Pf.: 9.
Phone: +36-1-391-1400
Fax: +36-1-391-1410
E-mail: ugyfelszolgalat@naih.hu

Closing Remarks

In preparing this notice we had regard to the following legislation:

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)
Act CXII of 2011 – on the Right of Informational Self-Determination and on Freedom of Information (hereinafter: Info Act)
Act CVIII of 2001 – on certain issues 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 business advertising activity (in particular Section 6)
Act XC of 2005 on the Freedom of Electronic Information
Act C of 2003 on Electronic Communications (specifically Section 155)
Opinion 16/2011 on the EASA/IAB Best Practice Recommendation on Online Behavioural Advertising
Recommendation of the Hungarian National Authority for Data Protection and Freedom of Information on the data protection requirements of prior information
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