Lugossy Ákos ev.
Privacy Notice
Introduction
THE COMPANY ( Lugossy Ákos ev. (9011 Győr, Kenderes út 31. 1 em. 2a In the event of withdrawal, please return the product to the following address: 2030 Érd, Köszörűs utca 18., tax number: 69704154-1-28, company ID / registration number: 53564306) provides this information.
The following information is provided in accordance with REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Regulation (EC) No 95/46/EC (General Data Protection Regulation).
This privacy notice governs the processing relating to the following site: https://ranger-dog.sk
This privacy notice is available at the following link: https://ranger-dog.com/adatkez...
Amendments to this notice take effect upon their publication at the above address.
The controller and contact details:
Name: Lugossy Ákos ev.
Registered seat: 9011 Győr, Kenderes út 31. 1 em. 2a In the event of withdrawal, please return the product to the following address: 2030 Érd, Köszörűs utca 18.
E-mail: hello@ranger-dog.sk
Telephone: +421 2 3332 9758
Contact details of the person responsible for data protection:
Name: Lugossy Ákos ev.
Registered seat: 9011 Győr, Kenderes út 31. 1 em. 2a In the event of withdrawal, please return the product to the following address: 2030 Érd, Köszörűs utca 18.
E-mail: hello@ranger-dog.sk
Telephone: +421 2 3332 9758
Definitions
- “personal data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
- “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
- “controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may also be provided for by Union or Member State law;
- “processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
- “recipient” means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. Public authorities which may have access to personal data in the framework of a particular inquiry in accordance with Union or Member State law are not recipients; the processing of those data by those public authorities must be in compliance with the applicable data protection rules in accordance with the purposes of the processing;
- “consent of the data subject” means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
- “personal data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
Principles relating to the processing of personal data
Personal data shall be:
- Processing must be lawful, fair and transparent to the data subject (“lawfulness, fairness and transparency”);
- collected only for specified, explicit and legitimate purposes and not 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 is not considered incompatible with the initial purposes, in accordance with Article 89(1) (“purpose limitation”);
- processing must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is intended (“data minimisation”);
- they must be 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 undue delay (“accuracy”);
- they must be 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 only insofar as they will be processed 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 data subjects (“storage limitation”);
- processing must be carried out 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 (“integrity and confidentiality”), using appropriate technical or organisational measures.
7. The controller is responsible for compliance with the above requirements and must be able to demonstrate such compliance (“transparency”).
Registration (creating a user account)
1. The fact of data collection, the scope of the data processed and the purposes of the data processing:
| Personal data | Purpose of the data processing | Legal basis |
|---|---|---|
| Surname, first name | Identification, ensuring secure login to the user account. | Article 6(1)(a). |
| E-mail address | Communication, sending system messages, logging in to the user account. | Article 6(1)(a). |
| Password | Ensuring secure login to the user account. | Article 6(1)(a). |
| Time of registration / IP address at registration | Carrying out a technical operation. | Article 6(1)(a). |
The e-mail address need not contain personal data.
2. Data subjects: all data subjects registered on the website/mobile application.
3. Duration of the data processing, time limit for erasure of the data: If one of the conditions set out in Article 17(1) GDPR applies, the data processing lasts until the data subject's request for erasure. Upon deletion of the registration, the personal data are erased immediately. The controller informs the data subject electronically, pursuant to Article 19 GDPR, of the erasure of any personal data provided by the data subject. If the data subject's erasure request also extends to the e-mail address provided, the controller also erases the e-mail address after providing the information.
4. Persons entitled to access the data, recipients of the personal data: The personal data may be processed and accessed by authorised employees of the controller on the basis of the provisions set out in this notice.
5. Information on the data subjects' rights in relation to the data processing:
The data subject may request from the controller access to, rectification, erasure or restriction of the processing of personal data concerning them, and the data subject has the right to data portability and the right to withdraw consent at any time.
6. The data subject may initiate access to, erasure, modification or restriction of processing of their personal data, and data portability, in the following ways:
- by post to this address 9011 Győr, Kenderes út 31. 1 em. 2a In the event of withdrawal, please return the product to the following address: 2030 Érd, Köszörűs utca 18.,
- by e-mail at hello@ranger-dog.sk,
- by telephone on +421 2 3332 9758.
7. Legal basis of the data processing: Article 6(1)(a) GDPR. The data subject's consent.
8. We inform you that:
the data processing is based on your consent;
the provision of personal data is necessary so that we can create the user account;
failure to provide the data has the consequence that we cannot create the user account;
withdrawal of consent does not affect the lawfulness of data processing based on consent before its withdrawal.
Data management
Data processing related to the operation of the webshop
- The fact of collection, the scope of the data processed and the purpose of the processing:
|
Personal data |
Purpose of the data processing |
Legal basis |
|
Username |
Identification, enabling registration. |
Article 6(1)(b) GDPR |
|
Password |
Serves secure access to the user account. |
Article 6(1)(b) GDPR |
|
Surname and first name |
Necessary for contact, purchase, proper invoicing, exercising the right of withdrawal from the contract. |
|
|
E-mail address |
Contact person |
|
|
Telephone number |
Keeping in touch, more efficient coordination of questions relating to invoicing or deliveries. |
|
|
Billing name and address |
Issuing proper invoices and concluding, defining the content of, amending and monitoring the performance of the contract, invoicing the resulting fees and enforcing related claims. |
Article 6(1)(c) and Section 169 (2) of Act C of 2000 on Accounting |
|
Delivery name and address |
Enabling delivery to your home. |
Article 6(1)(b) GDPR |
|
Date of purchase/registration |
Carrying out a technical operation. |
|
|
IP address at the time of purchase/registration |
Carrying out a technical operation. |
- Data subjects: All persons registered/purchasing on the webshop website.
- Duration of the data processing, time limit for erasure of the data: Immediately upon cancellation of the registration. Erasure of all personal data provided by the data subject. If the data subject's erasure request also includes the e-mail address provided by the data subject, the controller also erases that e-mail address after giving notice. With the exception of accounting records, since under Article 169 (2) of Act C of 2000 on Accounting these data must be retained for 8 years.
Accounting documents (including general ledger accounts and analytical or detailed records) directly and indirectly supporting accounting entries must be retained for at least 8 years in legible form, retrievable by reference to the accounting records.
- Identity of possible controllers, recipients of the personal data: The personal data may be processed by the controller's sales and marketing staff in accordance with the above principles.
- Description of the data subjects' rights in relation to the data processing:
- The data subject may request from the controller access to, rectification, erasure or restriction of the processing of personal data concerning them, and
- the data subject has the right to data portability and the right to withdraw consent at any time.
- The data subject may request access to, erasure, rectification or restriction of processing of personal data, data portability, and may object to the processing, in the following ways:
- by post to this address 9011 Győr, Kenderes út 31. 1 em. 2a In the event of withdrawal, please return the product to the following address: 2030 Érd, Köszörűs utca 18.,
- by e-mail at hello@ranger-dog.sk,
- by telephone on +421 2 3332 9758. .
- Legal basis of the data processing:
- Article 6(1)(b) GDPR,
- Section 13/A (3) of Act CVIII of 2001 on certain issues of electronic commerce services and information society services (hereinafter: the E-Commerce Act):
The service provider may process personal data that are technically indispensable for providing the service. Subject to the other conditions being equal, the provider must choose, and in every case operate, the tools used in providing the information society service in such a way that personal data are processed only to the extent absolutely necessary for providing the service and for fulfilling the other purposes laid down in this Act, and then only to the extent and for the period necessary.
- In the case of invoicing in compliance with accounting legislation, Article 6(1)(c) applies
- In the case of enforcing claims arising from the contract, the limitation period under Section 6:21 of Act V of 2013 on the Civil Code is 5 years.
Section 6:22 [Limitation period]
(1) Unless this Act provides otherwise, claims lapse after five years.
(2) The limitation period begins when the claim becomes due.
(3) An agreement to change the limitation period must be made in writing.
(4) An agreement excluding limitation is null and void.
- Please note that
- the data processing is necessary for the performance of the contract.
- you are obliged to provide the personal data so that we can fulfil your order.
- failure to provide the data will have the consequence that we cannot process your order.
Newsletter, DM activity
- In accordance with Section 6 of Act XLVIII of 2008 on the essential conditions and certain limitations of commercial advertising activity, the user may give prior express consent to the service provider contacting them with advertising offers and other mailings at the contact details provided at registration.
- In addition, in accordance with the provisions of this information, the customer may consent to the processing by the service provider of the personal data necessary for sending advertising offers.
- The service provider will not send unsolicited advertising messages, and the user may unsubscribe from receiving such messages free of charge, without any restriction and without giving reasons. In this case the service provider will erase from its records all personal data necessary for sending advertising messages and will not contact the User with further advertising offers. The user may unsubscribe from advertising messages by clicking the link in the message.
- The fact of collection, the scope of the data processed and the purpose of the processing:
|
Personal data |
Purpose of the data processing |
Legal basis |
|
Name, e-mail address. |
Identification, so that it is possible to subscribe to news/special offers. |
The data subject's consent, Article 6(1)(a). In accordance with Section 6 of Act XLVIII of 2008 on the essential conditions and certain limitations of commercial advertising activity, Section 13 (5). |
|
Date of subscription |
Carrying out a technical operation. |
|
|
IP address at the time of subscription |
Carrying out a technical operation. |
- Data subjects: Everyone who has subscribed to the newsletter.
- Purpose of the processing: sending electronic messages (e-mail, SMS, push messages) containing advertising to the data subject, providing information on current news, products, promotions, new features, etc.
- Duration of the data processing, time limit for erasure of the data: until the consent is withdrawn, i.e. until unsubscription.
- Identity of possible controllers, recipients of the personal data: The personal data may be processed by the controller's sales and marketing staff in accordance with the above principles.
- Description of the data subjects' rights in relation to the data processing:
- The data subject may request from the controller access to, rectification, erasure or restriction of the processing of personal data concerning them, and
- may object to the processing of such personal data, and
- the data subject has the right to data portability and the right to withdraw consent at any time.
- The data subject may request access to, erasure, rectification or restriction of processing of personal data, data portability, and may object to the processing, in the following ways:
- by post to this address 9011 Győr, Kenderes út 31. 1 em. 2a In the event of withdrawal, please return the product to the following address: 2030 Érd, Köszörűs utca 18.,
- by e-mail at hello@ranger-dog.sk,
- by telephone on +421 2 3332 9758. .
- The data subject may unsubscribe from the newsletter at any time, free of charge.
- Please note that
- the data processing is based on your consent.
- If you wish to receive newsletters from us, you must provide your personal data.
- failure to provide the data will have the consequence that we cannot send you a newsletter.
- withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Cookie management
1. The use of so-called “password-protected cookies”, “shopping cart cookies”, “security cookies”, “essential cookies”, “functional cookies” and “cookies responsible for managing website statistics” does not require the data subject's prior consent.
2. Method of data management, scope of the data processed: Unique identification number, dates, times
3. Data subjects: All visitors to the website.
4. Purpose of the data processing: Identifying users, tracking visitors, ensuring personalisation.
5. Duration of the data processing, time limit for erasure of the data:
|
Type of cookie |
Legal basis of the data processing |
Duration of the data management |
|
Session cookies or other cookies that are indispensable for the operation of the website |
No data are processed by managing session cookies. |
The period until the end of the relevant visitor session |
|
Statistical, marketing cookies |
Article 6(1)(a) GDPR |
1 month - 2 years |
6. Identity of possible controllers entitled to access the data: The personal data may be accessed by the controller.
7. Description of the data subjects' rights in relation to the data processing: Data subjects have the option to delete cookies in the Tools/Settings menu of their browser, usually under the Privacy settings.
8. Most browsers used by our users allow you to set which cookies are saved and to allow (certain) cookies to be deleted again. If you restrict the saving of cookies on certain websites or do not allow third-party cookies, under certain circumstances our websites may no longer be fully usable. Here you can find information on how to customise cookie settings for the 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-engedelyezese-es-tiltasa-amit-weboldak-haszn)
Safari (https://support.apple.com/hu-hu/guide/safari/sfri11471/mac)
Use of Google Analytics
1. This website uses Google Analytics, a service provided by Google Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer that help the website analyse how users use the site visited.
2. The information generated by the cookie about the website you use is usually transmitted to and stored by Google on servers in the United States. By activating IP anonymisation on the website, Google first shortens the user's IP address within the Member States of the European Union or in other states party to the Agreement on the European Economic Area.
3. 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 your use of the website, to compile reports on website activity for the website operator and to provide other services relating to website activity and internet usage.
4. Google Analytics will not associate the IP address sent by the user's browser with any other data held by Google. You may refuse the use of cookies by selecting the appropriate setting on your browser; however, please note that in this case you may not be able to use all the functions of this website. You can also prevent Google from collecting and processing information about your use of the website (including your IP address) through cookies by downloading and installing the browser plug-in available at this link. https://tools.google.com/dlpage/gaoptout?hl=hu
The fact of collection, the scope of the data processed and the purpose of the processing:
- The fact of collection, the scope of the data processed and the purpose of the processing:
|
Personal data |
Purpose of the data processing |
Legal basis |
|
Surname and first name |
Identification, contact details. |
Article 6(1)(c) and Article 17/A (2) of Act CLV of 1997 on Consumer Protection, paragraph (7). |
|
E-mail address |
Contact person |
|
|
Telephone number |
Contact person |
|
|
Billing name and address |
Identification and handling of complaints, questions and quality problems relating to the ordered products. |
- Data subjects: All data subjects who purchase on the webshop website and complain about quality.
- Duration of the data processing, time limit for erasure of the data: Copies of the record, transcript and reply to the recorded complaint are retained for 5 years under Article 17/A (7) of Act CLV of 1997 on Consumer Protection.
- Identity of possible controllers, recipients of the personal data: The personal data may be processed by the controller's sales and marketing staff in accordance with the above principles.
- Description of the data subjects' rights in relation to the data processing:
- The data subject may request from the controller access to, rectification, erasure or restriction of the processing of personal data concerning them, and
- the data subject has the right to data portability and the right to withdraw consent at any time.
- The data subject may request access to, erasure, rectification or restriction of processing of personal data, data portability, and may object to the processing, in the following ways:
- by post to this address 9011 Győr, Kenderes út 31. 1 em. 2a In the event of withdrawal, please return the product to the following address: 2030 Érd, Köszörűs utca 18.,
- by e-mail at hello@ranger-dog.sk,
- by telephone on +421 2 3332 9758. .
- Please note that
- the provision of personal data is based on a contractual and legal 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 will have the consequence that we cannot handle your complaint.
Use of Barion Pixel
|
Cookie name |
Description and purpose of the cookie |
Service provider |
How long is it stored on your device? |
|
ba_vid |
The purpose of the Barion Smart Gateway service is to detect credit card fraud on the basis of the digital fingerprint of your device and your browsing habits. The cookie is used to detect fraudsters. The cookie ensures that we know that the data from your browsing habits originate from one user. |
For 1.5 years from the last update. |
|
|
ba_vid.xxx |
The purpose of the Barion Smart Gateway service is to detect credit card fraud on the basis of the digital fingerprint of your device and your browsing habits. The cookie allows us to track your website browsing habits between two sessions. It collects the following data: ba_vid, a user ID that is a hash compiled from the browser's properties, the timestamp of your first, current and last visit to the website, the current session ID, and third-party cookie permissions. |
For 1.5 years from the last update. |
|
|
ba_sid |
The purpose of the Barion Smart Gateway service is to detect credit card fraud on the basis of the digital fingerprint of your device and your browsing habits. The cookie ensures that we can identify your session across different websites. |
30 minutes |
|
|
ba_sid.xxx |
The purpose of the Barion Smart Gateway service is to detect credit card fraud on the basis of the digital fingerprint of your device and your browsing habits. The cookie allows us to identify your browser's session within the website. |
30 minutes |
If the lifetime of a cookie is defined from the last update, this means that each visit extends the validity of the cookie by 1.5 years from the last visit. Consent is not required for data collection resulting from the extension. The data processing is in the legitimate interest of Barion Payment Ltd. for the purpose of fraud prevention. Further information here.
Other technologies: Digital fingerprint in the browser: The aim is to filter out fraudulent sessions on the basis of visitor behaviour and the fingerprint of their browser. It helps us identify browsers on each device. We use it on this website and on the websites of other merchants, for those who use the Barion Smart Gateway. Further details can be found in section 5.4 of the Privacy Notice.
Marketing cookies:
|
Cookie name |
Description and purpose of the cookie |
Service provider |
How long is it stored on your device? |
|
BarionMarketingConsent.xxx |
Its purpose is to store your consent to the collection of data about your browsing habits and to the analysis of your shopping habits in order to display personalised advertisements and offers. If you have given us your consent, the data collected through the following cookies for the prevention of credit card fraud, which are placed among the cookies necessary for the operation of the website, and your browsing habits, will also be used by us to analyse your shopping habits in order to display personalised advertisements and offers. |
For 1.5 years from the last update |
|
|
Cookies of media and advertising partners |
The purpose of this cookie is to synchronise and match the different user IDs of the Barion system and of the partner's system. As part of their operation, the above cookies signal to the partners' server to download its own cookie with the user ID into the website visitor's browser. In this way the identifiers created in both systems at the same time in the same browser are matched. |
Detailed information on the cookies can be found in the cookie notice of each partner. The list of partners that use cookies for this purpose, together with a link to their cookie policies, can be found here. |
Setting a marketing cookie requires the visitor's consent. Without consent the cookie cannot be stored in the browser. You can change or withdraw your consent at any time on the website. Barion Payment Zrt. uses the cookie to collect data about visits; information about what was clicked, which product/service the visitor is interested in, or about unfinished orders. The data are collected to build models of visitor behaviour and to create personalised offers and digital advertisements. The aim is to display to visitors relevant advertisements about products they are genuinely interested in. These cookies ensure that we avoid irrelevant advertisements and offers and provide only truly relevant content to which the visitor has an affinity. Barion Payment Zrt. processes the information itself or passes it on to its contracted media and advertising partners[1]. For this purpose the identifiers of these partners are also stored together with the Barion cookies. Consent also allows these cookies to be stored. You can find more detailed information on the storage of data in the privacy notice.
Data processing partners
|
Barion Marketing Cloud and Barion Pixel are covered by DataMe Kft. 1118 Budapest, Ugron Gábor utca 35. |
|
Telephone customer service is provided by Minerva-Soft Development and Provider LLC. Address: 3900 Szerencs, Lipták út 1 / a. |
|
Telephone handling of user complaints is provided by Interswitch LLC. Address: 1056 Budapest, Irányi utca 15. |
|
The infrastructure for the online user identification services required by anti-money-laundering laws is provided by TechTeamer LLC. Address: 1095 Budapest, Lechner Ödön sugárút 3. 2. 1., B. |
|
The traffic statistics of our website and mobile application are provided by MIXPANEL Inc. Address: 405 Howard Street San Francisco, CA 94105 |
|
For our accounting services we are in contact with In-Voice Kontroll LLC. Address: 1046 Budapest, Leiningen Károly utca 16 / B |
|
Our partner for mobile parking e-invoicing is KBOSS.hu LLC. (also known as szamlazz.hu) Address: 1031 Budapest, Záhony utca 7. |
Barion Pixel – prevention of bank card fraud
Place of the processing (web address): pixel.barion.com
Purpose of the processing: Prevention of bank card fraud.
Legal basis of the processing: The legitimate interest of Barion Payment Zrt. (barion.com).
Duration of the processing: 50 months from the visit to the website.
Categories of data processed: IP address, type of operating system and internet browser.
Method of obtaining the data: Automatically, when the website is visited.
Further information: https://www.barion.com/hu/adatvedelmi-tajekoztato/
Social media
- Method of data collection, scope of the data processed: Name registered on the social networks Meta/Twitter/Pinterest/Youtube/Instagram etc. and the user's public profile picture.
- Data subjects: All data subjects who have registered on the social networks Meta/Twitter/Pinterest/Youtube/Instagram etc. and “liked” the website.
- Purpose of the data collection: Sharing or “liking” and promoting certain content, products, promotions or the website itself on social network pages.
- Duration of the data processing, time limit for erasure of the data, identity of possible controllers with access to the data, and the data subjects' rights in relation to the processing: The data subject can learn about the source of the data, the data processing and the manner and legal basis of the transfer on the page of the social network concerned. The data are processed on the social network pages, so the duration of the processing, the manner of data processing and the options for erasing and modifying the data are governed by the rules of the social network page concerned.
- Legal basis of the processing: the data subject's voluntary consent to the processing of their personal data on social network pages.
Recipients to whom the personal data are disclosed
“recipient” means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not.
1. Processors (who carry out the data processing on behalf of the controller)
The controller uses processors to facilitate its own processing activities and to fulfil its contractual and legal obligations towards data subjects.
The controller places great emphasis on using only processors who provide adequate guarantees to implement appropriate technical and organisational measures to ensure compliance with the requirements of the GDPR and to protect the rights of data subjects.
The processor and all persons acting under the control of the controller or the processor who have access to personal data process only the personal data covered by this policy, in accordance with the controller's instructions.
The controller is legally responsible for the activities of the processor. The processor is liable for damage caused by the processing only if it has not complied with the obligations specifically imposed on processors by the GDPR, or if it has disregarded or acted contrary to the controller's lawful instructions.
The processor has no substantive decision-making power in relation to the processing of the data.
The controller may use a hosting service provider to provide the IT background and a courier service as a processor to deliver the ordered products.
2. Specific processors
|
Processing activities |
Name, address, contact details |
|
Hosting service |
nGroup Kft. |
|
Other processor (e.g. online invoicing, website development, marketing) |
Számlázz.hu Backblaze Copyright Agent WEBSHIPPY KFT. |
"third party" means a natural or legal person, public authority, agency or any other body other than the data subject, controller, processor or persons who, under the direct authority of the controller or processor, are authorised to process personal data.
3. Transfer of data to third parties
Third-party controllers process the personal data provided by us in their own name and in accordance with their own privacy policies.
|
Controller activities |
Name, address, contact details |
|
Transport |
DPD Hungary Kft. 1134 Budapest, Váci út 33. 2nd floor +36 1 501 6200 FoxPost Zrt. 3300 Eger, Maklári út 119. +36 1 999 0369 MPL Magyar Posta Logisztika Kft. |
|
Online payment |
BARION Barion Payment Zrt.. H-1117, Budapest, Irinyi József utca 4-20. 2nd floor +36 1 464 70 99 |
Customer relations and management of other data
- If the data subject has a question or problem when using our services, they may contact the controller through the means indicated on the website (telephone, e-mail, social networks, etc.).
- The controller erases the e-mails, messages and data provided by telephone, on Facebook, etc. received, together with the enquirer's name and e-mail address and any other personal data that the enquirer provided voluntarily, no later than 2 years after the date of the communication.
- Any processing not listed in this notice will be notified at the time of data collection.
- In exceptional cases, the service provider is obliged to provide information, data or documents at the request of a public authority or other bodies authorised by law.
- In such cases the service provider discloses personal data to the requesting party only to the extent and in the amount strictly necessary for the purpose of the request, provided that the requesting party has specified the exact purpose and scope of the data.
Rights of data subjects
- Right of access
You have the right to obtain feedback from the controller as to whether or not your personal data are being processed, and, where that is the case, the right of access to your personal data and to the information listed in the Regulation.
- Right to rectification
You have the right to obtain from the controller, upon your request and without undue delay, the rectification of inaccurate personal data concerning you. Taking into account the purpose of the processing, you have the right to request that incomplete personal data be completed, including by means of providing a supplementary statement.
- Right to erasure
You have the right to obtain from the controller, upon your request and without undue delay, the erasure of personal data concerning you, and the controller is obliged, under certain conditions, to erase personal data concerning you without undue delay.
- Right to be forgotten
Where the controller has made the personal data public and is obliged to erase them, it takes reasonable steps, including technical measures, taking account of available technology and the cost of implementation, to inform controllers which are processing the data that you have requested the erasure of any links to, or copies of, those personal data.
- Right to restriction of processing
You have the right to obtain from the controller, upon your request, restriction of processing where one of the following applies:
- In this 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 need them for the establishment, exercise or defence of legal claims;
- you have objected to the processing; in this case the restriction applies for the period until it is verified 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 the controller, in a structured, commonly used and machine-readable format, and 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 your personal data by (...), including profiling based on the above 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, including profiling to the extent that it is related to direct marketing. Where you object to processing of your personal data for direct marketing purposes, your personal data may no longer be processed for those 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 if 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.
Time limit for taking action
The controller informs you of the action taken on the above requests without undue delay and in any event within 1 month of receipt of the request.
If necessary, this period may be extended by 2 months. The controller informs you of the extension, stating the reasons for the delay, within 1 month of receipt of the request.
If the controller does not take action on your request, it informs you without delay and at the latest within 1 month of receipt of the request of the reasons for not taking action and of your right to lodge a complaint with a supervisory authority and to seek legal redress through the courts.
Security of data processing
The controller and the processor implement appropriate technical and organisational measures to ensure a level of security appropriate to the level of risk, taking into account the state of the art, the costs of implementation, the nature, scope, context and purposes of the processing and the varying likelihood and severity of the risk to the rights and freedoms of natural persons, including, where appropriate:
- the pseudonymisation and encryption of personal data;
- ensuring the ongoing confidentiality, integrity, availability and resilience of the systems and services used to process personal data;
- in the event of a physical or technical problem, the ability to restore access to and the availability of personal data in a timely manner;
- a procedure for regularly testing, assessing and evaluating the effectiveness of the technical and organisational measures taken to ensure the security of the processing.
Informing the data subject of a personal data breach
Where the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, the controller informs the data subject of the personal data breach without undue delay.
The information provided to the data subject must describe in clear and plain language the nature of the personal data breach and state 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; and describe the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate any possible adverse effects of the personal data breach.
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 personal data breach, in particular measures, such as the use of encryption, that render the data inaccessible to persons who are not authorised to access the personal data;
- the controller has taken subsequent measures following the personal data breach which ensure that the high risk to the rights and freedoms of the data subject is no longer likely to materialise;
- providing the information would involve disproportionate effort. In such cases, data subjects are informed by means of publicly disclosed information or by a similar measure whereby the data subjects are informed in an equally effective manner.
If the controller has not yet informed the data subject of the personal data breach, the supervisory authority, having considered whether the personal data breach is likely to result in a high risk, may order that the data subject be informed.
Notification of a personal data breach to the supervisory 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 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 must be accompanied by reasons for the delay.
Review in the case of mandatory data processing
Unless the duration of mandatory processing, or the periodic review of its necessity, is laid down by an act, a local government decree or a binding legal act of the European Union, the controller reviews at least every three years from the start of the processing whether the processing of personal data processed by the controller, or by a processor acting on its behalf or under its instructions, is necessary for the purposes of the processing.
The controller documents the circumstances and results of this review, retains this documentation for ten years after the review has been carried out and submits it to the National Authority for Data Protection and Freedom of Information (hereinafter: the Authority) upon request.
Possibility of lodging a complaint
A complaint about a possible infringement by the controller may be lodged with the National Authority for Data Protection and Freedom of Information:
Nemzeti Adatvédelmi és Információszabadság Hatóság
1055 Budapest, Falk Miksa utca 9-11.
Postal address: 1374 Budapest, Pf.: 603.
Telephone: +36 -1-391-1400
Fax: +36-1-391-1410
E-mail: ugyfelszolgalat@naih.hu
Closing remarks
The following legislation was taken into account in preparing this information material:
- REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Regulation (EC) No 95/46/EC (General Data Protection Regulation).
- Act CXII of 2011 – on the Right of Informational Self-Determination and on Freedom of Information (hereinafter: Infotv.)
- Act CVIII of 2001 – on certain aspects of electronic commerce services and information society services (in particular Section 13/A)
- Act XLVII of 2008 – on the prohibition of unfair commercial practices against consumers;
- Act XLVIII of 2008 – on the essential conditions and certain limitations of commercial advertising (in particular Section 6)
- Act XC of 2005 on the Freedom of Electronic Information
- Act C of 2003 on electronic communications (in particular Section 155)
- Opinion No 16/2011 on the EASA/IAB Best Practice Recommendation on Online Behavioural Advertising
- Recommendation of the National Authority for Data Protection and Freedom of Information on the data protection requirements of prior information
