Privacy Statement

CSÓK ISTVÁN GALLERY AND ANTIQUE STORE

Privacy Policy

 

Introduction

HUNGART ANTIK KFT. Registered office: 1149 Budapest, Várna u. 6.; Branch office: 1052 Budapest, Váci u. 23. (e-mail: antikvitas.vaci23@gmail.com. Tel: +36-1-267-7465, Company Registration Number: 01-09-326934, hereinafter: Service Provider, Data Controller) hereby submits to the following notice.

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) REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (April 27, 2016), we provide the following information.

• Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) , hereinafter referred to as the GDPR
• Act CXII of 2010 – on the Right to Informational Self-Determination and Freedom of Information (Infotv.)
• Act C of 2010 – on Accounting (Accounting Act)
• Act CVIII of – on certain issues regarding electronic commerce services and information society services (Eker.tv.)
• Act XLVIII of – on the fundamental conditions and certain restrictions of commercial advertising activities
• Act V of – on the Civil Code

This privacy policy governs data processing on the following websites: www.csokantikvitas.hu tel.: +36-1-267-7465

Amendments to this policy take effect upon publication at the above address.

 

The data controller and its contact information:

 

Name: HUNGART ANTIK KFT.

Registered office: 1149 BUDAPEST VÁRNA ST. 6.

Email: ANTIKVITAS.VACI23@GMAIL.COM

Phone: +36-1-267-7465

 

Contact information for the Data Protection Officer:

 

Name: JÚLIA VAS

Registered office: 1052 BUDAPEST VÁCI U. 23.

Email: VASJULIA1@GMAIL.COM

Phone: +36-70-6269010

 

Definitions

1.  
2. “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, number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person;

1. “data processing”: any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, including collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction;

 

1. “data controller”: a natural or legal person, public authority, agency, or any other body that determines the purposes and means of the processing of personal data, either alone or jointly with others; where the purposes and means of processing are determined by Union or Member State law, Union or Member State law may also determine the controller or the specific criteria for designating the controller;

 

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

 

1. “recipient”: a natural or legal person, public authority, agency, or any other body to whom or which personal data is disclosed, whether a third party or not. Public authorities that have access to personal data in the context of a specific investigation in accordance with Union or Member State law shall not be considered recipients; the processing of such data by those public authorities must comply with the applicable data protection rules in accordance with the purposes of the processing;

 

1. “consent of the data subject”: a 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;

 

1. “data breach”: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.

 

Principles governing the processing of personal data

 

Personal data:

 

1. must be processed lawfully, fairly, and in a manner that is transparent to the data subject (“lawfulness, fairness, and transparency”);

 

1. collected only for specified, explicit, and legitimate purposes and not processed in a manner incompatible with those purposes; in accordance with Article 89(1), further processing for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes (“purpose limitation”);

1. they must be adequate and relevant in relation to the purposes of the processing and limited to what is necessary (“data minimization”);

 

1. 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 of the processing, are erased or rectified without delay ( “accuracy”);

1. stored in a form that 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 a longer period only if the processing of personal data is carried out for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to the implementation of appropriate technical and organizational measures required by this Regulation to protect the rights and freedoms of data subjects (“limited storage”);

 

1. processing must be carried out in such a manner that appropriate technical or organizational measures ensure the security of personal data, including protection against unauthorized or unlawful processing, accidental loss, destruction, or damage (“integrity and confidentiality”).

 

The data controller is responsible for compliance with the above and must be able to demonstrate such compliance (“accountability”).

 

Data Processing

 

Data processing related to the operation of the online store

 

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

 

Personal DataPurpose of Data Processing

Username Identification, enabling registration.

 

Used to ensure secure access to the user account.

First and last name Required for contacting you, making a purchase, and issuing a proper invoice.

Email address

 

 

 

Maintaining contact, and more efficient coordination of issues related to billing or shipping.

Billing name and address Issuing a valid invoice, as well as creating the contract, determining its content, modifying it, monitoring its fulfillment, billing the resulting fees, and enforcing related claims.

Shipping name and address Enabling home delivery.

Date of purchase/registration: To perform technical operations.

IP address at the time of purchase/registration: To perform technical operations.

 

Neither the username nor the email address is required to contain personal data.

 

1. Scope of data subjects: All data subjects registered on the webshop website or making a purchase.

 

1. Duration of data processing, deadline for data deletion: Immediately upon cancellation of registration. The data controller shall notify the data subject electronically of the deletion of any personal data provided by the data subject, in accordance with Article 19 of the GDPR. If the data subject’s request for erasure also extends to the email address provided by them, the data controller will also delete the email address following the notification. Except in the case of accounting documents, as these data must be retained for 8 years pursuant to Section 169(2) of Act C of 2000 on Accounting.

 

Accounting documents directly and indirectly supporting the bookkeeping records (including general ledger accounts, analytical, and detailed records) must be retained in a readable format for at least 8 years, in a manner that allows them to be retrieved based on references in the accounting records.

 

1. Identity of potential data controllers authorized to access the data, and recipients of personal data: Personal data may be processed by the data controller’s sales and marketing staff, in compliance with the above principles.

 

1. Description of data subjects’ rights regarding data processing:

 

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

 

1. The data subject may request access to personal data, its erasure, rectification, or restriction of processing, data portability, or object to data processing in the following ways:

• by mail to 1149 Budapest, Várna u. 6. or 1052 Budapest, Váci u. 23.,
• by email at antikvitas.vaci23@mail.com,
• or by phone at +36-1-267-7465.

 

1. Legal basis for data processing:

 

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

 

1. Section 13/A(3) of Act CVIII of 2001 on Certain Issues Concerning Electronic Commerce Services and Information Society Services (hereinafter: Elker Act):

 

The service provider may process personal data that is technically indispensable for the provision of the service. Where other conditions are identical, the service provider must select and, in all cases, operate the tools used in the provision of information society services in such a way that personal data are processed only if this is absolutely necessary for the provision of the service and the fulfillment of other purposes specified in this Act; however, even in this case, only to the extent and for the duration necessary.

 

1. The issuance of an invoice in accordance with accounting regulations is governed by Article 6(1)(c).

 

1. The statute of limitations for claims arising from the contract is five years pursuant to Section 6:21 of Act V of 2013 on the Civil Code.

 

Section 6:22 [Statute of Limitations]

(1) Unless otherwise provided by this Act, claims shall be barred by the statute of limitations after five years.

(2) The statute of limitations begins to run when the claim becomes due.

(3) Any agreement to modify the statute of limitations must be in writing.

(4) Any agreement excluding the statute of limitations is void.

 

1. Please be advised that

 

• it is necessary for the performance of the data processing agreement.
• you are required to provide your personal data so that we can fulfill your order.
• Failure to provide the data will result in the consequence that we will be unable to process your order.

 

 

Data processors used

Hosting provider:

Shoprenter.hu Kft.

4028 Debrecen, Kassai út 129.

+36-1/234-5012

info@shoprenter.hu

Courier service:

GLS General Logistics Systems Hungary Csomag-Logisztikai Kft.

2351 Alsónémedi

GLS Európa u. 2.

info@gls-hungary.com (06 29) 886 694

OTP Simple Pay service

OTP Mobil Szolgáltató Kft.

Headquarters: 1143 Budapest, Hungária krt. 17-19.

Customer Service: ugyfelszolgalat@simple.hu +36 1/20/30/70 3-666-611

 

Delivery

 

1. Activities performed by the data processor: Product delivery, transportation

1. Name and contact information of the data processor: GLS General Logistics Systems Hungary Parcel Logistics Ltd.
2. 2351 Alsónémedi
3. GLS Európa u. 2.
4. info@gls-hungary.com (06 29) 886 694
5. Fact of data processing, scope of processed data: Delivery name, delivery address, phone number, email address.

 

 

1. Scope of data subjects: All data subjects requesting home delivery.

 

1. Purpose of data processing: Home delivery of the ordered product.

 

1. Duration of data processing, deadline for data deletion: Until the home delivery is completed.

 

1. Legal basis for data processing: Article 6(1)(b).

 

Hosting provider

 

1. Activity performed by the data processor: Hosting service

 

1. Name and contact information of the data processor:Shoprenter.hu Kft.4028 Debrecen, Kassai út 129.+36-1/234-5012info@shoprenter.hu

 

1. Fact of data processing, scope of processed data: All personal data provided by the data subject.

 

1. Scope of data subjects: All data subjects using the website.

 

1. Purpose of data processing: Making the website available and ensuring its proper operation.

 

1. Duration of data processing, deadline for data deletion: Data processing continues until the termination of the agreement between the data controller and the hosting provider, or until the data subject submits a deletion request to the hosting provider.

 

1. Legal basis for data processing: Article 6(1)(c) and (f), and Section 13/A(3) of Act CVIII of 2001 on Certain Issues Concerning Electronic Commerce Services and Information Society Services.

Recipients to whom personal data is disclosed (Data transfer): courier service and OTP

Online payment

 

1. Activity performed by the Recipient: Online payment

1. Name and contact information of the Recipient:
2. OTP Simple Pay service OTP Mobil Szolgáltató Kft. Registered office: 1143 Budapest, Hungária krt. 17-19. Customer service: ugyfelszolgalat@simple.hu +36 1/20/30/70 3-666-611

 

 

1. Fact of data processing, scope of processed data: Billing information, name, email address

 

1. Scope of data subjects: All data subjects who choose to make a payment on the website.

 

1. Purpose of data processing: To facilitate online payments, confirm transactions, and conduct fraud monitoring (to prevent misuse)

 

1. Duration of data processing and retention period: Until the online payment is processed.

 

1. Legal basis for data processing: Article 6(1)(b) of the GDPR. Data processing is necessary to fulfill the online payment requested by the data subject.

 

1. Rights of the data subject:

1. You may inquire about the circumstances of data processing,

1. You have the right to receive confirmation from the data controller as to whether your personal data is being processed, and to access all information related to the data processing.
2. You have the right to receive your personal data in a structured, commonly used, machine-readable format.
3. You have the right to have the data controller correct any inaccurate personal data concerning you without undue delay upon your request.

 

 

Cookie Management

 

1. Cookies typical of online stores include so-called “cookies used for password-protected sessions,” “cookies necessary for the shopping cart,” and “security cookies,” for which prior consent from data subjects is not required.

 

1. Fact of data processing, scope of processed data: Unique identifier, dates, times

 

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

 

1. Purpose of data processing: User identification, maintaining the “shopping cart,” and tracking visitors.

 

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

 

Cookie typeLegal basis for data processingData processing

Scope of processed data

Session cookies

Section 13/A(3) of Act CVIII of 2001 on certain issues regarding electronic commerce services and information society services (Elkertv.) Section 13/A(3) The period until the end of the relevant visitor’s session

connect.sid

 

 

 

1. Identity of potential data controllers entitled to access the data: The data controller does not process personal data through the use of cookies.

 

1. Description of the data subjects’ rights regarding data processing: Data subjects have the option to delete cookies in the Tools/Settings menu of their browsers, typically under the Privacy settings.

 

1. Legal basis for data processing: Consent from the data subject is not required if the sole purpose of using cookies is the transmission of communications via an electronic communications network, or if the service provider absolutely needs them to provide an information society service expressly requested by the subscriber or user.

Use of Google AdWords conversion tracking

 

1. The data controller uses the online advertising program called “Google AdWords” and, within that framework, utilizes Google’s conversion tracking service. Google conversion tracking is an analytics service provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”).

 

1. When a User accesses a website via a Google ad, a cookie required for conversion tracking is placed on their computer. These cookies have a limited validity period and do not contain any personal data, so the User cannot be identified by them.

1. 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 ad.

 

1. Each Google AdWords client receives a different cookie, so they cannot be tracked across the websites of other AdWords clients.

1.  
2. The information—collected using conversion tracking cookies—is used to generate conversion statistics for AdWords clients who have opted into conversion tracking. This allows customers to see how many users clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not have access to information that could be used to identify any individual user.

 

1. If you do not wish to participate in conversion tracking, you can opt out by disabling the installation of cookies in your browser. You will then not be included in the conversion tracking statistics.

1.  
2. Further information and Google’s privacy policy are available at the following link: www.google.de/policies/privacy/

Use of Google Analytics

1.  
2. This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses so-called “cookies,” which are text files stored on your computer to help analyze your use of the website.

 

1. The information generated by the cookies regarding your use of this website is usually transmitted to and stored on a Google server in the United States. By activating IP anonymization on this website, Google will truncate your IP address beforehand within member states of the European Union or in other states party to the Agreement on the European Economic Area.

 

1. The full IP address will only be transmitted to a Google server in the U.S. and shortened there in exceptional cases. On behalf of the operator of this website, Google will use this information to evaluate how the User used the website, as well as to compile reports for the website operator regarding website activity and to provide other services related to website and internet usage.

1. Within the scope of Google Analytics, the IP address transmitted by the User’s browser is not combined with other data held by Google. The User can prevent the storage of cookies by adjusting their browser settings accordingly; however, please note that in this case, not all features of this website may be fully usable.

 

1. You can also prevent Google from collecting and processing data related to your use of the website (including your IP address) via cookies by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=hu

Newsletter, Direct Marketing

 

1. Pursuant to Section 6 of Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Commercial Advertising Activities, the User may give their prior and express consent for the Service Provider to contact them with advertising offers and other communications via the contact details provided during registration.

 

1. Furthermore, the Customer may consent, subject to the provisions of this notice, to the Service Provider processing the personal data necessary for sending advertising offers.

 

1. The Service Provider does not send unsolicited advertising messages, and the User may unsubscribe from receiving such offers free of charge, without restriction or justification. In this case, the Service Provider will delete all — from its records and will not contact the User with further promotional offers. The User may unsubscribe from advertisements by clicking the link in the message.

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

 

Personal dataPurpose of data processing

Name, email address. Identification, enabling subscription to the newsletter.

Time of subscription Execution of a technical operation.

IP address at the time of subscription Execution of a technical operation.

 

1. Scope of data subjects: All data subjects who subscribe to the newsletter.

 

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

 

1. Duration of data processing, deadline for data deletion: data processing continues until the consent statement is withdrawn, i.e., until unsubscription.

 

1. Identity of potential data controllers entitled to access the data, recipients of personal data: Personal data may be processed by the data controller’s sales and marketing staff, in compliance with the above principles.

 

1. Description of data subjects’ rights regarding data processing:

 

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

 

1. The data subject may request access to personal data, its erasure, rectification, or restriction of processing, data portability, or object to data processing in the following ways:

• by mail at 1149 Budapest, Várna u. 6. or 1052 Budapest, Váci u. 23.,
• by email at antikvitas.vaci23@gmail.com,
• by phone at +36-1-267-7465.

 

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

 

1. Legal basis for data processing: the data subject’s consent, Article 6(1)(a) and (f), and Section 6(5) of Act XLVIII of 2008 on the Fundamental Conditions and Certain Restrictions of Commercial Advertising Activities:

 

The advertiser, the advertising service provider, and the publisher of the advertisement shall maintain a record of the personal data of persons who have provided a statement of consent to them, within the scope specified in the consent. The data recorded in this record—relating to the recipient of the advertisement – may only be processed in accordance with the terms of the consent statement until such consent is withdrawn, and may only be disclosed to third parties with the prior consent of the data subject.

 

1. Please be advised that

• data processing is based on your consent.
• You are required to provide your personal data if you wish to receive our newsletter.
• Failure to provide the data will result in us being unable to send you the newsletter.

 

 

Complaint Handling

 

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

 

Personal DataPurpose of Data Processing

First and Last Name Identification, maintaining contact.

Email address

 

 

 

 

 

Billing name and address Identification; handling quality complaints, questions, and issues related to ordered products.

 

1. Scope of data subjects: All individuals who make purchases on the webshop website and who submit quality complaints or file complaints.

 

1. Duration of data processing, deadline for data deletion: Copies of the record of the complaint, the transcript, and the response thereto must be retained for 5 years pursuant to Section 17/A(7) of Act CLV of 1997 on Consumer Protection.

 

1. Identity of potential data controllers entitled to access the data, and recipients of personal data: Personal data may be processed by the data controller’s sales and marketing staff, in compliance with the above principles.

 

1. Description of data subjects’ rights regarding data processing:

 

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

 

1. The data subject may request access to personal data, its erasure, rectification, or restriction of processing, data portability, or object to data processing in the following ways:

• by mail at 1149 Budapest, Várna u. 6, or 1052 Budapest, Váci u. 23,
• by email at antikvitas.vaci23@gmail.com,
• by phone at +36-1-267-7465.

 

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

 

1. Please be advised that

 

• the provision of personal data is based on a contractual obligation.
• the processing of personal data is a prerequisite for concluding the contract.
• you are required to provide personal data so that we can process your complaint.
• failure to provide data will result in the consequence that we will be unable to process the complaint you have submitted to us.

 

 

Social Media Platforms

 

1. Fact of data collection, scope of processed data: Your name registered on social media platforms such as Facebook, Google+, Twitter, Pinterest, YouTube, Instagram, etc., as well as your public profile picture.

 

1. Scope of data subjects: All data subjects who have registered on social media sites such as Facebook/Google+/Twitter/Pinterest/YouTube/Instagram, etc., and have “liked” the website.

 

1. Purpose of data collection: To share, “like,” or promote specific content elements, products, promotions, or the website itself on social media platforms.

 

1. Duration of data processing, deadline for data deletion, identity of potential data controllers authorized to access the data, and description of data subjects’ rights regarding data processing: The data subject may obtain information about the source of the data, its processing, the method of transfer, and the legal basis on the relevant social media platform. Data processing takes place on social media platforms, therefore the duration and method of data processing, as well as the options for deleting and modifying data, are governed by the terms of service of the respective social media platform.

1. Legal basis for data processing: the data subject’s voluntary consent to the processing of their personal data on social media platforms.

Customer Relations and Other Data Processing

 

1. If any questions arise or the data subject encounters any issues while using our services, they may contact the data controller via the methods provided on the website (phone, email, social media, etc.).

 

1. The data controller will delete the data provided via email, messages, phone, Facebook, etc., along with the data subject’s name and email address, as well as any other personal data voluntarily provided, no later than 2 years after the data was provided.

 

1. We will provide information regarding data processing not listed in this notice at the time the data is collected.

 

1. In the event of an exceptional request from an authority, or upon request from other bodies authorized by law, the Service Provider is obligated to provide information, disclose data, transfer data, or make documents available.

 

1. In such cases, the Service Provider shall disclose personal data to the requesting party—provided that the party has specified the exact purpose and scope of the data—only to the extent strictly necessary to fulfill the purpose of the request.

 

Rights of Data Subjects

 

1. Right of Access

 

You have the right to receive confirmation from the data controller as to whether your personal data is being processed, and if such processing is taking place, you have the right to access your personal data and the information listed in the Regulation.

 

1. Right to rectification

 

You have the right to have inaccurate personal data concerning you rectified by the data controller without undue delay upon your request. Taking into account the purposes of the processing, you have the right to request that incomplete personal data be completed, including by means of providing a supplementary statement.

 

1. The Right to Erasure

 

You have the right to request that the data controller erase personal data concerning you without undue delay, and the data controller is obligated to erase personal data concerning you without undue delay under certain conditions.

 

1. The right to be forgotten

 

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

 

1. The right to restriction of processing

 

You have the right to request that the data controller restrict data processing if any of the following conditions are met:

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

 

1. Right to data portability

 

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

 

1. Right to object

 

You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data by (...), including profiling based on those provisions.

 

1. Objection in the case of direct marketing

 

If the processing of personal data is carried out for the purpose of direct marketing, you have the right to object at any time to the processing of your personal data for this purpose, including profiling, to the extent that it is related to direct marketing. If you object to the processing of personal data for direct marketing purposes, the personal data may no longer be processed for that purpose.

 

1. Automated decision-making in individual cases, including profiling

 

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

The preceding paragraph does not apply if the decision:

• is necessary for the conclusion or performance of a contract between you and the data controller;
• is permitted by Union or Member State law applicable to the data controller, which also provides for appropriate measures to safeguard your rights and freedoms and legitimate interests; or
• is based on your explicit consent.

 

Time Limit for Action

 

The data controller shall inform you of the actions taken in response to the above requests without undue delay, but in any event within 1 month of receiving the request.

 

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

 

If the data controller does not take action in response to your request, it shall inform you without delay, but no later than one month from receipt of the request, of the reasons for the failure to act, as well as of your right to lodge a complaint with a supervisory authority and to seek judicial remedy.

 

Security of data processing

 

The data controller and the data processor shall, taking into account the state of the art, the costs of implementation, as well as the nature, scope, context, and purposes of the processing, and the risk of varying likelihood and severity to the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk, including, where appropriate:

 

1. the pseudonymization and encryption of personal data;

 

1. ensuring the ongoing confidentiality, integrity, availability, and resilience of the systems and services used to process personal data;

 

1. in the event of a physical or technical incident, the ability to restore access to personal data and the availability of the data in a timely manner;

 

1. a procedure for regularly testing, assessing, and evaluating the effectiveness of the technical and organizational measures taken to ensure the security of data processing.

 

Notifying the data subject of a data breach

 

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

 

The information provided to the data subject must clearly and concisely describe the nature of the data breach and include the name and contact details of the data protection officer or other contact person providing further information; it must describe the likely consequences of the data breach; the measures taken or planned by the data controller to address the data breach must be described, including, where applicable, measures to mitigate any adverse consequences resulting from the data breach.

 

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

the controller has implemented appropriate technical and organizational protection measures, and these measures have been applied to the data affected by the data breach, in particular measures—such as encryption—that render the data unintelligible to persons not authorized to access the personal data;the controller has taken further measures following the data breach,

which ensure that the high risk to the data subject’s rights and freedoms is unlikely to materialize in the future;providing such information would require a disproportionate effort. In such cases, data subjects must be informed through publicly available information or by taking similar measures that ensure data subjects are informed in an equally effective manner.

 

If the data controller has not yet notified the data subject of the data breach, the supervisory authority, after assessing whether the data breach is likely to result in a high risk, may order that the data subject be notified.

 

Reporting a data breach to the authority

 

The data controller shall report the data breach without undue delay, and, where feasible, no later than 72 hours after becoming aware of the data breach, to the supervisory authority competent pursuant to Article 55, unless the data breach is unlikely to result in a risk to the rights and freedoms of natural persons. If the notification is not made within 72 hours, the reasons justifying the delay must also be provided.

 

Review in the case of mandatory data processing

 

If the duration of mandatory data processing or the periodic review of its necessity is not specified 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 the data controller or by a data processor acting on its behalf or pursuant to its instructions is necessary .

 

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

 

 

 

 

 

Right to File a Complaint

 

Complaints regarding any potential violations by the data controller may be filed with the National Authority for Data Protection and Freedom of Information:

 

National Authority for Data Protection and Freedom of Information

Address

1055 Budapest,

Falk Miksa Street 9-11

Tax ID: 15795771-1-41

Phone

+36 (30) 683-5969+36 (30) 549-6838+36 (1) 391 1400

Email / Mailing Address: ugyfelszolgalat@naih.hu

1363 Budapest, P.O. Box 9.

Closing Remarks:

preparing this notice, we have taken into account the following legislation: 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) REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (April 27, 2016)Act CXII of 2011 – on the right to informational self-determination and freedom of information (hereinafter: Infotv.)Act CVIII of 2001 – on certain issues concerning electronic commerce services and information society services (in particular Section 13/A)2008. Act XLVII of 2008 – on the Prohibition of Unfair Commercial Practices against Consumers;Act XLVIII of 2008 – on the Fundamental Conditions and Certain Restrictions of Commercial Advertising (in particular Section 6)Act XC of 2005 on Freedom of Electronic InformationAct C of 2003 on Electronic Communications (specifically Section 155)Opinion No. 16/2011 on the EASA/IAB Recommendation on Best Practices for Behavioral Online AdvertisingRecommendation of the National Authority for Data Protection and Freedom of Information on data protection requirements for prior information