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Managing cookies

  1. Webshop-specific cookies are so-called “passwords used for password-protected sessions”, “shopping cart cookies” and “security cookies”, the use of which does not require the prior consent of the parties concerned.
  2. The fact of data management, the scope of the managed data: Unique identification number, dates, times.
  3. Stakeholders: All stakeholders who visit the website.
  4. Purpose of data management: To identify users, record the ’shopping cart’ and track visitors.
  5. Duration of data processing, deadline for deleting data:
The type of the cookie Legal basis for data management Data handling duration Managed data set

Session

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

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  1. Identity of potential data controllers entitled to access the data: The data controller does not process personal data with the use of cookies.
  1. Description of the data subjects’ rights related to data management: The data subject has the possibility to delete cookies in the Tools/ Settings menu of browsers, usually under the settings of the Privacy menu item.
  1. Most Internet browsers are initially set to accept cookies without any user intervention and / or indication. Some Cookies are absolutely necessary for the operation of the site, while others are used to increase performance and user experience. You can change these settings to block cookies or request an alert when websites you visit set cookies on your device.
    There are several ways to manage cookies:
    Instructions for setting cookies for the most popular browsers can be found here:
  1. Legal basis for data processing: The consent of the data subject is not required if the sole purpose of the use of cookies is the transmission of communications via an electronic communications network or the provision of an information society service specifically requested by the subscriber or the user.
  1. However, please note that certain website features or services may not work properly without cookies.

Using Google adwords conversion tracking

  1. An online advertising programme called ’Google Adwords’ is used by the data controller and uses Google’s conversion tracking service. Google Converison Tracking is an analytics service provided by Google Inc. (1600 Amphitheater Parkway, Mountain View, CA 94043, USA, ’Google’).
  1. When a user accesses a webpage through a Google ad, a conversion tracking cookie is placed on their computer. These cookies have a limited validity 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 expired yet, both Google and the data controller may see that the User has clicked on the advertisement.
  1. Each Google AdWords customer receives a different cookie, so they cannot be tracked through AdWords customers’ websites.
  1. The information obtained through conversion tracking cookies is used to generate conversion statistics for AdWords conversion tracking customers. This is how customers find out the number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they do not have access to information that could identify any user.
  1. If you do not wish to participate in conversion tracking, you can refuse it by disabling cookies in your browser. Then you will not be included in your conversion tracking statistics.
  1. For further information and Google’s privacy statement, please visit: google.de/policies/privacy/

Applying Google Analytics

  1. This website uses Google Analytics, a web analytics service provided by Google, Inc. (’Google’). Google Analytics uses so-called ’cookies’, which are text files placed on your computer, to help the website analyze how users use the site.
  1. The information generated by the cookie associated with the website used by you will normally be stored on a Google server in the USA. By activating IP anonymization on the Website, Google will abbreviate 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.
  1. The full IP address will be transmitted to and truncated to Google’s server in the United States only in exceptional cases. On behalf of the operator of this website, Google will use this information to evaluate how the user has used the website, to provide the website operator with reports on website activity and to provide additional services related to website and internet usage.
  1. Within the framework of Google Analytics, the IP address transmitted by the User’s browser is not reconciled with other data of Google. The User may prevent the storage of cookies by setting their browser properly, however, please note that in this case, not all functions of this website may be fully available. You may also prevent Google from collecting and processing your information about your use of the Website (including your IP address) by cookies by downloading and installing the browser plugin available at the following link.
    https://tools.google.com/dlpage/gaoptout?hl=hu

Newsletter, DM Activity

  1. Act XLVIII of 2008 on the basic conditions and certain restrictions of economic advertising activity. Pursuant to Section 6 of Act No. 1/2002 Coll. The User may in advance and expressly consent to being contacted by the Service Provider at the contact details provided with his advertising offers and other items.
  1. Furthermore, keeping in mind the provisions of this prospectus, the User may consent to the Service Provider handling his personal data necessary for sending advertising offers.
  1. The Service Provider does not send unsolicited advertising messages, and the User may unsubscribe from sending offers free of charge without restriction or justification. In this case, the Service Provider deletes all personal data – necessary for sending advertising messages – from its register and does not contact the User with its further advertising offers. The user can unsubscribe from the ads by clicking on the link in the message.
  1. Fact of data collection, scope of data processed and purpose of data management:
Personal data Purpose of data management
Name, email address Identification, allowing you to subscribe to the newsletter.
Date of subscription Perform a technical operation.
The IP address at the time of suscription Perform a technical operation.
  1. Stakeholders: All stakeholders who subscribe to the newsletter.
  1. The purpose of data management: to send electronic messages containing advertising (e-mail, sms, push message) to the data subject, to provide information on current information, promotions, new functions, etc.
  1. Duration of the data processing, deadline for deleting the data: the data processing lasts until the withdrawal of the consent statement, until the 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, respecting the above principles.
  1. Description of data subjects’ rights in connection with data processing:
    The affected person may request from the controller access to, rectification, erasure or restriction of the processing of personal data concerning him or her, and object to the processing of such personal data, and the affected person has the right to data portability and to withdraw his or her consent at any time.
  1. Access to, deletion, modification or restriction of the processing of personal data, portability of data, protest against data processing may be initiated by the affected person in the following ways:
    INDUPRO Ltd. (registered office: 11. Rozalia park, Biatorbágy, 2051, Phone: ……., e-mail address: …..)
  1. The affected person may unsubscribe from the newsletter free of charge at any time.
  1. Legal basis for data processing: data subject’s consent, Article 6 (1) (a), Infotv. Section 5 (1) of Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Economic Advertising Activities. Section 6 (5) of the Act:
    The advertiser, the advertising service provider or the publisher of the advertisement shall keep records of the personal data of the persons who have made a statement to them, within the scope specified in the consent. The data contained in this register relating to the recipient of the advertisement may be processed only in accordance with the statement of consent, until it is withdrawn, and may be disclosed to third parties only with the prior consent of the person concerned.

We inform you that,

  • data management is based on your consent.
  • you must provide personal information if you wish to receive a newsletter from us.
  • without providing personal information, the result will be that we will not be able to send you a newsletter.

 Handling Complaints

  1. The fact of data collection, the scope of the data processed and the purpose of the data management:
Personal data The purpose of data management
Surname and First name Identification, keeping contact
E-mail address Keeping contact.
Telephone number Keeping contact.
The name and address of billing Identification, handling of quality objections, questions and problems related to the ordered products.
  1. Stakeholders: all stakeholders with a quality complaint who complain.
  1. Duration of data processing, deadline for erasure of data: Copies of the record, transcript and response to the objection entered in the CLV Act 1997 on Consumer Protection. Act 17 / A. § (7) shall be kept for 5 years.
  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, respecting the above principles.
  1. Description of data subjects’ rights in relation to data processing:
    • The affected person may request from the controller access to, rectification, erasure or restriction of the processing of personal data concerning him or her, and
    • object to the processing of such personal data, and
    • the affected person has the right to data portability and to withdraw his or her consent at any time.
  1. Access to, deletion, modification or restriction of the processing of personal data, portability of data, protest against data processing may be initiated by the data subject in the following ways:
    INDUPRO Ltd. (registered office: 11. Rozalia park, Biatorbágy, 2051, Phone: ……., e-mail address: …..)
    Legal basis for data processing: the affected person’s consent, Article 6 (1) (c), Infotv. Section 5 (1) and Act CLV of 1997 on Consumer Protection. Act 17 / A. § (7).
  1. We inform you, that:
    • the provision of personal data is based on a contractual obligation.
    • the processing of personal data is a precondition for concluding a contract.
    • it is required to provide personal information so that we can handle your complaint.
    • if you do not provide information it has the consequence that we are unable to handle your complaint.

 

Community sites

  1. The fact of data collection, the scope of the managed data: Facebook / Google + / Twitter / Pinterest / Youtube / Instagram, etc. registered name on social networking sites and the user’s public profile picture.
  1. Stakeholders: All stakeholders who have registered on Facebook / Google + / Twitter / Pinterest / Youtube / Instagram, etc. social networking sites and “liked” the website.
  1. Purpose of data collection: On social networking sites, to share or “like” certain content elements, products, promotions or the website itself.
  1. Duration of data processing, deadline for erasure of data, identity of potential data controllers entitled to access the data and description of affected people’s rights related to data processing: The affected person may be informed about the source of data, their processing Data management is carried out on social networking sites, so the duration and method of data management, as well as the possibilities of deleting and modifying data, are regulated by the given social networking site.
  1. Legal basis for data processing: the affected person’s voluntary consent to the processing of his or her personal data on social networking sites.

Customer relations and other data processes

  1. In the case the data controller has any questions or problems during the use of our data controller services, he / she may contact the data controller in the ways provided on the website (telephone, e-mail, social networking sites, etc.).
    INDUPRO Ltd. (registered office: 11. Rozalia park, Biatorbágy, 2051, Phone number: ……., e-mail address: …..)
  1. The Data Controller shall delete the received e-mails, messages, data provided by telephone together with the name and e-mail address of the interested party, as well as other personal data provided voluntarily, no later than 2 years after the communication.
  1. We provide information on data processing not listed in this prospectus at the time of data collection.
  1. The Service Provider is obliged to provide information, communicate and hand over data, or make documents available upon exceptional authority request or in case of requesting other bodies based on the authorization of legislation.
  1. In such cases, the Service Provider shall provide the requester with personal data only to the extent and to the extent that is absolutely necessary for the realization of the purpose of the request, provided that it has indicated the exact purpose and scope of the data.

Rights of the stakeholders

  1. Right of access
    You have the right to receive feedback from the controller as to whether your personal data is being processed and, if such processing is in progress, you have the right to access your personal data and the information listed in the Regulation.
  1. Right to rectification
    You have the right, at the request of the controller, to correct inaccurate personal data concerning him or her without undue delay. Taking into account the purpose of the data processing, you have the right to request that the incomplete personal data be supplemented, inter alia, by means of a supplementary statement.
  1. Right of cancellation
    You have the right, at the request of the data controller, to delete personal data concerning him or her without undue delay, and the data controller is obliged to delete personal data concerning you without undue delay under certain conditions.
  1. The right to be forgotten
    If the controller has disclosed the personal data and is obliged to delete it, it shall take reasonable steps, including technical measures, taking into account the available technology and the costs of implementation, to inform the controllers that you have requested the personal data in question. deleting links or copies or duplicates of such personal data.
  1. Right to restrict data processing
    You have the right, at the request of the controller, to restrict the processing if one of the following conditions is met:
    • You dispute the accuracy of personal data, in this case the restriction applies to the period of time that allows the data controller to verify the accuracy of the personal data;
    • the processing is unlawful and you oppose the deletion of the data and instead ask for a restriction on its use;
    • the data controller no longer needs the personal data for the purpose of data processing, but you request them in order to submit, enforce or protect legal claims;
    • You objected to the data processing; in this case, the restriction applies for as long as it is established whether the legitimate reasons of the controller take precedence over your legitimate reasons.
  1. The right to data portability
    You have the right to receive the personal data concerning you provided to the data controller in a structured, widely used, machine-readable format and to transfer this data to another data controller without being hindered by the data controller whose personal data have been processed and made it available to him.
  1. Right to protest
    You have the right to object at any time to the processing of your personal data, including profiling based on these provisions, for reasons related to your own situation.
  1. Protest in case of direct acquisition
    If personal data is processed for the purpose of direct business acquisition, you have the right to object at any time to the processing of personal data concerning you for this purpose, including profiling, if it is related to direct business acquisition. If you object to the processing of personal data for the purpose of direct business acquisition, the personal data may no longer be processed for this purpose.
  1. Automated decision making in individual cases, including profiling
    You have the right not to be covered by a decision based solely on automated data processing, including profiling, which would have legal effect or similar effect on him or her.
    The preceding paragraph shall not apply if the decision:
    • Necessary for the conclusion or performance of a contract between you and the data controller;
    • is governed by EU or Member State law applicable to the controller, which also lays down appropriate measures to protect your rights and freedoms and legitimate interests; or
    • is based on your express consent.

Deadline for action

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

If necessary, it can be extended by 2 months. The data controller shall inform you of the extension of the deadline, indicating the reasons for the delay, within 1 month from the receipt of the request.

If the controller does not take action on your request, it will inform you without delay, but no later than one month after receipt of the request, of the reasons for the non-action and of the fact that you can lodge a complaint with a supervisory authority and have a judicial remedy.

Security of data processing

The controller and the processor shall take appropriate technical and organizational measures to take account of the state of science and technology and the costs of implementation, as well as the nature, scope, circumstances and purposes of the processing and the varying likelihood and severity of the risk to individuals’ rights and freedoms, to guarantee a level of data security appropriate to the degree of risk, including, inter alia, where appropriate:

  1. the aliasing and encryption of personal data;
  2. ensuring the continued confidentiality, integrity, availability and resilience of the systems and services used to process personal data;
  3. in the event of a physical or technical incident, the ability to restore access to and availability of personal data in a timely manner;
  4. a procedure for regular testing, assessment and evaluation of the effectiveness of the technical and organizational measures taken to ensure the security of data processing.

INFORM THE STAKEHOLDER ABOUT THE DATA PROTECTION INCIDENT

If the data protection incident is likely to pose a high risk to the rights and freedoms of natural persons, the controller shall inform the affected person of the data protection incident without undue delay.

The information provided to the affected person shall clearly and intelligibly describe the nature of the data protection incident and the name and contact details of the data protection officer or other contact person who provided further information; the likely consequences of the data protection incident must be described; describe the measures taken or planned by the controller to remedy the data protection incident, including, where appropriate, measures to mitigate any adverse consequences arising from the data protection incident.

The affected person 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 protection incident, in particular measures such as the use of encryption which make it incomprehensible to persons not authorized to access personal data the data;
  • the data controller has taken further measures following the data protection incident to ensure that the high risk to the data subject’s rights and freedoms is no longer likely to materialize;
  • information would require a disproportionate effort. In such cases, the affected person shall be informed through publicly available information or a similar measure shall be taken to ensure that the affected person is informed in an equally effective manner.

If the controller has not yet notified the affected person of the data protection incident, the supervisory authority may, after considering whether the data protection incident is likely to involve a high risk, order that the affected person will be informed.

DATA PROTECTION INCIDENT REPORT TO THE AUTHORITY

The data protection incident shall be reported by the controller to the supervisory authority competent under Article 55 without undue delay and, if possible, no later than 72 hours after becoming aware of the data protection incident, unless the data protection incident is not likely to jeopardize the rights of individuals. and its freedoms. If the notification is not made within 72 hours, the reasons for the delay must be provided.

Possibility to complain

Complaints against possible breaches of the data controller can be lodged with the National Data Protection and Freedom of Information Authority:

National Data Protection and Freedom of Information Authority
22/C. Szilágyi Erzsébet avenue, Budapest, 1125
Mailing address: Mailbox: 5. Budapest 153
Phone: +36 -1-391-1400
Fax: + 36-1-391-1410
E-mail: ugyfelszolgalat@naih.hu

Conclusion

During the preparation of the prospectus, we took into account the following legislation:

  • Regulation (EU) No. 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of. On the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Regulation (EC) No. 95/46 April 27)
  • 2011 CXII. Act – on the right to information self-determination and freedom of information (hereinafter: Infotv.)
  • CVIII of 2001 Act – on certain issues of electronic commerce services and services related to the information society (especially Section 13 / A)
  • XLVII of 2008 Act on the Prohibition of Unfair Commercial Practices against Consumers;
  • XLVIII of 2008 Act – on the basic conditions and certain restrictions of commercial advertising (especially § 6)
  • 2005 XC. Electronic Freedom of Information Act
  • Act C of 2003 on electronic communications (specifically § 155)
  • 16/2011. s. Opinion on the EASA / IAB Recommendation on Best Practices for Behavioral Online Advertising
  • Recommendation of the National Authority for Data Protection and Freedom of Information on data protection requirements for prior information
  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Regulation (EC) No 95/46

Done at Budapest, 20 September 2019.

_____________________________

INDUPRO Ltd.
Zsolt Piheni

managing director

References

 
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