Privacy Policy

Introduction

Csillag Ltd. (company registration number: 13 09 060423, tax number: 10260872213, registered office: 2230 Gyömrő, Munkás u 18.) (hereinafter referred to as the “Service Provider”, “Data Controller”) is subject to the following information.

The following information is provided pursuant to 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 of data onthe following websites and their associated mobile applications: http://bagoly.hu, https://restaurant.bagoly-fogado.hu and https://www.bagoly-fogado.hu

The privacy notice is available at: https://www.bagoly-fogado.hu/adatvedelem

Amendments to the Prospectus will enter into force upon publication at the above address.

The data controller and its contact details:

Name: Csillag Ltd.

Office: 2230 Gyömrő, Munkás u 18.

E-mail: bagoly@bagoly.hu

Phone: +36 70 330-1086

Definitions of terms

  1. “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, 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;
  1. “processing” means any operation or set of operations which is performed upon personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
  1. ‘controller’ means a natural or legal person, public authority, agency or any 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 the processing are determined by Union or Member State law, the controller or specific criteria for the designation of the controller may also be determined by Union or Member State law;
  1. “processor” means a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller;
  1. “recipient” means a natural or legal person, public authority, agency or any other body to whom or with which personal data is disclosed, whether or not a third party. Public authorities that may have access to personal data in the context of an individual investigation in accordance with Union or Member State law are not recipients; the processing of those data by those public authorities must comply with the applicable data protection rules in accordance with the purposes of the processing;
  1. “the data subject’s consent” means a freely given, specific, informed and unambiguous indication of his or her wishes by which the data subject signifies, by a statement or by an act expressing his or her unambiguous consent, that he or she signifies his or her agreement to the processing of personal data concerning him or her;
  1. “data breach” means a breach of security that results in the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Principles governing the processing of personal data

Personal data:

  1. must be lawful, fair and transparent for the data subject (“lawfulness, fairness and transparency”);
  1. collected only for specified, explicit and legitimate purposes and not processed in a way incompatible with those purposes; and 89. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes (“purpose limitation”) shall not be considered incompatible with the original purpose, in accordance with Article 3(1);
  1. be adequate and relevant for the purposes for which the data are processed and limited to what is necessary (“data minimisation”);
  1. be accurate and, where necessary, kept up to date; all reasonable steps must be taken to ensure that personal data which are inaccurate for the purposes for which they are processed are erased or rectified without undue delay (“accuracy”);
  1. 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 kept for longer periods only if the processing of the personal data is subject to the conditions laid down in Article 89. in accordance with Article 3(1) for archiving purposes in the public interest, scientific and historical research purposes or statistical purposes, subject to the implementation of appropriate technical and organisational measures as provided for in this Regulation to safeguard the rights and freedoms of data subjects (‘limited retention’);
  1. be carried out in such a way as to ensure adequate security of personal data, including protection against unauthorised or unlawful processing, accidental loss, destruction or damage (“integrity and confidentiality”), by implementing appropriate technical or organisational measures.

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

Data management

Booking accommodation, request an offer

  1. The fact of collection, the scope of the data processed and the purpose of the processing:
Personal data Purpose of data processing Legal basis
Surname and first name It is required for contacting, booking and issuing a proper invoice. a GDPR 6. Article from b) and c).
E-mail address Staying in touch.
Phone number Maintaining contacts, coordinating more efficiently on booking and billing issues.
Billing name and address In the case of accommodation and services, the issuing of proper invoices, as well as the creation, definition, modification, monitoring of the performance of the contract, invoicing of the fees arising from it, and the enforcement of claims related to it.
Reservation details (date and time, arrival time, departure time, number of adults, number of children, age of children, type of board, room type) Enabling reservations.
Date of booking/request for a quote Perform a technical operation. Section 13/A (3) of the Elker Act.
IP address at the time of booking/request Perform a technical operation.

The e-mail address does not need to contain personal data.

  1. Data subjects: all data subjects booking on the website.
  1. Duration of processing, deadline for deletion of data: the data will be deleted immediately after the User has replied to the request (in this case, the Data Controller is no longer entitled to send him/her a newsletter), if he/she has not booked a room. If the User has booked a room in the Service Provider’s system, a contract has been concluded, so the deadline for deletion of personal data is different for accounting documents, since the Hungarian Accounting Act 2000. Act C of 2006 No 169. § (2), these data must be kept for 8 years.

The accounting documents (including general ledger accounts, analytical or detailed records) directly and indirectly supporting the accounting accounts must be kept for at least 8 years in a legible form, retrievable by reference to the accounting records.

  1. Potential controllers of the data, recipients of the personal data: personal data may be processed by the sales and marketing staff of the controller, in compliance with the above principles.
  1. Description of data subjects’ rights in relation to data processing:
  • The data subject may request the controller to access, rectify, erase or restrict the processing of personal data relating to him or her, and
  • the data subject has the right to data portability and the right to withdraw consent at any time.
  1. The data subject may initiate theaccess to, deletion, modification or restriction of processing ofpersonal data , data portability and objection to processing in the following ways:
  • by post to 2230 Gyömrő, Munkás u 18. at
  • by e-mail to bagoly@bagoly.hu,
  • by phone on +36 70 330-1086.
  1. Legal basis for processing:
  • a GDPR 6. Article 2(1) b) and point c),
  • The Act on electronic commerce services and certain aspects of information society services of 2001. CVIII. Act (hereinafter: Elker tv.) 13/A. § (3):

The service provider may process personal data that are technically necessary for the provision of the service. The service provider must, other things being equal, choose and in any case operate the means used in the provision of the information society service in such a way that personal data are processed only to the extent strictly necessary for the provision of the service and for the fulfilment of the other purposes laid down in this Act, but only to the extent and for the duration necessary.

  • If the invoice is issued in accordance with accounting legislation, the 6. Article 4(1)(c).
  • For the enforcement of claims arising from the contract, the provisions of the Civil Code 2013. Act V of 2007 6:21. § 5 years.

6:22. § [Elévülés]

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

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

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

(4) An agreement excluding the limitation period shall be null and void.

  1. Please note that
  • processing is based on the conclusion of a contract in the case of an offer or reservation, or is necessary to take the steps you have requested prior to the conclusion of the contract ,
  • obliged provide the personal data in order to complete the booking.
  • the failure to provide the data is due to consequences we will not be able to process your reservation or request.

Reservations at bagoly-fogado.hu

  1. The fact of collection, the scope of the data processed and the purpose of the processing:
Personal data Purpose of data processing Legal basis
Surname and first name The contact. Article 6(1) a) and point b)
E-mail address Staying in touch.
Phone number Keeping in touch, better coordination of booking issues.
Booking details (date and time, number of guests) Enabling reservations.
Date of reservation Perform a technical operation. Elker tv. 13/A. § (3)
IP address at the time of booking Perform a technical operation. Elker tv. 13/A. § (3)

The e-mail address does not need to contain personal data.

  1. Data subjects: all data subjects booking on the website.
  1. Duration of data processing, deadline for deletion of data: the data processing lasts until the end of the date.
  1. Identity of potential controllers of the data, recipients of personal data: personal data may be processed by the controller’s staff, in compliance with the principles set out above.
  1. Description of data subjects’ rights in relation to data processing:
  • The data subject may request the controller to access, rectify, erase or restrict the processing of personal data relating to him or her, and
  • the data subject has the right to data portability and the right to withdraw consent at any time.
  1. The data subject may initiate theaccess to, deletion, modification or restriction of processing ofpersonal data , data portability and objection to processing in the following ways:
  • by post to 2230 Gyömrő, Munkás u 18. at
  • by e-mail to bagoly@bagoly.hu,
  • by phone on +36 70 330-1086.
  1. Legal basis for processing: consent of the data subject, 6. Article 2(1) a) and (b) and the provisions of the Decree on electronic commerce services and certain aspects of information society services of 2001. CVIII. Act (hereinafter: Elker tv.) 13/A. § (3):

The service provider may process personal data that are technically necessary for the provision of the service. The service provider must, other things being equal, choose and in any case operate the means used in the provision of the information society service in such a way that personal data are processed only to the extent strictly necessary for the provision of the service and for the fulfilment of the other purposes laid down in this Act, but only to the extent and for the duration necessary.

  1. Please note that
  • the processing is based on your consent
  • obliged provide personal information so that we can fulfil your reservation.
  • the failure to provide the data is due to consequences will result in our inability to process your reservation.

Data processing related to food ordering

  1. The fact of collection, the scope of the data processed and the purpose of the processing:
Personal data Purpose of the processing Legal basis
User name Identification, enabling registration. a GDPR 6. Art.1(1)(b) and the Elker tv. 13/A. § (3).
Password It is used for secure access to the user account.
Surname and first name It is necessary to contact you, to make a purchase, to issue a proper invoice.
E-mail address Staying in touch.
Phone number Maintaining contacts, coordinating more efficiently on billing or delivery issues.
Billing name and address To issue proper invoices, and to create, define, amend, monitor the performance of, invoice the fees arising from, and enforce the claims related to the contract. Article 6(1)(c) and Article 6(1)(c) of the Accounting Act 2000. Act C of 2006 No 169. § (2) paragraph
Delivery name and address Enabling home delivery. a GDPR 6. Art.1(1)(b) and the Elker tv. 13/A. § (3).
Date of purchase Perform a technical operation.
Location Enabling effective service delivery.
IP address at the time of purchase Perform a technical operation.

Neither the username nor the e-mail address need to contain personal data.

  1. Data subjects: all data subjects who make a purchase on the website.
  1. Duration of data processing, deadline for deletion of data: if the GDPR 17. Where one of the conditions laid down in Article 3(1) is met, it shall continue until the request for erasure by the data subject. The erasure of any personal data provided by the data subject is subject to the provisions of GDPR 19. the data subject shall be informed by electronic means. If the data subject’s request for erasure also includes the e-mail address provided by him or her, the controller shall erase the e-mail address after the information is provided. Except in the case of accounting vouchers, since the Accounting Act 2000. Act C of 2006 No 169. § (2), these data must be kept for 8 years. The contractual data of the data subject may be erased after the expiry of the civil limitation period on the basis of a request for erasure by the data subject.

The accounting documents (including general ledger accounts, analytical or detailed records) directly and indirectly supporting the accounting accounts must be kept for at least 8 years in a legible form, retrievable by reference to the accounting records.

  1. Potential controllers of the data, recipients of the personal data: personal data may be processed by the sales and marketing staff of the controller, in compliance with the above principles.
  1. Description of data subjects’ rights in relation to data processing:
  • The data subject may request the controller to access, rectify, erase or restrict the processing of personal data relating to him or her, and
  • the data subject has the right to data portability and the right to withdraw consent at any time.
  1. The data subject may requestaccess to, deletion, modification or restriction of processing ofpersonal data , or the portability of data in the following ways:
  • by post to 2230 Gyömrő, Munkás u 18. at
  • by e-mail to bagoly@bagoly.hu,
  • by phone on +36 70 330-1086.
  1. Legal basis for processing:
  • a GDPR 6. Article 3(1) b) and point c),
  • The Act on electronic commerce services and certain aspects of information society services of 2001. CVIII. Act (hereinafter: Elker tv.) 13/A. § (3):

The service provider may process personal data that are technically necessary for the provision of the service. The service provider must, other things being equal, choose and in any case operate the means used in the provision of the information society service in such a way that personal data are processed only to the extent strictly necessary for the provision of the service and for the fulfilment of the other purposes laid down in this Act, but only to the extent and for the duration necessary.

  • If the invoice is issued in accordance with accounting legislation, the 6. Article 4(1)(c).
  • For the enforcement of claims arising from the contract, the provisions of the Civil Code 2013. Act V of 2007 6:21. § 5 years.

6:22. § [Elévülés]

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

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

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

(4) An agreement excluding the limitation period shall be null and void.

  1. Please note that
  • processing is necessary for the performance of a contract and the submission of an offer .
  • obliged provide personal data so that we can fulfil your order.
  • the failure to provide the data is due to with the consequence will result in our inability to process your order.

The data processors used

Hosting provider

  1. Activity provided by the data processor: Hosting
  1. Name and contact details of the data processor:

MAXER Hosting Kft

Phone: +3612579913

Email: info@maxer.hu

  1. Fact of processing, scope of data processed: all personal data provided by the data subject.
  1. Data subjects: all data subjects using the website.
  1. Purpose of data processing: to make the website available and to ensure its proper operation.
  1. Duration of data processing, deadline for deletion of data: immediately upon cancellation of registration.
  1. Legal basis for the processing: article (1)(b).

Other data processors:

Hostware Kft., 1149 Budapest, Róna utca 120., (+36-1) 469-9000 (booking, billing, support)

Laurel Ltd., 8000 Székesfehérvár, Gyümölcs Utca 4-6., +36 22 510 350 (cashier program, support)

Partner Log Kft., 2351 Alsónémedi, 2402/1 (franchise cooperation)

Re-Marco Kft., 2120 Dunakeszi, Kolozsvár utca 27. , (Profittárs invoicing program)

Recipients to whom personal data are disclosed (Transfers):

Online payment

  1. Activity provided by the Recipient: online payment
  1. Name and contact details of the addressee:

OTP Mobil Szolgáltató Kft.

Head office: 1093 Budapest, Közraktár u. 30-32.

E-mail: ugyfelszolgalat@simple.hu

Phone: +36 1 776-6901

  1. Fact of processing, scope of data processed: billing data, name, e-mail address
  1. Data subjects: all data subjects who choose to pay on the website.
  1. Purpose of the processing: to process online payments, confirm transactions and perform fraud-monitoring to protect users.
  1. Duration of processing, deadline for deletion of data: until the online payment is completed.
  1. Legal basis for the processing of the data: the GDPR 6. Article 4(1)(b). The processing is necessary to complete an online payment at the request of the data subject.
  1. Rights of the data subject:
  1. You can find out about the circumstances of data processing,
  2. You have the right to receive feedback from the controller on whether your personal data are being processed and to have access to all information relating to the processing.
  3. You have the right to receive your personal data in a structured, commonly used, machine-readable format.
  4. You have the right to have inaccurate personal data corrected by the controller without undue delay at your request.

Newsletter, DM activity

  1. The 2008 Act on the Basic Conditions and Certain Restrictions on Commercial Advertising. XLVIII. Act 6. §-the User may expressly consent in advance to the Service Provider contacting him/her with advertising offers and other mailings at the contact details provided upon registration.
  1. In addition, the Customer may, subject to the provisions of this notice, consent to the processing of personal data by the Service Provider necessary for the sending of advertising offers.
  1. The Service Provider will not send unsolicited commercial messages and the User may unsubscribe from receiving offers without any restriction and without giving any reason, free of charge. In this case, the Service Provider will delete all personal data necessary for sending advertising messages from its records and will not contact the User with further advertising offers. Users can unsubscribe from advertising by clicking on the link in the message.
  1. The fact of collection, the scope of the data processed and the purpose of the processing:
Personal data Purpose of data processing Legal basis
Name, e-mail address. Identification, to enable subscription to the newsletter/special offers. Consent of the data subject,6. Article 3(1)(a).The Act on the basic conditions and certain restrictions on commercial advertising of 2008. XLVIII. Act 6. § (5).
Date of subscription Perform a technical operation.
IP address at the time of subscription Perform a technical operation.
  1. Data subjects: all data subjects who subscribe to the newsletter.
  1. Purpose of data processing: sending electronic messages (e-mail, SMS, push messages) containing advertising to the data subject, providing information about current information, products, promotions, new features, etc.
  1. Duration of data processing, deadline for deletion of data: data processing lasts until the consent is withdrawn, i.e. until unsubscription.
  1. Potential controllers of the data, recipients of the personal data: personal data may be processed by the sales and marketing staff of the controller, in compliance with the above principles.
  1. Description of data subjects’ rights in relation to data processing:
  • The data subject may request the controller to access, rectify, erase or restrict the processing of personal data relating to him or her, and
  • 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.
  1. The data subject may initiate theaccess to, deletion, modification or restriction of processing ofpersonal data , data portability and objection to processing in the following ways:
  • by post to 2230 Gyömrő, Munkás u 18. at
  • by e-mail to bagoly@bagoly.hu,
  • by phone on +36 70 330-1086.
  1. The data subject may unsubscribe from the newsletter at any time, free of charge.
  1. Legal basis for processing: consent of the data subject, 6. Article 3(1)(a) and (f) and Article 3(1)(a) and (f) of the Act of 2008 on the basic conditions and certain restrictions on commercial advertising. XLVIII. Act 6. § (5):

The advertiser, the advertising service provider or the publisher of the advertisement shall keep a record of the personal data of the persons who have given their consent within the scope specified in the consent. The data recorded in this register – relating to the recipient of the advertising – may only be processed in accordance with the consent form, until it is withdrawn, and may only be disclosed to third parties with the prior consent of the person concerned.

  1. Please note that
  • the processing is based on your consent and the legitimate interest of the service provider
  • obliged provide personal data if you wish to receive newsletters from us.
  • the failure to provide the data is due to consequences we will not be able to send you a newsletter.
  • Please note that you can withdraw your consent at any time by clicking on the unsubscribe, withdraw consent does not affect the lawfulness of the processing based on consent prior to its withdrawal.

Complaints handling

  1. The fact of collection, the scope of the data processed and the purpose of the processing:
Personal data Purpose of the processing Legal basis
Surname and first name Identification, contact. Article 6(1)(c), and Article 6(1)(c) of the Consumer Protection Act 1997. CLV. Act 17/A. § (7).
E-mail address Staying in touch.
Phone number Staying in touch.
Billing name and address Identifying, handling quality complaints, questions and problems related to the services ordered.
  1. Stakeholders: all data subjects who use the services of the host and who have quality complaints.
  1. Duration of data processing, deadline for deletion of data: copies of the record of the complaint, the transcript and the reply to the complaint shall be kept in accordance with the provisions of the Consumer Protection Act 1997. CLV. Act 17/A. § (7) shall be kept for 5 years.
  1. Potential controllers of the data, recipients of the personal data: personal data may be processed by the sales and marketing staff of the controller, in compliance with the above principles.
  1. Description of data subjects’ rights in relation to data processing:
  • The data subject may request the controller to access, rectify, erase or restrict the processing of personal data relating to him or her, and
  • the data subject has the right to data portability and the right to withdraw consent at any time.
  1. The data subject may requestaccess to, deletion, modification or restriction of processing ofpersonal data , or the portability of data in the following ways:
  • by post to 2230 Gyömrő, Munkás u 18. at
  • by e-mail to bagoly@bagoly.hu,
  • by phone on +36 70 330-1086.
  1. Legal basis for processing: the GDPR 6. Article 2(1)(c) and Article 3(1)(c) of the Consumer Protection Directive 1997. CLV. Act 17/A. § (7).
  1. Please note that
  • the provision of personal data a legal obligation
  • the conclusion of the contract prerequisite for the contract the processing of personal data.
  • obliged provide personal data so that we can handle your complaint.
  • the failure to provide the data is due to consequences we will not be able to deal with your complaint that we have received.

Contact

  1. The fact of collection, the scope of the data processed and the purpose of the processing:
Personal data Purpose of data processing Legal basis
Name Identification Article 6(1) a), b) and point c)
E-mail address Keep in touch, send reply messages Article 6(1) a), b) and point c)
Message content Required to reply Article 6(1) a), b) and point c)
Date of contact Perform a technical operation. Article 6(1) a), b) and point c)
IP address at the time of contact Perform a technical operation. Article 6(1) a), b) and point c)

The e-mail address does not need to contain any personal data.

  1. Data subjects: all data subjects who send a message via the contact form.
  1. Duration of data processing, deadline for deletion of data: if the GDPR 17. Where one of the conditions laid down in Article 3(1) is met, it shall continue until the request for erasure by the data subject.
  1. Identity of the possible controllers who may have access to the data, recipients of personal data: personal data may be processed by the authorised staff of the controller.
  1. Description of data subjects’ rights in relation to data processing:
  • The data subject may request the controller to access, rectify, erase or restrict the processing of personal data relating to him or her, and
  • the data subject has the right to data portability and the right to withdraw consent at any time.
  1. The data subject may requestaccess to, deletion, modification or restriction of processing ofpersonal data , or the portability of data in the following ways:
  • by post to 2230 Gyömrő, Munkás u 18. at
  • by e-mail to bagoly@bagoly.hu,
  • by phone on +36 70 330-1086.
  1. Legal basis for processing: consent of the data subject, 6. Article 3(1) a), b) and point c). By contacting us, you consent to the processing of your personal data (name, e-mail address) provided to us in accordance with this policy.
  1. Please note that
  • the present processing is based on your consent and necessary to make an offer or, in the case of a contractual relationship, based on a legal obligation (cooperation).
  • obliged provide the personal data to contact us.
  • the failure to provide the data is due to consequences that you are unable to contact the Service Provider.
  • the withdrawal of consent does not affect the lawfulness of processing based on consent prior to its withdrawal.

Contact

  1. The fact of collection, the scope of the data processed and the purpose of the processing:
Personal data Purpose of the processing Legal basis
Name, e-mail address, telephone number. Contact, identification, contract fulfilment, business purpose. Article 6(1) b) and c) of the Civil Code 2013 on the Civil Code, in the case of enforcement of claims arising from the contract. Act V of 2007 6:21. §-a
  1. Data subjects: all data subjects in contact with the data controller by telephone/e-mail/in person or in a contractual relationship.
  1. Duration of processing, time limit for deletion of data: letters containing requests will be processed until the data subject requests their deletion, but not longer than 2 years.
  1. Identity of potential controllers of the data, recipients of the personal data: personal data may be processed by authorised staff of the controller, in compliance with the above principles.
  1. Description of data subjects’ rights in relation to data processing:
  • The data subject may request the controller to access, rectify, erase or restrict the processing of personal data relating to him or her, and
  • the data subject has the right to data portability and the right to withdraw consent at any time.
  1. The data subject may requestaccess to, deletion, modification or restriction of processing ofpersonal data , or the portability of data in the following ways:
  • by post to 2230 Gyömrő, Munkás u 18. at
  • by e-mail to bagoly@bagoly.hu,
  • by phone on +36 70 330-1086.
  1. Legal basis for processing:
  • a GDPR 6. Article 2(1) b) and c).
  • For the enforcement of claims arising from the contract, the provisions of the Civil Code 2013. Act V of 2007 6:21. § 5 years.

6:22. § [Elévülés]

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

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

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

(4) An agreement excluding the limitation period shall be null and void.

  1. Please note that
  • processing is necessary for the performance of a contract and the submission of an offer .
  • obliged provide personal data so that we can fulfil the contract/fulfil your other requests.
  • the failure to provide the data is due to consequences we are unable to fulfil the contract/process your request.

Internal data protection

  1. Legal basis for processing: to fulfil a legal obligation.
  1. Purpose of processing: to comply with the legal requirements relating to tourist tax.
  1. Duration of processing, time limit for erasure of data: until the competent authority can verify compliance with the obligations laid down in the relevant legislation and, in the case of a contract, until the deadline for the application of the provisions of the Act on Accounting 2000. Act C of 2006 No 169. § (2) – 7. 31 December of the year.
  1. Data processed: name, e-mail, address, ID number, nationality, date of birth, registration number, other personal data.
  1. Potential data controllers who may have access to the data: personal data may be processed by the controller’s staff, in compliance with the principles set out above.

Processing of business cards

  1. Legal basis for processing: the User’s voluntary consent, which is obtained by the User’s act of providing the Service Provider with his/her business card containing his/her personal data.
  1. Data processed: name, telephone number, address, e-mail address, workplace, work address, and other personal data on the business card.
  1. The purpose of the processing: to build relationships and facilitate contact between persons.
  1. The provisions of this Privacy Notice shall apply accordingly to the transfer and processing of business cards.
  1. Deadline for deletion of data: until the consent is withdrawn, i.e. until the instruction to destroy the business card.
  1. Potential data controllers who may have access to the data: personal data may be processed by the controller’s staff, in compliance with the principles set out above.

Community sites

  1. Fact of data collection, scope of data processed: Facebook/Twitter/Pinterest/Youtube/Instagram etc. the name registered on social networking sites or the user’s public profile picture.
  1. Data subjects: all data subjects who are registered on Facebook/ Twitter/Pinterest/Youtube/Instagram etc. on social media and “liked” the website.
  1. Purpose of the data collection: to share or “like” certain content, products, promotions or the website itself on social networking sites.
  1. Duration of data processing, time limit for deletion of data, the identity of the possible controllers entitled to access the data and the rights of the data subjects in relation to data processing: the data subject can find out about the source of the data, the processing of the data and the method and legal basis of the transfer on the relevant Community site. The processing of data takes place on social networking sites, so the duration of the processing, the way in which the data are processed, and the possibilities for deleting and modifying the data are governed by the rules of the social networking site concerned.
  1. Legal basis for processing: the data subject’s voluntary consent to the processing of his or her personal data on social networking sites.

Customer relations and other data management

  1. If the data subject has any questions or problems when using our services, he or she can contact the data controller by the means indicated on the website (telephone, e-mail, social networking sites, etc.).
  1. The Data Controller will process your incoming emails, messages, telephone, Facebook, etc. together with the name and e-mail address of the interested party and any other personal data voluntarily provided by the interested party, will be deleted after a maximum of 2 years from the date of the communication.
  1. Information about data processing not listed in this notice is provided at the time of collection.
  1. In exceptional cases, the Service Provider shall be obliged to provide information, disclose data, hand over data or make documents available upon request of a public authority or other bodies authorised by law.
  1. In such cases, the Service Provider shall disclose personal data to the requesting party only to the extent and to the extent strictly necessary for the purpose of the request, provided that the requesting party has indicated the exact purpose and scope of the data.

Rights of data subjects

  1. Right of access

You have the right to receive feedback from the controller as to whether or not your personal data are 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. The right to rectification

You have the right to have inaccurate personal data relating to you corrected by the controller without undue delay at 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 a supplementary declaration.

  1. The right to erasure

You have the right to have personal data concerning you erased by the controller without undue delay at your request, and the controller is obliged to erase 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 required to delete it, it will take reasonable steps, including technical measures, taking into account the available technology and the cost of implementation, to inform the controllers that process the data that you have requested the deletion of the links to or copies of the personal data in question.

  1. Right to restriction of processing

You have the right to have the controller restrict processing at your request if one of the following conditions is met:

  • You contest the accuracy of the personal data, in which case the restriction applies for the period of time that allows the controller to verify the accuracy of the personal data;
  • the processing is unlawful and you object to the deletion of the data and instead request the restriction of their use;
  • the controller no longer needs the personal data for the purposes of processing, but you require 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 established whether the controller’s legitimate grounds prevail over your legitimate grounds.
  1. The right to data portability

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

  1. The right to protest

In the case of processing based on legitimate interest or public authority as legal grounds, 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 these provisions.

  1. Objection in the case of direct acquisition

Where personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such purposes, including profiling, where it is related to direct marketing. If you object to the processing of your personal data for direct marketing purposes, your personal data will no longer be processed for these purposes.

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

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

The preceding paragraph shall not apply in the case where the decision:

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

Deadline for action

The controller shall inform you of the action taken on such requests without undue delay and in any event within 1 month of receipt of the request.

If necessary, this can be extended by 2 months. The controller will inform you of the extension of the deadline within 1 month of receipt of the request, stating the reasons for the delay.

If the controller fails to act on your request, it will inform you without delay and at the latest within one month of receipt of the request of the reasons for the failure to act, of the possibility to lodge a complaint with a supervisory authority and of your right to judicial remedy.

Security of data processing

The controller and the processor shall implement appropriate technical and organisational measures, taking into account the state of the art and the cost of implementation, the nature, scope, context and purposes of the processing and the varying degrees of probability and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of data security appropriate to the level of risk, including, where appropriate:

  1. the pseudonymisation and encryption of personal data;
  1. the continued 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 and availability of personal data in a timely manner;
  1. a procedure to test, assess and evaluate regularly the effectiveness of the technical and organisational measures taken to ensure the security of processing.
  1. Processed data must be stored in a way that does not allow unauthorised access. In the case of paper-based data carriers, by establishing a physical storage and filing system, and in the case of data managed in electronic form, by using a centralised access management system.
  1. The method of storing the data by computerised means must be chosen in such a way that they can be erased, also taking into account any different erasure deadline, at the end of the erasure deadline or if otherwise necessary. The deletion must be irreversible.
  1. Paper-based data media should be shredded or personal data should be removed by an external organisation specialised in shredding. In the case of electronic data media, physical destruction and, where necessary, prior secure and irretrievable deletion of the data must be ensured in accordance with the rules on the disposal of electronic data media.
  1. The controller will take the following specific data security measures:
  1. In order to ensure the security of personal data processed on paper, the Service Provider applies the following measures(physical protection):
  1. Store the documents in a secure, lockable, dry place.
  2. The Service Provider’s building and premises are equipped with fire and property protection equipment.
  • Personal data can only be accessed by authorised persons and cannot be accessed by third parties.
  1. The Service Provider’s employee performing data processing may leave the premises where data processing is taking place only by locking the data carriers entrusted to him or by locking the given premises.
  2. Where personal data processed on paper are digitised, the rules applicable to digitally stored documents apply.
  1. IT security
  1. Computers and mobile devices (other data carriers) used in the course of data processing are the property of the Service Provider.
  2. Access to data on computers is only possible with a username and password.
  • Access to the central server machine is only allowed to authorised and designated persons.
  1. To ensure the security of digitally stored data, the Service Provider uses data backups and archiving.
  2. The computer system containing personal data used by the Service Provider is protected against viruses.
  3. encrypted channel (SSL)
  • The Data Controller shall ensure that:
    1. the continued confidentiality, integrity, availability and resilience of the systems and services used to process personal data;
    2. in the event of a physical or technical incident, the ability to restore access to and availability of personal data in a timely manner.

Informing the data subject about the 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 shall inform the data subject of the personal data breach without undue delay.

The information provided to the data subject shall clearly and in an understandable way describe the nature of the personal data breach and provide the name and contact details of the Data Protection Officer or other contact person who can provide further information; describe the likely consequences of the personal data breach; describe the measures taken or envisaged by the controller to remedy the personal data breach, including, where appropriate, measures to mitigate any adverse consequences of the personal data breach.

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

  • the controller has implemented appropriate technical and organisational protection measures and these measures have been applied to the data affected by the personal data breach, in particular measures, such as the use of encryption, which render the data unintelligible to persons not authorised to access the personal data;
  • the controller has taken additional measures following the personal data breach to ensure that the high risk to the rights and freedoms of the data subject is no longer likely to materialise;
  • information would require a disproportionate effort. In such cases, the data subjects should be informed by means of publicly disclosed information or by a similar measure which ensures that the data subjects are informed in an equally effective manner.

If the controller has not yet notified the data subject of the personal data breach, the supervisory authority may, after having considered whether the personal data breach is likely to present a high risk, order the data subject to be informed.

Reporting a data protection incident to the authority

The controller shall notify the data protection incident to the 55th Data Protection Authority without undue delay and, if possible, no later than 72 hours after the data protection incident has come to its attention. to the supervisory authority competent pursuant to Article 13, unless the personal data breach is unlikely to pose a risk to the rights and freedoms of natural persons. If the notification is not made within 72 hours, it must be accompanied by the reasons justifying the delay.

Review in case of mandatory data processing

If the duration of the mandatory processing or the periodic review of its necessity is not specified by law, local government regulation or a binding legal act of the European Union, reviewed by the controller at least every three years from the start of processingthat the processing of personal data processed by him or her or by a processor acting on his or her behalf or under his or her instructions is necessary for the purposes of the processing is it necessary.

The data controller shall document the circumstances and the results of this review , keep this documentation for ten years after the review and make it available to the National Authority for Data Protection and Freedom of Information (hereinafter referred to as “the Authority”) upon request.

Complaint possibility

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

National Authority for Data Protection and Freedom of Information

1125 Budapest, Szilágyi Erzsébet fasor 22/C.

Postal address: 1530 Budapest, P.O. Box 5.

Phone: +36 -1-391-1400

Fax: +36-1-391-1410

E-mail: ugyfelszolgalat@naih.hu

Closing words

The following legislation has been taken into account in the preparation of this 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 Regulation (EC) No 95/46/EC (General Data Protection Regulation) (GDPR) (27 April 2016)
  • CXII. Act on the Right to Informational Self-Determination and Freedom of Information (hereinafter: Infotv.)
  • CVIII. Act – on certain aspects of electronic commerce services and information society services (in particular § 13/A)
  • XLVII. Act – on the prohibition of unfair commercial practices against consumers;
  • XLVIII. Act on the basic conditions and certain restrictions on commercial advertising (in particular § 6)
  • XC. law on electronic freedom of information
  • Act C of 2006 on Electronic Communications (specifically § 155)
  • 16/2011. s. Opinion on the EASA/IAB Recommendation on best practice for behavioural online advertising
  • Recommendation of the National Authority for Data Protection and Freedom of Information on the data protection requirements for prior information