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Privacy policy

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KéK Cégcsoport Kft (Ltd)

Introduction

A / Az KéK Cégcsoport Kft (Ltd) (6326 Harta, Rákóczi 11 / A, tax number: 12579877-2-03, company registration number / registration number: 0309108719) (hereinafter: Service Provider, data controller) submits to the following regulations:

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 (General Data Protection Regulation) REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 2016 27.) we provide the following information.

This data protection policy regulates the data management of the following sites / mobile applications: https://info.kekkorkep.hu/

The privacy policy is available on the following page: https://www.kekceghmä.hu/adatvedelem

Amendments to the Regulations shall enter into force upon publication at the above address.

Data controller and contact details

Name: KéK Cégcsoport Kft (Ltd)

Headquarters: 6326 Harta, Rákóczi 11 / A

E-mail: info@kekkorkep.hu

Phone: +36302825885

Concept definitions

  1. personal data“Means any information relating to an identified or identifiable natural person (” data subject “); identify a natural person who, directly or indirectly, in particular by an identifier such as name, number, location, online identifier or one or more factors relating to the physical, physiological, genetic, mental, economic, cultural or social identity of the natural person identifiable;
  2. data handling “Means any operation or set of operations on personal data or files, whether automated or non-automated, such as collecting, recording, organizing, segmenting, storing, transforming or altering, querying, accessing, using, transmitting, disseminating or otherwise making available by lot, harmonization or interconnection, restriction, deletion or destruction;
  3. data controller“Means any 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 the specific criteria for the designation of the controller may also be determined by Union or Member State law;
  4. data processor “Means any natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller;
  5. addressee “Means any natural or legal person, public authority, agency or any other body to whom personal data are disclosed, whether a third party or not. Public authorities that may have access to personal data in the framework of an individual investigation in accordance with Union or Member State law shall not be considered as 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;
  6. the consent of the data subject “Means a voluntary, specific and well-informed and clear statement of the will of the data subject, by which he or she indicates his or her consent to the processing of personal data concerning him or her by means of a statement or an unequivocal statement of confirmation;
  7. privacy incident “Means a breach of security resulting in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or unauthorized access to, personal data transmitted, stored or otherwise handled.

Principles for the processing of personal data

Personal information:

  1. must be handled lawfully and fairly and in a manner legality, due process and transparency ”);
  2. collected only for specified, explicit and legitimate purposes and not treated in a way incompatible with those purposes; a 89. further processing for the purposes of archiving in the public interest, scientific and historical research or statistical purposes shall not be considered incompatible with the original purpose in accordance with Article purpose limitation ”);
  3. be appropriate and relevant to the purposes of the processing and be limited to what is necessary (‘ data saving ”);
  4. they must be accurate and, where necessary, kept up to date; all reasonable steps shall be taken to ensure that personal data which are inaccurate for the purposes of the processing are erased or rectified without delay (“ accuracy ”);
  5. it must be stored in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for a longer period only if the processing of personal data is carried out in accordance with Article 89. will be carried out for archiving in the public interest, for scientific and historical research or for statistical purposes in accordance with Article limited storage ”);
  6. appropriate technical or organizational measures to ensure the adequate security of personal data, including protection against unauthorized or unlawful handling, accidental loss, destruction or damage integrity and confidentiality ”).

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

The data controller declares that its data processing is carried out in accordance with the principles set out in this section.

Registration (creating a user account)

1. The fact of data collection, the scope of the data processed and the purposes of data management :

Personal dataPurpose of data managementLegal basis
Surname first nameAuthentication, for secure access to the user account.Article 6 (1) (a).
E-mail addressStay in touch, send system messages, log in to a user accountArticle 6 (1) (a).
PasswordProvides secure access to the user account.Article 6 (1) (a).
Date of registrationPerform a technical operation.Article 6 (1) (a).
The IP address at the time of registrationPerform a technical operation.Article 6 (1) (a).

The email address does not need to contain any personal information.

2. Stakeholders : all stakeholders registered on the website / mobile application.

3. Duration of data management, deadline for deleting data : If GDPR 17. If one of the conditions set out in Article 1 (1) is met, it shall last until the data subject requests the cancellation. Deleting the registration will immediately delete the personal data. The controller shall delete the personal data provided by the data subject in accordance with Article 19 of the GDPR. shall inform the data subject by electronic means in accordance with Article If the data subject’s request for cancellation includes the e-mail address provided by the data subject, the data controller will also delete the e-mail address after the notification.

4. The identity of the potential data controllers entitled to access the data, the recipients of the personal data : Personal data may be processed by the authorized employees of the data controller in accordance with the contents of this information.

5. Description of the data subjects’ rights in relation to data processing :

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

6. For personal information access , their deletion, modification or restriction of their handling, the portability of the data can be initiated by the data subject in the following ways :

  • by post to the address 6326 Harta, Rákóczi 11 / A,
  • by e-mail to info@kekkorkep.hu,
  • by phone at +36302825885.

7. Legal basis for data management : 6. Article 1 (1) (a). Consent of the data subject.

8. Please be informed that

  • data management based on your consent.
  • obliged provide personal information so we can register.
  • failure to provide data with a consequences that the user account cannot be created.
  • the withdrawal of consent shall not affect the lawfulness of the pre-withdrawal data processing based on consent.

B2B Customer Relationship Management

In this section, the data controller regulates the processing of the contact data of natural persons (data subjects) acting on behalf of their business partners and other clients.

1. Fact of data collection, scope of data processed and purpose of data management:

Personal dataPurpose of data managementLegal basis
Name, e-mail address, telephone number, other contact details in the contract.Contact, cooperation, conclusion of a contract, fulfillment of rights and obligations arising from a contract.In the case of legal persons:. Article 6 (1) (f) (legitimate interest of the controller), in the case of self – employed persons. Article 1 (1) (b).

2. Source of data:

  • In the case of a legal entity: the personal data of the data subject are provided by the business partner of the data controller.
  • In the case of sole proprietors and individuals directly from the data subject.

3. Stakeholders: All stakeholders in a contractual relationship with the controller and natural persons acting on behalf of the controller’s business partners.

4. Duration of data management, deadline for deletion of data: Data management until the termination of the legal relationship between the data controller and the business partner or, in the case of claims, until the statute of limitations.

5. The identity of the potential data controllers entitled to access the data, the recipients of the personal data : Personal data may be processed by authorized employees of the data controller, in compliance with the above principles.

6. Description of the data subjects’ rights in relation to data processing :

  • The data subject may request from the controller access to, rectification, erasure or restriction of the processing of personal data concerning him or her, and
  • the data subject has a right to data portability,
  • Natural persons acting on behalf of legal persons may object to the processing.

7. For personal information access , their deletion, modification or restriction of their handling, the portability of the data can be initiated by the data subject in the following ways :

  • by post to the address 6326 Harta, Rákóczi 11 / A,
  • by e-mail to info@kekkorkep.hu,
  • by phone at +36302825885.

8. Legal basis for data management :

  • In the case of natural persons acting on behalf of legal persons, Article 6 of the GDPR Article 1 (1) (f). Name of legitimate interest: cooperation, performance of contract, business purpose.
  • For sole proprietors and natural persons: Article 6 of the GDPR. Article 1 (1) (b).
  • In the case of enforcement of claims arising from the contract, the Civil Code of 2013. Act V of 2006 6:21. § 5 years.

6:22. § [Elévülés]

(1) Unless otherwise provided by this Act, claims shall lapse within five years.

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

(3) An agreement to change the limitation period shall be in writing.

4. An agreement precluding limitation shall be null and void.

9. Please be informed that

  • data management a contract or in the legitimate interest of the controller based on.
  • the contact details are provided by the data controller’s business partner,
  • failure to provide data
    • In the case of legal persons, those a consequences the performance of the contract, the exercise of the rights and obligations arising from the contract and the cooperation between the contracting parties may be hampered.
    • in the case of natural persons, by a consequences that we cannot enter into a contractual relationship.
  • the controller has performed a balancing test on the processing of personal data of natural persons acting on behalf of legal persons, as a result of which it is established that the data subject’s interests or fundamental rights and freedoms that would require personal data protection do not take precedence.

Contact

  1. The fact of data collection, the scope of the data processed and the purpose of data management :
Personal dataPurpose of data managementLegal basis
NameIdentificationArticle 6 (1) (a), and point b)
E-mail addressStay in touch, send reply messagesArticle 6 (1) (a), and point b)
Phone numberKeeping in touchArticle 6 (1) (a), and point b)
Message contentRequired to respondArticle 6 (1) (a), and point b)
Date of contactPerform a technical operation.Article 6 (1) (a), and point b)
The IP address at the time of contactPerform a technical operation.Article 6 (1) (a), and point b)

The email address does not need to contain any personal information.

2. Stakeholders : All those who send a message through the contact form.

3. Duration of data management, deadline for deleting data : If GDPR 17. If one of the conditions set out in Article 1 (1) is met, it shall last until the data subject requests the cancellation.

4. The identity of the potential data controllers entitled to access the data, the recipients of the personal data : Personal data may be processed by authorized employees of the data controller.

5. Description of the data subjects’ rights in relation to data processing :

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

6. Access to personal information , their deletion, modification or restriction of their handling, the portability of the data can be initiated by the data subject in the following ways :

  • by post to the address 6326 Harta, Rákóczi 11 / A,
  • by e-mail to info@kekkorkep.hu,
  • by phone at +36302825885.

7. Legal basis for data management : consent of the data subject,. Article 1 (1) (a) and point b). If you contact us, you consent to the processing of your personal data (name, telephone number, e-mail address) provided to us during the contact in accordance with these policies.

8. Please be informed that

  • this data management with your consent based on or required to make an offer .
  • obliged provide personal information so you can contact us.
  • failure to provide data with a consequences that you cannot contact the data controller.
  • the withdrawal of consent shall not affect the lawfulness of the consent-based data processing prior to the withdrawal.

Newsletter, DM activity

1. évi XLVIII. Act 6. Pursuant to §, the User may consent in advance and expressly to contact the Service Provider with his advertising offers and other items at the contact details provided during registration.

2. In addition, the Customer may, keeping in mind the provisions of this prospectus, consent to the Service Provider handling the personal data necessary for sending advertising offers.

3. 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.

4. The fact of data collection, the scope of the data processed and the purpose of data management :

Personal dataPurpose of data managementLegal basis
Name, e-mail address.Identification, allowing you to subscribe to the newsletter / promotional coupons.Consent of the data subject,. Article 1 (1) (a) of Regulation (EC) No. évi XLVIII. Act 6. § (5).
Date of subscriptionPerform a technical operation.
The IP address at the time of subscriptionPerform a technical operation.

5. The stakeholders : All subscribers to the newsletter.

6. Data management its goal : sending electronic messages containing advertising (e-mail, sms, push message) to the data subject, providing information on current information, products, promotions, new features, etc.

7. Data management duration , deadline for deleting data: the data processing lasts until the withdrawal of the consent statement, ie until the unsubscription.

8. The identity of the potential data controllers entitled to access the data, the recipients of the personal data : Personal data may be processed by the data controller and its sales and marketing staff, in accordance with the above principles.

9. THE z a description of the data subjects’ rights in relation to data processing :

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

10. Access to personal information , the deletion, modification or restriction of their processing, the portability of the data or the protest can be initiated by the data subject in the following ways :

  • by post to the address 6326 Harta, Rákóczi 11 / A,
  • by e-mail to info@kekkorkep.hu,
  • by phone at +36302825885.

11. The data subject may at any time you can unsubscribe for free about the newsletter.

12. Please be informed that

  • data management with your consent and in the legitimate interest of the service provider based on.
  • obliged provide personal information if you would like to receive a newsletter from us.
  • failure to provide data with a consequence we are unable to send you a newsletter.
  • we inform you that you can withdraw your consent at any time by clicking on unsubscribe.
  • withdrawal of consent does not affect the lawfulness of consent-based data processing prior to withdrawal.

The data processors used

Hosting provider

1. Activity performed by data processor: Hosting service

2. Name and contact details of the data processor:

Google

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

4. Stakeholders: All stakeholders using the website / mobile application.

5. The purpose of data management: To make the website / mobile application available and to operate it properly.

6. Duration of data processing, deadline for deletion of data: The data processing lasts until the termination of the agreement between the data controller and the hosting provider or the data subject’s request for deletion to the hosting provider.

7. Legal basis for data processing: Article 6 Article 1 (1) (c) and (f) of Regulation (EC) No 1/2003 and Regulation (EC) No. évi CVIII. Act 13 / A. § (3). There is a legitimate interest in the proper operation of the website, protection against attacks and fraud.

Other data processors (if any)

MailChimp
The Rocket Science Group, LLC
675 Ponce de Leon Ave NE
Suite 5000
Atlanta, GA 30308 USA
privacy@mailchimp.com

Számlázz.hu
Company: KBOSS.hu Kft.
Website: https // www.szamlazz.hu
Email: info@szamlazz.hu
Phone: 06 30 35 44 789

Management of cookies

1. The so-called “password used for the password-protected session”, “cookies for the shopping cart”, “security cookies”, “Required cookies”, “Functional cookies” and “cookies responsible for managing website statistics” k ”does not require prior consent from those 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: Identify users and track visitors.

5. Duration of data processing, deadline for deleting data:

Cookie typeLegal basis for data managementData handling duration
Session cookie 2001 on certain aspects of electronic commerce services and information society services. CVIII. Act (Elkertv.) 13 / A. § (3)The period until the end of the relevant visitor session
Permanent or saved cookies 2001 on certain aspects of electronic commerce services and information society services. CVIII. Act (Elkertv.) 13 / A. § (3)until the deletion of the data subject
Statistical, marketing cookies2001 on certain aspects of electronic commerce services and information society services. CVIII. Act (Elkertv.) 13 / A. § (3)1 month – 2 years

6. Identity of potential data controllers entitled to access the data: The data controller does not process personal data using cookies.

7. 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 the browser, usually under the settings of the Privacy menu item.

8. 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 over an electronic communications network or the provision of an information society service specifically requested by the subscriber or user.

9. Most browsers used by our users allow you to set which cookies to save and allow (specified) cookies to be deleted again. If you restrict the storage of cookies on certain websites or do not allow third-party cookies, this may in certain circumstances result in our website no longer being used in its entirety. Here’s how to customize cookie settings for standard browsers:

Google Chrome ( https://support.google.com/chrome/answer/95647?hl=en_US )

Internet Explorer ( https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies )

Firefox ( https://support.mozilla.org/hu/kb/sutik-engedelyezese-es-tiltasa-amit-weboldak-haszn )

Safari ( https://support.apple.com/hu-hu/guide/safari/sfri11471/mac )

Use Google Ads Conversion Tracking

  1. An online advertising program called “Google Ads” is used by the data controller and uses Google’s conversion tracking service. Google Conversion Tracking is an analytics service provided by Google Inc. (1600 Amphitheater Parkway, Mountain View, CA 94043, USA; “Google”).
  2. When a User accesses a website 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.
  3. 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 has clicked on the advertisement.
  4. Each Google Ads customer receives a different cookie, so they cannot be tracked through Ads customers’ websites.
  5. The information obtained through conversion tracking cookies is used to generate conversion statistics for Ads opt-in customers. This is how customers find out the number of users who clicked on your 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.
  6. If you do not wish to participate in conversion tracking, you can disable it by disabling the ability to set cookies in your browser. You will then not be included in your conversion tracking statistics.
  7. More information and Google’s privacy statement can be found at: www.google.de/policies/privacy/

Apply 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.
  2. The information created by the cookie about the website used by the User is usually stored and stored on a Google server in the USA. By activating IP anonymization on the Website, Google will shorten the User’s IP address within the Member States of the European Union or in other States party to the Agreement on the European Economic Area.
  3. The full IP address will be transmitted to and truncated to Google’s server in the U.S. 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.
  4. 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 the appropriate browser, 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=en_US

Google Tag Manager

Google Tag Manager is a service provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”), which allows you to create, update and manage tags (tags). Tags are small pieces of code on our website that are used, among other things, to measure traffic and visitor behavior, and to determine the impact of online advertising and social channels. When you visit our website, the current tag configuration will be sent to your browser. This will give you instructions on which tags to activate. The device itself does not collect any personal data, but ensures the activation of other tags, which in turn may collect data. For more information on how Google Tag Manager works, visit: https://support.google.com/tagmanager/answer/6102821?hl=en_US and in the terms of use you can find: https://www.google.de/tagmanager/use-policy.html

Facebook pixel

A Facebook pixel is a code that is used to report conversions on a website, compile target audiences, and give the page owner detailed analytics data about visitors ’use of the website. With the help of the Facebook remarketing pixel tracking code, you can display personalized offers and advertisements on the Facebook interface to the visitors of the website. The Facebook remarketing list is not personally identifiable. You can find more information about Facebook Pixel / Facebook Pixel here: https://www.facebook.com/business/help/651294705016616

Facebook remarketing

The fact of data collection, the scope of the data processed and the purpose of data management :

Personal dataPurpose of data managementLegal basis
E-mail addressRemarketing, displaying targeted ads by Facebook.Consent of the data subject,. Article 1 (1) (a) of Regulation (EC) No. évi XLVIII. Act 6. § (5).

5. The stakeholders : Everyone involved in contributing to Facebook remarketing, targeted ads.

6. Data management its goal : Targeted ad content to the affected audience.

7. Data management duration , deadline for deleting data: Data processing lasts until the consent is withdrawn.

8. The identity of the potential data controllers entitled to access the data, the recipients of the personal data : Personal data may be processed by the data controller and its sales and marketing staff, in accordance with the above principles.

9. THE z a description of the data subjects’ rights in relation to data processing :

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

10. Access to personal information , the deletion, modification or restriction of their processing, the portability of the data or the protest can be initiated by the data subject in the following ways :

  • by post to the address 6326 Harta, Rákóczi 11 / A,
  • by e-mail to info@kekkorkep.hu,
  • by phone at +36302825885.

11. Please be informed that

  • withdrawal of consent does not affect the lawfulness of consent-based data processing prior to withdrawal.

Recipient Name: Facebook Inc., Address: 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Phone: +1 650-543-4800

Using Barion Pixel

Cookie nameCookie description and purposeService providerHow long is it stored on your device?
ba_vidIts purpose in the Barion Smart Gateway service is to detect credit card fraud based on the digital fingerprint of the device you are using and your browsing habits. The use of cookies is necessary to detect fraudsters. A cookie ensures that we know that data from your browsing habits comes from a user.Barion Payment Zrt.1.5 years since last update.
ba_vid.xxxThe purpose of the Barion Smart Gateway service is to detect credit card fraud based on the digital fingerprint of the device you are using and your browsing habits. A cookie ensures that we can track your browsing habits between two sessions on that website. This information is collected by: ba_vid, a user-related ID, which is a hash compiled from the browser properties, based on the timestamp of your first, current and last visit to the website, the current session ID, permission for third-party cookies.Barion Payment Zrt.1.5 years since last update.
ba_sidIts purpose in the Barion Smart Gateway service is to detect credit card fraud based on the digital fingerprint of the device you are using and your browsing habits. The cookie ensures that we can identify your session across websites.Barion Payment Zrt.30 minutes
ba_sid.xxxIts purpose in the Barion Smart Gateway service is to detect credit card fraud based on the digital fingerprint of the device you are using and your browsing habits. The cookie ensures that we can identify your browser’s session within that website.Barion Payment Zrt.30 minutes

If the cookie lifetime is defined since the last update, it means that each visit extends the expiration date of the cookie by 1.5 years from the last visit. The collection of data resulting from the extension does not require consent. Data management is provided by Barion Payment Zrt. legitimate interest in fraud prevention. More information here .
Other technologies: Browser digital reprint: Aimed at filtering out fraudulent sessions based on visitor behavior and their browser reprint. It helps us to identify browsers on each device. We also use this on this website and on the websites of other retailers who use the Barion Smart Gateway. For more details, see Privacy Policy Can be found in section 5.4.

Marketing cookies:

Cookie nameCookie description and purposeService providerHow long is it stored on your device?
BarionMarketingConsent.xxxIts purpose is to store a statement as to whether you have consented to the collection of data from your browsing habits and the examination of your shopping habits in order to display personalized ads and offers. If you have consented, we will also use the following data collected by the credit card fraud prevention cookies placed among the cookies necessary for the operation and your browsing habits in order to examine your shopping habits in order to display personalized advertisements and offers.Barion Payment Zrt.1.5 years since last update
Media and advertiser partners’ cookieIts purpose is to synchronize and pair the different user IDs of the Barion system and the given partner’s system. The above cookies, as part of their operation, signal to the partners ’server to download their own user ID cookie into the browser of the website visitor. Thus, the IDs generated simultaneously in one browser on the two systems will be paired.See data management informationYou can find detailed information about cookies in the cookie information of each partner. A list of partners who use cookies for this purpose, together with a link to their cookie information here you will find.

The placement of a marketing cookie requires the consent of the visitor. Without consent, the cookie cannot be stored in the browser. Modification or withdrawal of consent can be done at any time on the website. Barion Payment Zrt. uses the cookie to collect data about visits; information about what they click on which product / service the visitor is interested in or abandoned orders. They collect data to build models of visitor behavior and to generate personalized offers and digital ads. The goal is to show relevant ads to visitors about products they are genuinely interested in. These cookies ensure that we avoid irrelevant advertisements and recommendations and that they are only truly relevant content to which the visitor is affiniscent. Barion Payment Zrt. it manages the information itself or passes it on to contracted media and advertising partners. [1] . For this purpose, the IDs of these partners are also stored next to the Barion cookies. The consent also allows these cookies to be stored. For more details, see in the data management information you can read about the use of data.

Data processing partners

DataMe Kft. Applies to the Barion Marketing Cloud and the Barion Pixel. 1118 Budapest, Ugron Gábor utca 35.
Customer service telephony is provided by Minerva-Soft Development and Provider LLC. Address: 3900 Szerencs, Lipták út 1 / a.
Telephone complaint services for user complaints are provided by Interswitch LLC. Address: 1056 Budapest, Irányi utca 15.
The infrastructure for online user identification services required by money laundering laws is provided by TechTeamer LLC. Address: 1095 Budapest, Lechner Ödön Avenue 3. 2. 1., B.
Traffic statistics for our website and mobile application are provided by MIXPANEL Inc. Address: 405 Howard Street San Francisco, CA 94105
We are associated with In-Voice Control LLC for our accounting duties. Address: 1046 Budapest, Leiningen Károly utca 16 / B
Our mobile parking e-invoicing partner is KBOSS.hu LLC. (also known as szamlazz.hu) Address: 1031 Budapest, Záhony utca 7.

Barion Pixel credit card fraud prevention

Location of data management (web address): pixel.barion.com

The purpose of data management: credit card fraud prevention

Legal basis for data management: legitimate interest of barion.com

Duration of data management: 50 months from the visit

Data types: IP address, operating system and browser type

Method of data collection: Automatically by visiting the site.

More information: https://www.barion.com/hu/adatvedelmi-tajekoztato/

Community sites

  1. The fact of data collection, the range of data managed: Facebook / Twitter / Pinterest / Youtube / Instagram, etc. registered name on social networking sites and the user’s public profile picture.
  2. Stakeholders: All stakeholders who have registered on Facebook / Twitter / Pinterest / Youtube / Instagram, etc. social sites and “liked” the Service Provider’s social site or contacted the data controller via the social site.
  3. The purpose of data collection: On social networking sites, to share or “like”, follow and promote certain content elements, products, promotions or the website itself.
  4. Duration of data processing, deadline for deletion of data, identity of potential data controllers entitled to access the data and description of data subjects’ rights related to data processing: The data subject can find out about the source of the data, its 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.
  5. Legal basis for data processing: the voluntary consent of the data subject to the processing of his or her personal data on social networking sites.

Customer relations and other data management

  1. Should the data controller have any questions or problems during the use of our data management services, he / she may contact the data controller in the ways provided on the website (telephone, e-mail, social networking sites, etc.).
  2. Data controller for incoming emails, messages, phone, Facebook, etc. will delete the data provided together with the name and e-mail address of the interested party and other personal data voluntarily provided, no later than 2 years after the communication.
  3. Information on data processing not listed in this prospectus will be provided at the time of data collection.
  4. Upon exceptional official request, or in case of requesting other bodies based on the authorization of legislation, the Service Provider is obliged to provide information, communicate and hand over data, and make documents available.
  5. In these cases, the Service Provider will provide the requester with personal data only to the extent and to the extent that is absolutely necessary to achieve the purpose of the request, provided that it 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 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.

2. Right to rectification

You have the right, at the request of the data controller, to correct inaccurate personal data concerning you 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.

3. Right of cancellation

You have the right, at the request of the data controller, to delete personal data concerning you without undue delay, and the data controller is obliged to delete personal data concerning you without undue delay under certain conditions.

4. The right to be forgotten

If the controller has disclosed personal data and is obliged to delete it, it shall take reasonable steps, including technical measures, taking into account the available technology and the cost 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.

5. 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 the personal data, in which case the restriction applies to the period of time that allows the data controller to verify the accuracy of the personal data;
  • the data processing is illegal 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 make, 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.

6. The right to data portability

You have the right to receive personal data about you provided by you to a data controller in a structured, widely used, machine-readable format, and you have the right to transfer this data to another data controller without being hindered by the data controller whose provided personal data to him (…)

7. Right to protest

In the case of data processing based on a legitimate interest or public authority as a legal basis, you have the right to object at any time to the processing of your personal data (…), including profiling based on the said provisions, for reasons related to your situation.

8. Protest in case of direct business 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, insofar as it relates 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.

9. 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;
  • EU or Member State law applicable to the controller, which also lays down appropriate measures to protect your rights and freedoms and legitimate interests; obsession
  • It is based on your express consent.

Deadline for action

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

If necessary, this It can be extended for 2 months . The extension of the time limit shall be notified to the controller from the date of receipt of the request, stating the reasons for the delay. Within 1 month informs you.

If the controller does not act on your request, inform you without delay, but no later than one month after receipt of the request, of the reasons for not taking action , and that you can lodge a complaint with a supervisory authority and exercise your right to a judicial remedy.

Security of data management

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. pseudonymisation and encryption of personal data;
  2. ensuring the continued confidentiality, integrity, availability and resilience of 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.
  5. The processed data must be stored in such a way that they cannot be accessed by unauthorized persons. In the case of paper-based data carriers, by establishing the order of physical storage and archiving, in the case of data processed in electronic form, by applying a central rights management system.
  6. The method of storing the data by IT must be chosen in such a way that their erasure can be carried out at the end of the erasure period or, if necessary for other reasons, taking into account the possible erasure period. Deletion must be irreversible.
  7. Paper-based media must be deprived of personal data by means of a shredder or by an external shredder. In the case of electronic media, the rules on the disposal of electronic media shall provide for physical destruction and, where necessary, for the secure and irreversible erasure of data in advance.
  8. The controller shall take the following specific data security measures:

In order to ensure the security of personal data processed on paper, the Service Provider applies the following measures ( physical protection ):

  1. Store documents in a safe, lockable, dry room.
  2. Where personal data processed on paper are digitized, the rules governing digitally stored documents shall apply.
  3. The employee of the Service Provider performing data management may only leave the room where data management is taking place by closing the data carriers entrusted to him or her or closing the given room.
  4. Personal data may only be disclosed to authorized persons and may not be accessed by third parties.
  5. The building and premises of the Service Provider are equipped with fire protection and property protection equipment.

IT protection

  1. The computers and mobile devices (other data carriers) used in the data management are the property of the Service Provider.
  2. The computer system containing the personal data used by the Service Provider is equipped with virus protection.
  3. In order to ensure the security of digitally stored data, the Service Provider uses data backups and archives.
  4. The central server machine can only be accessed with the appropriate authority and only by designated persons.
  5. Data on computers can only be accessed with a username and password.

Informing the data subject 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 data subject without undue delay.

In the information provided to the data subject clearly and intelligibly the nature of the data protection incident shall be described and the name and contact details of the data protection officer or other contact person providing further information shall be provided; the likely consequences of the data protection incident must be described; a description of 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 data subject need not be informed if any of the following conditions are met:

  • the data controller implemented appropriate technical and organizational security measures , and these measures have been applied to the data affected by the data protection incident, in particular those such as the application of encryption to persons who are not entitled to access personal data. make the data incomprehensible;
  • the controller has taken further action following the data protection incident which: ensure that the high risk to the data subject’s rights and freedoms is unlikely to materialize ;
  • the information would require a disproportionate effort . In such cases, data subjects shall be informed through publicly available information or a similar measure shall be taken to ensure that data subjects are informed in an equally effective manner.

If the data controller has not yet notified the data subject 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 data subject be informed.

Report a privacy incident to the authority

The data protection incident shall be reported by the controller without undue delay and, if possible, no later than 72 hours after becoming aware of the data protection incident in accordance with Article 55. unless the data protection incident is not likely to pose a risk to the rights and freedoms of natural persons. If the notification is not made within 72 hours, the reasons for the delay must be provided.

Review in case of mandatory data management

If the duration of the mandatory data processing or the periodic review of the need for it is not specified by law, a decree of a local government or a binding legal act of the European Union, it shall be reviewed by the controller at least every three years from the start of the data processing that the processing of personal data processed by him or by a data processor acting on his or her behalf or on his or her behalf for the purpose of data processing whether it is necessary .

The circumstances and results of this review shall be communicated to the controller shall keep this documentation for ten years after the review and make it available to the Authority at the request of the National Data Protection and Freedom of Information Authority (hereinafter: the Authority).

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

1055 Budapest, Falk Miksa utca 9-11.

Mailing address: 1363 Budapest, Pf. 9.

Phone: +36 -1-391-1400

Fax: + 36-1-391-1410

E-mail: ugyfelszolgalat@naih.hu

Closing remarks

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

  • 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 (General Data Protection Regulation) REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (GDPR) ( April 27, 2016);
  • 2011. évi CXII. Act on the Right to Information Self-Determination and Freedom of Information (hereinafter: the Information Act);
  • 2001. évi CVIII. Act – on certain issues of electronic commerce services and services related to the information society (mainly § 13 / A);
  • 2008. évi XLVII. Act on the Prohibition of Unfair Commercial Practices against Consumers;
  • 2008. évi XLVIII. Act on the Basic Conditions and Certain Restrictions of Commercial Advertising (especially Section 6a);
  • 2005. year XC. Electronic Freedom of Information Act;
  • 2003. Act C of 2006 on Electronic Communications (specifically § 155a);
  • 16/2011. s. opinion on the EASA / IAC 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.

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