Data Protection Policy

Introduction

Tóbelurna Kft. (registered office: 1026 Budapest, Szilágyi Erzsébet fasor 97. 1. tax number: (27836291-2-41 hereinafter referred to as: Service Provider, Data Controller) submits 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) (27 April 2016).

This Privacy Notice governs the processing of data on the following pages: https://tobelurna.hu

This privacy notice is available at: https://tobelurna.hu/adatvedelmi-nyilatkozat

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

The data controller and its contact details:

Name: Tóbelurna Ltd.

Registered office: 1026 Budapest, Szilágyi Erzsébet fasor 97. 1.

E-mail: info@tobelurna.hu

Phone: +36 70 230 0522

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;
2. „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;
3. „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;
4. „processor” means a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller;
5. „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 which 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;
6. „data subject’s consent” means a freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she 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;
7. „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. be carried out lawfully and fairly and in a transparent manner for the data subject („lawfulness, fairness and transparency”);
2. be collected only for specified, explicit and legitimate purposes and not processed in a way incompatible with those purposes; further processing for archiving purposes in the public interest, scientific and historical research purposes or statistical purposes shall not be considered incompatible with the original purposes in accordance with Article 89(1) (‘purpose limitation’);
3. the processing must be adequate, relevant and limited to what is necessary for the purposes for which it is intended (‘data minimisation’);
4. 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 of the processing are erased or rectified without undue delay (‘accuracy’);
5. 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 personal data will be processed for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1), subject to the implementation of appropriate technical and organisational measures as provided for in this Regulation to safeguard the rights and freedoms of data subjects (‘limited storage’);
6. be processed 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.

Data management

Hosting provider

1. Activity provided by the data processor: Hosting
2. Name and contact details of the data processor.
   Location: 1122 Gaál József út 24
   Phone: +36 1 700 41401 422-1836
   Postal address: 1122 Gaál József út 24
   E-mail: info@tarhelypark.hu

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

1. Fact of processing, scope of data processed: all personal data provided by the data subject.
2. Data subjects: all data subjects using the website.
3. Purpose of data processing: to make the website available and to ensure its proper operation.
4. Duration of data processing, time limit for deletion of data: until the termination of the agreement between the data controller and the hosting provider or until the data subject’s request for deletion to the hosting provider.
5. The legal basis for data processing: the User’s consent, the Infotv. Article 5(1), Article 6(1)(a), and Article 13/A(3) of Act CVIII of 2001 on Certain Aspects of Electronic Commerce Services and Information Society Services.

Cookie management (cookies)

1. Website-specific cookies
2. Fact of processing, scope of data processed: unique identifier, dates, times
3. Data subjects: all data subjects visiting the website.
4. Purpose of the processing: identification of users and tracking of visitors.
5. Duration of processing, time limit for deletion of data:

The duration of data processing for Addthis cookies is 2 years.

1. Identity of the potential data controllers who may access the data: no personal data is processed by the data controller through the use of cookies.
2. Data subjects’ rights regarding data processing.
3. Legal basis for processing: consent is not required from the data subject where the sole purpose of the use of cookies is to provide a communication over an electronic communications network or where it is strictly necessary for the service provider to provide an information society service explicitly requested by the subscriber or user.

Use Google Adwords conversion tracking

1. The data controller uses the online advertising program „Google AdWords” and makes use of Google’s conversion tracking service within its framework. Google Conversion Tracking is an analytics service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; „Google”).
2. When you access a website through a Google ad, a cookie for conversion tracking is placed on your 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 expired, Google and the data controller can see that the User has clicked on the ad.
4. Each Google AdWords client receives a different cookie, so they cannot be tracked through AdWords clients’ websites.
5. The information obtained through conversion tracking cookies is used to generate conversion statistics for AdWords customers who opt for conversion tracking. Clients are then informed of the number of users who click on their ad and are referred to a page with a conversion tracking tag. However, they do not have access to information that would allow them to identify any user.
6. If you do not wish to participate in conversion tracking, you can opt out by disabling the option to set cookies in your browser. You will then not be included in the conversion tracking statistics.
7. For more information and to read Google’s privacy statement, please visit www.google.de/policies/privacy/

Using Google Analytics

1. This website uses Google Analytics, a web analytics service provided by Google Inc. („Google”). Google Analytics uses „cookies”, which are text files placed on your computer, to help the website analyze how users use the site you have visited.
2. The information generated by the cookie about the website you use is usually transmitted to and stored by Google on servers in the United States. By activating the IP anonymisation on the website, Google will previously 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. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity for the website operator and to provide other services relating to website activity and internet usage.
4. Google Analytics will not associate the IP address transmitted by the User’s browser with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You may also prevent Google from collecting and processing information about your use of this website (including your IP address) by means of cookies by downloading and installing the browser plug-in available at https://tools.google.com/dlpage/gaoptout?hl=hu

Newsletter, DM activity

1. Pursuant to Article 6 of Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Economic Advertising Activity, 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 at the time of registration.
2. In addition, the Customer may, subject to the provisions of this information, consent to the processing of personal data by the Service Provider necessary for sending advertising offers.
3. The Service Provider shall not send unsolicited commercial communications and the User may unsubscribe from receiving such communications free of charge, without any restriction and without giving any reason. 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. The User may unsubscribe from advertising by clicking on the link in the message.
4. The fact of data collection, the scope of data processed and the purpose of data processing:

1. Data subjects: all data subjects who subscribe to the newsletter.
2. Purpose of processing: sending electronic messages (e-mail, SMS, push messages) containing advertising to the data subject, providing information on current information, products, promotions, new features, etc.
3. Duration of data processing, deadline for deletion of data: until the consent is withdrawn, i.e. until the unsubscription.
4. The data may be processed by the sales and marketing staff of the controller, in compliance with the above principles.
5. 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.

The data subject may request access to, erasure, modification or restriction of processing of personal data, data portability and objection to processing in the following ways:

• by post to 1026 Budapest, Szilágyi Erzsébet fasor 97. 1,
• by e-mail to info@tobelurna.hu,
• by telephone at +36 70 230 0522.

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

Legal basis for processing: the data subject’s consent, Article 6 (1) (a), in accordance with the Infotv. Article 5(1), and Article 6(5) of Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Economic Advertising Activities:

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

Please note that

• the processing is based on your consent.
• You are required to provide personal data if you wish to receive newsletters from us.
• failure to provide this information will result in our inability to send you a newsletter.

Community sites

The fact of data collection, the scope of data processed: the name registered on Facebook/Google+/Twitter/Pinterest/Youtube/Instagram, etc. social networking sites, and the user’s public profile picture.

Data subjects: all data subjects who have registered on Facebook/Google+/Twitter/Pinterest/Youtube/Instagram etc. and have „liked” the website.

Purpose of the data collection: to share or „like” the website, to promote certain content, products, promotions or the website itself on social networking sites.

The duration of the processing, the time limit for the deletion of the data, the identity of the possible controllers of the data and the rights of the data subjects in relation to the processing of the data. The data are processed on the 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.

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

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.).

The Data Controller will delete the data provided in e-mails, 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, after a maximum of 2 years from the date of the communication.

Any processing not listed in this notice will be notified at the time the data is collected.

In exceptional cases, the Service Provider is obliged to provide information, data or documents in response to a request from a public authority or other bodies authorised by law.

In these cases, the Service Provider shall only disclose personal data to the requesting party – provided that the latter has indicated the precise purpose and scope of the data – to the extent and to the extent that is indispensable for the purpose of the request.

Rights of data subjects

Right of access

You have the right to receive feedback from the controller on whether your personal data are being processed and, if such processing is ongoing, the right to access your personal data and the information listed in the Regulation.

Right to rectification

You have the right to obtain, at your request and without undue delay, the rectification by the controller of inaccurate personal data relating to you. Taking into account the purposes of the processing, you have the right to request the completion of incomplete personal data, including by means of a supplementary declaration.

Right to erasure

You have the right to obtain from the controller the erasure of personal data relating to you without undue delay at your request and the controller is obliged to erase personal data relating to you without undue delay under certain conditions.

Right to be forgotten

If the controller has disclosed the personal data and is under an obligation to erase it, the controller 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 erasure of the links to or copies of the personal data in question.

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 oppose the erasure 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 a period of time until it is established whether the controller’s legitimate grounds override your legitimate grounds.

The right to data portability

You have the right to receive the personal data concerning you which 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 (…)

The right to object

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

Objection in case of direct marketing

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 may no longer be processed for those purposes.

Automated decision-making in individual cases, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects 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;
• it 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
• is based on your explicit consent.

Deadline for action

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

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

If the controller does not take action on your request, it shall inform you without delay and at the latest within one month of receipt of the request of the reasons for the non-action and of the possibility to lodge a complaint with a supervisory authority and exercise your right to judicial remedy.

Security of data processing

The controller and the processor shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the scale of the risk, 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, including, where appropriate:

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

Informing the data subject about the personal data breach

If 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 given to the data subject shall clearly and prominently 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 those measures have been applied in relation 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;
• the provision of information would require a disproportionate effort. In such cases, the data subjects shall be informed by means of publicly disclosed information or by means of a similar measure which ensures that the data subjects are informed in an equally effective manner.

Where 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 a personal data breach to the supervisory authority competent pursuant to Article 55 without undue delay and, where possible, no later than 72 hours after the personal data breach has come to its attention, 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 shall be accompanied by the reasons justifying the delay.

Complaint possibility

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

National Authority for Data Protection and Freedom of Information

If you wish to inform the Data Protection Authority about any violation of the Privacy and Information Protection Act, please contact the Data Protection Authority at 22/C Szilágyi Erzsébet fasor, 1125 Budapest, Szilágyi Erzsébet fasor.

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

Phone: +36 -1-391-1400

Fax: +36-1-391-1410

E-mail: ugyfelszolgalat@naih.hu

Closing address

The following legislation has been taken into account in the preparation of this information:

• REGULATION (EU) No 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Regulation (EC) No 95/46/EC (General Data Protection Regulation)
• Act CXII of 2011 – on the Right to Informational Self-Determination and Freedom of Information (hereinafter referred to as the „Infotv.”)
• Act CVIII of 2001 – on certain aspects of electronic commerce services and information society services (in particular Article 13/A)
• Act XLVII of 2008 – on the prohibition of unfair commercial practices against consumers;
• Act XLVIII of 2008 – on the basic conditions and certain restrictions on commercial advertising (in particular § 6)
• Act XC of 2005 on Freedom of Electronic Information
• Act C of 2003 on Electronic Communications (specifically § 155)
• Opinion No 16/2011 on the EASA/IAB Recommendation on best practice on behavioural online advertising
• Recommendation of the National Authority for Data Protection and Freedom of Information on data protection requirements for prior information
• Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of 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