Tento sa naozaj vráti

Privacy Policy

  1. Purpose of the Privacy Policy.. 3
  2. Data of the controller.. 4
  3. Data processing.. 5

3.1.Data processing concerning contacting and communication.. 5

3.1.1. Processed personal data and purpose of processing. 5

3.1.2. Legal basis of processing. 5

3.1.3. Duration of the processing. 6

3.1.4. Mode of processing. 6

3.1.5. Data protection contractual clause. 6

3.2. Processing concerning ordering.. 7

3.2.1. Processed personal data and purpose of processing. 7

3.2.2. Legal basis of processing. 7

3.2.3. Duration of the processing. 8

3.2.4. Mode of processing. 8

3.2.5. Provision of processing. 8

3.3. Processing concerning invoicing.. 9

3.3.1. Processed personal data and purpose of processing. 9

3.3.2. Legal basis of processing. 9

3.3.3. Duration of the processing. 9

3.3.4. Mode of processing. 10

3.4. Processing concerning complaint handling.. 11

3.4.1. Processed personal data and purpose of processing. 11

3.4.2. Legal basis of processing. 11

3.4.3. Duration of processing. 11

3.4.4. Mode of processing. 11

3.5. Processing related to the handling of warranty claims. 12

3.5.1. Processed personal data and purpose of processing. 12

3.5.2. Legal basis of processing. 12

3.5.3. Duration of processing. 12

3.5.4. Mode of processing. 12

3.6. Processing related to prize draw lot.. 13

3.6.1. Processed personal data and purpose of processing. 13

3.6.2. Legal basis of processing. 13

3.6.3. Duration of processing. 13

Until the goal is achieved; until the complete closing of that sweepstakes. 13

3.6.4. Mode of processing. 13

  1. What are your rights?. 14

4.1. Right to access. 14

4.2. Right to rectification. 14

4.3. Right to erasure. 14

4.4. Right to be forgotten. 15

4.5. Right to restriction of processing. 15

4.6. Right to data portability. 15

4.7. Right to object. 16

4.8. Right to lodge complaint. 16

  1. Measures and notification.. 17

5.1. Informing Data subjects. 17

5.2. Mode and deadline of notification. 17

5.3. Monitoring. 17

5.4. Costs of measures and notifications. 17

  1. Possible recipients. 18

6.1. During the operation of our website. 18

6.2. Delivery of the ordered products. 18

6.3. Payment of the order fee. 18

6.4. Social media. 18

6.5. Invoicing. 18

  1. Data security.. 19
  2. Cookies. 20

8.1. Cookies in general. 20

8.2. Google Analytics. 20

8.3. Facebook Pixel. 20

8.4. How to manage cookies?. 21

  1. Other provisions. 22

9.1. Processing for different purpose. 22

9.2. Data protection. 22

9.3. Record of processing. 22

9.4. Data breaches. 22

9.5. Changes to our Privacy Policy. 22

Appendix – Definitions. 23

 

 

 

1. Purpose of the Privacy Policy

 

The goal of our Privacy Policy is to provide all necessary information about processing your personal data in a concise, transparent, intelligible and easily accessible form, using clear and plain language, and assist the Data subjects in exercising their rights under Section 4.

The legal basis of our duty to communicate information is Article 12 of Regulation 2016/679 of the European Parliament and Council (hereinafter referred to as: GDPR) and the relevant Hungarian data protection regulations.

In the Privacy Policy, we may define you as “data subject”, or “contact person of our business partners” in the following.

You may find further definitions concerning your personal data within the Appendix of the current Privacy Policy.

Our services are available at www.flatloop.com and related websites.

2. Data of the controller

 

NameMultinvent Kft.
Registry number13-09-168291
Registered seat2014 Csobánka, Cinke utca 10.
E-mailloopboomerangs@gmail.com
Telephone number+36209806314
Tax number24832827-2-13

 

 

 

 

3. Data processing

3.1. Data processing concerning contacting and communication

It is possible to connect us through our availabilities located on the website. Also, by communicating with our business partners, we process the personal data of their contact person. The details of these processing are described hereunder.

3.1.1. Processed personal data and purpose of processing

 

personal datapurpose of processingLawfulness of processing
nameidentification of the Data subject, or the contact person of our business partnerthe data subject has given consent to the processing of his or her personal data for one or more specific purposes [article 6 (1) a) of GDPR]; in the case of contact person of our business partner processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party [article 6 (1) f) of GDPR]
phone numbercontacting and communication with the Data subject, or the contact person of our business partnerthe data subject has given consent to the processing of his or her personal data for one or more specific purposes [article 6 (1) a) of GDPR]; in the case of contact person of our business partner processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party [article 6 (1) f) of GDPR]
e-mail addresscontacting and communication with the Data subject, or the contact person of our business partnerthe data subject has given consent to the processing of his or her personal data for one or more specific purposes [article 6 (1) a) of GDPR]; in the case of contact person of our business partner processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party [article 6 (1) f) of GDPR]

 

3.1.2. Legal basis of processing

 

If you contact us through our website, we process your personal data on your freely given consent that you provide in the moment of your connection by phone or email (article 6 (1) a) of GDPR).

If you, as the representative of our business partners provide your personal data to communicate with us, the legal basis of processing personal data is the legitimate interest of us and our business partners (section 6 paragraph 1 point f of GDPR). It is each Party’s legitimate interest to maintain an effective business communication and to perform the contract. Since it is the part of your scope of duty (representation of our business partners), in our view, processing your name and contact data doesn’t restrict disproportionately your privacy and freedom of self-determination.

 

3.1.3. Duration of the processing

 

If you contact us through our website, we process your personal data until the withdrawal of your consent. You have the right to withdraw your consent at any time via email. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

 

In relation to the processing of the personal data of our business partners’ contact persons, we process their personal data until the personal data are no longer necessary in relation to the purposes for which they were collected or as long as it is possible according to the relevant acts (pursuant to the Hungarian Civil Code, 5 years following the performance or the termination of the contract, or 8 years following invoicing, in accordance with the Hungarian accounting act).

 

3.1.4. Mode of processing

 

Electronic form.

 

3.1.5. Data protection contractual clause

 

Taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for rights and freedoms of natural persons posed by the processing concerning communicating with our business partners, we, as data controllers, while performing the contracts concluded with our business partners, both at the time of the determination of the means for processing, and at the time of the processing itself, implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing in order to meet the requirements of GDPR.

 

 

 

3.2. Processing concerning ordering

You can order any of our products shown in our website. The details of such processing are described hereunder.

3.2.1. Processed personal data and purpose of processing

 

personal datapurpose of processingLawfulness of processing
name (first name, surname, title)identification of the purchaser or its representativeprocessing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract [article 6 (1) b) of GDPR]; if the customer is a legal person then processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party [article 6 (1) f) of GDPR]
addressidentification of the place of transportationprocessing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract [article 6 (1) b) of GDPR]
phone numberconnecting the purchaser or its representative and giving information about the servicesprocessing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract [article 6 (1) b) of GDPR]; if the customer is a legal person then processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party [article 6 (1) f) of GDPR]
e-mail addressconnecting the purchaser or its representative and giving information about the servicesprocessing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract [article 6 (1) b) of GDPR]; if the customer is a legal person then processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party [article 6 (1) f) of GDPR]
a unique coupon code that can be linked to the useridentification of the customer in order to take advantage of the individual discount we provideprocessing is necessary for the purposes of the legitimate interests pursued by the controller [article 6 (1) f) of GDPR]

 

3.2.2. Legal basis of processing

If the legal person purchaser’s representative provides his or her personal data for these purposes, the legal basis of processing personal data – with regard to the relevant authorial practice – is the legitimate interest of us and the purchaser company (section 6 paragraph 1 point f of GDPR). It is each party’s legitimate interest to maintain an effective business communication and to finalize the purchase. In our view – since it is the part of the representative’s scope of duty, and in case of the children’s and partner’s personal data, we need these pieces of information to make the gifts for the event – the processing of the mentioned personal data doesn’t restrict disproportionately the Data subject’s privacy and freedom of self-determination.

 

All the personal data you give us during the ordering of the available products are processed for the performance of the contract concluded between you and us (article 6 b) of GDPR).

 

3.2.3. Duration of the processing

 

Until the personal data are no longer necessary in relation to the purposes for which they were collected or as long as it is possible according to the relevant acts (8 years after accounting or 5 years following performance).

 

3.2.4. Mode of processing

 

Electronic form.

 

3.2.5. Provision of processing

Since we cannot perform the order without knowing any information about you, the processing is a requirement necessary to enter into a contract.

 

 

3.3. Processing concerning invoicing

 

After the performing of the orders we – with regard to Act C of 2000 on accounting – make out a bill. The details of such processing are described hereunder.

 

3.3.1. Processed personal data and purpose of processing

 

 

personal datapurpose of processingLawfulness of processing
nameconfirmation of the accountingprocessing is necessary for compliance with a legal obligation to which the controller is subject [article 6 (1) c) of GDPR] based on the Act No. CXII. of 2011. on the right to information self-determination and freedom of information 5. § (1) b), and the Act No. C. of 2000. on accounting 166. § (1)-(3)
addressconfirmation of the accountingprocessing is necessary for compliance with a legal obligation to which the controller is subject [article 6 (1) c) of GDPR] based on the Act No. CXII. of 2011. on the right to information self-determination and freedom of information 5. § (1) b), Act No. C. of 2000. on accounting 166. § (1)-(3)
individual entrepreneur tax numbersupport the accountingprocessing is necessary for compliance with a legal obligation to which the controller is subject [article 6 (1) c) of GDPR] based on the Act No. CXII. of 2011. on the right to information self-determination and freedom of information 5. § (1) b), Act No. C. of 2000. on accounting 166. § (1)-(3)

 

3.3.2. Legal basis of processing

 

Processing is necessary for compliance with a legal obligation; with regard to section 6 paragraph 1 point c of GDPR, section 5 article 1 point b of Information Act and section 166 paragraph 1 to 3 of Act C of 2000.

 

3.3.3. Duration of the processing

 

8 years after accounting based on the 169 paragraph 1of Act C of 2000 and 166 paragraph 6 of Act C of 2000.

3.3.4. Mode of processing

 

Electronic form.

 

The document issued in electronic form – in accordance with the provisions of the legislation on the rules of digital archiving – is preserved in such a way that the applied method ensures the immediate production and continuous readability of all data of the document, and excludes the possibility of subsequent modification.

 

 

3.4. Processing concerning complaint handling

 

In order to answer your questions or to inspect the circumstances you requested a complaint for, we operate customer service.

 

3.4.1. Processed personal data and purpose of processing

personal datapurpose of processingLawfulness of processing
nameidentification of the userprocessing is necessary for compliance with a legal obligation to which the controller is subject [article 6 (1) c) and (2) of GDPR] based on the Act No. CXII. of 2011. on the right to information self-determination and freedom of information 5. § (1) b), and the Act No. CLV. of 1997. on consumer protection
e-mail addressconnecting with the user and providing informationprocessing is necessary for compliance with a legal obligation to which the controller is subject [article 6 (1) c) and (2) of GDPR] based on the Act No. CXII. of 2011. on the right to information self-determination and freedom of information 5. § (1) b), and the Act No. CLV. of 1997. on consumer protection
phone numberconnecting with the user and providing informationprocessing is necessary for compliance with a legal obligation to which the controller is subject [article 6 (1) c) and (2) of GDPR] based on the Act No. CXII. of 2011. on the right to information self-determination and freedom of information 5. § (1) b), and the Act No. CLV. of 1997. on consumer protection

 

3.4.2. Legal basis of processing

We process the personal data we collect from you by legal obligations (article 6 point (1) c) of GDPR) based on the Act No. CXII. of 2011. on the right to information self-determination and freedom of information 5. § (1) b), and the Act No. CLV. of 1997. on consumer protection

3.4.3. Duration of processing

5 years after the upon receipt of a complaint based on paragraph 17/A § 7 of the Act No. CLV. of 1997. on consumer protection

3.4.4. Mode of processing

Electronic form.

 

 

3.5. Processing related to the handling of warranty claims

If the costumer enforces supplies warranty and product warranty claim according to the Hungarian Civil Code, then we are required to write a report according to 19/2014 (IV.29) NGM regulation

3.5.1. Processed personal data and purpose of processing

personal datapurpose of processingLawfulness of processing
nameidentification of the user and write the reportprocessing is necessary for compliance with a legal obligation to which the controller is subject [article 6 (1) c) and (2) of GDPR] based on the Act No. CXII. of 2011. on the right to information self-determination and freedom of information 5. § (1) b), and 19/2014 (IV.29) NGM regulation 4. § (1)
addressidentification of the user and write the reportprocessing is necessary for compliance with a legal obligation to which the controller is subject [article 6 (1) c) and (2) of GDPR] based on the Act No. CXII. of 2011. on the right to information self-determination and freedom of information 5. § (1) b), and 19/2014 (IV.29) NGM regulation 4. § (1)
information to consent to processwrite the reportprocessing is necessary for compliance with a legal obligation to which the controller is subject [article 6 (1) c) and (2) of GDPR] based on the Act No. CXII. of 2011. on the right to information self-determination and freedom of information 5. § (1) b), and 19/2014 (IV.29) NGM regulation 4. § (1)

 

3.5.2. Legal basis of processing

We process the personal data we collect from you by legal obligations (article 6 point (1) c) and (2) of GDPR) based on the Act No. CXII. of 2011. on the right to information self-determination and freedom of information 5. § (1) b), and 19/2014 (IV.29) NGM regulation 4. § (1).

3.5.3. Duration of processing

3 years after the completion of the report based on the paragraph 4 (1) and (6)

3.5.4. Mode of processing

Electronic form.

 

 

 

 

 

3.6. Processing related to prize draw lot

 

We advertise games on our Facebook page and on the website. We draw prizes among the Users who comment on the given entry or perform a specific activity.

 

3.6.1. Processed personal data and purpose of processing

personal datapurpose of processingLawfulness of processing
nameidentification of the winner user.the data subject has given consent to the processing of his or her personal data for one or more specific purposes [article 6 (1) a) of GDPR]
e-mail addressidentification of the winner user.the data subject has given consent to the processing of his or her personal data for one or more specific purposes [article 6 (1) a) of GDPR]
fact of winningidentification of the winner user.the data subject has given consent to the processing of his or her personal data for one or more specific purposes [article 6 (1) a) of GDPR]

 

3.6.2. Legal basis of processing

If you participate the prize draw you have given consent to the processing of his or her personal data for one or more specific purposes [article 6 (1) a) of GDPR]

3.6.3. Duration of processing

Until the goal is achieved; until the complete closing of that sweepstakes.

3.6.4. Mode of processing

Electronic form.

 

 

 

 

 

 

 

 

 

 

 

4. What are your rights?

 

4.1. Right to access

You have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the information featured in point 3.

You have the right to access to the following information concerning the processing of your personal data:

  • the purposes of the processing;

 

  • the categories of personal data concerned;

 

  • the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;

 

  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

 

  • the existence of the right to request from us rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing;

 

  • the right to lodge a complaint with a supervisory authority;

 

  • the existence of automated decision-making, including profiling, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

 

4.2. Right to rectification

You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

 

4.3. Right to erasure

You have the right to obtain from us the erasure of personal data concerning you without undue delay and we shall have the obligation to erase personal data without undue delay if it is mandatory according to Article 17 of GDPR. The erasure of your personal data is obligatory for us in the following instances:

 

  • the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

 

  • you withdraw consent on which the processing is based, and where there is no other legal ground for the processing;

 

  • you object to the processing and there are no overriding legitimate grounds for the processing;

 

  • the personal data have been unlawfully processed;

 

  • the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.

 

4.4. Right to be forgotten

If we made the personal data public and are obliged to erase your personal data, we inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

We do not make your personal data public.

 

4.5. Right to restriction of processing

You have the right to obtain from us restriction of processing if is obligatory according to Article 18 of GDPR. Such instances are the following:

 

  • the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;

 

  • the processing is unlawful and you oppose the erasure of the personal data and requests the restriction of their use instead;

 

  • we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims;

 

If you obtain restriction of processing in accordance with the above, we inform you before the restriction of processing is lifted.

 

4.6. Right to data portability

You have the right to receive the personal data concerning you, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us if is possible according to Article 20 of GDPR. Where technically feasible, you have the right to have the personal data transmitted directly from us to another controller.

 

4.7. Right to object

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (f) of Article 6(1) of GDPR (see: point 3.1. and 3.2. of the current policy). In such case, we no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

 

4.8. Right to lodge complaint

You have the right to appeal to the Hungarian courts and to make a complaint to the Hungarian (https://naih.hu/) Supervisory Authority.

 

 

 

5. Measures and notification

 

5.1. Informing Data subjects

We communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1) and Article 18 of GDPR to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. We also inform you about those recipients on the request of yours.

 

5.2. Mode and deadline of notification

We provide information on action taken on a request under Articles 15 to 22 of GDPR to you without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We inform you of any such extension within one month of receipt of the request, together with the reasons for the delay. Where you make the request by electronic form means, we provided the information by electronic means where possible, unless you request it otherwise.

If we do not take action on your request, we inform you without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy (see point 4.7.).

 

5.3. Monitoring

If we have reasonable doubts concerning the identity of the natural person making the request, we may request the provision of additional information necessary to confirm the identity of the data subject.

 

5.4. Costs of measures and notifications

We provide you information and take the necessary measures free of charge.

If your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested or we refuse to act on your request.

 

 

 

6. Possible recipients

 

6.1. During the operation of our website

 

Our website’s hosting provider (data processor) can have access to the personal data you provide while using the website. The data processor’s data are the following:

 

Name: GTT NETWORX Korlátolt Felelősségű Társaság

Registered seat: 2030 Érd, Bertalan utca 22.

Registry number: 13 09 145403

E-mail: admin@gttnetworx.hu

 

 

6.2. Delivery of the ordered products

In order to deliver the ordered products, we use fulfillment companies as data processors. These service providers enter into contracts with transport companies to deliver the products ordered by the user, so in this respect these additional service providers are considered sub-data processors. We ensure that sub-data processors also comply with legal requirements regarding the handling and protection of personal data in the course of their activities

6.3. Payment of the order fee

The order fee can be paid through the payment service provider’s data processing interface.

Name: PayPal (Europe) S.a.r.l. et Cie

Connection: https://www.paypal.com/hu/home

6.4. Social media

Our website has several social media profile (for example: Facebook, Linkedin Twitter, Google+, Instagram, You Tube) so that if you „like” us on Facebook or „follow” us on Instagram, we may learn all the personal data which is public on your profile.

6.5. Invoicing

In connection with invoicing, the data processor gets to know the personal data provided by the Users for this purpose.

Name: KBOSS.hu Kft

Connection: https://www.szamlazz.hu/szamla/main

 

 

7. Data security

We and the employees of the data processors have the right to get to know the personal data of the User to the extent necessary for the performance of the tasks belonging to their job. We take all security, technical and organizational measures that guarantee the security of the data.

7.1. Organizational measures

We provide access to our IT systems with personal permission. The principle of “necessary and sufficient rights” applies to the allocation of access, ie all employees may use our IT systems and services only to the extent necessary for the performance of their duties, with the appropriate rights and for the required period of time. Access to IT systems and services should only be granted to a person who is not restricted for security or other reasons (eg conflicts of interest) and who has the professional, business and information security knowledge necessary to use it securely.

We and the data processors undertake strict confidentiality rules in a written statement and we are obliged to act in accordance with these confidentiality rules in the course of our activities.

7.2. Technical measures

We store the data – with the exception of the data stored by our data processors – on our own devices, in a data center. The IT tools, that stores the data are stored in a separate, separate closed server room, protected by a multi-stage access control system.

We protect our internal network with multi-level firewall protection. In all cases, a hardware firewall (border protection device) is located at the entry points of the applied public networks. The data is stored redundantly – ie in several places – in order to protect it from destruction, loss, damage and illegal destruction due to the failure of the IT device.

We protect our internal networks from external attacks with multi-level, active protection against complex malicious code (eg virus protection). We implement the essential external access to the IT systems and databases operated by us via an encrypted data connection (VPN).

We do our best to ensure that our IT tools and software continuously comply with the technology solutions generally accepted in the operation of the market.

During our development, we design systems in which logging can be used to control and track the operations performed, and to detect incidents, such as unauthorized access.

Our server is located on the hosting provider’s separate dedicated server, protected and closed.

Taking into account of the NAIH recommendation about the parts we use https protocol which provides a higher level of data security than the http protocol.

 

 

 

 

8. Cookies

 

8.1. Cookies in general

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website.

List of the cookies we use on the website

SourceNameFunctionExpiration
FacebookFacebook pixelFacebook advertising data collection180 days
GoogleGoogle AnalyticsAnonymous analysis of visitor dataMore information in the  8.2.1. point.
HotjarHotjarAnalyze visitors’ website usage365 days, more information https://help.hotjar.com/hc/en-us/articles/115011640427-How-long-does-Hotjar-keep-my-data-

 

 

8.2. Google Analytics

We use Google Analytics to analyse the use of our website.

Our analytics service provider generates statistical and other information about website use by means of cookies.

The information generated relating to our website is used to create reports about the use of our website.

Our analytics service provider’s privacy policy is available at: https://unas.hu/adatkezelesi-tajekoztato

8.3. Facebook Pixel

Facebook Custom Audience is an online analytics and advertising service of Facebook, Inc. (Facebook) through which the Data Controller obtains information about how visitors to the Website use the Website. You can read more about Facebook Custom Audience or Facebook Pixel cookies here: https://www.facebook.com/policies/cookies/.

Facebook Pixel requires cookies to be placed on user devices. We also use Facebook Pixel on the Website, both for advertising and Website analytics. Facebook pixels place cookies on the Website browser for the purpose of generating the right advertising audience, measuring conversions between devices, targeting ads, optimizing the right audience, displaying personalized advertisements, advertisements and reports, reporting on the Website and application traffic. data.

This data management activity of Facebook may be regulated and set up by the User in his Facebook and Google accounts, and the collection of data by Facebook cookies on the Website may be authorized by the User. On Facebook, the User can view these cookies in the Facebook Ads Settings by logging into their account, and there they can also set or change their preferences regarding cookies. On the Website, the User may give his consent to cookies in groups according to their type.

 

8.4. How to manage cookies?

Cookies can be deleted (detailed information: www.AllAboutCookies.org) or blocked by most browsers today. In this case, however, when using our website, certain settings will need to be reconfigured each time and certain services may not work.

Detailed information on deleting and blocking cookies can be found at www.AllAboutCookies.org (in English) and on the browser used by the User at the following links:

 

 

9. Other provisions

 

9.1. Processing for different purpose

If we intend to further process the personal data for a purpose other than that for which the personal data were collected, we provide the you prior to that further processing with information on that other purpose and with any relevant further information.

 

9.2. Data protection

We secure your personal information from unauthorized access, use or disclosure. We secure the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When personal information (such as connection data) is transmitted to other Web sites, it is protected through the use of encryption.

 

9.3. Record of processing

To comply with section 30 of GDPR, we maintain a record of processing activities under our responsibility.

 

9.4. Data breaches

Data breach is a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed. In case of data breach, we act according to section 33 and 34 of GDPR.

 

9.5. Changes to our Privacy Policy

We will occasionally update this Privacy Policy to reflect feedback. We encourage you to periodically review this Policy to be informed of how we are protecting your information.

 

Effective: [*]

 

 

 

Multinvent Kft.

Controller

 

 

 

Appendix – Definitions

  • ‘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, an identification 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;

 

  • ‘processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

 

  • ‘restriction of processing’ means the marking of stored personal data with the aim of limiting their processing in the future;

 

  • ‘pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;

 

  • ‘filing system’ means any structured set of personal data which are accessible according to specific criteria, whether centralized, decentralized or dispersed on a functional or geographical basis;

 

  • ‘controller’ means the natural or legal person, public authority, agency or 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 such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

 

  • ‘processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

 

  • ‘recipient’ means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;

 

  • ‘third party’ means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data;

 

  • ‘personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed;

 

  • ‘data concerning health’ means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status;

 

  • ‘enterprise’ means a natural or legal person engaged in an economic activity, irrespective of its legal form, including partnerships or associations regularly engaged in an economic activity;

 

  • group of undertakings’ means a controlling undertaking and its controlled undertakings;

 

  • ‘supervisory authority’ means an independent public authority which is established by a Member State pursuant to Article 51;

 

  • ‘supervisory authority concerned’ means a supePRIVACY POLICY

     

    1. Purpose of the Privacy Policy.. 3
    2. Data of the controller.. 4
    3. Data processing.. 5

    3.1.Data processing concerning contacting and communication.. 5

    3.1.1. Processed personal data and purpose of processing. 5

    3.1.2. Legal basis of processing. 5

    3.1.3. Duration of the processing. 6

    3.1.4. Mode of processing. 6

    3.1.5. Data protection contractual clause. 6

    3.2. Processing concerning ordering.. 7

    3.2.1. Processed personal data and purpose of processing. 7

    3.2.2. Legal basis of processing. 7

    3.2.3. Duration of the processing. 8

    3.2.4. Mode of processing. 8

    3.2.5. Provision of processing. 8

    3.3. Processing concerning invoicing.. 9

    3.3.1. Processed personal data and purpose of processing. 9

    3.3.2. Legal basis of processing. 9

    3.3.3. Duration of the processing. 9

    3.3.4. Mode of processing. 10

    3.4. Processing concerning complaint handling.. 11

    3.4.1. Processed personal data and purpose of processing. 11

    3.4.2. Legal basis of processing. 11

    3.4.3. Duration of processing. 11

    3.4.4. Mode of processing. 11

    3.5. Processing related to the handling of warranty claims. 12

    3.5.1. Processed personal data and purpose of processing. 12

    3.5.2. Legal basis of processing. 12

    3.5.3. Duration of processing. 12

    3.5.4. Mode of processing. 12

    3.6. Processing related to prize draw lot.. 13

    3.6.1. Processed personal data and purpose of processing. 13

    3.6.2. Legal basis of processing. 13

    3.6.3. Duration of processing. 13

    Until the goal is achieved; until the complete closing of that sweepstakes. 13

    3.6.4. Mode of processing. 13

    1. What are your rights?. 14

    4.1. Right to access. 14

    4.2. Right to rectification. 14

    4.3. Right to erasure. 14

    4.4. Right to be forgotten. 15

    4.5. Right to restriction of processing. 15

    4.6. Right to data portability. 15

    4.7. Right to object. 16

    4.8. Right to lodge complaint. 16

    1. Measures and notification.. 17

    5.1. Informing Data subjects. 17

    5.2. Mode and deadline of notification. 17

    5.3. Monitoring. 17

    5.4. Costs of measures and notifications. 17

    1. Possible recipients. 18

    6.1. During the operation of our website. 18

    6.2. Delivery of the ordered products. 18

    6.3. Payment of the order fee. 18

    6.4. Social media. 18

    6.5. Invoicing. 18

    1. Data security.. 19
    2. Cookies. 20

    8.1. Cookies in general. 20

    8.2. Google Analytics. 20

    8.3. Facebook Pixel. 20

    8.4. How to manage cookies?. 21

    1. Other provisions. 22

    9.1. Processing for different purpose. 22

    9.2. Data protection. 22

    9.3. Record of processing. 22

    9.4. Data breaches. 22

    9.5. Changes to our Privacy Policy. 22

    Appendix – Definitions. 23

     

     

    1. Purpose of the Privacy Policy

     

    The goal of our Privacy Policy is to provide all necessary information about processing your personal data in a concise, transparent, intelligible and easily accessible form, using clear and plain language, and assist the Data subjects in exercising their rights under Section 4.

    The legal basis of our duty to communicate information is Article 12 of Regulation 2016/679 of the European Parliament and Council (hereinafter referred to as: GDPR) and the relevant Hungarian data protection regulations.

    In the Privacy Policy, we may define you as “data subject”, or “contact person of our business partners” in the following.

    You may find further definitions concerning your personal data within the Appendix of the current Privacy Policy.

    Our services are available at www.flatloop.com and related websites.

    2. Data of the controller

     

    NameMultinvent Kft.
    Registry number13-09-168291
    Registered seat2014 Csobánka, Cinke utca 10.
    E-mailloopboomerangs@gmail.com
    Telephone number+36209806314
    Tax number24832827-2-13

     

     

     

    3. Data processing

    3.1. Data processing concerning contacting and communication

    It is possible to connect us through our availabilities located on the website. Also, by communicating with our business partners, we process the personal data of their contact person. The details of these processing are described hereunder.

    3.1.1. Processed personal data and purpose of processing

     

    personal datapurpose of processingLawfulness of processing
    nameidentification of the Data subject, or the contact person of our business partnerthe data subject has given consent to the processing of his or her personal data for one or more specific purposes [article 6 (1) a) of GDPR]; in the case of contact person of our business partner processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party [article 6 (1) f) of GDPR]
    phone numbercontacting and communication with the Data subject, or the contact person of our business partnerthe data subject has given consent to the processing of his or her personal data for one or more specific purposes [article 6 (1) a) of GDPR]; in the case of contact person of our business partner processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party [article 6 (1) f) of GDPR]
    e-mail addresscontacting and communication with the Data subject, or the contact person of our business partnerthe data subject has given consent to the processing of his or her personal data for one or more specific purposes [article 6 (1) a) of GDPR]; in the case of contact person of our business partner processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party [article 6 (1) f) of GDPR]

     

    3.1.2. Legal basis of processing

     

    If you contact us through our website, we process your personal data on your freely given consent that you provide in the moment of your connection by phone or email (article 6 (1) a) of GDPR).

    If you, as the representative of our business partners provide your personal data to communicate with us, the legal basis of processing personal data is the legitimate interest of us and our business partners (section 6 paragraph 1 point f of GDPR). It is each Party’s legitimate interest to maintain an effective business communication and to perform the contract. Since it is the part of your scope of duty (representation of our business partners), in our view, processing your name and contact data doesn’t restrict disproportionately your privacy and freedom of self-determination.

     

    3.1.3. Duration of the processing

     

    If you contact us through our website, we process your personal data until the withdrawal of your consent. You have the right to withdraw your consent at any time via email. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

     

    In relation to the processing of the personal data of our business partners’ contact persons, we process their personal data until the personal data are no longer necessary in relation to the purposes for which they were collected or as long as it is possible according to the relevant acts (pursuant to the Hungarian Civil Code, 5 years following the performance or the termination of the contract, or 8 years following invoicing, in accordance with the Hungarian accounting act).

     

    3.1.4. Mode of processing

     

    Electronic form.

     

    3.1.5. Data protection contractual clause

     

    Taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for rights and freedoms of natural persons posed by the processing concerning communicating with our business partners, we, as data controllers, while performing the contracts concluded with our business partners, both at the time of the determination of the means for processing, and at the time of the processing itself, implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing in order to meet the requirements of GDPR.

     

     

    3.2. Processing concerning ordering

    You can order any of our products shown in our website. The details of such processing are described hereunder.

    3.2.1. Processed personal data and purpose of processing

     

    personal datapurpose of processingLawfulness of processing
    name (first name, surname, title)identification of the purchaser or its representativeprocessing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract [article 6 (1) b) of GDPR]; if the customer is a legal person then processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party [article 6 (1) f) of GDPR]
    addressidentification of the place of transportationprocessing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract [article 6 (1) b) of GDPR]
    phone numberconnecting the purchaser or its representative and giving information about the servicesprocessing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract [article 6 (1) b) of GDPR]; if the customer is a legal person then processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party [article 6 (1) f) of GDPR]
    e-mail addressconnecting the purchaser or its representative and giving information about the servicesprocessing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract [article 6 (1) b) of GDPR]; if the customer is a legal person then processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party [article 6 (1) f) of GDPR]
    a unique coupon code that can be linked to the useridentification of the customer in order to take advantage of the individual discount we provideprocessing is necessary for the purposes of the legitimate interests pursued by the controller [article 6 (1) f) of GDPR]

     

    3.2.2. Legal basis of processing

    If the legal person purchaser’s representative provides his or her personal data for these purposes, the legal basis of processing personal data – with regard to the relevant authorial practice – is the legitimate interest of us and the purchaser company (section 6 paragraph 1 point f of GDPR). It is each party’s legitimate interest to maintain an effective business communication and to finalize the purchase. In our view – since it is the part of the representative’s scope of duty, and in case of the children’s and partner’s personal data, we need these pieces of information to make the gifts for the event – the processing of the mentioned personal data doesn’t restrict disproportionately the Data subject’s privacy and freedom of self-determination.

     

    All the personal data you give us during the ordering of the available products are processed for the performance of the contract concluded between you and us (article 6 b) of GDPR).

     

    3.2.3. Duration of the processing

     

    Until the personal data are no longer necessary in relation to the purposes for which they were collected or as long as it is possible according to the relevant acts (8 years after accounting or 5 years following performance).

     

    3.2.4. Mode of processing

     

    Electronic form.

     

    3.2.5. Provision of processing

    Since we cannot perform the order without knowing any information about you, the processing is a requirement necessary to enter into a contract.

     

    3.3. Processing concerning invoicing

     

    After the performing of the orders we – with regard to Act C of 2000 on accounting – make out a bill. The details of such processing are described hereunder.

     

    3.3.1. Processed personal data and purpose of processing

     

     

    personal datapurpose of processingLawfulness of processing
    nameconfirmation of the accountingprocessing is necessary for compliance with a legal obligation to which the controller is subject [article 6 (1) c) of GDPR] based on the Act No. CXII. of 2011. on the right to information self-determination and freedom of information 5. § (1) b), and the Act No. C. of 2000. on accounting 166. § (1)-(3)
    addressconfirmation of the accountingprocessing is necessary for compliance with a legal obligation to which the controller is subject [article 6 (1) c) of GDPR] based on the Act No. CXII. of 2011. on the right to information self-determination and freedom of information 5. § (1) b), Act No. C. of 2000. on accounting 166. § (1)-(3)
    individual entrepreneur tax numbersupport the accountingprocessing is necessary for compliance with a legal obligation to which the controller is subject [article 6 (1) c) of GDPR] based on the Act No. CXII. of 2011. on the right to information self-determination and freedom of information 5. § (1) b), Act No. C. of 2000. on accounting 166. § (1)-(3)

     

    3.3.2. Legal basis of processing

     

    Processing is necessary for compliance with a legal obligation; with regard to section 6 paragraph 1 point c of GDPR, section 5 article 1 point b of Information Act and section 166 paragraph 1 to 3 of Act C of 2000.

     

    3.3.3. Duration of the processing

     

    8 years after accounting based on the 169 paragraph 1of Act C of 2000 and 166 paragraph 6 of Act C of 2000.

    3.3.4. Mode of processing

     

    Electronic form.

     

    The document issued in electronic form – in accordance with the provisions of the legislation on the rules of digital archiving – is preserved in such a way that the applied method ensures the immediate production and continuous readability of all data of the document, and excludes the possibility of subsequent modification.

     

    3.4. Processing concerning complaint handling

     

    In order to answer your questions or to inspect the circumstances you requested a complaint for, we operate customer service.

     

    3.4.1. Processed personal data and purpose of processing

    personal datapurpose of processingLawfulness of processing
    nameidentification of the userprocessing is necessary for compliance with a legal obligation to which the controller is subject [article 6 (1) c) and (2) of GDPR] based on the Act No. CXII. of 2011. on the right to information self-determination and freedom of information 5. § (1) b), and the Act No. CLV. of 1997. on consumer protection
    e-mail addressconnecting with the user and providing informationprocessing is necessary for compliance with a legal obligation to which the controller is subject [article 6 (1) c) and (2) of GDPR] based on the Act No. CXII. of 2011. on the right to information self-determination and freedom of information 5. § (1) b), and the Act No. CLV. of 1997. on consumer protection
    phone numberconnecting with the user and providing informationprocessing is necessary for compliance with a legal obligation to which the controller is subject [article 6 (1) c) and (2) of GDPR] based on the Act No. CXII. of 2011. on the right to information self-determination and freedom of information 5. § (1) b), and the Act No. CLV. of 1997. on consumer protection

     

    3.4.2. Legal basis of processing

    We process the personal data we collect from you by legal obligations (article 6 point (1) c) of GDPR) based on the Act No. CXII. of 2011. on the right to information self-determination and freedom of information 5. § (1) b), and the Act No. CLV. of 1997. on consumer protection

    3.4.3. Duration of processing

    5 years after the upon receipt of a complaint based on paragraph 17/A § 7 of the Act No. CLV. of 1997. on consumer protection

    3.4.4. Mode of processing

    Electronic form.


     

    3.5. Processing related to the handling of warranty claims

    If the costumer enforces supplies warranty and product warranty claim according to the Hungarian Civil Code, then we are required to write a report according to 19/2014 (IV.29) NGM regulation

    3.5.1. Processed personal data and purpose of processing

    personal datapurpose of processingLawfulness of processing
    nameidentification of the user and write the reportprocessing is necessary for compliance with a legal obligation to which the controller is subject [article 6 (1) c) and (2) of GDPR] based on the Act No. CXII. of 2011. on the right to information self-determination and freedom of information 5. § (1) b), and 19/2014 (IV.29) NGM regulation 4. § (1)
    addressidentification of the user and write the reportprocessing is necessary for compliance with a legal obligation to which the controller is subject [article 6 (1) c) and (2) of GDPR] based on the Act No. CXII. of 2011. on the right to information self-determination and freedom of information 5. § (1) b), and 19/2014 (IV.29) NGM regulation 4. § (1)
    information to consent to processwrite the reportprocessing is necessary for compliance with a legal obligation to which the controller is subject [article 6 (1) c) and (2) of GDPR] based on the Act No. CXII. of 2011. on the right to information self-determination and freedom of information 5. § (1) b), and 19/2014 (IV.29) NGM regulation 4. § (1)

     

    3.5.2. Legal basis of processing

    We process the personal data we collect from you by legal obligations (article 6 point (1) c) and (2) of GDPR) based on the Act No. CXII. of 2011. on the right to information self-determination and freedom of information 5. § (1) b), and 19/2014 (IV.29) NGM regulation 4. § (1).

    3.5.3. Duration of processing

    3 years after the completion of the report based on the paragraph 4 (1) and (6)

    3.5.4. Mode of processing

    Electronic form.

     

     

     

     

     

    3.6. Processing related to prize draw lot

     

    We advertise games on our Facebook page and on the website. We draw prizes among the Users who comment on the given entry or perform a specific activity.

     

    3.6.1. Processed personal data and purpose of processing

    personal datapurpose of processingLawfulness of processing
    nameidentification of the winner user.the data subject has given consent to the processing of his or her personal data for one or more specific purposes [article 6 (1) a) of GDPR]
    e-mail addressidentification of the winner user.the data subject has given consent to the processing of his or her personal data for one or more specific purposes [article 6 (1) a) of GDPR]
    fact of winningidentification of the winner user.the data subject has given consent to the processing of his or her personal data for one or more specific purposes [article 6 (1) a) of GDPR]

     

    3.6.2. Legal basis of processing

    If you participate the prize draw you have given consent to the processing of his or her personal data for one or more specific purposes [article 6 (1) a) of GDPR]

    3.6.3. Duration of processing

    Until the goal is achieved; until the complete closing of that sweepstakes.

    3.6.4. Mode of processing

    Electronic form.

     

     

     

     

     

     

     

     

     

     

     

    4. What are your rights?

     

    4.1. Right to access

    You have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the information featured in point 3.

    You have the right to access to the following information concerning the processing of your personal data:

    • the purposes of the processing;

     

    • the categories of personal data concerned;

     

    • the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;

     

    • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

     

    • the existence of the right to request from us rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing;

     

    • the right to lodge a complaint with a supervisory authority;

     

    • the existence of automated decision-making, including profiling, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

     

    4.2. Right to rectification

    You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

     

    4.3. Right to erasure

    You have the right to obtain from us the erasure of personal data concerning you without undue delay and we shall have the obligation to erase personal data without undue delay if it is mandatory according to Article 17 of GDPR. The erasure of your personal data is obligatory for us in the following instances:

     

    • the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

     

    • you withdraw consent on which the processing is based, and where there is no other legal ground for the processing;

     

    • you object to the processing and there are no overriding legitimate grounds for the processing;

     

    • the personal data have been unlawfully processed;

     

    • the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.

     

    4.4. Right to be forgotten

    If we made the personal data public and are obliged to erase your personal data, we inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

    We do not make your personal data public.

     

    4.5. Right to restriction of processing

    You have the right to obtain from us restriction of processing if is obligatory according to Article 18 of GDPR. Such instances are the following:

     

    • the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;

     

    • the processing is unlawful and you oppose the erasure of the personal data and requests the restriction of their use instead;

     

    • we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims;

     

    If you obtain restriction of processing in accordance with the above, we inform you before the restriction of processing is lifted.

     

    4.6. Right to data portability

    You have the right to receive the personal data concerning you, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us if is possible according to Article 20 of GDPR. Where technically feasible, you have the right to have the personal data transmitted directly from us to another controller.

     

    4.7. Right to object

    You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (f) of Article 6(1) of GDPR (see: point 3.1. and 3.2. of the current policy). In such case, we no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

     

    4.8. Right to lodge complaint

    You have the right to appeal to the Hungarian courts and to make a complaint to the Hungarian (https://naih.hu/) Supervisory Authority.

     

     

    5. Measures and notification

     

    5.1. Informing Data subjects

    We communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1) and Article 18 of GDPR to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. We also inform you about those recipients on the request of yours.

     

    5.2. Mode and deadline of notification

    We provide information on action taken on a request under Articles 15 to 22 of GDPR to you without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We inform you of any such extension within one month of receipt of the request, together with the reasons for the delay. Where you make the request by electronic form means, we provided the information by electronic means where possible, unless you request it otherwise.

    If we do not take action on your request, we inform you without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy (see point 4.7.).

     

    5.3. Monitoring

    If we have reasonable doubts concerning the identity of the natural person making the request, we may request the provision of additional information necessary to confirm the identity of the data subject.

     

    5.4. Costs of measures and notifications

    We provide you information and take the necessary measures free of charge.

    If your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested or we refuse to act on your request.

     

     

    6. Possible recipients

     

    6.1. During the operation of our website

     

    Our website’s hosting provider (data processor) can have access to the personal data you provide while using the website. The data processor’s data are the following:

     

    Name: GTT NETWORX Korlátolt Felelősségű Társaság

    Registered seat: 2030 Érd, Bertalan utca 22.

    Registry number: 13 09 145403

    E-mail: admin@gttnetworx.hu

     

     

    6.2. Delivery of the ordered products

    In order to deliver the ordered products, we use fulfillment companies as data processors. These service providers enter into contracts with transport companies to deliver the products ordered by the user, so in this respect these additional service providers are considered sub-data processors. We ensure that sub-data processors also comply with legal requirements regarding the handling and protection of personal data in the course of their activities

    6.3. Payment of the order fee

    The order fee can be paid through the payment service provider’s data processing interface.

    Name: PayPal (Europe) S.a.r.l. et Cie

    Connection: https://www.paypal.com/hu/home

    6.4. Social media

    Our website has several social media profile (for example: Facebook, Linkedin Twitter, Google+, Instagram, You Tube) so that if you „like” us on Facebook or „follow” us on Instagram, we may learn all the personal data which is public on your profile.

    6.5. Invoicing

    In connection with invoicing, the data processor gets to know the personal data provided by the Users for this purpose.

    Name: KBOSS.hu Kft

    Connection: https://www.szamlazz.hu/szamla/main

     

     

    7. Data security

    We and the employees of the data processors have the right to get to know the personal data of the User to the extent necessary for the performance of the tasks belonging to their job. We take all security, technical and organizational measures that guarantee the security of the data.

    7.1. Organizational measures

    We provide access to our IT systems with personal permission. The principle of “necessary and sufficient rights” applies to the allocation of access, ie all employees may use our IT systems and services only to the extent necessary for the performance of their duties, with the appropriate rights and for the required period of time. Access to IT systems and services should only be granted to a person who is not restricted for security or other reasons (eg conflicts of interest) and who has the professional, business and information security knowledge necessary to use it securely.

    We and the data processors undertake strict confidentiality rules in a written statement and we are obliged to act in accordance with these confidentiality rules in the course of our activities.

    7.2. Technical measures

    We store the data – with the exception of the data stored by our data processors – on our own devices, in a data center. The IT tools, that stores the data are stored in a separate, separate closed server room, protected by a multi-stage access control system.

    We protect our internal network with multi-level firewall protection. In all cases, a hardware firewall (border protection device) is located at the entry points of the applied public networks. The data is stored redundantly – ie in several places – in order to protect it from destruction, loss, damage and illegal destruction due to the failure of the IT device.

    We protect our internal networks from external attacks with multi-level, active protection against complex malicious code (eg virus protection). We implement the essential external access to the IT systems and databases operated by us via an encrypted data connection (VPN).

    We do our best to ensure that our IT tools and software continuously comply with the technology solutions generally accepted in the operation of the market.

    During our development, we design systems in which logging can be used to control and track the operations performed, and to detect incidents, such as unauthorized access.

    Our server is located on the hosting provider’s separate dedicated server, protected and closed.

    Taking into account of the NAIH recommendation about the parts we use https protocol which provides a higher level of data security than the http protocol.

     

     

     

     

    8. Cookies

     

    8.1. Cookies in general

    A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

    Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

    Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

    Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website.

    List of the cookies we use on the website

    SourceNameFunctionExpiration
    FacebookFacebook pixelFacebook advertising data collection180 days
    GoogleGoogle AnalyticsAnonymous analysis of visitor dataMore information in the  8.2.1. point.
    HotjarHotjarAnalyze visitors’ website usage365 days, more information https://help.hotjar.com/hc/en-us/articles/115011640427-How-long-does-Hotjar-keep-my-data-

     

     

    8.2. Google Analytics

    We use Google Analytics to analyse the use of our website.

    Our analytics service provider generates statistical and other information about website use by means of cookies.

    The information generated relating to our website is used to create reports about the use of our website.

    Our analytics service provider’s privacy policy is available at: https://unas.hu/adatkezelesi-tajekoztato

    8.3. Facebook Pixel

    Facebook Custom Audience is an online analytics and advertising service of Facebook, Inc. (Facebook) through which the Data Controller obtains information about how visitors to the Website use the Website. You can read more about Facebook Custom Audience or Facebook Pixel cookies here: https://www.facebook.com/policies/cookies/.

    Facebook Pixel requires cookies to be placed on user devices. We also use Facebook Pixel on the Website, both for advertising and Website analytics. Facebook pixels place cookies on the Website browser for the purpose of generating the right advertising audience, measuring conversions between devices, targeting ads, optimizing the right audience, displaying personalized advertisements, advertisements and reports, reporting on the Website and application traffic. data.

    This data management activity of Facebook may be regulated and set up by the User in his Facebook and Google accounts, and the collection of data by Facebook cookies on the Website may be authorized by the User. On Facebook, the User can view these cookies in the Facebook Ads Settings by logging into their account, and there they can also set or change their preferences regarding cookies. On the Website, the User may give his consent to cookies in groups according to their type.

     

    8.4. How to manage cookies?

    Cookies can be deleted (detailed information: www.AllAboutCookies.org) or blocked by most browsers today. In this case, however, when using our website, certain settings will need to be reconfigured each time and certain services may not work.

    Detailed information on deleting and blocking cookies can be found at www.AllAboutCookies.org (in English) and on the browser used by the User at the following links:

     

    9. Other provisions

     

    9.1. Processing for different purpose

    If we intend to further process the personal data for a purpose other than that for which the personal data were collected, we provide the you prior to that further processing with information on that other purpose and with any relevant further information.

     

    9.2. Data protection

    We secure your personal information from unauthorized access, use or disclosure. We secure the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When personal information (such as connection data) is transmitted to other Web sites, it is protected through the use of encryption.

     

    9.3. Record of processing

    To comply with section 30 of GDPR, we maintain a record of processing activities under our responsibility.

     

    9.4. Data breaches

    Data breach is a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed. In case of data breach, we act according to section 33 and 34 of GDPR.

     

    9.5. Changes to our Privacy Policy

    We will occasionally update this Privacy Policy to reflect feedback. We encourage you to periodically review this Policy to be informed of how we are protecting your information.

     

    Effective: [*]

     

     

     

    Multinvent Kft.

    Controller

     

     

    Appendix – Definitions

    • ‘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, an identification 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;

     

    • ‘processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

     

    • ‘restriction of processing’ means the marking of stored personal data with the aim of limiting their processing in the future;

     

    • ‘pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;

     

    • ‘filing system’ means any structured set of personal data which are accessible according to specific criteria, whether centralized, decentralized or dispersed on a functional or geographical basis;

     

    • ‘controller’ means the natural or legal person, public authority, agency or 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 such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

     

    • ‘processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

     

    • ‘recipient’ means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;

     

    • ‘third party’ means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data;

     

    • ‘personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed;

     

    • ‘data concerning health’ means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status;

     

    • ‘enterprise’ means a natural or legal person engaged in an economic activity, irrespective of its legal form, including partnerships or associations regularly engaged in an economic activity;

     

    • group of undertakings’ means a controlling undertaking and its controlled undertakings;

     

    • ‘supervisory authority’ means an independent public authority which is established by a Member State pursuant to Article 51;

     

    • ‘supervisory authority concerned’ means a supervisory authority which is concerned by the processing of personal data because:

     

    • ‘relevant and reasoned objection’ means an objection to a draft decision as to whether there is an infringement of this Regulation, or whether envisaged action in relation to the controller or processor complies with this Regulation, which clearly demonstrates the significance of the risks posed by the draft decision as regards the fundamental rights and freedoms of data subjects and, where applicable, the free flow of personal data within the Union;

    rvisory authority which is concerned by the processing of personal data because:

 

  • ‘relevant and reasoned objection’ means an objection to a draft decision as to whether there is an infringement of this Regulation, or whether envisaged action in relation to the controller or processor complies with this Regulation, which clearly demonstrates the significance of the risks posed by the draft decision as regards the fundamental rights and freedoms of data subjects and, where applicable, the free flow of personal data within the Union;