Privacy policy

Introduction

The company, artimo.design Kft. (1115 Budapest, FRAKNÓ UTCA 16/B. 6 floor, door 20, EU VAT number: HU32138867, company registration number: 01-09-408632) (hereinafter referred to as the “Service Provider” or “Controller”) is subject to the following policy:

The following information is provided pursuant to REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Regulation (EC) No 95/46/EC (General Data Protection Regulation).

This Privacy Policy governs the processing of data on the following sites/mobile applications: https://artimo.design/

The privacy policy is available at: https://artimo.design//adatvedelem

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


Data controller and contact details

Name: artimo.design Kft.

Head office: 1115 Budapest, FRAKNÓ UTCA 16/B. 6th floor , door number 20

E-mail: support@artimo.design

Phone: +36305138964


Definitions of terms

  1. personal data“: 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. data controller“: the natural or legal person, public authority, agency or any other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of the processing are determined by Union or Member State law, the controller or the specific criteria for the controller’s designation 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 that may have access to personal data in the context of an individual investigation in accordance with Union or Member State law are not recipients; the processing of those data by those public authorities must comply with the applicable data protection rules in accordance with the purposes of the processing;
  6. the data subject’s consent” means a freely given, specific, informed and unambiguous indication of his or her wishes by which the data subject signifies, by a statement or by an act expressing his or her unambiguous consent, that he or she signifies his or her agreement to the processing of personal data concerning him or her;
  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 lawful, fair and transparent for the data subject (“lawfulness, fairness and transparency“);
  2. collected only for specified, explicit and legitimate purposes and not processed in a way incompatible with those purposes; and 89. Further processing for archiving purposes in the public interest, scientific and historical research purposes or statistical purposes (“purpose limitation“) shall not be considered incompatible with the original purpose, in accordance with Article 3(1);
  3. be adequate and relevant for the purposes for which the data are processed and limited to what is necessary (“data minimisation“);
  4. be accurate and, where necessary, kept up to date; all reasonable steps must be taken to ensure that personal data which are inaccurate for the purposes for which they are processed are erased or rectified without undue delay (“accuracy“);
  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 processing of the personal data is subject to the conditions laid down in Article 89. in accordance with Article 4(1) for archiving purposes in the public interest, scientific and historical research purposes or statistical purposes, subject to the implementation of appropriate technical and organisational measures as provided for in this Regulation to safeguard the rights and freedoms of data subjects (‘limited retention‘);
  6. be carried out in such a way as to ensure adequate security of personal data, including protection against unauthorised or unlawful processing, accidental loss, destruction or damage (“integrity and confidentiality“), by implementing appropriate technical or organisational measures.

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

The controller declares that its processing will be carried out in accordance with the principles set out in this point.


Data processing related to the operation of the webshop/use of the service

1. The fact of data collection, the scope of data processed and the purpose of data processing:

Personal dataPurpose of data processingLegal basis
User nameIdentification, enabling registration.a GDPR 6. Art.1(1)(b) and the Elker tv. 13/A. § (3).
PasswordIt is used for secure access to the user account.
Surname and first nameIt is necessary to contact you, to make a purchase, to issue a proper invoice, to exercise the right of withdrawal.
E-mail addressStaying in touch.
Phone numberMaintaining contact, coordinating more efficiently on billing or delivery issues.
Billing name and addressTo issue proper invoices, and to create, define, amend, monitor the performance of, invoice the fees arising from, and enforce the claims related to the contract.Article 6(1)(c) and Article 6(1)(c) of the Accounting Act 2000. Act C of 2006 No 169. § (2) paragraph
Delivery name and addressEnabling home delivery.a GDPR 6. Art.1(1)(b) and the Elker tv. 13/A. § (3).
Date of purchase/registrationPerform a technical operation.
IP address at the time of purchase/registrationPerform a technical operation.

2. Data subjects: all data subjects registered/customers of the webshop website.Neither the username nor the e-mail address need to contain personal data.

3. Duration of processing, time limit for erasure of data: if one of the conditions of Article 17(1) of the GDPR is met, until the data subject’s request for erasure. The deletion of any personal data provided by the data subject shall be notified by the controller to the data subject by electronic means pursuant to Article 19 of the GDPR. If the data subject’s request for erasure also includes the e-mail address provided by him or her, the controller shall erase the e-mail address after the information is provided. Except in the case of accounting documents, since according to Act C of 2006 No 169. of 2000 on Accounting, these data must be kept for 8 years. The contractual data of the data subject may be erased after the expiry of the civil limitation period on the basis of a request for erasure by the data subject.

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

4. Identity of the potential controllers of the data, recipients of the personal data: personal data may be processed by the controller and by its authorised staff, in compliance with the principles set out above.

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
  • the data subject has the right to data portability and the right to withdraw consent at any time.

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

  • by post to 1115 Budapest, FRAKNÓ UTCA 16/B. 6th floor 20 doors,
  • by e-mail to support@artimo.design,
  • by phone on +36305138964.

7. Legal basis for processing:

1. a GDPR 6. Article 3(1) b) and point c),

2. Section 13/A (3) of Act CVIII of 2001 CVIII. commerce services and information society services (hereinafter: Elker Act):

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

3. Article 6(1)(c) where invoices are issued in accordance with accounting legislation.

4. In the event of enforcement of claims arising from the contract, 5 years pursuant to § 6:22 of Act V of 2013 on the Civil Code.

6:22. § 6:22 [Limitation period] [Elévülés]

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

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

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

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

8. Please be informed that

  • the processing is necessary for the performance of a contract and the submission of an offer.
  • you must provide personal information so that we can fulfil your order.
  • failure to provide the data will result in our inability to process your order.

Cookie management (cookies)

1. The use of the so-called “password-protected session cookies”, “shopping cart cookies”, “security cookies”, “essential cookies”, “functional cookies” and “cookies responsible for the management of website statistics” does not require prior consent from the data subject.

2. Fact of processing, scope of data processed: unique identifier, dates, times

3. Data subjects: all data subjects visiting the website.

4. Purpose of data processing: to identify users and track visitors.

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

Type of cookieLegal basis for data processingData managementDuration
Session cookies (session) The Directive on certain aspects of electronic commerce services and information society services of 2001. CVIII. Act (Elkertv.) 13/A. § (3)Period of time to close the train transfer session
Permanent or saved cookies The Directive on certain aspects of electronic commerce services and information society services of 2001. CVIII. Act (Elkertv.) 13/A. § (3)until the deletion of the data subject
Statistical, marketing cookiesThe Directive on certain aspects of electronic commerce services and information society services of 2001. CVIII. Act (Elkertv.) 13/A. § (3)1 month – 2 years

6. Who are the potential controllers of the data: no personal data are processed by the controller through the use of cookies.

7. Description of data subjects’ rights in relation to data processing: data subjects have the possibility to delete cookies in the Tools/Preferences menu of their browsers, usually under the Privacy settings.

8.Legal basis for data processing: no consent is required from the data subject where the sole purpose of the use of cookies is the transmission of communications over an electronic communications network or where the use of cookies is strictly necessary for the provision of an information society service expressly requested by the subscriber or user.

9. Most browsers used by our users allow you to set which cookies should be saved and allow (certain) cookies to be deleted again. If you restrict the saving of cookies on certain websites or do not allow third party cookies, this may, under certain circumstances, lead to our website no longer being fully usable. Here you will find information on how to customise your cookie settings for common browsers:

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

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

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

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


Using Google Ads conversion tracking

  1. The data controller uses the online advertising program “Google Ads” and makes use of Google’s conversion tracking service within its framework. Google Conversion Tracking is an analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”).
  2. When you visit a website through a Google ad, a cookie is placed on your computer for conversion tracking. 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 may see that the User has clicked on the advertisement.
  4. Each Google Ads client receives a different cookie, so they cannot be tracked through Ads clients’ websites.
  5. The information, which is obtained through the use of conversion tracking cookies, is used to provide conversion statistics to Ads customers who opt for conversion tracking. Customers are then informed about the number of users who click on their ad and are redirected 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 want 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. Further information and Google’s privacy statement can be found at: https://policies.google.com/privacy

Using Google Analytics

  1. This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses so-called “cookies”, text files that are saved on your computer to help the analysis of the use of the website visited by the User.
  2. The information generated by the cookies on the website used by the User is usually transferred to a Google server in the USA and stored there. By activating IP anonymisation on the website, Google will shorten the User’s IP address in the Member States of the European Union or in other states party to the Agreement on the European Economic Area.
  3. The full IP address will be transmitted to a Google server in the USA and shortened there only in exceptional cases. 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 and internet usage.
  4. The IP address transmitted by the User’s browser within the framework of Google Analytics will not be merged with other data held by Google. The User may prevent the storage of cookies by selecting the appropriate settings on his/her browser, however, please note that in this case, not all functions of this website may be fully functional. You may also prevent Google from collecting and processing information about your use of the website (including your IP address) through 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 XLVIII. 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. Furthermore, the Customer may, subject to the provisions of this information, consent to the processing of personal data by the Service Provider necessary for the sending of advertising offers.

3. The Service Provider shall not send unsolicited advertising messages, and the User may unsubscribe from receiving such offers without any restriction and without giving any reason, free of charge. In this case, the Service Provider will delete all personal data necessary for sending advertising messages from its records and will not contact the User with further advertising offers. Users can unsubscribe from advertising by clicking on the link in the message.

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

Personal dataPurpose of data processingLegal basis
Name, e-mail address.Identification, to enable subscription to the newsletter/special offers.Consent of the data subject,6. Article 2(1)(a).The Act on the basic conditions and certain restrictions on commercial advertising of 2008. XLVIII. the User may expressly consent in advance to the Service Provider contacting him/her with advertising offers § (5).
Date of subscriptionPerform a technical operation.
IP address at the time of subscriptionPerform a technical operation.

5. Data subjects: all data subjects who subscribe to the newsletter.

Purpose of processing: sending electronic messages (e-mail, SMS, push messages) containing advertising to the data subject, providing information about current information, products, promotions, new features, etc.

7. Duration of data processing, deadline for deletion of data: data processing lasts until the consent is withdrawn, i.e. until unsubscription.

8. Identity of potential controllers of the data, recipients of personal data: personal data may be processed by the controller and its sales and marketing staff, in compliance with the principles set out above.

9. 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 your personal data; and
  • the data subject has the right to data portability and the right to withdraw consent at any time.

10. Data subjects may request access to, erasure, modification, restriction of processing, portability or objection to the processing of their personal data by:

  • by post to 1115 Budapest, FRAKNÓ UTCA 16/B. 6th floor 20 doors,
  • by e-mail to support@artimo.design,
  • by phone on +36305138964.

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

12. Please be informed that

  • the processing is based on your consent and the legitimate interest of the service provider .
  • must provide personal data if you wish to receive newsletters from us.
  • failure to provide this information will result in us not being able to send you a newsletter.
  • please note that you can withdraw your consent at any time by clicking on the unsubscribe button.
  • the withdrawal of consent does not affect the lawfulness of processing based on consent prior to its withdrawal.

Complaints handling

1. The fact of data collection, the scope of data processed and the purpose of data processing:

Personal dataPurpose of data processingLegal basis
Surname and first nameIdentification, contact.Article 6(1)(c), and Article 6(1)(c) of the Consumer Protection Act 1997. CLV. Act 17/A. § (7).
E-mail addressStaying in touch.
Phone numberStaying in touch.
Billing name and addressIdentifying, handling quality complaints, questions and problems with the products/services ordered.

2. Data subjects: all data subjects who make a complaint and shop on the website and who have quality complaints.

3. Duration of data processing, time limit for deletion of data: copies of the record of the complaint, the transcript and the reply to the complaint shall be kept in accordance with the provisions of the Consumer Protection Act 1997. CLV. Act 17/A. § (7) shall be kept for 3 years.

4. Identity of the potential controllers of the data, recipients of the personal data: personal data may be processed by the controller and by its authorised staff, in compliance with the principles set out above.

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
  • the right to data portability and the right to withdraw consent at any time

6. The data subject may requestaccess to, deletion, modification or restriction of processing of personal data , or the portability of data in the following ways:

  • by post to 1115 Budapest, FRAKNÓ UTCA 16/B. 6th floor 20 doors,
  • by e-mail to support@artimo.design,
  • by phone on +36305138964.

7. Please be informed that

  • the provision of personal data is based on a legal obligation.
  • the processing of personal data is a precondition for the conclusion of the contract.
  • must provide personal data in order for us to handle your complaint.
  • failure to provide the data will mean that we will not be able to deal with your complaint.

Recipients to whom personal data are disclosed

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.

1. Processors (who carry out processing on behalf of the controller)

The data controller uses data processors to facilitate its own data processing activities and to fulfil its contractual and legal obligations with data subjects.

The controller places great emphasis on using only processors that provide adequate guarantees to implement appropriate technical and organisational measures to ensure compliance with the requirements of the GDPR and to protect the rights of data subjects.

The processor and any person acting under the control of the controller or the processor who has access to the personal data shall process the personal data covered by this Policy only in accordance with the instructions of the controller.

The controller is legally responsible for the activities of the processor. A processor is only liable for damage caused by processing if it has failed to comply with the obligations specifically imposed on processors by the GDPR or if it has disregarded or acted contrary to lawful instructions from the controller.

The processor has no substantive decision-making power with regard to the processing of the data.

The data controller may use a hosting provider to provide the IT background and a courier service as a data processor for the delivery of ordered products.

2. Some data processors

Data processing activitiesName, address, contact details
Hosting serviceKinsta Inc.
8605 Santa Monica Blvd #92581
West Hollywood,
CA 90069 United States,
contact@kinsta.com
Other data processing (e.g. online billing, web development, marketing)newsletter sender:
MailerLite
MailerLite Limited
Ground Floor, 71 Lower Baggot Street
Dublin 2
D02 P593, Ireland
support@mailerlite.com
https://www.mailerlite.com/contact-us?category=legal
online invoicing:
Billingo
Billingo Technologies Zrt.
Head office: 1133 Budapest, Árbóc utca 6. III. floor
E-mail: hello@billingo.hu

third party“: a natural or legal person, public authority, agency or any other body other than the data subject, the controller, the processor or the persons who, under the direct authority of the controller or processor, are authorised to process personal data.

3. Transfer of data to third parties

Third party data controllers process the personal data we provide on their own behalf and in accordance with their own privacy policies.

Activity of the Data ControllerName, address, contact details
TransportGLS General Logistics Systems Hungary Csomag-Logisztikai Kft.
2351 Alsónémedi, Európa u. 2.
info@gls-hungary.com
Phone number: 06-29-88-66-94
FoxPost Zrt.
3200 Gyöngyös, Batsányi János utca 9.
Telephone: 06-1-999-0-369
Customer service address: 1097 Budapest, Táblás utca 36-38. The building
E-mail: info@foxpost.hu
iLogistic Ltd.
Biatorbágy, WestLog DC, Verebély László u. 2, 2051
Phone: +36 30 356 9246
E-mail: david.reider@ilogistic.hu
Online paymentStripe Inc.
web: https://stripe.com email:support@stripe.com.
Headquarters 185 Berry Street Suite 550. San Francisco, CA 94107

Community sites

  1. Fact of data collection, scope of data processed: meta/Twitter/Pinterest/Youtube/Instagram etc. the name registered on social networking sites or the user’s public profile picture.
  2. Data subjects: all data subjects who are registered on Meta/Twitter/Pinterest/Youtube/Instagram etc. social networking sites and “liked” the Service Provider’s social networking site or contacted the data controller through the social networking site.
  3. Purpose of the data collection: to share, “like”, follow, promote, or follow certain content, products, promotions or the website itself on social networking sites.
  4. Duration of data processing, time limit for deletion of data, the identity of the possible controllers entitled to access the data and the rights of the data subjects in relation to data processing: the data subject can find out about the source of the data, the processing of the data and the method and legal basis of the transfer on the relevant Community site. The processing of data takes place on social networking sites, so the duration of the processing, the method of processing and the possibility to delete and modify the data are governed by the rules of the social networking site concerned.
  5. Legal basis for processing: the data subject’s voluntary consent to the processing of his or her personal data on social networking sites.

Customer relations and other data management

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

Rights of data subjects

1. Right of access

You have the right to receive feedback from the controller as to whether or not your personal data are being processed and, if such processing is taking place, you have the right to access your personal data and the information listed in the Regulation.

2. The right to rectification

You have the right to have inaccurate personal data relating to you corrected by the controller without undue delay at your request. Taking into account the purpose of the processing, you have the right to request that incomplete personal data be completed, including by means of a supplementary declaration.

3. Right to erasure

You have the right to have personal data concerning you erased by the controller without undue delay at your request, and the controller is obliged to erase personal data concerning you without undue delay under certain conditions.

4. The right to be forgotten

If the controller has disclosed the personal data and is required to delete it, it will take reasonable steps, including technical measures, taking into account the available technology and the cost of implementation, to inform the controllers that process the data that you have requested the deletion of the links to or copies of the personal data in question.

5. Right to restriction of processing

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

  • You contest the accuracy of the personal data, in which case the restriction applies for the period of time that allows the controller to verify the accuracy of the personal data;
  • the processing is unlawful and you object to the deletion of the data and instead request the restriction of their use;
  • the controller no longer needs the personal data for the purposes of processing, but you require them for the establishment, exercise or defence of legal claims;
  • you have objected to the processing; in this case, the restriction applies for the period until it is established whether the controller’s legitimate grounds prevail over your legitimate grounds.

6. The right to data portability

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

7. The right to object

In the case of processing based on legitimate interest or public authority as legal grounds, you have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data by (…), including profiling based on these provisions.

8. Objection in the case of direct solicitation

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

9. 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 would have legal effects concerning you or similarly significantly affect you.

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

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

Deadline for action

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

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

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


Security of data processing

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

  1. the pseudonymisation and encryption of personal data;
  2. the continued confidentiality, integrity, availability and resilience of the systems and services used to process personal data;
  3. in the event of a physical or technical incident, the ability to restore access to and availability of personal data in a timely manner;
  4. a procedure to regularly test, assess and evaluate the effectiveness of the technical and organisational measures taken to ensure the security of processing.
  5. The data processed must be stored in a way that does not allow unauthorised access. In the case of paper-based data carriers, by establishing a system of physical storage and archiving, and in the case of data managed in electronic form, by applying a centralised access management system.
  6. The method of storing the data by computerised means must be chosen in such a way that they can be erased, also taking into account any different erasure deadline, at the end of the erasure deadline or if otherwise necessary. The deletion must be irreversible.
  7. Paper-based data media must be destroyed by shredding or by using an external organisation specialised in shredding. In the case of electronic data media, physical destruction and, where necessary, prior secure and irretrievable deletion of the data must be ensured in accordance with the rules on the disposal of electronic data media.
  8. The controller will take the following specific data security measures:

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

  1. Store the documents in a secure, lockable, dry place.
  2. Where personal data processed on paper are digitised, the rules applicable to digitally stored documents apply
  3. The Service Provider’s data processing staff may leave the premises where data processing is taking place only by locking the data carriers entrusted to them or by locking the premises.
  4. Personal data can only be accessed by authorised persons and cannot be accessed by third parties.
  5. The Service Provider’s building and premises are equipped with fire and property protection equipment.

IT security

  1. Computers and mobile devices (other data carriers) used in the course of data processing are the property of the Service Provider.
  2. The computer system containing personal data used by the Service Provider is protected against viruses.
  3. To ensure the security of digitally stored data, the Service Provider uses data backups and archiving.
  4. Access to the central server machine is only allowed to authorised and designated persons.
  5. Access to data on computers is only possible with a username and password.

Informing the data subject about the personal data breach

Where a 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 without undue delay.

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

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

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

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


Reporting a data protection incident to the authority

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


Review in case of mandatory data processing

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

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


Complaint possibility

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

National Authority for Data Protection and Freedom of Information

1055 Budapest, Falk Miksa utca 9-11.

Address for correspondence: 1363 Budapest, Pf. 9.

Phone: +36 -1-391-1400

Fax: +36-1-391-1410

E-mail: ugyfelszolgalat@naih.hu


Closing words

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

  • REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Regulation (EC) No 95/46/EC (General Data Protection Regulation) (GDPR) (27 April 2016);
  • 2011. CXII. Act on the Right to Informational Self-Determination and Freedom of Information (hereinafter: Infotv.);
  • 2001. CVIII. Act – on certain aspects of electronic commerce services and information society services (in particular § 13/A);
  • 2008. XLVII. Act – on the prohibition of unfair commercial practices against consumers;
  • 2008. XLVIII. Act on the basic conditions and certain restrictions on commercial advertising (in particular § 6);
  • 2005. XC. law on electronic freedom of information;
  • 2003. Act C of 2006 on electronic communications (specifically § 155);
  • 16/2011. s. opinion on the EASA/IA Recommendation on best practices for behavioural online advertising;
  • Recommendation of the National Authority for Data Protection and Freedom of Information on the data protection requirements for prior information.

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