Privacy Policy

Adoption Date: 11/19/2019 

contents

Data Manager

Name: Trans-Europe Consulting Zrt.  

Headquarters: 1026 Budapest Torockó utca 4. mfsz. First 

Mailing address, complaint handling: 1026 Budapest Torockó utca 4. mfsz. First 

E-mail: info@trans-europe.hu 

Phone number: +361 392 0700 

Website: http://www.szoftverbolt.hu 

hosting Provider

Name: Bokor & Vizmeg GbR 

Mailing address: Kunigundenstr. 35. 91207 Lauf 

Email: info@pws-server.net 

Phone number: 004901723125986 

Description of Data Management During Webshop Information

on the use of cookies

What is a cookie?
The Data Controller uses so-called cookies when visiting the website. A cookie-alphanumeric information packet sent by our website to your browser in order to save certain settings, to facilitate our use of the website and to collect some relevant statistical information about our visitors. 

Some cookies do not contain personal information and are not capable of identifying an individual user, but some contain a unique identifier - a secret, randomly generated number - that is stored on your device, which also ensures that you are identifiable. The duration of each cookie is described in the respective cookie description.

Legal background and legal basis for cookies:

The legal basis for the processing of the data is your consent pursuant to Article 6 (1) (a) of the Regulation . 

The main features of cookies used by this website are:

Google Adwords cookie When a visitor visits our site, the visitor's cookie ID is added to the remarketing list. Google uses cookies, such as NID and SID cookies, to customize ads on Google products, such as Google Search. For example, you use such cookies to remember your recent searches, your previous interactions with each advertiser's ads or search results, and your visits to advertiser websites. AdWords Conversion Tracking uses cookies. To track sales and other conversions resulting from an ad, it saves cookies on the user's computer when that person clicks on an ad. Some common uses of cookies are: choosing ads based on what is relevant to a particular user, improving reporting on campaign performance, and avoiding ads that the user has already viewed. 

Google Analytics Cookie: Google Analytics is a Google analytics tool that helps website and app owners get a more accurate picture of their visitors' activity. The Service may use cookies to collect information and report statistics about your use of the Website without personally identifying your visitors to Google. The main cookie used by Google Analytics is the "__ga" cookie. In addition to reporting website usage statistics, Google Analytics, along with some of the advertising cookies described above, can also be used to serve more relevant ads on Google products (like Google Search) and across the web. 

Remarketing cookies: May appear to previous visitors or users when browsing other sites on the Google Display Network, or when searching for terms related to your products or services 

Strictly necessary cookies: These cookies are essential for the use of the website and allow us to use the basic functions of the website. Otherwise, many of the features of this site will not be available to you. The lifetime of these types of cookies is limited to the duration of the session. 

Cookies to improve the user experience: These cookies collect information about the user's use of the site, such as which pages you visit most often or error messages you receive from the site. These cookies do not collect visitor-identifying information, so they work with general, anonymous information. The data obtained from these are used to improve the performance of the website. The lifetime of these types of cookies is limited to the duration of the session. 

Session cookie: These cookies store the visitor's location, browser language, payment currency, lifetime of closing the browser, or up to 2 hours. 

Referral Cookies: Records the external site a visitor came to. They last until the browser closes. 

Last viewed product cookie: Records the items the visitor last viewed. Their lifetime is 60 days. 

Last viewed category cookie: Captures the last viewed category. Lifetime is 60 days. 

Recommended products cookie: The "recommend to a friend" feature records the list of products you want to recommend. Lifetime is 60 days. 

Mobile version, design cookie: Detects the visitor's device and switches to full view on mobile. Lifetime 365 days. 

Cookie Acceptance: When you arrive at the site, you accept the cookie declaration in the warning window. Lifetime 365 days. 

Shopping Cart Cookie: Locates items placed in the shopping cart. Lifetime 365 days. 

Smart Bid Cookie: Sets the conditions for displaying smart bids (e.g., whether a visitor was already on the page or if you have an order). Lifetime 30 days. 

Exit # 2 cookie: Option # 2 expires the visitor after 90 days. Lifetime is 90 days. 

Backend ID cookie: The ID of the backend server serving the page. It lasts until the browser closes. 

employee_login_last_email Keeps the email address when logging in until you close your browser. 

Ealrm, ealem, ealpw Provides Permanent access. Lifetime 180 days. 

come_from Access control redirects. Lifetime 10 minutes. 

currency Stores the buyer's currency. Lifetime 30 days. 

Facebook pixel (Facebook cookie) Facebook pixel is a code used to report conversions on a website, to compile target audiences, and to provide the site owner with detailed analysis of visitors' use of the website. With the help of Facebook pixel, you can display personalized offers and advertisements on the Facebook interface to the visitors of the website. You can read Facebook's Privacy Policy here: https://www.facebook.com/privacy/explanation 

If you do not accept the use of cookies, certain features will not be available to you. For more information about deleting cookies, visit the following links:

Data processed for contracting and performance purposes

There may be several cases of data management in order to conclude and fulfill the contract. Please be advised that any data processing related to complaint and warranty management will only take place if you exercise any of these rights.

If you do not make a purchase through the webshop, but only a visitor to the webshop, then what you have written about marketing data management may apply to you as long as you give us a marketing consent.

More detailed data management for contracting and performance:

Contact

For example, if you contact us about a product via email, contact form, or phone.

Pre-contact is not required, and you can leave it at any time from the webshop.


Managed Data

The data you provided when you contacted us.

Duration

of Data Management Data will only be processed until the contact is complete.

Legal basis for data management

Your voluntary consent to the Data Controller by contacting us. [Data management pursuant to Article 6 (1) (a) of the Regulation]

Registration on the website

By storing the data provided during the registration, the Data Controller can provide a more convenient service (eg the data of the data subject need not be re-entered at the time of purchase) Registration is a condition of contracting Managed Data 

In the course of data management, Data Controller manages your name, address, telephone number, email address, product characteristics and date of purchase.

Duration of data management

Until your consent is withdrawn.

Legal basis for data management

Your voluntary consent to the Data Controller upon registration [Data Management according to Article 6 (1) (a) of the Regulation]

Order processing

Processing of orders requires data management activities to fulfill the contract

Managed data

In the course of data management, the Data Controller manages your name, address, telephone number, e-mail address, product characteristics, order number and date of purchase.

If you have placed an order in the webshop, data management and data entry is essential for the performance of the contract.

Duration of data management

The data will be processed for 5 years according to the civil statute of limitations.

Legal basis for data management

Performance of the contract. [Data management pursuant to Article 6 (1) (b) of the Regulation]

Invoice issue

The data management process is performed in order to issue a statutory invoice and to fulfill the obligation to keep accounting documents. The St. Pursuant to Article 169 (1) to (2), companies must keep accounting documents in support of their accounting, either directly or indirectly.

Managed data

Name, address, email address, phone number.

Duration of data management

The invoices issued are in accordance with St. Pursuant to Article 169 (2), it must be kept for 8 years from the date of issue of the invoice.

Legal basis for data management

Act CXXVII of 2007 on Value Added Tax Pursuant to Article 159 (1), the issue of an invoice is mandatory and must be retained for 8 years pursuant to Article 169 (2) of Act C of 2000 on Accounting [data management pursuant to Article 6 (1) (c) of the Regulation].

Data management related to freight transport

The data management process takes place to deliver the ordered product.

Managed data

Name, address, email address, phone number.

Duration of data management

The Data Controller shall process the data until the delivery of the ordered goods.

Legal basis for data management

Execution of the contract [Data management within the meaning of Article 6 (1) (b) of the Regulation].

Guarantee service

The data management process is in place to handle warranty claims. If you have requested warranty service, data management and data entry is essential. 

Managed data

Customer name, phone number, email address, complaint content.

Duration of data management

Warranty claims are retained for 5 years under the Consumer Protection Act.

Legal basis for data management

Whether or not you will be contacted is your voluntary decision in the event of a warranty claim, but if so, the 1997 CLV on Consumer Protection. 17 / A. (7), we are obliged to keep the complaint for 5 years [Data management pursuant to Article 6 (1) (c) of the Regulation]

Treatment of other consumer complaints

The data management process is in place to deal with consumer complaints. If you have contacted us with a complaint, it is essential that you manage and provide data.

Managed data

Customer name, phone number, email address, complaint content.

Duration of data management

Warranty claims are retained for 5 years under the Consumer Protection Act.

Legal basis for data management

Whether or not you are complaining about your voluntary decision, but if you do, the 1997 CLV on Consumer Protection. 17 / A. (7), we are obliged to keep the complaint for 5 years [data management pursuant to Article 6 (1) (c) of the Regulation].

Data processed in relation to the verifiability of the consent

During the registration, ordering, signing up for the newsletter, the IT system will store the information related to the consent for later verification.

Managed Data

The date of consent and the IP address of the data subject.

Duration of data management

Due to legal requirements the consent has to be verified at a later date, therefore the data storage period is stored for a period of time after the termination of data management.

Legal basis for data management

Article 7 (1) of the Regulation requires this obligation. [Data management pursuant to Article 6 (1) (c) of the Regulation]

Data management for marketing purposes

Data management for newsletter sending

Managed data

Name, address, email address, phone number.

Duration of data management

Until the consent of the data subject is withdrawn.

Legal basis for data management

Your voluntary consent to the Data Controller by subscribing to the Newsletter [Data Management according to Article 6 (1) (a) of the Regulation]

Data management relating to the sending and display of personalized advertisements

Managed data

Name, address, email address, phone number.

Duration of data management

Until your consent is withdrawn.


Legal basis for data management

Your voluntary specific contribution to the Data Controller at the time of recording [Data Management according to Article 6 (1) (a) of the Regulation]

remarketing

Data management as a remarketing activity is implemented through cookies.

Managed Data

The data managed by the cookies specified in the cookie information.

Duration of data management The data

storage duration of a given cookie, more information is available here:

Google General Cookie Information: https://www.google.com/policies/technologies/types/ 

Google Analitycs Brief: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage?hl=en Facebook Brief https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen 

 

Legal basis for data management

Your voluntary consent to the Data Controller using the Website [Data Management under Article 6 (1) (a) of the Regulation].

Raffle

The data management process is conducted for the purpose of conducting the lottery.

Managed Data

Name, email address, telephone number.

Duration

of Data Management Data will be deleted after the end of the Sweepstakes, with the exception of the data of the winner, which, under the Accounting Act, is required to be retained by the Data Controller for 8 years.

Legal basis for data management

Your voluntary consent to the Data Controller using the Website. [Data management pursuant to Article 6 (1) (a) of the Regulation]

Further data management

If the Data Controller wishes to carry out further data processing, it shall provide prior information on the essential circumstances of the data processing (legal background and legal basis of data processing, purpose of data processing, scope of data processed, duration of data processing).

Please be advised that written requests for information by law from the authorities must be complied with by the Data Controller. Data Controller on data transfers is provided in Infotv. In accordance with Article 15 (2) - (3), it shall keep records (to which authority, what personal data, on what legal basis, when the Data Controller was transmitted), the content of which shall be provided by the Data Controller upon request, unless its disclosure is prohibited by law.

Your use of a data processor and their data management activities

Processing of personal data

The data processor is named Bokor & Vizmeg GbR 

Contact details of the data processor:

Phone number: 004901723125986 

Email: info@pws-server.net 

Head office: Kunigundenstr. 35. 91207 Lauf 

The Data Processor stores personal data on the basis of a contract with the Data Controller. You are not entitled to access personal information.

Data processing activities related to freight transport

Name of the data processor: GLS General Logistics Systems Hungary Package Logistics Ltd. 

Registered office: 2351 Alsónémedi, GLS Európa u. Second 

Data processor telephone number: + 36-29 / 88 66 70  

Data Processor's e-mail address: info@gls-hungary.com Data Processor participates in the delivery of the ordered goods on the basis of a contract with the Data Controller. In doing so, the Data Processor may manage the name, address and telephone number of the customer until the end of the calendar year following the date of dispatch of the postal item and thereafter delete it immediately. 

Name of the data processor: TNT Express Hungary Kft. 

Registered office: 1185 Budapest II. Logistics Center - Office Building, BUD International Airport Building 283 

The processor's telephone number is +36 80 31 3131  

Data processor's e-mail address: The data processor

participates in the delivery of the ordered goods on the basis of a contract concluded with the Data Controller. In doing so, the Data Processor may manage the name, address and telephone number of the customer until the end of the calendar year following the date of dispatch of the postal item and thereafter delete it immediately.

Data processing activities related to newsletters

Name of the company operating the newsletter system: Mini CRM Zrt. 

Headquarters of the company operating the newsletter system: 1075 Budapest Madách Imre út 13-14. 

The company that operates the newsletter system is 06 (1) 999-0402 

E-mail address of the company that operates the newsletter system: help@minicrm.hu 

The Data Processor participates in the sending of newsletters on the basis of the contract concluded with the Data Controller. In doing so, the Data Controller shall manage the data subject's name and e-mail address to the extent necessary for sending the newsletter, and shall delete it immediately upon request of the data subject.

Invoicing data processing

Name of the data processor: TRL Hungary Kft. 

Registered office: 1036 Budapest Tímár u. 5th 

The processor's phone number is +36 1 388 9850  

Data Processor Email:

The Data Processor participates in the registration of accounting documents on the basis of the contract concluded with the Data Controller. In doing so, the Data Processor shall, to the extent necessary for the accounting records, name and address of the data subject, in accordance with St. It shall be treated for a period consistent with Article 169 (2) and thereafter canceled.

Data processing relating to the operation of a CRM system

Name of the data processor: Mini CRM Zrt. 

Registered office: 1075 Budapest Madách Imre út 14 

The processor's phone number is +36 1 999 0402  

Data Processor Email:

The Data Processor participates in the registration of orders on the basis of the contract concluded with the Data Controller. In doing so, the Data Processor shall manage the data subject's name, address, telephone number, order number and date within the civil limitation period.

Processing of data relating to online payment

Name of the data processor: Budapest Bank Zrt. 

Registered office: 1138 Budapest, Váci út 193. 

The processor's phone number is +36 1 450-6000  

The e-mail address of the data processor is info@budapestbank.hu 

The Data Processor participates in the execution of the Online payment on the basis of the contract concluded with the Data Controller. In doing so, the Data Processor shall manage the billing name and address of the data subject, as well as the order number and date, within the civil statute of limitations.

Name of the data processor: Barion Payment Zrt. 

Registered office: 1117 Budapest Infopark sétány 1. 

Data processor telephone number: +36 1 464 70 99  

The e-mail address of the data processor is hello@barion.hu 

The Data Processor participates in the execution of the Online payment on the basis of the contract concluded with the Data Controller. In doing so, the Data Processor shall manage the billing name and address of the data subject, as well as the order number and date, within the civil statute of limitations.

Transfer of data to a third country

SAMPLE

The following data processor is located outside the European Union and processes the data outside the European Union. The data processor is a party to the Privacy Shild List, which ensures that the data is handled with the guarantees provided in the European Union. More information is available at: www.privacyshild.gov Google LLC (sending, receiving, storing email)  

Keith Enright Chief Privacy Officer

Google Data Protection Office

1600 Amphitheater Parkway

Mountain View, California 94043

Email: privacy-shield-google@google.com 

Phone: (650) 253-0000 https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI 


 

Your rights during data processing

During the period of data processing, you are entitled to the following rights under the provisions of the Regulation:

  • the right to withdraw consent
  • access to personal data and information related to data management
  • the right to rectification
  • restriction of data management,
  • the right to delete
  • right to protest
  • the right to portability.

If you wish to exercise your rights, this will entail your identification and the Data Controller will need to communicate with you. Therefore, you will be required to provide personal information for identification purposes (however, identification may only be based on data that is otherwise handled by you in the Data Controller) and your data management complaint will be made available in the Controller's email account within the timeframe specified in these complaints. If you were a customer and would like to identify yourself for complaints or warranty purposes, please also provide your order ID for identification. By using this, we can identify you as a customer.

Complaints about data management must be answered within 30 days by the Data Controller.

Right of withdrawal of consent

You have the right to withdraw your consent to data processing at any time, in which case the data you provide will be deleted from our systems. However, please note that for orders that have not yet been fulfilled, cancellation may result in us being unable to deliver to you. In addition, once your purchase has been completed, we will not be able to delete billing information from our systems in accordance with your accounting requirements, and if you owe it to us, we may process your information based on a legitimate interest in collecting your claim if your consent is withdrawn.

Access to personal data

You have the right to receive feedback from the Data Controller as to whether your personal data is being processed and, if data processing is in progress, to:

  • have access to the personal data processed and
  • please inform the Data Controller of the following information:
    • the purposes of data management;
    • the categories of personal data processed about you;
    • information on the recipients or categories of recipients to whom the Personal Data have been or will be disclosed by the Data Controller;
    • the intended period for which the personal data will be stored or, if this is not possible, the criteria for determining this period;
    • your right to request from the Data Controller the rectification, erasure or limitation of your processing of personal data concerning you and to object to the processing of such personal data in the event of a legitimate interest;
    • the right to lodge a complaint to the supervisory authority;
    • if the data were not collected from you, all available information on their source;
    • the fact of automated decision making (if applicable), including profiling, and at least in these cases, understandable logic and the significance and expected consequences of such data management for you.

The purpose of exercising the right may be to establish and verify the lawfulness of the data management, and therefore, in the event of multiple requests for information, the Data Controller may charge a reasonable fee in exchange for the provision of the information.

Access to personal data is provided by the Data Controller by emailing you with your personal data and information that you manage, once you have been identified. If you have a registration, we will grant you access by logging in to your account to view and verify the personal information about you.

Please indicate in your application whether you are requesting access to personal data or requesting information on data management.

Right to rectification

You have the right to request the Data Controller to correct any inaccurate personal information about you without delay.

Right to Restrict Data Management

You are entitled to request that the Data Controller restrict your data management if any of the following is true:

  • You dispute the accuracy of your personal data, in which case the limitation applies to the period of time that allows the Data Controller to verify the accuracy of your personal information;
  • the data processing is unlawful, but you are against the deletion of the data for any reason (for example, because the data are important to you because of a legal claim) and therefore do not request the deletion of the data, but instead request a restriction on their use;
  • the Data Controller no longer needs personal data for the purposes of the marked data processing, but you request it for the purpose of making, enforcing or defending legal claims; or
  • You have objected to the data management, but it may also be in the legitimate interest of the Data Controller to justify the data management, in which case data processing must be limited until it is determined whether the Data Controller's legitimate reasons take precedence over your legitimate reasons.

Where personal data processing is subject to restrictions, such personal data may be processed, except for storage, only with the consent of the data subject or for the purpose of submitting, asserting or defending legal claims or other natural or legal persons or of an important public or Union interest.

The Data Controller will inform you in advance (at least 3 working days prior to the lifting of the restriction).

The right to delete - the right to forget

You are entitled to have your personal data deleted by you without undue delay if any of the following applies:

  • the personal data are no longer needed for the purpose for which they were collected or otherwise processed by the Data Controller;
  • You withdraw your consent and there is no other legal basis for data processing;
  • You object to data processing based on a legitimate interest and there is no overriding legitimate reason (ie a legitimate interest) to control the data,
  • the personal data was unlawfully processed by the Data Controller and ascertained from the complaint,
  • personal data must be deleted in order to comply with a legal obligation under Union or Member State law applicable to the Data Controller.

If the Data Controller has, for any lawful reason, disclosed Personal Data processed about you and is required to delete it for any of the reasons set forth above, it shall take reasonable steps, including technical measures, to inform the Data, taking into account the available technology and implementation costs other data controllers that you have requested that links to, or duplicate or duplicate, such personal data be deleted.

Deletion shall not apply where processing is necessary:

  • for the exercise of the right to freedom of expression and information;
  • to fulfill an obligation under EU or Member State law applicable to the controller for the processing of personal data (in this case, billing data management as the retention of the account is required by law) or in the public interest or in the exercise of public authority delegated to the controller;
  • to assert, enforce or defend legal claims (eg if the Data Controller has a claim against you and has not yet fulfilled it, or a consumer or data processing complaint is pending).

Right to protest

You have the right to object at any time to the processing of your personal data for legitimate reasons related to your situation. In this case, the Data Controller may not further process the personal data unless it proves that the processing is justified by compelling legitimate reasons that take precedence over your interests, rights and freedoms, or that are related to the filing, enforcement or defense of legal claims.

If your personal data is being processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for this purpose, including profiling, if it is related to direct marketing. If you object to the processing of personal data for the purpose of direct marketing, personal data may no longer be processed for this purpose.

Right to portability

If the data processing is done in an automated way, or if the data processing is based on your voluntary consent, you have the right to request the Data Controller to receive the data you provide to the Data Controller in xml, JSON or csv format. if technically feasible, you may request the Data Controller to transfer the data in this form to another Data Controller.

Automated Decision Making

You have the right not to be subject to any decision based solely on automated data management (including profiling) that would have legal effect or would have a significant impact on you. In such cases, the Data Controller shall take appropriate measures to protect the rights, freedoms and legitimate interests of the data subject, including at least the right of the data subject to request human intervention, to express his or her views and to object to the decision. 

The foregoing shall not apply where the decision:

  • Necessary for the conclusion or performance of a contract between you and the controller;
  • it is made possible by Union or national law applicable to the controller, which also lays down appropriate measures to protect your rights and freedoms and legitimate interests; or
  • is based on your explicit consent.

Signing in to the Privacy Register

Infotv. of the Act, the Data Controller had to report certain data processing operations to the Data Protection Register. This reporting obligation expired on May 25, 2018.

NAIH Number Registered before May 25, 2018:
Privacy Registration Number : NAIH-137290/2018

Data security measures

The Data Controller declares that it has taken appropriate security measures to protect personal data against unauthorized access, alteration, transfer, disclosure, deletion or destruction, as well as accidental destruction and damage, or from access due to changes in the technology used.

Data Controller will do everything within its organizational and technical capabilities to ensure that its data processors also take appropriate data security measures when handling your personal data.

Remedies

If you believe that the Data Controller has violated a provision of the Data Processing Act or has not complied with your request, you may initiate an investigation by the National Data Protection and Freedom of Information Authority to remove suspected unlawful data processing (mailing address: 1530 Budapest, PO Box 5, e- mail: ugyfelszolgalat@naih.hu).

In addition, please be advised that in the event of a violation of the data processing laws or of any failure by the Data Controller to comply with your request, you may institute civil proceedings against the Data Controller in court. 

Modifying the Privacy Notice

The Data Controller reserves the right to modify this Privacy Policy in a manner that does not affect the purpose and legal basis of the data management. By using this website after the change comes into effect, you accept the modified privacy notice.

If the Data Controller intends to further process the data collected for purposes other than the purpose for which they were collected, it will inform you of the purpose of the data processing and the following information:

  • the length of time for which the personal data will be stored or, where this is not possible, the criteria for determining the duration;
  • your right to request from the Data Controller access to, rectification, erasure or restriction of your personal data and to object to the processing of personal data in the case of legitimate interest processing, and to consent to data portability for consent or contractual relationship rights;
  • in the case of consent-based data processing, that you may withdraw your consent at any time,
  • the right to lodge a complaint to the supervisory authority;
  • whether the provision of personal data is based on a legal or contractual obligation or prerequisite for entering into a contract, and whether you are required to provide personal data and the potential consequences of failure to disclose it;
  • the fact of automated decision making (if applicable), including profiling, and at least in these cases, understandable logic and the significance and expected consequences of such data management for you.

The data management can only start after this, if the legal basis of the data management is consent, in addition to the information you have to give your consent to the data management.

This document contains all relevant data management information regarding the operation of the webshop in accordance with the General Data Protection Regulation of the European Union 2016/679 (hereinafter: "Regulation. GDPR") and the 2011 CXII. TV. (hereinafter referred to as "Info").

 

Postal and postal delivery

Please note that Magyar Posta Zrt. Identifies the addressee in accordance with the prevailing data management information, and may, where appropriate, require you to provide your personal information upon delivery by post or postal delivery.