Sylverro Kft. (Molett Divat) is committed to the protection of personal data. This notice sets out, in accordance with the GDPR (Regulation (EU) 2016/679), what data we process, for what purpose and on what legal basis, as well as what rights you are entitled to.
Sylverro Kereskedelmi és Szolgáltató Kft. (as data controller) sets out in the following notice its data processing activities connected with the operation of the molettdivat.hu webshop, on the basis of Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation, "GDPR"). This privacy notice regulates the data processing of the www.molettdivat.hu website and its subdomains, and is continuously available at https://www.molettdivat.hu/adatvedelem. Amendments to the notice enter into force upon publication at the above address.
Name: Sylverro Kereskedelmi és Szolgáltató Kft.
Registered seat: 2143 Kistarcsa, Baross G. utca 11.
E-mail: info@molettdivat.hu
Phone: +36 70 538 2467
personal preferences, interests, reliability, behaviour, location or movements.
Personal data:
The controller is responsible for compliance with the above, and must be able to demonstrate this compliance (" accountability ").
The controller declares that its data processing takes place in accordance with the principles set out in this point.
1. The fact of the data collection, the scope of the data processed and the purpose of the processing :
Personal data
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Purpose of the processing
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Legal basis
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Name, phone number, e-mail address
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Identification, keeping contact, consultation
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Article 6(1)(b) GDPR.
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Settlement, size of the area | Making an on-site survey possible |
Article 6(1)(b) GDPR.
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Name of the area, time of installation | Making an on-site survey possible |
Article 6(1)(b) GDPR.
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Message
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Necessary for drawing up and customising the offer.
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Article 6(1)(b) GDPR.
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Time of the enquiry
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Execution of a technical operation.
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Article 6(1)(b) GDPR.
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IP address at the time of the enquiry
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Execution of a technical operation.
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Article 6(1)(b) GDPR.
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2. The scope of the data subjects : All data subjects who request an offer (request an on-site survey) on the website.
3. The duration of the data processing, the deadline for erasing the data : If one of the conditions set out in Article 17(1) of the GDPR exists, it lasts until the data subject's erasure request.
4. The identity of the possible controllers entitled to become acquainted with the data, the recipients of the personal data : The personal data may be processed by the controller's staff authorised for this purpose.
5. Presentation of the data subjects' rights relating to the data processing :
6. The data subject can initiate access to the personal data , their erasure, modification, or the restriction of their processing, and the portability of the data, in the following ways :
7. The legal basis of the data processing : the consent of the data subject, Article 6(1)(a), (b) and (c). If you contact us, you consent to us processing, in accordance with these rules, the personal data (name, phone number, e-mail address) that came to us during the contact.
8. We inform you that
Personal data
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Purpose of the processing
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Legal basis
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Name, e-mail address
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Identification
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Article 6(1)(a)
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Website
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Data collection
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Article 6(1)(a)
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Content of the comment
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Displaying the comment
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Article 6(1)(a)
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Time of the comment
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Execution of a technical operation.
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Article 6(1)(a)
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IP address at the time of the comment
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Execution of a technical operation.
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Article 6(1)(a)
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In the case of the e-mail address, it is not necessary for it to contain personal data.
2. The scope of the data subjects : All data subjects who comment on the blog posts.
3. The duration of the data processing, the deadline for erasing the data : If one of the conditions set out in Article 17(1) of the GDPR exists, it lasts until the data subject's erasure request.
4. The identity of the possible controllers entitled to become acquainted with the data, the recipients of the personal data : The personal data may be processed by the controller's staff authorised for this purpose.
5. Presentation of the data subjects' rights relating to the data processing :
6. The data subject can initiate access to the personal data , their erasure, modification, or the restriction of their processing, and the portability of the data, in the following ways :
7. The legal basis of the data processing : the consent of the data subject, Article 6(1)(a). If you comment on the blog posts, you consent to us processing, in accordance with these rules, the personal data (name, phone number, e-mail address) that came to us during the comment.
8. We inform you that
This point regulates the processing of the contact-person data of natural persons (data subjects) acting on behalf of the controller's business partners or other customers.
1. The fact of the data collection, the scope of the data processed and the purpose of the processing:
Personal data
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Purpose of the processing
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Legal basis
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Name, e-mail address, phone number, other contact-person data appearing in the contract.
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Keeping contact, cooperation, conclusion of the contract, fulfilment of rights and obligations arising from the contract.
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In the case of legal persons: Article 6(1)(f) (the controller's legitimate interest),
In the case of sole traders: Article 6(1)(b).
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2. The source of the data:
3. The scope of the data subjects: All data subjects in a contractual legal relationship with the controller, as well as natural persons acting on behalf of the controller's business partners.
4. The duration of the data processing, the deadline for erasing the data: The data processing lasts until the termination of the legal relationship between the controller and the business partner, or, in the case of claims, until the statute of limitations.
5. The identity of the possible controllers entitled to become acquainted with the data, the recipients of the personal data : The personal data may be processed by the controller's staff authorised for this purpose, with respect for the above principles.
6. Presentation of the data subjects' rights relating to the data processing :
7. The data subject can initiate access to the personal data , their erasure, modification, or the restriction of their processing, and the portability of the data, in the following ways :
8. The legal basis of the data processing :
Section 6:22 [Limitation]
(1) Unless otherwise provided by this Act, claims lapse in five years.
(2) The limitation period begins when the claim falls due.
(3) An agreement aimed at changing the limitation period must be put in writing.
(4) An agreement excluding limitation is void.
9. We inform you that
1. Pursuant to Section 6 of Act XLVIII of 2008 on the basic conditions and certain restrictions of commercial advertising activity, the User may give prior and express consent to the Service Provider contacting them with its advertising offers and other consignments at the contact details provided during registration.
2. Furthermore, bearing in mind the provisions of this notice, the Customer may consent to the Service Provider processing their personal data necessary for sending the advertising offers.
3. The Service Provider does not send unsolicited advertising messages, and the User may unsubscribe from the sending of offers without restriction and without justification, free of charge. In this case, the Service Provider erases from its records all personal data of the User necessary for sending advertising messages, and does not contact the User with its further advertising offers. The User may unsubscribe from the advertisements by clicking on the link in the message.
4. The fact of the data collection, the scope of the data processed and the purpose of the processing :
Personal data
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Purpose of the processing
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Legal basis
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Name, e-mail address.
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Identification, making it possible to subscribe to the newsletter/promotional coupons.
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The consent of the data subject,
Article 6(1)(a).
Section 6(5) of Act XLVIII of 2008 on the basic conditions and certain restrictions of commercial advertising activity.
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Time of the subscription
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Execution of a technical operation.
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IP address at the time of the subscription
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Execution of a technical operation.
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5. The scope of the data subjects : All data subjects who subscribe to the newsletter.
6. The purpose of the data processing: sending electronic messages containing advertising (e-mail, sms, push message) to the data subject, providing information about current information, products, promotions, new functions, etc.
7. The duration of the data processing, the deadline for erasing the data: The data processing lasts until the withdrawal of consent (until unsubscription, until the data subject's erasure request), or until the discontinuation of the newsletter.
8. The identity of the possible controllers entitled to become acquainted with the data, the recipients of the personal data : The personal data may be processed by the controller, as well as its sales and marketing staff, with respect for the above principles.
9. Presentation of the data subjects' rights relating to the data processing :
10. The data subject can initiate access to the personal data , their erasure, modification, or the restriction of their processing, the portability of the data, or their objection, in the following ways :
11. The data subject may unsubscribe from the newsletter free of charge at any time.
12. We inform you that
" recipient ": a natural or legal person, public authority, agency or other body, to which the personal data are disclosed, whether a third party or not.
1. Processors (who carry out the data processing on behalf of the controller)
The controller engages processors for the purpose of facilitating its own data processing activities, and further in order to fulfil the obligations imposed by the contract concluded with the data subject and by the legislation.
The controller places great emphasis on engaging exclusively processors who provide sufficient guarantees to implement appropriate technical and organisational measures ensuring compliance with the requirements of the GDPR relating to data processing and the protection of the rights of the data subjects.
The processor and any person acting under the authority of the controller or the processor who has access to the personal data processes the personal data set out in these rules exclusively in accordance with the controller's instructions.
The controller bears legal liability for the processor's activities. The processor bears liability for the damage caused by the processing only if it has not complied with the obligations of the GDPR specifically addressed to processors, or if it has acted outside or contrary to the lawful instructions of the controller.
The processor has no substantive decision-making power concerning the processing of the data.
The controller may engage, as a processor, a hosting provider to ensure the IT background, and a courier service to deliver the ordered products.
2. The individual processors
Processing activity
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Name, address, contact details
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Hosting service
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EZM Informatikai Szolgáltató és Kereskedelmi Bt. 1139 Budapest, Röppentyű u. 25-29. info@ezm.hu
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Other processor (e.g. online invoicing, web development, marketing)
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Hubspot – https://www.hubspot.com/
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" third party ": 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 authorised to process the personal data.
3. Transfer of data to a third party
The third-party controllers process the personal data disclosed by us in their own name, in accordance with their own privacy policies.
Activity of the controller
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Name, address, contact details
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Transport
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None
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Online payment
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None
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1. For the use of the so-called "cookie used for a password-protected session", "cookies necessary for the shopping basket", "security cookies", "Necessary cookies", "Functional cookies", and "cookies responsible for managing the website's statistics", it is not necessary to request prior consent from the data subjects.
2. The fact of the data processing, the scope of the data processed: Unique identification number, dates, times.
3. The scope of the data subjects: All data subjects visiting the website.
4. The purpose of the data processing: Identification of the users, tracking of visitors, ensuring customised operation.
5. The duration of the data processing, the deadline for erasing the data:
Type of cookie
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Legal basis of the data processing
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Data processing
duration
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Session cookies, or other cookies indispensably necessary for the operation of the website
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No data processing takes place with the use of the cookie.
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The period until the end of the relevant visitor session, i.e. it remains on the computer only until the browser is closed.
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Statistical, marketing cookies
| Article 6(1)(a) of the GDPR |
1 day – 2 years, in accordance with the cookie notice, or the data processing lasts until the withdrawal of the data subject's consent.
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6. The identity of the possible controllers entitled to become acquainted with the data: The personal data may be accessed by the controller.
7. Presentation of the data subjects' rights relating to the data processing: The data subject has the option to delete the cookies in the Tools/Settings menu of the browsers, generally under the settings of the Privacy menu item.
8. Most of the browsers that our users use make it possible to set which cookies should be saved and make it possible for (specified) cookies to be deleted again. If you restrict the saving of cookies on specified websites or do not allow third-party cookies, then this may, in certain circumstances, lead to our website no longer being fully usable. Here you will find information on how, in the case of the usual browsers, you can customise the cookie settings:
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 )
Google Tag Manager is a service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"), which makes it possible to create, update and manage tags. Tags are small code elements on our website which serve, among other things, to measure traffic and visitor behaviour, as well as to determine the effect of online advertisements and social channels. When you visit our website, the current tag configuration is sent to your browser. In this way, you receive instructions on which tags to activate. The tool itself does not collect any personal data, but it ensures the activation of other tags which may, however, potentially collect data. Further information about the operation of Google Tag Manager is available at the following link: https://support.google.com/tagmanager/#topic=3441530
The Meta pixel is a piece of code with the aid of which a report on conversions is prepared on the website, target audiences can be compiled, and the owner of the page receives detailed analytics data about the visitors' use of the website. With the aid of the Meta remarketing pixel tracking code, personalised offers and advertisements can be displayed to the website's visitors on the Facebook surface. The Meta remarketing list is not suitable for personal identification. You can find further information in connection with the Meta Pixel here: https://www.facebook.com/business/help/651294705016616
The controller has a Facebook / Meta profile relating to its activity. The statistical data processing carried out on the Facebook social media page is a joint controllership of the Controller and Facebook Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, D2 Dublin, Ireland). Detailed information about the details of the joint controllership agreement is provided by the controller addendum of the Facebook Page Insights function. The addendum is available
at the following link: https://www.facebook.com/legal/terms/page_controller_addendum
The controller communicates by private message on the social media page exclusively if you contact us there.
1. Categories of data subjects
2. The purpose of the data processing
The purpose of the data processing is the sharing and promotion of the controller's activity and service on the Facebook social media page. The Controller may use the data provided by the data subject in a private message in order to give a reply to the message; otherwise, the Controller does not collect data via the social media pages and does not extract data from there.
3. The legal basis of the data processing
The data processing is based on Article 6(1)(a) of the GDPR; the legal basis of the data processing is the consent of the data subject to the processing of their personal data on the Facebook social media page.
4. The scope of the data processed
5. The source of the personal data processed: The source of the data processed is the data subject.
6. Withdrawal of consent: You can withdraw your consent given to the data processing at any time; you can delete your post or comment. The data processing takes place via the social media pages, which are operated by a third party.
If you withdraw your consent, the Controller deletes the conversation conducted with you. The withdrawal of consent does not affect the lawfulness of the consent-based processing carried out before the withdrawal.
The data subject can initiate access to the personal data, their erasure, modification, or the restriction of their processing, and the portability of the data, in the following ways:
7. The duration of the data processing
8. The transfer of the personal data, their recipients, and the categories of recipients: For the concept of the recipient, see Article 4(9) of the GDPR. The Controller transfers the personal data of the data subject to state organs, authorities ‐ in particular a court, prosecutor's office, investigating authority and misdemeanour authority, the National Authority for Data Protection and Freedom of Information – only in exceptional cases and on the basis of a legal obligation.
9. The possible consequences of the failure to provide the data
In the case of the failure to provide the data, the data subject cannot obtain information via the Facebook social media page about the Controller's activity and services, and cannot send a message to the Controller via Facebook Messenger.
10. Automated decision-making (and profiling): During the data processing, no automated decision-making, including profiling, takes place.
11. The joint controllership agreement concluded with Facebook Ireland Ltd.:
The Page Insights function displays aggregated data with the aid of which it is transparent how the data subjects use the Facebook page. Facebook Ireland Limited ("Facebook Ireland") and the Controller are joint controllers with respect to the processing of the insights data. The Page Insights addendum defines the responsibility of Facebook Ireland and the responsibility of the Controller in connection with the processing of the insights data. Facebook Ireland assumes primary responsibility under the GDPR for the processing of the insights data, and undertakes to comply with all relevant obligations prescribed in the GDPR in connection with the processing of the insights data. In addition, Facebook Ireland makes an extract of the Page Insights addendum available to every data subject. The Controller ensures that it has an appropriate legal basis under the GDPR for the processing of the insights data, identifies the controller of the page, and complies with all other relevant legal obligations. Facebook Ireland has sole responsibility for the processing of personal data in connection with the Page Insights function, except for the data falling within the scope of the Page Insights addendum. The Page Insights addendum does not provide the Controller with the right to request the personal data of Facebook users that Facebook Ireland processes in connection with Facebook, including the page insights data. The Controller may not act and may not give a reply on behalf of Facebook Ireland in the course of fulfilling data protection requests.
1. The right of access
You have the right to obtain from the controller confirmation as to whether or not the processing of your personal data is taking place, and, where that is the case, you have the right to obtain access to the personal data and to the information listed in the Regulation.
2. The right to rectification
You have the right to obtain from the controller 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 – among other things, by means of providing a supplementary statement.
3. The right to erasure
You have the right to obtain from the controller the erasure of personal data concerning you without undue delay, and the controller is obliged to erase personal data concerning you without undue delay in the case of specified conditions.
4. The right to be forgotten
Where the controller has made the personal data public and is obliged to erase them, taking account of available technology and the cost of implementation, it takes reasonable steps – including technical measures – to inform the controllers which are processing the data that you have requested the erasure of any links to, or copy or replication of, those personal data.
5. The right to restriction of processing
You have the right to obtain from the controller restriction of processing where one of the following applies:
6. The right to data portability
You have the right to receive the personal data concerning you, which you have provided to a controller, in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided (…)
7. The right to object
In the case of data processing based on the legal bases of legitimate interest or the exercise of official authority, you have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data (…), including profiling based on those provisions.
8. Objection in the case of direct marketing
Where personal data are processed for the purposes of direct marketing, you have the right to object at any time to the processing of your personal data for such purposes, including profiling to the extent that it is related to such direct marketing. If you object to the processing of the personal data for the purposes of direct marketing, then the personal data may no longer be processed for such purposes.
9. Automated individual decision-making, including profiling
You have the right not to be subject to a decision based solely on automated processing – including profiling – which produces legal effects concerning you or similarly significantly affects you.
The previous paragraph does not apply if the decision:
The controller informs you without undue delay, but in any case within 1 month of the receipt of the request, about the actions taken in response to the above requests.
If necessary, this can be extended by 2 months . The controller informs you about the extension of the deadline, with an indication of the reasons for the delay, within 1 month of receiving the request.
If the controller does not take action in response to your request, it informs you without delay, but at the latest within one month of the receipt of the request, of the reasons for not taking action , and of the fact that you may lodge a complaint with a supervisory authority and exercise your right to a judicial remedy.
Taking into account the state of the art and technology and the costs of implementation, as well as the nature, scope, context and purposes of the processing and the risk of varying likelihood and severity for the rights and freedoms of natural persons, the controller and the processor implement appropriate technical and organisational measures in order to ensure a level of data security appropriate to the degree of the risk, including, among other things, as appropriate:
In the interest of the security of the personal data processed on paper, the Service Provider applies the following measures ( physical protection ):
IT protection
If the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, the controller informs the data subject without undue delay.
In the information given to the data subject, the nature of the personal data breach must be described clearly and in plain language , and the name and contact details of the data protection officer or other contact point providing further information must be communicated; the likely consequences arising from the personal data breach must be described; the measures taken or planned by the controller to remedy the personal data breach must be described, including, where appropriate, measures aimed at mitigating any possible adverse consequences arising from the personal data breach.
The data subject does not need to be informed if any of the following conditions is met:
If the controller has not yet notified the data subject of the personal data breach, the supervisory authority, having considered whether the personal data breach is likely to result in a high risk, may order the informing of the data subject.
The controller notifies the personal data breach to the supervisory authority competent under Article 55 without undue delay and, where feasible, not later than 72 hours after having become aware of the personal data breach, unless the personal data breach is unlikely to result in 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 serving to justify the delay.
If the duration of the mandatory data processing, or the periodic review of its necessity, is not determined by an act of law, a decree of a local government, or a mandatory legal act of the European Union, the controller reviews at least every three years from the commencement of the data processing whether the processing of the personal data processed by it, or by the processor acting on its behalf or on its instruction, is necessary for realising the purpose of the data processing.
The controller documents the circumstances and result of this review, keeps this documentation for ten years following the performance of the review , and makes it available to the National Authority for Data Protection and Freedom of Information (hereinafter: the Authority) at the Authority's request.
A complaint against a possible infringement by the controller may be lodged with the National Authority for Data Protection and Freedom of Information:
National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság)
1055 Budapest, Falk Miksa utca 9-11.
Mailing address: 1363 Budapest, Pf. 9.
Phone: +36 -1-391-1400
Fax: +36-1-391-1410
E-mail: ugyfelszolgalat@naih.hu
In preparing this notice, we had regard to the following legislation:
Dated: Kistarcsa, 7 July 2026.
This notice was prepared in accordance with the GDPR in force at any given time and the relevant Hungarian legislation. In the case of a question or a data-subject request, we are at your disposal at our contact details.