Privacy policy

Privacy notice

Introduction

The operator of the website,  SCHLOSSER-MESTER Industrial and Commercial Ltd. (seat: 81 Algyői street, 6727 Szeged, Hungary út 81., tax number: 13997094-2-06) (hereinafter referred to as the Service Provider, Data Controller) hereby submits to the following privacy 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 Notice governs the website www.smablak.hu and other data processing by the data controller.

It is available at: www.smablak.hu/adatkezeles

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

 

The data controller and its contact details

Name: SCHLOSSER-MESTER Industrial and Commercial Ltd.

Seat: 81 Algyői street, 6727 Szeged, Hungary

E-mail: 

Phone: +36 70 388 4485
               +36 62 486 596

 

DEFINITIONS

  1. 'personal data' means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
  2. 'processing' means any operation or set of operations which is performed upon personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
  3. 'controller' means a natural or legal person, public authority, agency or any other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of the processing are determined by Union or Member State law, the controller or specific criteria for the designation of the controller may also be determined by Union or Member State law;
  4. 'processor' means a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller;
  5. 'recipient' means a natural or legal person, public authority, agency or any other body to whom or with which personal data are 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. 'consent of the data subject' means a freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she signifies, by a statement or by an act expressing his or her unambiguous consent, that he or she signifies his or her agreement to the processing of personal data relating to him or her;
  7. 'personal data breach' means a breach of security leading to 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

  • The processing of personal data must be lawful, fair and transparent for the data subject ('lawfulness, fairness and transparency');
  • Personal data should be collected only for specified, explicit and legitimate purposes and not processed in a way incompatible with those purposes; further processing for archiving purposes in the public interest, scientific and historical research purposes or statistical purposes ('purpose limitation') shall not be considered incompatible with the original purpose in accordance with Article 89(1);
  • Personal data must be adequate, relevant and limited to what is necessary for the purposes for which they are processed ('data minimisation');
  • The personal data must 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');
  • Personal data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be kept for longer periods only if the personal data will be processed for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1), subject to the implementation of appropriate technical and organisational measures as provided for in this Regulation to safeguard the rights and freedoms of data subjects ('limited storage');
  • Personal data shall be processed in such a way as to ensure adequate security of personal data, including protection against unauthorised or unlawful processing, accidental loss, destruction or damage ('integrity and confidentiality'), by implementing appropriate technical or organisational measures.

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

 

DATA MANAGEMENT

Sending a message, placing an order, contacting us

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

Personal data

Name, e-mail address, telephone, address. Purpose of processing: contact, identification.

The time the message was sent. Purpose of processing: to carry out a technical operation.

IP address at the time of sending the message. Purpose of processing: to carry out a technical operation.

  1. Data subjects: all data subjects sending a message or placing an order/requesting a quote on the website.
  2. Duration of processing, deadline for erasure of data: processing lasts until the data subject requests erasure.
  3. Identity of the potential controllers who may access the data, recipients of personal data: personal data may be processed by the controller, in compliance with the above principles.
  4. 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 concerning him or her
  • he/she can object to the processing of such personal data
  • he/she has the right to data portability and to withdraw consent at any time.
  1. The data subject may initiate the access to, deletion, modification or restriction of processing of personal data, data portability and objection to processing in the following ways:
  • by post to the address 81 Algyői street, 6727 Szeged, Hungary
  • by e-mail to 
  1. Legal basis for processing: the data subject's consent, Article 6 (1) (a), Article 5 (1) of Act CXII of 2011 on the Right of Informational Self-Determination and Freedom of Information, and Article 13/A (3) of Act CVIII of 2001 on certain issues of electronic commerce services and information society services:

The service provider may process personal data which 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 the information society service 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 specified in this Regulation, but only to the extent and for the duration necessary.

  1. Please be informed that
  • the processing is based on your consent.
  • you are obliged to provide personal data so that we can respond to your request.
  • failure to provide the data will result in our inability to comply with the request.

 

THE DATA PROCESSORS INVOLVED

  1. The activity performed by the processor and the name and contact details of the processor:

Hosting provider

IntroWeb Ltd.
Tax number: 13037176-2-06
Registration number: 06-09-008564
Seat: 5 Gelei József street, 6724 Szeged, Hungary
Phone: (+36) 20 414 2574

Technical background

IntroWeb Ltd.
Tax number: 13037176-2-06
Registration number: 06-09-008564
Seat: 5 Gelei József street, 6724 Szeged, Hungary
Phone: (+36) 20 414 2574

  1. Processing of data, scope of data processed: all personal data provided by the data subject.
  2. Data subjects: all data subjects who use the website and all data subjects processed by the controller.
  3. Purpose of processing: to make the website available, to provide technical support.
  4. Duration of processing, time limit for erasure of data: processing lasts until the termination of the agreement between the controller and the service provider or until the data subject's request for erasure to the service provider.
  5. Legal basis for data processing: the consent of the User, Article 5 (1), 6 (1) a) of Act CXII of 2011 on the Right of Informational Self-Determination and Freedom of Information, and Article 13/A (3) of Act CVIII of 2001 on certain issues of electronic commerce services and information society services..

 

COOKIE MANAGEMENT

  1. Processing of data, scope of data processed: unique identifier, dates, times
  2. Data subjects: all data subjects visiting the website.
  3. Purpose of processing: identification of users and tracking of visitors.
  4. The duration of processing, time limit for deletion of data:
  5. Identity of the potential data controllers: no personal data is processed by the data controller through the use of cookies.
  6. Az érintettek adatkezeléssel kapcsolatos jogainak ismertetése: az érintettnek lehetőségük van a cookie-kat törölni a böngészőkből. To find out about cookie settings and restrictions in the most popular browsers, please follow the links below:
  1. Legal basis for processing: no consent is required from the data subject where the sole purpose of the use of cookies is to provide a communication over an electronic communications network or where the service provider strictly needs the cookies to provide an information society service explicitly requested by the subscriber or user.

 

USING GOOGLE ADWORDS CONVERSION TRACKING

  1. The data controller uses the online advertising program 'Google AdWords' and uses Google's conversion tracking service within its framework. Google Conversion Tracking is an analytics service of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; 'Google').
  2. When a User reaches a website through a Google ad, a cookie is placed on their computer for conversion tracking. These cookies have a limited validity and do not contain any personal data, so they do not identify the User.
  3. When the User browses certain pages of the website and the cookie has not expired, Google and the data controller can see that the User has clicked on the ad.
  4. Each Google AdWords client receives a different cookie, so they cannot be tracked through AdWords clients' websites.
  5. The information obtained through the use of conversion tracking cookies is used to provide conversion statistics to AdWords customers who choose to track conversions. This provides customers with information on the number of users who click on their ad and are referred to a page with a conversion tracking tag. However, they do not have access to information that would allow them to identify any user.
  6. If you do not wish to participate in conversion tracking, you can opt out by disabling the option to set cookies in your browser. You will then not be included in the conversion tracking statistics.
  7. For more information and to read Google's privacy statement, please visit 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 'cookies', which are text files placed on your computer, to help the website analyze how users use the site you have visited.
  2. The information generated by the cookies on the website used by the User is usually transferred to a Google server in the USA and stored there. By activating the IP anonymisation on the website, Google will previously shorten the IP address of the User within 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 activity and internet usage.
  4. Google Analytics will not associate the IP address transmitted by the User's browser with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You may also prevent Google from collecting and processing information about your use of this website (including your IP address) by means of cookies by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout

 

 

HANDLING COMPLAINTS

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

Personal data

Surname and first name. Purpose of processing: identification, contact.
E-mail address. Purpose of processing: contact.
Telephone number. Purpose of processing: contact.
Invoicing name and address. Purpose of data processing: identification, handling of quality complaints, questions and problems related to the services ordered.

  1. Persons concerned: all data subjects who use the service and complain about quality.
  2. Duration of data processing, deadline for deletion of data: copies of the minutes, transcripts and the reply to the recorded objections shall be kept for 5 years pursuant to Article 17/A (7) of Act CLV of 1997 on Consumer Protection.
  3. Identity of the potential controllers who may access the data, recipients of personal data: personal data may be processed by the controller, in compliance with the above principles.
  4. 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
  • he/she can object to the processing of such personal data
  • he/she has the right to obtain the portability of the data and the right to withdraw consent at any time.
  1. The data subject may request access to, erasure, rectification or restriction of the processing of personal data, data portability and object to the processing of personal data by the following means:
  • by post to the address 81 Algyői street, 6727 Szeged, Hungary
  • by e-mail to 
  1. Legal basis for processing: the data subject's consent, Article 6 (1) (a), Article 5 (1) of Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information, and Article 17/A (7) of Act CLV of 1997 on Consumer Protection.
  2. Please be informed that
  • the provision of personal data is based on a contractual obligation
  • the processing of personal data is a condition for the conclusion of the contract.
  • you are obliged to provide the personal data in order for us to be able to handle your complaint.
  • failure to provide the data will result in our inability to handle your complaint.

 

SOCIAL MEDIA

  1. Fact of data collection, scope of data processed: name registered on Facebook / Google+ / Twitter / Pinterest / Youtube / Instagram etc. social networking sites, and public profile picture of the user.
  2. Data subjects: all data subjects who have registered on Facebook / Google+ / Twitter / Pinterest / Youtube / Instagram etc. and have 'liked' the website.
  3. The purpose of the data collection: to share or "like" or promote certain content, products, promotions or the website itself on social networking sites.
  4. The duration of the processing, the time limit for deletion of the data, the identity of the possible controllers of the data and the rights of the data subjects in relation to the processing: 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 social networking site. The processing takes place on the social networking sites, so the duration of the processing, the way in which it is carried out and the possibilities for deleting and modifying 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.

 

CONTACT BY TELEPHONE

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

Personal data

Name, phone number, property address. Purpose of processing: contact, identification, business purpose, ordering services.

  1. Data subjects: all data subjects who have telephone contact with the data controller.
  2. Duration of processing, deadline for erasure of data: processing lasts until the data subject requests erasure.
  3. Identity of the potential controllers who may access the data, recipients of personal data: personal data may be processed by the controller, in compliance with the above principles.
  4. 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
  • he/she can object to the processing of such personal data
  • he/she has the right to data portability and the right to withdraw consent at any time.
  1. The data subject may request access to, erasure, rectification or restriction of processing of personal data, data portability and object to processing in the following ways:
  • by post to the address 81 Algyői street, 6727 Szeged, Hungary
  • by e-mail to 
  1. Legal basis for processing: consent of the data subject, Article 6 (1) (a), Article 5 (1) of Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information.
  2. Please be informed that
  • the processing is based on your consent.
  • you are obliged to provide personal data so that we can respond to your request.
  • failure to provide the data will result in our inability to comply with the request, carry out the work, etc.

 

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 delete the received e-mails, messages, data provided by telephone, Facebook, etc., together with the name and e-mail address of the data subject and other personal data voluntarily provided by the data subject, after a maximum of 2 years from the date of the communication.
  3. Any processing not listed in this notice will be notified at the time the data is collected.
  4. In exceptional cases, the Service Provider is obliged to supply information, data or documents in response to a request from a public authority or other bodies authorised by law.
  5. In these cases, the Service Provider shall only disclose personal data to the requesting party – provided that the latter has indicated the precise purpose and scope of the data – to the extent and to the extent that is indispensable for the purpose of the request.

 

THE RIGHTS OF DATA SUBJECTS

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

    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 the completion of incomplete personal data, including by means of a supplementary declaration.

    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 under certain conditions.

    4. The right to be forgotten
    If the controller has disclosed the personal data and is obliged 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 have processed the data that you have requested the deletion of the links to or copies of the personal data in question.

    5. The 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.
  1. 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 being hindered by the controller to whom you have provided the personal data.
  2. The right to protest
    You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data, including profiling based on the aforementioned provisions.
  3. Objection in case of direct marketing
    If personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such purposes, including profiling, where it is related to direct marketing. If you object to the processing of your personal data for direct marketing purposes, your personal data may no longer be processed for those purposes.
  4. Automated decision-making on individual cases, including profiling
    You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

The previous paragraph does not apply where the decision:

  • is needed 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
  • is based on your explicit consent.
  1. The legal grounds for processing are set out in the Regulation:

a) the consent of the data subject

b) fulfilment of the contract

c) compliance with a legal obligation to which the controller is subject

d) the protection of the vital interests of the data subject

e) the processing is carried out in the public interest or in the exercise of official authority conferred on the controller

f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party.

 

DEADLINE FOR ACTION

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

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

If the controller 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, and of your right to lodge a complaint with a supervisory authority and to seek judicial remedy.

 

THE SECURITY OF DATA PROCESSING

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

  1. pseudonymisation and encryption of personal data;
  2. ensuring the continuous 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 reasonable time;
  4. a procedure for regularly testing, assessing and evaluating the effectiveness of the technical and organisational measures taken to ensure the security of data processing.

 

INFORMING THE DATA SUBJECT OF THE PERSONAL DATA BREACH

Where the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, the controller shall inform the data subject of the personal data breach without undue delay.

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

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

  • the controller has implemented appropriate technical and organisational protection measures and 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;
  • the provision of information would require a disproportionate effort. In such cases, the data subjects shall be informed by means of publicly disclosed information or by means of a similar measure ensuring that the data subjects are informed in an equally effective manner.

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

 

REPORTING A PERSONAL DATA BREACH TO THE AUTHORITY

The controller shall notify a personal data breach to the supervisory authority competent pursuant to Article 55 without undue delay and, where possible, no later than 72 hours after the personal data breach has come to its attention, unless the personal data breach is unlikely to pose a risk to the rights and freedoms of natural persons. If the notification is not made within 72 hours, it shall be accompanied by the reasons justifying the delay.

 

 

COMPLAINT PROCEDURE

Complaints against possible infringements 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

22/C Erzsébet Szilágyi alley, 1125 Budapest, Hungary
Postal address: 1530 Budapest, P.O. Box 5.
Phone: +36 -1-391-1400
Fax: +36-1-391-1410
E-mail:

 

DISCLAIMER

When preparing this document, we have taken into account the following legislation:

  • 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)
  • Act CXII of 2011 on the right to informational self-determination and freedom of information
  • Act CVIII of 2001 on certain aspects of electronic commerce services and information society services (in particular § 13/A)
  • Act XLVII of 2008 on the prohibition of unfair commercial practices against consumers;
  • Act XLVIII of 2008 on the basic conditions and certain restrictions of economic advertising (in particular § 6)
  • Act XC of 2005 on electronic freedom of information
  • Act C of 2003 on electronic communications (specifically § 155)
  • Opinion No 16/2011 on the EASA/IAB Recommendation on best practice for behavioural online advertising
  • Recommendation of the National Authority for Data Protection and Freedom of Information on data protection requirements for prior information (29 September 2015)