BONTOUR HUNGARY KFT. (hereinafter referred to as: Service Provider, data controller) submits itself to the following information.

In accordance with 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 95/46/EC (General Data Protection Regulation), we hereby provide the following information.

This data management information regulates the data management of the following sites: www.vasbutor.hu

The data processing information is available from the following page: https://www.vasbutor.hu/adatvedelmi_falykozat

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

The data controller and their contact details:

Name: BONTOUR HUNGARY LTD.

Révivám köz 4, Budapest, 1174, Hungary

Email: info@vasbutor.hu

Phone: +3614900588

Contact details of the data protection officer:

Name: BONTOUR HUNGARY LTD.

Révivám köz 4, Budapest, 1174, Hungary

Email: info@vasbutor.hu

Phone: +361490058

Definitions of terms

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, a 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. "data processing" means any operation or set of operations which is performed on personal data or data files, 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 the natural or legal person, public authority, agency or any other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of the processing are determined by Union or Member State law, the controller or the specific criteria for the 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 the natural or legal person, public authority, agency or any other body to which personal data are disclosed, whether or not a third party. Public authorities which may have access to personal data in the context of an individual investigation in accordance with Union or Member State law shall not be considered recipients; the processing of such data by such public authorities shall be in accordance with the applicable data protection rules in accordance with the purposes of the processing;

6. "consent of the data subject" means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which the data subject, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

7. "data breach" means a breach of security that results in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.

Principles for the processing of personal data

Personal data:

1. processing must be carried out lawfully and fairly, and in a manner that is transparent to the data subject (“lawfulness, fairness and transparency”);

2. collected only for specified, explicit and legitimate purposes and not further processed in a manner 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 initial purpose in accordance with Article 89(1);

3. they must be adequate and relevant in relation to the purposes of the processing and limited to what is necessary (“data economy”);

4. they must be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes of the processing, are erased or rectified without delay (“accuracy”);

5. shall be stored 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 stored for a longer period only where the personal data are processed for archiving purposes in the public interest, scientific and historical research purposes or statistical purposes in accordance with Article 89(1), subject to the implementation of appropriate technical and organisational measures to safeguard the rights and freedoms of data subjects as provided for in this Regulation (‘storage limitation’);

6. must 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 to the data ("integrity and confidentiality"), by applying appropriate technical or organisational measures.

The data controller is responsible for compliance with the above and must be able to demonstrate this compliance ("accountability").

Data processing

Data processing related to web store operation

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

Personal data	Purpose of data processing
Username	Identification, enabling registration.
Password	It serves as a secure login to the user account.
Last name and first name	It is necessary for contact, purchase and issuing a proper invoice.
Email address	Staying in touch.
Phone number	More efficient coordination of communication, billing, or shipping issues.
Billing name and address	Issuing a proper invoice, as well as creating the contract, defining its content, modifying it, monitoring its performance, invoicing the fees arising from it, and enforcing the claims related to it.
Shipping name and address	Enabling home delivery.
Date of purchase/registration	Performing a technical operation.
IP address at the time of purchase/registration	Performing a technical operation.

Neither the username nor the email address is required to contain personal information.

2. Scope of data subjects: All data subjects registered/purchasers on the webshop website.

3. Duration of data processing, deadline for data deletion: Immediately upon registration deletion. The data controller shall inform the data subject electronically, pursuant to Article 19 of the GDPR, of the deletion of any personal data provided by the data subject. If the data subject's request for deletion also covers the e-mail address provided by him/her, the data controller shall also delete the e-mail address after the information has been provided. Except in the case of accounting documents, since these data must be retained for 8 years pursuant to Section 169 (2) of Act C of 2000 on Accounting.

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

4. Potential data controllers authorized to access the data, recipients of personal data : Personal data may be processed by the data controller's sales and marketing staff, in compliance with the above principles.

5. Description of the rights of data subjects regarding data processing :

• The data subject may request from the data controller access to, rectification, erasure or restriction of processing of personal data concerning him or her, and
• object to the processing of such personal data, and
• the data subject has the right to data portability and to withdraw consent at any time.

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

• by post at 1174 Budapest, Régivam köz 4,
• via e- mail info@vasbutor.hu  by email,
• by phone at +3614900588 .

7. Legal basis for data processing :

1. 1 Article 6(1)(b) of the GDPR,

1. 2 Act CVIII of 2001 on certain issues of electronic commerce services and services related to the information society (hereinafter referred to as the Elker Act) Section 13/A (3):

The service provider may process personal data for the purpose of providing the service that is technically indispensable for the provision of the service. All other conditions being the same, the service provider must select and in all cases operate the means used in the provision of the information society service in such a way that personal data are processed only if this is absolutely necessary for the provision of the service and for the fulfilment of other purposes specified in this Act, but even then only to the extent and for the period necessary.

1. 3 In the case of issuing an invoice in accordance with accounting legislation, Article 6(1)(c).

1. 4 In the case of enforcing claims arising from the contract, according to Section 6:21 of Act V of 2013 on the Civil Code, 5 years.

§ 6:22 [Limitation]

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

(2) The limitation period begins when the claim becomes due.

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

(4) An agreement excluding the limitation period is void.

8. We inform you that

• data processing is necessary for the performance of a contract .
• You are required to provide personal data so that we can fulfill your order.
• Failure to provide data will result in us not being able to process your order.

The data processors used

Transport

1. Activity performed by the data processor: Delivery of products, transportation

2. Name and contact details of the data processor:

Name of data controller: GLS General Logistics Systems Hungary Kft.

Headquarters: 2351 Alsónémedi, GLS Európa utca 2.

Email address: dataprotection@gls-hungary.com

Mailing address: 2351 Alsónémedi, GLS Európa utca 2.

Name of Data Protection Officer: Dr. Rita Katona

Contact: adatvedelem@gls-hungary.com

3. The fact of data processing, the scope of data processed: Shipping name, shipping address, telephone number, e-mail address.

4. Scope of data subjects: All data subjects requesting home delivery.

5. Purpose of data processing: Delivery of the ordered product to your home.

6. Duration of data management, deadline for data deletion: Until home delivery is completed.

7. Legal basis for data processing: Article 6(1)(b).

 

Hosting provider

1. Activity provided by the data processor: Hosting service

2. Name and contact details of the data processor:

Name of the data controller: ShopRenter.hu Trading and Service Provider Ltd.

Headquarters: 4028 Debrecen, Kassai Street 129.

Cg. number: 09-09-020636

Email address: info@shoprenter.hu

Mailing address: 4028 Debrecen, Kassai út 129.

3. The fact of data processing, the scope of data processed: All personal data provided by the data subject.

4. Scope of data subjects: All data subjects using the website.

5. Purpose of data management: Making the website available and operating it properly.

6. Duration of data management, deadline for data deletion: Data management lasts until the termination of the agreement between the data controller and the hosting service provider, or until the data subject submits a deletion request to the hosting service provider.

7. The legal basis for data processing is Article 6(1)(c) and (f) and Section 13/A(3) of Act CVIII of 2001 on certain issues of electronic commerce services and information society services.

Recipients to whom personal data are disclosed (Data Transfer):

Online payment

1. Activity performed by the Recipient: Online payment

2. Recipient's name and contact information:

Name of data controller: OTP Mobil Kft.

Headquarters: 1093 Budapest, Közraktár u. 30-32.

Mailing address: 1093 Budapest, Közraktár u. 30-32.

3. The fact of data processing, the scope of data processed: Billing data, name, e-mail address

4. Scope of data subjects: All data subjects who choose to pay on the website.

5. Purpose of data processing: Processing online payments, confirming transactions and fraud monitoring to protect users

6. Duration of data management, deadline for data deletion: Until the online payment is processed.

7. Legal basis for data processing: Article 6(1)(b) of the GDPR. Data processing is necessary to complete an online payment at the request of the data subject.

8. Rights of the data subject:

1. You can find out about the conditions of data processing,
2. You have the right to receive feedback from the data controller as to whether your personal data is being processed, and to access all information related to data processing.
3. You have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format.
4. You have the right to request that the controller rectify inaccurate personal data about you without undue delay.

Managing cookies

1. Cookies typical for online stores are the so-called "password-protected session cookies", "shopping cart cookies" and "security cookies", the use of which does not require prior consent from the data subjects.

2. The fact of data processing, the scope of data processed: Unique identification number, dates, times

3. Scope of data subjects: All data subjects who visit the website.

4. Purpose of data processing: To identify users, to register the "shopping cart" and to track visitors.

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

Cookie type	Legal basis for data processing	Data management	Managed data set
Session cookies	Section 13/A. Subsection (3) of Act CVIII of 2001 on certain issues of electronic commerce services and information society services (Elkertv.)	The relevant period until the visitor session ends	connect.sid

6. Potential data controllers authorized to view the data: The data controller does not process personal data using cookies.

7. Description of the data subjects' rights regarding data processing: The data subject has the option to delete cookies in the Tools/Settings menu of the browser, usually under the settings of the Privacy menu item.

8. Legal basis for data processing: Consent from the data subject is not required if the sole purpose of using cookies is to transmit information via an electronic communications network or if the service provider absolutely needs it 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, within its framework, uses Google’s conversion tracking service. Google conversion tracking is an analytics service provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”).

2. When a User reaches a website through a Google ad, a cookie required for conversion tracking is placed on their computer. These cookies have a limited validity and do not contain any personal data, so the User cannot be identified by them.

3. When the User browses certain pages of the website and the cookie has not yet expired, both Google and the data controller can see that the User clicked on the advertisement.

4. Each Google AdWords customer receives a different cookie, so they cannot be tracked across AdWords customers' websites.

5. The information – obtained using conversion tracking cookies – is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. This allows customers to see the number of users who clicked on their ads and were redirected to a page with a conversion tracking tag. However, they do not receive any information that could be used to identify any individual user.

6. If you do not wish to participate in conversion tracking, you can refuse this by disabling the installation of cookies in your browser. You will then not be included in the conversion tracking statistics.

7. Further information and Google's privacy policy can be found at: www.google.de/policies/privacy/

Using Google Analytics

1. This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses so-called “cookies”, text files that are saved on your computer, to help the website operator analyze how users use the website.

2. The information generated by the cookie about the website used by the User is usually transmitted to and stored on a Google server in the USA. By activating IP anonymization on the website, Google will shorten the User's IP address beforehand within 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 only be transmitted to a Google server in the USA and shortened there in exceptional cases. On behalf of the operator of this website, Google will use this information to evaluate how the user uses the website, to compile reports on website activity for the website operator and to provide other services relating to website and internet usage.

4. Within the framework of Google Analytics, the IP address transmitted by the User's browser will not be merged with other data held by Google. The User can prevent the storage of cookies by setting their browser accordingly; however, please note that in this case not all functions of this website may be fully usable. You can also prevent Google from collecting and processing the data generated by cookies and relating to your use of the website (including your IP address) by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=hu

Newsletter, DM activity

1. Pursuant to Section 6 of Act XLVIII of 2008 on the Basic Conditions and Certain Limitations of Economic Advertising Activity, the User may give prior and express consent to the Service Provider contacting him/her with advertising offers and other mailings at the contact details provided upon registration.

2. Furthermore, the Customer, taking into account the provisions of this information, may consent to the Service Provider processing his/her personal data necessary for sending advertising offers .

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

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

Personal data	Purpose of data processing
Name, email address.	Identification, enabling subscription to the newsletter.
Date of subscription	Performing a technical operation.
IP address at the time of registration	Performing a technical operation.

5. Scope of data subjects: All data subjects who subscribe to the newsletter.

6. The purpose of data processing is to send electronic messages (e-mail, SMS, push message) containing advertising to the data subject, to provide information about current information, products, promotions, new features, etc.

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

8. Potential data controllers authorized to access the data, recipients of personal data : Personal data may be processed by the data controller's sales and marketing staff, in compliance with the above principles.

9. Description of the rights of data subjects regarding data processing :

• The data subject may request from the data controller access to, rectification, erasure or restriction of processing of personal data concerning him or her, and
• object to the processing of such personal data, and
• the data subject has the right to data portability and to withdraw consent at any time.

10. The data subject can request access to personal data , their deletion, modification or restriction of processing, data portability, and objection to data processing in the following ways :
    - by post at 1174 Budapest, Régivam köz 6,
    - by e-mail at info@vasbutor.hu ,
    - by phone at +3614900588.
11. The data subject can unsubscribe from the newsletter at any time, free of charge .

12. Legal basis for data processing : the consent of the data subject, Article 6(1)(a) and (f), and Section 6(5) of Act XLVIII of 2008 on the basic conditions and certain limitations of economic advertising activities:

The advertiser, the advertising service provider, or the publisher of the advertisement shall keep a record of the personal data of the persons who have given their consent to the advertising, within the scope specified in the consent. The data recorded in this record - concerning the recipient of the advertisement - may only be processed in accordance with the provisions of the consent declaration, until its withdrawal, and may only be transferred to a third party with the prior consent of the person concerned.

13. We inform you that

• data processing is based on your consent .
• You are required to provide personal data if you want to receive a newsletter from us.
• Failure to provide data will result in us not being able to send you a newsletter.

 

Complaints handling

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

Personal data	Purpose of data processing
Last name and first name	Identification, contact.
Email address	Staying in touch.
Phone number	Staying in touch.
Billing name and address	Identification and handling of quality complaints, questions and problems arising in connection with ordered products.

2. Scope of the affected parties: All affected parties who purchase on the webshop website and have quality complaints or complaints.

3. Duration of data processing, deadline for data deletion: The minutes, transcript and copies of the response to the objection must be kept for 5 years pursuant to Section 17/A. (7) of Act CLV of 1997 on Consumer Protection.

4. Potential data controllers authorized to access the data, recipients of personal data : Personal data may be processed by the data controller's sales and marketing staff, in compliance with the above principles.

5. Description of the rights of data subjects regarding data processing :

• The data subject may request from the data controller access to, rectification, erasure or restriction of processing of personal data concerning him or her, and
• object to the processing of such personal data, and
• the data subject has the right to data portability and to withdraw consent at any time.

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

- by post at 1174 Budapest, Régivam köz 6,

- via e-mail info@vasbutor.hu by email,

- by phone at +3614900588.

7. Legal basis for data processing : Article 6(1)(c) and Section 17/A(7) of Act CLV of 1997 on Consumer Protection.

8. We inform you that

• the provision of personal data is based on a contractual obligation .
• The processing of personal data is a prerequisite for concluding a contract.
• You are required to provide your personal data so that we can handle your complaint.
• Failure to provide data will result in our inability to handle the complaint you have received.

Social media

1. The fact of data collection, the scope of data processed: the user's registered name on social media sites such as Facebook/Google+/Twitter/Pinterest/Youtube/Instagram, etc., and their public profile picture.

2. Scope of data subjects: All data subjects who have registered on social media sites such as Facebook/Google+/Twitter/Pinterest/Youtube/Instagram etc. and have "liked" the website.

3. Purpose of data collection: Sharing, "liking" and promoting certain content elements, products, promotions or the website itself on social media.

4. Duration of data management, deadline for data deletion, possible data controllers authorized to view the data and description of the data subjects' rights related to data management: The data subject can find out about the source of the data, its management, the method of transfer and its legal basis on the given social media site. Data management is carried out on social media sites, so the duration, method of data management and the possibilities for data deletion and modification are subject to the regulations of the given social media site.

5. Legal basis for data processing: the data subject's voluntary consent to the processing of their personal data on social media sites.

Customer relations and other data processing

1. If the data controller has any questions or problems while using our services, the data subject can contact the data controller via the methods provided on the website (telephone, e-mail, social media, etc.).

2. The data controller deletes received e-mails, messages, data provided by telephone, Facebook, etc., together with the name and e-mail address of the interested party, as well as other voluntarily provided personal data, no later than 2 years after the data was disclosed.

3. We will provide information about data processing not listed in this information when the data is collected.

4. In the event of an exceptional official request or a request from other bodies based on legal authorization, the Service Provider is obliged to provide information, communicate and transfer data, or make documents available.

5. In these cases, the Service Provider will only provide the requester with personal data to the extent and insofar as it is absolutely necessary to achieve the purpose of the request, provided that the requester has indicated the precise purpose and scope of the data.

Rights of data subjects

1. Right of access

You have the right to receive feedback from the controller as to whether your personal data is being processed and, if such processing is taking place, you have the right to access the personal data and the information listed in the regulation.

2. The right to rectification

You have the right to request that the controller rectify inaccurate personal data concerning you without undue delay. Taking into account the purpose of the processing, you have the right to request that incomplete personal data be completed, including by means of a supplementary statement.

3. The right to erasure

You have the right to request that the controller erase your personal data without undue delay, and the controller is obliged to erase your personal data without undue delay under certain conditions.

4. The right to be forgotten

Where the controller has made the personal data public and is obliged to erase them, the controller, taking into account available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform the controllers processing the data that you have requested the erasure of links to the personal data in question or of copies or replications of those personal data.

5. Right to restriction of data processing

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

• You contest the accuracy of the personal data, in which case the restriction shall apply for a period of time that allows the controller to verify the accuracy of the personal data;
• the processing is unlawful and you oppose the erasure of the data and instead request the restriction of its use;
• the data controller no longer needs the personal data for the purposes of data 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 a period of time until it is determined whether the legitimate grounds of the data controller override your legitimate grounds.

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 have the right to transmit those data to another controller without hindrance from the controller to whom the personal data have been provided (...).

7. 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.

8. Objection to direct marketing

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

9. Automated decision-making in individual cases, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

The previous paragraph shall not apply if the decision:

• Necessary for the conclusion or performance of a contract between you and the data controller;
• is permitted by Union or Member State law applicable to the controller, which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
• It is based on your express consent.

Deadline for action

The data controller will inform you of the measures taken in response to the above requests without undue delay, but in any case within 1 month of receipt of the request.

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

If the controller does not take action on your request, it shall inform you without delay, but no later than one month from the date of receipt of the request, of the reasons for the failure to take action and of the possibility of lodging a complaint with a supervisory authority and of exercising your right to a judicial remedy.

Security of data processing

The controller and the processor shall implement appropriate technical and organizational measures to ensure a level of data security appropriate to the risk, taking into account the state of the art and the costs of implementation, the nature, scope, circumstances and purposes of the processing, and the varying likelihood and severity of the risk to the rights and freedoms of natural persons, including, where appropriate:

1. pseudonymization and encryption of personal data;

2. ensuring the continued confidentiality, integrity, availability and resilience of systems and services used to process personal data;

3. the ability to restore access to and availability of personal data in a timely manner in the event of a physical or technical incident;

4. a procedure for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures taken to guarantee the security of data processing.

Informing the data subject about the data protection incident

If the 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 data breach without undue delay.

The information provided to the data subject must clearly and intelligibly describe the nature of the data protection incident 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 data protection incident; describe the measures taken or planned by the data controller to remedy the data protection incident, including, where applicable, measures aimed at mitigating any adverse consequences resulting from the data protection incident.

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

• the controller has implemented appropriate technical and organisational security measures and these measures have been applied to the data affected by the data breach, in particular measures – such as the use of encryption – which make the data unintelligible to persons not authorised to access the personal data;
• the data controller has taken further measures following the data protection incident 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 involve a disproportionate effort . In such cases, the data subjects shall be informed by means of publicly published information or a similar measure shall be taken which ensures that the data subjects are informed in a similarly effective manner.

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

Reporting a data protection incident to the authority

The controller shall notify the personal data breach to the supervisory authority competent pursuant to 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 shall be accompanied by reasons justifying the delay.

Review in case of mandatory data processing

If the duration of mandatory data processing or the periodic review of its necessity is not specified by law, a local government decree, or a binding legal act of the European Union, the data controller shall review at least every three years from the start of data processing whether the processing of personal data processed by it or by a data processor acting on its behalf or on its instructions is necessary for the achievement of the purpose of data processing.

The circumstances and results of this review shall be documented by the data controller, this documentation shall be retained for ten years after the review has been completed and shall be made available to the National Data Protection and Freedom of Information Authority (hereinafter referred to as the Authority) upon request.

Possibility to file a complaint

A complaint against a possible violation of the data controller can be filed with the National Data Protection and Freedom of Information Authority:

National Data Protection and Freedom of Information Authority

1125 Budapest, Szilágyi Erzsébet fasor 22/C.

Mailing address: 1530 Budapest, PO Box: 5.

Phone: +36 -1-391-1400

Fax: +36-1-391-1410

E-mail: ugyfelszolgalat@naih.hu

Closing remarks

When preparing this information, we took 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 95/46/EC (General Data Protection Regulation)
• Act CXII of 2011 – on the right to informational self-determination and freedom of information (hereinafter: Infotv.)
• Act CVIII of 2001 – on certain issues of electronic commerce services and services related to the information society (mainly Section 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 limitations of economic advertising activities (especially Section 6)
• Act XC of 2005 on Electronic Freedom of Information
• Act C of 2003 on Electronic Communications (specifically Section 155)
• Opinion No 16/2011 on the EASA/IAB Recommendation on best practice in online behavioural advertising
• Recommendation of the National Data Protection and Freedom of Information Authority on the data protection requirements for prior information