Data protection statement

Introduction

Paál László József SE (registered office: 1195 Budapest, Petőfi utca 11. tax number: 56685064-1-43) (hereinafter referred to as the Service Provider, Data Controller) is subject to the following information.

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 processing of data on the following pages: http://www.paalmode.com/

This privacy notice is available at: http://www.paalmode.com/adatvedelmi-nyilatkozat

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

The controller and contact details:

Name: Paál László József 

Headquarters: 1195 Budapest, Petőfi utca 11.

E-mail: paallaszlo@gmail.com

Phone: +36-20/337-6469 

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, number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

2. “processing” means any operation or set of operations which is performed upon personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

3. “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 which 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. “data subject’s consent” 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 concerning him or her;

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

Principles governing the processing of personal data

Personal data:

1. be lawful, fair and transparent for the data subject (“lawfulness, fairness and transparency”);

2. 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 shall not be considered incompatible with the original purpose in accordance with Article 89(1) (‘purpose limitation’);

3. be adequate, relevant and limited to what is necessary for the purposes for which the data are processed (“data minimisation”);

4. be accurate and, where necessary, kept up to date; all reasonable steps must be taken to ensure that personal data which are inaccurate for the purposes for which they are processed are erased or rectified without undue delay (“accuracy”);

5. be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be kept for longer periods only if the 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 to safeguard the rights and freedoms of data subjects as provided for in this Regulation (‘limited storage’);

6. be carried out in such a way as to ensure adequate security of personal data, including protection against unauthorised or unlawful processing, accidental loss, destruction or damage (“integrity and confidentiality”), by implementing appropriate technical or organisational measures.

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

Data management

Hosting provider

1. Activity provided by the data processor: Hosting

2. Name and contact details of the data processor:
   3 in 1 Hosting Bt.
   Headquarters.
   Postal address: 2310 Szigetszentmiklós, Dévai utca 10/A

3. Fact of processing, scope of data processed: all personal data provided by the data subject.

4. Data subjects: all data subjects using the website.

5. Purpose of data processing: to make the website available and to ensure its proper operation.

6. Duration of data processing, time limit for deletion of data: until the termination of the agreement between the data controller and the hosting provider or until the data subject’s request for deletion to the hosting provider.

7. The legal basis for data processing: the User’s consent, the Infotv. Article 5(1), Article 6(1)(a), and Article 13/A(3) of Act CVIII of 2001 on Certain Aspects of Electronic Commerce Services and Information Society Services.

Cookie management (cookies)

1. Website-specific cookies

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

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

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

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

The duration of data processing for Addthis cookies is 2 years.

6. Who are the potential controllers of the data: no personal data are processed by the controller through the use of cookies.
7. Description of data subjects’ rights in relation to data processing: data subjects have the possibility to delete cookies in the Tools/Preferences menu of their browsers, usually under the Privacy settings.

8. Legal basis for 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.

Use Google Adwords conversion tracking

1. The data controller uses the online advertising program “Google AdWords” and makes use of 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 you visit a website through a Google ad, a cookie is placed on your computer for conversion tracking. These cookies have a limited validity and do not contain any personal data, so they do not identify the User.

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

4. Each Google AdWords client receives a different cookie, so they cannot be tracked through AdWords clients’ websites.

5. The information, which is obtained through the use of conversion tracking cookies, is used to provide conversion statistics to AdWords customers who choose to track conversions. Clients are then informed of 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 want to participate in conversion tracking, you can opt-out by disabling the option to set cookies in your browser. You will then not be included in the conversion tracking statistics.

7. Further information and Google’s privacy statement can be found at: 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 “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. The IP address transmitted by the User’s browser within the framework of Google Analytics will not be merged with other data held by Google. 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 https://tools.google.com/dlpage/gaoptout?hl=hu

Newsletter, DM activity

1. Pursuant to Article 6 of Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Economic Advertising Activity, the User may expressly consent in advance to the Service Provider contacting him/her with advertising offers and other mailings at the contact details provided at the time of registration.

2. In addition, the Customer may, subject to the provisions of this notice, consent to the processing of personal data by the Service Provider for the purpose of sending advertising offers.

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

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

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

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

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

8. Potential controllers of the data, recipients of the personal data: personal data may be processed by the sales and marketing staff of the controller, in compliance with the above principles.
9. Description of data subjects’ rights in relation to data processing:

• The data subject may request the controller to access, rectify, erase or restrict the processing of personal data relating to him or her, and
• object to the processing of such personal data; and
• the data subject has the right to data portability and the right to withdraw consent at any time.

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

• by post to 1195 Budapest, Petőfi utca 11.
• by e-mail to paallaszlo@gmail.com,
• by telephone on +36-20/337-6469.

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

Legal basis for processing: the data subject’s consent, Article 6 (1) (a), in accordance with the Infotv. Article 5(1), and Article 6(5) of Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Economic Advertising Activities:

The advertiser, the advertising service provider or the publisher of the advertisement shall, within the scope specified in the consent, keep a record of the personal data of the persons who have given their consent. The data recorded in this register concerning the addressee of the advertisement may only be processed in accordance with the consent given in the consent form, until it is withdrawn, and may only be disclosed to third parties with the prior consent of the person concerned.

Please note that

• the processing is based on your consent.
• You are required to provide personal data if you wish to receive newsletters from us.
• failure to provide this information will result in our inability to send you a newsletter.

Community sites

1. The fact of data collection, the data processed: the name registered on Facebook/Google+/Twitter/Pinterest/Youtube/Instagram etc. social networking sites, and the user’s public profile picture.

2. Data subjects: all data subjects who are registered on Facebook/Google+/Twitter/Pinterest/Youtube/Instagram etc. and have “liked” the website.

3. Purpose of data collection: to share, “like” or promote certain content, products, promotions or the website itself on social networking sites.

4. Duration of data processing, time limit for deletion of data, the identity of the possible controllers entitled to access the data and the rights of the data subjects in relation to data processing: the data subject can find out about the source of the data, the processing of the data and the method and legal basis of the transfer on the relevant Community site. The data are processed on the social networking sites, so the duration of the processing, the way in which the data are processed 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 their personal data on social networking sites.

Customer relations and other data management

1. If the data subject has any questions or problems when using our services, he or she can contact the data controller using the methods provided on the website (telephone, e-mail, social networking sites, etc.).

2. The Data Controller shall delete the data provided in e-mails, messages, telephone, Facebook, etc., together with the name and e-mail address of the interested party and other personal data voluntarily provided by the interested party, after a maximum of 2 years from the date of the communication.

3. Information on data processing not listed in this notice is provided at the time of collection.

4. The Service Provider shall be obliged to provide information, disclose data, hand over data or make documents available in response to exceptional requests from public authorities or other bodies authorised by law.

5. In such cases, the Service Provider will 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 strictly necessary for the purpose of the request.

Rights of data subjects

1. Right of access

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

2. The right to rectification

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

3. The right to erasure

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

4. The right to be forgotten

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

5. Right to restriction of processing

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

• You contest the accuracy of the personal data, in which case the restriction applies for the period of time that allows the controller to verify the accuracy of the personal data;
• the processing is unlawful and you oppose the erasure 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 a period of time until it is established whether the controller’s legitimate grounds override your legitimate grounds.

6. The right to data portability

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

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 by (…), including profiling based on these provisions.

8. Objection in case of direct acquisition

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

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

The preceding paragraph shall not apply where the decision:

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

Deadline for action

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

If necessary, this 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 does not take action on your request, it shall inform you without delay and at the latest within one month of receipt of the request of the reasons for the non-action and of the possibility to lodge a complaint with a supervisory authority and exercise your right to judicial remedy.

Security of data processing

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

1. the encryption of personal data;

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

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

4. a procedure to regularly test, assess and evaluate the effectiveness of the technical and organisational measures taken to ensure the security of processing.

Informing the data subject about 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 given to the data subject shall clearly and prominently 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.

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

Reporting a data protection incident to the authority

The data protection incident shall be notified by the controller to the supervisory authority competent under Article 55 without undue delay and, if possible, no later than 72 hours after the data protection incident has come to its attention, unless the data protection incident 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.

Possibility to complain

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

National Authority for Data Protection and Freedom of Information

Hungarian Data Protection Authority (DPA).

Postal address: 1530 Budapest, P.O. Box 5.

Phone: +36 -1-391-1400

Fax: +36-1-391-1410

E-mail: ugyfelszolgalat@naih.hu

ugyfelszolgalat@naih.hu

Closing words

In preparing this information, we have taken into account the following legislation:

• REGULATION (EU) No 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of individuals 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 (hereinafter referred to as the “Infotv.”)
• Act CVIII of 2001 – on certain aspects of electronic commerce services and information society services (in particular Article 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 on commercial advertising (in particular § 6)
• Act XC of 2005 on Freedom of Electronic 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
• 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

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