Privacy Policy

DATA PROCESSING NOTICE FOR WEBSITE

The FEBE Transport Limited Liability Company – hereinafter referred to as the Enterprise – complies with the obligation to provide prior information regarding the processing of personal data of data subjects by publishing this data protection notice, as required by Regulation (EU) 2016/679 of the European Parliament and of the Council, in accordance with which all information required by the articles of the Regulation must be made available to data subjects in a concise, transparent, intelligible, and easily accessible form, in clear and plain language.

I. NAME OF THE DATA CONTROLLER

The Enterprise informs the data subject that it qualifies as the data controller in the processing of their personal data.

DATA CONTROLLER’S NAME: MISSION TRANSPORT and LOGISTICS Kft.
REGISTERED OFFICE: 9171 Győrújfalu, Petőfi Sándor u. 19.
COMPANY REGISTRATION NUMBER: 08-09-011 882
TAX IDENTIFICATION NUMBER: 13200918-2-08
PHONE: +36 96 518 325
REPRESENTATIVE’S NAME: Emese Bedő, CEO
E-MAIL: info@missiontrans.hu
WEBSITE: www.missiontrans.hu

The personal data may be accessed by the employees of the Enterprise who have access rights related to the relevant data processing purpose and by individuals performing data processing activities based on a service contract with the Enterprise, to the extent determined by the Enterprise and to the extent necessary for the performance of their activities.

II. NAMES OF DATA PROCESSORS

(1) The Enterprise uses an external data processor for the personal data processed based on voluntary consent for the operation of its website.

ACTIVITY: Hosting services
DATA PROCESSOR’S NAME: IRQ Hosting Kft.
REGISTERED OFFICE: 1015 Budapest, Donáti u. 38/A.
COMPANY REGISTRATION NUMBER: 01-09-964 304
TAX IDENTIFICATION NUMBER: 23408416-2-41
PHONE: +36 1 233 7777
REPRESENTATIVE’S NAME: Róbert Szecsődi, CEO
E-MAIL: info@irq.hu
WEBSITE: www.irq.hu

III. DEFINITIONS

“Personal data”: 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, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
“Data processing”: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
“Restriction of processing”: the marking of stored personal data with the aim of limiting their processing in the future.
“Profiling”: any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
“Pseudonymization”: the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.
“Filing system”: any structured set of personal data which are accessible according to specific criteria, whether centralized, decentralized, or dispersed on a functional or geographical basis.
“Data controller”: the natural or legal person, public authority, agency, or 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 such processing are determined by Union or Member State law, the data controller or the specific criteria for its nomination may be provided for by Union or Member State law.
“Processor”: a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
“Recipient”: a natural or legal person, public authority, agency, or another body, to which the personal data is disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
“Third party”: a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
“Consent of the data subject”: any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
“Personal data breach”: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.
“Enterprise”: a natural or legal person engaged in an economic activity, irrespective of its legal form, including partnerships or associations regularly engaged in economic activities.

IV. LEGAL BASIS FOR DATA PROCESSING

Consent of the Data Subject

(1) The lawfulness of data processing must be based on the consent of the data subject or another legitimate basis provided by law.

(2) Data processing based on the consent of the data subject can be given in the following forms:

a) In writing, by providing a statement of consent for personal data processing.
b) Electronically, through explicit behavior on the Enterprise’s website, such as ticking a checkbox, or by making technical settings related to information society services, as well as any other statement or action that clearly indicates the data subject’s consent to the planned processing of their personal data.

(3) Silence, pre-ticked boxes, or inaction does not constitute consent.

(4) Consent covers all data processing activities carried out for the same purpose or purposes.

(5) If data processing serves multiple purposes simultaneously, consent must be given for all data processing purposes. If the data subject gives consent after an electronic request, the request must be clear and concise and must not unnecessarily hinder the use of the service for which consent is requested.

(6) The data subject has the right to withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of data processing based on consent before its withdrawal. The data subject must be informed of this possibility before giving consent. Withdrawal of consent must be as simple as giving consent.

Performance of a Contract

(1) Data processing is considered lawful when it is necessary for the performance of a contract to which the data subject is a party, or for steps taken at the request of the data subject prior to entering into a contract.

(2) The data subject’s consent for the processing of personal data that is necessary for the performance of a contract cannot be a condition for the conclusion of the contract.

Compliance with a Legal Obligation of the Data Controller or Protection of Vital Interests

(1) The legal basis for data processing in the case of compliance with a legal obligation is determined by law, and therefore, the consent of the data subject is not necessary for the processing of personal data.

(2) The data controller is obligated to inform the data subject about the purpose, legal basis, duration, the data controller’s identity, and the rights and remedies available to the data subject.

(3) After the withdrawal of consent, the data controller is entitled to process the data necessary for the fulfillment of a legal obligation.

Public Interest or Exercise of Official Authority and Legitimate Interests of the Data Controller or a Third Party

(1) The data controller, including a data controller to whom the personal data may be disclosed, or a third party, can establish a legal basis for data processing based on a legitimate interest, provided that the interests or fundamental rights and freedoms of the data subject do not override, taking into account the reasonable expectations of the data subject in the context of the relationship with the data controller. Such legitimate interests can be, for example, situations where there is a relevant and appropriate relationship between the data subject and the data controller, such as when the data subject is a customer of the data controller or an employee of the data controller.

(2) To establish the existence of a legitimate interest, it is essential to carefully examine whether the data subject can reasonably expect data processing to occur at the time of data collection and in connection with the data processing.

(3) The interests and fundamental rights and freedoms of the data subject take precedence over the interests of the data controller if personal data are processed under circumstances where data subjects do not reasonably expect further processing.

V. RIGHTS RELATED TO THE PROCESSING OF PERSONAL DATA

The Company provides the following brief information about the data subject’s rights:

The data subject has the right to:

a) be informed before the start of data processing,
b) obtain confirmation from the data controller as to whether their personal data is being processed and, if such processing is in progress, to have access to the personal data and the following information,
c) request the correction or deletion of their data and receive notification from the data controller regarding the actions taken in this regard,
d) request a restriction on processing and receive notification from the data controller regarding the actions taken in this regard,
e) data portability,
f) object if their personal data is processed for reasons of public interest or the legitimate interests of the data controller.
g) be exempt from automated decision-making, including profiling,
h) the right to lodge a complaint with the supervisory authority. The data subject can exercise their right to lodge a complaint at the following contact details: National Authority for Data Protection and Freedom of Information, address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c., Phone: +36 (1) 391-1400; Fax: +36(1) 391-1410, Website: http://www.naih.hu; Email: ugyfelszolgalat@naih.hu
i) effective judicial remedy against a supervisory authority,
j) effective judicial remedy against the data controller or data processor,
k) to be informed about data protection incidents.
Detailed information on the data subject’s rights

Right to be Informed

(1) The data subject has the right to receive information about data processing activities before they commence.

(2) The information to be provided when personal data is collected from the data subject shall include:

the identity and contact details of the data controller and, where applicable, the data controller’s representative;
the contact details of the data protection officer, if applicable;
the purpose of the intended processing of personal data and the legal basis for the processing;
where the processing is based on Article 6(1)(f) of the Regulation, the legitimate interests pursued by the data controller or by a third party;
where applicable, the recipients or categories of recipients of the personal data;
where applicable, the fact that the data controller intends to transfer personal data to a third country or international organization and the existence or absence of a Commission adequacy decision or, in the case of data transfers referred to in Article 46, Article 47, or the second subparagraph of Article 49(1) of the Regulation, reference to the appropriate or suitable safeguards and the means by which to obtain a copy of them..

(3) In addition to the information mentioned in paragraph (1), the data controller informs the data subject, at the time of obtaining personal data, of the following additional information to ensure fair and transparent data processing:

the duration of the storage of personal data or, if this is not possible, the criteria used to determine that period;
the right of the data subject to request access to, rectification, erasure, or restriction of processing of their personal data and to object to such processing, as well as the right to data portability;
the right to withdraw consent at any time, where the processing is based on Article 6(1)(a) or Article 9(2)(a) of the Regulation, without affecting the lawfulness of processing based on consent before its withdrawal;
the right to lodge a complaint with a supervisory authority;
whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the data subject is obliged to provide the personal data and the possible consequences of failure to provide such data;
the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the Regulation and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing.

(4) Where personal data have not been obtained from the data subject, the data controller shall provide the data subject with the following information:

the identity and contact details of the data controller and, where applicable, the data controller’s representative;
the contact details of the data protection officer, if applicable;
the purposes of the processing for which the personal data are intended as well as the legal basis for the processing;
the categories of personal data concerned;
the recipients or categories of recipients of the personal data, if any;
where applicable, whether the data controller intends to transfer personal data to a third country or international organization, and the existence or absence of an adequacy decision by the Commission, or in the case of data transfers referred to in Article 46, Article 47, or the second subparagraph of Article 49(1) of the Regulation, reference to the appropriate or suitable safeguards and the means to obtain a copy of them.

(5) In addition to the information mentioned in paragraph (1), the data controller shall provide the data subject with the following additional information necessary to ensure fair and transparent data processing:

the duration of the storage of personal data or, if this is not possible, the criteria used to determine that period;
if the processing is based on Article 6(1)(f) of the Regulation, the legitimate interests pursued by the data controller or by a third party;
the data subject’s right to request access to, rectification, erasure, or restriction of processing of their personal data and to object to such processing, as well as the right to data portability;
the right to withdraw consent at any time, where the processing is based on Article 6(1)(a) or Article 9(2)(a) of the Regulation, without affecting the lawfulness of processing based on consent before its withdrawal;
the right to lodge a complaint with a supervisory authority;
the source of the personal data, and whether the data comes from publicly available sources; and
the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the Regulation and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing.

(6) Where the data controller intends to carry out further processing for a purpose other than that for which the personal data were collected, the data controller shall inform the data subject of that different purpose and provide the data subject with any relevant additional information referred to in paragraph (2) prior to that further processing.

(7) Paragraphs (1) to (3) shall not apply if and to the extent that:

the data subject already has the information;
providing such information proves impossible or would involve a disproportionate effort, in particular for processing for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, taking into account the conditions and safeguards referred to in Article 89(1), or if the obligation is likely to render impossible or seriously impair the achievement of the objectives of such processing. In such cases, the data controller shall take appropriate measures to protect the rights, freedoms, and legitimate interests of the data subject, including making the information publicly available;
the processing is required by Union or Member State law to which the data controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or
the personal data must remain confidential subject to an obligation of professional secrecy regulated by Union or Member State law, including a statutory obligation of secrecy.

Right of access by the data subject

(1) The data subject shall have the right to obtain from the data controller confirmation as to whether or not personal data concerning them are being processed and, where that is the case, access to the personal data and the following information:

the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipients to whom the personal data have been or will be disclosed, including recipients in third countries or international organizations;
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
the existence of the right to request from the data controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
the right to lodge a complaint with a supervisory authority;
where the personal data are not collected from the data subject, any available information as to their source;
the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the Regulation and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing.

(2) Where personal data are transferred to a third country or to an international organization, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.

(3) The data controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the data controller may charge a reasonable fee based on administrative costs. If the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a widely used electronic format.

The right to rectification and deletion of the data subject

The right to rectification

(1) The data subject is entitled to request the data controller to rectify inaccurate personal data concerning them without undue delay. Taking into account the purposes of the data processing, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary statement.

The right to erasure (“the right to be forgotten”)

(1) The data subject has the right to request the data controller to erase personal data concerning them without undue delay, and the data controller is obliged to erase personal data concerning the data subject without undue delay, if one of the following reasons applies:

The personal data is no longer necessary for the purposes for which it was collected or otherwise processed.
The data subject withdraws consent on the basis of Article 6(1)(a) or Article 9(2)(a) of the Regulation (express consent), and there is no other legal basis for the processing.
The data subject has objected to the processing pursuant to Article 21(1) of the Regulation (right to object), and there are no overriding legitimate grounds for the processing, or the data subject has objected to the processing pursuant to Article 21(2) of the Regulation (objection to processing for direct marketing purposes).
The personal data has been processed unlawfully.
The erasure of personal data is required to fulfill a legal obligation under Union or Member State law to which the data controller is subject.
The personal data has been collected in relation to the offer of information society services referred to in Article 8(1) of the Regulation.

(2) Where the data controller has made the personal data public and is obliged to erase it, taking into account available technology and the cost of implementation, they shall take reasonable steps, including technical measures, to inform other data controllers processing the personal data that the data subject has requested the erasure of any links to, or copies or duplicates of, this personal data.

(3) Paragraphs (1) and (2) shall not apply to the extent that processing is necessary:

For the exercise of the right to freedom of expression and information.
For compliance with a legal obligation that requires processing by Union or Member State law to which the data controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller.
For reasons of public interest in the area of public health, as specified in Article 9(2)(h) and (i) and Article 9(3) of the Regulation.
For archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) of the Regulation in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing, or
For the establishment, exercise or defense of legal claims.

The right to restriction of processing

(1) The data subject has the right to request the data controller to restrict processing if one of the following applies:

The data subject contests the accuracy of the personal data, in which case the restriction shall apply for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
The data controller no longer needs the personal data for the purposes of the processing, but it is required by the data subject for the establishment, exercise or defense of legal claims, or
The data subject has objected to processing pursuant to Article 21(1) of the Regulation. In this case, the restriction shall be in place for the time necessary to determine whether the data controller’s legitimate grounds override those of the data subject.

(2) If processing is restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

(3) The data controller shall inform the data subject before the restriction of processing is lifted.

Notification obligation regarding rectification or erasure of personal data or restriction of processing

(1) The data controller shall communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data have been disclosed unless this proves impossible or involves disproportionate effort.

(2) The data controller shall inform the data subject about those recipients if the data subject requests it.

The right to data portability

(1) The data subject has the right to receive their personal data, which they have provided to a data controller, in a structured, commonly used, machine-readable format, and has the right to transmit this data to another data controller without hindrance from the data controller to which the personal data has been provided, where:

The processing is based on the data subject’s consent as per Article 6(1)(a) or Article 9(2)(a) of the Regulation (explicit consent), or on a contract pursuant to Article 6(1)(b) of the Regulation; and
The processing is carried out by automated means.

(2) When exercising the right to data portability under paragraph (1), the data subject has the right to request the direct transmission of personal data between data controllers if technically feasible.

(3) The exercise of the right mentioned in paragraph (1) shall not adversely affect the rights and freedoms of others. This right shall not apply to the extent that the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller.

(4) The right mentioned in paragraph (1) shall not adversely affect the rights and freedoms of others.

The right to object

(1) The data subject has the right to object at any time, on grounds relating to their particular situation, to the processing of their personal data based on public interest or the exercise of public authority, or for the purposes of the legitimate interests pursued by the data controller or a third party (processing under Article 6(1)(e) or (f)), including profiling based on those provisions. In such cases, the data controller shall not process the personal data unless the data controller demonstrates compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defense of legal claims.

(2) Where personal data is processed for direct marketing purposes, the data subject shall have the right to object at any time to the processing of their personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.

(3) Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

(4) The right referred to in paragraphs (1) and (2) shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.

(5) In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise their right to object by automated means using technical specifications.

(6) Where personal data is processed for scientific or historical research purposes or statistical purposes in accordance with Article 89(1) of the Regulation, the data subject shall have the right to object to the processing of their personal data on grounds relating to their particular situation, except where the processing is necessary for the performance of a task carried out for reasons of public interest.

The right to object to automated decision-making

(1) The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.

(2) Paragraph (1) shall not apply if the decision:

Is necessary for entering into or performance of a contract between the data subject and the data controller;
Is authorized by Union or Member State law to which the data controller is subject and which also lays down suitable measures to safeguard the data subject’s rights, freedoms, and legitimate interests; or
Is based on the data subject’s explicit consent.

(3) In the cases referred to in paragraph (2), the data controller shall implement suitable measures to safeguard the data subject’s rights, freedoms, and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view, and to contest the decision.

(4) Decisions referred to in paragraph (2) shall not be based on special categories of personal data referred to in Article 9(1), unless Article 9(2)(a) or (g) applies and suitable measures to safeguard the data subject’s rights and freedoms are in place.

Right to lodge a complaint with a supervisory authority

(1) The data subject has the right to lodge a complaint with a supervisory authority if the data subject considers that the processing of personal data relating to them infringes this Regulation, in accordance with Article 77 of the Regulation.

(2) The right to lodge a complaint can be exercised by the data subject with the following contact details:

National Authority for Data Protection and Freedom of Information, Address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c., Phone: +36 (1) 391-1400, Fax: +36 (1) 391-1410, Website: http://www.naih.hu, Email: ugyfelszolgalat@naih.hu.

(3) The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint, including the possibility of a judicial remedy under Article 78 of the Regulation.

Right to an effective judicial remedy against a supervisory authority

(1) Without prejudice to any available administrative or non-judicial remedy, including the right to lodge a complaint with a supervisory authority pursuant to Article 77, every data subject shall have the right to an effective judicial remedy where the data subject considers that their rights under this Regulation have been infringed as a result of the processing of their personal data in non-compliance with this Regulation.

(2) Proceedings against a supervisory authority shall be brought before the courts of the Member State where the supervisory authority is established.

(3) Where proceedings are brought against a decision of a supervisory authority which was preceded by an opinion or a decision of the Board in the consistency mechanism, the supervisory authority shall forward that opinion or decision to the court.

Right to an effective judicial remedy against a data controller or processor

(2) Proceedings against a data controller or a processor shall be brought before the courts of the Member State where the data controller or processor has an establishment.

Limitations

(1) Union or Member State law may restrict the scope of the rights and obligations referred to in Articles 12 to 22 and Article 34 in respect of the data controller or processor with regard to the processing of personal data in order to reconcile the right to the protection of personal data with the rights and freedoms of data subjects, where such restrictions respect the essence of those rights and freedoms and are necessary and proportionate in a democratic society for one of the following:

National security;
Defense;
Public security;
The prevention, investigation, detection or prosecution of criminal offenses, including the safeguarding against and the prevention of threats to public security and the execution of criminal penalties;
Other important objectives of general public interest of the Union or of a Member State, in particular an important economic or financial interest of the Union or of a Member State, including monetary, budgetary, and taxation a matters, public health and social security;
The protection of judicial independence and judicial proceedings;
Professional secrecy obligations;
The protection of the data subject or the rights and freedoms of others;
The enforcement of civil law claims.

(2) In cases involving restrictions as per paragraph (1), the applicable legislation shall contain specific provisions at least as to:

The purposes of the processing or categories of processing;
The categories of personal data;
The data subject’s rights to be informed about the restriction;
The obligations of the data controller or processor to ensure compliance with the restriction;
The period for which the restriction applies;
The risks to the rights and freedoms of data subjects;
The right of data subjects to be informed about the restriction, unless such a notification would be detrimental to the purpose of the restriction.

Notification of a personal data breach to the data subject

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

(2) The communication to the data subject referred to in paragraph (1) of this Article shall describe in clear and plain language the nature of the personal data breach and contain at least:

The name and contact details of the data protection officer or other contact point where more information can be obtained;
A description of the likely consequences of the personal data breach;
A description of the measures taken or proposed to be taken by the data controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.

(3) The data subject does not need to be notified if any of the following conditions are met:

The data controller has implemented appropriate technical and organizational protection measures and those measures were applied to the personal data affected by the personal data breach, in particular those that render the personal data unintelligible to any person who is not authorized to access it, such as encryption;
The data controller has taken subsequent measures which ensure that the high risk to the rights and freedoms of data subjects is no longer likely to materialize;
Notification would involve disproportionate effort. In such a case, there shall instead be a public communication or similar measure whereby the data subjects are informed in an equally effective manner.

(4) If the data controller has not already communicated the personal data breach to the data subject, the supervisory authority, having considered the likelihood of the personal data breach resulting in a high risk, may require it to do so or may decide that one or more of the conditions referred to in paragraph (3) are met.

VI. PROCEDURE FOR HANDLING REQUESTS FROM THE DATA SUBJECT

(1) The Enterprise facilitates the exercise of the data subject’s rights and shall not refuse to fulfill a request related to the exercise of rights as specified in this data processing notice, unless it can demonstrate that it is unable to identify the data subject.

(2) The Enterprise shall inform the data subject of the measures taken in response to the request without undue delay, and in any case, within one month from the receipt of the request. This period may be extended by an additional two months if necessary, taking into account the complexity and the number of requests. The data controller shall inform the data subject of any such extension within one month of receiving the request, providing reasons for the delay.

(3) If the data subject submitted the request electronically, the information shall, as far as possible, be provided electronically, unless the data subject requests otherwise.

(4) If the Enterprise does not take action on the data subject’s request, it shall inform the data subject without undue delay, but no later than one month from the receipt of the request, of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.

(5) The Enterprise shall provide the data subject with the following information and actions free of charge: feedback on the processing of personal data, access to the processed data, rectification, completion, erasure, restriction of processing, data portability, objection to processing, and notification of a personal data breach.

(6) If the data subject’s request is clearly unfounded or, especially due to its repetitive character, excessive, the data controller may charge a fee of 5,000 HUF or refuse to take action based on the request, considering the administrative costs associated with providing the requested information or action.

(7) The burden of proving that the request is clearly unfounded or excessive lies with the data controller.

(8) Without prejudice to Article 11 of the Regulation, if the data controller has reasonable doubts concerning the identity of the natural person making a request pursuant to Articles 15 to 21 of the Regulation, it may request further information necessary to confirm the data subject’s identity.

VII. PROCEDURE FOR PERSONAL DATA BREACHES

(1) A personal data breach, as defined by the Regulation, is a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data that has been transmitted, stored, or otherwise processed.

(2) A personal data breach includes the loss or theft of devices containing personal data (e.g., laptops, mobile phones) or the loss of access to or decryption codes used by the data controller. It also encompasses ransomware infections that render data inaccessible until a ransom is paid, attacks on information systems, unintentional disclosure of personal data via email, public exposure of mailing lists, and similar incidents.

(3) Upon detecting a personal data breach, a representative of the Enterprise shall promptly conduct an investigation to identify the breach and determine its potential consequences. Necessary measures must be taken to mitigate the damage.

(4) The personal data breach shall be reported to the competent supervisory authority without undue delay and, where feasible, no later than 72 hours after becoming aware of the breach, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. If the notification is not made within 72 hours, it must be accompanied by reasons for the delay.

(5) The data processor shall promptly notify the data controller of the personal data breach upon becoming aware of it.

(6) The notification mentioned in paragraph (4) shall include at least:

a description of the nature of the personal data breach, including, if possible, the categories and approximate number of data subjects affected and the categories and approximate number of personal data records involved;
the name and contact details of the data protection officer or other contact point providing further information;
a description of the likely consequences of the personal data breach;
a description of the measures taken or proposed by the data controller to address the personal data breach, including, where applicable, measures to mitigate any possible adverse effects.

(7) If it is not possible to provide the information simultaneously, it may be provided in phases without undue delay.

(8) The data controller shall maintain a record of personal data breaches, including the facts, effects, and remedial actions associated with each breach. This record allows the supervisory authority to verify compliance with the requirements of Article 33 of the Regulation.

VIII. DATA PROCESSING RELATED TO THE WEBSITE

Information Regarding Data of Visitors to the Company’s Website

(1) When visitors access the Company’s website, one or more cookies—small packets of information sent by the server to the browser and then sent back to the server with every request made towards the server—are sent to the visitor’s computer. These cookies allow the visitor’s browser to be uniquely identified, provided that the visitor, following clear and unambiguous information, has given explicit (active) consent for further browsing of the website.

(2) Cookies are used solely to enhance user experience and automate the login process. Cookies used on the website do not store information suitable for personal identification, and the Company does not engage in personal data processing within this scope.

Online Contact and Online Quote Request

(1) The legal basis for data processing in case of online contact and online quote requests is the consent of the data subject, given by checking the checkbox on the “contact” or “quote request” forms on the Company’s website after being provided with information on the processing of their data.

(2) The data subjects in the context of online contact and quote requests are any natural persons who wish to get in touch with the Company or request a quote through the website and provide their consent for the processing of their personal data.

(3) The scope of the processed data for contact requests includes: name, phone, and email address.

(4) The scope of the processed data for quote requests includes: name, address, phone, and email address.

(5) The purpose of data processing in case of contact requests is to inform the data subject about the requested information.

(6) The purpose of data processing in case of quote requests is to inform the data subject about the requested services.

(7) Recipients of the data (those who may access the data) in the context of contact and quote requests include the Company’s manager, customer relations personnel, marketing personnel, and data processors responsible for the operation of the Company’s website.

The Use of Google Analytics

(1) This website uses Google Analytics, which is a web analytics service provided by Google Inc. Google Analytics uses so-called “cookies,” text files that are stored on your computer and allow an analysis of your website usage.

(2) Information created through cookies related to your use of this website is generally transmitted to and stored on one of Google’s servers in the United States. When IP anonymization is activated on this website, Google will shorten your IP address within member states of the European Union or other states that are part of the European Economic Area.

(3) Only in exceptional cases will the full IP address be transmitted to a Google server in the United States and shortened there. Google will use this information on behalf of the operator of this website to evaluate your use of the website, compile reports on website activity, and provide the website operator with further services related to website and internet usage.

(4) Within the framework of Google Analytics, the IP address transmitted by your browser is not associated with any other data held by Google. You can prevent cookies from being stored by selecting the appropriate settings in your browser. However, please note that if you do this, you may not be able to use all the features of this website. Additionally, you can prevent Google from collecting and processing data generated by cookies and related to your website usage (including your IP address) by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en

IX. CUSTOMER RELATIONS AND OTHER DATA PROCESSING

If data subjects have questions or encounter problems while using the Data Controller’s services, they can contact the Data Controller through the means provided on the website (postal mail, phone, email).
The Data Controller retains emails, messages, and phone data received with the name and email address of the inquirer and other voluntarily provided personal data for up to 2 years from the date of disclosure. After the 2-year retention period has expired, data will be deleted due to business interests.
For data processing not mentioned in this notice, information will be provided at the time of data collection.
In case of exceptional authority requests or requests from other authorities based on statutory authorization, the Service Provider is obliged to provide information, disclose, transfer, or make documents available.
In such cases, the Service Provider will only disclose personal data to the requesting party as much as is essential to achieve the purpose of the request, provided that the precise purpose and scope of data have been indicated.

X. DATA PROCESSING RELATED TO CONTRACT PERFORMANCE

(1) The Company processes the personal data of natural persons who enter into a contractual relationship with it, such as customers, buyers, and suppliers. Data subjects must be informed about the processing of their personal data.

(2) Data subjects include all natural persons who establish a contractual relationship with the Company.

(3) The legal basis for data processing is the performance of a contract, and the purpose of data processing is to maintain contact, enforce claims arising from the contract, and ensure compliance with contractual obligations.

(4) Recipients of the personal data include the Company’s manager, employees responsible for customer service and accounting tasks, as well as data processors.

(5) The scope of the processed personal data includes: name, address, phone number, email address, tax identification number, bank account number, business license number, individual farming license number.

(6) The duration of data processing is 5 years from the termination of the contract.

XI. PROVISIONS REGARDING DATA SECURITY

(1) The Company processes personal data only in accordance with the activities specified in this regulation and for the purpose of data processing.

(2) The Company ensures the security of data and undertakes to take all technical and organizational measures that are essential to enforce data security regulations, data protection rules, and confidentiality regulations in effect, and to establish the procedural rules required for the enforcement of the above.

(3) The Company protects data with appropriate measures against unauthorized access, alteration, transmission, disclosure, deletion, or destruction, as well as against accidental destruction or damage, and also against becoming inaccessible due to changes in technology.

(4) Technical and organizational measures to be taken by the Company to ensure data security are specified in the Company’s data protection policy.

(5) When determining and applying measures to ensure data security, the Company takes into account the current level of technology and, in cases where there are multiple data processing solutions, chooses the solution that provides a higher level of personal data protection, unless it would entail disproportionate difficulty.

XII. RULES REGARDING DATA PROCESSING

General Rules on Data Processing

(1) The rights and obligations of the data processor with respect to the processing of personal data are determined by law and specific data processing laws within the framework set by the data controller.

(2) The Company declares that the data processor does not have the competence to make substantive decisions regarding data processing, and data received can only be processed in accordance with the data controller’s instructions. It cannot perform data processing for its own purposes, and it is obligated to store and preserve personal data in accordance with the data controller’s instructions.

(3) The Company is responsible for the legality of the instructions regarding data processing issued to the data processor.

(4) The Company is obliged to provide information about the data processor’s identity and the location of data processing to data subjects.

(5) The Company does not authorize the data processor to use additional data processors.

(6) Contracts for data processing must be in writing. Organizations involved in the business that uses the personal data to be processed should not be entrusted with data processing.

This notice is effective from May 25, 2018.