I. Data of the Data Controller

Name: KLIMATRIO Trading and Service Limited Liability Company

Headquarters: 7622 Pécs, Légszeszgyár u. 40.

Tax number: 11016621-2-02

Company registration number: 02-09-062993

Representative: Gábor Reitz, managing director (senior officer)

Correspondence address, complaint handling: 7622 Pécs, Légszeszgyár u. 40.

E-mail: info@klimatrio.hu

Phone number: +3672512240

Website: https://www.szellozes-joaron.us/

II. Description of data processing carried out during the operation of the webshop and the performance of contracts

II.1. Contact

Content and purpose of data processing
Receiving your inquiry, answering your question and maintaining contact as necessary, for example, if you contact us with a question by email, contact form or telephone. Prior contact is not mandatory, you can order from the webshop at any time without doing so.

Processed data
All data provided by you during contact (Name, address, e-mail address, telephone number).

Duration of data processing
We process the data until the relationship is established or terminated.

Legal basis for data processing
Your voluntary consent, which you provide to the Data Controller when contacting us. [Data processing pursuant to Article 6(1)(a) of the Regulation]

II.2. Registration on the website

Content and purpose of data processing
By storing the data provided during registration, the Data Controller can provide a more convenient service (e.g. the data subject does not have to be provided again when making a new purchase). Registration is not a condition for concluding a contract

Data processed
During data processing, the Data Controller processes your name, address, telephone number, e-mail address, the characteristics of the purchased product and the time of purchase.

Duration of data processing
Until the registered person withdraws their consent or their registration is deleted.

Legal basis for data processing
Your voluntary consent, which you provide to the Data Controller by registering [Data processing pursuant to Article 6(1)(a) of the Regulation]

II.3. Order processing

Content and purpose of data management
Order processing, fulfillment, and order-related contact (including sending notifications about order statuses, sending invoices) are carried out as data management activities necessary for the performance of the contract.

Processed data
During data management, the Data Controller processes your name, address, telephone number, e-mail address, characteristics of the purchased product, order number, and date of purchase.

Duration of data management
We process the data for 5 years from the performance of the contract, according to the civil law statute of limitations.

Legal basis for data processing
Performance of the contract concluded with you as a customer. [Data processing pursuant to Article 6(1)(b) of the Regulation]

II.4. Issuance of the invoice

Content and purpose of data management

The data management process is carried out in order to issue invoices in accordance with the law and to fulfill the obligation to retain accounting documents. According to Section 169 (1)-(2) of Act C of 2000 on Accounting (hereinafter: Sztv.), business companies must retain accounting documents that directly and indirectly support the accounting settlement

Data processed
Name, address, e-mail address and telephone number.

Duration of data management
The invoices issued are stored in accordance with the Sztv. Pursuant to Section 169 (2) of the Hungarian VAT Act, it must be retained for 8 years from the date of issue of the invoice.

Legal basis for data processing

Fulfillment of a legal obligation. Pursuant to Section 159 (1) of the Hungarian VAT Act of 2007, the issuance of an invoice is mandatory and pursuant to Section 169 (2) of the Hungarian VAT Act, it must be retained for 8 years [Data processing pursuant to Article 6 (1) c) of the Regulation].

II.5. Data processing related to the delivery of goods

Content and purpose of data processing
We will deliver your order to the address you have provided, using the delivery method you have selected, with the help of our partners.

Data processed
Name, address, e-mail address and telephone number.

Duration of data processing
The Data Controller processes the data until the delivery of the ordered goods.

Legal basis for data processing
Legal basis for data processing Performance of contract [Regulation Article 6(1) b) data processing].

II.6. Handling of warranty and guarantee claims

Content and purpose of data processing
When handling warranty and guarantee claims, the 19/2014. (IV. 29.) NGM Decree, which also determines how your claim should be handled.

Processed data

When handling warranty and guarantee claims, we must act in accordance with the rules of NGM Decree 19/2014. (IV. 29.) NGM Decree.

According to the regulation, we are obliged to record a report on the warranty or guarantee claim reported to us, in which we record:

1. your name, address and your declaration that you consent to the processing of your data recorded in the report in accordance with the provisions of the regulation,
2. the name and purchase price of the movable property sold under the contract concluded between you and us,
3. the date of performance of the contract,
4. the date of notification of the defect,
5. a description of the defect,
6. the right you wish to assert based on your warranty or guarantee claim, and
7. the method of settling the warranty or guarantee claim or the reason for rejecting the claim or the right you wish to assert based on it.

If we take over the purchased product from you, we will we must issue a receipt, which must include

1. your name and address,
2. the data necessary to identify the item,
3. the date of receipt of the item, and
4. the date when you can receive the repaired item.

Duration of data processing
The company shall keep a record of the consumer’s warranty or guarantee claim in accordance with Act No. 19/2014. (IV. 29.) NGM Decree, it is obliged to keep it for three years from the date of its recording and to present it to the supervisory authority upon request.

Legal basis for data processing
The legal basis for data processing is compliance with the legal obligations pursuant to [Article 4 (1) and (6) of Decree 19/2014 (IV. 29.) NGM, as well as Article 6 (1) of the Regulation] [data processing pursuant to Article 6 (1) c) of the Regulation].

II.7. Handling other consumer protection complaints

Content and purpose of data processing

You have the opportunity to file a consumer protection complaint. The purpose of data processing is to investigate, respond to and document consumer protection complaints related to the webshop.

A consumer protection complaint is an objection to the conduct, activity or omission of a person acting in our interest or on our behalf, directly related to the distribution or sale of goods to you, and aimed at eliminating an individual violation of rights or interests (complaint pursuant to Section 2, Section 28a of the 1997 CLV Act on Consumer Protection).

If you have contacted us with a complaint, data processing and the provision of data are essential in order to investigate the complaint.

Processed data

The minutes of the complaint must include the following:

1. your name, address or e-mail address,
2. place, time and method of submitting the complaint,
3. a detailed description of your complaint, a list of the documents, records and other evidence presented by you,
4. our statement of our position on your complaint, if immediate investigation of the complaint is possible,
5. the signature of the person taking the minutes and – with the exception of a verbal complaint submitted by telephone or using other electronic communications services – your signature,
6. place and time of recording the minutes,
7. in the case of a verbal complaint submitted by telephone or using other electronic communications services, the complaint is unique identification number.)

Duration of data processing
We retain warranty complaints for 3 years under the Consumer Protection Act.

Legal basis for data processing
It is your voluntary decision whether to contact us with a complaint, however, if you contact us, we are obliged to process it according to Section 17/A of Act CLV of 1997 on Consumer Protection [Data processing pursuant to Article 6(1)(c) of the Regulation].

II.8. Right of withdrawal/termination

Content and purpose of data processing
The purpose of data processing is to ensure the exercise of the right of withdrawal. The processing of data related to the contract in question is carried out within the framework of the management of the right of withdrawal (receiving the withdrawal/termination declaration, identifying the order or contract concerned, processing and confirming the declaration, handling the withdrawal/termination, and later confirming the withdrawal/termination).

Processed data

In the event of withdrawal and termination, we process the following data related to your withdrawal:

• Name,
• Order or contract identification data,
• Content of the withdrawal/termination declaration,
• If you request a payment method other than the one used for payment to be used for the refund of the purchase price of the product, the data related to the refund (e.g. bank account number)

If you If you submit your withdrawal or termination statement using the withdrawal function in accordance with Government Decree 45/2014. (II. 26.), we will also process the following technical data:

• the exact date and time of submission and receipt of the declaration,
• e-mail address or other electronic contact information,
• data related to sending confirmation of receipt of the declaration of withdrawal/termination

Duration of data processing
The Data Controller processes personal data related to the declaration of withdrawal/termination and its processing and management for 3 calendar years from the date of exercise of the right of withdrawal/termination. Data retention is the legitimate interest of the Data Controller in order to be able to prove the fact of handling the withdrawal and the measures taken in connection with it in the event of a consumer protection or other official/judicial procedure.

Legal basis for data processing

The legal basis for data processing necessary for the administration of the right of withdrawal/termination, termination of the contract, return, refund and contact is Article 6(1)(b) of the Regulation, i.e. the administration related to the performance or termination of the contract concluded with the data subject.

The legal basis for the retention of personal data related to the exercise of the withdrawal based on the legitimate interest related to the defense against consumer claims is Article 6(1)(f) of the GDPR, i.e. the legitimate interest of the data controller.

II.9. Data processed in connection with the verification of consent

Content and purpose of data processing
In the case of data processing based on consent, especially during registration and newsletter subscription, the IT system stores the IT data related to the consent for the purpose of later verification.

Data processed
Date of consent and IP address of the data subject.

Duration of data processing
The data is processed for the duration of the data processing related to the consent.

Legal basis for data processing
The data subject’s consent [Regulation Data processing pursuant to Article 6(1)(a)].

II.10. Data processing related to sending newsletters

Content and purpose of data processing
The data processing process is carried out in order to send newsletters.

Data processed
Name, e-mail address

Duration of data processing
Until the date of unsubscribing from the newsletter or until the date of the deletion request being fulfilled in another way, or until the withdrawal of the data subject’s consent.

Legal basis for data processing
Your voluntary consent, which you provide to the Data Controller by subscribing to the newsletter [Article 6(1) of the Regulation] a) data processing]

II.11. Data processing related to sending and displaying personalized advertisements

Content and purpose of data processing
When sending newsletters, we formulate personalized advertisements for you.

Data processed
Name, address, e-mail address, telephone number, data on previous purchases.

Duration of data processing
Until you withdraw your consent.

Legal basis for data processing
Your voluntary, separate consent that you provide to the Data Controller during data collection [Regulation Article 6 (1) paragraph a) data processing]

III. Information on the use of cookies

III.1. What is a cookie?

The Data Controller uses so-called cookies when visiting the website. A cookie is a package of letters and numbers that our website sends to your browser in order to save certain settings, make our website easier to use and help us collect some relevant statistical information about our visitors.

Some cookies do not contain personal information and are not suitable for identifying an individual user, but some contain a unique identifier – a secret, randomly generated string of numbers – that is stored on your device, thus ensuring your identification. The operating period of each cookie is included in the relevant description of each cookie.

You can also disable cookies in your browser settings, more information can be found at the following links:

• Internet Explorer:  http://windows.microsoft.com/en-us/internet-explorer/delete-manage-cookies#ie=ie-11
• Firefox:  https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
• Mozilla: https://support.mozilla.org/hu/kb/weboldalak-altal-elhelyezett-sutik-torlese-szamito
• Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
• Chrome: https://support.google.com/chrome/answer/95647
• Edge: https://support.microsoft.com/hu-hu/help/4027947/microsoft-edge-delete-cookies

III.2. A cookie-k jogszabályi háttere és jogalapja:

Alapvetően három típusú cookiet különböztetünk meg, a működéshez elengedhetetlen cookie-t, ami a Weboldal megfelelő működését szolgálja, statisztikai célú és marketing célú cookiekat.

Az adatkezelés jogalapja a Rendelet 6. cikk (1) bekezdés a) pontja alapján az Ön hozzájárulása a statisztikai és a marketing célú cookie-k esetében, valamint a Rendelet 6. cikk (1) bekezdés f) pontja szerint a Weboldal működésének biztosításához szükséges jogos érdek, a működéshez szükséges cookiek esetében.

III.3. A honlap által használt cookie-k főbb jellemzői:

A működéshez elengedhetetlen cookie-k:

Amennyiben Ön nem fogadja el ezen cookie-k használatát, akkor bizonyos funkciók nem biztos, hogy elérhetőek lesznek az Ön számára.

A működéshez szigorúan szükséges cookie-k: Ezek a cookie-k a weboldal használatához nélkülözhetetlenek, és lehetővé teszik a weboldal alapvető funkcióinak használatát. Ezek hiányába az oldal számos funkciója nem lesz elérhető az Ön számára. Ezen típusú cookie-k élettartama kizárólag a munkamenet idejére korlátozódik.

Munkamenet cookie: Ezek a sütik a látogató tartózkodási helyét, a böngésző nyelvét, a fizetés pénznemét tárolják, élettartamuk a böngésző bezárása, vagy maximum 2 óra.

Korhatáros tartalom cookie: Ezek a sütik a korhatáros tartalom jóváhagyásának tényét és azt rögzítik, hogy az érintett 18 éven felüli, élettartamuk a böngésző bezárásáig tart.

Ajánlott termékek cookie: Az „ajánlom ismerősömnek” funkciónál az ajánlani kívánt termékek listáját rögzíti. Élettartama 60 nap.

Mobil verzió, design cookie: Érzékeli a látogató használt eszközt, és mobilon átvált teljes nézetre. Élettartama 365 nap.

Cookie elfogadás cookie: Az oldalra érkezéskor a figyelmeztető ablakban elfogadja a cookiek tárolásáról szóló nyilatkozatot. Élettartama 365 nap.

Exit #2 cookie: According to option #2, the system logs the visitor out after 90 days. Its lifetime is 90 days.

Backend identification cookie: The identifier of the backend server serving the page. Its lifetime lasts until the browser is closed.

Barion Pixel cookies Barion Payment Zrt. uses cookies (these are the ba_vid, ba_vid.xxx, and ba_sid cookies) to prevent fraud when using the Barion payment solution, and these also process personal data (profile). In the case of Barion payment, this Seller can only ensure payment by using these cookies, and cannot disable them. The purpose of the ba_vid cookie, according to the Barion Cookie information: to filter out bank card fraud based on the digital fingerprint of the device used by the Buyer and their browsing habits. The use of the cookie is necessary to recognize fraudsters. The cookie ensures that we know that the data from browsing habits comes from a user. The purpose of the ba_vid.xxx cookie, according to the Barion Cookie information: to filter out bank card fraud based on the digital fingerprint of the device used by the Buyer and their browsing habits. The cookie ensures that Barion Zrt. can track browsing habits between two sessions on the given website. This data is collected by: ba_vid, user-related ID, which is a hash compiled from the browser properties, based on which the timestamp of the first, current and last visit to the given website is calculated, the current session ID, permission for third-party cookies. The purpose of the ba_sid cookie, according to the Barion Cookie Information: to filter out bank card fraud based on the digital fingerprint of the device used by the Customer and their browsing habits. The cookie ensures that the session can be identified across Barion Zrt. websites. The storage period of the ba_vid and ba_vid.xxx cookies is 1.5 years from the last update, the storage period of the ba_sid cookie is 30 minutes. The data is stored by Barion Zrt. The Barion Cookie Policy is available here: https://www.barion.com/hu/suti-tajekoztato/

Cookies for statistical purposes:

Google Analytics cookie: Google Analytics is Google’s analytics tool that helps website and app owners get a more accurate picture of their visitors’ activities. The service may use cookies to collect information and report on statistical data about website usage without individually identifying visitors to Google. The main cookie used by Google Analytics is the “__ga” cookie.

In addition to reporting on website usage statistics, Google Analytics – together with some of the advertising cookies described above – may also be used to display more relevant ads in Google products (such as Google Search) and across the web.

Google Analytics cookie lifetime:_ga – 2 years; ga – 2 years.

Analytics cookies store information about you if you have consented to the use of cookies in the cookie management panel and Google stores the fact of consent using Google Consent mode v2. In this case, Google will also have information about if you later withdraw this consent.

Cookies to improve user experience: These cookies collect information about the user’s use of the website, for example, which pages are visited most often or what error messages are received from the website. These cookies do not collect information that identifies the visitor, i.e. they work with completely general, anonymous information. We use the data obtained from them to improve the performance of the website. The lifespan of these types of cookies is limited to the duration of the session only.

Referer cookies: They record the external website from which the visitor came to the site. Their lifespan lasts until the browser is closed.

Last viewed product cookie: Records the products that the visitor last viewed. Their lifespan is 60 days.

Last viewed category cookie: Records the last viewed category. Lifespan 60 days.

Cart cookie: Records the products placed in the cart. Lifespan 365 days.

Smart offer cookie: Records the conditions for displaying smart offers (e.g. whether the visitor has already been to the site, whether they have an order). Lifespan 30 days.

Marketing cookies:

Google Adwords cookie When someone visits our site, the visitor’s cookie ID is added to the remarketing list.

Google uses cookies, such as NID and SID cookies, to personalize the ads you see on Google products, such as Google Search. For example, Google uses such cookies to remember your recent searches, your previous interactions with ads or search results from individual advertisers, and your visits to advertisers’ websites. AdWords conversion tracking uses cookies. Cookies are placed on a user’s computer when a person clicks on an ad to track sales and other conversions resulting from an ad.

Some common uses of cookies include: selecting ads based on what is relevant to a given user, improving campaign performance reporting, and avoiding showing ads that a user has already seen.

Google Adwords cookie lifetime:
NID – 6 months;
_gcl_aw – 90 days;
_gcl_au – 90 days;
Conversion – 90 days.

Adwords cookies store information about you if you have consented to the use of cookies in the cookie management panel and Google stores the fact of consent using Google Consent mode v2. In this case, Google will also have information about if you later withdraw this consent.

Remarketing cookies: They may be displayed to previous visitors or users when browsing other websites in the Google Display Network or when searching for terms related to your products or services.

Remarketing cookies store information about you if you have consented to the use of cookies in the cookie management panel and Google stores the fact of consent using Google Consent mode v2. In this case, Google will also have information about if you later withdraw this consent.

Facebook pixel (Facebook cookie) The Facebook pixel is a code that is used to generate reports on conversions on the website, create target audiences, and provide the website owner with detailed analysis data on the use of the website by visitors.
With the help of the Facebook pixel, you can display personalized offers and advertisements to website visitors on the Facebook interface.
Facebook pixel cookies used and their lifespan:_fbp – 3 months; fr – 3 months

IV. Recipients of personal data

IV.1. The scope of data processors used by the Data Controller

Data processor: the natural or legal person, public authority, agency or any other body that processes personal data on behalf of the data controller.

IV.1.1. Hosting provider

Name of the data processor: UNAS Online Kft.

Contact details of the data processor:

Phone number:

E-mail address: unas@unas.hu

Head office: 9400 Sopron, Kőszegi út 14.

Website: unas.hu

The Data Processor stores personal data based on the contract concluded with the Data Controller. It is not authorized to view personal data.

IV.1.2. Data processing related to sending newsletters

Name of the company operating the newsletter system: UNAS Newsletter Sender; UNAS Online Kft.

Headquarters of the company operating the newsletter system: 9400 Sopron, Kőszegi út 14.

Telephone number of the company operating the newsletter system:

Email address of the company operating the newsletter system: unas@unas.hu

Website of the company operating the newsletter system: unas.hu

The Data Processor participates in sending newsletters based on the contract concluded with the Data Controller.

IV.1.3. Data processing related to sending newsletters

Name of the company operating the newsletter sending system: MailerLite

Headquarters of the company operating the newsletter sending system: J. Basanavičiaus g. 26, Vilnius, Lithuania, LT 03224

Newsletter system operator phone number: MailerLite does not list a public phone number on its official website. They cannot be reached directly by phone.

Newsletter system operator email address: support@mailerlite.com

Newsletter system operator website: https://www.mailerlite.com/

The Data Processor participates in sending newsletters based on a contract concluded with the Data Controller.

IV.1.4. Data processing related to billing

Name of the data processor: Kulcs-Soft Management and billing system

Headquarters of the data processor: 1016 Budapest, Mészáros u. 13,

Data processor’s telephone number:  06 1 336 5300

Data processor’s e-mail address: ugyvitel@kulcs-soft.hu

Data processor’s website: https://www.kulcs-soft.hu/

The Data Processor participates in the issuance and registration of accounting documents based on the contract concluded with the Data Controller.

IV.1.5. Data processing related to the operation of the CRM system

Name of the data processor: UNAS Online Kft.

Registered office of the data processor: 9400 Sopron, Kőszegi út 14.

Phone number of the data processor:

Email address of the data processor: unas@unas.hu

Website of the data processor: unas.hu

The Data Processor participates in the registration of orders based on the contract concluded with the Data Controller.

IV.1.6. Data processing related to the use of the withdrawal function

Name of the data processor: UNAS Online Kft.

Registered office of the data processor: 9400 Sopron, Kőszegi út 14.

Phone number of the data processor:

Email address of the data processor: unas@unas.hu

Website of the data processor: unas.hu

The Data Processor contributes to the technical provision and operation of the online withdrawal function based on a written contract concluded with the Data Controller.

IV.2. Data transfer to third parties

The Data Controller transfers data to third parties (recipients) as follows. These recipients process the data as independent data controllers, not according to the instructions of the Data Controller, but according to their own data processing policies.

IV.2.1. Recipients of data processing related to the transport of goods

Name of the recipient: Magyar Posta Zártkórűen Működő Részvénytársaság

Head office of the recipient: 1138 Budapest, Dunavirág utca 2-6.

Telephone number of the recipient: +36-1/767-8200

Email address of the recipient: ugyfelszolgalat@posta.hu

Recipient’s website: posta.hu

The courier service assists in the delivery of the ordered goods based on the contract concluded with the Data Controller. The courier service processes the personal data received in accordance with the data processing information available on its website.

Purpose of data transfer: to provide the courier service with purchase-related data in order to implement the delivery.

Legal basis for data transfer: the performance of the contract concluded between you and the Data Controller based on Article 6(1)(b) of the Regulation, which also includes the delivery of the product, if you have chosen a delivery method during the order.

IV.2.2. Recipients of data processing related to the delivery of goods

Name of the recipient: PXP Courier Service

Headquarters of the recipient: 2220 Vecsés, Fő út 1.

Phone number of the recipient: +36 20 773 3399

Email address of the recipient: info@pannonxp.hu

Website of the recipient: https://pannonxp.hu/?gad_source=1

The courier service with the Data Controller participates in the delivery of the ordered goods based on a concluded contract. The courier service processes the personal data received in accordance with the data processing information available on its website.

Purpose of data transfer: to provide the courier service with purchase-related data in order to carry out the delivery.

Legal basis for data transfer: the performance of the contract concluded between you and the Data Controller pursuant to Article 6(1)(b) of the Regulation, which also includes the delivery of the product, if you have chosen a delivery method during the order.

IV.2.3. Data transfer related to online payment

Name of the data controller: Barion Payment Kft.

Headquarters of the data controller: 1117, Budapest, Irinyi József utca 4-20. 2nd floor

Phone number of the data controller:  +3614647099

Data controller’s e-mail address: barion@barion.com

Data controller’s website: https://www.barion.com/hu/

Purpose of data transfer: 

The payment service provider participates in the execution of online payments based on a contract concluded with the Data Controller, for which purpose data is transferred to the online payment service provider during the purchase process in order to implement the payment transaction.

The purpose of data transfer: to provide the online payment service provider with the transaction data necessary for the payment transaction initiated by it related to the purchase.

Scope of data transferred: As part of the data transfer, we transfer the data necessary for the execution of the payment transaction to the payment service provider, in particular the amount to be paid, order identifier, email data.

Legal basis for data transfer: The performance of the contract concluded between you and the Data Controller pursuant to Article 6(1)(b) of the Regulation, part of which is payment by the buyer, and in the case of online payment, the payment requires the transfer of data in accordance with this point

V. Your rights during data processing

Within the period of data processing, you are entitled to the rights indicated in this information according to the provisions of the Regulation.

If you wish to exercise your rights, this will involve your identification, and the Data Controller will necessarily have to communicate with you. Therefore, for the purpose of identification, it will be necessary to provide personal data (but the identification may only be based on data that the Data Controller already processes about you), and your complaints regarding data processing will be available in the Data Controller’s email account within the period specified in this information regarding complaints.

The Data Controller will respond to complaints related to data processing within 30 days at the latest.

V.1. Right to withdraw consent

You have the right to withdraw your consent to data processing at any time. In this case, we will delete your personal data based on your consent from our systems.

V.2. Right to access personal data

You have the right to receive feedback from us about whether we are processing your personal data. If so, you have the right to access this data and to be informed about:

• the purposes for which we process your personal data;
• what types (categories) of personal data we process about you;
• to whom and to what recipients we have or may transfer the personal data;
• how long we store the personal data or, if this cannot be determined in advance, on what grounds we determine the duration of the data processing;
• what rights you have to rectify, erase or restrict the processing of your personal data, as well as to object in the case of processing based on legitimate interests;
• the possibility of lodging a complaint with a supervisory authority;
• if we did not obtain the data from you, the source of the data;
• whether we use automated decision-making (including profiling), and if so, its essence, logic and expected effects on you.

The purpose of exercising the right of access is primarily to verify the lawfulness of data processing. If you unreasonably frequently request information with the same content, we are entitled to charge a fair fee.

V.3. Right to rectification

You have the right to obtain from the Controller, upon request, the rectification of inaccurate personal data concerning you without delay.

V.4. Right to restriction of processing

You have the right to obtain from the Controller restriction of processing where one of the following applies:

• You contest the accuracy of the personal data, in which case the restriction shall apply for a period of time enabling the Controller to verify the accuracy of the personal data; if the accuracy of the data is immediately ascertainable, the restriction shall not apply;
• The processing is unlawful, but you oppose the erasure of the data for any reason (for example, because the data are important to you for the exercise of legal claims), and therefore you do not request the erasure of the data, but instead request the restriction of their use;
• The Controller no longer needs the personal data for the purposes of the specified processing, but you require them for the establishment, exercise or defence of legal claims; or
• You have objected to the processing, but the legitimate interests of the Data Controller may also justify the processing, in which case the processing must be restricted until it is determined whether the legitimate interests of the Data Controller override your legitimate interests.

If processing is subject to restriction, such personal data may only be processed, with the exception of storage, with the consent of the data subject, or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or for important public interests of the Union or of a Member State.

V.5. Right to erasure – right to be forgotten

You have the right to obtain from the Data Controller the erasure of personal data concerning you without undue delay where one of the following grounds applies:

• the personal data are no longer necessary for the purposes for which they were collected or otherwise processed by the Data Controller;
• you withdraw your consent and there is no other legal basis for the processing;
• you object to the processing based on legitimate interest and there is no overriding legitimate reason (i.e. legitimate interest) for the processing,
• the personal data have been processed unlawfully by the Data Controller and this has been established on the basis of a complaint,
• the personal data must be erased for compliance with a legal obligation to which the Data Controller is subject under Union or Member State law.

Erasing shall not apply where the processing is necessary:

• the processing of the personal data is necessary for the purposes for which the Data Controller is responsible for the processing of the personal data. compliance with a mandatory obligation under EU or Member State law applicable to the controller (such a case is data processing carried out in the context of invoicing, since the retention of the invoice is required by law), or for the purpose of performing a task carried out in the public interest or in the exercise of official authority vested in the controller;
• for the establishment, exercise or defence of legal claims (e.g. if the Controller has a claim against you and has not yet satisfied it, or a consumer or data processing complaint is in progress).

V.6. Right to object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data based on legitimate interest. In such a case, the Data Controller shall no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.

V.7. Right to portability

If the data processing is based on your voluntary consent or is carried out in order to fulfill a contractual obligation, you have the right to request the Data Controller to receive the data you have provided to the Data Controller, which the Data Controller will make available to you in xml, JSON, or csv format, if this is technically feasible, you may request that the Data Controller transmit the data in this form to another data controller.

V.8. Right to legal remedy

If you believe that the Data Controller has violated any legal provisions relating to data processing or has not fulfilled any of your requests, you may initiate proceedings with the National Data Protection and Freedom of Information Authority (registered office: 1055 Budapest, Falk Miksa utca 9-11., postal address: 1363 Budapest, Pf. 9., e-mail: ugyfelszolgalat@naih.hu, telephone numbers: +36 (30) 683-5969 +36 (30) 549-6838; +36 (1) 391 1400) in order to terminate the allegedly unlawful data processing.

We also inform you that in the event of a violation of the legal provisions relating to data processing, or if the Data Controller has not has fulfilled any of your requests, you may apply to the court competent for your place of residence or stay.

VI. Other provisions

VI.1. Modification of the data processing information

The Data Controller reserves the right to modify this data processing information in a way that does not affect the purpose and legal basis of the data processing.

VI.2. Downloadable version

You can also download this data processing information in PDF format here.