Privacy Policy

The SATRASOFT Kft. – hereinafter referred to as the Company – by publishing this privacy policy fulfills its obligation to provide prior information to data subjects regarding the processing of personal data, as prescribed by REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL. According to the Regulation, all information must be provided to the data subjects in a concise, transparent, intelligible, and easily accessible form, using clear and plain language.

1. Name of the Data Controller

   The Company informs the data subject that, regarding the processing of their personal data, it qualifies as the data controller.

   • Company name: Satrasoft Korlátolt Felelősségű Társaság
   • Registered address: 1087 Budapest, Hős utca 1/A, Hungary
   • Company registration number: 01-09-715431
   • Tax number: 32340989-2-42
   • Phone: +36 20 431 6097
   • Representative name: Dr. Boda Anikó
   • E-mail: satrasoft@2dmintatarolas.hu
   • Website: www.satrasoft.com

   Personal data may be accessed by employees of the Company with access rights related to the purpose of data processing, persons or organizations performing data processing activities for the Company based on service contracts, as well as legal and natural persons who have entered into a business relationship with the Company, to the extent specified by the Company and to the extent necessary for the performance of their activities.

2. Name(s) of the Data Processor(s)

   The Company does not engage any external data processor for the operation or maintenance of its website in the scope of personal data managed based on voluntary consent.

3. Definitions

   1. "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 to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
   2. "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;
   3. "restriction of processing": the marking of stored personal data with the aim of limiting their processing in the future;
   4. "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 natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements;
   5. "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 are not attributed to an identified or identifiable natural person;
   6. "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;
   7. "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 controller or the specific criteria for its nomination may be provided for by Union or Member State law;
   8. "processor": a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
   9. "recipient": a natural or legal person, public authority, agency or another body, to which the personal data are 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;
   10. "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;
   11. "the data subject's consent": 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;
   12. "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;
   13. "enterprise": a natural or legal person engaged in an economic activity, irrespective of its legal form, including partnerships or associations regularly engaged in an economic activity.

4. Legal Basis for Data Processing

   1. Consent of the Data Subject

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

      (2) In case of data processing based on the data subject's consent, the data subject may give their consent to the processing of their personal data in the following forms:

      1. in writing, by making a statement giving consent to personal data processing,
      2. electronically, through explicit action performed on the Company's website, by ticking a checkbox, or by implementing technical settings during the use of information society services, as well as any other statement or action which, in the given context, clearly indicates the data subject's consent to the intended processing of their personal data.

      (3) Silence, pre-ticked boxes, or inactivity shall therefore not constitute consent.

      (4) Consent shall cover all processing activities carried out for the same or the same set of purposes.

      (5) If the processing serves several purposes at once, consent must be given for all the purposes of processing. If the data subject gives consent following an electronic request, the request must be clear and concise, and it must not unnecessarily hinder the provision of the service for which consent is requested.

      (6) The data subject shall have the right to withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. The data subject must be informed of this before giving consent. It shall be as easy to withdraw as to give consent.

   2. Performance of a Contract

      (1) Processing shall be lawful if it is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

      (2) Consent of the data subject to processing of personal data that is not necessary for the performance of the contract shall not be required as a condition for concluding the contract.

   3. Compliance with a Legal Obligation, or Protection of Vital Interests of the Data Subject or Another Natural Person

      (1) The legal basis for processing is established by law in the case of compliance with a legal obligation, so the data subject's consent to the processing of their personal data is not required.

      (2) The controller is obliged to inform the data subject about the purpose, legal basis, and duration of the data processing, the identity of the controller, their rights, and legal remedies.

      (3) The controller is entitled to process the category of data required for compliance with a legal obligation, even after the withdrawal of the data subject's consent, on the basis of legal obligation.

   4. Task Carried Out in the Public Interest or in the Exercise of Official Authority, or Legitimate Interests of the Controller or a Third Party

      (1) The controller – including a controller to whom personal data may be disclosed – or a third party may have a legitimate interest in processing data, provided that the interests, fundamental rights, and freedoms of the data subject do not override those interests, taking into account the data subject's reasonable expectations based on their relationship with the controller. Such legitimate interest may exist, for example, where there is a relevant and appropriate relationship between the data subject and the controller, such as where the data subject is a client of or is in the employment of the controller.

      (2) In order to establish the existence of a legitimate interest, it is necessary to carefully examine, among other things, whether the data subject could reasonably expect, at the time and in the context of the collection of the personal data, that processing for that purpose may take place.

      (3) The interests and fundamental rights of the data subject may override the interests of the controller if personal data are processed in circumstances in which data subjects do not reasonably expect further processing.

5. Rights Related to the Processing of the Data Subject’s Personal Data

   1. The Company provides the following brief information about the rights of the data subject

      The data subject has the right:

      1. to information before the start of data processing,
      2. to receive feedback from the controller as to whether or not their personal data are being processed, and, if so, to access the personal data and the following information,
      3. to request rectification or erasure of their data, to be notified by the controller when this has been done,
      4. to request restriction of processing, to be notified by the controller when this has been done,
      5. to data portability,
      6. to object if their personal data are processed for public interest purposes or based on the legitimate interests of the controller,
      7. not to be subject to automated decision-making, including profiling,
      8. to file a complaint with the supervisory authority. The right to complain can be exercised at the following contacts: National Authority for Data Protection and Freedom of Information, 1125 Budapest, Szilágyi Erzsébet fasor 22/c., Phone: +36 (1) 391-1400, Fax: +36 (1) 391-1410, www.naih.hu, e-mail: ugyfelszolgalat@naih.hu
      9. to effective judicial remedy against the supervisory authority,
      10. to effective judicial remedy against the controller or processor,
      11. to be informed of a personal data breach.

   2. Detailed information about data subject rights

      Right to information

      (1) The data subject is entitled to receive information about the processing of their data before the start of such processing.

      (2) Information to be provided if the personal data are collected from the data subject:

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

      (3) In addition to the information referred to in paragraph (1), at the time when personal data are obtained, in order to ensure fair and transparent processing, the controller shall provide the data subject with the following further information:

      1. the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period;
      2. the existence of the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data portability;
      3. where the processing is based on point (a) of Article 6(1) or point (a) of Article 9(2) of the Regulation, the existence of the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
      4. the right to lodge a complaint with a supervisory authority;
      5. 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 of the possible consequences of failure to provide such data;
      6. 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 for the data subject.

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

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

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

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

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

      (7) Paragraphs (1)–(3) shall not apply where and insofar as:

      1. the data subject already has the information;
      2. the provision of 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, subject to the conditions and safeguards in Article 89(1), or insofar as the obligation referred to in this paragraph is likely to render impossible or seriously impair the achievement of the objectives of that processing. In such cases, the controller shall take appropriate measures, including making the information publicly available, to protect the rights, freedoms, and legitimate interests of the data subject;
      3. obtaining or disclosure is expressly laid down by Union or Member State law to which the controller is subject and which provides appropriate measures to protect the data subject’s legitimate interests; or
      4. where 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 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:

      1. the purposes of the processing;
      2. the categories of personal data concerned;
      3. the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
      4. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
      5. the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing concerning the data subject or to object to such processing;
      6. the right to lodge a complaint with a supervisory authority;
      7. where the personal data are not collected from the data subject, any available information as to their source;
      8. 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 for the data subject.

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

      Right to Rectification and Erasure

      Right to Rectification

      (1) The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning them. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

      Right to Erasure (“Right to be Forgotten”)

      (1) The data subject shall have the right to obtain from the controller the erasure of personal data concerning them without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

      1. the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
      2. the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1) or point (a) of Article 9(2), and where there is no other legal ground for the processing;
      3. the data subject objects to the processing pursuant to Article 21(1), and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
      4. the personal data have been unlawfully processed;
      5. the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
      6. the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).

      (2) Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

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

      1. for exercising the right of freedom of expression and information;
      2. for compliance with a legal obligation which requires processing by Union or Member State law to which the 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 controller;
      3. for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) and Article 9(3);
      4. for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) 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
      5. for the establishment, exercise, or defence of legal claims.

      Right to Restriction of Processing

      (1) The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

      1. the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
      2. the processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
      3. the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise, or defence of legal claims;
      4. the data subject has objected to processing pursuant to Article 21(1), pending the verification whether the legitimate grounds of the controller override those of the data subject.

      (2) Where processing has been 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 defence 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 controller shall inform the data subject who has obtained restriction of processing pursuant to paragraph (1) before the restriction of processing is lifted.

      Notification Obligation Regarding Rectification or Erasure of Personal Data or Restriction of Processing

      (1) The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1), and Article 18 to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort.

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

      Right to Data Portability

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

      1. the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and
      2. the processing is carried out by automated means.

      (2) In exercising the right to data portability under paragraph (1), the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

      (3) The exercise of the right referred to in paragraph (1) shall be without prejudice to Article 17 of the Regulation. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

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

      Right to Object

      (1) The data subject shall have the right to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the 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 defence of legal claims.

      (2) Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning them 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) At the latest at the time of the first communication with the data subject, 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 are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to their particular situation, shall have the right to object to processing of personal data concerning them, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

      Right Not to be Subject to Automated Decision-Making

      (1) The data subject shall have 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:

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

      (3) In the cases referred to in points (a) and (c) of paragraph (2), the controller shall implement suitable measures to safeguard the data subject's rights and 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 the special categories of personal data referred to in Article 9(1), unless point (a) or (g) of Article 9(2) applies and suitable measures to safeguard the data subject's rights and freedoms and legitimate interests are in place.

      Right to Lodge a Complaint and to Judicial Remedy

      Right to Lodge a Complaint with a Supervisory Authority

      (1) Pursuant to Article 77 of the Regulation, the data subject shall have 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.

      (2) The right to lodge a complaint can be exercised at the following contacts: 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 www: http://www.naih.hu e-mail: 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 pursuant to Article 78.

      Right to Effective Judicial Remedy Against a Supervisory Authority

      (1) Without prejudice to any other administrative or non-judicial remedy, every natural or legal person shall have the right to an effective judicial remedy against a legally binding decision of a supervisory authority concerning them.

      (2) Without prejudice to any other administrative or non-judicial remedy, every data subject shall have the right to an effective judicial remedy where the competent supervisory authority does not handle a complaint or does not inform the data subject within three months of the progress or outcome of the complaint lodged pursuant to Article 77.

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

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

      Right to Effective Judicial Remedy Against a Controller or Processor

      (1) Without prejudice to any available administrative or non-judicial remedy – including the right to lodge a complaint with a supervisory authority under Article 77 – every data subject shall have the right to an effective judicial remedy where they consider 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 controller or processor shall be brought before the courts of the Member State where the controller or processor has an establishment. Alternatively, such proceedings may be brought before the courts of the Member State where the data subject has their habitual residence, unless the controller or processor is a public authority of a Member State acting in the exercise of its public powers.

      Restrictions

      (1) Union or Member State law to which the controller or processor is subject may restrict by legislative measures the scope of the obligations and rights provided for in Articles 12–22 and Article 34, and in accordance with Articles 5 in so far as its provisions correspond to the rights and obligations provided for in Articles 12–22, when such a restriction respects the essence of the fundamental rights and freedoms and is a necessary and proportionate measure in a democratic society to safeguard:

      1. national security;
      2. defence;
      3. public security;
      4. the prevention, investigation, detection, or prosecution of criminal offences or the execution of criminal penalties, including the safeguarding against and the prevention of threats to public security;
      5. 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 matters, public health, and social security;
      6. the protection of judicial independence and judicial proceedings;
      7. the prevention, investigation, detection, and prosecution of breaches of ethics for regulated professions;
      8. in the cases referred to in points (a)–(e) and (g) – even occasionally – the monitoring, inspection, or regulatory functions connected with the exercise of official authority;
      9. the protection of the data subject or the rights and freedoms of others;
      10. the enforcement of civil law claims.

      (2) The legislative measures referred to in paragraph (1) shall, where relevant, contain specific provisions at least as to:

      1. the purposes of the processing or categories of processing;
      2. the categories of personal data;
      3. the scope of the restrictions introduced;
      4. the safeguards to prevent abuse or unlawful access or transfer;
      5. the specification of the controller or categories of controllers;
      6. the storage periods and the applicable safeguards taking into account the nature, scope, and purposes of the processing or categories of processing;
      7. the risks to the rights and freedoms of data subjects; and
      8. the right of data subjects to be informed about the restriction, unless this may be prejudicial to the purpose of the restriction.

      Information About Personal Data Breach

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

      (2) The communication referred to in paragraph (1) to the data subject shall describe in clear and plain language the nature of the personal data breach and shall contain at least the following information: 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 controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.

      (3) The communication to the data subject referred to in paragraph (1) shall not be required if any of the following conditions are met:

      1. the 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;
      2. the controller has taken subsequent measures which ensure that the high risk to the rights and freedoms of data subjects referred to in paragraph (1) is no longer likely to materialize;
      3. it 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 controller has not already communicated the personal data breach to the data subject, the supervisory authority, after considering the likelihood of the personal data breach resulting in a high risk, may require the controller to do so, or may decide that any of the conditions referred to in paragraph (3) are met.

6. Procedure Applicable Upon the Data Subject's Request

   (1) The Company shall facilitate the exercise of the data subject's rights; it may not refuse to act on the data subject's request for exercising their rights recorded in this Privacy Notice unless it proves that it is not in a position to identify the data subject.

   (2) The Company shall inform the data subject without undue delay and in any event within one month of receipt of the request of the action taken on the request. Where necessary, taking into account the complexity and number of the requests, that period may be extended by two further months. The controller shall inform the data subject of any such extension within one month of receipt of the request, together with the reasons for the delay.

   (3) Where the data subject makes the request by electronic means, the information shall be provided by electronic means where possible, unless otherwise requested by the data subject.

   (4) Where the Company does not take action on the data subject's request, it shall inform the data subject without delay and at the latest within one month of 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 Company shall provide information and action free of charge to the data subject, including: feedback on the processing of personal data, access to processed data, rectification, supplementation, erasure, restriction of processing, data portability, objection to processing, and information about a personal data breach.

   (6) Where requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character, the controller may charge a fee of 5000 HUF, or refuse to act on the request, taking into account the administrative costs of providing the information or communication or taking the action requested.

   (7) The burden of demonstrating the manifestly unfounded or excessive character of the request shall lie with the controller.

   (8) Without prejudice to Article 11 of the Regulation, where the controller has reasonable doubts concerning the identity of the natural person making the request pursuant to Articles 15–21 of the Regulation, it may request the provision of additional information necessary to confirm the identity of the data subject.

7. Procedure in the Event of a Personal Data Breach

   (1) According to the Regulation, a personal data breach is 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.

   (2) A personal data breach also includes the loss or theft of a device (laptop, mobile phone) containing personal data, or loss/inaccessibility of decryption keys for encrypted files, or infection by ransomware that makes data processed by the controller inaccessible until the ransom is paid, or an attack on the IT system, misdirected email containing personal data, publication of a mailing list, etc.

   (3) Upon detection of a personal data breach, the representative of the Company shall immediately conduct an investigation to identify the breach and assess possible consequences. The necessary measures shall be taken to eliminate the damage.

   (4) The personal data breach shall be notified to the competent supervisory authority without undue delay and, where feasible, not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. Where the notification is not made within 72 hours, it shall be accompanied by reasons for the delay.

   (5) The processor shall notify the controller of a personal data breach without undue delay after becoming aware of it.

   (6) The notification referred to in paragraph (3) shall at least:

   1. describe the nature of the personal data breach including, where possible, the categories and approximate number of data subjects concerned, and the categories and approximate number of personal data records concerned;
   2. communicate the name and contact details of the data protection officer or other contact point where more information can be obtained;
   3. describe the likely consequences of the personal data breach;
   4. describe the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.

   (7) If and to the extent that it is not possible to provide the information at the same time, it may be provided in phases without undue further delay.

   (8) The controller shall document any personal data breaches, comprising the facts relating to the personal data breach, its effects, and the remedial action taken. That documentation shall enable the supervisory authority to verify compliance with Article 33 of the Regulation.

8. Data Processing Related to the Website

   Information Regarding Visitors to the Company's Website

   (1) When visiting the Company's website, one or more cookies – small packets of information sent by the server to the browser, which the browser returns to the server with each request to the server – are sent to the visitor's computer, by means of which the visitor's browser becomes individually identifiable, provided that the person visiting the website has given their express (active) consent to continue browsing after having been clearly and explicitly informed.

   (2) Cookies operate exclusively for improving the user experience and automating the login process. The cookies used on the website do not store information suitable for personal identification, and the Company does not process personal data in this context.

   (3) Among the cookies used on the website, third-party cookies may also appear if the user enables, for example, the Google Maps service. For more information about the cookies placed by Google Maps and how they are managed, please refer to Google’s Privacy Policy and Cookie Policy.

9. Data Processing Activity Related to Performance of Contracts

   (1) The Company processes the personal data of natural persons (clients, buyers, suppliers) who contract with it in connection with the contractual relationship. The data subject must be informed about the processing of their personal data.

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

   (3) The legal basis for processing is performance of the contract, the purpose of processing is contact, enforcement of claims arising from the contract, ensuring compliance with contractual obligations.

   (4) Recipients of personal data: the Company's management, employees performing customer service or accounting tasks based on their position, and data processors.

   (5) Categories of personal data processed: name, address, registered office, phone number, email address, tax number, bank account number, entrepreneur license number, primary producer license number.

   (6) Duration of processing: 5 years after the termination of the contract.

10. Information on Data Processing Related to the Use of Electronic Surveillance Systems

    (1) Our Company does not operate an electronic surveillance and recording system (camera system) in the customer area or the related units.

11. Provisions Regarding Data Security

    (1) The Company may process personal data only in accordance with the activities specified in these regulations and for the purpose of data processing.

    (2) The Company ensures the security of the data, undertakes to take all technical and organizational measures essential for the enforcement of the legal provisions on data security and confidentiality, and to establish the procedural rules necessary for the enforcement of the above-mentioned laws.

    (3) The Company protects the data with appropriate measures against unauthorized access, alteration, transmission, disclosure, deletion, destruction, accidental loss or damage, and inaccessibility resulting from changes in the technology used.

    (4) The technical and organizational measures to be implemented by the Company to ensure data security are set out in the Company's data protection policy.

    (5) When determining and applying measures for data security, the Company takes into account the state of the art. In the case of several possible solutions, the one offering higher protection for personal data shall be chosen, except where this would cause disproportionate difficulty.

12. Rules Regarding Data Processing

    General Rules Regarding Data Processing

    (1) The rights and obligations of the processor regarding the processing of personal data are determined by law and specific laws governing data processing, within the framework of instructions from the controller.

    (2) The Company declares that the processor does not have the competence to make substantive decisions regarding data processing during the course of their activities, may only process the personal data coming to their knowledge in accordance with the controller's instructions, may not process data for their own purposes, and must store and retain personal data as instructed by the controller.

    (3) The Company is responsible for the lawfulness of the instructions given to the processor regarding data processing operations.

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

    (5) The Company does not authorize the processor to engage another processor.

    (6) The data processing contract must be concluded in writing. An organization engaged in business activities involving the use of the personal data to be processed cannot be appointed as a processor.