DATA PROCESSING POLICY
PREMIUM SPORT KFT.
Effective: 20th November, 2015
4. OUR PRINCIPLES OF DATA PROCESSING
5. PROCESSING OF OBLIGATORY DATA PROVIDED BY WEBSHOP BUYERS
6.DELIVERY RELATED DATA PROCESSING
7. PROCESSING OF PERSONAL DATA OF REGISTERED BUYERS
8. PROCESSING OF DATA OF WEBSHOP VISITORS
9. HANDLING OF QUALITY COMPLAINTS
10. PROPERTY FOUND
11. PROCESSING OF NEWSLETTER RELATED DATA
12. OPERATION OF ELECTRONIC SURVEILLANCE SYSTEMS
13. LOYALTY PROGRAMME
14. JOB OFFERS
15. AD HOC DATA PROCESSING
16. EQUIPMENT AND MEASURES USED FOR DATA PROCESSING
17. THIRD PARTY PROCESSORS
18. DISPOSURE OVER PERSONAL DATA AND LEGAL RECOURSE
19. FINAL PROVISIONS
This DATA PROCESSING POLICY of PREMIUM SPORT KFT., being the sole distributor of Heavy Tools products, contains the rules pertaining to their data processing.
1.1.1. Premium Sport Kft. (hereinafter: Processor) by way of this Policy inform a) their heavytools.hu webshop buyers; b) visitors of the heavytools.hu website; c) addressees of the heavytools.hu webshop newsletters and d) other parties as defined in this Policy of their data processing practice, organizational and technical measures undertaken in the interest of data protection and the possibilities of legal recourse, and hereby records the rules of their data processing in accordance with the provisions of relevant legislation.
1.1.2. Premium Sport Kft. is committed to protecting personal data. Premium Sport Kft. processes personal data according to legal provisions and the data processing principles and conditions contained in this data processing policy (hereinafter: Policy) at all times.
1.1.3.Our prime intention with this Policy was to provide you with all necessary information for you to be able to make an informed decision regarding the processing of your personal data.
Name: PREMIUM SPORT LIMITE LIABILITY COMPANY
Registered office and correspondence address: H-1037 Budapest, Kunigunda útja 70/A, Hungary
Telephone number: +36-1-453-0860
E-mail address: firstname.lastname@example.org
Company registration number: 01-09-888925
Registering court: Fővárosi Bíróság (Court of the Capital City) as Registrar of Companies
Tax number: 14101087-2-41
Data processing registration numbers: [NAIH-88006/2015; NAIH-90949/2015; NAIH-90950/2015; NAIH-90951/2015; NAIH-90952/2015; NAIH-91373/2015].
reference to specific personal data;
the name and identification number of the data subject or one or more factors specific to his
physical, physiological, mental, economic, cultural or social identity as well as conclusions
drawn from the data in regard to the data subject;
with political parties, religious or philosophical beliefs or trade-union membership, and
personal data concerning sex life,
pertain to any prior criminal offense committed by the data subject and that is obtained by
organizations authorized to conduct criminal proceedings or investigations or by penal
institutions during or prior to criminal proceedings in connection with a crime or criminal
registered in any mode or form, controlled by the body or individual performing state or local
government responsibilities, as well as other public tasks defined by legislation, concerning
their activities or generated in the course of performing their public tasks, irrespective of the
method or format in which it is recorded, its single or collective nature; in particular data
concerning the scope of authority, competence, organisational structure, professional
activities and the evaluation of such activities covering various aspects thereof, the type of
data held and the regulations governing operations, as well as data concerning financial
management and concluded contracts;
information, that are prescribed by law to be published, made available or otherwise disclosed
for the benefit of the general public;
informed indication of the will of the data subject by which he signifies his agreement to
personal data relating to him being processed fully or to the extent of specific operations;
to the processing of his/her personal data and requesting the termination of data processing, as
well as the deletion of the data processed;
which alone or jointly with others determines the purposes and means of the processing of
data; makes and executes decisions concerning data processing (including the means used) or
have it executed by a data processor;
the data, irrespective of the procedure applied; in particular, collecting, recording, registering,
classifying, storing, modifying, using, querying, transferring, disclosing, synchronising or
connecting, blocking, deleting and destructing the data, as well as preventing their further use,
taking photos, making audio or visual recordings, as well as registering physical
characteristics suitable for personal identification (such as fingerprints or palm prints, DNA
samples, iris scans);
definitely restrict its further processing;
operations, irrespective of the method and means used for executing the operations, as well as
the place of execution, provided that the technical task is performed on the data;
personality processing the data on the grounds of a contract, including contracts concluded
pursuant to legislative provisions;
which generated the data of public interest that must be disclosed through electronic means, or
during the course of operation in which this data was generated;
than the data subject, the data controller or the data.
4. OUR DATA PROCESSING PRINCIPLES
4.1.1. Premium Sport Kft. processes data based partly on legal authorization and obligation, partly on voluntary consent of the data subject. This Policy sets out the legal basis for each individual case of data processing.
4.1.2. Personal data are processed exclusively for purposes set out in this Policy and in the interest of fulfilling our legal obligations. Data processing shall at all times be adequate, relevant and not excessive in relation to the purposes for which data are collected and their collection shall be fair and lawful.
4.1.3. We only collect personal data which are indispensable and suitable for achieving the intended purpose. Personal data are only processed to the extent and for the time period that is adequate for achieving the purpose.
4.1.4. We ensure that the processed data are accurate and, where necessary, kept up to date and that they are kept in a format which permits identification of data subjects for no longer than is necessary for the purposes for which the data were collected.
4.1.5. Personal data shall not be transferred to third parties, especially not for remuneration (prohibition of selling databases), save for controllers and third party processors as defined in this Policy.
4.1.6. Personal data are collected from data subjects exclusively, therefore the source of the data is always the data subject (prohibition of buying databases).
4.1.7. Premium Sport Kft. does not process special data.
4.1.8. Data processing technology used by Premium Sport Kft. and third party processors – save for different provisions of this Policy – means data processing by means of IT.
4.1.9. In the event of an authority empowered hereto requesting personal data from us, we only transfer absolutely necessary information as laid down by law after checking the legal basis of the request.
4.1.10. Premium Sport Kft. hereby advises data subjects that, in terms of point (5) of § 6 of the Information Act (hereinafter: INFOtv.), if the data collection was done with the express consent of the data subject, the collected data can – in the absence of contrary legal provisions – be processed without further consent of the data subject even after withdrawal of such consent in the interest of fulfilling the processor’s legal obligations or enforcing the rights of the processor or of any third party, provided that such limitations of human rights are proportional to the aimed purpose.
4.1.11. Consenting to data processing always means voluntary and informed consent. Should you feel, in connection with the consent requested by us from you, that these conditions are not fully satisfied, or that your request to or expectation from us can be fulfilled without the data requested by us, please let us know as soon as possible before giving your consent.
4.1.12. In the course of processing personal data, we pay distinguished attention to the principle of transparency. This means that data subjects must be fully aware of the way their data are being processed, which creates (legal) security for both the data subject and the processor.
4.1.13. The INFOtv. contains the most important general rules for data processing. Should you be still unclear about the provisions of this Policy, please refer directly to the Act (http://www.naih.hu) or contact an expert on data protection issues.
4.1.14. This Policy can be downloaded and saved to a permanent data carrier without any limitations and it is also available in any of the Heavy Tools shops.
5.PROCESSING OF OBLIGATORY DATA TO BE PROVIDED BY WEBSHOP BUYERS
5.1.1. Data processed: order code, date, time, name, address, phone number, e-mail address, description, quantity, purchase price, colour and size of the products ordered as well as the means of payment and delivery.
5.1.2. Purpose of data processing: documentation of purchases made via the heavytools.hu webshop, of orders, issuing of invoices, execution of contracts, of purchases and payments as well as adhering to the rules of accounting.
5.1.3. Legal basis of data processing: we process data according to § 13/A clauses (1)-(3) of Act Nᵒ 108 of 2001 on electronic trade and certain issues pertaining to the information society, being legally authorized hereto and bound by the provisions of the said Act.
5.1.4. The time limit for processing the data: in accordance with the provisions of clause (2) of § 169 of the Accounting Act, we keep all accounting records directly or indirectly supporting the balance sheet and income statement (including the ledger accounts, analytics and detailed records) for 8 years in a readable and retrievable format.
5.1.5. Complementary data processing: In the event of credit card transactions our servers record the following data: transaction code, authorization code, amount and order code. We do not connect these data with the personal data of the consumer, save for explicit provisions of the Policy to this effect.
5.1.6. Data processing by the payment service provider 1.: in the event of payment by credit card the data of the payment transaction is processed by the OTP Bank Ltd. (H-1051 Budapest, Nádor u. 16.)
5.1.7. Data processing by the payment service provider 2.: if payment is made through PayPal the data of the payment transaction are processed by the PayPal online payments system (PayPal Europe S.à r.l. & Cie, S.C.A. 5th Floor 22-24 Boulevard Royal, L-2449, Luxembourg).
5.1.8. Data transfer 1.: in the event of credit card payment your name, the order code, the value of the transaction, its date and time are transferred to the OTP Bank (H.1051 Budapest, Nádor u. 16.) in accordance with the provisions of clauses (1) - (3) of § 13/A of the Ekertv and clause (6) of § 6. of the INFOtv.
5.1.9. Data transfer 2.: in the event of using PayPal your name, the order code, the transaction value, its date and time are transferred to PayPal online payment system (PayPal Europe S.à r.l. & Cie, S.C.A. 5th Floor 22-24 Boulevard Royal, L-2449, Luxembourg) in accordance with the provisions of clauses (1) - (3) of § 13/A of the Ekertv and clause (6) of § 6. of the INFOtv.
5.1.10. Data transfer 3.: in the event of choosing door-to-door delivery and C.O.D. payment your name, address, delivery address, order code, value of the transaction, its date and time are transferred to GLS courier service (GLS General Logistics System Hungary Parcel Logistics Kft., H-2351 Alsónémedi, GLS Európa u. 2.) in accordance with the provisions of clauses (1) - (3) of § 13/A of the Ekertv and clause (6) of § 6. of the INFOtv.
5.1.11. Data transfer 4.: if delivery is taken at a Pick Pack point with C.O.D. payment your name, address, the name and address of the Pick Pack point chosen, the order code, the value of the transaction, its date and time are transferred to Sprinter Courier Service operating the service (Sprinter Courier Service Kft., H.1097 Budapest, Táblás u. 39.) in accordance with the provisions of clauses (1) - (3) of § 13/A of the Ekertv and clause (6) of § 6. of the INFOtv. Sprinter Courier Service processes the data further by transferring them to the Pick Pack point chosen by you, the name and address of which can be found in the roll-bar menu.
6.DELIVERY RELATED DATA PROCESSING
6.1.1. Data processed: name, address, phone number, purchase price, chosen means of payment and delivery and information provided by the consumer regarding presence at the delivery address, as well as additional information in the remarks (e.g. a different name on the doorbell)
6.1.2. Purpose of data processing: execution of orders, documenting the purchase and payment, and fulfilling accounting obligations.
6.1.3. Legal basis of data processing: we process data according to § 13/A clauses (1)-(3) of Act Nᵒ 108 of 2001 on electronic trade and certain issues pertaining to the information society, being legally authorized hereto and bound by the provisions of the said Act.
6.1.4. The time limit for processing the data: in accordance with the provisions of clause (2) of § 169 of the Accounting Act, we keep all accounting records directly or indirectly supporting the balance sheet and income statement (including the ledger accounts, analytics and detailed records) for 8 years in a readable and retrievable format.
6.1.5. Data transfer 1.: in the event of door-to-door delivery, the above data are transferred to GLS courier service (GLS General Logistics System Parcel-Logistics Kft., H-2351 Alsónémedi, GLS Európa u. 2.) in accordance with the provisions of clauses (1) - (3) of § 13/A of the Ekertv and clause (6) of § 6. of the INFOtv. To services provided by GLS courier service their general terms and conditions of sale are applicable which can be found here: https://gls-group.eu/EN. By choosing door-to-door delivery by GLS the consumer accepts the relevant provisions of the general terms and conditions of sale of GLS courier service.
6.1.6. Data transfer 2.: in the event of delivery to a Pick Pack point the above data are transferred to the operator of the service, Sprinter courier service (Sprinter Courier Service Kft., H-1097 Budapest, Táblás u. 39.) in accordance with the provisions of clauses (1) - (3) of § 13/A of the Ekertv and clause (6) of § 6. of the INFOtv. To services provided by Sprinter courier service their general terms and conditions of sale are applicable which can be found here: http://www.pickpackpont.hu/ASZF. By choosing a Pick Pack point delivery the consumer accepts the relevant provisions of the general terms and conditions of sale of Sprinter courier service.
7. PROCESSING PERSONAL DATA OF REGISTERED USERS
7.1.1. In the webshop reachable through the heavytools.hu website it is possible to create your individualized “Heavy Tools account” which offers numerous advantages as set out in the GTCS.
7.1.2. Data processed: personal data of buyers of the webshop as per chapter 5. and delivery related data as per chapter 6. above, while processing the latter data is subject to the data subject’s consent. The data subject may give their voluntary consent in the interest of gaining access to convenience functions, discounts and customized service. The range of data set out in chapters 5. and 6. may be broadened by data provided by the consumer in the course of registration, which are primarily data in connection with identifying consumer preferences regarding Heavy Tools products more precisely and data enabling a more personal contact with the consumer. Examples may be the data subject’s customer code, the way they wish to be addressed, date of birth, gender, e-mail address and password used for log-in, details of the individual purchases, (date, time, items bought, purchase value), declaration made when requesting a loyalty card, number and balance of the loyalty card, interest shown in Heavy Tools products and opinion offered (cart’s content, products last viewed, compared products, favourites, voting, filling in questionnaires and evaluating products), subscribing to the general and customized Heavy Tools newsletter and the times of logging in to their Heavy Tools account. For registering an account all those data must be provided which in terms of chapters 5. and 6. above are legally obligatory in case of purchasing without registration, as well as the log-in e-mail address and password. As regards further data, these are optional – voluntarily offered information and declarations – even in connection with registering an account. Please note that by registering an account the user agrees to the connecting of data processed as set out in the next chapter (8.) and data processed as laid down in this (7.) chapter in connection with their visits to the website in the interest of achieving the goals defined in subclause b) of the next clause for the period shown in this chapter.
7.1.3. The purpose of data processing: a) to record purchases made in the webshop reachable through the heavytools.hu website, issuing invoices, keeping customer records and differentiating them from each other, execution of the orders, documenting purchases and payments, adhering to the rules of accounting, offering convenience functions with regard to legally obligatory data to be provided in the event of purchases made without registration as defined in chapters 5. and 6., and b) to be able to keep closer contact with customers, analysis of customer habits, market research, offering more customized service and to improve customer satisfaction in respect of all the data that can be provided in terms of this chapter.
7.1.4. Legal basis of data processing: the voluntary consent of the data subject in accordance with clause (4) of § 13/A of the Act on electronic trade and certain issues of information society and clause (5) of § 6 of Act 48 of 2008 about the fundamental conditions and certain limitations of commercial advertising (hereinafter: Grt.).
7.1.5. Data processing period: until the cancellation of the registration by the data subject in accordance with the provisions of clause (5) of § 6 of the Grt., or until the deletion of certain registered data with due consideration to the fact that the cancellation of the registration or deleting certain registered data has no effect on processing data as set out in chapter 5. Should the data subject not log in to their Heavy Tools account for 10 years, the data of that account shall be deleted.
7.1.6. Data processing registration number: NAIH-91373/2015
8. PROCESSING DATA OF WEBSHOP VISITORS
8.1. General information
8.1.1. Data subjects are hereby advised by the processor that the contents of this chapter address more involved technology specific issues which should, however, be clearly understandable provisions for data subject with sufficiently up-to-date, yet not exceeding average, IT knowledge. Due to the divergent nature of the relevant legislation and the pursuant possible interest collisions, it is unavoidable that compromises be sought. With regard to this, we would like to ask every data subject to contact us with their questions should they feel that what follows does not satisfy the endeavours of the aforesaid.
8.1.2. Premium Sport Kft. would hereby like to draw the attention of data subjects to the legal uncertainty with regard to data transfer directed into the United States. Hungarian speaking data subjects can find further information here: http://www.naih.hu/files/2015-10-06-Kozlemeny---Safe-harbor.pdf
8.2. Server ledgers
8.2.1. Data collected by the server ledgers as set out in this chapter are in themselves not suitable for identifying visitors, however, connected with other data (e.g. data provided when registering) they are suitable for drawing conclusions as to the identity of the user.
8.2.2. Premium Sport Kft. hereby declares that data they got access to in the course of analysing the ledgers shall not be connected with other data nor shall they endeavour to identify visitors, save for explicit provisions of this Policy to the contrary.
8.2.3. Data processed: IP address, search engine, data of the operation system, automatically created technical identification, addresses of visited pages and the order they were visited in, time and duration of the visits, location of the clicks, time of viewing and error massages sent to visitors. This chapter details the conditions of processing visitors’ data, however server ledgers are created for other reasons, too (e.g. in connection with purchases made), the processing of which are detailed in connection with the purposes of data processing of data subjects’ data.
8.2.4. Purpose of data processing: to secure and to control the operation of the services data subjects encounter when visiting heavytools.hu, to ensure operational safety (prevention of data loss), webshop development, statistical analysis of visitors’ habits, customized service and prohibition of abuse.
8.2.5. Legal basis of data processing: consent of the data subject and clauses (3) and (4) of § 13/A of Ekertv.
8.2.6. Processor: The independent measurement and auditing of data relating to the number of visits to the heavytools.hu pages and other web-analytics are supported by Google Analytics as third party service supplier. Detailed information regarding the processing of data such acquired is available on http://www.google.com/intl/en/policies/.
8.2.7. Data processing time limit: 30 days.
8.3. Data processing of ledgers of third party service providers.
8.3.1. Third party service providers (e.g. google, Facebook and similar, including default settings for data processing) may collect data relating to your visits to the webshop reachable through the heavytools.hu website, provided you are a registered user of them and you have explicitly consented to it. These data are not processed by Premium Sport Kft., therefore you are kindly requested to contact the third party suppliers regarding data collected by them.
8.3.2. The heavytools.hu pages contain information from servers operated by third parties and, as the case may be, redirects visitors of the website of Premium Sport Kft. to third party pages. The servers of such third party service providers are directly linked with the servers used by the users. The referred service providers are capable of collecting and connecting personal data (e.g. IP address, search engine, data of the operation system, address of pages visit and time of the visits) with other data processed by them through direct communication with the user’s search engine.
8.3.3. The independent measuring and auditing of the visits to the heavytools.hu pages and other web-analytical data are supported by the server of Google Analytics. Detailed information about the processing of measured data is available at http://www.google.com/intl/en/policies/.
8.3.4. In the interest of enhancing user experience Facebook also has access to certain data of registered visitors consenting to it on the heavytools.hu pages. Information as to the data processing conditions is available at https://www.facebook.com/privacy/explanation.
8.4.2. If the search engine used by the user sends back cookies saved earlier, the processor has the possibility to connect the current visit of the user with earlier ones.
8.4.3. Data processed: automatically created ID, date, time, addresses of pages visited earlier and the order, time and duration of the visits, the location of the clicks, error messages sent to the visitor, IP address, search engine, data of the operation system, content of the cart, products last viewed, compared products, favourites, opinion volunteered via voting, questionnaires and product evaluation.
8.4.4. Purpose of data processing: verification, security and integrity of the pages, differentiation between the users, identification of the work-in-progress of visitors, prevention of data loss, customized offers based on data gained during the visit to the website, presentation of surfaces, operation of the webshop, web-analytical measurements, measuring the success of campaigns, surveying customer expectations in the interest of development.
8.4.5. Legal basis of data processing: consent of the data subject which we ask for when the heavytools.hu address is accessed, and clauses (3) and (4) of § 13/A of the Ekertv.
8.4.6. Time limit for processing the data:
- for data relating to time and duration of the visit, location of clicks, viewing duration, error messages sent to visitors, address and order of pages visited earlier, IP address, search engine and data of the operational system: until the browser is closed (in the case of non-registered users);
- statistical data gained from data listed above: 5 years;
- automatically created technical ID, content of the cart, products last viewed, compared products, favourites, opinion volunteered via voting, questionnaires and product evaluation: 30 days (in the case of non-registered users).
Processor: the independent measuring and auditing of the visits to the heavytools.hu pages and other web-analytical data are supported by the server of Google Analytics. Detailed information about the processing of measured data is available at http://www.google.com/intl/en/policies/. Making customized offers possible and measuring the success of our campaigns is secured by the services of GoogleAdWords. Our website uses the follow-up codes of GoogleAdWords remarketing services so that visitors to the website may be reached by websites belonging to the network of Google Display with customized offers.
8.4.8. Cookies can be blocked by the user and cookies allowed earlier can be deleted (the concrete menu buttons depend on the equipment and browser used, but typically they should be looked for under “privacy” or “history”).
8.5. Cookies of third party service providers
8.5.1.Some service providers of whom you are a registered user and whom you have given your consent to their remarketing and placing customized advertisements on pages operated by third parties for the purpose of verification, safety and integrity of the pages, identification of and differentiation between the users, identification of the work-in-progress of users, storing data provided, prohibition of data loss, making customized offers and opening surfaces may place cookies on the equipment of the user in terms of the above, may retrieve these at later uses of the internet and they may connect these with other data processed by them.
8.5.2. Should the search engine used by the user send back a cookie saved earlier, the service provider processing it has the possibility of connecting the current visit of the user with earlier ones to the websites using the cookies of the same service provider.
8.5.3. When visiting the heavytools.hu pages such cookies are processed by Google Analytics and the Facebook and therefore they are deemed to be the processors of such data. Further information can be found at: http://www.google.com/intl/en/policies/privacy/partners/ and https://www.facebook.com/privacy/explanation.
9. HANDLING QUALITY COMPLAINTS
9.1.1. Data processed: order code, name and address of customer, product description, purchase price, time of making the purchase and of making the quality complaint, details of the complaint, consumer capacity of the customer, the claim made by the customer and method of settling the claim.
9.1.2. Purpose of data processing: handling quality complaints with regard to products distributed by Premium Sport Kft.
9.1.3. Legal basis of data processing: clause (6) of § 6 of the INFOtv. and clause (7) of § 17/A of Act 155 of 1997 about consumer protection (hereinafter: Fgytv.)
9.1.4. Duration of data processing: in terms of clause (7) of § 17/A of the Fgytv. 5 years from the date of the protocol.
10. PROPERTY FOUND
10.1.1. Provisions of this chapter are to be applied to movable property found in the Heavy Tools shops whose owners at the given time cannot be identified.
10.1.2. Data processed: name and address of the finder, description of the found property, circumstances of the finding, signature of the finder and of the shop assistant, and the date of the protocol.
10.1.3. Purpose of data processing: keeping record of property found in the Heavy Tools shops and notification of the owner and the finder.
10.1.4. Legal basis of data processing: f Act Nᵒ 5 of 2013 (Hungarian Civil Code, hereinafter: Ptk.) o
10.1.5. Time limit of data processing: data get deleted when the owner takes possession of the found property, within 8 days latest following the handing it over to the notary and after three months in the event of selling off the found property.
10.1.6. Registration number for data processing: NAIH-90949/2015
11. NEWSLETTER RELATED DATA PROCESSING
11.1.1. The Heavy Tools newsletter can be subscribed to in the Heavy Tools shops, directly on the heavytools.hu website, when requesting a loyalty card, when making a purchase and in the course of sweepstakes organized by Premium Sport Kft.
11.1.2. Data processed: e-mail address, name, consent to receiving direct marketing material and the date of such consent, analytical data pertaining to the sending and receiving of messages (e.g. the date and time of sending, opening and clicking onto the link conveyed in the letter, as well as cause of delivery failure).
11.1.3. Purpose of data processing: sending newsletters by e-mail also containing commercial advertisements and marketing messages, current information in connection with Heavy Tools products, special offers, direct marketing and keeping in touch with customers.
11.1.4. Legal basis of data processing: voluntary consent of the data subject in accordance with clause (4) of § 13/A of Ekertv. and clause (5) of § 6 of Grt.
11.1.5. Time limit of data processing: until the withdrawal of the user’s consent with the proviso that the time limits of data processing and cancellation as per point 7.1.5. above also apply to newsletter subscriptions.
11.1.6. Hard copy requests for newsletter subscriptions in terms of point 11.1.1. and consents given to receiving newsletters are registered in the IT systems of Premium Sport Kft. by its staff, whereafter these data are processed via our IT systems. Hard copy consents are made obsolete after one year following their registration in our IT systems, or earlier if the data subject withdraws their consent to receiving newsletters.
Withdrawing consent given to receiving Heavy Tools newsletters and deleting or modifying personal data provided in this regard can be done in the following ways:
- The simplest method: click on “ the bottom of the newsletter; at
- By logging into the personal account on the heavytools.hu website;
- By sending an e-mail to email@example.com, or
- By post sent to Premium Sport Kft., H-1033 Budapest, Szőlőkert u. 4, Hungary
11.1.8. Data processing registration number: NAIH-88006/2015
11.1.9. Processor: The Heavy Tools newsletter service is operated by Wanadis Kereskedelmi és Szolgáltató Kft. (H-1118 Budapest, Rétköz u. 7., also being the central place of data processing, company registration number: Cg, 01-09-885144), therefore data stored on their servers are processed by them.
11.1.10. Customers who have registered in our webshop (customers with a Heavy Tools account according to chapter 7. of the Policy) have the possibility to request a customized newsletter and to consent to receiving such. In this case we process data as per chapter 7. of the Policy in connection with customized newsletters and we synchronize our newsletter with the interests of the customer (e.g. newsletters for men or women, information about regional special offers according to the customer’s address of notification, contents taking into account special interests volunteered by the customer, etc.). Subscribing and unsubscribing to a customized newsletter is only possible through a Heavy Tools account. The withdrawal of consent in terms of point 11.1.7. above is also taken as a withdrawal of the consent given to receiving customized Heavy Tools newsletters, while data stored in the Heavy Tools account are hereafter processed according to chapter 7. of the Policy, i.e. unsubscribing from the customized newsletter does not mean that data processed in this regard would also be deleted automatically. For this to happen the Heavy Tools account must be cancelled.
12. OPERATING ELECTRONIC SURVEILLANCE SYSTEMS
12.1.1. In some of the Heavy Tools shops electronic surveillance systems (surveillance cameras) are being operated. Shoppers are informed about such cameras being installed at the entrance in a clearly visible manner. Further, customers’ attention is drawn to the fact that by entering the Heavy Tools shop they implicitly consent to such voice and image recordings being made.
12.1.2. Data processed: voice and image recordings, including the image of data subjects.
12.1.3. Purpose of data processing: protection of property, prevention of crime and reconnaissance.
12.1.4. Legal basis of data processing: the above described voluntarily given implicit consent of data subjects in accordance of § 30 of Act Nᵒ 133 on protection of persons and property and the rules of private investigation.
12.1.5. Time limit of data processing: if the recording is not used, three working days from date of recording.
12.1.6. Data processing registration number: NAIH-90950/2015
13. LOYALTY PROGRAMME
13.1.1. Requests for participation in the loyalty programme can be submitted in the heavytools.hu webshop when registering an account and any time when logging in, or in our Heavy Tools shops by signing a written declaration. The loyalty programme entitles participants to have access to discounts specified in the loyalty policy, which can be found here: http://www.heavytools.hu/index.php?id=torzsvasarloi_program&al_id=1&nyelv=hun[R2]
13.1.2..Data processed: name, address, phone number, e-mail address, number of loyalty card and its balance.
13.1.3. Purpose of data processing: securing discounts and recording the conditions where discounts are applicable.
13.1.4. Legal basis of data processing: consent of the data subject in accordance with clause (4) of § 13/A of .
13.1.5. Time limit of data processing: until the explicit declaration by the participant that they wish to leave the loyalty programme. This declaration may be made in the same way as unsubscribing from the newsletter.
13.1.6. Registration number of the data processing: NAIH-90951/2015
14. JOB OFFERS
14.1.1. Premium Sport Kft. stores job applications received.
14.1.2. Data processed: CVs, applications, letters of motivation, including personal data volunteered.
14.1.3. Purpose of data processing: applications for vacant positions at Premium Sport Kft. and participation in the selection process.
14.1.4. Legal basis of data processing: voluntary consent of the data subject given when applying to Premium Sport Kft. for a position in accordance with clause (6) of § 6 of INFOtv.
14.1.5..Time limit of data processing: six months from submitting the application if the applicant is not employed.
14.1.6. Registration number of data processing: NAIH-90952/2015
15. AD HOC DATA PROCESSING
15.1.1. Rules of ad hoc data processing (e.g. for sweepstakes and campaignes organized together with third parties) are determined on an individual basis event by event in the interest of doing best possible justice to the characteristics of the events.
16. EQUIPMENT USED AND MEASURES TAKEN FOR DATA PROCESSING
16.1.1. Premium Sport Kft. selects and operates IT equipment for the processing of personal data in a way that they be:
- accessible for those authorized hereto (availability);
- authentic (authenticity of data processing);
- provably permanent (integrity of data), and
- protected against unauthorized access (confidentiality of data).
16.1.2.Premium Sport Kft. protects the data by taking appropriate measures with special emphasis on preventing unauthorized access, modification, transfer, disclosure, deletion or destruction and accidental destruction or damage, and on protection against data becoming inaccessible due to a change in the applied technology.
16.1.3. In the interest of protecting electronically processed data in the records of Premium Sport Kft. appropriate technical solutions are applied to make sure that stored data – save for legislation or this Policy making allowance for it – would not become directly connectable to data subjects.
16.1.4. With regard to the state of the art technology, Premium Sport Kft. provides for technical, organizational and structural measures regarding the safety of data processing which are proportionate to the known and accepted risk levels in connection with data processing in general.
17. OTHER PROCESSORS
17.1.1. Other processors we avail ourselves of in connection with our various data processing activities are described in the relevant chapters of the Policy.
17.1.2. Further to the processors referred to in point 17.1.1. we employ the services of the following third party processors for all the processing of data by IT systems:
- Our business data processing servers are operated by NetGo.hu (H-2100 Gödöllő, Kosuth u. 32. II/6), therefore data on these servers are processed by them via these IT systems (technical support). The place of data processing is the registered seat of our company, whereas in the case of distance access the place of data processing is the registered seat of the third party processor;
- Our business management system is being developed and operated by MNP-Szoftverház Kft. (H-1113 Budapest, Badacsonyi u. 21.), therefore data stored there are processed via this IT system (technical support). The place of data processing is the registered seat of our company, whereas in the case of distance access the place of data processing is the registered seat of the third party processor
18. DISPOSURE OVER DATA AND LEGAL RECOURSE
18.1.1. Should you have any questions, queries or complaints regarding the data processing of Premium Sport Kft., please do not hesitate to contact us.
18.1.2. The data subject is entitled to ask for information about the processing of their personal data and they can demand correction, secret processing and – save for obligatory data processing – deletion of their personal data.
18.1.3. At the request of the data subject Premium Sport Kft. provides information about data processed by them and by other processors employed, about the sources of the data, the purpose, legal basis and time limit of data processing, the name, address and data processing related activities of the processor, about possible data protection incidents, their effects and measures taken to avert them, as well as about the legal basis and addressee of data disclosure and data transfer. The processor informs the data subject in writing within the shortest possible time but not later than within 30 days from receiving the data subject’s request for such information.
18.1.4..The data subject has the right to object to the processing of their personal data in accordance with the provisions of the INFOtv.
18.1.5. The processor advises the data subject about the execution of their request or objection before the expiry of the time limit provided for by the INFOtv.
18.1.6. The possibilities of legal recourse are regulated by the INFOtv. in detail, which we ensure in accordance with the provisions of the Act. The processor and data processors fully adhere to the provisions of the INFOtv. and in general they act bona fide when processing data.
18.1.7. The data subject can turn to the Hungarian National Authority for Data Protection and Freedom of Information (postal address: H-1053 Budapest, POB 5., address: H-1125 Budapest, Szilágyi Erzsébet Fasor 22/c, phone: +36 (1) 391 1400, Fax: +36 (1) 391 1410, e-mail: firstname.lastname@example.org, URL: http://naih.hu) for legal recourse, or they can start court proceedings.
19. FINAL PROVISIONS
19.1.1. To issues not regulated by the Policy the rules of Hungarian law are applicable with special regard to the following Acts:
Act Nᵒ 5. of 2013 – on the Hungarian Civil Code (Ptk.)
Act Nᵒ 100. of 2000 – on Accounting (Számv. tv.)
Act Nᵒ 108. of 2001 – on electronic trade and certain issues in connection with the information society (Eker. tv.);
Act Nᵒ 112. of 2011 - on the Right of Informational Self-Determination and on Freedom of Information (INFOtv.);
Act Nᵒ 48. of 2008 – on the fundamental conditions of commercial advertising and certain limitations (Grt.).
19.1.2. This Policy was drafted by dr. Kövi László, attorney at law (Kövi Lawyer’s Office) on 22nd October, 2015. This information is provided in line with the provision of point 7/2 of the 8/1999 (III.22.) policy of MÜK (Hungarian Chamber of Lawyers).