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MacSzerez
Magyar

Privacy notice

This is a courtesy translation of the Hungarian document. In case of any discrepancy, the Hungarian version prevails.

Takarék Trading Vagyonkezelő Kft.

Privacy Notice

Introduction

Takarék Trading Vagyonkezelő Kft. (1137 Budapest, Katona József utca 6. fsz. 2., tax number: 24301415-2-41, company registration number: 01 09 170791) (hereinafter: the Service Provider, the controller) carries out its data processing activities as set out in this notice.

We provide the following information in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

This privacy notice governs the data processing of the following websites/mobile applications: https://www.macszerez.com

The privacy notice is available at: www.macszerez.com/adatvedelem

Amendments to the notice take effect upon publication at the above address.

The controller and its contact details

Name: Takarék Trading Vagyonkezelő Kft.

Registered office: 1137 Budapest, Katona József utca 6. fsz. 2.

E-mail: kapcsolat@macszerez.com

Telephone: 06302636755

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, a 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, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
  3. "controller": 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;
  4. "processor": a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
  5. "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. 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;
  6. "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;
  7. "personal data breach": a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
  8. "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 analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;
  9. "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 authorised to process personal data.

Principles relating to the processing of personal data

Personal data shall be:

  1. processed lawfully, fairly and in a transparent manner in relation to the data subject ("lawfulness, fairness and transparency");
  2. collected only for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes ("purpose limitation");
  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed ("data minimisation");
  4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay ("accuracy");
  5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1), subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject ("storage limitation");
  6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures ("integrity and confidentiality").

The controller shall be responsible for, and be able to demonstrate compliance with, the above ("accountability").

The controller declares that its data processing is carried out in accordance with the principles set out in this section.

Data processing related to the fulfilment of orders

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

Personal data Purpose of the processing Legal basis
User name Identification, enabling registration. The data subject's consent, Article 6(1)(a) GDPR.
Password Serves secure login to the user account.
Surname and first name Necessary for contact, for the purchase, for issuing a proper invoice and for exercising the right of withdrawal. Performance of a contract, Article 6(1)(b) GDPR.
E-mail address Keeping in contact.
Telephone number Keeping in contact, more efficient coordination of questions concerning invoicing or delivery.
Billing name and address Issuing a proper invoice, as well as the conclusion of the contract, the determination of its content, its amendment, the monitoring of its performance, the invoicing of the fees arising from it, and the enforcement of claims relating to it.

Compliance with a legal obligation, Article 6(1)(c) GDPR.

(The legal obligation is Section 169(2) of Act C of 2000 (2000. évi C. törvény) on Accounting)
Delivery name and address Enabling home delivery. Performance of a contract, Article 6(1)(b) GDPR.
Time of purchase/registration Carrying out a technical operation. Performance of a contract, Article 6(1)(b) GDPR.
IP address at the time of purchase/registration Carrying out a technical operation.

2. Data subjects: All data subjects registered on or purchasing from the webshop website. Neither the user name nor the e-mail address is required to contain personal data.

3. Duration of the processing, time limit for the erasure of the data: If any of the conditions set out in Article 17(1) GDPR applies, until the data subject's request for erasure. Pursuant to Article 19 GDPR, the controller informs the data subject electronically of the erasure of any personal data provided by the data subject. If the data subject's request for erasure also extends to the e-mail address provided by the data subject, the controller will also erase the e-mail address after providing the information. The exception is accounting documents, since under Section 169(2) of Act C of 2000 (2000. évi C. törvény) on Accounting these data must be retained for 8 years. The data subject's contractual data may be erased upon the data subject's request for erasure once the civil law limitation period has expired.

Accounting documents directly and indirectly supporting the bookkeeping accounts (including general ledger accounts and analytical or detailed records) must be retained for at least 8 years in a legible form, retrievable by reference to the accounting records.

4. Description of the data subjects' rights relating to the processing:

  • The data subject may request from the controller access to, rectification, erasure or restriction of the processing of the personal data concerning him or her, and
  • the data subject has the right to data portability and the right to withdraw consent at any time.

5. The data subject may initiate access to personal data, their erasure, modification or restriction of processing, and data portability in the following ways:

  • by post at 1137 Budapest, Katona József utca 6. fsz. 2.,
  • by e-mail at kapcsolat@macszerez.com,
  • by telephone on 06302636755.

6. We inform you that

  • the processing is necessary for the performance of a contract and for making an offer.
  • you are obliged to provide the personal data so that we can fulfil your order.
  • failure to provide the data has the consequence that we cannot process your order.

Management of cookies

1. No prior consent needs to be requested from data subjects for the use of the so-called "password-protected session cookies", "shopping cart cookies", "security cookies", "necessary cookies", "functional cookies" and "cookies responsible for managing website statistics".

2. The fact of the data processing, the scope of the data processed: Unique identification number, dates, times.

3. Data subjects: All data subjects visiting the website.

4. Purpose of the processing: Identifying users, tracking visitors, ensuring personalised operation.

5. Duration of the processing, time limit for the erasure of the data:

Type of cookie Legal basis of the processing Duration of the processing
Session cookies, or other cookies that are indispensable for the operation of the website No data processing takes place through the use of the cookie. The period until the end of the relevant visitor session, that is, it remains on the computer only until the browser is closed.
Statistical and marketing cookies Article 6(1)(a) GDPR 1 day to 2 years, in accordance with the cookie notice, and the processing lasts until the data subject withdraws consent.

6. Description of the data subjects' rights relating to the processing: Data subjects have the option to delete cookies in the Tools/Settings menu of their browsers, usually under the settings of the Privacy menu item.

7. Most browsers used by our users allow you to set which cookies are to be saved and allow (certain) cookies to be deleted again. If you restrict the saving of cookies on certain websites or do not allow third-party cookies, this may, under certain circumstances, result in our website no longer being fully usable. Here you can find information on how to customise the cookie settings for the usual browsers:

Google Chrome (https://support.google.com/chrome/answer/95647?hl=hu)

Microsoft Edge (https://support.microsoft.com/...)

Firefox (https://support.mozilla.org/hu/kb/sutik-engedelyezese-es-tiltasa-amit-weboldak-haszn)

Safari (https://support.apple.com/hu-hu/guide/safari/sfri11471/mac)

Use of Google Ads conversion tracking

  1. The controller uses the online advertising programme called "Google Ads" and, within its framework, uses Google's conversion tracking service. Google conversion tracking is an analytics service of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; "Google").
  2. When a User reaches a website through a Google advertisement, a cookie required for conversion tracking is placed on the User's computer. The validity of these cookies is limited, and they do not contain any personal data, so the User cannot be identified by them.
  3. When the User browses certain pages of the website and the cookie has not yet expired, both Google and the controller can see that the User clicked on the advertisement.
  4. Each Google Ads customer receives a different cookie, so they cannot be tracked across the websites of Ads customers.
  5. The information obtained with the help of conversion tracking cookies serves the purpose of producing conversion statistics for customers who have chosen Ads conversion tracking. Customers are thus informed of the number of users who clicked on their advertisement and were forwarded to a page tagged with a conversion tracking tag. However, they do not receive any information that could be used to identify any user.
  6. If you do not wish to participate in conversion tracking, you can decline this by disabling the installation of cookies in your browser. You will then not be included in the conversion tracking statistics.
  7. Under Google Consent Mode v2, Google also uses two new types of cookies: ad_user_data and ad_personalization, which are based on the data subject's consent and which concern the use and sharing of data. ad_user_data serves to give consent for the sending of user data to Google for advertising purposes. ad_personalization governs whether the data may be used to personalise advertisements (e.g. remarketing). The controller ensures that the appropriate consents are obtained and withdrawn through its cookie banner/panel. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
  8. Further information and Google's privacy statement are available at: https://policies.google.com/privacy

Use of Google Analytics

  1. This website uses Google Analytics, a web analytics service of Google Inc. ("Google"). Google Analytics uses so-called "cookies", text files that are saved on your computer and thus help analyse the use of the website visited by the User.
  2. The information generated by the cookies about the website used by the User is usually transmitted to and stored on a Google server in the USA. By activating IP anonymisation on the website, Google shortens the User's IP address beforehand within the Member States of the European Union or in other states party to the Agreement on the European Economic Area.
  3. The transmission of the full IP address to a Google server in the USA and its shortening there takes place only in exceptional cases. On behalf of the operator of this website, Google will use this information to evaluate how the User has used the website, to compile reports for the website operator on website activity, and to provide further services relating to website and internet usage.
  4. Within the framework of Google Analytics, the IP address transmitted by the User's browser is not merged with other data of Google. The User can prevent the storage of cookies by setting the browser accordingly; however, we draw your attention to the fact that in this case not all functions of this website may be fully usable. You can also prevent Google from collecting and processing the data relating to the User's use of the website generated by the cookies (including the IP address) by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=hu

Newsletter, direct marketing (DM) activity based on consent

1. Pursuant to Section 6 of Act XLVIII of 2008 (2008. évi XLVIII. törvény) on the Essential Conditions of and Certain Limitations to Commercial Advertising Activity, unless a separate act provides otherwise, an advertisement may be communicated to a natural person (the User) as the addressee of the advertisement by the method of direct approach (hereinafter: direct marketing), in particular by electronic mail or an equivalent other individual means of communication, only if the addressee of the advertisement has given prior, clear and express consent to it.

2. Furthermore, bearing in mind the provisions of this notice, the User may consent to the Service Provider processing the personal data necessary for sending advertising offers.

3. The Service Provider does not send unsolicited advertising messages, and the User may unsubscribe from receiving offers free of charge, without restriction and without giving reasons. In this case the Service Provider erases from its records all of the User's personal data necessary for sending advertising messages and will not approach the User with further advertising offers. The User can unsubscribe from advertisements by clicking the link in the message.

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

Personal data Purpose of the processing Legal basis
Name, e-mail address. Identification, enabling subscription to the newsletter/discount coupons. The data subject's consent, Article 6(1)(a) GDPR.
Time of subscription Carrying out a technical operation.
IP address at the time of subscription Carrying out a technical operation.

5. Newsletters are sent in compliance with the provisions of Act XLVIII of 2008 (2008. évi XLVIII. törvény) on the Essential Conditions of and Certain Limitations to Commercial Advertising Activity.

6. Data subjects: All data subjects subscribing to the newsletter.

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

8. Duration of the processing, time limit for the erasure of the data: The processing lasts until the consent is withdrawn (unsubscription, the data subject's request for erasure) or until the newsletter is discontinued.

9. Description of the data subjects' rights relating to the processing:

  • The data subject may request from the controller access to, rectification, erasure or restriction of the processing of the personal data concerning him or her, and
  • the data subject has the right to data portability and the right to withdraw consent at any time.

10. The data subject may initiate access to personal data, their erasure, modification or restriction of processing, and data portability in the following ways:

  • by post at 1137 Budapest, Katona József utca 6. fsz. 2.,
  • by e-mail at kapcsolat@macszerez.com,
  • by telephone on 06302636755.

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

12. We inform you that

  • the processing is based on your consent.
  • you are obliged to provide the personal data if you wish to receive a newsletter from us.
  • failure to provide the data has the consequence that we cannot send you a newsletter.
  • you can withdraw your consent at any time by clicking on unsubscribe.
  • the withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Complaint handling

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

Personal data Purpose of the processing Legal basis
Surname and first name Identification, keeping in contact.

Compliance with a legal obligation, Article 6(1)(c) GDPR.

(The relevant legal obligation: Section 17/A(7) of Act CLV of 1997 (1997. évi CLV. törvény) on Consumer Protection)
E-mail address Keeping in contact.
Telephone number Keeping in contact.
Billing name and address Identification, handling quality objections, questions and problems arising in connection with the products/services ordered.

2. Data subjects: All data subjects purchasing on the website who raise a quality objection or lodge a complaint.

3. Duration of the processing, time limit for the erasure of the data: Copies of the record taken of the objection, the transcript and the reply given to it must be retained for 3 years pursuant to Section 17/A(7) of Act CLV of 1997 (1997. évi CLV. törvény) on Consumer Protection.

4. Description of the data subjects' rights relating to the processing:

  • The data subject may request from the controller access to, rectification, erasure or restriction of the processing of the personal data concerning him or her, and
  • the data subject has the right to data portability and the right to withdraw consent at any time

5. The data subject may initiate access to personal data, their erasure, modification or restriction of processing, and data portability in the following ways:

  • by post at 1137 Budapest, Katona József utca 6. fsz. 2.,
  • by e-mail at kapcsolat@macszerez.com,
  • by telephone on 06302636755.

6. We inform you that

  • the provision of personal data is based on a legal obligation.
  • the processing of personal data is a precondition for concluding the contract.
  • you are obliged to provide the personal data so that we can handle your complaint.
  • failure to provide the data has the consequence that we cannot handle the complaint you have submitted to us.

Recipients to whom the personal data are disclosed

"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.

1. Processors (who carry out the processing on behalf of the controller)

The controller uses processors to facilitate its own data processing activities and to fulfil its obligations under contracts concluded with the data subject and under legislation.

The controller places great emphasis on using only processors that provide sufficient guarantees to implement appropriate technical and organisational measures ensuring compliance of the processing with the requirements of the GDPR and the protection of the rights of data subjects.

The processor and any person acting under the authority of the controller or of the processor who has access to personal data processes the personal data set out in these rules only in accordance with the instructions of the controller.

The controller is legally liable for the activities of the processor. The processor is liable for damage caused by the processing only if it has not complied with the obligations specified in the GDPR that are directed specifically at processors, or if it has disregarded or acted contrary to the lawful instructions of the controller.

The processor has no substantive decision-making power concerning the processing of the data.

The controller may use a hosting provider as a processor to provide the IT background, and a courier service as a processor to deliver the products ordered.

2. Individual processors

Processor activity Name, address, contact details
Hosting service NetMasters Europe Kft.
1105 Budapest, Cserkesz u. 32.
szia@netmasters.hu
Other processor (e.g. online invoicing, web development, marketing) Billingo (Octonull Kft) Magyar Posta Zrt
1133 Budapest, Árbóc utca 6. III. emelet,
hello@billingo.hu

"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 authorised to process personal data.

3. Transfer of data to a third party

Third-party controllers process the personal data disclosed by us in their own name, in accordance with their own privacy policies.

Controller activity Name, address, contact details
Transport GLS General Logistics Systems Hungary Csomag-Logisztikai Kft. Magyar Posta Zrt.
2351 Alsónémedi GLS Európa u. 2. Budapest, VI. ker. Teréz krt. 51-53.
info@gls-hungary.com ugyfelszolgalat@posta.hu
Online payment Stripe Inc.
Headquarters 185 Berry Street Suite 550. San Francisco, CA 94107
support@stripe.com

Social media platforms

The controller is also present on social media platforms in order to present its services and to keep in contact with prospects and customers.

Scope of the data processed: Data publicly available on the data subject's social media profile, in particular:

– name (user name)

– public profile picture

– interactions published by the data subject or related to the controller's page (e.g. comment, message).

Data subjects: Natural persons who follow the controller's social media page, interact with it or send a message through it.

Purpose of the processing:

– presenting the controller's activities and services,

– marketing and communication on social media platforms,

– keeping in contact with prospects and customers.

Legal basis of the processing: The data subject's voluntary consent to the processing of his or her personal data on the social media platforms.

Duration of the processing: The processing lasts for as long as the data subject's interaction exists, or until the content published by the data subject is deleted. The controller retains messages and communications for a maximum of 2 years.

Other controllers: The social media platforms process users' data as independent controllers in accordance with their own privacy policies.

Facebook / Meta joint controllership

The controller has a Facebook / Meta profile for its activity. The processing for statistical purposes carried out on the Facebook social media page is joint controllership between the Controller and Facebook Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, D2 Dublin, Ireland). Details of the joint controllership arrangement are provided in the Controller Addendum for the Facebook Page Insights function. The addendum is available
at the following link: https://www.facebook.com/legal/terms/page_controller_addendum

On the social media platform, the Controller communicates by private message only if you contact us there.

1. Categories of data subjects

  • a data subject who has registered on the social media platform and has "liked" the Controller's profile page,
  • a data subject who contacts the Controller by private message on the social media platform.

2. Purpose of the processing

The purpose of the processing is to share and promote the controller's activities and services on the Facebook social media platform. The Controller may use the data provided by the data subject in a private message to reply to the message; otherwise the Controller does not collect data through the social media platforms and does not extract data from them.

3. Legal basis of the processing

The processing is based on Article 6(1)(a) GDPR; the legal basis of the processing is the data subject's consent to the processing of his or her personal data on the Facebook social media platform.

4. Scope of the data processed

  • the data subject's registered name,
  • the data subject user's public profile picture
  • other public data provided or shared by the data subject on the social media platform

5. Source of the personal data processed: The source of the data processed is the data subject.

6. Withdrawal of consent: You may withdraw your consent to the processing at any time and may delete your post or comment. The processing takes place through the social media platforms, which are operated by a third party.
If you withdraw your consent, the Controller deletes the conversation held with you. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

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

  • by post at 1137 Budapest, Katona József utca 6. fsz. 2.,
  • by e-mail at kapcsolat@macszerez.com,
  • by telephone on 06302636755.

7. Duration of the processing

  • until the data subject withdraws consent,
  • if messages are exchanged, then 2 years.

8. Transfer of the personal data, recipients and categories of recipients: For the definition of recipient, see Article 4(9) GDPR. The Controller discloses the Data Subject's personal data to state bodies and authorities, in particular courts, the public prosecutor's office, investigating authorities and misdemeanour authorities, and the Hungarian National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság, NAIH), only in exceptional cases and on the basis of a legal obligation.

9. Possible consequences of failure to provide data

If the data are not provided, the data subject cannot obtain information about the Controller's activities and services through the Facebook social media platform, nor send a message to the Controller via Facebook Messenger.

10. Automated decision-making (and profiling): No automated decision-making, including profiling, takes place during the processing.

11. Joint controller agreement concluded with Facebook Ireland Ltd.:

The Page Insights function displays aggregated data that make it transparent how data subjects use the Facebook page. Facebook Ireland Limited ("Facebook Ireland") and the Controller are joint controllers with regard to the processing of insights data. The Page Insights addendum determines Facebook's responsibility and the Controller's responsibility in connection with the processing of insights data. Facebook Ireland assumes primary responsibility under the GDPR for the processing of insights data and for complying with all relevant obligations laid down in the GDPR in connection with the processing of insights data. Facebook Ireland also makes the essence of the Page Insights addendum available to all data subjects. The Controller ensures that it has an appropriate legal basis under the GDPR for the processing of insights data, identifies the controller of the page, and complies with all other applicable legal obligations. Facebook Ireland is solely responsible for the processing of personal data in connection with the Page Insights function, except for data falling within the scope of the Page Insights addendum. The Page Insights addendum does not give the Controller the right to request the personal data of Facebook users that Facebook Ireland processes in connection with Facebook, including page insights data. The Controller may not act or respond on behalf of Facebook Ireland in fulfilling data protection requests.

Customer relations and other data processing

  1. If a question arises or the data subject has a problem in the course of using the controller's services, he or she may contact the controller in the ways provided on the website (telephone, e-mail, social media platforms, etc.).
  2. The controller deletes the e-mails and messages received, and the data provided by telephone, on Meta, etc., together with the enquirer's name and e-mail address and any other personal data provided voluntarily, after a maximum of 2 years from the communication of the data.
  3. We provide information on data processing not listed in this notice at the time the data are collected.
  4. In the case of an exceptional request from an authority, or a request from other bodies on the basis of authorisation by law, the Service Provider is obliged to provide information, to disclose and transfer data, and to make documents available.
  5. In these cases the Service Provider discloses personal data to the requesting party, provided that the requesting party has specified the exact purpose and the scope of the data, only to the extent and in the amount that is indispensable for achieving the purpose of the request.

Rights of data subjects

1. Right of access

You have the right to obtain from the controller confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and to the information listed in the Regulation.

2. Right to rectification

You have the right to obtain from the controller, upon your request and without undue delay, the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

3. Right to erasure

You have the right to obtain from the controller, upon your request and without undue delay, the erasure of personal data concerning you, and the controller is obliged to erase personal data concerning you without undue delay where certain conditions are met.

4. Right to be forgotten

Where the controller has made the personal data public and is obliged to erase them, 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 data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

5. Right to restriction of processing

You have the right to obtain from the controller, upon your request, restriction of processing where one of the following applies:

  • you contest the accuracy of the personal data, in which case the restriction applies for a period enabling the controller to verify the accuracy of the personal data;
  • the processing is unlawful and you oppose the erasure of the data and request the restriction of their use instead;
  • the controller no longer needs the personal data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims;
  • you have objected to processing; in this case the restriction applies for the period until it is verified whether the legitimate grounds of the controller override your legitimate grounds.

6. Right to data portability

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

7. Right to object

In the case of processing based on legitimate interests or on the exercise of official authority as legal bases, you have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you (...), including profiling based on those provisions.

8. Objection in the case of direct marketing

Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

9. Automated individual decision-making, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

The preceding paragraph shall not apply if the decision:

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

Time limit for taking action

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

If necessary, this period may be extended by 2 months. The controller shall inform you of any such extension, together with the reasons for the delay, within 1 month of receipt of the request.

If the controller does not take action on your request, it shall inform you without delay and at the latest within one month of receipt of the request of the reasons for not taking action, and of the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.

Security of the processing

The controller and the processor shall implement appropriate technical and organisational measures, taking into account the state of the art and the costs of implementation and the nature, scope, context and purposes of the processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk, including inter alia as appropriate:

  1. the pseudonymisation and encryption of personal data;
  2. the ability to ensure the ongoing confidentiality, integrity, availability and resilience of the systems and services used for processing personal data;
  3. the ability to restore the availability of and access to personal data in a timely manner in the event of a physical or technical incident;
  4. a process for regularly testing, assessing and evaluating the effectiveness of the technical and organisational measures taken to ensure the security of the processing.
  5. The data processed must be stored in such a way that unauthorised persons cannot access them. In the case of paper-based data carriers, by establishing rules for physical storage and filing; in the case of data processed in electronic form, by using a central access management system.
  6. The method of storing data by IT means must be chosen so that the data can be erased, also taking into account any different erasure deadlines, upon expiry of the erasure deadline or if this is necessary for any other reason. The erasure must be irreversible.
  7. Paper-based data carriers must be stripped of personal data by means of a document shredder or by engaging an external organisation specialising in document destruction. In the case of electronic data carriers, physical destruction must be ensured in accordance with the rules on the disposal of electronic data carriers, and, where necessary, the data must first be securely and irreversibly erased.
  8. The controller takes the following specific data security measures:

To ensure the security of personal data processed on paper, the Service Provider applies the following measures (physical protection):

  1. Documents must be kept in a secure, well-lockable, dry room.
  2. If personal data processed on paper are digitised, the rules applicable to digitally stored documents must be applied.
  3. An employee of the Service Provider carrying out data processing may leave the room in which data processing takes place during work only after locking away the data carriers entrusted to him or her, or locking the room concerned.
  4. Personal data may be accessed only by persons authorised to do so; third parties may not have access to them.
  5. The Service Provider's building and premises are equipped with fire protection and property protection devices.

IT protection

  1. The computers and mobile devices (other data carriers) used in the processing are in the possession of the Service Provider.
  2. The computer system containing personal data used by the Service Provider is equipped with virus protection.
  3. To ensure the security of digitally stored data, the Service Provider uses data backups and archiving.
  4. The central server machine may be accessed only with appropriate authorisation and only by the persons designated for that purpose.
  5. Data on the computers can be accessed only with a user name and password.

Informing the data subject of a personal data breach

If the 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.

The information given to the data subject shall describe, in clear and plain language, the nature of the personal data breach and shall communicate the name and contact details of the data protection officer or other contact point where more information can be obtained; shall describe the likely consequences of the personal data breach; and shall 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.

The data subject does not need to be informed if any of the following conditions is met:

  • the controller has implemented appropriate technical and organisational protection measures, and those measures were applied to the data affected by the personal data breach, in particular measures, such as encryption, that render the data unintelligible to any person who is not authorised to access it;
  • the controller has taken subsequent measures following the personal data breach which ensure that the high risk to the rights and freedoms of the data subject is no longer likely to materialise;
  • it would involve disproportionate effort. In such cases, data subjects shall be informed by means of publicly available information, or a similar measure shall be taken whereby the data subjects are informed in an equally effective manner.

If the controller has not already communicated the personal data breach to the data subject, the supervisory authority, having considered the likelihood of the personal data breach resulting in a high risk, may order the data subject to be informed.

Reporting a personal data breach to the authority

The controller shall report the personal data breach to the supervisory authority competent under Article 55 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 report is not made within 72 hours, it shall be accompanied by reasons for the delay.

Review in the case of mandatory processing

If the duration of mandatory processing, or the periodic review of its necessity, is not specified by an act, a decree of a local government, or a binding legal act of the European Union, the controller shall review at least every three years from the start of the processing whether the processing of the personal data processed by it, or by a processor acting on its behalf or on its instructions, is necessary for achieving the purpose of the processing.

The controller shall document the circumstances and the result of this review, retain this documentation for ten years after the review has been carried out, and make it available to the Hungarian National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság, hereinafter: the Authority) upon the Authority's request.

Right to lodge a complaint

A complaint against any infringement by the controller may be lodged with the Hungarian National Authority for Data Protection and Freedom of Information:

Nemzeti Adatvédelmi és Információszabadság Hatóság (Hungarian National Authority for Data Protection and Freedom of Information, NAIH)
1055 Budapest, Falk Miksa utca 9-11.
Postal address: 1363 Budapest, Pf. 9.
Telephone: +36 -1-391-1400
Fax: +36-1-391-1410
E-mail: ugyfelszolgalat@naih.hu

Closing provisions

In preparing this notice, we have taken into account the following legislation and recommendations:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (GDPR);
  • 2001. évi CVIII. törvény (Act CVIII of 2001) on certain issues of electronic commerce services and information society services (mainly Section 13/A);
  • 2008. évi XLVII. törvény (Act XLVII of 2008) on the prohibition of unfair commercial practices against consumers;
  • 2008. évi XLVIII. törvény (Act XLVIII of 2008) on the essential conditions of and certain limitations to commercial advertising activity (in particular Section 6);
  • 2005. évi XC. törvény (Act XC of 2005) on the freedom of electronic information;
  • 2003. évi C. törvény (Act C of 2003) on electronic communications (specifically Section 155);
  • Opinion No. 16/2011 on the EASA/IAB Best Practice Recommendation on Online Behavioural Advertising;
  • The recommendation of the Hungarian National Authority for Data Protection and Freedom of Information on the data protection requirements of prior information.

Previous versions of the Macszerez.com Privacy Notice

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Date of last update: 2026.08.06