Privacy Policy

1. General Principles

• We collect and process personal data only in accordance with applicable laws.
• We only transfer personal data to third parties with consent.
• We do not sell the personal data we process to third parties under any circumstances.
• We store data as securely as possible.
• We only send newsletters to those who have given their prior and explicit consent.
• Data subjects may request access to, modification or deletion of the data stored about them at any time.

2. Details and Contact Information of Our Company (Data Controller, Service Provider)

Name of the data controller: Kolics Imre EV
Contact details of the data controller: 
Telephone: +36309972426
Email: info@kimedia.hu
Web: https://www.kimedia.hu
Tax number: 67534821-1-51

The Service Provider reserves the right to amend this Privacy Policy and will inform data subjects of any such changes in an appropriate manner. Information relating to data processing is published on the LINK GOES HERE website.

3. Definitions According to the GDPR (Regulation)

3.1. data subject/User:any identified or identifiable natural person based on personal data, whether directly or indirectly;

3.2. personal data: any data relating to the data subject – in particular the name, identification mark and one or more elements characteristic of their physical, physiological, mental, economic, cultural or social identity – as well as any conclusion that can be drawn from such data concerning the data subject;

3.3. consent: a voluntary and specific expression of the data subject's wishes, based on appropriate information, by which they give their unambiguous consent to the processing of personal data relating to them, either in full or for specific processing operations;

3.4. data controller:the natural or legal person or organisation without legal personality that, alone or jointly with others, determines the purposes of data processing, makes and implements decisions regarding data processing (including the means used), or has them carried out by the data processor;

3.5. data processing: any operation or set of operations performed on data, regardless of the procedure used, including in particular collection, recording, organisation, storage, alteration, use, retrieval, transmission, disclosure, coordination or combination, blocking, deletion and destruction of data, prevention of further use of the data, creation of photographs, audio or video recordings, and recording physical characteristics suitable for identifying a person (e.g. fingerprint or palm print, DNA sample, iris image);

3.6. data transfer: making data accessible to a specific third party;

3.7. disclosure: making data accessible to anyone;

3.8. data deletion:making data unrecognisable in such a way that it can no longer be restored;

3.9. data processing: performing technical tasks related to data processing operations, regardless of the method and means used to carry out the operations and the place of application, provided that the technical task is performed on the data;

3.10. data processor: the natural or legal person or organisation without legal personality that processes data under a contract, including a contract concluded pursuant to a legal provision;

3.11. personal data breach: unlawful processing or handling of personal data, including in particular unauthorised access, alteration, transfer, disclosure, deletion or destruction, as well as accidental destruction or damage.

4. Scope of Data Processed, Purpose and Duration of Processing, and Data Processor

Data subjects concerned: All data subjects registered/purchasing on the webshop website.

Personal data is shared exclusively with the third party specified in the “Processor of the relevant personal data” column, for the purpose of fulfilling the obligations set out in the contract.

Details and tasks of the data processors used during data processing

Hosting provider
Name: InfoNetfort Kft.
Address: 7900 Szigetvár, Szent István ltp 17. IV/25.
Telephone: +36-30/530-2953
Email: kapcsolat@netfort.hu
Web: www.netfort.hu
Tax number: 26648082-2-02
Company registration number: 02 09 084205

Accounting tasks

Courier service

Direct marketing, newsletter
Name:
Address:

4.1 Contact form:

Data subjects concerned: Persons who contact us by telephone, email or via the contact form.

Personal data is not shared with third parties.

5. Newsletter, Direct Marketing Activities

We only send newsletters to Users who have given their prior and explicit consent. Consent is given using the “Subscribe to newsletter” form.

Data subjects concerned: All data subjects subscribed to the newsletter.

The operator of the newsletter sending system and the data processor:
Name:
Address:

5.1 Procedure for withdrawing consent (unsubscription)
The data subject may unsubscribe from the newsletter at any time and free of charge. Unsubscription may take place using the link included in the newsletters or by sending an email to EMAIL ADDRESS GOES HERE.

6. Cookie Management

6.1 What is a cookie?

During visits to the website, the Data Controller uses so-called cookies. A cookie is an information package consisting of letters and numbers that our website sends to the data subject's browser in order to save certain settings, facilitate the use of our website and help us collect some relevant statistical information about our visitors. Cookies do not contain personal information and are not suitable for identifying individual users. Cookies often contain a unique identifier – a secret, randomly generated sequence of numbers – which is stored on the data subject's device.
Some cookies expire when the website is closed, while others are stored on your computer for a longer period.

6.2. Legal background and legal basis for cookie management

Cookies characteristic of webshops include the “password-protected session cookie”, “shopping cart cookies” and “security cookies”, the use of which does not require prior consent from data subjects.

The fact of data processing, scope of data processed: Unique identifier, dates, times

Data subjects concerned: All data subjects visiting the website.

Purpose of data processing: Identification of users, tracking visitors.

Legal basis for data processing: the consent of the data subject in accordance with Section 5(1)(a) of the Infotv.

6.3 Duration of data processing, deadline for deletion of data: the website uses the following cookies:

• Security cookies: __cfduid, _biz_flagsA, _biz_nA 3, _biz_pendingA, _biz_sid, _biz_uid
• Google Analytics cookies: _ga, _gid
• Cookies necessary for proper use of the website:

Possible data controllers authorised to access the data: The Data Controller does not process personal data through the use of cookies.

Description of the rights of data subjects concerning data processing: Data subjects may delete cookies in the browser's Tools/Settings menu, generally under the Privacy settings.
If the data subject does not accept the use of cookies, certain functions will not be available to them. Further information about deleting cookies can be found at the following links:
• Internet Explorer: http://windows.microsoft.com/en-us/internet-explorer/delete-managecookies#ie=ie-11
• Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-yourcomputer
• Chrome: https://support.google.com/chrome/answer/95647?hl=en
• Safari: https://support.apple.com/kb/ph21411?locale=en_US

7. Google Analytics

7.1. This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses so-called “cookies”, text files that are stored on your computer and enable analysis of the use of the website visited by the User.
7.2. Information generated by cookies relating to the website used by the User is usually transmitted to and stored on one of Google's servers in the USA. By activating IP anonymisation on the website, Google shortens the User's IP address beforehand within member states of the European Union or in other states party to the Agreement on the European Economic Area.
7.3. The full IP address is transmitted to and shortened on Google's server in the USA 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 relating to website activity, and to provide further services related to website and internet usage.
7.4. Within Google Analytics, the IP address transmitted by the User's browser is not merged with other data held by Google. The User may prevent cookies from being stored by selecting the appropriate browser settings; however, please note that in this case not all functions of this website may be fully available. The User may also prevent Google from collecting and processing data generated by cookies relating to the User's use of the website (including the IP address) by downloading and installing the browser plugin available at the following link. https://tools.google.com/dlpage/gaoptout?hl=en

8. Google AdWords Conversion Tracking and Remarketing

8.1. The Data Controller uses the online advertising programme called “Google AdWords” and, within this framework, also uses Google's conversion tracking service. Google conversion tracking is an analytics service provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”).
8.2. When a User reaches a website through a Google advertisement, a cookie required for conversion tracking is placed on their computer. These cookies have a limited validity period and do not contain any personal data, so the User cannot be identified through them.
8.3. When the User browses certain pages of the website and the cookie has not yet expired, both Google and the Data Controller can see that the User clicked on the advertisement.
8.4. Each Google AdWords customer receives a different cookie, so cookies cannot be tracked through the websites of AdWords customers.
8.5. The information obtained using conversion tracking cookies is used to create conversion statistics for customers who have chosen AdWords conversion tracking. This allows customers to find out the number of Users who clicked on their advertisement and were redirected to a page tagged with a conversion tracking tag. However, they do not receive information that could be used to identify any User.
8.6. If you do not wish to participate in conversion tracking, you may refuse this by disabling the installation of cookies in your browser. The data subject will then not be included in conversion tracking statistics.
8.7. Further information and Google's privacy statement are available at: www.google.de/policies/privacy/

8.8. Google AdWords Remarketing

8.9. Data processing as a remarketing activity takes place using cookies.

Data processed
The data processed by the cookies specified in the cookie policy.
Duration of data processing
The data storage period of the relevant cookie; further information is available here:
Google general cookie information: https://www.google.com/policies/technologies/types/
Google Analytics information:
https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage?hl=en
Legal basis for data processing
The data subject's voluntary consent given to the Service Provider through the use of the website.

9. Rights of Data Subjects

9.1 Right to information
At the request of the data subject, the Service Provider, as Data Controller, provides information about the data processed by it or by a processor appointed by it, the source of the data, the purpose, legal basis and duration of processing, the name and address of the data processor and its activities related to data processing, the circumstances and effects of any personal data breach and the measures taken to remedy it, and, in the case of data transfer, the legal basis and recipient. The Data Controller shall provide the information in an understandable form and in writing at the request of the data subject as soon as possible, but no later than 30 days after the request is submitted. This information is free of charge if the person requesting the information has not submitted a request for information concerning the same data category to the Data Controller during the current year. In other cases, the Service Provider may charge a fee.

9.2 Right to rectification
The Service Provider shall rectify personal data if it does not correspond to reality and the correct personal data is available to it.

9.3 Right to restriction
The Service Provider shall restrict the processing of personal data if the data subject requests this or if, based on the information available, it can be assumed that deletion would violate the legitimate interests of the data subject. Restricted personal data may only be processed for as long as the purpose of processing that prevented deletion continues to exist. The Service Provider shall mark personal data if the data subject disputes its correctness or accuracy, but the incorrectness or inaccuracy of the disputed personal data cannot be clearly established.

9.4 Right to erasure
The Service Provider shall delete personal data if its processing is unlawful, the data subject requests it, the processed data is incomplete or incorrect – and this condition cannot be lawfully remedied – provided that deletion is not precluded by law, the purpose of processing has ceased, or the statutory storage period has expired, or if ordered by a court or the National Authority for Data Protection and Freedom of Information.

9.5 Procedural rules
The Data Controller has 30 days to delete, restrict or rectify personal data. If the Data Controller does not fulfil the data subject's request for rectification, restriction or deletion, it shall communicate the reasons for refusal in writing or electronically, with the data subject's consent, within 30 days. The Service Provider shall notify the data subject and all persons to whom the data was previously transmitted for processing purposes of the rectification, restriction, marking and deletion. Notification may be omitted if, in view of the purpose of processing, this does not infringe the legitimate interests of the data subject.

9.6 Objection
The data subject may object to the processing of their personal data if

a) the processing or transfer of personal data is necessary solely for the fulfilment of a legal obligation applicable to the Data Controller or for the enforcement of the legitimate interests of the Data Controller, data recipient or third party, unless the processing is ordered by law;

b) in other cases specified by law.

The Service Provider shall examine the objection as soon as possible after submission of the request, but no later than within 15 days, decide on its merits and inform the applicant of its decision in writing. If the Data Controller determines that the data subject's objection is justified, it shall terminate the processing – including further collection and transfer of data – and restrict the data, and shall notify all persons to whom the personal data concerned by the objection was previously transferred of the objection and the measures taken on the basis thereof; these persons shall take action to enforce the right to object.

If the data subject does not agree with the decision made by the Data Controller, they may bring the matter before a court within 30 days of notification of the decision.

The Service Provider may not delete the data of the data subject if processing is ordered by law. However, the data may not be transferred to the data recipient if the Data Controller has agreed with the objection or if the court has established that the objection was justified.

9.7 Right to data portability
Where data processing takes place by automated means, or where data processing is based on the data subject's voluntary consent, the data subject has the right to request the Data Controller to provide the data supplied by the data subject to the Data Controller. The Data Controller shall make the data available to the data subject in XML, JSON or CSV format, where technically feasible, and the data subject may request that the Data Controller transmit the data in this format to another data controller.

9.8 Compensation and non-material damages
The Service Provider shall compensate any damage caused to another person by the unlawful processing of the data subject's data or by a breach of data security requirements. In the event of infringement of the data subject's personality rights, the data subject may claim compensation for non-material damages (Section 2:52 of the Civil Code). The Data Controller is also liable to the data subject for damage caused by the data processor. The Data Controller shall be exempt from liability if the damage was caused by an unavoidable cause outside the scope of data processing.

The Data Controller shall not compensate the damage or pay compensation for non-material damages to the extent that the damage or infringement of personality rights was caused by the intentional or grossly negligent conduct of the injured party or data subject.

9.9 Right to take legal action
The data subject may bring an action against the Data Controller before a court in the event of infringement of their rights. The court shall proceed with the case as a priority.

9.10 Complaint
A complaint may be lodged with the National Authority for Data Protection and Freedom of Information:

Name: National Authority for Data Protection and Freedom of Information
Registered office: 1125 Budapest, Szilágyi Erzsébet fasor 22/C.
Postal address: 1530 Budapest, Pf.: 5.
Telephone: +361/391-1400
Fax: +361/391-1410
Email: ugyfelszolgalat@naih.hu
Website: http://www.naih.hu

10. Data Security

The Service Provider plans and carries out data processing operations in such a way as to ensure the protection of the privacy of data subjects.

The Service Provider and, within their activities, the data processor ensure the security of the data, take the technical and organisational measures and establish the procedural rules necessary to enforce the provisions of the Infotv. and other data and confidentiality protection regulations.

The Service Provider protects the data through appropriate measures, in particular against unauthorised access, alteration, transmission, disclosure, deletion or destruction, accidental destruction or damage, and becoming inaccessible due to changes in the technology used.

During data processing, the Service Provider maintains:
• confidentiality: protecting information so that only those who are authorised can access it
• integrity: protecting the accuracy and completeness of the information and the processing method
• availability: ensuring that when an authorised user needs the information, they can actually access the required information and that the related resources are available.

The IT systems and networks of the Service Provider and its partners involved in data processing are protected against computer-assisted fraud, espionage, sabotage, vandalism, fire and flood, as well as computer viruses, computer intrusions and denial-of-service attacks. The operator ensures security through server-level and application-level protection procedures.

11. Applicable Legislation Used for This Privacy Policy

• Act CXII of 2011 – on informational self-determination and freedom of information (Infotv.)
• Act V of 2013 – on the Civil Code (Ptk.)
• Act CLV of 1997 – on consumer protection (Fgytv.)
• Act XIX of 1998 – on criminal proceedings (Be.)
• Act CVIII of 2001 – on certain issues relating to electronic commerce services and information society services (Eker. Act)
• Act C of 2003 – on electronic communications (Eht.)
• Act XLVIII of 2008 – on the basic conditions and certain limitations of economic advertising activities (Grt.)
• Recommendation of the National Authority for Data Protection and Freedom of Information on data protection requirements for prior information
• GDPR, Regulation (EU) 2016/679 of the European Parliament and of the Council, on the processing and protection of personal data of natural persons and on the free movement of such data

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