Privacy notice

PRIVACY NOTICE FOR ALFOLDITEJ.HU WEBSITE

in which we inform you, as the user of our website and our services, on the data processing and data protection regulations of our Company.
1. What are the principles of data processing?
During data processing, our Company observes the following principles:

  1. personal data are processed lawfully, fairly and in a transparent manner in relation to you.
  2. personal data are collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
  3. the personal data collected and processed by us are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
  4. every reasonable step is taken by our Company to ensure that personal data are accurate and, where necessary, kept up to date, and that the personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
  5. personal data are kept in a form which permits your identification for no longer than is necessary for the purposes for which the personal data are processed.
  6. personal data are 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.

Our Company  

  1. processes, i.e. collects, records, structures, stores and uses your personal data on the basis of your freely given, informed consent, to the extent necessary for processing, with purpose limitation.
  2. in certain cases, the processing of your data is based on statutory requirements and is compulsory, in such cases we draw your attention to this.
  3. and in certain cases, your personal data are processed for the legitimate interest of our Company or third parties, e.g. the operation, development and security of our website.
 

2. Who are we?
Pursuant to Article 37 of the GDPR, our Company is not obliged to designate a data protection officer.
Company registration number: 07-09-015671
VAT number: 13044859-2-07
Email address: horvath_melinda@alfolditej.hu
Phone number: 06 22 540 213
Mailing address: 8000, Székesfehérvár, Seregélyesi út 127.
Contact person: Melinda Horváth
Our website: www.alfolditej.hu
Registered seat of the Company: 8000, Székesfehérvár, Seregélyesi út 127.

Name, address and contact details of our host: Y'SOLUTIONS PRG Informatikai Korlátolt Felelősségű Társaság (2463 Tordas, Szabadság út 2/B, Company registration number: 07-09-024852, VAT number: 13821191-2-07, represented by: Gábor Tóth)
For processing the data, our Company employs the following data processors for providing quality services to our customers:


 
NAME

 
ADDRESS

 
ACTIVITY

Y'SOLUTIONS PRG Informatikai Kft.

2463 Tordas, Szabadság út 2/B.

IT service

Y'SOLUTIONS PRG Informatikai Kft.

2463 Tordas, Szabadság út 2/B.

host service

Publicity Aim Kft.

1095 Budapest, Mester u. 83/C. 205.

database maintenance and processing, preparing reports

 
Data processors of our newsletter service:


 
NAME

 
ADDRESS

 
ACTIVITY

Y'SOLUTIONS PRG Informatikai Kft.

2463 Tordas, Szabadság út 2/B.

IT service

Y'SOLUTIONS PRG Informatikai Kft.

2463 Tordas, Szabadság út 2/B.

host service

Publicity Aim Kft.

1095 Budapest, Mester u. 83/C. 205.

database maintenance and processing, preparing reports

 
If we modify our data processors, we will amend this notice.
The data processed by us: 


Activity and purpose of processing

Legal basis

Processed data

Term

Registration number

Visiting the website
The purpose is to ensure the proper and high quality operation of the website, to check and improve the quality of our services, to identify malicious visitors attacking our website, to measure the number of visitors, statistical purposes

Legitimate interest of our Company

IP address
time of the visit
data of the visited pages,
the operating system and browser type used by you

6 months

 

Creating account on the website
The purpose is to provide a comprehensive user experience, to provide information on outages, on the changes of our contact details, etc.

consent

email address

until deleting the account, or revoking the consent

 

Newsletter service
Purpose: communication, providing information on new promotions, new products

consent

email address

until unsubscribing from the newsletter

 

Administration, complaints
providing replies to comments, complaints

legal obligation

  • full name
  • email address
  • mailing address
  • other personal message
  • for 5 years
 

 
We only request our visitors to provide their personal data if they wish to sign up, sign in or to participate in prize games.
We do not connect the personal data provided during signing up and using our marketing services, and the identification of our visitors is not our goal.
If you have any questions concerning data processing, please request further information by writing to krausz_viktoria@alfolditej.hu email address or to our mailing address. We will provide our reply as soon as possible, within 28 days (but within 1 month at the latest) to the address indicated by you. 
3. What are cookies and how do we manage them?
Cookies are small text files (hereinafter: cookies) that are stored on your computer by using the website so that your internet browser saves and stores them. The majority of the most frequently used internet browsers (Chrome, Firefox, etc.) accepts and allows the downloading and using of cookies by default, but you may opt to refuse or disable these by modifying the browser settings, and you also have the possibility to delete the cookies stored on your computer. The “help” menu of the browsers provide more information on using the cookies.
There are cookies that don’t require your prior consent. Our website provides information on the cookies upon commencing your first visit to our website. Such cookies are authentication, multimedia player, load balancing and other session cookies enhancing the tailoring of the user interface, and the security cookies focusing on the users.
Our Company informs you on the cookies requiring consent at the beginning of your first visit – if data processing starts as soon as you visit the page – and we request your consent.
Our Company does not use and permit cookies allowing third parties to collect data from you without your consent.
It is not obligatory to accept cookies, but our Company shall not be held liable for the improper operation of our website due to the lack of allowing cookies.
 

 

What kind of cookies do we use?


Type

Name

Consent

Description

Purpose

Validity

system cookies

 

not required

session cookies of the firewall of the internet application, aiming to prevent abuse against cross-references

ensuring the operation of the website

end of browser  session

tracking cookies
(third-party cookies)

Google
Analytics

 
 
required

identification of new sessions and visitors, saved by Google Analytics tracking service

related to the services of third parties (e.g. Google) during visiting the website

 
1-5
line tagging

tracking cookies
(third party cookies)

_ga

required

aims to identify the users

related to the services of third parties (e.g. Google) during visiting the website

2 years

tracking cookies
(third party cookies)

_gid

required

aims to identify the users

related to the services of third parties (e.g. Google) during visiting the website

24 hours

tracking cookies
(third party cookies)

_gat

required

used for decreasing the rate of queries. If the Google Analytics application is installed via Google tag manager, this cookie is _dc_gtm_ .

related to the services of third parties (e.g. Google) during visiting the website

1 minute

tracking cookies
(third party cookies)

AMP_
TOKEN

required

This can be used by the client to obtain ID from AMP Client ID service. Other possible values refer to requests arriving after leaving, or to the error of obtaining/identifying/retrieving client ID.

related to the services of third parties (e.g. Google) during visiting the website

30 sec-1 year

tracking cookies
(third party cookies)

_gac_

required

Contains campaign-related information for the user. If Google Analytics and Google AD accounts are connected, then the conversion tags of GA will read/identify this cookies, if it is not emitted.

related to the services of third parties (e.g. Google) during visiting the website

90 days

tracking cookies
(third party cookies)

Facebook

required

identification of new sessions and visitors, saved by Facebook tracking service

related to the services of third parties (e.g. Facebook, Instagram) during visiting the website

 
 
180 days

 
Please find further information on third party cookies here: https://www.google.com/policies/technologies/types/, and on data protection here: https://www.google.com/analytics/learn/privacy.html?hl=hu.
4. Further information on data processing related to our website
You provide us with your personal data voluntarily during sign-up and communication with our Company, and therefore, we request you to pay attention to the correctness and accuracy of such data, because it is your responsibility to provide accurate data. Inaccurate, incorrect or missing data may hinder the use of our services.
If you do not provide your own personal data but those of another person, then we suppose that you hold the relevant authorisation.
You are free to revoke your consent to data processing anytime

  • by deleting your account,
  • by withdrawing the consent to data processing, and
  • by withdrawing the consent to process or use any data required for signing up, or by requesting the blocking of any data.

For technical reasons, we record the withdrawal of consent with a deadline of 30 days, but we draw your attention to the fact that for the fulfilment of our legal obligations or for the enforcement of our legitimate interests, we may continue processing certain data even after the consent is withdrawn.
In case of using deceptive personal data, or if any visitor commits a crime, or attacks the system of our Company, then we delete the account and the details of the given visitor without delay, and, if needed, we keep those for establishing civil liability and during the criminal proceedings.
5. Further information on data processing for direct marketing and newsletter purposes
In your statement made during signing up or later, by modifying your personal data stored by signing up for newsletter and/or direct marketing (i.e. by clearly declaring your consent) you may give your consent to the use of your personal data for marketing purposes. In such case – until withdrawing your consent – we process your data for direct marketing purposes and/or for sending newsletters, and we send you advertising and other materials, notices, offers and/or newsletters (Section 6 of the Act on Advertising Activities).
For technical reasons, we record the withdrawal of consents with a deadline of 30 days.
6. Further information on prize games
Our Company may organise campaign-type prize games, the terms and conditions of which are contained in separate regulations.
7. Other data processing issues
We may only transfer your personal data in accordance with the legal regulations, and in case of our data processors, we stipulate contractual clauses for preventing the use of your personal data for purposes other than those detailed in your consent. Please find more information in Section 2.
Our Company does not transfer data abroad.
Courts, public prosecutions and other authorities (e.g. police, tax administration, National Authority for Data Protection and Freedom of Information) may contact us for providing information, data or documents. In such cases, we have to fulfil our data supply obligations, but only to the extent necessary for the purposes of the request.
The operators and employees of our Company participating in data processing and control are entitled to know your personal data to the extent specified in advance, under the obligation of confidentiality.
We protect your personal data with appropriate technical and other measures and we ensure the safety and availability of data, and we protect them against unauthorised access, change, damage, disclosure and any other unauthorised use.
Within the frameworks of organisational measures, we control physical access in our facilities, continuously train our employees and we store the printed documents with proper protection. Within the frameworks of technical measures, we apply encryption, password protection and virus screens. However, we draw your attention to the fact that data transfer on the internet cannot be considered completely safe. Our Company does its best to make its procedures as safe as possible, but we cannot assume liability for transferring data through our website. Concerning the data received by our Company, we comply with strict requirements for protecting the safety of your data and for preventing unauthorised access.
Concerning security, we request you to keep your password safe and to avoid disclosing it to anyone.
8. What are your rights and remedies?
Concerning data processing,

  • you may request information,
  • you may request the rectification, amendment or modification of the personal data processed by us,
  • you may object to the processing and request the deletion or blocking of your data (except for compulsory data processing),
  • you may enforce remedy before the court,
  • you may lodge complaint with the supervisory authority and initiate proceedings (https://naih.hu/panaszuegyintezes-rendje.html).

Supervisory authority: National Authority for Data Protection and Freedom of Information

  • Registered seat: 1125 Budapest, Szilágyi Erzsébet fasor 22/c.
  • Mailing address: 1530 Budapest, Pf.: 5.
  • Phone: +36 (1) 391-1400
  • Fax: +36 (1) 391-1410
  • ugyfelszolgalat@naih.hu
    Website: https://naih.hu/

Upon your request, we provide information on the following data processed by us or by a data processor appointed by us

  • your data,
  • the source of such data,
  • the purpose and legal basis of processing,
  • period of processing, or if this is not possible, on the aspects of establishing such period,
  • the name, address and data processing activities of our data processors,
  • on the circumstances, effects of data breaches and the measures taken for preventing such incidents, and
  • in case of transferring your personal data, the legal basis and addressees of the transfer.

We provide information as soon as possible after receiving the request, within 28 days (but within 1 month at the latest). The information is free of charge, except if in the given year, you have already submitted an information request for the same data. We will reimburse the costs paid by you if we processed the data unlawfully or if the information request resulted in rectification. We may only refuse providing information in the cases specified by law by indicating the relevant provision, and by providing information on the possibilities of court remedy or authority consultation.
Our Company informs you on the rectification, blocking, indication and deletion of the personal data, together with the parties to whom the data were transferred for the purposes of data processing, except if the lack of notification does not violate your legitimate interests.
If we do not fulfil your request concerning the rectification, blocking or deletion, we will inform you on the reasons of the refusal in writing, or with your consent, electronically within 28 days following the receipt of the request (but within 1 month at the latest), and we provide information on the possibilities of court remedy or authority consultation.
If you object to the processing of your personal data, we will assess your objection as soon as possible following the receipt of the objection, within 28 days following the receipt of the request (but within 1 month at the latest) and we will inform you on our decision in writing. If we decide that your objection is justified, we will terminate the data processing – including the further recording and transfer of data – and we will block the data. We will inform on the objection and the related measures all parties to whom the personal data subject to the objection were transferred, and they shall also take measures for enforcing the right to object.
We will refuse the fulfilment of the request if we can prove that the processing is required for compelling legitimate purposes that override your interests, rights and freedoms, or if the processing is necessary for the establishment, exercise or defence of legal claims. If you do not agree with our decision, or if we have missed the deadline, you may turn to court within 30 days following the communication of the decision or the last day of the deadline.
Data protection lawsuits are assessed by the courts, and the data subject may decide to initiate the lawsuit at the court competent at the data subject’s residence or place of stay. Foreign citizens may also lodge their complaints with the supervisory authority competent at their residence.
We kindly request you to contact our Company before lodging a complaint with the supervisory authority or the court for consulting with us and for resolving the problem as soon as possible.
9. What are the major relevant legal regulations governing our activities?

  • Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data (GDPR)
  • Act CXII of 2011 on informational self-determination and freedom of information (Privacy Act)
  • Act V of 2013 on the Civil Code (Civil Code)
  • Act CVIII of 2001 on certain issues of electronic commerce services and information society services (Act on Electronic Commerce)
  • Act C of 2003 on Electronic Communication - (Electronic Communication Act)
  • Act CLV of 1997 on Consumer Protection (Consumer Protection Act)
  • Act CLXV of 2013 on Complaints and Public Interest Disclosures (Complaints Act)
  • Act XLVIII of 2008 on Essential Conditions of and Certain Limitations to Business Advertising (Business Advertising Act)

 10. Amendment of the data privacy notice
 
Our Company reserves the right to amend this Privacy Notice, and we will provide proper information to the concerned parties. Information related to data processing will be published on the website www.alfolditej.hu/Adatvedelem.
 
28.02.2021