Privacy Policy

INTRODUCTION

HungaroSun Bt. (6725 Szeged, Hópárduc utca 4., Headquarters: 6724 Szeged, Ipoly sor 11/b., VAT number: 22303246-2-06) (hereinafter: Service Provider, Data Processor) employs the following privacy statement in regards of the processing of personal data:

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) REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (27th April 2016), we provide the following information.

This privacy statement governs the privacy of the following pages:

https://suncegcsoport.hu

https://hungarosun.hu

https://webbenprojects.hu/inszeged

This privacy statement is available on the following pages:

https://hungarosun.hu/adatvedelem/

https://webbenprojects.hu/inszeged/adatvedelem/

Changes to the Privacy Notice takes into effect by publishing on the above pages.

CONTACT DETAILS OF THE DATA CONTROLLER

Name: HungaroSun Bt.

Address: 6725 Szeged, Hópárduc utca 4

Headquarters: 6724 Szeged, Ipoly sor 11/b

E-mail: info@hungarosun.hu

Phone: +36 20 585 0030

DEFINITIONS

„personal data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
„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;
„controller” means 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;
„processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
„recipient” means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;
„consent” of the data subject means 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;
„personal data breach” means 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.

PRINCIPLES RELATING TO PROCESSING OF PERSONAL DATA

Personal data shall be:
processed lawfully, fairly and in a transparent manner in relation to the data subject („lawfulness, fairness and transparency”);
collected 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”);
adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed („data minimisation”);
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”);
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”);
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, paragraph 1 („accountability”).

DATA TREATMENTS

Contact

Fact of data collection, scope of data processed and purpose of data management:
- Personal data: Surname, First name, Company name, E-mail address, Phone. The purpose of data management: Contact, identification, making it possible to send offers.
- Personal data: Subject of request. The purpose of data management: Optional additional data for creating offers.
- Personal data: Contact time. The purpose of data management: Optional additional data for creating offers.
- Personal data: Message. The purpose of data management: Optional additional data for creating offers.
- Personal data: Any personal data that may be part of the message. The purpose of data management: Optional additional data for creating offers.
- Personal data: Send time of the message. The purpose of data management: Technical processing.
- Personal data: IP adress of the message. The purpose of data management: Technical processing.
Stakeholders: All stakeholders who request offers ont he website.
Duration of data management, deadline for deleting data : It lasts until consent is withdrawn.

In the case of accounting documents, the data must be kept by the data processor for 8 years pursuant to Section 169 (2) of Act C of 2000 on Accounting.

Identity of potential data processors entitled to access the data: Personal data may be processed by the data processor, with respect to the above principles.
Description of the data subject’s rights in relation to data processing:
- The data subject may request from the controller access to, rectification, erasure or restriction of the processing of personal data concerning him or her, and
- may object to the processing of such personal data, and
- the data subject has the right to data portability and to withdraw his or her consent at any time .
- The personal data access, their deletion, modification or limitation management, data portability, protests against the handling of data involved can be initiated in the following ways:
  - via post at the address 6725 Szeged, Hópárduc utca 4.,
  - e-mail via the info@hungarosun.hu, e-mail address,
  - phone to +36 20 585 0030 number.
Legal basis for processing: consent of the data subject, Article 6 (1) (a), Infotv. § 5 (1).

Data processing of business cards

Legal basis for processing: consent of the data subject, (paragraph a) of Article 1.), which is done by the act of the data subject giving their business card, which holds personal data, to the data processor.

The scope of data processed: Name, phone number, address, e-mail address, workplace, workplace address, as well as any other personal data present ont he business cards.
The purpose of data management: To facilitate creating personal contacts.
The provisions of this privacy statement shall be applied when handing over the cards or when processing them
Duration of data management: Until consent is withdrawn, by requesting the destruction of the business card.
Description of the data subject’s rights in relation to data processing:
- The data subject may request from the controller access to, rectification, erasure or restriction of the processing of personal data concerning him or her, and
- may object to the processing of such personal data, and
- the data subject has the right to data portability and to withdraw his or her consent at any time .
The personal data access, their deletion, modification or limitation management, data portability, protests against the handling of data involved can be initiated in the following ways:
- via post at the address 6725 Szeged, Hópárduc utca 4.,
- e-mail via the info@hungarosun.hu, e-mail address,
- phone to +36 20 585 0030 number.

DATA PROCESSORS USED

Hosting provider

Activity of data processor: Hosting provider
Name and contact details of the data processor:

- Name: CHS Electronics Kft
- Headquarters: 6728 Szeged, Hídverő u. 4/A
- Phone: +36 20 442 7837
- Website: www.chsel.hu

Fact of data collection, scope of data processed: All personal data given by the data subject.
Stakeholders: All stakeholders who use the website.
Purpose of data processing: Making the website available and operating properly.
Duration of data management, deadline for deleting data: Until the agreement between the webhosting provider and the data processor expires, or until the data subject signals the hosting provider about withdrawal of consent.
Legal basis for processing: Consent of the data subject, Article 6 (1) (a), Infotv. § 5 (1), and Act CVIII of 2001 on certain issues of electronic commerce services and information society services. Act 13 / A. § (3).

MANAGEMENT OF COOKIES

Fact of data collection, scope of data processed: Unique identifier, dates and time stamps
Stakeholders: All stakeholders who use the website.
Purpose of data processing: Identification of users and tracking of visitors.
Duration of data management, deadline for deleting data:

- Cookie type: Session cookie
- Legal basis for processing: Act CVIII of 2001 (Elker Act) on certain issues of electronic commerce services and information society services. Act 13 / A. § (3)
- Duration of data management: Until the closing of the relevant visitor session
- Scope of data: connect.sid

Cookies used explicitly for the operation of the website and for tasks related to the hosting process: CONSENT, PHPSESSID. These transient session cookies contain random string identifiers for the session. These help the website to identify and to remember You, and Your settings, while you browse the website.
Identity of potential data processors entitled to access the data: The data processor is not handling and personal data when using cookies.
Description of the data subject’s rights in relation to data processing: The data subjects have the opportunity to delete the cookies from their web browsers Tools/Settings usually under the Privacy and Security option.
Legal basis for processing: The data subject’s consent is not required if the sole purpose of the use of cookies is the transmission of communications via an electronic communications network or the provision of an information society service specifically requested by the subscriber or user.

USAGE OF GOOGLE ANALYTICS

This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses so-called “cookies”, text files that are saved on your computer and thus help user analysis by using Web pages visited.
The information generated by the cookies associated with the website used by you will normally be stored and stored on a Google server in the USA. By activating IP anonymisation on the Website, Google will shorten the User’s IP address within the Member States of the European Union or in other States party to the Agreement on the European Economic Area.
The full IP address will only be transmitted to and truncated to Google’s server in the U.S. 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 provide the website operator with reports on website activity and to provide additional services related to website and internet usage.
Google Analytics does not match the IP address provided by the User’s browser with other Google data. The User may prevent the storage of cookies by setting the appropriate browser, however, please note that in this case, not all functions of this website may be fully available. You may also prevent Google from collecting and processing your information (including your IP address) about your use of the Website by cookies by downloading and installing the browser plugin available at the following link. https://tools.google.com/dlpage/gaoptout?hl=hu

CUSTOMER RELATIONS AND OTHER DATA MANAGEMENT

Should the data controller have any questions or problems during the use of our data management services, he or she may contact the data controller in the ways provided on the website (telephone, e-mail, social networking sites, etc.).
Data manager for incoming emails, messages, phone, Facebook, etc. will delete the data provided together with the name and e-mail address of the interested party, as well as any other personal data voluntarily provided, no later than 2 years after the communication .
Information on data processing not listed in this prospectus is provided at the time of data collection.
Upon exceptional official request, or in case of contacting other bodies based on the authorization of legislation, the Service Provider is obliged to provide information, communicate and hand over data, and make documents available.
In these cases, the Service Provider will provide the requester with personal data only to the extent and to the extent that is absolutely necessary to achieve the purpose of the request, provided that it has indicated the exact purpose and scope of the data.

RIGHTS OF DATA SUBJECTS

Right of access

You have the right to receive feedback from the controller as to whether your personal data is being processed and, if such processing is in progress, you have the right to access your personal data and the information listed in the Regulation.

Right to rectification

You have the right, at the request of the data controller , to correct inaccurate personal data concerning you without undue delay . Taking into account the purpose of the data processing, you have the right to request that the incomplete personal data be supplemented, inter alia, by means of a supplementary statement.

Right of cancellation

You have the right, at the request of the controller, to delete personal data concerning you without undue delay , and the controller is obliged to delete personal data concerning you without undue delay under certain conditions.

The right to forget

If the controller has disclosed the personal data and is obliged to delete it, it shall take reasonable steps, including technical measures, taking into account the available technology and the costs of implementation, to inform the controllers that you have requested the personal data in question. deleting links or copies or duplicates of such personal data.

Right to restrict data processing

You have the right, at the request of the controller, to restrict the processing of data if one of the following conditions is met:

- You dispute the accuracy of personal data, in which case the restriction applies to the period of time that allows the data controller to verify the accuracy of the personal data;
- the processing is unlawful and you oppose the deletion of the data and instead ask for a restriction on its use;
- the data controller no longer needs the personal data for the purpose of data processing, but you require them to make, enforce or protect legal claims;
- You objected to the data processing; in this case, the restriction applies for as long as it is established whether the legitimate reasons of the controller take precedence over your legitimate reasons.

The right to data portability

You are entitled to you about, you articulate your personal data provided to a controller’s disposal, receive widely used in machine-readable format and is entitled to this information forward without another controller that this would hamper the controller, which provided personal data to him (…)

Right to protest

You have the right to object at any time to the processing of your personal data (…), including profiling based on these provisions, for reasons related to your own situation.

Protest in case of direct business acquisition

If personal data is processed for the purpose of direct business acquisition, you have the right to object at any time to the processing of personal data concerning you for this purpose, including profiling, insofar as it relates to direct business acquisition. If you object to the processing of personal data for the purpose of direct business acquisition, the personal data may no longer be processed for this purpose.

Automated decision making in individual cases, including profiling

You are entitled not to extend to you of only automated data management – including profiling as well – a decision based on the scope of that effect on him or her would likewise significantly affected.

The preceding paragraph shall not apply if the decision:

- Necessary for the conclusion or performance of a contract between you and the data controller;
- is governed by EU or Member State law applicable to the controller, which also lays down appropriate measures to protect your rights and freedoms and legitimate interests; obsession
- It is based on your express consent.

DEADLINE FOR ACTION

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

If necessary, it can be extended by 2 months . The data controller shall inform you of the extension of the deadline, indicating the reasons for the delay, within 1 month from the receipt of the request .

If the controller does not take action on your request , it shall inform you without delay, but no later than one month after receipt of the request, of the reasons for the non-action and of the fact that you can lodge a complaint with a supervisory authority and have a judicial remedy.

SECURITY OF DATA MANAGEMENT

The controller and the processor shall take appropriate technical and organizational measures to take account of the state of science and technology and the costs of implementation, as well as the nature, scope, circumstances and purposes of the processing and the varying likelihood and severity of the risk to individuals’ rights and freedoms. to guarantee a level of data security appropriate to the degree of risk, including, inter alia, where appropriate:

the aliasing and encryption of personal data;
ensuring the continued confidentiality, integrity, availability and resilience of the systems and services used to process personal data;
in the event of a physical or technical incident, the ability to restore access to and availability of personal data in a timely manner;
a procedure for regular testing, assessment and evaluation of the effectiveness of the technical and organizational measures taken to ensure the security of data processing.

INFORMING THE DATA SUBJECT ABOUT THE DATA PROTECTION INCIDENT

If the data protection incident is likely to pose a high risk to the rights and freedoms of natural persons, the controller shall inform the data subject of the data protection incident without undue delay.

The information provided to the data subject shall clearly and intelligibly describe the nature of the data protection incident and the name and contact details of the data protection officer or other contact person providing further information; the likely consequences of the data protection incident must be described; a description of the measures taken or planned by the controller to remedy the data protection incident, including, where appropriate, measures to mitigate any adverse consequences arising from the data protection incident.

The data subject need not be informed if any of the following conditions are met:

the controller has implemented appropriate technical and organizational protection measures and these measures have been applied to the data affected by the data protection incident, in particular those measures, such as the use of encryption, which make it incomprehensible to persons not authorized to access personal data; data;
the controller has taken further measures following the data protection incident to ensure that the high risk to the data subject’s rights and freedoms is no longer likely to materialize ;
information would require a disproportionate effort . In such cases, data subjects shall be informed through publicly available information or a similar measure shall be taken to ensure that data subjects are informed in an equally effective manner.

If the controller has not yet notified the data subject of the data protection incident, the supervisory authority may, after considering whether the data protection incident is likely to involve a high risk, order that the data subject be informed .

REPORT A PRIVACY INCIDENT TO THE AUTHORITY

The data protection incident shall be reported by the controller to the supervisory authority competent under Article 55 without undue delay and, if possible, no later than 72 hours after becoming aware of the data protection incident, unless the data protection incident is not likely to jeopardize the rights of individuals. and freedoms. If the notification is not made within 72 hours, the reasons for the delay must be provided.

Complaints against possible breaches of the data controller can be lodged with the National Data Protection and Freedom of Information Authority:

National Data Protection and Freedom of Information Authority

1125 Budapest, Szilágyi Erzsébet fasor 22 / C.

Mailing address: 1530 Budapest, Mailbox: 5.

Phone: +36 -1-391-1400

Fax: + 36-1-391-1410

E-mail: ugyfelszolgalat@naih.hu

CLOSING REMARKS

During the preparation of the prospectus, we took into account the following legislation:

The protection and the free movement of such data and Regulation 95/46 / EC and repealing (General Data Protection Regulation) natural persons in the handling of personal data THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (EU) 2016/679 REGULATION (2016th April 27)
2011 CXII. Act – on the right to information self-determination and freedom of information (hereinafter: Infotv.)
CVIII of 2001 Act – on certain issues of electronic commerce services and services related to the information society (especially Section 13 / A)
XLVII of 2008 Act on the Prohibition of Unfair Commercial Practices against Consumers;
XLVIII of 2008 Act – on the basic conditions and certain restrictions of commercial advertising (especially § 6)
2005 XC. Electronic Freedom of Information Act
Act C of 2003 on Electronic Communications (specifically § 155)
16/2011. s. Opinion on the EASA / IAB Recommendation on Best Practices for Behavioral Online Advertising
Recommendation of the National Authority for Data Protection and Freedom of Information on data protection requirements for prior information

Modern