Information on data processing
on the website of Győr Projekt Kft.
1. The purpose of this Policy
Győr Projekt Kft. (address: H-9025 Győr, Radnóti Miklós u 46.) Hereinafter: Company / as data controller processes data in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter referred to as GDPR). The purpose of this notice is to inform visitors and customers registering on the website of the Company on the scope of data processed by the Company during its operating the web-shop and other, processing-related activities. The terms in this Notice are identical to those defined in Regulation (EU) 2016/679 (hereinafter referred to as GDPR).
2. 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’ means 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
· ‘restriction of processing’ means the marking of stored personal data with the aim of limiting their processing in the future;
· ‘profiling’ means 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;
· ‘pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;
· ‘filing system’ means any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis 7. ‘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; 8. ‘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;
· ‘third party’ means 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;
· ‘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;
· ‘genetic data’ means personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person and which result, in particular, from an analysis of a biological sample from the natural person in question;
· ‘biometric data’ means personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images or dactyloscopic data;
· ‘data concerning health’ means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status;
· ‘main establishment’ means: (a) as regards a controller with establishments in more than one Member State, the place of its central administration in the Union, unless the decisions on the purposes and means of the processing of personal data are taken in another establishment of the controller in the Union and the latter establishment has the power to have such decisions implemented, in which case the establishment having taken such decisions is to be considered to be the main establishment; (b) as regards a processor with establishments in more than one Member State, the place of its central administration in the Union, or, if the processor has no central administration in the Union, the establishment of the processor in the Union where the main processing activities in the context of the activities of an establishment of the processor take place to the extent that the processor is subject to specific obligations under this Regulation;
· ‘representative’ means a natural or legal person established in the Union who, designated by the controller or processor in writing pursuant to Article 27, represents the controller or processor with regard to their respective obligations under this Regulation;
· ‘enterprise’ means a natural or legal person engaged in an economic activity, irrespective of its legal form, including partnerships or associations regularly engaged in an economic activity;
· ‘group of undertakings’ means a controlling undertaking and its controlled undertakings;
· ‘binding corporate rules’ means personal data protection policies which are adhered to by a controller or processor established on the territory of a Member State for transfers or a set of transfers of personal data to a controller or processor in one or more third countries within a group of undertakings, or group of enterprises engaged in a joint economic activity;
· ‘supervisory authority’ means an independent public authority which is established by a Member State pursuant to Article 51;
· ‘supervisory authority concerned’ means a supervisory authority which is concerned by the processing of personal data because: (a) the controller or processor is established on the territory of the Member State of that supervisory authority; (b) data subjects residing in the Member State of that supervisory authority are substantially affected or likely to be substantially affected by the processing; or (c) a complaint has been lodged with that supervisory authority;
· ‘cross-border processing’ means either: (a) processing of personal data which takes place in the context of the activities of establishments in more than one Member State of a controller or processor in the Union where the controller or processor is established in more than one Member State; or (b) processing of personal data which takes place in the context of the activities of a single establishment of a controller or processor in the Union but which substantially affects or is likely to substantially affect data subjects in more than one Member State;
· ‘relevant and reasoned objection’ means an objection to a draft decision as to whether there is an infringement of this Regulation, or whether envisaged action in relation to the controller or processor complies with this Regulation, which clearly demonstrates the significance of the risks posed by the draft decision as regards the fundamental rights and freedoms of data subjects and, where applicable, the free flow of personal data within the Union;
· ‘information society service’ means a service as defined in point (b) of Article 1(1) of Directive (EU) 2015/1535 of the European Parliament and of the Council (1);
· ‘international organisation’ means an organisation and its subordinate bodies governed by public international law, or any other body which is set up by, or on the basis of, an agreement between two or more countries.
3. Principles relating to processing of personal data:
The Company shall process personal data in a lawful, fair, purpose-limited, data-minimised, accurate, storage-limited, confidential and accountable manner that is transparent to the data subject.
Personal data shall be:
· collected for specified, explicit and legitimate purposes
· processed in a manner compatible with these purposes
· must be adequate and relevant
· and limited to what is necessary
· accurate and, where necessary, kept up to date
· 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;
· 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 measure
Processing on the websites:
4. Operation of the Győr-Card Tourist card:
Collection and the purpose of processing: The Company operates a tourist card system with a purpose to provide natural persons and their family members living in the same household, or legal persons with individual discounts, custom offers and direct information on the current offers, special offers related to the GyőrCard tourist card systems.
Data subjects: Visitors, customers requesting a GyőrCard tourist card
Processed data: In case of natural persons: Date, time, surname, first name, email address In case of legal persons: Company name, registered seat, tax number, email address
Legal basis for the processing: Article 6(1)(a) of Regulation (EU) 2016/679 and Paragraph (5) of Section 6 of Act XLVIII of 2008 on Business Advertising Activity for subscriptions to newsletters
Duration of the processing: If a request of erasure is received, personal data not subject to any legal requirement shall be deleted immediately. In case of accounting documents, this duration shall be 8 years, according to Paragraph (2) of Section 169 of Act C of 2000 on Accounting.
The controlling persons authorised to access personal data and recipients of personal data: Persons authorised to represent the Company, salespersons and contacts, Processors, Data Protection Officer
5. Processing of personal data in case of quality issues:
Collection and the purpose of processing: Recording the personal data of persons having quality complaints against the products ordered in the web-shop of the Company, resolution of issues.
Data subjects: Persons having quality complaints against the products purchased.
Processed data: family name, first name, email address, telephone number, billing name, address, tax number
Legal basis for the processing: Section 5 of Act CXII of 2011 on Informational Self-Determination and Freedom of Information, Article 6(1)(c) of Regulation (EU) 2016/679 (GDPR) and Paragraph (7) of Section 17/a of Act CLV of 1997 on Consumer Protection.
Duration of the processing: Pursuant to Section 17/A of Act CLV of 1997, the Controller shall keep the protocol of such issues for a period of 5 years.
The controlling persons authorised to access personal data and recipients of personal data: Persons authorised to represent the Company, employees performing financial functions, Processors, Data Protection Officer
6. Processing or joint processing in the operation of the websites
In operating the web-shop, the Controller shall only involve processors or joint processors who guarantee to perform technical and organisational measures ensuring compliance with the requirements of Regulation (EU) 2016/679 and the protection of the rights of data subjects. In processing and joint processing, the Parties shall divide their liability for fulfilling their obligations, including their responsibilities regarding the exercising of the rights of persons concerned by the processing, in their written agreement.
7. Preparation of visitor statistics, use of the Google Analytics application:
Győr Projekt Kft would like to send cookies to your computer to increase the user experience provided by its websites. Protection of your personal data and informing you of their use are important to us. The information is of informative nature and helps to make the time you spend on our websites more entertaining.
Definition of cookies:
A text file containing a small amount of data and put on your computer when you open a website. Its purpose is to let websites remember what you did during the time you spent on them. The data it stores identify where you have clicked on specific links or sites, logged in with your username or read certain sites on the website, even months or years ago.
There are several types of cookies and, without them, the websites would not operate in the way you have got used to. The websites of Győr Projekt Kft. also use cookies to ensure the best possible user experience, and they apply only the most necessary and most useful cookies.
What types of cookies are there on the websites of Győr Projekt Kft?
Cookies can be either ones that are valid only in a specific workflow or permanent ones, and one should distinguish between cookies of the first party and cookies of third parties. In the following, we explain the meaning of these terms so that you can better understand the cookies we use and the purpose of their use.
Cookies valid in browsing sessions:
Cookies that are valid in the browsing session make your recognition possible if you visit a website so that the browser can remember the alteration or selection of each site. Such cookies make it possible that you go through many pages of a website quickly and easily without identifying yourself or performing the same processes on each and every page you visit. Cookies that are valid in the browsing session are temporary ones and expire as soon as you close your browser or leave the website.
Permanent cookies:
Permanent cookies are the ones that stay “permanently” on your computer for a given period after the browsing session has ended; therefore, they make it possible to remember the preferences or operations of users when they later visit a specific website.
Cookies of the website operator:
These are the cookies that come from the operator of the browsed website.
Third-party cookies:
Cookies can be own (internal) cookies or ones that come from third parties (external). Internal cookies are set by the website you visit, while external cookies are set by somebody else. Győr Projekt Kft. allows the setting of pre-approved cookies only.
The files of Google Analytics are necessary for the monitoring of the site and provide information on its use. We use such information to prepare statistics and to improve the site. The files of Google Analytics store information in an anonymised way, in the form of the number of visitors to the site or the sites visited. Such files are set up by Google Analytics. For further information, please visit the following website: http://www.google.com/analytics. To disable tracking by Google Analytics on all sites, please visit the following website: http://tools.google.com/dlpage/gaoptout.
Enabling cookies:
We place cookies on your computer, telephone or tablet with your approval only. You can give your approval by clicking on the “Elfogadom” (Accept) button of the cookie pop-up window. If you do not want to have the cookies of our website put on your computer, telephone or tablet, you can reject them—even if you first approve of them, you have the option to disable and delete them at any time in the settings of your website browser.
Setting and deleting cookies
If you decide not to use cookies, you can delete them in the cookie folder of your browser. You can set your browser to block cookies or to show a warning message before the downloading of a cookie. You can normally access these settings in the “settings” or “preferences” menu of your browser. If you had further questions, please visit the “All About Cookies” website: http://www.allaboutcookies.org
8. Other rights of data subjects:
· Right of access by the data subject
The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information.
· Right of rectification
The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
· Right of erasure
The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where the conditions set out in Article 17(1) of Regulation (EU) 2016/679:
· Right to be forgotten
Where the controller has made the personal data public and is obliged to erase the personal data, 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 personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
· Right to restriction of processing
The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
· the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
· the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
· the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
· the data subject has objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject.
· Right to data portability
The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent pursuant to Article 6(1)(a) of Regulation (EU) 2016/679 and the processing is carried out by automated means.
· Right to object
The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (a) of Article 6(1) of Regulation (EU) 2016/679, including profiling based on those provisions. The controller shall no longer process the personal data.
· Automated individual decision-making, including profiling
The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
The previous paragraph shall not apply if the decision:
· is necessary for entering into, or performance of, a contract between the data subject and a data controller;
· is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests; or
· is based on the data subject's explicit consent.
9. Deadlines for actions regarding processing on the websites:
The Company shall provide information on the actions it has made at the requests regarding processing within 1 month following the receipt of such requests. This deadline may be extended by 2 months if there are legitimate grounds. Controller shall provide information on the extension of the deadline, specifying the reasons for the delay, within 1 month following the receipt of such the relevant request. If the Controller does not take action at the request of the data subject, then it shall, immediately, but within 1 month following the receipt of such requests at the latest, provide information on the reason for non-action and the process to lodge complaints before the supervisory authority and the court.
10. Security of processing:
Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, the controller and the processor shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:
a) the pseudonymisation and encryption of personal data;
b) the ability to ensure the ongoing confidentiality, integrity, availability and one-on-one resilience of processing systems and services;
c) the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
d) a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.
11. Communication of a personal data breach to the data subject, notification of a personal data breach to the supervisory authority
In the case of a personal data breach, the controller shall without undue delay, but not later than 72 hours, after having become aware of it, notify the personal data breach to the supervisory authority competent, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.
When 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.
12. Legal remedies:
The Controller shall erase personal data if:
· he personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
· the data subject withdraws consent, and where there is no other legal ground for the processing;
· the data subject objects to the processing, and there are no overriding legitimate grounds for the processing.
· the personal data have been unlawfully processed;
· he personal data have to be erased for compliance with a legal obligation;
· personal data are collected to offer information society services to minors under 16.
Persons entitled to erase, modify or limit the processing of personal data:
Csaba Simon, Managing Director, Phone number: +36 20 527 9492 email: gyorprojekt@gyorprojekt.hu
Dr. László Erős, Data Protection Officer, Phone number: 06 30 650 1718 Email: info@dreroslaszlo.hu
Any person concerned by the processing may refer to the following authority in case of any prejudice to his or her or its rights:
National Authority for Data Protection and Freedom of Information: H-1530 Budapest, Szilágyi Erzsébet fasor 22/C
Phone number: +36-1-391-1400
Email: ugyfelszolgalat@naih.hu