Privacy policy

Last updated: 19.03.2025

 Privacy Notice

Introduction

The Farkas Anett ev. (florm.eu) (1335 Budapest, Tahi utca 53-57. 4th floor, 6a., tax number: 904807731141, company registration number: 59677042 ) (hereinafter: Service Provider, data controller) submits itself to the following policy:

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 policy governs the data processing of the following websites/mobile applications: Florm.eu The privacy policy is available at the following page: Florm.eu/policies/privacy-policy

Amendments to this policy take effect upon publication at the address above.

The data controller and its contact details

Name: Farkas Anett ev. (florm.eu)

Registered seat: 1335 Budapest, Tahi utca 53-57. 4th floor, 6a.

Correspondence address, complaint handling: 1335 Budapest, Tahi utca 53-57. 4th floor, 6a.

email  hello@florm.eu

phone +36 20 436 0836

Definitions

1. "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;
   
2. "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;
   
3. "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;

1. "processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
   
2. "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. 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;
   
3. "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;
   
4. "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 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");

1. 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");
   
2. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed ("data minimisation");
   
3. 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");
   
4. 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");
   
5. 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 is responsible for, and must be able to demonstrate compliance with, the above ("accountability").

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

Data processing related to operating the webshop / using the service

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

Personal data	Purpose of processing	Legal basis
Username	Identification, enabling registration.	Article 6(1)(b) GDPR and Section 13/A(3) of Act CVIII of 2001 on E-Commerce Services (the "E-Commerce Act").
Password	Enables secure login to the user account.
Last and first name	Necessary for contact, purchase, issuing a proper invoice, and exercising the right of withdrawal.
Email address	Communication.
Phone number	Communication, more effective coordination of billing- or shipping-related questions.
Billing name and address	Issuing a proper invoice, as well as establishing, defining the content of, amending and monitoring performance of the contract, invoicing the resulting fees, and enforcing related claims.	Article 6(1)(c) GDPR, and Section 169(2) of Act C of 2000 on Accounting.
Shipping name and address	Enabling home delivery.	Article 6(1)(b) GDPR and Section 13/A(3) of the E-Commerce Act.
Date/time of purchase/registration	Performing a technical operation.
IP address at the time of purchase/registration	Performing a technical operation.

1. Scope of data subjects: all data subjects registered on / purchasing from the webshop website. Neither the username nor the email address needs to contain personal data.
2. Duration of processing, deadline for erasure: If any of the conditions set out in Article 17(1) GDPR are met, processing continues until the data subject's erasure request. The controller will notify the data subject electronically of the erasure of any personal data provided by the data subject, pursuant to Article 19 GDPR. If the data subject's erasure request also covers the email address provided, the controller will also erase the email address after providing this notification. This does not apply to accounting records, since these must be retained for 8 years pursuant to Section 169(2) of Act C of 2000 on Accounting. The data subject's contractual data may be erased, upon the data subject's erasure request, once the civil-law limitation period has expired.

Accounting documents that directly and indirectly support bookkeeping entries (including general ledger accounts, as well as analytical and detailed records) must be kept in a legible form, retrievable by reference to the accounting entries, for at least 8 years.

1. Persons who may act as data controller with access to the data, recipients of the personal data: The personal data may be processed by the data controller and its authorised staff, in compliance with the principles above.
2. Description of the data subjects' rights relating to data processing:

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

1. The data subject may initiate access to, erasure, modification or restriction of processing of personal data, or data portability, in the following ways:
   • by post, at 1135 Budapest, Tahi utca 53-57,
     
   • by email, at  hello@florm.hu,
   • by phone, at +36 20 436-0836.

 

1. Legal basis of processing:

1. Article 6(1)(b) and (c) GDPR,
   
   
2. Section 13/A(3) of Act CVIII of 2001 on certain aspects of electronic commerce services and information society services (hereinafter: the E-Commerce Act):
   
   
1. The service provider may process personal data that is technically indispensable for providing the service, for the purpose of providing the service. Where other conditions are equal, the service provider must select and, in every case, operate the tools used in providing the information society service in such a way that personal data is processed only if this is strictly necessary for providing the service and for achieving the other purposes set out in this Act, and even then only to the necessary extent and for the necessary duration.
   
   
3.  For issuing invoices compliant with accounting legislation, Article 6(1)(c).
   
   
4. For the enforcement of claims arising from the contract, a 5-year period pursuant to Section 6:22 of Act V of 2013 on the Civil Code.
   
   
1. Section 6:22 [Limitation]

(1) Unless this Act provides otherwise, claims become time-barred after five years.

(2) The limitation period begins when the claim becomes due.

(3) An agreement changing the limitation period must be made in writing.

(4) An agreement excluding limitation is void.

 

1. Please be informed that:

the processing is necessary for the performance of the contract and for providing a quote.

• you are required to provide the personal data so that we can fulfil your order.
• failure to provide the data means that we will not be able to process your order.

Use of cookies

1. Prior consent from data subjects is not required for the use of so-called "password-protected session cookies", "shopping-cart cookies", "security cookies", "strictly necessary cookies", "functional cookies", and "cookies responsible for managing website statistics".
   
   
2. The fact of processing, the scope of data processed:
   Unique identifier, dates, times
   
   
3. Scope of data subjects:
   All data subjects visiting the website.
4. Purpose of processing:
   Identifying users and tracking visitors.
5. Duration of processing, deadline for erasure of data:
   
   
   

Data processing
Type of cookie	Legal basis	Duration
Session cookies	Section 13/A(3) of Act CVIII of 2001 on certain aspects of electronic commerce services and information society services (E-Commerce Act)	Until the end of the relevant visitor session
Persistent or saved cookies	Section 13/A(3) of Act CVIII of 2001 on certain aspects of electronic commerce services and information society services (E-Commerce Act)	Until deleted by the data subject
Statistical, marketing cookies	Section 13/A(3) of Act CVIII of 2001 on certain aspects of electronic commerce services and information society services (E-Commerce Act)	1 month - 2 years

1. Persons who may act as data controller with access to the data:
   The controller does not process personal data through the use of cookies.
   
   
2. Description of the data subjects' rights relating to data processing:
   Data subjects may delete cookies via their browser's Tools/Settings menu, generally under the Privacy section.
   
   
3. Legal basis of processing:
   Consent from the data subject is not required where the sole purpose of using cookies is to carry out the transmission of a communication over an electronic communications network, or where it is strictly necessary for the service provider to provide an information society service explicitly requested by the subscriber or user.
   
   
4. Most browsers used by our users allow the setting of which cookies should 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, mean that our website can no longer be used in full. Here you can find information on how to customise cookie settings for common browsers:

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

Internet Explorer (https://support.microsoft.com/hu-hu/help/17442/windows-internet-explorer-delete-manage-cookies)

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 program called "Google Ads" and, within it, makes use of 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 via a Google ad, a cookie required for conversion tracking is placed on their computer. These cookies have limited validity and 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 ad.
   
   
4. Each Google Ads customer receives a different cookie, so these cookies cannot be tracked across the websites of Ads customers.
   
   
5. The information obtained using conversion tracking cookies is used to generate conversion statistics for Ads customers who have opted for conversion tracking. Customers are informed of the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that would allow them to identify any individual user.
   
   
6. If you do not wish to participate in conversion tracking, you can opt out by disabling cookie installation in your browser. You will then no longer appear in the conversion tracking statistics.
   
   
7. Further information, as well as Google's privacy statement, is available at the following page:  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 saved on your computer, which help analyse how users use the website.
   
   
2. Information generated by the cookie about the user's use of the website 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 Member States of the European Union or in other states party to the Agreement on the European Economic Area.
   
   
3. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for the website operator, and providing other 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 held by Google. You can prevent the storage of cookies by adjusting your browser settings accordingly; however, please note that in this case you may not be able to use the full functionality of this website. You can also prevent Google from collecting and processing the data generated by the cookie about your use of the website (including your 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 activity

Pursuant to Section 6 of Act XLVIII of 2008 on the Basic Conditions of and Certain Limitations to Business Advertising Activity, the user may give prior, express consent to the Service Provider contacting them with advertising offers and other mailings at the contact details provided at registration.

Furthermore, having regard to the provisions of this notice, the customer may consent to the Service Provider processing the personal data necessary for sending advertising offers.

The Service Provider does not send unsolicited advertising messages, and the user may unsubscribe from receiving offers free of charge, without restriction or justification, at any time. In this case, the Service Provider will erase from its records all personal data necessary for sending advertising messages and will not contact the user with further advertising offers. The user may unsubscribe from advertisements by clicking the link in the message.

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

Personal data	Purpose of processing	Legal basis
Name, email address.	Identification, enabling subscription to the newsletter/promotional coupons.	Consent of the data subject, Article 6(1)(a). Section 6(5) of Act XLVIII of 2008 on the Basic Conditions of and Certain Limitations to Business Advertising Activity.
Date/time of subscription	Performing a technical operation.
IP address at the time of subscription	Performing a technical operation.

Scope of data subjects: all data subjects who subscribe to the newsletter.

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

 Duration of processing, deadline for erasure: processing continues until the consent declaration is withdrawn, i.e. until unsubscription.

Persons who may act as data controller with access to the data, recipients of the personal data: the personal data may be processed by the controller and its sales and marketing staff, in compliance with the principles above.

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

1. 1. The data subject may request from the controller access to, rectification, erasure or restriction of processing of personal data concerning him or her, as well as
      
      
   2. may object to the processing of their personal data, and
      
      
   3. the data subject has the right to data portability, and to withdraw consent at any time.
      
      

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

• by post, at 1135 Budapest, Tahi utca 53-57. 4th floor, 6a.,
  
• by email, at  hello@florm.eu,
• by phone, at +36 20 436 0836 .

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

Please be informed that

the processing is based on your consent and on the legitimate interest of the service provider.

• you are required to provide the personal data if you wish to receive a newsletter from us.
• failure to provide the data means that  we will not be able to send you a newsletter.
• please note that you may withdraw your consent at any time by clicking the unsubscribe link.
• withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Complaint handling

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

Scope of data subjects: all data subjects who make a purchase on the website and raise a quality complaint or file a complaint.

Duration of processing, deadline for erasure of data: copies of the minutes recorded about the complaint, the written record, and the response given to it must be retained for 3 years pursuant to Section 17/A(7) of Act CLV of 1997 on Consumer Protection.

Persons who may act as data controller with access to the data, recipients of the personal data: the personal data may be processed by the controller and its authorised staff, in compliance with the principles above.

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

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

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

• 1135 Budapest, Tahi utca 53-57. 4th floor, 6a. by post,
• by email, at  hello@florm.eu,
• by phone, at +36 20 436 0836 .

 

Please be informed that

• providing the personal data is based on a legal obligation.
  
  
• processing of personal data is a precondition for concluding the contract.
  
  
• you are required to provide the personal data so that we can handle your complaint.
  
  
• failure to provide the data means that we will not be able to handle the complaint you submit to us.

Recipients to whom personal data are disclosed

"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.

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 data subjects and under applicable legislation.

The controller places great emphasis on using only processors who or which provide sufficient guarantees to implement appropriate technical and organisational measures ensuring compliance 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 covered by this policy solely on the instructions of the controller.

The controller bears legal liability for the activities of the processor. The processor is liable for damage caused by processing only if it has failed to comply with the obligations of this Regulation specifically directed to processors, or has acted outside or contrary to the lawful instructions of the controller.

The processor has no substantive decision-making role in relation to the processing of the data.

The controller may use a hosting provider to ensure the IT infrastructure and a courier service to deliver ordered products, as processors.

1.  Individual processors:

Processing activity	Name, address, contact details
Hosting
Other processor (e.g. online invoicing, web development, marketing)	Newsletter software provider: Invoicing software provider: Bookkeeper and payroll provider:

"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.

1. Transfer of data to third parties

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

Controller's activity	Name, address, contact details
Shipping/transport
Online payment

Social media platforms

The fact of data collection, the scope of data processed: the name registered on Meta/Twitter/Pinterest/Youtube/Instagram etc. social media platforms, and the user's public profile picture.

Scope of data subjects: all data subjects who are registered on Meta/Twitter/Pinterest/Youtube/Instagram etc. social media platforms and who have "liked" the Service Provider's social media page, or who have contacted the controller through a social media platform.

Purpose of data collection: sharing, "liking", following and promoting certain content elements, products, promotions of the website, or the website itself, on social media platforms.

Duration of processing, deadline for erasure of data, persons who may act as data controller with access to the data, and description of the data subjects' rights relating to data processing: the data subject can obtain information about the source of the data, its processing, and the manner and legal basis of transfer on the relevant social media platform. Processing takes place on the social media platforms themselves, so the duration and manner of processing, and the options for deleting or modifying data, are governed by the rules of the relevant social media platform.

Legal basis of processing: the data subject's voluntary consent to the processing of their personal data on social media platforms.

Customer relations and other data processing

If any question arises, or the data subject encounters any problem, in connection with the use of the controller's services, they may contact the controller using the methods provided on the website (phone, email, social media, etc.).

The controller erases incoming emails, messages, and data provided by phone, Meta, etc., together with the enquirer's name and email address and any other voluntarily provided personal data, at the latest within 2 years from the date the data was provided.

We provide information about processing not listed in this notice at the time the data is collected.

In exceptional cases of requests by authorities, or requests by other bodies authorised by law, the Service Provider is obliged to provide information, disclose or transfer data, or make documents available.

In these cases, the Service Provider will disclose to the requesting party – provided it has specified the exact purpose and scope of the data requested – only the personal data strictly necessary to achieve the purpose of the request, and only to that extent.

Rights of data subjects

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

Right to rectification
You have the right to obtain from the controller, 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.

Right to erasure
You have the right to obtain from the controller, without undue delay, the erasure of personal data concerning you, and the controller is obliged to erase such personal data without undue delay where certain conditions apply.

 Right to be forgotten
Where the controller has made the personal data public and is obliged to erase it, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the data that you have requested the erasure of any links to, or copies or replications of, that personal data.

 Right to restriction of processing
You have the right to obtain from the controller restriction of processing where one of the following applies:

1. you contest the accuracy of the personal data, for a period enabling the controller to verify the accuracy of the personal data;
2. the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
3. the controller no longer needs the personal data for the purposes of processing, but you require them for the establishment, exercise or defence of legal claims;
4. you have objected to processing; in this case the restriction applies for the period pending verification whether the legitimate grounds of the controller override those of the data subject.
   
   

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 have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided (...)

Right to object
Where processing is based on legitimate interest or the exercise of official authority, you have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you (...), including profiling based on such provisions.

 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 the processing of your personal data for such purposes, including profiling to the extent it is related to such direct marketing. Where you object to processing for direct marketing purposes, the personal data will no longer be processed for such purposes.

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 previous paragraph shall not apply if the decision:

1. is necessary for entering into, or the performance of, a contract between you and the controller;
2. 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
3. is based on your explicit consent.

Deadline for action

The controller shall inform you of the measures taken in response to the requests above without undue delay, and in any event within 1 month of receipt of the request.

This period may be extended by 2 months where necessary. 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 in response to 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 of seeking a judicial remedy.

Security of processing

Taking into account the state of the art, the cost 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, among others, as appropriate:

the pseudonymisation and encryption of personal data;

the ability to ensure the ongoing confidentiality, integrity, availability and resilience of systems and services used for processing personal data;

the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;

a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.

Processed data must be stored in such a way that unauthorised persons cannot access it: for paper-based data carriers, by establishing appropriate physical storage and filing arrangements; for electronically processed data, by using a centralised access-rights management system.

The IT method of storing data must be chosen so that erasure – having regard to any differing erasure deadlines – can be carried out when the data retention period expires, or whenever otherwise necessary. Erasure must be irreversible.

Paper-based data carriers must be stripped of personal data using a document shredder, or by using an external organisation specialising in document destruction. For electronic data carriers, physical destruction must be carried out in accordance with the rules on decommissioning electronic data carriers, and, where necessary, preceded by secure and irreversible erasure of the data.

The controller applies 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 are kept in a secure, lockable, dry room.
   
   
2. Where personal data processed on paper is digitised, the rules applicable to digitally stored documents apply.
   
   
3. A staff member of the Service Provider who is engaged in data processing may only leave the room where processing is taking place if they lock away the data carriers entrusted to them, or lock the room in question.
   
   
4. Personal data may only be accessed by persons authorised to do so; third parties do not have access to it.
   
   
5. The Service Provider's building and premises are equipped with fire-protection and security equipment.

 IT protection

1. The computers and mobile devices (other data carriers) used for processing are the property of the Service Provider.
   
   
2. The computer system used by the Service Provider containing personal data is protected with antivirus software.
   
   
3. To ensure the security of digitally stored data, the Service Provider performs backups and archiving.
   
   
4. Access to the central server is restricted to persons with appropriate authorisation who have been specifically designated.
   
   
5. Data on the computers can only be accessed with a username and password.

Informing the data subject about a personal data breach

Where a personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, the controller shall inform 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 include the name and contact details of the data protection officer or other contact point where more information can be obtained; it shall describe the likely consequences of the personal data breach; and it shall describe the measures taken or proposed 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 are met:

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

If the controller has not yet notified the data subject of the personal data breach, the supervisory authority, having considered the likelihood of the personal data breach resulting in a high risk, may require it to do so.

Notification of a personal data breach to the authority

The controller shall notify a personal data breach to the competent supervisory authority 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 notification is not made within 72 hours, it shall be accompanied by reasons for the delay.

Review in the case of mandatory processing

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

The controller shall document the circumstances and outcome of this review, retain such documentation for ten years following completion of the review, and make it available to the National Authority for Data Protection and Freedom of Information (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 National Authority for Data Protection and Freedom of Information:

National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság)

1055 Budapest, Falk Miksa utca 9-11.

Postal address: 1363 Budapest, Pf. 9.

Phone: +36-1-391-1400

Fax: +36-1-391-1410

Email: ugyfelszolgalat@naih.hu

Closing remarks

In preparing this notice, we had regard to the following legislation:

• 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);
  
  
• Act CXII of 2011 on Informational Self-Determination and Freedom of Information (hereinafter: the Information Act);
  
  
• Act CVIII of 2001 on certain aspects of electronic commerce services and information society services (in particular Section 13/A);
  
  
• Act XLVII of 2008 on the Prohibition of Unfair Commercial Practices against Consumers;
  
  
• Act XLVIII of 2008 on the Basic Conditions of and Certain Limitations to Business Advertising Activity (in particular Section 6);
  
  
• Act XC of 2005 on the Freedom of Electronic Information;
  
  
• Act C of 2003 on Electronic Communications (in particular Section 155);
  
  
• Opinion 16/2011 on the EASA/IAB best practice recommendation on online behavioural advertising;
  
  
• The recommendation of the National Authority for Data Protection and Freedom of Information on the data protection requirements of prior notice.

Last updated: 19.03.2025