By publishing this data protection information, Budapest Sightseeing Kft. (in the followings:  Budapest Sightseeing Tour Operator) – hereinafter referred to as the Company – fulfills its prior information obligation regarding the handling of the personal data of the data subjects prescribed by REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL, according to which each and every one of the relevant articles of the Regulation information must be made available to those affected by data management in a concise, transparent, comprehensible and easily accessible form, clearly and comprehensibly worded.

1.NAME OF DATA PROCESSOR

The Enterprise informs the data subject that it is considered a data controller in the management of his personal data.

COMPANY NAME: Budapest Sightseeing Kft. (in the followings:  Budapest Sightseeing Tour Operator)

HEADQUARTERS: Address: H – 1075 Budapest, Madách Imre út 13-14. B. ép. 1. HUNGARY

COMPANY REGISTRATION NUMBER: 15-09-088766

TAX NUMBER: 01 09 424612

Insurance Company: Allianz Hungária & Colonnade Inscurance S.A.

TELEPHONE: +36/1-327-6690 (EUrama Travel Agency – as a tour organizer)

REPRESENTATIVE’S NAME: Györgyi Fraknói – Managing Director

E-MAIL: tour@eurama.hu (EUrama Travel Agency – as a tour organizer)

WEBSITE: www.rivercruisesbudapest.eu

Personal data may be accessed by employees of the Company with access rights related to the relevant data management purpose, as well as persons and organizations performing data processing activities on the basis of service contracts for the Company, within the scope determined by the Company and to the extent necessary for the performance of their activities.

NAME OF DATA PROCESSOR(S).

(1) The Company uses an external data processor for the purpose of operating and maintaining its website for the personal data it manages on the basis of voluntary consent.

COMPANY NAME: iWebMa Magyarország Kft.

HEADQUARTERS:   H-1061 Budapest, Király u. 26.

TAX NUMBER: 14666641242

COMMUNITY TAX NUMBER: HU 14666641242

COMPANY REGISTRATION NUMBER: 01 09 914318

ACTIVITY: website operation, maintenance

III. DEFINITIONS

“personal data”: any information relating to an identified or identifiable natural person (“data subject”); a natural person can be identified directly or indirectly, in particular on the basis of an identifier such as name, number, location data, online identifier or one or more factors relating to the physical, physiological, genetic, mental, economic, cultural or social identity of the natural person identifiable;

“data management”: any operation or set of operations performed on personal data or data files in an automated or non-automated manner, such as collection, recording, organization, segmentation, storage, transformation or change, query, insight, use, communication, transmission, distribution or otherwise by making it available, coordinating or connecting, limiting, deleting or destroying;

“restriction of data management”: designation of stored personal data for the purpose of limiting their future management;

“profiling”: any form of automated processing of personal data in which personal data is used to evaluate certain personal characteristics of a natural person, in particular work performance, economic situation, state of health, personal preferences, interests, reliability, behavior, location or movement used to analyze or predict related characteristics;

“Pseudonymization”: processing of personal data in such a way that, without the use of additional information, it is no longer possible to determine which specific natural person the personal data refers to, provided that such additional information is stored separately and secured by technical and organizational measures that this personal data cannot be linked to identified or identifiable natural persons;

“registration system”: the file of personal data in any way – centralized, decentralized or divided according to functional or geographical aspects – which is accessible based on specific criteria;

“data controller”: the natural or legal person, public authority, agency or any other body that determines the purposes and means of processing personal data independently or together with others; if the purposes and means of data management are determined by EU or member state law, the data manager or the special aspects regarding the designation of the data manager may also be determined by EU or member state law;

“data processor”: the natural or legal person, public authority, agency or any other body that processes personal data on behalf of the data controller;

“recipient”: the natural or legal person, public authority, agency or any other body to whom or to which the personal data is communicated, regardless of whether it is a third party. Public authorities that have access to personal data in the context of an individual investigation in accordance with EU or member state law are not considered recipients; the handling of said data by these public authorities must meet the purposes of the data management in accordance with the applicable data protection rules;

“third party”: the natural or legal person, public authority, agency or any other body that is not the same as the data subject, the data controller, the data processor or the persons who, under the direct control of the data controller or data processor, are authorized to process personal data they got;

“the consent of the data subject”: the voluntary, specific and clear declaration of the will of the data subject based on adequate information, with which the data subject indicates by means of a statement or an act clearly expressing the confirmation that he gives his consent to the processing of personal data concerning him;

“data protection incident”: a breach of security that results in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure or unauthorized access to personal data transmitted, stored or otherwise handled;

“enterprise”: a natural or legal person engaged in economic activity, regardless of its legal form, including partnerships and associations engaged in regular economic activity.

LEGAL BASIS OF DATA MANAGEMENT

Consent of the data subject

(1) The legality of processing personal data must be based on the consent of the data subject or have some other legal basis established by law.

(2) In the case of data processing based on the consent of the data subject, the data subject may give his consent to the processing of his personal data in the following form:

1. a) in writing, in the form of a statement giving consent to personal data management,
2. b) by electronic means, by the express behavior implemented on the website of the Company, by ticking a check box, or by making relevant technical settings during the use of services related to the information society, as well as any other statement or action that, in the given context, constitutes the consent of the data subject to the personal data clearly indicates the intended treatment.

(3) Silence, a pre-ticked box or inaction is therefore not considered to be a contribution. (4) Consent covers all data management activities carried out for the same purpose or purposes.

(5) If data management serves several purposes at the same time, consent must be given for all data management purposes. If the data subject gives his consent following an electronic request, the request must be clear and concise, and it must not unnecessarily prevent the use of the service for which the consent is requested.

(6) The data subject is entitled to withdraw his consent at any time. Withdrawal of consent does not affect the legality of data processing based on consent prior to withdrawal. Before giving consent, the data subject must be informed of this. Withdrawal of consent should be possible in the same simple way as giving it.

Fulfillment of contract

Data processing is considered lawful if it is necessary for the performance of a contract to which the data subject is a party, or if it is necessary for taking steps at the request of the data subject prior to the conclusion of the contract.

The consent of the data subject to the processing of personal data that is not necessary for the performance of the contract cannot be a condition for entering into a contract.

Fulfilling the legal obligation of the data controller or protecting the vital interests of the data subject or other natural person

The legal basis for data management is determined by law in the event of the fulfillment of a legal obligation, so the consent of the data subject is not required for the processing of their personal data.

The data controller is obliged to inform the data subject about the purpose, legal basis, duration of the data management, the person of the data controller, as well as about his rights and legal remedies.

In order to fulfill a legal obligation, the data controller is entitled, after withdrawing the data subject’s consent, to manage the data that is necessary to fulfill a legal obligation concerning him.

Execution of a task carried out in the public interest or in the context of the exercise of public authority granted to the data controller, enforcement of the legitimate interests of the data controller or a third party.

The data controller – including the data controller with whom the personal data may be disclosed – or the legitimate interest of a third party may create a legal basis for data processing, provided that the interests, fundamental rights and freedoms of the data subject do not take precedence, taking into account the data subject’s reasonable expectations. Such a legitimate interest can be discussed, for example, when a relevant and appropriate relationship exists between the data subject and the data controller, for example in cases where the data subject is a client of the data controller or is employed by it.

In order to establish the existence of a legitimate interest, it is necessary to carefully examine, among other things, whether the data subject can reasonably expect, at the time and in connection with the collection of personal data, that data processing may take place for the given purpose.

The interests and fundamental rights of the data subject may take precedence over the interests of the data controller if the personal data are processed under circumstances in which the data subjects do not expect further data processing.

THE RIGHTS OF THE PERSON CONCERNED RELATED TO THE MANAGEMENT OF DATA 1. The Company provides the following brief information on the rights of the person concerned: The person concerned has the right to:

for information before the start of data management,

to receive feedback from the data controller as to whether your personal data is being processed, and if such data processing is underway, you are entitled to access the personal data and the following information,

to request the correction or deletion of your data, to receive a notification from the data controller that this has occurred,

to request restriction of data processing, to receive a notification from the data controller about this happening, 5. for data portability,

to protest if your personal data is processed for purposes of public interest or with reference to the legitimate interests of the data controller.

exempt the automatic from decision-making, including profiling,

to file a complaint with the supervisory authority. The data subject can exercise his right to file a complaint at the following contact details: National Data Protection and Freedom of Information Authority, address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c., Phone: +36 (1) 391-1400; Fax: +36 (1) 391-1410 .,www:http://www.naih.hu e-mail: ugyfelszolgalat@naih.hu

for an effective judicial remedy against a supervisory authority, 10. For an effective judicial remedy against the data controller or data processor, 11. For information about the data protection incident.

Detailed information on data subject rights

Right to information

(1) The data subject has the right to be informed about the information related to data management before the start of the activity aimed at managing his data.

(2) Information to be made available if personal data is collected from the data subject:

the identity and contact details of the data controller and, if any, the representative of the data controller;

the contact details of the data protection officer, if any;

the purpose of the planned processing of personal data, as well as the legal basis for data processing;

in the case of data management based on point f) of Article 6, paragraph (1) of the Regulation, the legitimate interests of the data controller or a third party;

where applicable, recipients of personal data and categories of recipients, if any; 6.

where appropriate, the fact that the data controller wishes to transfer the personal data to a third country or an international organization, as well as the existence or absence of the Commission’s compliance decision, or Article 46, Article 47 or Article 49 (1) of the Regulation in the case of data transfer referred to in the second subparagraph of paragraph 1, indicating the appropriate and suitable guarantees, as well as referring to the means of obtaining a copy of them or their availability.

(3) In addition to the information mentioned in paragraph (1), the data controller informs the data subject of the following additional information at the time of obtaining the personal data, in order to ensure fair and transparent data management:

on the period of storage of personal data, or if this is not possible, on the aspects of determining this period;

the data subject’s right to request from the data controller access to personal data relating to him, their correction, deletion or restriction of processing, and to object to the processing of such personal data, as well as the data subject’s right to data portability;

in the case of data processing based on point a) of Article 6 (1) or point a) of Article 9 (2) of the Regulation, the right to withdraw consent at any time, which does not affect the legality of data processing carried out on the basis of consent before the withdrawal;

on the right to submit a complaint to the supervisory authority;

about whether the provision of personal data is based on legislation or a contractual obligation or is a prerequisite for the conclusion of a contract, as well as whether the data subject is obliged to provide the personal data, and what possible consequences the failure to provide data may have;

the fact of automated decision-making referred to in paragraphs (1) and (4) of Article 22 of the Regulation, including profiling, as well as, at least in these cases, understandable information on the logic used and the significance of such data management and what is expected for the data subject has consequences.

(4) If the personal data were not obtained from the data subject, the data controller makes the following information available to the data subject:

the identity and contact details of the data controller and, if any, the representative of the data controller;

the contact details of the data protection officer, if any;

the purpose of the planned processing of personal data, as well as the legal basis for data processing; 4. categories of personal data concerned;

recipients of personal data and categories of recipients, if any;

where applicable, the fact that the data controller wishes to forward the personal data to a recipient in a third country or to an international organization, and the existence or absence of the Commission’s compliance decision, or in Article 46, Article 47 of the Regulation or Article 49 ( In the case of data transfer referred to in the second subparagraph of paragraph 1), indicating the appropriate and suitable guarantees, as well as referring to the methods for obtaining a copy of them or their availability.

(2) In addition to the information mentioned in paragraph (1), the data controller provides the data subject with the following additional information necessary to ensure fair and transparent data management for the data subject:

the period of storage of personal data or, if this is not possible, the criteria for determining this period;

if the data management is based on point f) of Article 6 (1) of the Regulation, on the legitimate interests of the data controller or a third party;

the data subject’s right to request from the data controller access to personal data relating to him, their correction, deletion or restriction of processing, and to object to the processing of personal data, as well as the data subject’s right to data portability;

in the case of data processing based on point a) of Article 6 (1) or point a) of Article 9 (2) of the Regulation, the right to withdraw consent at any time, which does not affect the legality of data processing carried out on the basis of consent before the withdrawal;

submitting a complaint to a supervisory authority his right;

the source of the personal data and, where applicable, whether the data comes from publicly available sources; and

the fact of automated decision-making referred to in paragraphs (1) and (4) of Article 22 of the Regulation, including profiling, as well as, at least in these cases, understandable information about the applied logic and the significance of such data management and what is expected for the data subject has consequences.

(3) If the data controller wishes to carry out further data processing on personal data for a purpose other than the purpose of their acquisition, he must inform the data subject about this different purpose and all relevant additional information mentioned in paragraph (2) before the further data processing.

(4) Paragraphs (1)–(3) shall not be applied if and to the extent that:

the data subject already has the information;

the provision of the information in question proves to be impossible or would require a disproportionately large effort, especially for the purpose of archiving in the public interest, for scientific and historical research purposes or for statistical purposes, in the case of data processing taking into account the conditions and guarantees contained in Article 89 (1), or if the the obligation referred to in paragraph (1) of this article would probably make it impossible or seriously endanger the achievement of the goals of this data management. In such cases, the data controller must take appropriate measures – including making the information publicly available – in order to protect the rights, freedoms and legitimate interests of the data subject;

the acquisition or disclosure of the data is expressly required by the EU or Member State law applicable to the data controller, which provides for appropriate measures to protect the legitimate interests of the data subject; obsession

personal data must remain confidential on the basis of the obligation of professional confidentiality prescribed by an EU or member state law, including the obligation of confidentiality based on legislation.

The data subject’s right of access

(1) The data subject has the right to receive feedback from the data controller as to whether his personal data is being processed, and if such data processing is underway, he is entitled to access the personal data and the following information:

the purposes of data management;

categories of personal data concerned;

the recipients or categories of recipients to whom or to whom the personal data has been or will be communicated, including in particular recipients in third countries and international organizations;

where appropriate, the planned period of storage of personal data or, if this is not possible, the criteria for determining this period;

the right of the data subject to request from the data controller the correction, deletion or restriction of processing of personal data concerning him and to object to the processing of such personal data;

the right to submit a complaint to a supervisory authority;

if the data were not collected from the data subject, all available information about their source;

the fact of automated decision-making referred to in paragraphs (1) and (4) of Article 22 of the Regulation, including profiling, as well as, at least in these cases, comprehensible information about the logic used and the significance of such data management and what it means for the data subject has expected consequences.

(2) If personal data is transferred to a third country or to an international organization, the data subject is entitled to receive information about the appropriate guarantees in accordance with Article 46 regarding the transfer.

(3) The data controller makes a copy of the personal data subject to data management available to the data subject. For additional copies requested by the data subject, the data controller may charge a reasonable fee based on administrative costs. If the data subject submitted the request electronically, the information must be provided in a widely used electronic format, unless the data subject requests otherwise.

The data subject’s right to rectification and erasure

Right to rectification

(1) The data subject has the right to have inaccurate personal data corrected without undue delay upon request by the data controller. Taking into account the purpose of data management, the data subject is entitled to request the addition of incomplete personal data, among other things, by means of a supplementary statement.

The right to erasure (“the right to be forgotten”)

(1) The data subject has the right to request that the data controller delete the personal data concerning him without undue delay, and the data controller is obliged to delete the personal data concerning the data subject without undue delay if one of the following reasons exists:

the personal data are no longer needed for the purpose for which they were collected or otherwise processed;

the touch revokes the consent that forms the basis of the data management pursuant to point a) of Article 6 (1) of the Regulation (consent to the processing of personal data) or point a) of Article 9 (2) of the Regulation (giving express consent), and the data management has no other its legal basis;

the data subject objects to the processing of his data on the basis of Article 21 (1) of the regulation (right to object) and there is no overriding legitimate reason for data processing, or the data subject on the basis of Article 21 (2) of the regulation (personal data processing for the purpose of obtaining business) objection to) object to data processing;

personal data has been processed unlawfully;

the personal data must be deleted in order to fulfill the legal obligation prescribed by the EU or Member State law applicable to the data controller;

the collection of personal data took place in connection with the offering of services related to the information society referred to in Article 8 (1).

(2) If the data controller has disclosed the personal data and is obliged to delete it at the request of the data subject, taking into account the available technology and the costs of implementation, it will take the reasonably expected steps – including technical measures – in order to inform the data controllers handling the data that the the data subject requested from them the deletion of the links to the personal data in question or the copy or duplicate of this personal data.

(3) Paragraphs (1) and (2) do not apply if data management is necessary: 1. for the purpose of exercising the right to freedom of expression and information;

for the purpose of fulfilling the obligation under the EU or Member State law applicable to the data controller requiring the processing of personal data, or for the execution of a task performed in the public interest or in the context of the exercise of public authority conferred on the data controller;

in accordance with points h) and i) of Article 9 (2) of the Regulation and Article 9 (3) of the Regulation on the basis of public interest in the field of public health;

in accordance with Article 89, paragraph (1) of the Regulation, for the purpose of archiving in the public interest, for scientific and historical research purposes or for statistical purposes, if the right mentioned in paragraph (1) would likely make this data management impossible or seriously endanger it; obsession

for the presentation, enforcement and defense of legal claims.

The right to restrict data processing

(1) The data subject has the right to request that the data controller limit the data processing, if one of the following conditions is met:

the data subject disputes the accuracy of the personal data, in which case the limitation applies to the period that allows the data controller to check the accuracy of the personal data;

the data processing is illegal and the data subject opposes the deletion of the data and instead requests the restriction of its use;

the data controller no longer needs the personal data for the purpose of data management, but the data subject requires them to present, enforce or defend legal claims; obsession

the data subject objected to the data processing in accordance with Article 21 (1) of the Regulation; in this case, the restriction applies to the period until it is determined whether the legitimate reasons of the data controller take precedence over the legitimate reasons of the data subject.

(2) If data processing is subject to restrictions based on paragraph (1), such personal data, with the exception of storage, will only be processed with the consent of the data subject, or for the presentation, enforcement or defense of legal claims, or for the protection of the rights of other natural or legal persons, or in the interest of the Union , or can be handled in the important public interest of a member state.

(3) The data controller informs the data subject, at whose request the data processing was restricted based on paragraph (1), of the lifting of the data processing restriction in advance.

Notification obligation related to the correction or deletion of personal data, or the limitation of data management

(1) The data controller informs all recipients of the correction, deletion or limitation of data management to whom or to whom the personal data was communicated, unless this proves to be impossible or requires a disproportionately large effort.

(2) At the request of the data subject, the data controller shall inform about these recipients.

The right to data portability

(1) The data subject has the right to receive the personal data concerning him/her provided to a data controller in a segmented, widely used, machine-readable format, and is also entitled to transmit this data to another data controller without being hindered by the data manager to whom you have made the personal data available, if:

data processing is carried out in accordance with point a) of Article 6 (1) of the regulation (the consent of the data subject to the processing of personal data) or point a) of Article 9 (2) of the regulation (express consent of the data subject to the processing of data) consent, or a contract according to Article 6 (1) point b); and

data management is automated.

(2) During the exercise of the right to data portability in accordance with paragraph (1), the data subject has the right to – if this is technically possible – request the direct transfer of personal data between data controllers.

(3) The exercise of the right referred to in paragraph (1) of this article may not violate Article 17 of the Regulation. The mentioned right does not apply if the data management is in the public interest

it is necessary for the execution of the task performed in the framework of the exercise of the public authority delegated to the data controller.

(4) The right referred to in paragraph (1) may not adversely affect the rights and freedoms of others.

The right to protest

1) The data subject has the right to object at any time, for reasons related to his own situation, to the processing of his personal data carried out in the context of the exercise of public interest or public authority, or to the processing necessary to assert the legitimate interests of the data controller or a third party (Article 6 (1) of the Decree e) or f) against data management), including profiling based on the aforementioned provisions. In this case, the data controller may no longer process the personal data, unless the data controller proves that the data processing is justified by compelling legitimate reasons that take precedence over the interests, rights and freedoms of the data subject, or that are necessary for the presentation, enforcement or defense of legal claims. are connected.

(2) If personal data is processed for the purpose of direct business acquisition, the data subject has the right to object at any time to the processing of his personal data for this purpose, including profiling, if it is related to direct business acquisition.

(3) If the data subject objects to the processing of personal data for the purpose of direct business acquisition, then the personal data may no longer be processed for this purpose.

(4) The right mentioned in paragraphs (1) and (2) must be specifically brought to the attention of the person concerned during the first contact at the latest, and the relevant information must be displayed clearly and separately from all other information.

(5) In connection with the use of services related to the information society and deviating from Directive 2002/58/EC, the data subject may also exercise the right to protest with automated means based on technical specifications.

(6) If personal data is processed for scientific and historical research purposes or for statistical purposes in accordance with Article 89 (1) of the Regulation, the data subject has the right to object to the processing of personal data concerning him for reasons related to his own situation, except , if the data management is necessary for the performance of a task carried out for reasons of public interest.

The right to be exempt from automated decision-making

(1) The data subject has the right not to be covered by the scope of a decision based solely on automated data management, including profiling, which would have a legal effect on him or affect him to a similar extent.

2) Subsection (1) does not apply if the decision:

necessary for the conclusion or fulfillment of the contract between the data subject and the data controller;

is made possible by EU or Member State law applicable to the data controller, which also establishes appropriate measures to protect the rights and freedoms and legitimate interests of the data subject; obsession

based on the express consent of the data subject.

(3) In the cases referred to in points a) and c) of paragraph (2), the data controller must take appropriate measures to protect the rights, freedoms and legitimate interests of the data subject, including at least the right of the data subject to request human intervention on the part of the data controller, his/her position express and file an objection against the decision.

(4) The decisions referred to in paragraph (2) may not be based on the special categories of personal data referred to in paragraph (1) of Article 9 of the Regulation, unless point a) or g) of paragraph (2) of Article 9 applies and the data subject appropriate measures have been taken to protect your rights, freedoms and legitimate interests.

The data subject’s right to complaint and legal remedy

The right to complain to the supervisory authority.

(1) Based on Article 77 of the Regulation, the data subject is entitled to file a complaint with the supervisory authority if, in the opinion of the data subject, the handling of personal data relating to him/her violates this Regulation.

(2) The data subject may exercise his right to file a complaint at the following contact details:

National Data Protection and Freedom of Information Authority address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c Telephone: +36 (1) 391-1400; Fax: +36 (1) 391-1410 www: http://www.naih.hu

e-mail: ugyfelszolgalat@naih.hu

(3) The supervisory authority, to which the complaint was submitted, is obliged to inform the customer about the procedural developments related to the complaint and its result, including that the customer is entitled to a judicial remedy based on Article 78 of the Regulation.

The right to an effective judicial remedy against the supervisory authority

(1) Without prejudice to other administrative or non-judicial remedies, all natural and legal persons are entitled to an effective judicial remedy against the legally binding decision of the supervisory authority.

(2) Without prejudice to other administrative or non-judicial remedies, all affected persons are entitled to an effective judicial remedy if the competent supervisory authority does not deal with the complaint, or does not inform the affected person within three months about the complaint submitted under Article 77 of the Decree about procedural developments or their results.

(3) Proceedings against the supervisory authority must be initiated before the court of the Member State where the supervisory authority is based.

(4) If proceedings are initiated against a decision of the supervisory authority, in relation to which the Board previously issued an opinion or made a decision within the framework of the uniformity mechanism, the supervisory authority is obliged to send this opinion or decision to the court.

The right to an effective judicial remedy against the controller or processor

(1) Without prejudice to the available administrative or non-judicial legal remedies, including the right to complain to the supervisory authority according to Article 77, all affected persons are entitled to an effective judicial remedy if, in their judgment, their personal data has been handled in a way that does not comply with this regulation your rights under this regulation have been violated.

(2) Proceedings against the data controller or the data processor must be initiated before the court of the Member State where the data controller or the data processor operates. Such proceedings can also be initiated before the court of the Member State of the habitual residence of the person concerned, unless the data controller or the data processor is a public authority of a Member State acting in its public authority.

Restrictions

(1) The EU or Member State law applicable to the data manager or data processor may limit the provisions of Articles 12-22 through legislative measures. Article and Article 34, as well as Articles 12–22. in view of its provisions in accordance with the rights and obligations set out in Article 5, the scope of the rights and obligations contained in Article 5, if the restriction respects the essential content of fundamental rights and freedoms, and is a necessary and proportionate measure in a democratic society for the protection of the following:

national security;

national defense;

public safety;

the prevention, investigation, detection or prosecution of crimes, or the enforcement of criminal sanctions, including the protection against threats to public safety and the prevention of such threats;

other important general public interest objectives of the Union or a Member State, in particular an important economic or financial interest of the Union or a Member State, including monetary, budgetary and tax issues, public health and social security;

the protection of judicial independence and judicial proceedings;

in the case of regulated occupations, the prevention, investigation and detection of ethical violations and the conduct of related procedures;

in the cases mentioned in points a)-e) and g) – even occasionally – control, investigation or regulatory activities related to the performance of public authority tasks;

the protection of the data subject or the protection of the rights and freedoms of others; 10. enforcement of civil law claims.

(2) The legislative measures referred to in paragraph (1) contain, where appropriate, detailed provisions at least:

for the purposes of data management or the categories of data management,

categories of personal data,

on the scope of the restrictions introduced,

guarantees aimed at preventing misuse, unauthorized access or transmission,

to define the data controller or to define the categories of data controllers,

for the duration of data storage, as well as applicable guarantees, taking into account the nature, scope and purposes of data management or categories of data management,

to risks affecting the rights and freedoms of the data subjects, and

the right of the data subjects to be informed about the restriction, unless this may adversely affect the purpose of the restriction.

Information about the data protection incident

(1) If the data protection incident likely involves a high risk for the rights and freedoms of natural persons, the data controller shall inform the data subject of the data protection incident without undue delay.

(2) In paragraph (1). In the aforementioned information given to the data subject, the nature of the data protection incident must be clearly and comprehensibly described, and at least the

the name and contact information of the data protection officer or other contact person providing additional information, the likely consequences of the data protection incident, the measures taken or planned by the data controller to remedy the data protection incident, including, where appropriate, measures aimed at mitigating any adverse consequences resulting from the data protection incident.

(3) The data subject need not be informed as mentioned in paragraph (1) if any of the following conditions are met:

the data controller has implemented appropriate technical and organizational protection measures, and these measures have been applied to the data affected by the data breach, in particular those measures – such as the use of encryption – that make it unintelligible to persons not authorized to access personal data data;

after the data protection incident, the data controller has taken additional measures to ensure that the high risk to the rights and freedoms of the data subject referred to in paragraph (1) is unlikely to materialize in the future;

providing information would require a disproportionate effort. In such cases, the data subjects must be informed through publicly published information, or a similar measure must be taken that ensures similarly effective information to the data subjects.

(4) If the data controller has not yet notified the data subject of the data protection incident, the supervisory authority, after considering that the data protection incident is likely to be of high risk

can order the information of the person concerned, or establish the fulfillment of one of the conditions mentioned in paragraph (3).

PROCEDURE TO BE APPLIED IN THE EVENT OF A REQUEST BY THE PARTICIPANT

(1) The Company facilitates the exercise of the data subject’s rights, and may not refuse to fulfill the data subject’s request to exercise his rights, which are also recorded in this data management information, unless it proves that the data subject cannot be identified.

(2) The Enterprise informs the person concerned about the measures taken following the request without undue delay, but in any case within one month from the receipt of the request. If necessary, taking into account the complexity of the application and the number of applications, this is the deadline

it can be extended by another two months. The data controller shall inform the data subject of the extension of the deadline, indicating the reasons for the delay, within one month of receiving the request.

(3) If the data subject submitted the application electronically, the information must be provided electronically, if possible, unless the data subject requests otherwise.

(4) If the Company does not take measures following the data subject’s request, it shall inform the data subject without delay, but at the latest within one month from the receipt of the request, of the reasons for the failure to take action, as well as that the data subject may file a complaint with the supervisory authority and take legal action. with his right of redress.

(5) The Company provides the data subject with the following information and measures free of charge: feedback on the processing of personal data, access to processed data, correction, addition, deletion of data, restriction of data processing, data portability, objection to data processing, information about data protection incidents.

(6) If the data subject’s request is clearly unfounded or – especially due to its repeated nature – excessive, the data controller, taking into account the administrative costs associated with providing the requested information or information or taking the requested measure: may charge a fee of HUF 5,000, or may refuse the request action based on

(7) It is the responsibility of the data controller to prove that the request is clearly unfounded or exaggerated.

(8) Without prejudice to Article 11 of the Regulation, if the data controller has well-founded doubts about Articles 15-21 of the Regulation. regarding the identity of the natural person who submitted the application according to Article, you may request the provision of additional information necessary to confirm the identity of the person concerned.

PROCEDURE IN CASE OF A DATA PROTECTION INCIDENT (PERSONAL DATA BREACH)

(1) According to the Regulation, a data protection incident is a breach of security that results in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure or unauthorized access to personal data transmitted, stored or handled in another way.

(2) The loss or theft of a device containing personal data (laptop, mobile phone) is considered a data protection incident, as well as the loss, inaccessibility of the code used to decrypt files encrypted by the data controller, or ransomware.

infection by mware (ransomware), which makes the data managed by the data controller inaccessible until the ransom is paid, attacking the IT system, e-mail containing wrongly sent personal data, disclosure of address lists, etc.

(3) If a data protection incident is detected, the representative of the Company shall immediately conduct an investigation in order to identify the data protection incident and establish its possible consequences. Necessary measures must be taken to prevent damage.

(4) The data protection incident must be reported to the competent supervisory authority 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 likely to pose no risk to the rights and freedoms of natural persons looking at. If the notification is not made within 72 hours, the reasons justifying the delay must also be attached.

(5) The data processor shall report the data protection incident to the data controller without undue delay after becoming aware of it.

(6) In the notification referred to in paragraph (3), at least:

the nature of the data protection incident must be described, including – if possible – the categories and approximate number of affected persons, as well as the categories and approximate number of data affected by the incident;

the name and contact details of the data protection officer or other contact person providing additional information must be provided;

the likely consequences of the data protection incident must be described;

the measures taken or planned by the data controller to remedy the data protection incident must be described, including, where applicable, measures aimed at mitigating any adverse consequences resulting from the data protection incident.

(7) If and to the extent that it is not possible to provide the information at the same time, it can be provided later in parts without further undue delay.

(8) The data controller keeps records of data protection incidents, indicating the facts related to the data protection incident, its effects and the measures taken to remedy it. This register enables the supervisory authority to check compliance with the requirements contained in Article 33 of the Regulation.

DATA MANAGEMENT IN CONNECTION WITH THE WEBSITE

Information regarding the data of visitors to the Company’s website

(1) During visits to the Company’s website, one or more cookies – small information packages that the server sends to the browser, and then the browser sends back to the server for every request directed to the server – are sent to the computer of the person visiting the website, which(s) ) will make its browser uniquely identifiable if

to this, the person visiting the website gave his express (active) consent after clear and unequivocal information by continuing to browse the website.

(2) Cookies work solely for the purpose of improving the user experience and automating the login process. The cookies used on the website do not store personally identifiable information, and the Company does not manage personal data in this context.

Registration, newsletter subscription

(1) The legal basis for data management is the data subject’s consent in the case of registration or newsletter subscription, which the data subject provides by ticking the box next to the “registration” or “newsletter subscription” text section on the Company’s website following the information regarding the processing of their data.

(2) The circle of stakeholders in the case of registration and newsletter subscription: all natural persons who wish to subscribe to the Company’s newsletter or register on the website and give their consent to the processing of their personal data.

(3) Scope of processed data in case of newsletter subscription: name, e-mail address.

(4) Scope of processed data in case of registration: name, address, e-mail address, phone number, login password.

(5) The purpose of data management in the case of subscription to the newsletter: informing the data subject about the Company’s services and products, the changes that have occurred in them, information about news and events.

(6) In the case of registration, the purpose of data management is: contact for the preparation of a contract, provision of free services available on the website to the affected party, access to non-public content of the website.

(7) Recipients of the data (those who can access the data) in the case of subscription or registration to the newsletter: the head of the Company, staff providing customer relations, data processing staff operating the website of the Company.

(8) Duration of data management in the case of newsletter subscription and registration: until unsubscribing in the case of newsletter subscription, until deletion at the request of the data subject in the case of registration.

(9) The data subject can unsubscribe from the newsletter at any time or request registration (personal data)

deletion. The newsletter is unsubscribed by clicking on the unsubscribe link in the footer of the e-mails sent to the person concerned, or in the postal letter sent to the Company’s headquarters.

Data management related to direct marketing activities

(1) The legal basis for the Company’s data management for direct marketing purposes is the consent of the data subject, which is clear and explicit. The data subject gives his clear, express prior consent on the Company’s website by ticking the box next to the consent to direct marketing inquiry after receiving information about the processing of his data.

(2) The consent of the data subject can also be given on paper, no. 2 of these regulations. by filling out the data sheet forming its annex.

(3) The circle of stakeholders: all natural persons who give their clear, express consent to the Company handling their personal data for direct marketing purposes.

(4) Data management purposes: advertising related to service provision, product sales, sending offers, notification of promotions electronically or by post.

(5) Recipients of personal data: the head of the Company, employees performing customer service tasks and marketing tasks based on their job title.

(6) Scope of processed personal data: name, address, telephone number, e-mail address.

(7) Duration of data management: processing of personal data for direct marketing purposes until withdrawn by the data subject.

Online store-related data management

(1) The above provisions govern data management activities related to registration in the online store, subscription to the newsletter, and information to visitors.

(2) Online, electronic contracts (purchases) on the Company’s website are subject to CVIII of 2001. Act (Eker tv.), therefore, the purpose of data management, in addition to the above, is to prove the fulfillment of the service provider’s obligation to provide consumer information prescribed by law, to prove the conclusion of the contract, to create the contract, to determine its content, to modify it, to monitor its fulfillment, the invoicing of the resulting fee(s), as well as the enforcement of related claims.

(3) In the case of a purchase in the online store, the legal basis for data management is the performance of the contract, the fulfillment of a legal obligation.

(4) Categories of data affected by data management: customer name, address, phone number, access password, bank account number.

(5) Categories of persons affected by data management: all natural persons who register in the Company’s online store, subscribe to newsletters, and make purchases.

(6) The categories of recipients of the data: the head of the Company, the employees performing tasks related to customer relations and sales, the data processing employees who operate the website of the Company, and the employees performing accounting tasks of the Company, the data processing employees performing these tasks.

(7) The place of data management is the registered office of the Company.

(8) Duration of data management: 5 years from the termination of the contract.

VII. DATA MANAGEMENT ACTIVITY RELATED TO CONTRACT PERFORMANCE

(1) The Company manages the personal data of the natural persons contracting with it – customers, buyers, suppliers – in connection with the contractual relationship. The data subject must be informed about the handling of personal data.

(2) Scope of stakeholders: all natural persons who establish a contractual relationship with the Enterprise.

(3) The legal basis of data management is the performance of a contract, the purpose of data management is to maintain contact, assert claims arising from the contract, and ensure compliance with contractual obligations.

(4) Recipients of personal data: the head of the Company, the Company’s employees and data processors performing customer service and bookkeeping tasks based on their duties.

(5) Scope of personal data handled: name, address, seat, telephone number, e-mail address, tax number, bank account number, entrepreneur ID number, primary producer ID number.

(6) Duration of data management: 5 years from the termination of the contract.

VIII. INFORMATION ABOUT DATA MANAGEMENT USING AN ELECTRONIC MONITORING SYSTEM

(1) Our company operates an electronic monitoring and recording system (camera system) in the customer space/in the area it owns, in the units belonging to it. Upon entering the monitored area (room) marked with this sign, the electronic surveillance system will record the image and actions of the person concerned.

(2) The legal basis for camera surveillance is the consent of the concerned volunteer based on the information posted by our company in the form of notice boards. The data subject’s consent can also be given in the form of explicit suggestive behavior. Such explicit suggestive behavior is considered to be caught by the electronic monitoring and recording system lt enters the room/area or stays there. If you do not wish to give your consent, do not enter the rooms/areas or units marked with the warning sign.

(3) The purpose of the recordings is to protect human life, physical integrity, personal freedom, protect business secrets, prevent and detect violations of law in order to protect persons and property, to prove violations, to document the circumstances of possible accidents occurring in the customer area, and the protection of the public’s private area is necessary for the performance of the insurer’s duties. The camera surveillance system does not record sound.

(4) The legal basis for camera surveillance is the consent of the concerned volunteer based on the information posted by the Company in the form of notice boards. The data subject’s consent can also be given in the form of explicit suggestive behavior. Such explicit suggestive behavior is considered if you enter or stay in the room/area monitored by the electronic monitoring and recording system.

(5) The place of storage of the recordings (personal data) recorded by the electronic surveillance system is the headquarters of our company, the duration of the storage of the recordings is 3 working days from the date of creation.

(6) The scope of the processed data: the affected person’s image recorded by the operated camera system and other personal data.

(7) Personal data recorded through camera recording can be accessed by: Company manager, the employees operating the camera system, the data processor performing the operation for the purpose of detecting legal violations and checking the operation of the system.

DATA SECURITY PROVISIONS

(1) The Company may process personal data only in accordance with the activities set out in these regulations and according to the purpose of data management.

(2) The Company ensures the security of the data, in this context it undertakes to take all the technical and organizational measures that are absolutely necessary for the enforcement of the legislation on data security, data and privacy protection rules, and to establish the procedural rules necessary for the enforcement of the legislation defined above. .

(3) The Company protects the data with appropriate measures against unauthorized access, modification, transmission, disclosure, deletion or destruction, as well as against accidental destruction and damage, as well as against becoming inaccessible due to changes in the technology used.

(4) The technical and organizational measures to be implemented by the Enterprise for the sake of data security are recorded in the Enterprise’s data protection policy.

(5) When defining and applying measures for data security, the Company takes into account the state of the art at all times, and in the case of several possible data management solutions, chooses a solution that ensures a higher level of protection of personal data, unless it would represent a disproportionate difficulty.

RULES RELATED TO DATA PROCESSING

General rules related to data processing

(1) The rights and obligations of the data processor related to the processing of personal data are defined by the law and the data controller within the framework of separate laws on data management.

(2) The Enterprise declares that the data processor does not have the competence to make substantive decisions regarding data management during its activities, it can only process the personal data that it has come to know in accordance with the provisions of the data controller, it cannot process data for its own purposes, and it is also obliged to process personal data according to the provisions of the data controller store and preserve.

(3) The Company is responsible for the legality of the instructions given to the data processor regarding data management operations.

(4) It is the obligation of the Enterprise to provide the data subjects with information about the person of the data processor and the place of data processing.

(5) The Enterprise does not authorize the data processor to use additional data processors.

(6) The contract for data processing must be in writing. Data processing cannot be entrusted to an organization that is interested in business activities that use the personal data to be processed.

Dated, Budapest, 20.07.2023.