From 25 May 2018, the processing of personal data in Regulation No. 2016/679 of the European Parliament and of the Council (hereinafter: the Regulation) and in Regulation CXII of 2011 Act (hereinafter: Info. Act.).

This data management information contains information on the handling of personal data managed by the data controller in accordance with the decree written above and the Info. to comply with the TV.

The Info. TV. according to:

• personal data: any information about the data subject

• data subject: any natural person identified or identifiable on the basis of any information;

• identifiable natural person: any natural person who, directly or indirectly, in particular by means of an identifier, such as a name, an identification number, a location data, an online identifier or a identifiable by one or more factors;

• data management: any operation or set of operations on data, irrespective of the procedure used, in particular their collection, recording, recording, systematisation, storage, alteration, use, interrogation, transmission, disclosure, coordination or aggregation, blocking, erasure and destruction; and to prevent further use of the data, to take photographs, sound or images and to record physical characteristics (eg fingerprints or palm prints, DNA samples, irises) that can be used to identify the person;

• recipient: the natural or legal person or entity without legal personality to whom personal data are made available by the controller or processor;

• data processor: a natural or legal person or an organization without legal personality who, within the framework and under the conditions laid down by law or a binding act of the European Union, processes personal data on behalf of or at the request of the controller;

• consent: a clear, voluntary and well-informed statement of the will of the data subject, by which he or she indicates his or her consent to the processing of personal data concerning him or her by means of a statement or other unambiguous expression of his or her will;

I. Identity and contact details of the data controller, the data controller's representative

1. / Identity and contact details of the data controller and the data controller's representative

Data controller:

Beck & Söhne Kft.

head office: 7771 Palkonya, Fő utca 50.

company registration number: 02-09-061672

tax number: 11003289-2-02

email address: info@borverandapalkonya.hu

website: www.borverandapalkonya.hu

​

Data controller's representative name:

Dr. Beck Engelbert Joachim

7771 Palkonya, Fő utca 50.

II. Management of personal data

1. / Purpose of data management, scope of data processed, duration of data management, legal basis of data management, source of data, definition of recipients

The data controller is the operator of the website available at www.borverandapalkonya.hu (hereinafter: website).

The data controller handles the personal data indicated in the appendix to this prospectus via the website.

The data on the purpose of data management, the scope of the processed data, the duration of the data processing, the legal basis of the data processing and the definition of the recipients are contained in the annexes to this data management information.

2. / Withdrawal of consent

We would like to inform you that if the data processing is based on consent, you, as the data subject, have the right to withdraw your consent at any time without giving reasons. Please be informed that the withdrawal of consent does not affect the lawfulness of the data processing based on consent prior to the withdrawal.

3. / Transfer of data to a third country or to an international organization

We would like to inform you that the data controller does not transfer the processed personal data to a third country or an international organization.

4. / Automated decision making, profiling

We would like to inform you that third parties independent of the data controller (Google Inc., Facebook Inc.) may perform profiling on the website in order to get a picture of the measurable behavior of the website visitor on the website in order to display personalized ads. Profiling is any form of automated processing of personal data in which personal data is used to assess certain personal characteristics of a natural person, in particular to analyze or predict characteristics related to personal preferences, interests, behavior, location or movement.

5. / Cookies information

We would like to inform you that the information about the cookies used by the data controller is provided by the so-called "Cookie information" included.  

III. Rights of the data subject

The data subject may request from the controller access to, rectification, erasure or restriction of the processing of personal data concerning him or her and may object to the processing of personal data and has the right to data portability, which rights may be exercised through the contact details set out in point I.  

In addition to the above, the person concerned may lodge a complaint with the supervisory authority.

A detailed explanation of the data subject's rights is provided in the following sections.

1. / Right of access

The data subject shall have the right to receive feedback from the controller as to whether the processing of his or her personal data is in progress and, if such processing is in progress, the controller shall provide the controller with the processed personal data and the following information:  

a) the purposes and legal basis of the data processing; 

(b) the scope of the personal data processed; 

(c) the recipients or categories of recipients to whom or with whom the personal data have been or will be communicated, including in particular third country recipients or international organizations; the legal basis for the transfer; 

(d) the intended period for which the personal data will be stored or, if that is not possible, the criteria for determining that period; 

(e) the data subject's right to request the controller to rectify, erase or restrict the processing of personal data concerning him or her and to object to the processing of such personal data; 

(f) the right to lodge a complaint with a supervisory authority; 

(g) all available information on the source of the data; 

(h) where the controller makes a decision in relation to the data subject based solely on automated data processing, including profiling, which would have a legal effect on him or her or a significant effect on him or her, the fact and, at least, the logic and comprehensible information on the significance of such data processing and the expected consequences for the data subject;

(i) if profiling is used, its fact;

(j) the circumstances of the occurrence of data protection incidents in connection with the processing of the personal data of the data subject, their effects and the measures taken to deal with them;

If the data controller restricts or refuses the data subject's rights described above, he / she is obliged to immediately inform the data subject in writing about the fact, legal and factual reasons for the restriction or refusal, and the data subject shall be informed by Info. TV. the right of access, with the assistance of the National Data Protection and Freedom of Information Authority.

2. / Right to rectification

If the data controller handles inaccurate, incorrect or incomplete data processed by him or by the data controller entrusted by him or her, he or she shall immediately correct or correct them, in particular at the request of the data subject. If it is compatible with the data processing, the data subject has the right to request that the incomplete personal data be supplemented with the data provided by him or her or with a statement attached to the data.

3. / Right of cancellation ("right of oblivion")

The data subject shall have the right, at the request of the controller, to delete personal data concerning him or her without delay if one of the following reasons exists:  

(a) the processing is unlawful, in particular if the processing

aa) the Info. TV. Contrary to the principles set out in Article 4,

(ab) its purpose has ceased to exist or further processing of the data is no longer necessary for the purpose of the processing,

(ac) a period of time specified by law, international treaty or binding act of the European Union has elapsed, or

(ad) its legal basis has ceased to exist and there is no other legal basis for the processing of the data,

b) the data subject withdraws his or her consent to the data processing or requests the deletion of his or her personal data, unless the processing is ordered by law or a local government decree in the public interest or to protect the vital interests of the data subject or other person. necessary and proportionate to avert or prevent an imminent threat to its assets, or  if it is absolutely necessary and proportionate for the implementation of an international treaty promulgated by law, or it is ordered by law for the enforcement of a fundamental right guaranteed in the Basic Law, as well as for national security, prevention, detection or prosecution of criminal offenses;

(c) the erasure of the data has been ordered by law, an act of the European Union, the Authority or a court;

d) the Info. TV. The period specified in Section 19 (1) (b) - (d) has elapsed;

(e) the data subject objects to a processing operation necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller or for the legitimate interests of the controller or a third party and there is no overriding legitimate reason for the processing; the data subject objects to the processing of data in the interest of direct business acquisition or to data processing in the course of profiling related to direct business acquisition;  

(f) personal data have been collected in connection with the provision of information society services directly to children.

4. / The right to restrict data processing

The data subject shall have the right, at the request of the controller, to restrict the processing if one of the following is met:  

(a) the data subject contests the accuracy, correctness or completeness of the personal data and the accuracy, correctness or completeness of the personal data processed cannot be established beyond a reasonable doubt for the duration of the clarification;  

(b) the processing is unlawful and the data subject opposes the erasure of the data and instead requests that their use be restricted;

(c) if the erasure of the data would be necessary because the processing is unlawful but there is a reasonable presumption on the basis of the data subject's written statement or information available to the controller that the erasure would harm the data subject's legitimate interest;

(d) where the erasure of the data would be necessary because the processing is unlawful but requires the retention of data as evidence in statutory investigations or proceedings, including in particular criminal proceedings, carried out by or with the participation of the controller or other public authority, such investigation or until the final or final conclusion of the proceedings;

e) if it would be appropriate to delete the data due to the fact that the data processing is illegal, but the retention of the data is necessary in order to fulfill the documentation obligation regarding the international data transfer, the Info. TV. 25 / F. § (4);  

(f) the controller no longer needs the personal data for the purpose of processing the data, but the data subject requests them in order to make, enforce or protect legal claims;  

(g) the data subject objects to a processing operation necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller or for the protection of the legitimate interests of the controller or a third party; in that case, the restriction shall apply for as long as it is established that the legitimate reasons of the controller take precedence over the legitimate reasons of the data subject.  

Where the processing is subject to a restriction as defined above, such personal data, with the exception of storage, shall be subject to the consent of the data subject or to the submission, enforcement or protection of legal claims in the public interest.

5. / The right to protest

The data subject shall have the right to object at any time, for reasons related to his or her situation, to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of public authority. based profiling. In that case, the controller may not further process the personal data unless the controller demonstrates that the processing is justified by overriding legitimate reasons which take precedence over the interests, rights and freedoms of the data subject or which are necessary to bring, assert or defend legal claims. are related.  

Where personal data are processed for the purpose of direct business acquisition, the data subject shall have the right to object at any time to the processing of personal data concerning him or her for that purpose, including profiling, in so far as it relates to direct business acquisition.  

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

In connection with the use of information society services and by way of derogation from Directive 2002/58 / EC, the data subject may also exercise the right to object by automated means based on technical specifications.  

Where personal data are processed for scientific and historical research or statistical purposes, the data subject shall have the right to object to the processing of personal data concerning him or her on grounds relating to his or her situation, unless such processing is necessary for the performance of a task carried out in the public interest.

6. / Right to data portability

The data subject shall have the right to receive personal data concerning him or her made available to a controller in a structured, widely used machine-readable format and to transfer such data to another controller without being hindered by the controller whose provided personal data if:  

(a) the processing is based on consent to personal data or special categories of personal data or on a contract to which one of the parties is a party; and  

(b) the data processing is automated; with that  

(c) the exercise of this right shall be without prejudice to the right to cancel ("right to forget"); furthermore, the right to data portability must not adversely affect the rights and freedoms of others; or the right to data portability shall not apply where the processing is necessary for the performance of a task carried out in the public interest or in the exercise of public authority vested in the controller.  

In exercising the right to data portability as described above, the data subject shall have the right, if technically feasible, to request the direct transfer of personal data between data controllers.  

7. / Method of enforcing the rights of the data subject

Any person concerned shall have the right to initiate an investigation by the supervisory authority, in particular in the Member State of his habitual residence, place of work or suspected infringement, in order to enforce his rights, or to request that the supervisory authority conduct proceedings.

In Hungary, the National Data Protection and Freedom of Information Authority exercises supervisory rights, the contact details of which are:

National Data Protection and Freedom of Information Authority

registered office: 1125 Budapest, Szilágyi Erzsébet avenue 22 / c.

postal address: 1530 Budapest, Pf .: 5.

telephone number: +36 (1) 391-1400

fax number: +36 (1) 391-1410

central e-mail address: ugyfelszolgalat@naih.hu

Website URL: http://www.naih.hu

Contact customer service or public relations:

National Data Protection and Freedom of Information Authority Customer Service

telephone number: +36 (1) 391-1400

fax number: +36 (1) 391-1410

address: 1125 Budapest, Szilágyi Erzsébet avenue 22 / c.

postal address: 1530 Budapest, Pf .: 5

online administration contact:  https://naih.hu/online-uegyinditas.html  

The data subject may, in connection with data processing operations falling within the scope of the data controller's activities, take legal action against the data processor if, in his or her opinion, the data controller or the data processor acting on his or her behalf or at his or her disposal In breach of the rules laid down in a binding act of the Union.  

Proceedings shall be instituted before the competent court, provided that the person concerned may, at his or her choice, also institute proceedings before the court having jurisdiction over his or her place of residence or stay.

ARC. Procedure of the controller in exercising the data subject's right of access to personal data, right of rectification, right of erasure or restriction of the processing of personal data, right of objection and right of data portability

If the data subject's request is rejected by the controller, the data subject shall be informed in writing or, if the data subject has submitted the request electronically, by electronic means without delay.

(a) the fact of the refusal, the legal and factual grounds for it; and

(b) the data subject's rights under this Act and the manner in which they are enforced, in particular the right to rectify, erase or restrict the processing of personal data processed by the controller or the processor acting on his behalf or at his disposal, with the assistance of the Authority. .

The controller shall provide the information and action requested in the request free of charge.  

If the data subject's request is manifestly unfounded or excessive, in particular due to its repetitive nature, the controller may charge a reasonable fee or refuse to act on the request, taking into account the administrative costs of providing the requested information or action or taking the requested action.

Palkonya, 27/10/2020