Privacy Policy

The data controller of Cinemax – Insta – Media Limited Liability Company (company registration number: 01-09-908314, tax number: 14536702-2-42, registered office: 1062 Budapest, Andrássy út 92-94. Fszt.6.) submits to the following privacy policy.
During the preparation of the prospectus, we took into account the following legislation:

  • Regulation on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing the 95/46 EC Regulation(general data protection regulation) REGULATION (EU) No 2016/679 (27 April 2016) OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
  • 2011 CXII. Act – on the right to information self-determination and freedom of information (hereinafter: Info-act.)
  • 2001 CVIII. Act – on certain issues of electronic commerce services and services related to the information society (mainly Section 13 / A)
  • XLVII of 2008. Act on the Prohibition of Unfair Commercial Practices against Consumers;
  • 2008 XLVIII. Act – on the basic conditions and certain restrictions of commercial advertising (especially § 6)
  • 2005 XC. Electronic Freedom of Information Act
  • Act C of 2003 on Electronic Communications (specifically § 155)
  • 16/2011. s. Opinion on the EASA / IAB Recommendation on Best Practices for Behavioral Online Advertising
  • Recommendation of the National Authority for Data Protection and Freedom of Information on data protection requirements for prior information

On the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Regulation (EC) No 95/46 (General Data Protection Regulation) REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 2016 27.) we provide the following information.

This data management information regulates the data management of the following pages: https://pickpacktrockner.hu./

The data management information is available on the following page: https://pickpacktrockner.hu./adatvedelem
Amendments to the prospectus will take effect upon publication at the above address.

Data controller and contact details:

Name of the service provider: Cinemax – Insta – Media Limited Liability Company
Company registration number: 01-09-908314
Tax number: 14536702-2-42
Language of the contract: Hungarian
Phone number: 06302933986
Web address: www.pickpacktrockner.hu

Concept definitions

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

2. “data controlling/managing” means any operation or set of operations on personal data or files, whether automated or non-automated, such as collection, recording, systematisation, sorting, storage, transformation or alteration, retrieval, consultation, use, communication, transmission or dissemination; by other means of access, coordination or interconnection, restriction, deletion or destruction;

3. “data controller/manager” means the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the handling of personal data; where the purposes and means of the data handling are determined by Union or Member State law, the controller or the specific criteria for the designation of the controller may also be determined by Union or Member State law;

4. “data processor” means any natural or legal person, public authority, agency or any other body which processes personal data on behalf of the data controller;

5. “recipient” means a natural or legal person, public authority, agency or any other body to whom personal data are communicated, whether a third party or not. Public authorities that may have access to personal data in the framework of an individual investigation in accordance with Union or Member State law shall not be considered as recipients; the processing of such data by those public authorities must comply with the applicable data protection rules in accordance with the purposes of the processing;

6. “data subject’s consent” means the voluntary, specific and duly informed and unambiguous statement of the data subject’s intention, by means of a statement or unequivocal statement of consent, to consent to the handling of personal data concerning him or her;

7. “data protection incident” means a breach of security resulting in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or unauthorized access to, personal data which have been transmitted, stored or otherwise handled.

Principles for the managing of personal data

Personal data:

a. they must be managed lawfully and fairly and in a manner that is transparent to the data subject (“legality, fair process and transparency”);

b. they should be collected only for specified, explicit and legitimate purposes and not treated in a way incompatible with those purposes; further data managing for archiving in the public interest, for scientific and historical research purposes or for statistical purposes (“purpose limitation”) shall not be considered incompatible with the original purpose in accordance with Article 89 (1);

c. they must be appropriate and relevant to the purposes of the data managing and limited to what is necessary (“data saving”);

d. they must be accurate and, where necessary, kept up to date; all reasonable steps must be taken to ensure that personal data which are inaccurate for the purposes of the managing are erased or rectified without delay (“accuracy”);

e. they must be stored in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are managed; personal data may be stored for a longer period only if the managing of personal data is carried out in accordance with Article 89 (1) for archiving in the public interest, for scientific and historical research purposes or for statistical purposes,and, in accordance with this Regulation, considering the implementation of appropriate technical and organizational measures to protect the rights and freedoms of the data subjects(“limited storage”);

f. they shall be handled in such a way as to ensure the adequate security of personal data, including protection against unauthorized or unlawful handling, accidental loss, destruction or damage to personal data (“integrity and confidentiality”), using appropriate technical or organizational measures.

The data controller is responsible for compliance with the above and must be able to demonstrate such compliance (“accountability”).

Data management

Data management related to the operation of a web store

1. Fact of data collection, scope of the managed data and purpose of data management:

Personal data Purpose of data management
Provides secure access to the user account. Article 6 (1) (b) of the GDPR and Elker act. 13 / A. § (3).
Surname and first name It is necessary for contacting us, making a purchase, issuing a regular invoice, exercising the right of withdrawal. Article 6 (1) (b) of the GDPR and Elker act. 13 / A. § (3).
E-mail address Contact, billing or shipping issues more effectively.
Billing name and address Assurance of a regular invoice, as well as creation of the contract, determination of its content, modification, monitoring of its fulfillment, invoicing of the fees arising from it, and enforcement of the related claims. Article 6 (1) (c) and Section 169 (2) of Act C of 2000 on Accounting
Delivery name and address Allow home delivery. Article 6 (1) (b) of the GDPR and Elker tv. 13 / A. § (3).
Date of purchase / registration Perform a technical operation. Article 6 (1) (b) of the GDPR and Elker tv. 13 / A. § (3).
The IP address at the time of purchase / registration Perform a technical operation. Article 6 (1) (b) of the GDPR and Elker tv. 13 / A. § (3).

Email address does not need to contain personal information.

2. Stakeholders: All stakeholders registered / buyers on the webshop website.

3. Duration of data management, deadline for deleting data: Immediately by deleting the registration. The controller shall inform the data subject electronically pursuant to Article 19 of the GDPR of the deletion of any personal data provided by the data subject. If the data subject’s request for cancellation also covers the e-mail address provided by the data subject, the data controller will also delete the e-mail address after the notification. Except in the case of accounting documents, as these data must be kept for 8 years pursuant to Section 169 (2) of Act C of 2000 on Accounting.

The accounting document (including general ledger accounts, analytical and detailed records) supporting the accounting accounts, directly and indirectly, must be kept in a legible form for at least 8 years, retrievable by reference to the accounting records.

4. Identity of potential data controllers entitled to access the data, recipients of personal data: Personal data may be processed by the data controller’s sales and marketing staff, respecting the above principles.

5. Description of data subjects’ rights in relation to data managing:

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

6. Access to, deletion, modification or restriction of the managing of personal data, portability of data, protest against data managing may be initiated by the data subject in the following ways:

  • by post at 1062 Budapest, Andrássy út 92-94. fszt.6. at
  • by e-mail to cinemaxfilmstudio@gmail.com,
  • by telephone on 06302933986.

7. Legal basis for data processing:
Article 6 (1) (b) of the GDPR,

7. 1 Act CVIII of 2001 on certain issues of electronic commerce services and information society services. Act (hereinafter: Elker Act) 13 / A. § (3):

The service provider may manage personal data that are technically necessary for the provision of the service for the purpose of providing the service. If the other conditions are the same, the service provider must choose and in all cases operate the means used in the provision of the information society service in such a way that personal data are managed only if it is necessary for the provision of the service and other purposes specified in this Act., but in this case, too, only to the extent and for the time necessary.

7. 2 Article 6 (1) (c) if an invoice is issued in accordance with accounting legislation.

7. 3 In the case of enforcement of claims arising from the contract, Act V of 2013 on the Civil Code 6:21. § 5 years.

6:22. § [Obliteration]

(1) Unless otherwise provided by this Act, claims shall lapse within five years.

(2) The lapsing period shall begin when the claim becomes due.

(3) An agreement to change the lapsing period shall be in writing.

4. An agreement precluding obliteration shall be null and void.

7. 4. Please be informed that

      • the data management is necessary for the performance of the contract.
      • it is required to provide personal data so that we can fulfill your order.
      • lack of providing data information will result in the inability to manage your order.


The data processors used

Transport

1. Activity performed by data processor: Delivery of products, transportation

2. Name and contact details of the data processor:

WEBSHIPPY Hungary Logistics and Transporting Limited Liability Company
Company registration number: 01-09-282775
Tax number: 25569421-2-41
Headquarters: 1044 Budapest, Ezred utca 2. B2. building 13

3. The fact of data management, the scope of the managed data: Delivery name, delivery address, telephone number, e-mail address.

4. Stakeholders: All stakeholders requesting home delivery.

5. Purpose of data management: Home delivery of the ordered product.

6. Duration of data management, deadline for deleting data: It lasts until the home delivery is completed.

7. Legal basis for data processing: Article 6 (1) (b)

Hosting provider

1. Activity performed by data processor: Hosting service

2. Name and contact details of the data processor:

Hostingbazis Bt.
4642 Tornyospálca, Mándoki utca 40.
info@hostingbazis.hu

3. Fact of data managing, scope of the managed data: All personal data provided by the data subject.

4. Stakeholders: All stakeholders who use the website.

5. The purpose of data management: To make the website available and to operate it properly.

6. Duration of data managing, deadline for deletion of data: The data managing lasts until the termination of the agreement between the data controller and the hosting provider, or until the data subject’s request for deletion to the hosting provider.

7. Legal basis for data processing: Article 6 (1) (c) and (f) and Act. CVIII of 2001, A13 /. § 3 on certain aspects of electronic commerce services and information society services. There is a legitimate interest in the proper operation of the website, protection against attacks and fraud.


Recipients to whom personal data are communicated (Data transfer):

Online payment

1. Activity by the Recipient: Online payment

2. Name and contact details of the recipient:

K&H Bank Zrt.
Kereskedelmi és Hitelbank Zártkörűen Működő Részvénytársaság
Company registration number: 01-10-041043
Tax number: 10195664-4-44
Headquarters/Registered office: 1095 Budapest, Lechner Ödön fasor 9.

3. The fact of data management, the scope of data managed: Billing data, name, e-mail address

4. Stakeholders: All stakeholders who choose to pay on the website.

5. Purpose of data management: to effect online payments, confirm transactions and fraud monitoring in order to protect users.

6. Duration of data management, deadline for deleting data: It lasts until the online payment is completed.

7. Legal basis for data processing: Article 6 (1) (b) GDPR. Data managing is required to make an online payment at the request of the data subject.

8. Rights of the data subject:

  • You can inquire about the conditions of data management,
  • You have the right to receive feedback from the data controller as to whether your personal data are being managed and to have access to all information related to the data managing.
  • You have the right to receive your personal data concerning you in a structured, widely used, machine-readable format.
  • You have the right, that at your request the data controller shall correct inaccurate personal data without undue delay.

With credit card payment, You can shop conveniently and securely in our web-store. After ordering the selected goods, You will be directed to the K&H Bank website, where You can pay with your bank card via the encrypted transaction currently used by the Bank, which is considered the most secure. All our customers have to do is click on “pay by credit card” when selecting the payment method, and then enter the card number, expiration date and three-digit security code on K&H Bank’s payment server. K&H Bank accepts VISA, VISA Electron, V-Pay, MasterCard, Maestro and JCB cards.

Bank cards issued exclusively for electronic use can only be accepted if their use is authorized by the bank issuing the card! Please check with your bank to see if your card can be used for online purchases.

After a successful purchase, K&H Bank will issue an authorization number for the transaction, which is worth writing down or printing out the entire page. In case of an unsuccessful transaction, K&H Bank will state the reason for the error in an error message.

Management of cookies

1. Web store-specific cookies are so-called “cookies used for password-protected working process”, “shopping cart cookies” and “security cookies”, the use of which does not require the prior consent of the data subjects.

2. The fact of data management, the scope of the managed data: Unique identification number, dates, times

3. Stakeholders: All stakeholders who visit the website.

4. Purpose of data management: To identify users, record the “shopping cart” and track visitors.

5. Duration of data managing, deadline for deleting data:

Cookie type Legal basis for data management Data handling Managed data set
Session cookies Act 2001 CVIII (Elkertv.) 13 / A. § (3) on certain issues of electronic commerce services and information society services. the period until the end of the relevant visitor session connect.sid

For other cookies, the cancellation period is 30 days.

6. Identity of potential data controllers entitled to access the data: The data controller does not process personal data using cookies.

7. Description of the data subjects’ rights related to data management: The data subject has the possibility to delete cookies in the Tools / Settings menu of browsers, usually under the settings of the Privacy menu item.

8. Legal basis for data managing: The consent of the data subject is not required if the sole purpose of the use of cookies is the transmission of communications over an electronic communications network or the service provider absolutely needs it in order to provide the service related to the information society specifically requested by the subscriber or user.

Applying Google Analytics

1. This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses so-called “cookies”, which are text files placed on your computer, to help analyze how users use the site.

2. The informations created by the cookies about the website used by the user will normally get and be stored on a Google server in the USA. By activating IP anonymization on the Website, Google will shorten the User’s IP address within the Member States of the European Union or in other States party to the Agreement on the European Economic Area.

3. The full IP address will be transmitted to the Google’s server in the United States and truncated there only in exceptional cases. On behalf of the operator of this website, Google will use this information to evaluate how the user has used the website, to provide the website operator with reports on website activity and to provide additional services related to website and internet usage.

4. Within the framework of Google Analytics, the IP address transmitted by the User’s browser is not reconciled with other data of Google. The User may prevent the storage of cookies by setting their browser accordingly, however, please note that in this case, not all functions of this website may be fully available. The user may also prevent Google from collecting and processing informations about the use of the Website by the user by cookies (including his/her IP address) by downloading and installing the browser plugin available at the following link. https://tools.google.com/dlpage/gaoptout?hl=US

Newsletter, DM activity

1.Pursuant to Section 6 of the Act XLVIII of 2008 on the basic conditions and certain restrictions of economic advertising activity. the User may consent in advance and expressly to the Service Provider’ contacting him/her with his advertising offers and other items at the contact details provided during registration.

2. Furthermore, keeping in mind the provisions of this prospectus, the Customer may consent to the Service Provide’s handling the personal data necessary for sending advertising offers.

3. The Service Provider does not send unsolicited advertising messages, and the User may unsubscribe from sending offers free of charge without restriction or explanation. In this case, the Service Provider deletes all personal data – necessary for sending advertising messages – from its register and does not contact the User with its further advertising offers. The user can unsubscribe from the ads by clicking on the link in the message.

4. Fact of data collection, scope of data processed and purpose of data management:

Personal data Purpose of data management Legal basis for data management
Name, e-mail address. Identification, allowing you to subscribe to the newsletter / promotional coupons. The consent of the data subject,
Article 6 (1) (a).Section 6 (5) of Act XLVIII
of 2008 on the basic conditions and certain restrictions of economic advertising activity.
Date of subscription Perform a technical operation. „ „ „
The IP address at the time of subscription Perform a technical operation. „ „ „

5. Stakeholders: All stakeholders who subscribe to the newsletter.

6. The purpose of data management: to send electronic messages containing advertising (e-mail, sms, push message) to the data subject, to provide details on current informations, products, promotions, new features, etc.

7. Duration of the data managing, deadline for deleting the data: the data managing lasts until the withdrawal of the consent statement, ie until the unsubscription.

8. Identity of potential data controllers entitled to access the data, recipients of personal data: Personal data may be managed by the data controller’s sales and marketing staff, respecting the above principles.

9. Description of data subjects’ rights in relation to data management:

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

10. Access to, deletion, modification or restriction of the managing of personal data, portability of data, protest against data managing can be initiated by the data subject in the following ways:

  • by post at 1062 Budapest, Andrássy út 92-94. fszt.6. at
  • by e-mail to cinemaxfilmstudio@gmail.com,13. by phone at 06302933986.

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

12. Please be informed that

  • data management is based on your consent.
  • you must provide personal information if you wish to receive a newsletter from us.
  • failure to provide this will result in us not being able to send you a newsletter.
  • the withdrawal of the consent does not affect the lawfulness of the data managing based on the consent prior to the withdrawal.

Complaint handling

1. Fact of data collection, scope of managed data and purpose of data management:

Personal data Purpose of data management Legal basis for data management
Surname and first name Identification, contact. Article 6 (1) (c) and Act CLV 1997. 17 / A. § (7).on Consumer Protection.
E-mail address „ „ „ „ „ „
Billing name and address Identification, handling of quality objections, questions and problems related to the ordered products. „ „ „

2. Stakeholders: All stakeholders who buy on the webshop website and complain about quality insufficiencies.

3. Duration of data processing, deadline for deletion of data: on the strength of Act CLV 1997 17 / A. § (7) on Consumer Protection copies of the recorded complaint, transcript and response to the objection are contained in shall be kept for 5 years.

4. Identity of potential data controllers entitled to access to the data, recipients of personal data: Personal data may be managed by the data controller’s sales and marketing staff, respecting the above principles.

5. Description of data subjects’ rights in relation to data managing:

The data subject may request from the controller access to, rectification, erasure or restriction of the managing of personal data concerning him or her, and

  • the data subject has the right to data portability and to withdraw his or her consent at any time.

6. Access to, deletion, modification or restriction of the managing of personal data, portability of data, protest against data managing may be initiated by the data subject in the following ways:

  • by post at 1062 Budapest, Andrássy út 92-94. fszt.6. at
  • by e-mail to cinemaxfilmstudio@gmail.com,
  • by phone at 06302933986.

7. Please be informed that

  • the provision of personal data is based on a contractual and legal obligation.
  • the managing of personal data is a precondition for concluding a contract.
  • you are obliged to provide personal information so that we can handle your complaint.
  • failure to provide information has the consequence that we are unable to handle your complaint.

Community sites

1. The fact of data collection, the scope of the managed data: registered name of the user on social networking sites Facebook / Google + / Twitter / Pinterest / Youtube / Instagram, etc. and the user’s public profile picture.

2. Stakeholders: All stakeholders who have registered on Facebook / Google + / Twitter / Pinterest / Youtube / Instagram, etc. social networking sites and “liked” the website.

3. Purpose of data collection: On social networking sites, to share or “like” certain content elements, products, promotions or the website itself.

4. Duration of data managing, deadline for erasure of data, identity of potential data controllers entitled to access the data and description of data subjects’ rights related to data managing: The data subject may be informed about the source of data, their handling, about the method of their passing and its legal basis on social networking sites. Data management is carried out on social networking sites,so the duration and method of data management, as well as the possibilities of deleting and modifying data are regulated by the given social networking site.

5. Legal basis for data processing: the data subject’s voluntary consent to the managing of his or her personal data on social networking sites.

Customer relations and other data management

1. Should the data subject have any questions or problems during the use of our data management services, the data subject may contact the data controller in the ways provided on the website (telephone, e-mail, social networking sites, etc.).

2. Data controller will delete incoming e-mails, messages, data given by phone, Facebook, etc. provided together with the name and e-mail address of the interested party, as well as other personal data voluntarily provided, no later than 2 years after the communication.

3. We provide information on data handlings not listed in this prospectus at the time of the data registration.

4. Upon an exceptional official request, or in case of request of other bodies based on the authorization of legislation, the Service Provider is obliged to provide information, communicate and hand over data, or make documents available.

5. In these cases, the Service Provider shall provide the requester with personal data only to the extent that is absolutely necessary for the realization of the purpose of the request, provided that it has indicated the exact purpose and scope of the data.

Rights of data subjects

1. Right of access

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

2. Right to rectification

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

3. Right of cancellation

You have the right, that at the your request the controller deletes your personal data without undue delay, and the controller is obliged to delete your personal data without undue delay under certain conditions.

4. The right to be forgotten

If the data controller has disclosed the personal data and is obliged to delete it, he/she shall take reasonable steps, including technical measures, taking into account the available technology and the cost of implementation on order to inform the controllers that you have requested the deletion of the links related to your personal data in question and deletion of copies or duplicates of such personal data.

5. Right to restrict data managing

You have the right, that at your request the data controller restricts the data managing if one of the following conditions is met:

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

6. The right to data portability

You have the right to receive personal data about you provided by you to a data controller in a structured, widely used machine-readable format and to transfer these data to another data controller without being hindered by the data controller for whom you first made your personal data available.

7. Right to protest

You have the – for reasons related to your own situation – to object at any time to the managing of your personal data, including profiling based on these provisions,

8. Protest in case of direct business acquisition

If personal data is managed for the purpose of direct business acquisition, you have the right to object at any time to the managing of personal data concerning you for this purpose, including profiling, if it is related to direct business acquisition. If you object to the managing of personal data for the purpose of direct business acquisition, the personal data must no longer be managed for this purpose.

9. Automated decision making in individual cases, including profiling

You have the right not to be covered by a decision based solely on automated data processing, including profiling, which would have legal effect on you or affects you considerably.

The preceding paragraph shall not apply if the decision:

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

Deadline for action

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

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

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

Security of data management

The data controller and the data processor- taking into account the state of science and technology and the costs of implementation, as well as the nature, scope, circumstances and purposes of the data managing and the varying likelihood and severity of risks to the rights and freedoms of natural persons – shall take appropriate technical and organizational measures in order to guarantee a level of data security appropriate to the degree of risk, including, inter alia, where appropriate:

  1. the pseudonymisation and encryption of personal data;
  2. ensuring the continued confidentiality, integrity, availability and resilience of systems and services used to manage personal data;
  3. in the event of a physical or technical incident, the ability to restore access to and availability of personal data at the proper time;
  4. a procedure for regular testing, assessment and evaluation of the effectiveness of the technical and organizational measures taken to ensure the security of data processing.

The site uses SSL encryption. The data is password protected and stored encrypted.

Informing the data subject about the data protection incident

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

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

The data subject needs not be informed if any of the following conditions is 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 protection incident, in particular measures such as the use of encryption which make it inpossible for persons not authorized to access to personal data to interpret these data;
  • the data controller has taken further measures following the data protection incident to ensure that the high risk to the data subject’s rights and freedoms is no longer likely to materialize;
  • information would require a disproportionate effort. In such cases, data subjects shall be informed through publicly available information or a similar measure shall be taken to ensure that data subjects are informed in an equally effective manner.

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

Report a privacy incident to the authority

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

Review in case of mandatory data management

If the duration of the mandatory data managing or the periodic review of the need for it is not specified by law, a local government decree or a mandatory legal act of the European Union, the data controller shall review at least every three years after begin of the data managing whether the managing of personal data by him/her or by the data processor entrusted by him/her is necessary for the purpose of data managing.

The circumstances and results of this review shall be documented by the data controller, which shall keep this documentation for ten years after the review and shall make it available to the Authority upon request of the National Data Protection and Freedom of Information Authority (hereinafter: the Authority).

Possibility to complain

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

National Data Protection and Freedom of Information Authority
1125 Budapest, Szilágyi Erzsébet avenue 22 / C.
Mailing address: 1530 Budapest, Mailbox: 5.
Phone: +36 -1-391-1400
Fax: + 36-1-391-1410
E-mail: ugyfelszolgalat@naih.hu