Privacy policy
Privacy Notice
Entry into force: 01.03.2019
Introduction
Pitkovjat Melinda Ev., Pitkovjat Viktor Ev., Fekete Mária Ev., Hosseinzadehbazargani Kamyar Ev. (hereinafter: Service Provider, data controller) submits to the following prospectus.
REGULATION (EU) No 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (on the protection of individuals with regard to the processing of personal data and on the free movement of such data) April 27, 2016) we provide the following information.
This privacy statement governs the privacy of the following pages:
The data management information is available from the following page: https://www.cliplove.hu/policies/privacy-policy
Changes to this prospectus will take effect upon publication at the above address.
Contact details for the data controller:
- Name: Pitkovjat Melinda Ev.
Headquarters: 1102 Budapest, Kőrösi Cs.S.út 15.
E-mail: info@cliplove.hu
- Name: Pitkovjat Viktor Ev.
Headquarters: 1102 Budapest, Kőrösi Cs.S.út 15.
E-mail: info@cliplove.hu
- Name: Black Mary Ev.
Headquarters: 1102 Budapest, Kőrösi Cs.S.út 15.
E-mail: info@cliplove.hu
- Name: Hosseinzadehbazargani Kamyar Ev.
Headquarters: 1051 Budapest, Nádor utca 23
E-mail: info@cliplove.hu
Concept definitions:
1. "personal data" shall mean any information relating to an identified or identifiable natural person ("data subject"); identify a natural person who, directly or indirectly, in particular by reference to one or more factors such as name, number, location, online identifier or physical, physiological, genetic, mental, economic, cultural or social identity of the natural person identifiable;
2. "processing" means any operation or set of operations on personal data or files, whether automated or non-automated, such as collecting, recording, organizing, segmenting, storing, transforming or altering, retrieving, accessing, transmitting or otherwise transmitting harmonization or interconnection, restriction, deletion or destruction;
3. "controller" 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 processing of personal data; where the purposes and means of the processing are defined by Union or Member State law, the controller or the specific criteria for the designation of the controller may be determined by Union or Member State law;
4. "processor" means any natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller;
5. "recipient" means a natural or legal person, public authority, agency or any other body to whom personal data are disclosed, 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 these public authorities must comply with the applicable data protection rules in accordance with the purposes of the processing;
6."consent of the data subject" means the voluntary, specific and duly informed expression 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 unambiguous statement of consent;
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 are transmitted, stored or otherwise handled.
Principles for the processing of personal data
Personal information:
(a) processed in a lawful and fair manner and in a manner which is transparent to the data subject ("lawfulness, fairness and transparency");
(b) collected only for specified, explicit and legitimate purposes and not treated in a way incompatible with those purposes; further processing for data purposes for archiving in the public interest, for scientific and historical research purposes or for statistical purposes shall not be considered incompatible with the original purpose in accordance with Article 89 (1) ("purpose limitation"); (c) be appropriate and relevant to the purposes for which they are processed and limited to what is necessary ("data saving");
(d) 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 data processing are erased or rectified without delay ("accuracy");
(e) 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 processed; personal data may be stored for a longer period only if the processing 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, in accordance with this Regulation; subject to the implementation of appropriate technical and organizational measures to protect their freedoms ("limited storage capacity");
(f) processed in such a way as to ensure adequate security of personal data, including protection against unauthorized or unlawful processing, accidental loss, destruction or damage to personal data, by means of appropriate technical or organizational measures ("integrity and confidentiality"); ).
The controller is responsible for compliance with the above and must be able to demonstrate such compliance ("accountability").
Data Management
Webshop data management
1. Fact of data collection, scope of data processed and purpose of data management:
| Personal information | The purpose of data management is |
| Username | Identify, allow registration. |
| Password | Provides secure access to the user account. |
| Surname and first name | Required to contact, purchase, and issue a valid invoice. |
| Email address | Stay in touch. |
| Phone number | Get in touch more efficiently with billing or shipping issues. |
| Billing name and address | Issuing a regular invoice, as well as creating the contract, defining its content, modifying it, monitoring its fulfillment, invoicing the resulting fees and enforcing the related claims |
| Shipping Name and Address | Allow home delivery. |
| Date of purchase / registration | Perform a technical operation. |
| IP address at time of purchase / registration | Perform a technical operation. |
Neither your username nor your email address requires personal information.
2. Stakeholders: All stakeholders registered / purchasing on the webshop website.
3. Duration of data management, deadline for deleting data: By deleting the registration immediately. Except in the case of accounting documents, as this information must be kept for 8 years in accordance with Section 169 (2) of Act C of 2000 on Accounting.
The accounting document (including the general ledger accounts, analytical and detailed records) directly and indirectly supporting the accounting records must be kept in a legible form for at least 8 years, in a retrievable manner 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 processing:
ˇ The data subject may request the controller to access, rectify, delete or restrict the processing of personal data concerning him or her, and
ˇ may object to the processing of such personal data, and
ˇ 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 processing of personal data, portability of data, protest against data processing can be initiated by the data subject in the following ways:
- by post to Kőrösi Cs.S.út 15, 1102 Budapest,
- by e-mail to info@cliplove.hu,
7. Legal basis for data processing: consent of the data subject, Article 6 (1) (a), Infotv. § 5 (1) and 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 process personal data that is technically necessary for the provision of the service in order to provide 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 the processing of personal data takes place only if it is necessary for the provision of the service and other purposes specified in this Act. necessary, but even in this case only to the extent and for the time necessary.
8. Please note that
ˇ data management is based on your consent.
ˇ is required to provide personal information so that we can fulfill your order.
ˇ Failure to provide information will result in us being unable to process your order.
The data processors used
Shipping
1 Activity performed by data processing: Delivery of goods, transportation
2. Name and contact details of the data processor:
Dpd Hungária Kft.
1134 Budapest, Váci út 33
Tel: 0615016200
3. The fact of data management, the scope of the processed 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 processing, deadline for deleting data: It lasts until the home delivery is completed.
7. Legal basis for data processing: User's consent, Article 6 (1) (a), Infotv. Section 5 (1).
Hosting Provider
1. Activity performed by the data processor: Hosting service
2. Name and contact details of the data processor:
Shopify Inc.
150 Elgin Street, Suite 800
Ottawa, ON K2P 1L4
Canada
3. Fact of data processing, scope of data processed: 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 processing, deadline for deletion of data: The data processing 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. The legal basis of the data processing: the consent of the User, the Infotv. § 5 (1), Article 6 (1) (a), and CVIII of 2001 on certain issues of electronic commerce services and information society services. Act 13 / A. § (3).
Handling cookies
1. Web store-specific cookies are so-called "cookies used for password-protected sessions", "shopping cart cookies" and "security cookies", the use of which does not require the prior consent of those involved.
2. The fact of data management, the scope of data managed: Unique identification number, dates, times
3. Stakeholders: All stakeholders who visit the website.
4. The purpose of data management is to identify users, record "shopping carts" and track visitors.
5. Duration of data management, deadline for deleting data:
| Cookie type | Legal basis for data management | Duration of data management | Managed data set |
| Session cookie | CVIII of 2001 on certain aspects of electronic commerce services and information society services. Act (Elkertv.) 13 / A. § (3) | The period of time until the end of the relevant visitor session | connect.sid |
6. Identity of potential data controllers entitled to access the data: The data controller does not process personal data using cookies.
7. Description of data subjects' rights regarding data management: The data subject has the option to delete cookies in the Tools / Settings menu of the browser, usually under the settings of the Privacy menu item.
8.Legal basis for data processing: 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 provision of an information society service explicitly requested by the subscriber or user
Use Google Adwords Conversion Tracking
1. The online advertising program called "Google AdWords" is used by the data controller and uses Google's conversion tracking service. Google Conversion Tracking is an analytics service provided by Google Inc. (1600 Amphitheater Parkway, Mountain View, CA 94043, USA; "Google").
2. When a User accesses a website via a Google ad, a cookie is placed on their computer to track conversions. These cookies have a limited validity and do not contain any personal data, so the User cannot be identified by them.
3. When the User browses certain pages of the website and the cookie has not expired, both Google and the data controller may see that the User has clicked on the advertisement.
4. Each Google AdWords customer receives a different cookie, so they cannot be tracked through AdWords customers' websites.
5. The information obtained through conversion tracking cookies is used to generate conversion statistics for AdWords conversion tracking customers. This is how customers find out the number of users who clicked on your ad and sent to the page labeled conversion tracking. However, they do not have access to any information that could identify any user.
6. If you do not wish to participate in conversion tracking, you can disable it by disabling cookies in your browser. You will then not be included in your conversion tracking statistics.
7. For more information and Google's privacy statement, visit www.google.de/policies/privacy/
Using 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 the website analyze how users use the site.
2. The information generated by the cookie about the website used by you is typically stored and stored on a Google server in the USA. By activating IP anonymisation on the Website, Google will shorten the User's IP address within the European Union or in other states party to the Agreement on the European Economic Area.
3. The full IP address will only be transmitted and truncated to Google's server in the United States. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.
4. Google Analytics does not reconcile the IP address transmitted by the User's browser with any other data held by Google.You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. Your website usage information (including your IP address) by downloading and installing the browser plugin at the following link. https://tools.google.com/dlpage/gaoptout?hl=en
Newsletter, DM activity
1. Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Commercial Advertising Pursuant to Section 6 of the Act, the User may consent in advance and expressly to contact the Service Provider with the advertising offers and other items provided at the time of registration.
2. Furthermore, the Customer may consent to the processing of the personal data of the Service Provider necessary for the sending of the advertising offers, keeping in mind the provisions of this prospectus.
3. The Service Provider does not send unsolicited advertising messages, and the User may unsubscribe from sending offers free of charge without restriction or justification. In this case, the Service Provider will delete all personal data - necessary for sending advertising messages - from its register and will 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 information | The purpose of data management is |
| Name, email address. | Identify, allow you to subscribe to the newsletter. |
| 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 information about current information, products, promotions, new features, etc.
7. Duration of the data processing, deadline for deleting the data: the data processing lasts until the withdrawal of the consent statement, ie until the unsubscription.
8. Data management registration number: in progress ...
9. 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.
10. Description of data subjects' rights in relation to data processing:
ˇ The data subject may request the controller to access, rectify, delete or restrict the processing of personal data concerning him or her, and
ˇ may object to the processing of such personal data, and
ˇ the data subject has the right to data portability and to withdraw his or her consent at any time.
11. Access to, deletion, modification or restriction of the processing of personal data, portability of data, protest against data processing can be initiated by the data subject in the following ways:
- by post at the address 15 Kőrösi Cs.S.út, 1102 Budapest,
- by e-mail to info@cliplove.hu
12. You can unsubscribe from the newsletter at any time, free of charge.
13. Legal basis for data processing: consent of the data subject, Article 6 (1) (a), Infotv. 5.§ (1) and Act XLVIII of 2008 on the basic conditions and certain restrictions of commercial advertising activities. Section 6 (5) of the Act:
The advertiser, the advertising service provider and the publisher of the advertisement shall keep records of the personal data of the persons who have made a statement to them, within the scope specified in the consent. The data contained in this register concerning the recipient of the advertisement may be processed only in accordance with the statement of consent until it is withdrawn and may only be disclosed to third parties with the prior consent of the person concerned.
14. Please note that
ˇ data management is based on your consent.
ˇ is required to provide personal information if you wish to receive a newsletter from us.
ˇ Failure to provide information will result in us not being able to send you a newsletter.
Complaint handling
1. Fact of data collection, scope of data processed and purpose of data management:
| Personal information | The purpose of data management is |
| Surname and first name | Identification, contact. |
| Email address | Stay in touch. |
| Phone number | Stay in touch. |
| Billing name and address | Identification, handling of quality complaints, questions and issues related to the products ordered. |
2. Stakeholders: All stakeholders who buy on the webshop website and complain about quality.
3. Duration of data processing, deadline for deletion of data: Copies of the record, transcript and response to the complaint have been issued in accordance with CLV Act 1997 on Consumer Protection. Act 17 / A. § (7) shall be kept for 5 years.
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 processing:
ˇ The data subject may request the controller to access, rectify, delete or restrict the processing of personal data concerning him or her, and
ˇ may object to the processing of such personal data, and
ˇ 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 processing of personal data, portability of data, protest against data processing can be initiated by the data subject in the following ways:
- by post at the address 15 Kőrösi Cs.S.út, 1102 Budapest,
- by e-mail to info@cliplove.hu
7. Legal basis for data processing: consent of the data subject, Article 6 (1) (a), Infotv. § 5 (1) and the CLV of 1997 on consumer protection. Act 17 / A. § (7).
8. Please note that
ˇ the provision of personal data is based on a contractual obligation.
ˇ The processing of personal data is a precondition for concluding a contract.
ˇ is required to provide personal information so that we can handle your complaint.
ˇ Failure to provide information will result in us not being able to process your complaint.
Social Pages
1. The fact of data collection, the range of data managed: Facebook / Google + / Twitter / Pinterest / Youtube / Instagram, etc.registered name on social networking sites 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. The purpose of data collection is to share or "like" certain content elements, products, promotions or the website itself on social networking sites.
4. Duration of data processing, deadline for deletion of data, identity of potential data controllers entitled to access the data and data subjects' rights related to data processing: The data subject may be informed about the source of the data, their processing and the legal basis. 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 governed by the regulations of the given social networking site.
5. Legal basis for data processing: the voluntary consent of the data subject to the processing of his or her personal data on social networking sites.
Customer Relationships and Other Data Management
1. Should you have any questions or problems with the use of our data management services, you may contact the data controller in the ways provided on the website (telephone, e-mail, social networking sites, etc.).
2. Data controller for incoming emails, messages, phone, Facebook, etc. will delete the data provided together with the name and e-mail address of the interested party and any other personal data voluntarily provided after a maximum of 2 years from the date of disclosure.
3. Information on data processing not listed in this prospectus will be provided at the time of data collection.
4. In the event of an exceptional official request or the request of other bodies based on the authorization of legislation, the Service Provider is obliged to provide information, disclose data, or make documents available.
5. In such cases, the Service Provider shall release personal data to the requester only if and to the extent that it is essential for the realization of the purpose of the request.
Rights of data subjects
1. Access right
You have the right to receive feedback from the controller as to whether your personal data is being processed and, if such processing is in progress, you have the right to access the personal data and information listed in the Regulation.
2. Right to rectify
You have the right to have inaccurate personal data about the data controller rectified without undue delay upon request. Taking into account the purpose of the data processing, you have the right to request that the incomplete personal data be supplemented, inter alia, by means of an additional statement.
3. Right to delete
At your request, the data controller has the right to delete personal data concerning him or her without undue delay, and the data controller is obliged to delete personal data concerning you without undue delay under certain conditions.
4.The right to be forgotten
If the controller has disclosed personal data and is obliged to delete it, it shall take reasonable steps, taking into account the technology available and the cost of implementation, to take technical measures to inform the controllers that you have requested the personal data in question. deleting links to data or a copy or duplicate of such personal data
5. Right to restrict data processing
You have the right, at the request of the controller, to restrict the processing of data if one of the following conditions is met:
ˇ You dispute the accuracy of the personal data, in which case the restriction applies to the period of time that allows the controller to verify the accuracy of the personal data;
ˇ the processing is illegal and you oppose the deletion of the data and instead ask for a restriction on its use;
ˇ the data controller no longer needs personal data for data processing purposes, but you do so in order to make, enforce or protect legal claims;
ˇ You objected to the data processing; in this case, the restriction shall apply 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 to a data controller in a structured, widely used machine-readable format and to transfer this data to another data controller without being prevented from doing so by the data controller. , to whom you have provided personal data (...)
7. Right to protest
You have the right to object at any time to the processing of your personal data (...), including profiling based on these provisions, for reasons related to your situation.
8. Protest in case of direct business acquisition
If your personal data is processed for the purpose of direct business acquisition, you have the right to object at any time to the processing of your personal data for that purpose, including profiling, insofar as it relates to direct business acquisition. If you object to the processing of your personal data for the purpose of direct business acquisition, your personal data may no longer be processed 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 or similar effect on him or her.
The previous paragraph does not apply if the decision is
ˇ Necessary for the conclusion or performance of a contract between you and the data controller;
ˇ is governed by EU or national law applicable to the controller, which also lays down appropriate measures to protect your rights and freedoms and legitimate interests; or
ˇ Based on your express consent.
Deadline for action
The controller shall 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, this can be extended by 2 months.The data controller shall inform you of the extension of the deadline within 1 month from the receipt of the request, indicating the reasons for the delay.
If the controller does not take action on your request, it 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 recourse to the courts.
Security of data management
The controller and the processor shall take appropriate technical and organizational measures, taking into account the state of the art and the costs of implementation and the nature, scope, circumstances and purposes of the processing and the varying probability and severity of the risk to the rights and freedoms of natural persons. in order to guarantee a level of data security commensurate with the degree of risk, including, where appropriate:
(a) the pseudonymisation and encryption of personal data; (b) ensuring the continued confidentiality, integrity, availability and resilience of the systems and services used to process personal data; (c) in the event of a physical or technical incident, the ability to restore access to and availability of personal data in a timely manner; (d) a procedure for the regular testing, evaluation and evaluation of the effectiveness of the technical and organizational measures taken to ensure the security of data processing.
Inform the data subject about the privacy incident
If a data protection incident is likely to pose a high risk to the rights and freedoms of natural persons, the 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 for further information; the likely consequences of the data protection incident must be described; a description of the measures taken or planned by the controller to remedy the data protection incident, including, where appropriate, measures to mitigate any adverse consequences of the data protection incident.
The data subject need not be informed if any of the following conditions are met:
ˇ the 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 incomprehensible to persons not authorized to access personal data make the data;
ˇ the data controller has taken additional 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;
ˇ 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 the data subject to be informed
Report a privacy incident to the authority
The data protection incident shall be reported by the controller to the competent supervisory authority in accordance with 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 pose a risk to the data subject. the rights and freedoms of natural persons. If the notification is not made within 72 hours, the reasons for the delay must be provided.
Possibility to complain
Complaints against a possible breach of the data controller can be lodged with the National Data Protection and Freedom of Information Authority:
National Authority for Data Protection and Freedom of Information
1125 Budapest, Szilágyi Erzsébet fasor 22 / C.
Mailing address: 1530 Budapest, PO Box: 5.
Phone: +36 -1-391-1400
Fax: + 36-1-391-1410
E-mail: ugyfelszolgalat@naih.hu
Closing word
During the preparation of this prospectus, we complied with the following legislation:
- REGULATION (EU) No 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the protection of individuals with regard to the processing of personal data and on the free movement of such data (April 27, 2016)
- 2011 CXII. Act on the Right to Self-Determination of Information and Freedom of Information (hereinafter: the Information Act)
- 2001 CVIII. Act on certain issues of electronic commerce services and services related to the information society (especially Section 13 / A)
- 2008 XLVII Act on the Prohibition of Unfair Commercial Practices for 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
- Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 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 on the exclusion of
Date: 03.01.2019
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