Technical Support (on weekdays 8:00-17:00 Budapest time): +36 1 533 31 20

Technical Support: +36 1 533 31 20 (on weekdays 8:00-17:00 Budapest time) or [email protected]

Terms of purchase

General terms and conditions
Privacy Policy
General terms and conditions
Terms and Conditions

Terms and Conditions

GENERAL CONDITIONS OF CONTRACT

1. WEBSHOP, CONTRACTED PARTNERS

1.1 The Webshop (hereinafter ’Webshop’) is operated by T.EL.L. SOFTWARE HUNGARIA Szoftver-fejlesztő és Szolgáltató Korlátolt Felelősségű Társaság (T.E.L.L. SOFTWARE HUNGARIA Software Development and Service Provider Co. Ltd, Company seat: 4034 Debrecen, Vágóhíd utca 2, trade register number: 09-09-005193; registered at Debrecen Court of Law as registry court; tax number: 12203949-2-09; phone number:+36-52/530-130, fax number: +36-52/530-131, e-mail address: [email protected], web page: www.tell.hu) accesible on its website http://tell.hu (hereinafter: Website) and by T.E.L.L. Biztonságtechnikai Rendszerek Kereskedelmi és Szolgáltató Korlátolt Felelősségű Társaság (T.E.L.L. Safety Engineering Systems Trading and Service Providing Co. Ltd, Company seat: 4034 Debrecen, Vágóhíd utca 2.; trade register number: 09-09-027345; registered at Debrecen Court of Law as registry court; tax number: 25406812-2-09; phone number:+36-52/530-130, fax number: +36-52/530-131, e-mail address: [email protected], hereinafter together: T.E.L.L. Kft.) for the purpose of online selling of T.EL.L. SOFTWARE HUNGARIA Kft. products.

 

1.2 Particulars of the web hosting service: 

UNAS Online Kft. (UNAS Online Co. Ltd)

9400 Sopron, Kőszegi út 14.

email: [email protected]

 

1.3 The operation of the Webshop qualifies as providing electronic trade service. Conditions of using the Webshop, rights and obligations of T.E.L.L. Kft. and Buyers are stipulated in this General Conditions of Contract (GCC). 

2. REGISTRATION 

2.1 Only registered buyers (hereinafter: Buyers) can order products from the Webshop.  

 

2.2 Registration for the Webshop can be made on the Homepage. For doing so, the following particulars are necessary: name, company name, e-mail address, phone number of contact person. The registree is also required to provide information where he has heard about the Webshop. After registration, the personal account of the Buyer will be immediately established. 

 

2.3 The Buyer can modify their particulars given at the registration any time.  

 

2.4 The Buyer can delete his personal account anytime. T.E.L.L. Kft. will send a notification of the account deletion to the e-mail address given by the Buyer.  

3. DISPLAY OF PRODUCTS AND PRICES IN THE WEBSHOP

3.1 The Buyer can order the products (hereinafter: Product or Products) from T.E.L.L. Kft that are indicated in the current offerings of the Webshop. 

 

3.2 The Products are offered with their main characteristics, article number and short description.

 

3.3 Along with the Product its current gross price will be indicated, which is considered the final consumer’s price. The net price is also specified in the detailed information of the Products. Delivery costs are not included in prices. 

 

3.4 In case of Products offered at discount prices the actual discount rate is indicated. The original gross price is also provided in the detailed product information. 

 

3.5 T.E.L.L. Kft. reserves the right to change the prices of the Products, with the price change becoming valid when the Products are introduced in the Webshop. The price change does not apply to the prices of the Products ordered before the change’s coming into force.  

 

3.6 In case that despite due care and caution of T.E.L.L. Kft. a false price is specified on the Webshop interface, especially the price being obviously mistaken or resulting from system error, for example 0 or 1 HUF, which is by far different from the generally accepted or estimated price, T.E.L.L. Kft. is not bound to deliver the Product at false price but T.E.L.L. Kft has the right to offer the delivery for the correct price. The Buyer with knowledge of the correct price can give up his intention of buying or withdraw his order within 14 (fourteen) days upon having been informed about the correct price, or he can buy the Product. 

 

3.7 T.EL.L. Kft. regularly updates the images of the Products in the Webshop, however, their current look or/and packing may differ from those shown in the Webshop. T.E.L.L. Kft does not take responsibility for such external differences. 

4. PROCESS OF ORDERING

4.1 The Buyer can choose from and specify the quantity of the Products (hereinafter: Ordered Products) he wants to buy using the appropriate interface pages of the Webshop. In the process of ordering he can view and modify the content of the basket. 

By clicking on GO TO CHECKOUT button the Buyer can proceed to the ordering interface . 

Data needed for ordering:

- The buyer is a private person: Delivery and billing particulars: name; postal code; locality; street, street number. Accessibility of ordering person: name; phone number; e-mail address.

- The buyer is an end user company: Delivery and billing particulars: company name; postal code; locality; street, street number; tax number. Accessibility of ordering person: name; phone number; e-mail address.

After placing the Products into the basket, the delivery costs of the Ordered Products also appear along with the total price of the Products.

 

4.2 The Ordered Products can be delivered both in Hungary or abroad as well. In the course of ordering, the Buyer has to state the shipping address where he wants to take delivery of the Ordered Products. For one ordering only one shipping address can be given. The company seat of T.E.L.L. Kft can also be chosen as shipping address on the Webshop interface. In this case no shipping costs will be charged.

 

4.3 As for the person given in the shipping address to take delivery, the Buyer can entitle special requests and specify particular delivery time and mode.  T.E.L.L. Kft. forwards these special requests to the courier service but takes no responsibility for their fulfilment. 

 

4.4 The Buyer chooses the method of payment from the following options: bank card, bank transfer, cash on delivery, cash payment during personal receipt.

 

4.5 After choosing the method of payment, the Buyer makes his order (’Order’) final by confirming it. Before confirmation, the Buyer has the possibility to check the price and delivery costs of the Product he wants to buy and its delivery and billing particulars one more time, and in case of any mistake he can correct them. If he finds everything all right he can send his order by pressing the ’Order’ button.

Prior to confirmation of his Order, the Buyer has to accept the provisions of the present GCC. By ordering, the Buyer agrees and accepts that T.E.L.L. Kft., in order to perform and keep track of fulfilment of the Contract, forwards the following particulars to the courier service: name of Buyer, given shipping address, Order ID and value, mobile phone number and e-mail address supplied by the Buyer at his registration.  

In case of data entry mistakes perceived after sending the order, the Buyer can inform T.E.L.L. Kft on e-mail address [email protected], thus the particulars of the order will be accordingly modified. 

 

4.6 T.E.L.L. Kft. immediately sends a confirmation e-mail about the final Order to the e-mail address that is supplied by the Buyer. This e-mail will contain the Order ID. If the confirmation e-mail fails to arrive within 48 hours, the Order is not binding and the Buyer is not bound to receive the delivered Product.  

The e-mail confirmation qualifies as acceptance of the Order which becomes valid according to paragraphs 4.7 and 5.1. of this GCC. The e-mail confirmation provides textual information to the Buyer.  

 

4.7 If the Buyer has submitted the Order, and the e-mail confirmation comes in to him on a workday, he still can withdraw his Order on the same workday between 8:00 – 16:00h. The withdrawal of the Order can be performed by the Buyer on phone number +36-52/530-130/1, along with supplying the Order ID. The Buyer also gets an e-mail confirmation about the acceptance of Order withdrawal within 1 (one) hour after his telephone call. 

 

4.8 In case of bank card payment, there is no possibility for the withdrawal of the Order pursuant to paragraph 4.7, but the Buyer can exercise his right of withdrawal or termination according to the provisions of paragraph 8 of this GCC.

5. CONCLUSION AND CHARACTERISTICS OF THE CONTRACT 

5.1 If the Order has not been withdrawn pursuant to paragraph 4.7, the written confirmation pursuant to paragraph 4.6 becomes valid, and the contract for the Ordered Products (hereinafter: Contract) will be concluded between the Buyer as orderer and T.E.L.L. Kft. as supplier. Under the terms of the Contract T.E.L.L. Kft. sells the Ordered Products to the Buyer and arranges for their delivery to the shipping address given by the Buyer. On the other hand, the Buyer is bound to take over the Ordered Products and to pay for the purchase price and delivery costs. The obligations stipulated in this paragraph cease upon performing the contacted service.  

 

5.2 The Contract is made for a definite time and it ceases when the obligations stipulated in paragraph 5.1 and other obligations deriving from the Contract cease, and neither of the contracted parties exercises his right of receding from the Contract. The Contract will be terminated if either party exercises his right of receding according to the provisions of the Contract. The cessation or termination of the Contract does not affect the warrantees of accessories and products derived from the Contract and the guaranty claims stipulated in paragraph 10.1.  

 

5.3 The Buyer is bound to pay for the shipping costs of the Ordered Products according to paragraph 7. of the present GCC.  

 

5.4 The Contract qualifies as made between absent parties, in Hungarian wording.  

 

5.5 The Contract does not qualify as made in written form and will not be filed. 

 

5.6 General deadline for Contract fulfilment: 5 workdays upon confirmation. If T.E.L.L. Kft and the Buyer have not agreed on the deadline of the fulfilment, T.E.L.L. Kft. is bound to meet his contracted duty within or at the time specified by the Buyer’s demand or, failing that, not later than thirty days upon arrival of order at T.E.L.L. Kft.

 

5.7 If T.E.L.L. Kft. fails to meet its contractual liabilities because the ordered product is not available, it has to inform the Buyer immediately and to repay the amount paid by the Buyer without delay, but not later than within thirty days. The fulfilment of this obligation does not release T.E.L.L. Kft. from other consequences of its breach of contract. 

6. DELIVERY AND RECEIPT OF ORDERED PRODUCTS 

6.1 T.E.L.L. Kft. delivers the Ordered Products by a courier service to the delivery address specified by the Buyer. 

 

6.2 The received Orders of the previous day are summarized every workday until 12:00h, and on the basis of this summary, the parcel(s) (hereinafter ’Parcel’) will be separately assembled for each Order. 

 

6.3 The courier service takes the completed Parcel from T.E.L.L. Kft between 16:00 – 19:00h and tries to deliver it to the delivery address specified by the Buyer on the following workday. If the Buyer has chosen the receipt of goods at the Supplier’s seat, the Parcel can be taken only after crediting this item in the Supplier’s invoice of Products purchase prices.  

 

6.4 In case of home delivery, besides the addressee, his family members living in his household, or in their absence, the neighbours of the addresse are also entitled to receive the Parcel. When a company is specified in the shipping address, besides the manager or chief representative of the company, any other staff member of the company seat or plant qualifies as entitled recipient, who can acknowledge the receipt by his signature and company stamp.  

 

6.5 At home delivery, the courier service attempts the delivery of the Parcel no more than twice. If the delivery fails for the second time, the Parcel will be returned to T.E.L.L. Kft., whereupon T.E.L.L. Kft. will charge the Buyer for the return costs. The Buyer can ask for repeated delivery of the Parcel on the e-mail address [email protected]. T.EL.L. Kft. will arrange the repeated delivery of the Parcel only upon payment of the repeated delivery. After unsuccesful delivery of the Parcel T.E.L.L. Kft. can terminate the Contract at its own option. 

7. PAYMENT FOR ORDERED PRODUCTS 

7.1 The Buyer pays the purchase price of the Ordered Products and the shipping costs by bank transfer in advance or pay on delivery, or pay in cash during personal receipt or pay online by bank card.

In case the place of delivery is outside of Hungary, payment is only possible according to paragraphs 7.2 and 7.4. 

 

7.2. Payment by bank transfer in advance:

The confirmation e-mail includes the bank account number of T.E.L.L. Kft. and the ID number of the order which identifies the order of the Buyer. At bank transfer, the order ID has to be specified in the transfer notification. The Buyer has to transfer the equivalent value of the Ordered Products (price of products + shipping costs) to the specified bank account within 5 workdays counting from the order. Failing to do so, T.EL.L. Kft. cancels the order.

 

7.3. In case of Cash on Delivery payment method the payment is made on delivery.  At home delivery the Buyer pays the Product price and shipping cost by cash or bank card. The courier service deliveres the collected amount to the Webshop.

If Cash on Delivery is the selected payment method, the costs is paid by the Buyer, which is 1% of the total amount of the order.

 

7.4. Credit card payment allows the Buyer to place an order conveniently and safely in our Webshop. After ordering the selected products the Buyer will be redirected to the Stripe’s payment site, which allows the Buyer to pay by credit card through the most secure, encrypted transaction currently available. The Buyer has to select the Credit card as payment method and then on the Bank's payment server enter the card number, expiration date and also the security code (CVC) which is located on the back of the card.  The Bank accepts only the embossed VISA and Mastercard cards which have security code (CVC).

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

8. TERMINATION AND WITHDRAWAL OF CONTRACT BY THE BUYER 

8.1 The provisions of the Hungarian Civil Code apply to the right of withdrawal and termination of the Buyer who does not qualify as a consumer.

 

8.2. According to Section 8:1 (3) point 3 of the Hungarian Civil Code, a consumer is defined as a natural person acting outside the scope of their profession, independent occupation, or business activity. Sections 8.3 – 8.9 contain provisions applicable to consumers.

 

8.3. A Buyer who qualifies as a consumer has the right to withdraw from the Contract within 14 (fourteen) days from the receipt of the Package without providing any reason. Similarly, in the case of a contract for the provision of services, if the performance of the contract has commenced, the Buyer is entitled to terminate the contract within 14 days without providing any reason.

The withdrawal period expires 14 days after the day on which the Buyer or a third party other than the carrier and indicated by the Buyer takes possession of the product. The Buyer exercises their right of withdrawal within the deadline if they send their withdrawal declaration before the expiry of the above-mentioned period.

In the event of exercising the right of withdrawal, the cost of returning the Ordered Product shall be borne by the Buyer.

 

8.4 However, the consumer does not have the right to withdraw without justification in the following cases, in accordance with § 29 of Government Decree No. 45/2014. (II.26.) on the detailed rules of contracts between consumers and businesses:

  1. b) if the product price or service fee cannot be influenced by the money-market enterprise, or they depend on the instability of the money-market which may occur during the period of time specified in § 20.(2);
  2. c) if the prefabricated product has been made on the basis of consumer’s instructions or explicit request, or the product has been unambiguously customized;
  3. i) if the sealed packing of the sold sound and image record or computer software copy is opened by the consumer after receiving the product;
  4. m) if the undertaking has already started its performance with digital data content on non-material data carrier, having the explicit prior consent of the consumer, and the consumer declared, along with his consent, that he took notice of loosing his right of termination stipulated in §20 after the performance has started, furthermore, the undertaking has sent a confirmation to the consumer as specified in §12 (2) or §18.

 

8.5 If the Buyer terminates the Contract according to paragraph 8.1, he has to repack the Ordered Products in undamaged and complete condition and send them back to the address 4032 Debrecen, Vágóhíd utca 2. Besides sending by post, T.E.L.L. Kft. enables the Buyer to return the repacked Ordered Product personally at T.E.L.L. Kft. seat (4032 Debrecen, Vágóhíd utca 2.). 

In the case of Buyers who qualify as consumers, T.E.L.L. Kft. provides the option, in addition to returning the Ordered Product by postal mail, for the Buyer to personally return the repackaged Ordered Product to the headquarters or branch office of T.E.L.L. Kft. (40342 Debrecen, Vágóhíd utca 2., 1082 Budapest, Corvin sétány 1. A. ép. 9th floor, door 1). The Product must be returned or handed over without undue delay, but no later than 14 days from the communication of the withdrawal declaration. The deadline is deemed to have been met if the goods are sent back before the 14-day period has expired. The Buyer can only be held liable for any decrease in the value of the product if it results from use beyond what is necessary to determine the nature, characteristics, and functioning of the goods.

 

8.6 The Buyer can exercise his right to terminate the Contract by giving a declaration of contract termination in written form. Therefore, along with sending or bringing back the Ordered Product according to the provisions of paragraph 8.3, the Buyer has to enclose his declaration of termination of contract. The Buyer can e-mail the declaration of termination to [email protected], in this case he does not need to enclose his declaration to the Ordered Product. The declaration of termination must include the following particulars: which Ordered Product is it referred to, Buyer’s name and address, date of Order, date of declaration and Order ID. If the Order ID is not available to the Buyer, he has to specify other particulars in his declaration which are suitable for identification of the Order. If the Buyer decides to use the electronic method, T.E.L.L. Kft. will promptly confirm the receipt of the withdrawal by email.

The right of termination can also be exercised using the sample declaration form provided in Appendix 2 of the Governmental Regulation No. 45/2014. (II.26) on Detailed Regulation of Contracts between Consumers and Suppliers, however, in this case the Order ID also has to be specified (for its lack, other particulars suitable for Order identification must be provided).

 

8.7 In case of termination of Contract by the Buyer, he will be charged with the costs of return of the Ordered Products to T.E.L.L. Kft. (including especially the postal fees).

 

8.8 T.E.L.L. Kft. will promptly, but no later than 14 (fourteen) days after receiving the withdrawal declaration and the returned product, refund the Buyer the paid purchase price and the shipping cost, as well as all other payments made by the Buyer, via postal payment order, except for any additional costs that arose because the Buyer chose a delivery method different from the least expensive standard delivery method offered by T.E.L.L. Kft. T.E.L.L. Kft. may withhold the refund until it has received the returned Ordered Product or the Buyer has provided credible proof of having returned it, whichever occurs earlier.

 

8.9 The refund will be made using the same payment method as the original transaction, unless the Buyer expressly agrees to a different payment method. If the Buyer provides their bank account number, the name of the bank managing the account, and requests a bank transfer of the paid purchase price in their withdrawal declaration, T.E.L.L. Kft. will refund the paid purchase price within 14 (fourteen) days after receiving the withdrawal declaration and the returned product.

 

9. WARRANTY FOR ACCESSORIES

9.1 In the event of defective performance by T.E.L.L. Kft., the Buyer may enforce a warranty claim according to the provisions of the Hungarian Civil Code.

 

9.2 The rules set out in Sections 9.3 to 9.11 apply to Buyers who qualify as consumers.

 

9.3 The Buyer may, at their discretion, exercise the following warranty claims. They may request the repair or replacement of the Ordered Product unless the fulfillment of the chosen request is impossible or would result in disproportionate additional costs for T.E.L.L. Kft. compared to fulfilling another request. If the Buyer does not request or cannot request repair or replacement, they may demand a proportionate reduction of the consideration or may repair the defect in the Ordered Product themselves at the expense of T.E.L.L. Kft., or have it repaired by someone else, or as a last resort, they may withdraw from the contract. Withdrawal is not permitted for minor defects. The Buyer may switch from the chosen warranty right to another, but the cost of this transition is borne by the Buyer, unless it was justified or caused by T.E.L.L. Kft.

In the case of a contract between the Consumer and T.E.L.L. Kft. involving the sale of a movable item, the provision of digital content, or the provision of digital services, the Buyer may not repair the defect at the expense of T.E.L.L. Kft. or have it repaired by someone else within the scope of exercising their warranty rights.

 

9.4 The Buyer is required to notify the defects immediately after discovering them. In the case of a Consumer, a defect reported within two months is considered to have been reported without delay.

Warranty claims expire two years from the date of performance. After the two-year limitation period from the date of performance, the Buyer who qualifies as a consumer can no longer enforce their warranty rights.

 

9.5 For Consumers, within one (1) year from the date of performance, enforcing a warranty claim requires nothing beyond reporting the defect, provided that the Buyer proves that they purchased the product from T.E.L.L. Kft. However, after the one (1) year from the date of performance, the Buyer is required to prove that the defect recognized by them already existed at the time of performance.

When asserting a warranty claim, the Buyer must prove the conclusion of the Contract. The conclusion of the Contract is considered proven if the Buyer presents the document evidencing payment of the consideration.

 

9.6 T.E.L.L. Kft. is required to record a report of the Buyer’s warranty claim, in which it documents:

  1. The name and address of the Buyer, along with their declaration of consent to the handling of their data as specified in the decree,
  2. The name and purchase price of the Ordered Product,
  3. The date of performance of the Contract by T.E.L.L. Kft.,
  4. The date of the defect report,
  5. A description of the defect,
  6. The right the Buyer wishes to enforce based on their warranty claim, and
  7. Except in the case described in Section 9.11, the method of settling the warranty claim or the reason for rejecting the claim and the right the Buyer wishes to enforce based on it.

 

9.7 If T.E.L.L. Kft. fulfills its warranty obligation in a way different from the right the Buyer wishes to enforce, the reason for this must be stated in the report.

 

9.8 T.E.L.L. Kft. will promptly provide the Buyer with a copy of the report in a verifiable manner.

 

9.9 If T.E.L.L. Kft. cannot declare the enforceability of the Buyer’s warranty claim at the time of its report, it will notify the Buyer of its position within five (5) business days in a verifiable manner.

 

9.10 T.E.L.L. Kft. will strive to carry out the repair or replacement within 15 (fifteen) days at most.

 

9.11 T.E.L.L. Kft. will accept the Ordered Product for repair or, in the case mentioned in Section 9.9, for investigating the enforceability of the warranty claim, against an acknowledgment of receipt, which specifies:

 

  1. The name and address of the Buyer,
  2. The data necessary to identify the Ordered Product,
  3. The date of receipt of the Ordered Product, and
  4. The date when the Buyer can collect the repaired Ordered Product.

T.E.L.L. Kft. may also fulfill the provisions of Section 9.11 within the report of the warranty claim.

10. PRODUCT WARRANTY 

10.1 In the event of a defect in the Product, the Buyer may enforce their right to a warranty claim or a product warranty claim according to the provisions of the Hungarian Civil Code.

As a product warranty claim, the Buyer may request only the repair or replacement of the defective Ordered Product from T.E.L.L. Kft. as the manufacturer of the Product.

The Ordered Product is considered defective if it does not meet the quality requirements effective at the time of its release to the market or if it does not possess the characteristics listed in the description provided by T.E.L.L. Kft. The burden of proving the defect in the Ordered Product lies with the Buyer.

 

10.2 The Buyer may enforce their product warranty claim within 2 (two) years from the date of the release of the Ordered Product by the manufacturer, after which this right expires.

 

10.3 When enforcing a product warranty claim, the Buyer must prove that the product defect existed at the time of release to the market by T.E.L.L. Kft. (manufacturer). T.E.L.L. Kft. (the manufacturer) is exempt from the product warranty claim if it proves that:

  1. The Ordered Product was not manufactured or released to the market as part of its business activities, or
  2. The defect was not recognizable according to the state of science and technology at the time of release to the market, or
  3. The defect in the Ordered Product results from the application of a legal regulation or a mandatory authority provision.

 

10.4 For T.E.L.L. Kft. as the manufacturer, it is sufficient to prove one of the reasons listed in Section 9.14 for exemption.

 

10.5 The Buyer may simultaneously enforce both a warranty claim and a product warranty claim for the same defect. In the event of successful enforcement of a product warranty claim, the Buyer may enforce the warranty claim for the replaced Product or the repaired part against the manufacturer.

11. GUARANTEE

11.1 The duration of the guarantee is two years.

 

11.2 In the event of defective performance, the Buyer may enforce a guarantee claim based on the guarantee declaration issued by T.E.L.L. Kft. in accordance with the provisions of the Hungarian Civil Code.

 

11.3 A Buyer who qualifies as a consumer may enforce the rights specified in Section 9 due to defective performance under the conditions set out in the government decree on mandatory guarantees for certain durable consumer goods and in Sections 11.3 to 11.7.

 

11.4 During the guarantee period, the consumer may primarily request repair. Replacement is possible after the first repair attempt if it is determined that the Product cannot be repaired and the Buyer does not request the fulfillment of another claim. The Buyer may also request replacement if the repair is not carried out within thirty days following the notification of the repair claim. The right to replacement is also established if the Product fails again after three repairs during the guarantee period, provided the Buyer does not request the fulfillment of another claim. If replacement is not possible in the above cases, the Buyer may also claim a refund of the purchase price.

 

11.5 The consumer may exercise their rights under the guarantee with the guarantee certificate provided to them; the invalid issuance of the guarantee certificate or the failure to provide the guarantee certificate does not affect the validity of the guarantee. If the guarantee certificate is not provided, the conclusion of the contract is considered proven if the Buyer presents the receipt evidencing payment of the consideration. Fulfilling the guarantee claim does not require the return of the Product's opened packaging.

 

11.6 Special requirements (such as periodic inspections) may be imposed on the consumer for the proper installation or maintenance of the Product, provided that proper installation or maintenance cannot be ensured otherwise and fulfilling the requirement does not impose a disproportionate burden on the consumer.

 

11.7 T.E.L.L. Kft. is exempt from its guarantee obligation if it proves that the defect arose after the performance.

 

11.8 The Buyer may enforce both a warranty claim and a guarantee claim, as well as a product warranty claim and a guarantee claim, simultaneously or in parallel for the same defect. However, if the Buyer has successfully enforced a claim due to defective performance for a specific defect (e.g., T.E.L.L. Kft. replaced the product), they cannot make a further claim on the same legal basis for the same defect.

 

11.9 The provisions of the Hungarian Civil Code on guarantees and the exercise of warranty rights apply to the guarantee provided by T.E.L.L. Kft.

12. INFORMATION, COMPLAINTS, COMPLAINT MANAGEMENT 

12.1 The Buyer can contact T.E.L.L. Kft with questions regarding the operation of the Webshop, his Orders and possible complaints, choosing from the following accessibilities: 

  1. postal correspondence address: 4034 Debrecen, Vágóhíd utca 2. 
  2. electronic correspondence address: [email protected]
  3. telephone number: +36-52/530-130

Complaint management

 

12.2 T.E.L.L. Kft is available on phone from 8 to 17h on workdays. 

 

12.3 Complaints made by phone call are immediately checked by T.E.L.L. Kft. and, if needed, remedied according to possibilities.  

 

12.4 If the Buyer does not agree with the complaint management, or the immediate examination of the complaint by T.E.L.L. Kft. is not feasible, T.E.L.L. Kft. immediately records the complaint and its own related standpoint. T.E.L.L. Kft. sends a copy of the record to the Buyer at latest as enclosure to its response on the merits, specified in paragraph 

 

12.5 T.E.L.L. Kft. provides the complaints made by phone or e-mail with unique ID. 

 

12.6 T.E.L.L. Kft. responds, concerning the merits of the case, to oral complaints of the Buyer or if in Buyer’s opinion the complaint is being not satisfactorily handled by T.E.L.L. Kft., and to written complaints within 30 (thirty) days upon their arrival.  

 

12.7 If the Buyer wants to initiate the proceedings of an authority or reconciliatory body to be involved in his complaint, he can address – depending on the character of the case – the following organs: 

 

  1. Inspectorate of Consumer Protection of Hajdú-Bihar County Government Office (Hajdú-Bihar Vármegyei Kormányhivatal Fogyasztóvédelmi Osztály)

Postal address: 4025 Debrecen, Széchenyi utca 46.

Phone: 06-52/533-924

E-mail: [email protected]

 

  1. Reconciliatory Body of Hajdú-Bihar County (Hajdú - Bihar Vármegyei Békéltető Testület)

Address: 4025 Debrecen, Vörösmarty u. 13. -15. 

Phone: 06 52-500-710

E-mail: [email protected] 

 

13. MISCELLANEOUS PROVISIONS 

13.1 For questions not explicitly stipulated in present GCC, provisions of the following legal rules are to be appropriately applied: 

Act No.V of 2013. of Hungarian Civil Code 

Act No.CVIII of 2001. of Some Questions about Electronic Commercial Services and Services Related to Information Society; 

Act No.CLV of 1997. of Consumer Protection, 

Governmental Regulation No.45/2014.(II.26.) on Detailed Regulation of Contracts between Consumers and Suppliers  

Governmental Regulation No.151/2003.(IX.22) on Compulsory Guarantee for certain Durable Articles of Consumption  

Regulation No. 19/2014.(IV.29.)NGM of Administration Proceedings of Warranty and Guarantee Claims on Goods Sold within Contract between Consumer and Enterprise 

 

13.2 The Data Protection Guide of T.E.L.L. Kft. Webshop (http://.tell.hu) makes the inseparable constituent part of the present GCC, the content of which the Buyer learned in course of registration and agrees that T.E.L.L. Kft. manages his particulars supplied for registration, Order and Contract according to the conditions of these regulations. 

14. CODE OF CONDUCT 

T.E.L.L. Kft. is not subject to the Code of Conduct under the law prohibiting unfair commercial practices against consumers.

Privacy Policy
Data Protection Information of

 

T.E.L.L. SOFTWARE HUNGARIA Kft. and

T.E.L.L. Biztonságtechnikai Rendszerek Kft.

 

The following information is provided to the visitors of our website and the customers of the webshop with regard to our personal data processing practices, the technical and organizational measures we take to ensure the protection of their data, their related rights, and their possibilities of exercising those rights.

 

Data controller:

  • T.E.L.L. Biztonságtechnikai Rendszerek Kereskedelmi és Szolgáltató Korlátolt Felelősségű Társaság (registered seat: 4034 Debrecen, Vágóhíd utca 2.; company registration number: 09-09- 027345; court of registration: Debreceni Törvényszék (Debrecen Regional Court); tax number: 25406812- 2-09; phone:+36- 52/530-130, fax: +36-52/530-131, e-mail: [email protected], hereinafter collectively as: Company) and
  • T.E.L.L. SOFTWARE HUNGARIA Szoftver-fejlesztő és Szolgáltató Korlátolt Felelősségű Társaság (registered seat: 4034 Debrecen, Vágóhíd utca 2.; company registration number: 09-09-005193; court of registration: Debreceni Törvényszék (Debrecen Regional Court); tax number: 17783790-5-09; phone: +36- 52/530-130, fax: +36-52/530-131, e-mail: [email protected], website: www.tell.hu,) and

as joint controllers (hereinafter collectively as: Company)

 

Data processors:

The data controller shall inform the data subjects that it uses the following data processors to carry out its activities:

 

  • Data processing activities in relation to marketing activities:

T.E.L.L. Műszaki Fejlesztő Korlátolt Felelősségű Társaság (registered seat: 4034 Debrecen, Vágóhíd street 2.; company registration number: 09-09-027969; court of registration: Debreceni Törvényszék (Debrecen Regional Court); tax number: 25590395-2-09; phone:+36-52/530-130, fax: +36-52/530-131, e-mail: [email protected],

 

  • Data processing activities in relation to transport activities:

GLS General Logistics Systems Hungary Csomag-Logisztikai Kft. (2351 Alsónémedi, GLS Európa str. 2., [email protected], (+36 29) 88 66 70) Data processing activities related to transport activities

TNT Express Hungary Kft. (1185 Budapest, II. Logisztikai központ - Irodaépület, BUD Nemzetközi Repülőtér 283. ép., 06 8031 3131, https://www.tnt.com/express/hu_hu/site/support/contact.html)

The courier service participates in the delivery of the ordered goods on the basis of the contract concluded with the data Controller. The courier service handles the personal data received in accordance with the data management information available on its website.

  • Live chat on the website: twak.to inc., 187 East Warm Springs Rd, SB298 Las Vegas, NV, 89119

 

  • Data processing activity in relation to the operation of CRM:

MiniCRM Zrt. (company registration number: 01-10-047449, EU tax number: HU 23982273,  [email protected],  +36 (1) 999 0401)

The processor shall be involved in the registration of orders on the basis of a contract with the controller. In doing so, the data processor shall address the name, address, telephone number, number and date of orders within the civil-legal limitation period.

 

  • Customer service system (https://www.liveagent.com/" https://www.liveagent.com/, +421 2 33 456 826, [email protected], Quality Unit, s.r.o., Vajnorská 100/A, 831 04 Bratislava, SLOVAKIA

Hosting service provider: Unas Online Kft. (mailing address: 9400 Sopron, Kőszegi street 14., email: [email protected]" [email protected])

The data processor shall perform the storage of personal data on the basis of a contract with the controller. It is not entitled to know personal data.

 

 

  • Data processing activity in relation to sending newsletters:

Mailchimp system operator The Rocket Science Group, LLC (675 Ponce de Leon Avenue, Suite 5000, Atlanta, GA 30308 USA).

The data processor is involved in the sending of newsletters on the basis of a contract with the controller. In doing so, the data processor shall address the name and e-mail address of the data subject to the extent necessary for the newsletter.

 

The transmission of data to the data processor specified in this document may be carried out without the specific consent of the data subject. The data controller shall not transfer personal data it manages to third parties other than those specified in this document.

The data processor shall not act independently and shall be excluded from the contract with the controller and shall be entitled to act in accordance with the instructions received. The data processor shall record, manage and process personal data transferred and processed or processed by the data controller in accordance with the provisions laid down by GDPR and shall make a statement to the data controller.

The work of the data processor is overseed by the data controller.

The data processor is entitled to use additional data processors only with the consent of the data controller.

  • Processing the data of the visitors on the website of the Company

Website information on the use of cookies

Following a common Internet practice, our Company uses cookies on its website

as well. Cookies are small files containing a line of characters which are saved on the visitor’s computer when they visit a website. Should they visit the site again, the cookies enable the website to be able to recognize the visitor’s browser. Cookies can store user settings (e.g. selected language) and other information, as well. Among other things, they can collect information about the visitor and his or her device, they remember the individual settings of the visitor, they may be used for example during online purchases. Cookies in general ensure that website can be used more easily, they enable users to have a true web experience, and that the website can become an efficient source of information, furthermore, they enable the operator of the website to monitor the operation of the website, to prevent abuse and to continue providing uninterrupted services at a satisfactory level.

The following data is collected and processed during the use of the webpage by our Company website with regard to the visitor and the device they use for browsing:

  • the identifier of the product last viewed

 

From these data the system automatically generates statistical data. The operator does not link these with personal data.

 

It is not compulsory to accept and allow the use of cookies. You may reset your browser in a way that it bans all of the cookies or that is warns if the system is sending a cookie. Although most browsers automatically accept cookies by default, these may be changed to prevent automatic acceptance and so that        it would offer a choice every time.

 

You can find more information on the cookie settings of the most popular browsers in the links below

However, please be advised that some of the functions of the website or some of the services offered may  not function properly without cookies.

The cookies used on the website are not suitable to enable the identification of the user on their own.

 

The cookies used on the Company website:

  1. Session cookies that are technically indispensable

These cookies are necessary to enable visitors to browse the website, use all the functions and the services accessible through the website in a fault free manner, therefore - among others - specially to remember the operations carried out at the last visit on the specific webpage. Data processing period of these cookies is 2 hours.

Processed data:

  • Language displayed
  • Internal identifier of the currency
  • User’s address
  • Selected mode of delivery and payment
  • VAT rate
  • Coupon details
  • Current country
  • Contents of the shopping cart
  • Whether the user can make a purchase
  • Internal identifier of the user
  • Requests for quotation
  • User’s name

 

The legal basis of this data processing is Section 13/A. (3) of Act CVIII of 2001 on Certain Issues of Electronic Commerce Services and Information Society Services (Elkertv.).

Purpose of data processing: to ensure the appropriate operation of the website

 

  1. Cookies requiring consent:

These enable the Company to remember the choices the user made in connection with the website. Prior to using the service and during the use of the service users can ban this data processing at any time. These data cannot be linked to the personal data of the user and may not be transferred to third parties without the permission of the user.

Duration of processing: 1 day

 

  • Cookies necessary to facilitate functioning:

The legal basis of the processing is the consent of the visitor.

Purpose of data processing: To increase the efficiency of the service, to improve user experience, to make the use of the website more convenient.

Duration of processing: 2 hours

  • Performance cookies:

Google Analytics cookies – find more information here: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

 

Google AdWords cookies - find more information here: https://support.google.com/adwords/answer/2407785?hl=hu

 

 

The Company informs its visitors that in order to measure the number of visitors at the www.tell.hu website and its sub-pages and to monitor the behavior of its visitors, compile statistics and ensure the effectiveness of its advertisements, it uses the following programs:

- Google Analytics

- Google AdWords Conversion Tracking

- Hotjar

- Poptin

- Facebook Remarketing

The programs referred to place so-called cookies on the user’s computer that collect user data. Visitors of the website allow the Company to use Google Analytics, AdWords Conversation Tracking, and Facebook Remarketing, Hotjar programs. They also consent to the Company monitoring and tracking their user behavior and using all services provided by the programs. In addition, the visitor has the opportunity to disable the recording and storage of cookies for future reference at any time, as described below. We inform our visitors that Google Analytics, AdWords Conversion Tracking, and Facebook Remarketing, Hotjar and Poptin program settings and usage are fully compliant with the requirements of the data protection authority.

Google reports that Google Analytics uses a number of first-party cookies to report visitor interactions on its website. These cookies only store non-personally identifiable information. Browsers do not share their own cookies between domains. You can find more information on cookies in the Google Advertising and Privacy FAQ.

Google Analytics: The data controller uses Google Analytics primarily to generate statistics for, among other things, the performance of its campaigns. By using the program, the Company mainly obtains information about how many visitors visited the website and how much time the visitors spent on the website. The program recognizes the visitor's IP address thus it is able to track whether the visitor is a recurring or new visitor, and how the visitor traveled to the website and where they entered.

Google AdWords Conversion Tracking: Google AdWords Conversion Tracking is designed to help companies measure the effectiveness of its AdWords ads. It is done by using cookies placed on the visitor's computer, that last for 30 days and do not collect personal information.

Disable cookies: If you want to manage the cookie settings or disable this feature, you can do so in your own browser. This option can be found in the cookies/tracking functions menu, depending on your browser toolbar. You can usually set the tracking features you want to allow/disable on your computer in Tools > Settings > Privacy settings. If you do not want Google Analytics to report on your visits, you can install the Google Analytics disable browser plugin. This plug-in instructs Google Analytics JavaScript not to send information to Google on the visitors. In case the blocking plug-in is installed, visitors will not be participating in content experiments. To disable Google Analytics web activity, visit the Google Analytics disable page and install the plugin for your browser. For more information about installing and uninstalling the plugin, see the help function in your browser.

In addition to Google's services, the Company also uses Hotjar's analytics service: Hotjar Ltd. ("Hotjar") (http://www.hotjar.com, 3 Lyons Range, 20 Bisazza Street, Sliema SLM 1640, Malta, Europe). Through Hotjar’s analysis, the Company has the opportunity to learn about and evaluate the habits of visitors on the website (e.g., how much time they spend on certain sub-pages, what links they click on, etc.). During the operation, information collected about the visit on the website will be transmitted to Hotjar's servers in Ireland, where it will be stored by Hotjar.

The following information can be recorded in connection with the visitor's device and browser:

- IP address of the user's device (collected and stored in anonymous format)

- The screen size of the user's device

- The type of the user's device and the browser they are using

- User location (country only)

With the help of Hotjar, the visit and the use of the website is analyzed, which is reported separately. During this feature, Hotjar also uses third-party services such as Google Analytics and Optimizely. The third parties mentioned through the data transfer may store the information that the user's browser sends while visiting the website (e.g., cookies, IP requests, etc.). Cookies used by Hotjar are not deleted for a different period of time, some cookies are automatically deleted after the current visit, but there are some that may last up to 365 days.

To disable data logging by Hotjar, please visit https://www.hotjar.com/opt-out.

You can find Hotjar's privacy policy here (https://www.hotjar.com/legal/policies/privacy).

 

On the website, the Company uses the so-called "Facebook pixel" of the Facebook social network operated by Facebook Inc. (1 Hacker Way, Menlo Park, CA 94025, USA) or, if you live in the EU, Facebook Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland) (the “Facebook”). The Facebook pixel allows Facebook to target website visitors to display ads (called Facebook ads). Accordingly, the Company uses the Facebook pixel to ensure that the embedded Facebook ads are displayed only to Facebook users who have also shown interest in the Company's offerings. The purpose of the Facebook pixel is to make Facebook ads relevant to the potential interest of users and not to be distractions. The Facebook pixel also allows the Company to analyze the effectiveness of advertisements on Facebook for statistical and market research purposes, such as whether the users have reached our website by clicking on a Facebook advertisement. Facebook embeds the Facebook pixel directly when you open our website, which can place a so-called cookie on the visitor’s device. If you sign in to Facebook later or visit Facebook when you are signed in, your visits will be registered in your profile. The data obtained about visitors is anonymous to us, which means that we are unable to identify you based on that. However, the data is stored and processed by Facebook so that it can be linked to the user profile. Facebook manages data in accordance with its own privacy policy. For more information on how the remarketing pixel works and how Facebook ads are displayed in general, see Facebook's privacy policy at https://www.facebook.com/policy.php. You can disable Facebook pixel data recording and the use of your data for displaying Facebook ads. To do so, visit Facebook and follow the instructions for personal ads settings: https://www.facebook.com/settings?tab=ads, the U.S. page address: http://www.aboutads.info/ choices / and the EU website at http://www.youronlinechoices.com/. The settings are platform-independent, meaning they apply to both desktops and mobile devices.

 

Data processed for the purpose of concluding and fulfil contracts

Data management cases may be implemented for the purpose of concluding a contract and fulfilling it. We inform you that data processing related to complaints and warranty administration will only be exchanged if one of those rights is exercised by the data subject.

If the data subject does not purchase through the webshop, only visits it, the section of data management for marketing purposes may apply to them, in case they give consent to the company.

Data processing for the conclusion and fulfilment of contracts in more detail:

 

  • Contact

Contact is made when a person contact us by e-mail, contact form or phone with a question about a product. Pre-contact is not mandatory, it is possible to order from the webshop anytime.

 

Data processed:

Data provided during contact.

 

Duration of data processing:

The data will only be processed by the company until the contact is completed.

 

Legal basis for data processing:

The voluntary consent of the data subject, which is provided to the data controller by contact. [Data processing pursuant to article 6 (1) (a) of the regulation]

 

Recipients of personal data and categories of recipients: employees of the company performing customer service tasks, the company's hosting provider and its employees perfomring hosting tasks as data processors.

 

 

  • Registration for the use of the webshop/webstore

 

The person who registers on the website can provide his or her consent for the processing of his or her personal data by ticking the appropriate box.

 

Data provided during registration:

  • name
  • business name
  • e-mail address
  • point-of-contact’s phone number
  • category (end user, installer, reseller, remote assistance, distributor)
  • billing and shipping address

The purpose of personal data processing:

  1. Fulfilling the services provided on the website, improving services
  2. Keeping contact by electronic, phone, SMS and postal
  3. Analysing the usage of the
  4. Sale of advertising space
  5. Use for conducting own research and preparing

Results generated from these are only published in a form which does not allow the identification of individual users.

 

Legal basis of the processing is the consent of the data subject.

 

Recipient of personal data, and categories of recipients: employees of the Company performing tasks related to its customer service and its marketing activities, as data processors: IT provider of the Company and its employees dealing with hosting services.

 

Storage period of personal data: as long as registration is valid / the service is provided, or until data subject withdraws their consent (requests erasure, which can be sent to [email protected] e-mail address).

 

  • Processing of order

During the processing of orders, data processing activities are necessary in order to fulfill the contract.

Data processed: name, address / location, phone number, e-mail address, characteristics of the purchased product, order number and date of purchase.

If you have placed an order in the webshop, providing data and data processing are essential for the fulfillment of the contract.

 

Duration of data processing: The data will be processed for 5 years according to the civil law limitation period.

 

Legal basis for data processing:

Performance of the contract. [Data processing pursuant to article 6 (1) (b) of the regulation]

 

Recipients of personal data and categories of recipients: employees of the company performing tasks related to the processing of orders, the company's hosting provider and its employees performing hosting tasks as data processors.

 

 

  • Issuance of invoice:

Data processing is carried out in order to issue an invoice in accordance with the law and to fulfill the obligation to keep accounting records. Pursuant to paragraph 169 (1) to (2) of the Accounting Law, companies must keep the accounting document directly and indirectly supporting the accounting records.

 

Data processed:

Name, address, e-mail address, phone number.

 

Duration of data processing:

Pursuant to paragraph 169 (2) of the Accounting Law, the issued invoices shall be kept for 8 years from the date of issue of the invoice.

 

Legal basis for data processing:

Pursuant to paragraph 159 (1) Law CXXVII of 2007 on value added tax, the issuance of the invoice is obligatory and it must be kept for eight years pursuant to paragraph 169 (2) of the Accounting Law C of 2000. [Data processing pursuant to article 6 (1) (a) of the regulation]

 

Recipients of personal data and categories of recipients: employees of the company performing tasks related to billing.

 

 

  • Data processing in relation to the transport of goods

Data processing is carried out in order to deliver the ordered product.

 

Data processed: Name, address, e-mail address, phone number.

 

Duration of data processing:

The controller shall treat the data for the duration of the delivery of the ordered goods.

 

Legal basis for data processing: performance of the contract [Data processing pursuant to article 6 (1) (b) of the regulation].

 

Data processing recipients related to the transport of goods, data processors:

Name of the recipient: employees of the company performing tasks related to performing orders, GLS General Logistics Systems Hungary Csomag-Logisztikai Kft., TNT Express Hungary Kft.

 

The courier service shall contribute to the delivery of the ordered goods on the basis of a contract with the controller. The personal data received by the courier service shall be processed in accordance with the data management information available on its website.

 

  • Data processed in relation to the verifiability of the consent

 

During the registration, ordering and subscribing to the newsletter, the IT system stores the IT data related to the consent for later verification.

 

Data processed: Date of consent and IP address of the data subject.

 

Duration of data processing:

Due to legal requirements, the consent must be able to be verified later, thus the period of data storage is in line with the limitation period of the data processing.

 

Legal basis for data processing:

This obligation is laid down in Article 7 (1) of the Regulation [Data processing pursuant to Article 6 (1) (c) of the Regulation]

 

Recipients of personal data and categories of recipients: employees of the company providing technical support, the hosting provider of the company and its employees providing hosting services as data processors.

 

 

  • Data processing related to the newsletter service

The Company operates a newsletter system for the purpose of continuously informing those interested. In connection with that, we process the personal data (full name, e-mail address) provided during the registration on the website with the prior written consent of the recipient of the newsletter. The Company's newsletters are sent from abroad via the "Mailchimp" international newsletter system. In addition to the registration, your express consent is required to transfer your personal data to a foreign data controller. The Mailchimp system is operated by The Rocket Science Group, LLC (675 Ponce de Leon Avenue, Suite 5000, Atlanta, GA 30308 USA). The data processing in accordance with the European Union regulations is ensured by the foreign operator in accordance with the provisions of the "EU-U.S. Privacy Shield Framework" data exchange agreement. The data subject may unsubscribe from the newsletter at any time by clicking on the "Unsubscribe" button in the footer of the newsletters, which will automatically delete the data stored in the system. You can also express your request in e-mail to unsubscribe ([email protected]) and the Company will delete your data immediately or not later than within 15 days.

 

The person who registers on the website for the newsletter service can provide his or her consent for the processing of his or her personal data by pressing the Subscribe button after ticking the appropriate box for providing consent for the processing of data. Data subject can unsubscribe at any time by using the “Unsubscribe” application of the newsletter, or by sending a written declaration via an e-mail, which means the withdrawal of the consent. In such cases every data concerning the unsubscribing person must be deleted without delay.

Scope of personal data that can be processed: name of natural person (first and last name), e-mail address.

 The purpose of processing the personal data:

  1. Sending newsletters about the products and services of the Company
  2. Sending advertising material
  3. Communication regarding technical information (updates, new functions, patches)

 

Legal basis of the processing: the consent of the data subject

 

Recipient of personal data, and categories of recipients: employees of the Company performing tasks related to its customer service and its marketing activities, employees of the IT provider of the Company as data processors with the purpose of providing the hosting service.

 

Storage period of personal data: as long as the newsletter service is provided, or until data subject withdraws his or her consent (until his or her request for erasure, which can be sent to [email protected] e-mail address).

 

 

  • Recording the telephone conversations of the customer service

The Company records the telephone conversations made with its customer service with the purpose of conducting sales, providing services and with the purpose of providing information about them. Legal basis of the processing is the consent of the data subject.

Notification must be given that a recording will be made, and consent must be gained at the beginning of the call.

The following data are collected when phone conversations are recorded: phone number, date and time of the call, recording of the conversation, personal data provided during the conversation.

Recipient of personal data, and categories of recipients: employees of the Company performing tasks related to its customer service.

Telephone conversations are stored for 1 year. The recorded material can be searched using the telephone number and the date of the call.

 

  • Community guidelines / Data processing on the Facebook page of the Company

The Company maintains a Facebook page in order to raise awareness of and promote its products and services.

Questions submitted on the Facebook page of the Company do not constitute an official complaint.

The Company does not process the personal data that the visitors of the Facebook page of the Company reveal.

Data protection and General terms and conditions of Facebook apply to visitors.

In the event that unlawful or offensive content is posted, the Company may, without prior notification, ban data subject from the members, or delete their posts.

The Company does not accept any responsibility whatsoever for data content or posts published by Facebook users that are in breach of legislation. The Company does not accept any responsibility whatsoever for errors, malfunctions resulting from the operation of Facebook, or for issues resulting from a change in the functioning of the system.

 

 

  • Data processing with the purpose of direct marketing

Unless regulated otherwise by law, advertisements can only be sent to natural person recipients of an advertisement directly (direct marketing), especially by way of electronic correspondence or other, equivalent individual means of communication - with the exception set forth in Act XLVIII of 2008 - if the recipient of the advertisement has provided his or her prior, explicit and unequivocal consent.

Scope of personal data that the Company may use for direct marketing purposes: name, address, phone number, e-mail address, online identifier of the natural person.

The purpose of processing the personal data is to carry out direct marketing activities related to the operation of the Company, i.e. the sending of advertising publications, newsletters, current promotions in printed form (by post) or by an electronic means (e-mail) on a regular basis or at intervals to the contact details provided at registration.

Legal basis of the processing: the consent of the data subject

Recipients of personal data, and categories of recipients: employees of the Company performing tasks related to its customer service activities, as data processors: the employees of the IT provider of the Company providing server services and in case of postal deliveries, the employees of the Post.

Storage period of personal data: until consent is withdrawn.

 

  • Processing the data of contracting partners

Under the legal title of performing a contract, the Company processes the name, birth name, date of birth, mother’s name, address, tax identification number, tax number, residential address, address of the registered seat and premises, phone number, e-mail address, website URL, bank account number, client number (customer number, order number), online identifier (list of buyers and suppliers, customer loyalty lists) of the natural persons that enter into a contract with the Company as clients or suppliers, with the purpose of concluding, performing, terminating the contract or on order to provide contractual discounts. This data processing is lawful even if it is necessary for the implementation of the measures that data subject requested prior to entering into contract. Recipient of personal data: employees of the Company performing tasks related to serving customers, its employees performing accounting and taxation-related tasks, and its data processors. The duration of personal data processing: 5 years after the agreement terminated.

Data subject must be notified that the legal basis of the processing is the performing of the contract, this notification may be made in the agreement, as well.

Data subject must be notified that his or her personal data are forwarded to the data processor.

  

  • Contact details of natural persons who represent legal entities as clients, buyers, suppliers

Scope of the processed personal data: name, address, phone number, e-mail address of the natural person.

The purpose of processing the personal data: performing the contract the Company entered into with its partner who is a legal entity, maintaining business contact. Service Provider processes the personal data in accordance with Article 6 section (1) point f) of GDPR and the legal basis is its legitimate interest in establishing and maintaining business relations.

Recipient of personal data, and categories of recipients: employees of the Company performing tasks    related to its customer service.

Personal data are stored for five years after the business relation existed, or after the data subject acted as point of contact.

  • Data processing during technical support

The scope of personal data that can be managed: name, address, phone number, e-mail address of the natural person, the troubleshooting log, which contains all the communication between the device and the software.

The purpose of the processing of personal data: fulfillment of the contract concluded with the Company's partner, performance of technical support tasks, troubleshooting. The title of data processing is based on the title of performance of the contract.

Recipient of personal data, and categories of recipients: employees of the Company performing technical support tasks.

Storage period of personal data: duration of the performance of technical support tasks and troubleshooting, after which the data will be deleted immediately.

  • Activity related to the popup information windows appearing on the website:

The Data Controller uses the Poptin software for managing pop-up windows and data collection forms on its website. The purpose of data processing is market research and marketing activities. The data processing is always based on the consent of the visitors, provided they have accepted the use of cookies that require consent.

Processed data: name, email address, and other data provided by the visitor. In addition to the above, it collects and stores information related to the use of the website, such as visited pages, clicked links, non-sensitive text entries, and mouse movements, as well as more frequently collected information such as IP address, referring URL, browser, operating system, cookie information, Internet service provider, and any other information from the visitor related to the use of the website ("Visitor Information"). The entirety of Visitor Information can identify the visitor, however, the Poptin system does not identify the visitor during website browsing if cookies are disabled.

The operator of the Poptin system is Poptin LTD. Headquarters: Wework, Aluf Kalman Magen St 3, Tel Aviv-Yafo, Israel)

Website: https://www.poptin.com/ 

The service provider's privacy statement: https://www.poptin.com/gdpr/ 

The Data Processor processes and stores personal data on behalf of the Data Controller, based on the contract between them.

 

 

INFORMATION SUMMARY ON THE RIGHTS OF DATA SUBJECTS

 

 

In this chapter, to provide transparency and ensure unambiguity, we will summarize the rights of the data subject, and the next chapter will contain detailed information on how to exercise them.

 

 

Right to preliminary notification

 

Data subject has the right to receive information on the facts and information related to the processing prior to the beginning of the processing.

(Regulation Art. 13-14)

Data processing can only begin after the information has been provided. If the legal basis of the processing is consent, the data subject must provide his or her consent in addition to the information provided. Detailed rules are included in the next chapter.

 

Data subject’s right to access

The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the information determined in the Regulation.

(Regulation Art. 15)

Detailed rules are included in the next chapter.

 

 

Right to rectification

 

Data subject has the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Having regard to the purpose of the processing, data subject has the right to request the incomplete personal data to be completed, among others, by way of a supplementary declaration.

(Regulation Art. 16)

 

 

 

 

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

 

The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay, and controller shall be obliged to erase the personal data concerning the data subject without undue delay, where one of the grounds set forth in the Regulation applies. (Regulation Art. 17)

Detailed rules are included in the next chapter.

 

 

Right to restriction of processing

The data subject shall have the right to obtain from the controller restriction of processing where the grounds set forth in the Regulation apply.

(Regulation Art. 18)

Detailed rules are included in the next chapter.

 

Obligation to notify in case of the rectification, erasure of the personal data or the restriction of processing

Controller shall notify every recipient to whom the personal data have been revealed of every rectification, erasure or restriction of processing, except where this proves impossible or would require disproportionate efforts. Controller shall inform the data subject about those recipients should the data subject request it. (Regulation Art. 19)

 

Right to data portability

Subject to the conditions set forth in the Regulation, the data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to the Controller, in a structured, commonly used and machine-readable format; and furthermore, he or she has the right to have those data transferred to another Controller without this process being hindered by the Controller to whom he or she has provided such personal data.

(Regulation Art. 20)

Detailed rules are included in the next chapter.

 

Right to object

The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of his or her personal data which is based on point (e) of Article 6(1) of the Regulation (processing is 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 on point f) Art 6(1) (processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party).

(Regulation Art. 21)

Detailed rules are included in the next chapter.

 

Automated individual decision-making, including profiling

The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

(Regulation Art. 22)

Detailed rules are included in the next chapter.

 

Restrictions

Union or Member State law to which the Controller or processor is subject may restrict by way of a legislative measure the scope of the obligations and rights provided for in Articles 12 to 22, in so far as its provisions correspond to the rights and obligations provided for in Articles 12 to 22.

(Regulation Art. 23)

Detailed rules are included in the next chapter.

 

Communication of a personal data breach to the data subject

When the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, Controller shall communicate the personal data breach to the data subject without undue delay. (Regulation Art. 34)

Detailed rules are included in the next chapter.

 

Right to lodge a complaint with a supervisory authority

Data subject shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement, if the data subject considers that the processing of personal data relating to him or her infringes this Regulation. (Regulation Art. 77)

Detailed rules are included in the next chapter.

 

Right to an effective judicial remedy against a supervisory authority

Every natural or legal person shall have the right to an effective judicial remedy against a legally binding decision of a supervisory authority concerning them, or when the supervisory authority does not handle a complaint or does not inform the data subject within three months on the progress or outcome of the complaint.

(Regulation Art. 78)

Detailed rules are included in the next chapter.

 

Right to an effective judicial remedy against a controller or a data processor

Every data subject shall have the right to an effective judicial remedy where he or she considers that his or her rights under this Regulation have been infringed as a result of the processing of his or her personal data in non-compliance with this Regulation.

(Regulation Art. 79)

Detailed rules are included in the next chapter.

 

 

 

 

DETAILED INFORMATION ON THE RIGHTS OF THE DATA SUBJECT

 

 

Right to preliminary notification

Data subject has the right to receive information on the facts and information related to the processing prior to the processing begins.

 

Information to be provided where personal data are collected from the data subject

  1. Where personal data relating to a data subject are collected from the data subject, the controller shall, at the time when personal data are obtained, provide the data subject with all of the following information:
  2. the identity and the contact details of the controller and, where applicable, of the controller's representative;
  3. the contact details of the data protection officer, where applicable;
  4. the purposes of the processing for which the personal data are intended as well as the legal basis for the processing;
  5. where the processing is based on point (f) of Article 6(1) (pursuing legitimate interests), the legitimate interests pursued by the controller or by a third party;
  6. the recipients or categories of recipients of the personal data, if any;
  7. where applicable, the fact that the controller intends to transfer personal data to a third country or international organization and the existence or absence of an adequacy decision by the Commission, or in the case of transfers referred to in Article 46 or 47, or the second subparagraph of Article 49(1), reference to the appropriate or suitable safeguards and the means by which to obtain a copy of them or where they have been made available.
  8. In addition to the information referred to in paragraph 1, the controller shall, at the time when personal data are obtained, provide the data subject with the following further information necessary to ensure fair and transparent processing:
  9. the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period;
  10. the existence of the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data portability;
  11. where the processing is based on point (a) of Article 6(1) of the Regulation (data subject’s consent) or point (a) of Article 9(2) of the Regulation (data subject’s consent), the existence of the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
  12. the right to lodge a complaint with a supervisory authority;
  13. whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the data subject is obliged to provide the personal data and of the possible consequences of failure to provide such data;
  14. the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the Regulation and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
  15. Where the controller intends to further process the personal data for a purpose other than that for which the personal data were collected, the controller shall provide the data subject prior to that further processing with information on that other purpose and with any relevant further information as referred to in paragraph
  16. Paragraphs 1, 2 and 3 shall not apply where and insofar as the data subject already has the (Regulation Art. 13)

 

 

  1. Information to be provided where personal data have not been obtained from the data subject

 

  1. Where personal data have not been obtained from the data subject, the controller shall provide the data subject with the following information:
  2. the identity and the contact details of the controller and, where applicable, of the controller's representative;
  3. the contact details of the data protection officer, where applicable;
  4. the purposes of the processing for which the personal data are intended as well as the legal basis for the processing;
  5. the categories of personal data concerned;
  6. the recipients or categories of recipients of the personal data, if any;
  7. where applicable, that the controller intends to transfer personal data to a recipient in a third country or international organization and the existence or absence of an adequacy decision by the

Commission, or in the case of transfers referred to in Article 46 or 47, or the second subparagraph of Article 49(1), reference to the appropriate or suitable safeguards and the means to obtain a copy of them or where they have been made available.

  1. In addition to the information referred to in paragraph 1, the controller shall provide the data subject with the following information necessary to ensure fair and transparent processing in respect of the data subject:
  2. the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period;
  3. where the processing is based on point (f) of Article 6(1) (legitimate interest), the legitimate interests pursued by the controller or by a third party;
  4. the existence of the right to request from the controller access to and rectification or erasure of the personal data concerning him or her, as well as to restrict or to object to the processing of the personal data concerning the data subject, as well as the right to data portability;
  5. where the processing is based on point (a) of Article 6(1) of the Regulation (data subject’s consent) or point (a) of Article 9(2) of the Regulation (data subject’s consent), the existence of the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
  6. the right to lodge a complaint with a supervisory authority;
  7. from which source the personal data originate, and if applicable, whether it came from publicly accessible sources; and
  8. the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the Regulation and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
  9. The controller shall provide the information referred to in paragraphs 1 and 2:
  10. within a reasonable period after obtaining the personal data, but at the latest within one month, having regard to the specific circumstances in which the personal data are processed;
  11. if the personal data are to be used for communication with the data subject, at the latest at the time of the first communication to that data subject; or
  12. if a disclosure to another recipient is envisaged, at the latest when the personal data are first
  13. Where the controller intends to further process the personal data for a purpose other than that for which the personal data were obtained, the controller shall provide the data subject prior to that further processing with information on that other purpose and with any relevant further information as referred to in paragraph
  14. Paragraphs 1 to 4 shall not apply where and insofar as:
  15. the data subject already has the information;
  16. the provision of such information proves impossible or would involve a disproportionate effort, in particular for processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, subject to the conditions and safeguards referred to in Article 89(1) of the Regulation or in so far as the obligation referred to in paragraph 1 of this Article is likely to render impossible or seriously impair the achievement of the objectives of that processing. In such cases the controller shall take appropriate measures to protect the data subject's rights and freedoms and legitimate interests, including making the information publicly available;
  17. obtaining or disclosure is expressly laid down by Union or Member State law to which the controller is subject and which provides appropriate measures to protect the data subject's legitimate interests; or
  18. the personal data must remain confidential subject to an obligation of professional secrecy regulated by Union or Member State law, including a statutory obligation of

(Regulation Art. 14)

 

Data subject’s right to access

 

  1. The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
  2. the purposes of data processing:
  3. the categories of personal data concerned;
  4. the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
  5. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  6. the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
  7. the right to lodge a complaint with a supervisory authority;
  8. where the personal data are not collected from the data subject, any available information as to their source;
  9. the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the Regulation, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
  10. Where personal data are transferred to a third country or to an international organization, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 of the Regulation relating to the transfer.
  11. The controller shall provide the data subject with a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic The right to obtain a copy shall not adversely affect the rights and freedoms of others. (Regulation Art. 15)

 

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

 

  1. The data subject shall have the right to obtain from the Controller the erasure of personal data concerning him or her without undue delay, and Controller shall be obliged to erase the personal data concerning the data subject without undue delay, where one of the following grounds applies:
  2. personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  3. the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2) of the Regulation, and where there is no other legal ground for the processing;
  4. the data subject objects to the processing pursuant to Article 21(1) of the Regulation and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
  5. the personal data have been unlawfully processed;
  6. the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
  7. the personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the
  8. Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal
  9. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
  10. for exercising the right of freedom of expression and information;
  11. for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  12. for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3) of the Regulation;
  13. for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
  14. for the establishment, exercise or defence of legal claims. (Regulation Art. 17.)

Right to restriction of processing

  1. The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
  2. the accuracy of the personal data is contested by the data subject, in this case the restriction is for a period enabling the controller to verify the accuracy of the personal data;
  3. the processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
  4. the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
  5. the data subject has objected to processing pursuant to Article 21(1); in this case the restriction is for the period until it is verified whether or not the legitimate grounds of the controller override those of the data
  6. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member
  7. A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is

(Regulation Art. 18)

Right to data portability

The data subject shall have the right to receive the personal data concerning him or her, which he or she        

  has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal        data have been provided, where:

  1. the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and
  2. the processing is carried out by automated means.
  3. In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically
  4. The exercise of this right shall be without prejudice to Article 17 of the Regulation. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the
  5. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of (Regulation Art. 20)

 

Right to object

 

  1. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) of Article 6(1) of the Regulation (processing is 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 point f) (processing is necessary for pursuing the legitimate interests of controller or a third party), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal
  2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct
  3. Where the data subject objects to processing of personal data for direct marketing purposes, the personal data shall no longer be processed for such
  4. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other
  5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical
  6. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1) of the Regulation, the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

(Regulation Art. 21)

 

Automated individual decision-making, including profiling

 

  1. The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or
  2. Paragraph 1 shall not apply if the decision:
  3. is necessary for entering into, or performance of, a contract between the data subject and a data controller;
  4. is authorized by Union or Member State law to which the controller is subject, and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests; or
  5. is based on the data subject's explicit
  6. In the cases referred to in points (a) and (c) of paragraph 2, the data controller shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, including at least data subject’s right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.
  7. Decisions referred to in paragraph 2 shall not be based on special categories of personal data referred to in Article 9(1) of the Regulation, unless point (a) or (g) of Article 9(2) applies

and suitable measures to safeguard the data subject's rights and freedoms and legitimate interests are in place. (Regulation Art. 22)

 

 

Restrictions

 

  1. Union or Member State law to which the data controller or processor is subject may restrict by way of a legislative measure the scope of the obligations and rights provided for in Articles 12 to 22 and Article 34, as well as Article 5 in so far as its provisions correspond to the rights and obligations provided for in Articles 12 to 22, when such a restriction respects the essence of the fundamental rights and freedoms and is a necessary and proportionate measure in a democratic society to safeguard:
  2. national security;
  3. defence;
  4. public security;
  5. the prevention, investigation, detection or prosecution of criminal offenses or the execution of criminal penalties, including the safeguarding against and the prevention of threats to public security;
  6. other important objectives of general public interest of the Union or of a Member State, in particular an important economic or financial interest of the Union or of a Member State, including monetary, budgetary and taxation matters, public health and social security;
  7. the protection of judicial independence and judicial proceedings;
  8. the prevention, investigation, detection and prosecution of breaches of ethics for regulated professions;
  9. a monitoring, inspection or regulatory function connected, even occasionally, to the exercise of official authority in the cases referred to in points (a) to (e) and (g);
  10. the protection of the data subject or the rights and freedoms of others;
  11. the enforcement of civil law

 

  1. In particular, any legislative measure referred to in paragraph 1 shall contain specific provisions at least, where relevant, as to:
  2. the purposes of the processing or categories of processing;
  3. the categories of personal data;
  4. the scope of the restrictions introduced;
  5. the safeguards to prevent abuse or unlawful access or transfer;
  6. the specification of the controller or categories of controllers;
  7. the storage periods and the applicable safeguards taking into account the nature, scope and purposes of the processing or categories of processing;
  8. the risks to the rights and freedoms of data subjects; and
  9. the right of data subjects to be informed about the restriction, unless that may be prejudicial to the purpose of the

(Regulation Art. 23)

 

Communication of a personal data breach to the data subject

 

  1. When the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, Controller shall communicate the personal data breach to the data subject without undue
  2. The communication to the data subject referred to in paragraph 1 of this Article shall describe in clear and plain language the nature of the personal data breach and contain at least the information and measures referred to in points (b), (c) and (d) of Article 33(3) of the
  3. The communication to the data subject referred to in paragraph 1 shall not be required if any of the following conditions are met:
  4. the controller has implemented appropriate technical and organizational protection measures, and those measures were applied to the personal data affected by the personal data breach, in particular those that render the personal data unintelligible to any person who is not authorized to access the personal data, such as encryption;
  5. the controller has taken subsequent measures after the personal data breach which ensure that the high risk to the rights and freedoms of data subjects referred to in paragraph 1 is no longer likely to materialize;
  6. communication would involve disproportionate effort. In such a case, there shall instead be a public communication or similar measure whereby the data subjects are informed in an equally effective manner.
  7. If the controller has not already communicated the personal data breach to the data subject, the supervisory authority, having considered the likelihood of the personal data breach resulting in a high risk, may require it to do so or may decide that any of the conditions referred to in paragraph 3 are met. (Regulation Art. 34)

 

Right to lodge a complaint with a supervisory authority

 

  1. Without prejudice to any other administrative or judicial remedy, every data subject shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes this
  2. The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Article

(Regulation Art. 77)

The supervisory authority in Hungary is the National Authority for Data Protection and Freedom of Information. The detailed statutory regulations to be applied are included in Act CXII of 2011 on Informational Self-determination and Freedom of Information.

 

Right to an effective judicial remedy against a supervisory authority

 

  1. Without prejudice to any other administrative or non-judicial remedy, each natural or legal person shall have the right to an effective judicial remedy against a legally binding decision of a supervisory authority concerning
  2. Without prejudice to any other administrative or non-judicial remedy, each data subject shall have the right to an effective judicial remedy where the supervisory authority which is competent pursuant to Articles 55 and 56 does not handle a complaint or does not inform the data subject within three months on the progress or outcome of the complaint lodged pursuant to Article
  3. Proceedings against a supervisory authority shall be brought before the courts of the Member State where the supervisory authority is
  4. Where proceedings are brought against a decision of a supervisory authority which was preceded by an opinion or a decision of the Board in the consistency mechanism, the supervisory authority shall forward that opinion or decision to the court.

(Regulation Art. 78)

 

 

Right to an effective judicial remedy against a controller or a data processor

 

  1. Without prejudice to any available administrative or non-judicial remedy, including the right to lodge a complaint with a supervisory authority pursuant to Article 77 of the Regulation, each data subject shall have the right to an effective judicial remedy where he or she considers that his or her rights under this Regulation have been infringed as a result of the processing of his or her personal data in non-compliance with this
  2. Proceedings against a controller or a processor shall be brought before the courts of the Member State where the controller or processor has an Such proceedings may be brought before the courts of the Member State where the data subject has his or her habitual residence, unless the controller or processor is a public authority of a Member State acting in the exercise of its public powers.

(Regulation Art. 79)

 

 

 

LODGING A REQUEST BY DATA SUBJECT, CONTROLLER’S MEASURES

 

  1. The controller shall provide to the data subject information on the measures taken in response to his/her request for the exercising of his or her rights without undue delay but under no circumstances later than one month after the receipt of such a request.
  2. That period may be extended by two further months where necessary, taking into account the complexity and the number of the requests. The controller shall inform the data subject of any such extension no later than one month after the request has been received and shall provide the reasons for the
  3. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information, where possible, shall be provided by electronic
  4. If the controller does not take action on the request of the data subject, it shall inform the data subject of the reasons for not taking action without delay but not later than one month after the request has been received and shall inform the data subject of the possibility of lodging a complaint with a supervisory authority or seeking a judicial
  5. The data controller shall provide the information pursuant to Articles 13 and 14 of the Regulation and the information on the rights of the data subject (Articles 15 to 22 and 34 of the Regulation) without a fee. If the request

of the data subject is unquestionably unfounded or excessive, especially due to its repetitive nature, the controller may, with regard to the administrative costs of providing the requested information or communication or the implementation of the measures:

  1. charge a fee of HUF 6,350, or
  2. deny action in response to the

The burden of proof for determining the unquestionably unfounded or excessive nature of the request shall be borne by the controller.

  1. Where the controller has reasonable doubts concerning the identity of the natural person exercising the rights of the data subject, the controller may request the provision of additional information necessary to confirm the identity of the data subject.

 

 

DATA SECURITY

 

In the operation of our information technology systems, we implement the necessary solutions to manage privileges, and apply the necessary internal organizational and technical solutions to ensure that your data cannot be accessed, erased, saved from the system, or altered by unauthorized persons. We ensure that the data protection and data security requirements are observed by our data processors, as well. We keep records of any personal data breach, and where necessary, we inform the data subject of the incidents that have occurred and in so far as it is required by the Regulation.