Privacy policy

1. Introduction

Vörös Juharkert Kft. (hereinafter Vörös Juharkert Kft., service provider, data controller, the Company), as data controller, acknowledges the content of this legal notice as binding upon itself.
The Company undertakes that all data processing related to its activities complies with the requirements set out in this policy and in the applicable legislation.
Vörös Juharkert Kft. is the operator of the vorosjuharkert.hu website.

Vörös Juharkert Kft. reserves the right to amend this notice at any time. Naturally, it will inform its audience of any changes in good time.

Vörös Juharkert Kft. is committed to protecting the personal data of its clients and partners and considers it particularly important to respect its clients' right to informational self-determination. The Data Controller treats personal data confidentially and takes every security, technical and organizational measure that guarantees the security of the data.

Below, Vörös Juharkert Kft. sets out its data processing principles and the standards it has defined for itself as data controller and observes. Its data processing principles are in line with the applicable data protection legislation, in particular the following:

Act CXII of 2011 on the right to informational self-determination and on freedom of information;
Act V of 2013 on the Civil Code;
Act XLVIII of 2008 on the basic requirements and certain restrictions of commercial advertising activities;
Act CVIII of 2001 on certain issues of electronic commerce services and information society services;
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter „GDPR”)

2. Definitions

data subject: any natural person identified or identifiable, directly or indirectly, on the basis of specific personal data;
personal data: data that can be linked to the data subject, in particular the data subject's name, identification number and any information characteristic of one or more of their physical, physiological, mental, economic, cultural or social identity, as well as any conclusion about the data subject that can be drawn from such data;
consent: the voluntary and definite indication of the data subject's wish, based on adequate information, by which they give unambiguous agreement to the processing of their personal data, either in full or in respect of specific operations;
data controller: the natural or legal person, or organization without legal personality, who or which, alone or jointly with others, determines the purpose of the data processing, makes and implements the decisions concerning the processing (including the means used), or has them implemented by a data processor;
data processing: any operation or set of operations performed on data, irrespective of the procedure applied, in particular collecting, recording, registering, organizing, storing, altering, using, querying, transferring, disclosing, aligning or combining, blocking, erasing and destroying the data, as well as preventing their further use, taking photographs, audio or video recordings, and recording physical characteristics suitable for identifying a person (such as fingerprints or palm prints, DNA samples or iris images);
data transfer: making data accessible to a specified third party;
disclosure: making data accessible to anyone;
erasure of data: rendering data unrecognizable in such a way that their restoration is no longer possible;
data handling: the performance of technical tasks related to data processing operations, irrespective of the method and means applied and of the place of application, provided that the technical task is performed on the data;
data processor: the natural or legal person, or organization without legal personality, who or which processes the data on the basis of a contract, including a contract concluded pursuant to a statutory provision.

3. Company details

Our company's details and contact information are as follows:

Name: Vörös Juharkert Kft.
Postal address: 105 Pétfürdő, Hősök tere 1., Hungary
Company registration number: 19-09-523107
Tax number: 32001842-2-19
Phone: +36 30 293 5792
E-mail: info@vorosjuharkert.hu
Representative of the data controller: István Vörös, managing director

4. The scope of personal data, and the purpose, legal basis and duration of the processing

We draw the attention of those providing data to Vörös Juharkert Kft. to the fact that where they do not provide their own personal data, it is their obligation to obtain the data subject's consent. The data controller is not obliged to verify that such consent exists. The data controller draws the partner's attention to the fact that if they fail to meet this obligation and the data subject therefore asserts a claim against the data controller, the data controller may pass on the claim asserted, or the amount of the related damage, to the partner.

We provide the following information in relation to each of our processing activities.

4.1. Quote requests and enquiries by direct contact

Those interested may contact our Company directly by electronic mail sent to the Company's address or by telephone.

Purpose of the processing: keeping in contact, in order to promote communication between the data subject and our Company and to enable the closest and most effective cooperation possible.
Legal basis of the processing: legitimate interest – Article 6(1)(f) GDPR
Scope of the personal data processed: name of the person requesting the quote or the contact person; e-mail address, phone number and any other information provided by the data subject,
Duration of the processing: for three years following the expiry of the validity of the quote, or until the data subject objects
Recipients of the personal data: the data controller does not pass the data it has obtained to any third party, with the exception of the data processor(s) listed in point 7. The recorded data may only be accessed by the employees of the Data Controller and the designated colleagues of the data processor(s).
Specification of the legitimate interest: our Company's legitimate interest in processing the data subject's data is direct marketing.
Data subjects concerned: partners and data subjects who enquire directly (for example by e-mail or telephone) about the Company's services.

4.2. Quote requests and enquiries through the website (vorosjuharkert.hu)

Our company enables data subjects to request a quote electronically.

Purpose of the processing: keeping in contact, in order to promote communication between the data subject and our Company and to enable the closest and most effective cooperation possible.
Legal basis of the processing: the data subject's voluntary consent – Article 6(1)(a) GDPR.
Scope of the personal data processed: the name of the person enquiring (first name, surname); e-mail address, phone number, company name and any other information provided by the data subject.
Duration of the processing: for three years following the expiry of the validity of the quote, or until consent is withdrawn.
Recipients of the personal data: the data controller does not pass the data it has obtained to any third party, with the exception of the data processor(s) listed in point 7. The recorded data may only be accessed by the employees of the Data Controller and the designated colleagues of the data processor(s).
Data subjects concerned: partners and data subjects who enquire through the website about the Company's services and products.

4.3. Processing in connection with following up quote requests

Purpose of the processing: the data controller has a legitimate interest in keeping a record of the data subject's data beyond the validity period of the quote for the purpose of direct marketing.
Legal basis of the processing: the legitimate interest of the data controller, Article 6(1)(f) GDPR,
Scope of the personal data processed: the contact person's surname and first name; phone number; e-mail address
Recipients of the personal data: the data controller does not pass the data it has obtained to any third party, with the exception of the data processor(s) listed in point 7. The recorded data may only be accessed by the employees of the Data Controller and the designated colleagues of the data processor(s).
Duration of the processing: until the data subject objects
Specification of the legitimate interest: building business relationships with partners and those requesting quotes, and providing accurate information to data subjects. Our Company's legitimate interest in processing the data subject's data is direct marketing.
Data subjects concerned: the recipients of quotes previously issued by the Company and the contact person(s) named in them.

4.4. Newsletter registration

Purpose of the processing: sending e-mail newsletters that also contain commercial advertising to interested parties, and providing information on current matters
Legal basis of the processing: the data subject's prior, voluntary consent, Article 6(1)(a) GDPR,
Scope of the personal data processed: name, e-mail address
Duration of the processing: until the voluntary consent is withdrawn or the data subject unsubscribes from the newsletter. Our Company processes the data provided by the data subject until consent is withdrawn. Following the withdrawal of consent, we erase the processed data from our newsletter database within seven days at the latest, and will not send you newsletters thereafter.
Recipients of the personal data: the data controller does not pass the data it has obtained to any third party, with the exception of the data processor(s) listed in point 7. The recorded data may only be accessed by the employees of the Data Controller and the designated colleagues of the data processor(s). You may unsubscribe from the newsletter at any time by sending a message to our Company at info@vorosjuharkert.hu, or by clicking the unsubscribe icon in the newsletter.
Data subjects concerned: partners and data subjects who subscribe to the Company's electronic newsletter.

4.5. Newsletter data (for newsletter registrations made before 25 May 2018)

Purpose of the processing: sending e-mail newsletters that also contain commercial advertising to interested parties, and providing information on current matters
Legal basis of the processing: the legitimate interest of the data controller, Article 6(1)(f) GDPR,
Scope of the personal data processed: name, e-mail address
Duration of the processing: until the data subject objects
Specification of the legitimate interest: providing information containing commercial advertising and business offers to data subjects who have subscribed to the newsletter. Our Company's legitimate interest in processing the data subject's data is direct marketing.
Recipients of the personal data: the data controller does not pass the data it has obtained to any third party, with the exception of the data processor(s) listed in point 7. The recorded data may only be accessed by the employees of the Data Controller and the designated colleagues of the data processor(s). You may unsubscribe from the newsletter at any time by sending a message to our Company at info@vorosjuharkert.hu, or by clicking the unsubscribe icon in the newsletter.
Data subjects concerned: partners and data subjects who subscribed to the Company's electronic newsletter before 25 May 2018.

4.6. Camera system

Cameras operate on the premises run by the data controller in the interest of the personal and property security of data subjects and for other purposes. Information signs draw the attention of data subjects to their operation. The activities related to the operation of the camera system are set out in the site's „Data processing notice on property protection cameras”, which is available on the premises.

4.7. Processing related to ensuring the operation of the information technology service

Purpose of the processing: the websites of Vörös Juharkert Kft. may use so-called „cookies” (temporary markers) that allow faster access to them. By „cookies” we mean an item of information that is only active during an individual client session and that is placed from the website onto the Client's computer in order to enable faster identification. The Client may at any time request that cookies be switched off by changing their browser settings; this, however, may slow down or prevent access to some parts of the site or the use of certain functions.
The session cookies used avoid the need to resort to other IT tools that could potentially be harmful to the confidentiality of clients' browsing and do not allow the acquisition of identifying personal data.
The user is able to delete cookies from their own computer, or to disable the use of cookies in their browser. Cookies can generally be managed in the Tools/Settings menu of browsers, under privacy settings, labelled cookies.
Legal basis of the processing: the voluntary consent of the data subject (User), Article 6(1)(a) GDPR.
The User gives their voluntary consent to the processing by accepting the notice and declaration that appears when they begin browsing the website, or by continuing to browse.
Scope of the personal data processed: information technology processing concerns the range of data required for the operation of the „cookies” used to run the website and for the use of the log files applied by the web hosting provider.
Duration of the processing: until the session is closed
Recipients of the personal data: the data controller does not pass the data it has obtained to any third party, with the exception of the data processor(s) listed in point 7. The recorded data may only be accessed by the employees of the Data Controller and the designated colleagues of the data processor(s).
Data subjects concerned: every User visiting the website, irrespective of whether they use the services available on it.

5. Other processing activities

We provide information on processing activities not listed in this notice at the time the data are collected. We inform our clients that certain authorities, bodies performing public duties and courts may contact our company for the disclosure of personal data. Our company discloses personal data to such bodies – provided that the body concerned has specified the exact purpose and the scope of the data – only to the extent that is strictly necessary to achieve the purpose of the request, and only where the fulfilment of the request is prescribed by law.

6. Transfer of personal data to a third country or an international organization

Our Company does not transfer your personal data referred to above to any third country or international organization.

7. Information on the use of data processors

In the course of the processing, the data controller transfers the data to the data processor(s) it has contracted with for the performance of the contract.
Categories of recipients: system administration provider, accounting and payroll provider, server hosting and web hosting provider

8. Children

Our services are not intended for persons under the age of 16, and we ask that persons under 16 do not provide personal data to the Data Controller.
If it comes to our attention that we have collected personal data from a child under the age of 16 – with the exception of the processing of data required by law – we will take the steps necessary to erase the data as soon as possible.

9. Automated decision-making

Our Company does not apply automated decision-making in its data processing procedures or data collection.

10. The manner of storing personal data and the security of the processing

Our company's IT systems and other data storage locations are at its registered office and on the servers provided by the data processor. Our company selects and operates the IT tools used for processing personal data in the course of providing the service in such a way that the data processed are:

accessible to those entitled to access them (availability);
authentic and their authentication is ensured (authenticity of the processing);
verifiable as unaltered (data integrity);
protected against unauthorized access (confidentiality of the data).

We pay particular attention to the security of the data, and we take the technical and organizational measures and establish the procedural rules necessary to give effect to the guarantees under the GDPR. We protect the data with appropriate measures, in particular against unauthorized access, alteration, transfer, disclosure, erasure or destruction, as well as against accidental destruction or damage and against becoming inaccessible as a result of changes in the technology applied.

The IT systems and networks of our company and our partners are protected against computer-assisted fraud, computer viruses, computer intrusions and denial-of-service attacks. The operator ensures security through both server-level and application-level protection procedures. Daily backup of the data is in place. Our company takes every possible measure to avoid data protection incidents, and should such an incident occur, we act without delay – in accordance with our incident management policy – to minimize the risks and remedy the damage.

11. The rights of data subjects and remedies

The data subject may request information about the processing of their personal data, and may request the rectification or – with the exception of mandatory processing – the erasure of their personal data, may withdraw their consent, and may exercise their right to data portability and their right to object, in the manner indicated when the data were collected or using the contact details of the data controller given above.

The rights of data subjects and the remedies available to them are set out below on the basis of Act CXII of 2011 and Regulation (EU) 2016/679.

The right to information, otherwise known as the data subject's „right of access”: on the basis of Act CXII of 2011 and Article 15 of Regulation (EU) 2016/679, at the data subject's request the Data Controller provides information on

the data and the categories of personal data it processes,
the purpose of the processing,
the legal basis of the processing,
the duration of the processing,
where applicable, the period for which the data will be stored, or if this is not possible, the criteria used to determine that period,
where applicable, if the data were not collected from the data subject, all available information as to their source,
where applicable, automated decision-making, including profiling, and meaningful information about the logic involved and the significance of such processing, and
the consequences the data subject can expect,
the details of the data processor, if a data processor has been used, and the circumstances and effects of any data protection incident and the measures taken to remedy it, and
in the event of a transfer of the data subject's personal data, the legal basis, purpose and recipient of the transfer.

The information is provided free of charge if the person requesting it has not yet submitted a request for information on the same scope of data to the Data Controller in the current year. In other cases, a cost reimbursement may be charged. Any cost reimbursement already paid must be refunded if the data were processed unlawfully or if the request for information led to rectification.

The Data Controller draws the attention of data subjects to the fact that, pursuant to Act CXII of 2011, the information must be refused,

if, on the basis of an act, an international treaty or a binding legal act of the European Union, the Data Controller receives personal data in such a way that the transferring data controller indicates, at the same time as the transfer, that the rights of the data subject guaranteed by the said act are restricted, or that the processing is otherwise restricted;
in the interest of the external and internal security of the state, such as national defence, national security, the prevention or prosecution of criminal offences and the security of the enforcement of penalties, and further on state or municipal economic or financial grounds, on grounds of an important economic or financial interest of the European Union, as well as for the purpose of preventing and detecting disciplinary and ethical breaches connected with the practice of professions and breaches of labour law and occupational safety obligations – including in every case monitoring and supervision – and further in the interest of protecting the rights of the data subject or of others.

The Data Controller is obliged to notify the Hungarian National Authority for Data Protection and Freedom of Information of refused requests for information annually, by 31 January of the year following the year concerned.

The right to rectification: the data subject has the right to obtain from the Data Controller, without undue delay, the rectification of inaccurate personal data concerning them. Taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement. At the same time, if the personal data do not correspond to reality and the Data Controller has the accurate personal data at its disposal, the Data Controller is obliged to rectify the personal data even without a request from the data subject.

The right to erasure, otherwise known as the „right to be forgotten”: the data subject has the right to obtain from the Data Controller the erasure of personal data concerning them without undue delay, and the Data Controller is obliged to erase personal data concerning the data subject without undue delay, unless mandatory processing precludes this.

Beyond the case above, the Data Controller is obliged to erase the data pursuant to Act CXII of 2011 and Regulation (EU) 2016/679 of the European Parliament and of the Council if

the processing of the data is unlawful;
the data are incomplete or incorrect and this state cannot lawfully be remedied, provided that erasure is not precluded by law;
the purpose of the processing has ceased, or the statutory time limit for storing the data has expired;
it has been ordered by a court or by the Authority;
the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
the data subject objects to the processing and there is no overriding lawful ground for the processing;
the personal data have to be erased in order to comply with a legal obligation under the law applicable to the Data Controller;
the personal data were collected in relation to the offer of information society services referred to in Article 8(1) of Regulation (EU) 2016/679 offered directly to children.

Where the Data Controller has for some reason made the personal data public and is obliged to erase them in accordance with the above, it will take reasonable steps – including technical measures – taking account of the available technology and the cost of implementation, in order to inform other controllers processing the data that the data subject has requested the erasure of any links to, or copy or replication of, the personal data in question.

The Data Controller draws the attention of data subjects to the limits of the right to erasure or the „right to be forgotten” arising from the EU regulation, which are as follows:

the exercise of the right to freedom of expression and information;
compliance with an obligation under Union or Member State law applicable to the controller that requires the processing of personal data, or the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
reasons of public interest in the area of public health;
archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) of Regulation (EU) 2016/679, in so far as the right to erasure is likely to render impossible or seriously impair the achievement of that processing; or
the establishment, exercise or defence of legal claims.

The right to restriction of processing, otherwise known as the right to blocking: the data subject has the right to obtain from the Data Controller restriction of processing at their request.
If, on the basis of the information available, it can be assumed that erasure would harm the legitimate interests of the data subject, the data must be blocked. Personal data blocked in this way may only be processed for as long as the purpose of the processing that precluded the erasure of the personal data persists.

If the data subject contests the accuracy or correctness of the personal data but the incorrectness or inaccuracy of the contested personal data cannot be clearly established, the data are blocked. In this case the restriction applies for the period that enables the Data Controller to verify the accuracy of the personal data.

Pursuant to the EU regulation, the data must be blocked if

the processing is unlawful and the data subject opposes the erasure of the data and requests the restriction of their use instead;
the Data Controller no longer needs the personal data for the purposes of the processing, but the data subject requires them for the establishment, exercise or defence of legal claims; or
the data subject has objected to the processing; in this case the restriction applies for the period until it is established whether the legitimate grounds of the Data Controller override those of the data subject.

Where processing is subject to restriction (blocking), such personal data may, 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 State.

The Data Controller hereby expressly draws the attention of data subjects to the fact that the data subject's right to rectification, erasure and blocking may be restricted by law in the interest of the external and internal security of the state, such as national defence, national security, the prevention or prosecution of criminal offences and the security of the enforcement of penalties, and further on state or municipal economic or financial grounds, on grounds of an important economic or financial interest of the European Union, as well as for the purpose of preventing and detecting disciplinary and ethical breaches connected with the practice of professions and breaches of labour law and occupational safety obligations – including in every case monitoring and supervision – and further in the interest of protecting the rights of the data subject or of others.
The Data Controller informs the data subject of the matters set out in their request, and/or rectifies the data, and/or erases or restricts (blocks) the data, or takes other steps in accordance with the request unless there is a ground precluding this, without undue delay and at the latest within 30 days of receipt of the request.

The Data Controller notifies the data subject in writing of the rectification, the erasure and the restriction of processing, as well as all those to whom the data were previously transferred or handed over for the purposes of processing. At the data subject's request, the Data Controller informs them of these recipients. The notification may be omitted if this does not harm the legitimate interest of the data subject in view of the purpose of the processing, or if providing the information proves impossible or would require disproportionate effort. The Data Controller is also obliged to notify the data subject in writing if the exercise of the data subject's right cannot be realized for any reason, and must state precisely the factual and legal grounds as well as the remedies available to the data subject: the possibility of turning to the courts and to the National Authority for Data Protection and Freedom of Information.

The „right to data portability”: the data subject has the right to

receive the personal data concerning them, which they have provided to the Data Controller, in a structured, commonly used, machine-readable format, and further has the right to
transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
the processing is based on consent; and
the processing is carried out by automated means.

When exercising the right to data portability, the data subject has the right – where technically feasible – to request that the personal data be transmitted directly between controllers.
In view of the processing activities carried out by the Data Controller, the conditions for exercising the right to data portability are not met (there is no automated processing), and therefore the data subject cannot exercise this right.

The right to object: the data subject may object to the processing of their personal data, including profiling, if

the processing (transfer) of the personal data is necessary solely for the enforcement of a right or legitimate interest of the Data Controller or the recipient of the data, except in the case of mandatory processing;
the personal data are used or transferred for the purposes of direct marketing, public opinion polling or scientific research;
the exercise of the right to object is otherwise permitted by law.

The data subject may also object, on the basis of Article 21(3) of Regulation (EU) 2016/679, to the processing of their personal data for the purposes of direct marketing; in that case the personal data may no longer be processed for such purposes.

Where personal data are processed for scientific or historical research purposes or statistical purposes, the data subject has the right to object, on grounds relating to their particular situation, to the processing of personal data concerning them, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
The Data Controller – suspending the processing at the same time – examines the objection within the shortest possible time from the submission of the request, and within 30 days at the latest, and informs the applicant of the outcome in writing. If the applicant's objection is well founded, the Data Controller terminates the processing, including any further collection and transfer of data, and blocks the data, and notifies of the objection and of the measures taken on the basis of it all those to whom it previously transferred the personal data concerned by the objection and who are obliged to act in order to give effect to the right to object.

If the data subject disagrees with the Data Controller's decision, or if the Data Controller fails to meet the time limit referred to, the data subject may turn to the courts within 30 days of the communication of the decision.
The data subject has the right to object in connection with automated decision-making.

Judicial enforcement: in the event of an infringement of their rights, the data subject may turn to the courts. The court deals with the case as a priority. It is for the Data Controller to prove that the processing complies with the law.

In the event of an infringement of the right to informational self-determination, a report or complaint may be submitted to:

Hungarian National Authority for Data Protection and Freedom of Information (NAIH)
Address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c, Hungary
Phone: +36 (1) 391-1400, Fax: +36 (1) 391-1410
www: http://www.naih.hu
e-mail: ugyfelszolgalat@naih.hu