TABLE OF CONTENTS
INTRODUCTION CHAPTER I - NAME OF THE DATA CONTROLLER CHAPTER II - NAMES OF THE DATA PROCESSORS - The IT Service Provider of our company
- Postal services, delivery, dispatch of parcels
CHAPTER III - PROCESSING OF VISITORS’ DATA ON THE WEBSITE OF THE COMPANY - GUIDANCE ON THE APPLICATION OF COOKIES- General information on cookies
- Guidance on the cookies, web beacons applied on the web site of the Company and data generated during the visit
- Data processing
- Transfer of personal data
CHAPTER IV - GUIDANCE ON THE RIGHTS OF THE DATA SUBJECT- The right to be informed, the right of revocation of consent to data processing and the right of erasure
- Opportunities for enforcement of rights
INTRODUCTION
REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 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 (hereinafter: Regulation) requires that in line with the principle of transparency, controllers shall provide information and communication relating to processing of personal data in a concise, transparent, intelligible and easily accessible form, using clear and plain language, furthermore, that the controllers shall facilitate the exercise of data subject rights. Act CXII of 2011 on Informational self-determination and freedom of information also prescribes the obligation of providing information to the data subject in advance. We comply with this statutory obligation by the provision of the guidance below. This guidance applies to data control performed through the web site of https://www.guideofbudapest.hu/. The main purpose of these rules is to define the data protection and data processing principles applied by Kleyer Tolmács és Idegenforgalmi Szolgáltató Betéti Társaság. and the data protection and data processing policy of the organization, as well as to provide information on the data control activities performed by it. The purpose of these rules is also to guarantee that in every field of the services provided by Kleyer Tolmács és Idegenforgalmi Szolgáltató Betéti Társaság the protection of the rights and legitimate interests of every individual is ensured. As the Data Controller, Kleyer Tolmács és Idegenforgalmi Szolgáltató Betéti Társaság reserves the right to modify unilaterally its data protection policy and simultaneously the contents of these rules, if the services provided by it are modified, furthermore, in accordance with the currently applicable legal requirements. The Data Controller will notify the data subjects on any change in these Rules simultaneously with the implementation of the change, on the website of https://www.guideofbudapest.hu/
CHAPTER I
NAME OF THE DATA CONTROLLER
- The entity issuing this guidance, which is also the Data Controller is:
- Company name: Kleyer Tolmács és Idegenforgalmi Szolgáltató Betéti Társaság.
- Registered office: HUNGARY 1195 Budapest, Batthyány u. 4/2
- Registration number: 01-06-756402
- Tax number: 21552021-1-43
- Representative: Kleyer Éva
- Telephone number: +36 / 30 962-8656
- E-mail: ekleyer@gmail.com
- Web Site: www.guideofbudapest.hu
- (hereinafter: Company)
CHAPTER II
NAMES OF THE PROCESSORS
“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller; (Regulation Article 4 (8)).
The prior approval of the data subject is not required for using the services of a processor, but he must be informed. Accordingly, we provide the following information:
- The IT Service Provider of our Company
Our Company does not use the services of processors for the maintenance and management of its website, it provides the IT services (storage space provision) itself, and in that framework – for the term of our contract concluded with him - manages the personal data provided on the website, the activity performed by it is the storage of personal data on the server.
- The name of this processor is the following:
- Company name: Kleyer Tolmács és Idegenforgalmi Szolgáltató Betéti Társaság
- Registered office: HUNGARY 1195 Budapest, Batthyány u. 4/2
- Tax number: 21552021-1-43
- Representative: Kleyer Éva
- Data controller: Kleyer Viktória
- Postal services, delivery, dispatch of parcels
These data processors will receive from our Company the personal data necessary for the delivery of the ordered goods (name, address, telephone number of the data subject), and they will deliver the goods by using these data.
These service providers are: Hungarian Post
CHAPTER III
PROCESSING OF VISITORS’ DATA ON THE WEBSITE OF THE COMPANY - GUIDANCE ON THE APPLICATION OF COOKIES
- General information on cookies
1.1. A cookie is a data which is sent by the visited website to the browser of the visitor (in the form of a variable name – value), so that it should store it and later on the same website is able to load its content. Cookies are small data packages containing configuration settings that facilitate making online services more user-friendly, efficient and secure. 1.2. The essence of a cookie is that by their very nature, website services need to designate a user (e.g. that he has visited the website) and to be able to handle that user accordingly later on. 1.3. Types of cookies: 1.3.1. Technically essential session cookies: those without which the website simply could not function, these are necessary for the identification of the users, e.g. for his handling, whether he has visited the website, what he has put in the basket, etc. This typically means the storage of a session ID, the rest of the data are stored on the server, since it is more secure that way. It also has security implications, if the cookie value of the session has not been generated properly, then there is the danger of a session hijacking attack, therefore it is absolutely necessary to generate these values properly. According to other terminologies, every cookie is called a session cookie that gets deleted when leaving the browser (one session is the use of the browser, from start until exit). 1.3.2. Cookies facilitating use: this is the customary name of those cookies that memorize the choices of the user, for example, in what way the user wants to view the site. This kind of cookies essentially mean the setting data stored in the cookie. 1.3.3. Cookies ensuring performance: although these are not really related to "performance", this is the usual name of those cookies that collect information on the behaviour of the user within the visited website, the time spent there, his clicks. These are typically applications of third parties (e.g. Google Analytics, AdWords, or Yandex.ru cookies). These are capable of profiling the visitors. The proper setting of data protection of the browser or of the mobile devices enables you to receive notifications whenever cookies are sent to your device, that way you can decide on a case-by-case basis whether to allow or disallow the use of the cookies. In addition, you can prevent the acceptance of cookies in certain cases only or as a default setting, and you can activate the automatic deletion of the cookies every time your browser gets closed. However, you should always bear in mind that if you deactivate cookies, certain functions of online services will not be fully available.
- Guidance on the cookies, web beacons applied on the web site of the Company and data generated during the visit
2.1. The following scope of data is managed during your visit: When using the website of our Company (https://www.guideofbudapest.hu/), we may record and process the following data about the visitor and the device used by him for browsing:
- the IP address used by the visitor,
- the type of the browser,
- characteristics of the operating system of the device used for browsing (language setting),
- the date and time of the visit,
- functions or services of the visited (sub-)pages.
We will retain these data for a term not exceeding 90 days and we can use them primarily for the investigation of security breaches. 2.2. Cookies applied on the website
2.2.1. Session cookies that are
technically absolutely necessary The purpose of data control: assurance of the proper operation of the website. These cookies are necessary for our visitors to be able to browse our web site, to use its functions seamlessly and fully, as well as the services available through our website. The term of data processing by these cookies only applies to the current visit of the visitor, when the session is over and after the closing of the browser this kind of cookies will be deleted from his computer automatically. Our on-line services typically use “session cookies”, which get deleted automatically when the browser gets closed. On occasion they also use "permanent cookies", which will remain on your device until they get expired or until you delete them manually. Permanent cookies enable us to recognize your browser upon your next visit. Guidance is provided on “third-party cookies”, i.e. the cookies of third-party service providers, such as Google Inc., among the data protection policies of the given service provider.
2.2.2. Web beacons In addition to cookies, we also use so-called web beacons (which we can also call page labels) for the analysis of visits to our website or newsletters. For example, our newsletters and HTML emails may contain web beacons that are capable of determining whether the given email message or the link sent in the message was opened. Such information facilitates the improvement of our email services and the adaptation of our contents to the needs of the users. When you delete the email message, you also delete the web beacon. Obviously, email messages with plain text do not contain web beacons. 2.2.3 Web analytics In order to keep optimizing our operations and accomplish utmost user-friendliness, some of our online services use the web analytics services and social plug-ins listed here. The type of data used for this purpose is exclusively non-personal data.
- Google Analytics: The Google Analytics system of Google Inc., 1600 Amphitheatre Parkway Mountain View CA 94043, USA, uses cookies, i.e. text data packages stored on your computer, in order to analyze how you use our online services. Generally, the data collected by the cookie concerning your behaviour as a user will be forwarded to the Google server located in the US and stored on the server. If IP anonymization is activated for online services, then Google will truncate the IP address in member states of the European Union and the European Economic Area already. It is only in extraordinary cases that the entire IP address is forwarded to the Google server located in the US and is truncated there. Google uses this information under the commission of the operator of the online services, in order to analyze the use of online services by you, to compile reports on these activities, furthermore, to provide other services related to the use of online services and use of the Internet to the operator of the website. The IP address forwarded by your browser under Google Analytics will not be matched to other data in the possession of Google. You can prevent the saving of the cookies by the relevant setting of your browser software. However, in such a case you will not be able to use every function of the online services fully. The collection of the data generated by cookies and their use by Google can be prevented by downloading and installing the browser plug-in available on the following link (https://tools.google.com/dlpage/gaoptout?hl=en). You can find detailed information on conditions of use and roles of data protection on this link: www.google.com/analytics/terms/gb.htmlorhttps://www.google.com/policies/ /.
- Facebook plug-ins („Share” button): The plug-ins of the company Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA can be recognized by the logo of Facebook or the "Share" button. To review Facebook plug-ins click here: http://developers.facebook.com/docs/plugins/. When you use our online services, the plug-in will establish a direct connection between your browser and the servers of Facebook. That way, Facebook will receive information indicating that you are using online services with your IP address. When you click on the “Share” button of Facebook, while you are logged in your Facebook account, you can attach the contents of our online services to your Facebook profile. In that case Facebook is able to link the use of our online services with your user account. We would like to emphasize that as the provider of online services, we have no knowledge concerning the contents of the forwarded data and their use by Facebook. For further information please read the data protection policy of Facebook: https://www.facebook.com/policy.php. If you do not intend to authorize Facebook to link the use of online services to your Facebook user account, please log out from your Facebook user account.
- Xing: Every time when you use such online services that utilize the Xing network of XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany, a connection will be established with the Xing servers. As far as we know, no personal data get stored. Specifically, Xing will not store IP addresses or analyze user activities. For further information please read the data protection policy of Xing: https://www.xing.com/app/share?op=data_protection.
- YouTube: YouTube is operated by the company Google, i.e. YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. When you use any of our online services with a YouTube plug-in, then it will get connected to the servers of YouTube and the information related to the online service being used is forwarded to the servers of YouTube. If you are logged in your YouTube account, by this you enable YouTube to the connect your browsing activity directly with your user profile. You can prevent this by logging out from your YouTube account. Please refer to the data protection policy of YouTube for more information concerning the use of your data by YouTube: https://www.google.com/intl/en/policies/privacy/.
- Twitter: Twitter service is provided by the company Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. When you use the Twitter application and the „re-tweet” function, the online services being used by you will get connected with your twitter account and the rest of the users will also be notified on that. Simultaneously, data will be forwarded into the Twitter application. We would like to highlight that as the provider of online services we are not aware of the contents of the forwarded data and their use by Twitter. For more information please refer to the data protection policy of Twitter: http://twitter.com/privacy. The data privacy settings of your Twitter account can be changed, see: http://twitter.com/account/settings.
- LinkedIn: The LinkedIn network is operated by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. Each time you use any of our online services containing LinkedIn functions, a connection is established with the LinkedIn servers. LinkedIn will receive information indicating that you are using our online services with your IP address. When using the LinkedIn program, you click on the “Recommend” button while you are logged in your LinkedIn account, then the use of our online services can be connected to you and your user account. We would like to highlight that as the provider of online services we are not aware of the contents of the forwarded data and their use by LinkedIn. For more information please refer to the data protection policy of LinkedIn: https://www.linkedin.com/legal/privacy-policy
- Hotjar: In an effort to improve user experience, some of our on-line services use Hotjar software (http://www.hotjar.com, 3 Lyons Range, 20 Bisazza Street, Sliema SLM 1640, Malta, Europe). Hotjar enables the tracking and evaluate of user activities (mouse movements, clicks, scrolling). For that purpose Hotjar installs its own cookies on the device of the user and is capable of storing the data of the user, e.g. browser information, operating system, time spent in the website, etc. For further information on data processing by Hotjar, please refer to: hotjar.com/privacy.
- Siteimprove: Siteimprove Analytics is the web analytics service of Siteimprove A/S (Sankt AnnæPlads 28, 1250 Copenhagen, Denmark), which uses cookies, i.e. data packages stored on the computer, and analyses the use of our on-line services. Using the cookies, they collect information about our on-line services (including the encrypted IP address of the user), forward it to the Siteimprove server located in Denmark and store it there. Siteimprove uses this information for evaluating the use of on-line services and for compiling reports. Siteimprove does not forward this information to third parties. Siteimprove collects and processes the data according to the German data privacy requirements. The user may prevent the installation of the cookies by selecting the appropriate setting of the browser software. In such cases not every function of the on-line services will be fully available to the user. For more information please refer to the data protection policy of Siteimprove:https://siteimprove.com/legal/privacy-policy/
- Data processing
As a basic principle, we will process and utilize the personal data provided by you exclusively for the purposes presented. These include the following: 3.1. Ordering informative materials If you order informative materials from us, we will use the personal information provided by you exclusively for the processing of your order. We may use the services of third parties for the fulfillment of orders, and we may forward your data to these parties only in order to fulfill your order. We can only use the personal data provided by you for any other purpose if you have consented to such use. The purpose of data processing: Dispatch of informative materials. Legal basis for data control: Your voluntary consent. Scope of controlled data: Name, email address, telephone number. Term of data control: 1 year following the delivery of the informative material.
- Transfer of personal data
Depending on the type of the interaction requested by you (e.g. call-back, placement of an order, request for service, request for information, etc.) your data may be delivered to third parties involved in the fulfillment of the order (e.g. mail order companies, banks, etc.). In addition, we may be requested to transfer these data in order to fulfill legal requirements or implement rights and agreements. 4.1. Onward transfer We use third-party service providers for the fulfillment of certain orders and for the provision of certain services (e.g. forwarders). The service providers are allowed to use and transfer the data collected and processed by us, exclusively for the purpose of fulfilling the orders given by us. 4.2. Protection of rights and property: If we have reason to suppose that the rights and property of the Data Controller, the suppliers, customers or third parties have been or may be damaged, then we can use your personal data or disclose them in order to protect these rights and/or properties. In addition, we reserve the right to disclose your data if we are required to do so by laws or by competent authorities. We transfer your personal data for the following purposes:
- implementation of or compliance with laws, statutes, orders or obligatory instructions issued by public authorities,
- detection and prevention of security threats, fraud or other crimes,
- protection and/or implementation of the rights and property of Data Controllers or third parties,
- protection of the rights and personal safety of our own employees and the employees of third parties.
CHAPTER IV
ON THE RIGHTS OF THE DATA SUBJECT
- The right to be informed, the right of revocation of consent to data processing and the right of erasure
You are entitled to request information in writing about your personal data stored by us. In addition, concerning the use of your personal data, you are entitled to request rectification, erasure, termination or restriction of data processing, and you are also entitled to submit complaints to the data protection authority. Please send such requests, with all other questions, in writing to us, to our address provided in Chapter I.
- Opportunities for enforcement of rights
The Data Controller has informed the data subjects that if their rights were violated:
- They may refer the matter to the Data Controllers: the request will be investigated and the applicant will be notified on the results of the investigation in writing;
- They may refer the matter to court: litigation may be started at a tribunal having jurisdiction for the location or place of residence of the data subject, as the data subject chooses, the court will give priority to the procedure.
- Complaints may be submitted to the supervisory authority:
- competent authority: National Authority for Data Protection and Freedom of Information
- address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c
- tel.: +36 (1) 391-1400
- web site: http://www.naih.hu
- e-mail: ugyfelszolgalat@naih.hu
Done: Budapest, 25 May 2018
Kelt: Budapest, 2018. május 25. Close 
