Privacy policy

1. Introductory provisions

In the course of its operations and activities, Denevér-Comp Kereskedelmi és Szolgáltató Kft. (hereinafter: "Data Controller") pays particular attention to the protection of personal data that comes into its possession in connection with its activities, in particular, but not least, as required and expected by the mandatory legal provisions to comply with data management rules.

The Data Controller is committed to acting on the basis of the provisions of the European Union legal standards and Hungarian legislation in force at all times during the preservation and management of the personal data made available to it, and in all cases to take the measures required for safe data management.

These regulations were created based on the following main legislation in force:

• XLVIII of 2008 TV. about the basic conditions and certain limitations of economic advertising activity

• Act CXII of 2011 on the right to self-determination of information and freedom of information

• Regulation 2016/679/EU (April 27, 2016) on the protection of natural persons with regard to the processing of personal data and on the free flow of such data, and on the repeal of Regulation 95/46/EC

Data controller details:

name:Denevér-Comp Kereskedelmi és Szolgáltató Kft.

Headquarters: 1073 Budapest, Erzsébet körút 23.

Company registration number: 01-09-918023

Tax number: 14749265-2-42

The Data Controller undertakes to unilaterally comply with these regulations and requests that its customers also accept the provisions of the regulations. The Data Controller reserves the right to change the data protection policy, in which case the modified policy will be publicly published.

2. Interpretive provisions

Personal data:any information relating to an identified or identifiable natural person ("data subject"); a natural person can be identified directly or indirectly, in particular on the basis of an identifier such as name, number, location data, online identifier or one or more factors relating to the physical, physiological, genetic, mental, economic, cultural or social identity of the natural person can be identified

Data handling: any operation or set of operations performed on personal data or data files in an automated or non-automated manner, such as collection, recording, systematization, segmentation, storage, transformation or change, query, insight, use, communication, transmission, distribution or otherwise making it available , alignment or linking, restriction, deletion or destruction;

Affected: any natural person identified or - directly or indirectly - identified on the basis of personal data;

Consent of the affected person: the voluntary, concrete and clear declaration of the Data Subject's will based on adequate information, by means of which the Data Subject indicates by means of a declaration or an act clearly expressing the confirmation that he/she consents to the processing of personal data concerning him/her;

Data protection incident: a breach of security that results in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or unauthorized access to, personal data transmitted, stored or otherwise handled;

Protest: the statement of the Data Subject objecting to the processing of his personal data and requesting the termination of the data processing or the deletion of the processed data;

3. Basic principles of data management

Personal data:

a) it must be handled legally and fairly, as well as in a transparent manner for the data subject;

b) it is collected only for specific, clear and legitimate purposes, and they are not handled in a way that is incompatible with these purposes;

c) they must be appropriate and relevant for the purposes of data management and must be limited to what is necessary;

d) they must be accurate and, if necessary, up-to-date; all reasonable measures must be taken in order to immediately delete or correct personal data that is inaccurate in terms of the purposes of data management;

e) it must be stored in a form that allows the identification of the data subjects only for the time necessary to achieve the goals of personal data management;

f) must be handled in such a way that adequate security of personal data is ensured by applying appropriate technical or organizational measures, including protection against unauthorized or illegal processing, accidental loss, destruction or damage of data.

4. Legal basis of data management according to data management purposes

a) Contacting (GDPR Regulation Article 6 (1) point a)

If contact is made solely for the purpose of requesting preliminary information or an offer in written form, the data provided during the contact or request for an offer will be known to the Data Controller. Please note that the processing of your data provided in this way is based on your voluntary consent. The Data Controller considers consent to be given by sending the message to the Data Controller.

Legal basis for data management: the Data Subject's consent

Scope of processed data: data provided voluntarily by the Data Subject during contact

Duration of data management: the Data Controller manages the provided data until the contact is completed

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b) Request for quotation for troubleshooting of a laptop to be repaired (GDPR Regulation Article 6 (1) point b)

The person concerned has the right to order the troubleshooting of the laptop to be repaired on the interface available on the website of the Data Controller in order to make an offer to the Data Controller.

Legal basis for data management: At the request of the data subject, to take steps prior to entering into a contract

Scope of processed data:

• Affected name
• E-mail address and telephone number of the affected person
• the place of receipt of the device
• billing address
• tax number (only for business persons)

Duration of data management: until the 30th day after the offer was made to the Data Subject

c) Fulfillment of a repair (service) contract (GDPR Regulation Article 6 (1) point b)

By accepting the Repair Offer given by the Data Controller, the Data Subject expressly consents to the processing of his/her data necessary for the fulfillment of the Contract.

If a separate written contract is not concluded between the Parties regarding the repair, but a legal relationship/contract is established only through an agreement made by e-mail or telephone (making an offer and accepting it), the Data Controller shall consider it as express consent to data management if the Data Subject transfer the requested data to the Data Controller or do not object to the further processing of the data already transferred.

The purpose of the Data Management is to fulfill and execute the repair contract concluded with the Data Controller, including the placed and confirmed order, as well as to ensure any claims arising from it after fulfillment.

Legal basis for data management: fulfillment of the contract

Scope of data required to fulfill the contract and to be provided to the Data Controller:

• Affected name
• E-mail address and telephone number of the affected person
• the place of receipt of the device
• billing address
• tax number (only for business persons)

Duration of data management: after the completion of the contract, it is kept until the end of the general statute of limitations for any civil claims arising from the contract, i.e. for 5 years.

d) Fulfillment of sales contract (GDPR Regulation Article 6 (1) point b)

Data management is necessary in order to fulfill the sales contract concluded with the Data Controller.

The purpose of Data Management is to fulfill and execute the sales contract concluded with the Data Controller, as well as to ensure any claims arising from it after fulfillment.

Legal basis for data management: fulfillment of the contract

The range of data required for the performance of contracts and to be made available to the Data Controller:

• customer name
• customer address
• delivery address (if the order is delivered by home delivery)
• e-mail address and telephone number of the customer
• bank account number (in case of payment of the purchase price by bank transfer)

Duration of data management: The data manager shall keep the data provided to him necessary for the performance of the contract until the end of the general statute of limitations for any civil claims arising from the contract, i.e. for 5 years after the performance of the contract.

e) Issuance of an accounting certificate (GDPR Regulation Article 6 (1) point c)

The legal basis for the management of the data contained in the accounting certificate issued for the performance of the contract is created by the preservation obligation written in § 169.(2) of Act C of 2000 on accounting.

The purpose of handling the data included in the accounting certificate is to fulfill the obligation stipulated in the law.

Legal basis for data management: fulfillment of a legal obligation

The range of data required for the issuance of the accounting certificate and to be provided to the Data Controller:

• customer name
• customer address
• Delivery Address
• customer's tax number if necessary

Duration of data management: Based on § 169 (2) of Act C of 2000 on accounting, the data contained in the accounting documents are managed for 8 years. During this period, the Data Subject is not entitled to prohibit the processing of the data contained in the accounting document.

f) Warranty and warranty administration

The Data Subject wishes to enforce a guarantee or warranty claim against the Data Controller. If the Data Subject has requested warranty administration, data management and the provision of data are essential.

Legal basis for data management: fulfillment of contractual obligations

Scope of processed data:

• Affected name
• E-mail address and telephone number of the affected person

Duration of data management: CLV of 1997 on consumer protection. Act 17/A. 5 years based on § (7).

g) Contacting (GDPR Regulation Article 6 (1) point b)

By signing the contract with the Data Controller or, failing this, by using the contact details provided during the order, the data subject expressly consents to the processing of his/her data necessary for the fulfillment of the Contract. The Data Controller considers it an express and voluntary consent to data management if the Data Subject provides the requested data to the Data Controller.

Legal basis for data management: fulfillment of contractual obligations

The purpose of Data Management is to fulfill and execute the contract concluded in writing with the Data Controller or the order submitted and confirmed.

Scope of processed data:

• Name of the contact person
• contact address
• e-mail address and telephone number of the contact person

Duration of data management: until the 15th day after the completion of the contract.

Other recorded data

While browsing the web interface, technical information is recorded for statistical purposes. (IP address, duration of visit, etc.). During visits to the web interface, the Data Controller sends one or more cookies - i.e. a small file containing a series of characters - to the Data Subject's computer, through which his/her browser can be uniquely identified. These cookies are provided by Google and Facebook and are used through the Google and Facebook systems. These cookies are only used after the user's consent.

The cookies sent in this way are used as follows:

External service providers, including Google, store with the help of these cookies if the Data Subject has previously visited the web interface, and based on this, advertisements are displayed for the Data Subject on the websites of the external service providers, including Google and Facebook's partners. On the Google and Facebook ads deactivation page, you can disable Google cookies or change your consent settings at any time by clicking on the Cookie settings link in the footer of the website. (You can also indicate to the Data Subject that cookies from third-party providers can be disabled on the Network Advertising Initiative opt-out page.)

Used cookies:

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The legal basis for cookie management is the consent of the website visitor, based on Article 6 (1) point a) of the relevant GDPR regulation.

5. Data security

The Data Controller protects the data in particular against unauthorized access, alteration, transmission, disclosure, deletion or destruction, as well as against accidental destruction and damage.

In order to protect the personal data transferred to it on paper - in contracts, receipts - the Data Controller keeps them in a lockable cabinet and in a closed room, to which only senior officials and employees of the Data Controller have access.

Data transferred electronically to the Data Controller is stored on a computer device, which device is protected by a password known only to the Data Controller's senior officers and employees. The network used by the Data Controller is also password-protected against access to the personal data stored on the computing device on the World Wide Web.

6. Data processing

The Data Controller informs the Data Subject that IV. Data processed on the basis of sub-points c), d) and e) are transferred to the following person for the purpose of and for the purpose of fulfilling the accounting obligations required by law:

name: Adó-Faragó Team Kft.

registered office: 1134 Budapest, Gidófalvy L utca 33. III. em. 4.

Cg.: 01-09-930577

The Data Controller informs the Data Subject that IV. In order to carry out the delivery of goods for the purpose of fulfilling the contract, data processed on the basis of subparagraphs b), c), d) and e) will be transferred to the following contractors:

name: "PANNON XP" Kereskedelmi és Szolgáltató Kft.

registered office: 2142 Nagytarcsa, Csonka János utca 5.

Cg.: 13-09-205731

The Data Controller informs the Data Subject that IV. The following contractor is entitled to access the data processed on the basis of point 2.1 as a data processor due to hosting services:

Webflow, Inc.,

Address: 398 11th Street, 2nd Floor, San Francisco, CA 94103

Email: contact@webflow.com

The Data Controller informs the Data Subject that IV. As a data processor, the following contractor is entitled to access data processed on the basis of e-commerce services:

Ecwid Inc.

Address: 687 South Coast Highway 101, Suite 239, Encinitas, California 92024 USA

Support: https://support.ecwid.com/hc/en-us/requests/new

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The Data Controller informs the Data Subject that IV. Due to the online bank card payment service, the following entrepreneur is entitled to know the data processed on the basis of point 1 as a data processor:

Stripe Inc.

Address: 510 Townsend Street San Francisco, CA 94103, USA

Support: https://stripe.com/en-hu/contact

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The Data Controller informs the Data Subject that IV. Due to the use of invoicing software, the following entrepreneur is entitled to know the data processed on the basis of point 1 as a data processor:

name: Völgyerdő Nonprofit Kft.

registered office: Magyar utca 5, 8821 Nagybakónek.

Cg.: 20-09-076239

When using cookies, the following companies are entitled to access the data:

name: Google Inc.;

Headquarters: Google Inc., Mountain View, California, USA

Scope of known data: The IP address of visitors to the Data Management website - anonymized, not linked to a person.

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name: Facebook Inc.;

Headquarters: Facebook, Inc, Menlo Park, California, USA

Scope of known data: The IP address of visitors to the Data Management website - anonymized, not linked to a person.

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7. Data transfer to a third country

Data is transferred to the United States of America, with which a compliance decision was made on July 12, 2016 (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en).

The compliance decision a

Google (https://policies.google.com/privacy/frameworks),

Facebook (https://www.facebook.com/about/privacyshield),

Webflow (https://webflow.com/legal/eu-privacy-policy),

ECWID (https://www.ecwid.com/privacy-policy),

Stripe (https://stripe.com/privacy-shield-policy),

also applies in the case of data processing.

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8. Rights of Data Subjects

The Data Subject may request information from the Data Controller about the management of his personal data, the correction of his personal data, and the deletion of his personal data - with the exception of mandatory data management. You have addressed this type of request to the headquarters of the Data Controllerinfo@hasznaltlaptopszerviz.hu performed by the Data Controller by means of a request sent to the e-mail address. After logging in, the Data Subject has the right to modify or delete the data provided on the web interface.

At the request of the Data Subject, the Data Controller shall provide information about the Data Subject's data managed by it or processed by the data processor commissioned by it or at its disposal, its source, the purpose, legal basis, duration of the data management, the circumstances and effects of the data protection incident and the measures taken to prevent it, and - in the case of transmission of the personal data concerned - about the legal basis and recipient of the data transmission.

The Data Subject is entitled to request that the Data Controller restricts data processing if one of the following conditions is met:

a) the data subject disputes the accuracy of the personal data, in which case the limitation applies to the period that allows the data controller to check the accuracy of the personal data;

b) the data management is illegal and the data subject opposes the deletion of the data and instead requests the restriction of their use;

c) the data controller no longer needs the personal data for the purpose of data management, but the data subject requires them to submit, enforce or defend legal claims; obsession

d) the data subject objected to data processing; in this case, the restriction applies to the period until it is determined whether the legitimate reasons of the data controller take precedence over the legitimate reasons of the data subject.

The Data Controller is obliged to provide the information in writing at the request of the data subject in a form that is understandable to the public as soon as possible, but no later than 25 days after the submission of the request.

Information is provided free of charge if the person requesting information has not yet submitted an information request to the data controller for the same data set in the current year. In other cases, reimbursement may be established. The amount of reimbursement can also be fixed in the contract between the parties. The compensation already paid must be refunded if the data was handled unlawfully or the request for information led to a correction.

If the personal data does not correspond to the reality, and the personal data corresponding to the reality is available to the data controller, the personal data will be corrected by the data controller.

Personal data must be deleted if its processing is illegal, or the data subject requests its deletion, or if it is incomplete or incorrect - and this situation cannot be legally remedied - provided that the deletion is not precluded by law, and if the purpose of the data management has ceased, or the statutory period for data storage has expired or if it has been ordered by the court or the Authority.

The data subject and all those to whom the data was previously transmitted for the purpose of data management must be notified of the correction, blocking, marking and deletion. The notification can be omitted if this does not harm the legitimate interests of the data subject in view of the purpose of the data management.

If the data controller does not comply with the Data Subject's request for correction, blocking or deletion, within 25 days of receiving the request, it shall communicate the factual and legal reasons for rejecting the request for correction, blocking or deletion in writing or with the consent of the data subject electronically. In case of rejection of the request for correction, deletion or blocking, the data controller informs the data subject of the possibility of legal remedies in court, as well as the possibility of turning to the Authority.

The Data Subject may object to the processing of his personal data,

• if the data management is in the public interest or is necessary for the execution of a task performed in the framework of the exercise of a public authority granted to the data controller;
• if the data processing is necessary to enforce the legitimate interests of the data controller or a third party, unless these interests are overridden by the interests or fundamental rights and freedoms of the data subject that require the protection of personal data, especially if the data subject is a child;
• if the personal data is used or transmitted for the purpose of direct business acquisition, public opinion polls or scientific research; as well as
• in other cases specified by law.

The data controller examines the objection as soon as possible, but no later than 15 days after the submission of the application, makes a decision on its validity, and informs the applicant of his decision in writing.

If the data controller determines that the objection of the data subject is well-founded, it terminates the data management and blocks the data, as well as notifies all those to whom the personal data affected by the objection was previously transmitted, and who are obliged to take measures to enforce the right to object, about the objection and the measures taken based on it .

If the data subject does not agree with the data controller's decision, or if the data controller misses the deadline, the data subject may appeal to the court within 30 days of the communication of the decision or the last day of the deadline.

Legal remedies and complaints can be made at the following contacts:

Name: National Data Protection and Freedom of Information Authority

Address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c.

Phone: 06-1-391-1400

Fax: 06-1-391-1410

Email: ugyfelszolgalat@naih.hu

Website: naih.hu