Data processing information

On the use of a data processor and their activities related to data processing

Data processing for the storage of personal data

Name of the data processor: UNAS Online Kft.

Contact details of the data processor:

Phone number:

Email address: unas@unas.hu

Headquarters: 9400 Sopron, Kőszegi út 14.

The Data Processor stores personal data based on a contract concluded with the Data Controller. It is not authorized to view personal data.

Data processing activities related to the transport of goods

Name of the data processor: GLS General Logistics Systems Hungary Package-Logistics Ltd.

The data processor's registered office is: 2351 Alsónémedi, GLS Európa u. 2.

Data processor's telephone number: +36-29/88 66 70

Data processor's email address: info@gls-hungary.com

The Data Processor assists in the delivery of the ordered goods based on a contract concluded with the Data Controller. In doing so, the Data Processor may process the customer's name, address and telephone number until the end of the calendar year following the posting of the postal item, after which it will be deleted immediately.

Data processing activities related to sending newsletters

Name of the company operating the newsletter sending system: Sales Autopilot

Registered office of the company operating the newsletter system: Margit krt. 31-33. mezzanine 4. 1024 Budapest,

Telephone number of the company operating the newsletter sending system: (+36) 1 490 0172

Email address of the company operating the newsletter sending system: info@salesautopilot.hu

The Data Processor participates in sending newsletters based on a contract concluded with the Data Controller. In doing so, the Data Processor processes the name and e-mail address of the data subject to the extent necessary for sending the newsletter and deletes it immediately upon the data subject's request.

Your rights during data processing

Within the period of data processing, you have the following rights in accordance with the provisions of the Regulation:

• the right to withdraw consent
• access to personal data and information about data processing
• right to rectification
• restriction of data processing,
• right to erasure
• right to protest
• right to portability.

If you wish to exercise your rights, this will involve your identification, and the Data Controller will necessarily need to communicate with you. Therefore, for the purpose of identification, it will be necessary to provide personal data (but identification may only be based on data that the Data Controller already processes about you), and your complaint regarding data processing will be available in the Data Controller's email account within the period specified in this information regarding complaints. If you were our customer and would like to identify yourself for the purpose of complaint management or warranty administration, please also provide your order ID for identification. Using this, we can also identify you as a customer.

The Data Controller will respond to complaints related to data processing within 30 days at the latest.

Right to withdraw consent

You have the right to withdraw your consent to data processing at any time, in which case we will delete the data you have provided from our systems. However, please note that in the case of an order that has not yet been fulfilled, withdrawal may result in us not being able to deliver it to you. In addition, if the purchase has already been made, we cannot delete billing-related data from our systems based on accounting regulations, and if you have a debt to us, we may process your data based on our legitimate interest in collecting the debt even if you withdraw your consent.

Access to personal data

You have the right to receive feedback from the Data Controller as to whether your personal data is being processed and, if processing is in progress, you have the right to:

• obtain access to the personal data processed and
• The Data Controller shall inform you of the following information:
  • the purposes of data processing;
  • the categories of personal data processed about you;
  • information about the recipients or categories of recipients to whom the personal data have been or will be disclosed by the Data Controller;
  • the planned period for which the personal data will be stored or, if this is not possible, the criteria for determining this period;
  • your right to request from the Data Controller the rectification, erasure or restriction of processing of personal data concerning you, and to object to the processing of such personal data where processing is based on legitimate interest;
  • the right to lodge a complaint with the supervisory authority;
  • if the data was not collected from you, all available information about its source;
  • the fact of automated decision-making (if such a procedure is applied), including profiling, and at least in these cases, understandable information about the logic involved and the significance and likely consequences of such processing for you.

The purpose of exercising the right may be to establish and verify the lawfulness of data processing, therefore, in the event of multiple requests for information, the Data Controller may charge a fair fee in exchange for providing the information.

The Data Controller provides access to personal data by sending you the processed personal data and information by email after you have been identified. If you have registered, we provide access by logging into your user account to view and check the personal data processed about you.

Please indicate in your request whether you are requesting access to personal data or information related to data processing.

Right to rectification

You have the right to request that the Data Controller correct inaccurate personal data concerning you without delay.

Right to restrict data processing

You have the right to request that the Data Controller restrict data processing if one of the following applies:

• You dispute the accuracy of the personal data, in which case the restriction applies for a period of time that allows the Data Controller to verify the accuracy of the personal data; if the accuracy of the data can be determined immediately, the restriction will not apply;
• the data processing is unlawful, but you oppose the deletion of the data for any reason (for example, because the data is important to you for the enforcement of a legal claim), therefore you do not request the deletion of the data, but instead request the restriction of its use;
• the Data Controller no longer needs the personal data for the specified data processing purposes, but you require them for the establishment, exercise or defence of legal claims; or
• You have objected to the data processing, but the legitimate interests of the Data Controller may also justify the data processing, in which case, until it is determined whether the legitimate interests of the Data Controller override your legitimate interests, the data processing must be restricted.

Where processing is subject to restrictions, such personal data may be processed, with the exception of storage, only with the consent of the data subject, 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 important public interest reasons of the Union or of a Member State.

The data controller will inform you in advance (at least 3 working days before the restriction is lifted) about the lifting of the restriction on data processing.

Right to erasure – right to be forgotten

You have the right to have the Data Controller erase your personal data without undue delay if one of the following reasons applies:

• the personal data are no longer necessary for the purposes for which they were collected or otherwise processed by the Data Controller;
• You withdraw your consent and there is no other legal basis for the processing;
• You object to processing based on legitimate interest and there is no overriding legitimate reason (i.e. legitimate interest) for the processing,
• the personal data was processed unlawfully by the Data Controller and this was established based on the complaint,
• the personal data must be erased to comply with a legal obligation under Union or Member State law applicable to the Controller.

If the Data Controller has made personal data processed about you public for any legitimate reason and is obliged to erase them for any of the reasons indicated above, it is obliged to take reasonable steps, taking into account available technology and the cost of implementation, including technical measures, to inform other data controllers processing the data that you have requested the erasure of links to the personal data in question or of copies or replications of these personal data.

Erasure does not apply if data processing is necessary:

• for the purpose of exercising the right to freedom of expression and information;
• for the purpose of fulfilling an obligation under Union or Member State law to which the controller is subject to which the personal data must be processed (such as processing in the context of invoicing, as the retention of the invoice is required by law), or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• to submit, enforce or defend legal claims (e.g. if the Data Controller has a claim against you and has not yet fulfilled it, or a consumer or data processing complaint is in progress).

Right to object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data based on legitimate interest. In such a case, the Controller shall no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such purposes, including profiling, insofar as it is related to direct marketing. If you object to the processing of your personal data for direct marketing purposes, your personal data will no longer be processed for such purposes.

Right to portability

If the data processing is carried out by automated means or if the data processing is based on your voluntary consent, you have the right to request the Data Controller to receive the data you have provided to the Data Controller, which the Data Controller will make available to you in xml, JSON, or csv format, if this is technically feasible, you may request that the Data Controller transmit the data in this form to another data controller.

Automated decision-making

You have the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects concerning you or similarly significantly affects you. In such cases, the Controller shall take suitable measures to safeguard the rights, freedoms and legitimate interests of the data subject, including at least the right to obtain human intervention on the part of the Controller, to express his or her point of view and to object to the decision.

The above does not apply if the decision:

• Necessary for the conclusion or performance of a contract between you and the data controller;
• is permitted by Union or Member State law applicable to the controller, which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
• based on your express consent.

Logging into the data protection register

According to the provisions of the Infotv., the Data Controller had to report certain data processing operations to the data protection register. This reporting obligation ceased on May 25, 2018.

Data security measures

The Data Controller declares that it has taken appropriate security measures to protect personal data against unauthorized access, alteration, transmission, disclosure, deletion or destruction, as well as against accidental destruction and damage, as well as against inaccessibility resulting from changes in the technology used.

The Data Controller will do everything within organizational and technical capabilities to ensure that its data processors also take appropriate data security measures when working with your personal data.

Legal remedies

If you believe that the Data Controller has violated any legal provision relating to data processing or has not fulfilled any of your requests, you may initiate an investigation procedure with the National Data Protection and Freedom of Information Authority in order to terminate the alleged unlawful data processing (correspondence address: 1530 Budapest, P.O. Box: 5., e-mail: ugyfelszolgalat@naih.hu).

We also inform you that in the event of a violation of the legal provisions relating to data processing, or if the Data Controller has not fulfilled any of your requests, you may file a civil lawsuit against the Data Controller in court.

Modification of data processing information

The Data Controller reserves the right to amend this data management information in a way that does not affect the purpose and legal basis of the data management. By using the website after the amendment comes into force, you accept the amended data management information.

If the Data Controller intends to carry out further data processing in relation to the collected data for a purpose other than the purpose of their collection, it will inform you of the purpose of the data processing and the following information prior to further data processing:

• the duration of storage of personal data or, if this is not possible, the criteria for determining the duration;
• the right to request access to, rectification, erasure or restriction of processing of your personal data from the Data Controller, and to object to the processing of your personal data in the case of processing based on legitimate interest, and to request the right to data portability in the case of processing based on consent or a contractual relationship;
• in the case of data processing based on consent, that you can withdraw your consent at any time,
• the right to lodge a complaint with the supervisory authority;
• whether the provision of personal data is based on a legal or contractual obligation or is a prerequisite for entering into a contract, and whether you are obliged to provide the personal data, as well as the possible consequences of failure to provide the data;
• the fact of automated decision-making (if such a procedure is applied), including profiling, and at least in these cases, understandable information about the logic involved and the significance and likely consequences of such processing for you.

Data processing can only begin after this, if the legal basis for data processing is consent, you must also consent to data processing in addition to being informed.

This document contains all relevant data management information regarding the operation of the webshop, in accordance with the General Data Protection Regulation of the European Union 2016/679 (hereinafter: Regulation. GDPR) and Act CXII of 2011 (hereinafter: Infotv.).

Left at the post office and post office delivery

Please note that Magyar Posta Zrt. identifies the recipient in accordance with the data processing information in force at all times, therefore, if applicable, it may request that you provide your personal data upon delivery or upon receipt at a post office.