Aliaxis Hungary SEE Kft., as the operator of this website, undertakes to collect, process, and use personal data relating to our customers and business partners in a responsible manner. This Privacy Policy explains how we collect, use, and disclose your personal data. It also outlines your rights regarding your personal data.
This Privacy Policy applies exclusively to personal data that we collect through our website portfolio (including, but not limited to, www.aliaxis.hu and all subpages, hereinafter collectively referred to as the “website”). For information regarding personal data collected through other channels (e.g., through our mobile applications, if you have a contractual relationship with us, or if you participate in our recruitment activities), please refer to our specific privacy policies, the latest versions of which can be found on the www.aliaxis.hu website in the footer under the "Privacy Policy" section
For costumers and suppliers.pdf;
If you have any questions or concerns regarding the use of your personal data, please contact us:
Aliaxis Hungary SEE Kft.
Budai út 8.
2051 Biatorbágy, Hungary
T: +36 30 449 6901
agyory@aliaxis.com
Contents:
1. What personal data do we collect and why?
2. Legal basis for the processing of personal data
3. To whom and why do we disclose your personal data?
4. Data retention
5. Your data protection rights
6. Is your personal data transferred abroad?
7. Use of tracking tools
8. Protection of your personal data
9. Links to third-party websites
10. Changes to our Privacy Policy
11. Handling of newsletter subscriber data
1. What personal data do we collect and why?
The personal data we may collect about you through our website generally falls into the following categories:
Data you voluntarily provide
We collect personal data that you voluntarily provide on our website, such as when you fill out an online form to contact us or subscribe to our newsletter. The data we collect about you may include some or all of the following:
- Name, title, and address;
- Personal contact information (phone, email, fax, etc.);
- Where applicable, the name, address, departments, contact details, and other information regarding the company you represent and your role within it;
- VAT number;
- User settings (such as preferred language settings);
- Your marketing preferences;
- Service requests and orders placed;
- Shopping cart and payment information; and
- Newsletter subscriptions, registration for promotions, use of special offers, etc.
- Your responses to surveys, reviews, ratings, and other types of feedback;
- The content of messages sent through the website, including data shared with Aliaxis Hungary or an affiliated company and/or with other users in the website’s social communities or by other means;
- Any other information you provide or upload to the website (e.g., content entered in an online form, a photo uploaded).
Automatically Collected Data
When you visit our website, we may automatically collect certain data from your device. In some countries, including those in the European Economic Area, this data may be considered personal data subject to applicable data protection laws.
The data we collect automatically may include, in particular:
- IP address, operating system, browser type, browser version, browser settings, Internet service provider name, and other types of data about your computer and connections necessary to identify your device type and how you connect to the website, to enable data exchange with you and your device, and to ensure convenient use of the website.
- The URL and IP address of the website from which you accessed our website or from which you were redirected to our website, including the date and time;
- The subpages you opened during your visit to our website and the links on the website that you followed, including the date and time;
- The full Uniform Resource Locators (URL) clickstream to, through, and from our website, including the date and time;
- Your purchase history, including ongoing and completed transactions;
- The search terms you entered; and
- The services and products you viewed or searched for on the website.
Collecting this data allows us to better understand our website visitors, where they come from, and what content or products interest them on our website. We use this data for internal analysis purposes, as well as to improve the quality and relevance of our website for our visitors.
We may collect some of this data using cookies, web beacons, unique identifiers, and similar technologies to collect and store data (including, where applicable, your personal data).
a) This website uses the following types of cookies, the scope and functions of which are described below:
- Session cookies (see b)
- Persistent cookies (see c).
b) Session cookies are automatically deleted when you close your browser. These include, in particular, session cookies. These store a so-called session ID, which can be used to assign your browser’s various requests to a single session. This allows us to recognize your computer when you return to our website. Session cookies are deleted when you log out or close your browser.
c) Persistent cookies are automatically deleted after a specified period, which may vary from cookie to cookie. You can delete cookies at any time in your browser’s security settings.
d) You can configure your browser settings as you wish and, for example, choose not to accept third-party cookies or any cookies at all. Please note that if you do so, you may not be able to use all the features offered by the website.
We recommend that you regularly delete cookies and your browser history manually.
Children
We are committed to protecting children’s privacy. Our website is not intended for children, and to the best of our knowledge, we do not collect personal data from children.
2. Legal Basis for Processing Personal Data
The legal basis for the collection and use of the personal data described above depends on the specific personal data in question and the specific context of the data collection.
In general, however, we only collect personal data from you (i) if processing it is in our legitimate interest and does not conflict with your rights, (ii) if we need the personal data to fulfill a contract with you, or (iii) if we have obtained your consent to do so. We process your personal data specifically for the purposes listed below:
- managing, operating, maintaining, and developing the website;
- contacting you or your organization to inform you about new products and services we offer;
- assessing whether you or your organization are eligible for certain offers, products, or services;
- to improve and personalize our website, marketing, and our products and services;
- to conduct analyses and customer research, including general market research or surveys on demand for specific topics and our customers’ opinions, to generate sales and traffic patterns, and to analyze the effectiveness of our advertisements, both anonymously (e.g., through data aggregation) and on an individual basis (to the extent permitted by law);
- to respond to your questions and inquiries;
- to inform you about our company, the Aliaxis Group, its members, our products and services, and to provide you with regular updates on topics of interest to you via traditional mail, email, phone, fax, newsletters, SMS/MMS, social media posts, online ads, and search engine ads, including the periodic sending of promotional materials specifically tailored to you regarding our products, services, and sales promotions (direct marketing).
- compiling statistical data on the use of our website and our social media pages, as well as our products and services;
- to provide you or your organization, as a registered customer, with confirmation that your orders have been received and are being processed when you use our services and contact our customer service;
- to provide you or your organization with the appropriate products and services, to manage your account with us or your organization’s account, and for customer service and billing purposes;
- for our internal purposes, such as management, research, analysis, annual reports, and improving business efficiency;
- to ensure the safety of you, your organization, and our employees, and to maintain service quality (we may monitor or record calls to our customer service teams for authentication, security, quality, or training purposes);
- to track harassing or malicious calls;
- to ensure compliance with applicable laws, regulations, court orders, and requests from government and law enforcement agencies; to ensure the proper operation of our systems; to protect ourselves, our users, and our customers; and to resolve customer disputes;
- to segment our customer base and help develop offers, products, and services that provide the best customer experience for you or your organization;
- to communicate with you regarding other matters (e.g., sending maintenance reminders, technical data sheets, updates, security alerts, support and administrative messages, or service reports);
- to administer rewards, surveys, sweepstakes, contests, or other promotional activities or events;
- to comply with legal requirements, prevent unauthorized use of the website, resolve disputes, and enforce our agreements; and
- any other purpose to which you have expressly consented or that is permitted by applicable law.
If we intend to use your personal data for a new or different purpose that is incompatible with the purpose for which we collected or received it, we will notify you, and we will only use the data for that other purpose if required or permitted by applicable law, or if you have consented to it.
If you have any questions or need further information regarding the legal basis on which we collect and use your personal data, please contact us using the contact details provided at the end of this Privacy Policy.
3. To whom and why do we disclose your personal data?
For the purposes set out above, we may share your personal data with the following categories of recipients:
- Members of the Aliaxis Group and
- the following:
- Our vendors and suppliers, including those vendors and suppliers who provide us with services such as data analysis, website hosting, technical support, parcel delivery, mailing, and email delivery, removing redundant data from customer lists, providing sales and marketing support, processing credit card payments, and providing customer service;
- Our professional advisors and auditors;
- Competent law enforcement agencies, regulatory authorities, government agencies, and/or courts; and
- Individuals to whom you have given your consent to disclose your personal data.
We may also share your personal data with third parties in connection with the reorganization of the Aliaxis Group or the sale of the assets of its members or divisions.
4. Data Retention
We will retain the personal data collected from you as long as we have a current and legitimate business need to do so (e.g., to provide the service you have requested or to comply with applicable tax laws or accounting requirements).
If there is no current or legitimate business need to process your personal data, we will delete your personal data (where possible and feasible) or anonymize it by removing, replacing, or blocking data that could identify you.
5. Your Data Protection Rights
You have the following data protection rights:
- the right to know whether your personal data is being processed or not, and if so, the right to access and/or receive a copy of your personal data;
- the right to have inaccurate or incomplete information in your personal data corrected and/or updated;
- the right to have your personal data erased;
- the right to restrict the processing of your personal data for certain legal reasons;
- the right to object to the processing of your personal data on grounds relating to your particular situation, where such processing is necessary for the legitimate purposes of a business;
- the right to unsubscribe at any time from marketing communications sent by us;
- the right to receive your personal data in a structured, commonly used, and machine-readable format, and to have it transmitted to another data controller;
- the right to withdraw consent, where processing is based on your consent. Withdrawal of consent does not affect the lawfulness of processing prior to withdrawal or the processing of personal data on other legal grounds; and
- the right to lodge a complaint with the competent data protection authority.
If you wish to exercise one or more of the rights described above, please contact us using the contact information provided at the end of this Privacy Policy.
6. Is your personal data transferred abroad?
Since the Aliaxis Group operates worldwide, we may need to transfer your personal data to members of the Aliaxis Group or third-party service providers located outside the country where your personal data was originally collected.
In such cases, we take appropriate measures to ensure that the transferred personal data receives an adequate level of protection.In cases where we transfer personal data relating to European residents to countries outside the European Union (EU) and the European Economic Area (EEA), we take the necessary steps to ensure adequate data protection in accordance with EU law, such as signing EU standard contractual clauses with the recipient of the data.
7. Use of Analytics Tools/Social Media
a. Tracking tools
We implement the tracking measures described below based on Article 6(1)(f) of the GDPR. We use these tracking measures to ensure that we design and continuously optimize our website to meet the needs of our users. We also use the tracking measures to collect statistics on the use of our website and to evaluate them in order to optimize the services we offer you. These interests are considered legitimate interests within the meaning of the aforementioned provision.
aa) Google Analytics
In order to design our website in accordance with our users’ needs and to continuously optimize it, we use the Google Analytics web analytics service provided by Google Inc. (https://www.google.de/intl/de/about/) (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter: “Google”). This involves the creation of pseudonymous user profiles and the use of cookies (see above). The information generated by cookies regarding your use of the website, such as
- browser type/version,
- operating system used,
- referrer URL (the previously visited page),
- the hostname of the accessing computer (IP address),
- the time of the server request,
transmitted to and stored on one of Google’s servers in the United States. The information is used to evaluate the use of the website, compile reports on website activity, and provide other services related to website and internet usage for market research purposes, as well as to ensure the website’s user-friendly design. This information may also be transferred to third parties if required by law or if third parties process this data as contracted data processors. Under no circumstances will your IP address be merged with other Google data. IP addresses are anonymized so that they cannot be traced back to specific individuals (IP masking).
You can configure your browser software to prevent the installation of cookies. However, please note that if you do so, you may not be able to use all the features offered by the website.
By downloading and installing a browser plug-in (https://tools.google.com/dlpage/gaoptout?hl=de), you can also prevent Google from storing and processing data generated by cookies regarding your use of the website (including your IP address).
As an alternative to the browser extension, particularly for browsers used on mobile devices, you can also prevent Google Analytics from collecting data by clicking this link. A opt-out cookie will be stored, which prevents the collection of your data during future visits to the website. The opt-out cookie applies only to this browser and only to our website, and is stored on your device. If you clear the cookies in this browser, you will need to set the opt-out cookie again. For further privacy information regarding Google Analytics and , please visit, for example, the Google Analytics Help Center (https://support.google.com/analytics#topic=3544906).
b. Use of social media plugins
1. We currently use the following social media plugins: Facebook and LinkedIn. We use what is known as a “two-click” solution. This means that when you visit our website, no personal data is initially transmitted to the plugin providers. You can identify the plugin provider by its initials or the logo displayed in the box. We enable you to communicate directly with the plug-in provider using the button. Only if you activate it by clicking on the marked field will the plug-in provider be informed that you have accessed the corresponding page of our online offering. In addition, the data mentioned in Section 3 of this Privacy Policy will be transmitted. In the case of Facebook and Xing, the IP address is anonymized immediately after collection, according to the information provided by the respective service providers. This means that if you activate the plugin, your personal data will be transmitted to the plugin provider and stored there (in the case of U.S. providers, in the United States). Since the providers of these plugins collect data primarily through cookies, we recommend that you delete all cookies via your browser’s security settings before clicking the gray checkbox.
2. We have no control over the data collected or the data processing operations, and we are not aware of the full scope of data collection, the purposes of processing, or the storage periods. We also do not have any information regarding the deletion of data collected by the plug-in provider.
3. The providers of the plugins store the data collected about you as a user profile and use it for advertising, market research, and/or to ensure the website is user-friendly. These analyses are conducted, in particular (even for users who are not logged in), to display advertisements tailored to your needs and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, although to exercise this right, you must contact the provider of the relevant plugin. By offering these plugins, we enable you to interact with social networks and other users, which means we can improve our offerings and make them more interesting for you as a user. The legal basis for the use of these plugins is Article 6(1)(f) of the GDPR.
4. Data is transmitted regardless of whether you have an account with the plugin provider and are logged into that account. If you are logged into the plugin provider’s account, the data collected on our website that pertains to you will be directly associated with your account with the plugin provider. If you click the activated button and, for example, share the page, the plug-in provider will also store this data in your user account and make it publicly available to your contacts. We recommend that you log out after regular use of the social network, but especially before activating the “ ” button, as this will prevent the plugin provider from associating the information with your profile.
5. You can find further information on the purpose and scope of data collection and processing by the plugin providers in the privacy policies issued by these providers below. These privacy policies also contain further information about your rights in this regard, as well as the settings you can use to protect your privacy.
6. Addresses of the respective plugin providers and URLs of their privacy policies:
a) Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA; http://www.facebook.com/policy.php; further information on data collection: http://www.facebook.com/help/186325668085084, http://www.facebook.com/about/privacy/your-info-on-other#applications and http://www.facebook.com/about/privacy/your-info#everyoneinfo. Facebook has joined the EU-U.S. Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.
b) LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California 94043, USA; http://www.linkedin.com/legal/privacy-policy. LinkedIn has joined the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.
c. Integration of YouTube videos
1. We have integrated YouTube videos into our online offering, which are hosted on http://www.YouTube.com and can be played directly from our website. [All of these videos have been uploaded to our website in "Enhanced Privacy Mode," which means that no data relating to you as a user is transmitted to YouTube unless you play the videos. The data mentioned in section 2 is only transmitted if you play the videos. We have no control over this data transmission].
2. By visiting the website, YouTube is informed that you have accessed the corresponding subpage of our website. In addition, the data mentioned in Section 3 of this privacy policy is transmitted. This occurs regardless of whether you have a YouTube user account that you are logged into or do not have a user account. If you are logged into your Google account, your data will be directly associated with your account. If you do not want your data to be associated with your YouTube profile, you must log out before clicking the button. YouTube stores your data as a user profile and uses it for advertising, market research, and/or to ensure a user-friendly website design. We conduct these analyses (even for users who are not logged in) specifically to provide you with ads tailored to your interests and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, although you must contact YouTube to exercise this right.
3. You can find further information on the purpose and scope of data collection and processing by YouTube in the privacy policy. This privacy policy also contains further information about your rights in this regard and the settings available to protect your privacy: https://www.google.de/intl/de/policies/privacy. Google also processes your personal data in the United States and has joined the EU-U.S. Privacy Shield: https://www.privacyshield.gov/EU-US-Framework.
d. Integration of Google Maps
We use the services provided by Google Maps on this website. This allows us to display interactive maps directly on the website and enables the use of convenient map features.
When you visit the website, Google is notified that you have accessed the relevant subpage of our website. In addition, the data mentioned in Section 3 of this Privacy Policy will be transmitted. This occurs regardless of whether Google provides a user account that you are logged into or whether you do not have a user account. If you are logged into Google, your data will be directly associated with your account. If you do not want the data to be associated with your Google profile, you must log out before clicking the button. Google stores your data as a user profile and uses it for advertising, market research, and/or to ensure a user-friendly website design. These evaluations are carried out in particular (even for users who are not logged in) to offer you advertisements tailored to your needs and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, although you must contact Google to exercise this right. Further information regarding the purpose and scope of data collection and processing by the provider of the plugin can be found in the provider’s privacy policy. This privacy policy contains further information about your rights in this regard, as well as the settings you can use to protect your privacy: http://www.google.de/intl/de/policies/privacy. Google also processes your personal data in the United States and has joined the EU-U.S. Privacy Shield: https://www.privacyshield.gov/EU-US-Framework.
8. Protection of Your Personal Data
We are committed to maintaining the confidentiality and security of the data you provide, and we implement appropriate technical, physical, and organizational security measures to protect the personal data we collect and process about you from unauthorized access, damage, disclosure, or loss.
When you visit our website, we use standard SSL (Secure Socket Layer) encryption at the highest level supported by your browser. This is typically 256-bit encryption. If your browser does not support 256-bit encryption, we use 128-bit v3 technology instead. You can determine whether a page on our website is being transmitted in encrypted form by looking for the closed key or lock symbol in the status bar at the bottom of your browser.
The measures we implement are designed to maintain a level of security appropriate to the risks associated with the processing of your personal data.
Please note that messages sent over the internet, such as emails, are only secure if they are encrypted.
9. Links to Third-Party Websites
This Privacy Policy does not apply to third-party websites linked to our websites or that advertise on our website. These third-party websites have their own privacy statements or policies, which we recommend you read.
10. Changes to Our Privacy Policy
We may change this Privacy Policy from time to time, for example, to keep it up to date or to reflect changes in legal, technical, or business requirements.
The “last revised” date at the top of this Privacy Policy indicates when the most recent revision took place. If you use our website after reviewing the Privacy Policy, you accept these changes.
11. Handling of Newsletter Subscriber Data
We provide the following information regarding the processing of personal data for natural persons who subscribe to the Aliaxis Hungary SEE Kft. email newsletter via the www.aliaxis.hu website.
I. The data controller and data processors
Data Controller:
Aliaxis Hungary SEE Kft.
2051 Biatorbágy, Budai út 8, Hungary
Tel.: +36 30 449 6901
agyory@aliaxis.com
www.aliaxis.hu
Data processors:
a) Microsoft Dynamics 365
This website uses forms provided by Microsoft Dynamics 365 Marketing in connection with the newsletter. This allows data collected on the site to be transferred directly to the Data Controller’s CRM system. The Microsoft Dynamics service is provided by Microsoft Ireland Operations Ltd. (One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland).
II. Purpose of Data Processing
On the Data Controller’s website, the Data Controller also offers a newsletter exclusively for informational purposes to individuals who subscribe to the email newsletter, which reports on current developments and events in commercial law.
If the Data Controller intends to use the personal data it processes for a purpose other than the one specified above, it will inform the data subjects of the different purpose and any other relevant additional information in the manner customary in the locality prior to commencing data processing for the different purpose.
We use the Microsoft Dynamics 365 Cloud for Marketing marketing automation system provided by Microsoft Corporation (Microsoft Deutschland GmbH, Walter-Gropius-Straße 5, 80807 Munich). We use this system to carry out marketing activities, for analytical purposes, and to address targeted and potential customers. Data processing therefore takes place within the European Union.
We primarily use this system to send emails, organize events, and provide landing pages and contact forms.
We also collect statistical data to determine whether the newsletters we send are opened (email tracking), when they are opened, and which links are clicked within the emails. We can technically associate this information with individual newsletter recipients, but we use this feature exclusively on an anonymous basis, without analyzing personal data. We ourselves cannot decode the pseudonymized data or trace it back to individuals.
III. Legal basis and duration of data processing, scope of processed data
The legal basis for data processing is the prior and voluntary consent of the data subject (the person subscribing to the newsletter) pursuant to Article 6(1)(a) of the GDPR. However, if data is not provided or consent is not given, it is not possible to send the newsletter.
Subscription to our newsletter requires a double opt-in process, during which the user must confirm their initial registration. This serves to verify the user’s identity and prevent abuse. You may unsubscribe from our newsletter at any time or withdraw your consent at any time. A link to unsubscribe from the newsletter is provided at the end of each newsletter. After you unsubscribe from the newsletter, the data processed about you will be deleted.
Data processing takes place from the time of subscription to the newsletter until the time of unsubscription (withdrawal of consent) or until the purpose ceases to exist, i.e., until the newsletter distribution activity is discontinued.
The data controller processes the following data in connection with the sending of the newsletter:
a. the website from which the page was requested (the referring URL)
b. the date and time of access;
c. a description of the type of browser used;
d. the IP address of the computer initiating the request, which we shorten to avoid personal identification;
e. last name and first name
f. email address;
g. the date and time of login and confirmation.
The data controller will only transfer the data subject’s data to a third party based on the data subject’s prior written consent or to fulfill a legal obligation.
When you submit a form to us during newsletter sign-up, Dynamics 365 Marketing links the copy ID to the incoming contact data. The copy ID is then assigned to a Dynamics 365 Marketing contact ID. This allows us to determine which browser you used when filling out the registration form. We use this data to analyze visitor behavior on the relevant form pages on our website and to provide a personalized experience. If you do not use this cookie, you will not be able to open the registration forms and thus will not be able to subscribe to our marketing emails. Similarly, you will not be able to edit your existing data in the subscription center.
IV. Your rights and remedies regarding the processing of your personal data
Rights
Withdrawal of consent
Data subjects have the right to withdraw their consent to the specified data processing at any time during the processing period; however, the withdrawal does not affect the lawfulness of the data processing carried out on the basis of consent prior to the withdrawal.
Access
The data subject has the right to receive confirmation from the Data Controller as to whether their personal data is being processed, and if such processing is taking place, they have the right to access their personal data and the following information:
a) the purposes of the processing;
b) the categories of personal data concerning the data subject;
c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, including, in particular, recipients in third countries or international organizations;
d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
e) the data subject’s right to request from the controller the rectification, erasure, or restriction of processing of personal data concerning him or her, and to object to the processing of such personal data;
f) the right to lodge a complaint with a supervisory authority;
g) if the data were not collected from the data subject, any available information regarding their source.
Rectification
The data subject has the right to obtain from the Data Controller, upon request and without undue delay, the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject has the right to request that incomplete personal data be completed, including by means of providing a supplementary statement.
Right to Object
The data subject has the right to object at any time, on grounds relating to his or her particular situation, to the processing of his or her personal data based on the legitimate interests of the Data Controller. In this case, the Data Controller may no longer process the personal data, unless the Data Controller demonstrates that the processing is justified by compelling legitimate grounds that override the data subject’s interests, rights, and freedoms, or that are related to the establishment, exercise, or defense of legal claims.
Erasure and Restriction
The data subject has the right to request that the Data Controller erase personal data concerning him or her without undue delay, and the Data Controller is obligated to erase personal data concerning the data subject without undue delay if any of the following grounds apply:
a) the personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
b) the data subject withdraws the consent on which the processing is based, and there is no other legal basis for the processing;
c) the data subject objects to the processing, and there are no overriding legitimate grounds for the processing;
d) the personal data has been unlawfully processed;
e) the personal data must be erased for compliance with a legal obligation under Union or Member State law to which the controller is subject;
f) the personal data has been collected in connection with the offering of information society services directly to children.
The above provisions shall not apply where the processing is necessary:
a) for the exercise of the right to freedom of expression and information;
b) to comply with a legal obligation under Union or Member State law to which the Data 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 Data Controller;
c) for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, insofar as the right to erasure is likely to render impossible or seriously impair such processing; or
d) for the establishment, exercise, or defense of legal claims.
The data subject has the right to request that the Data Controller restrict data processing if any of the following applies:
a) the data subject disputes the accuracy of the personal data; in this case, the restriction applies for a period enabling the Data Controller to verify the accuracy of the personal data;
b) the data processing is unlawful, and the data subject opposes the erasure of the data and requests the restriction of their use instead;
c) the Data Controller no longer needs the personal data for the purposes of processing, but the data subject requires it for the establishment, exercise, or defense of legal claims; or
d) the data subject has objected to the processing; in this case, the restriction applies for the period until it is determined whether the Data Controller’s legitimate grounds take precedence over the data subject’s legitimate grounds.
If the processing is restricted, such personal data may be processed, with the exception of storage, only with the data subject’s consent, or for the establishment, exercise, or defense of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of substantial public interest of the Union or of a Member State.
The Data Controller shall inform the data subject, at whose request the processing has been restricted, in advance of the lifting of the restriction on processing.
Data Portability
The data subject has the right to receive the personal data concerning him or her, which he or she has provided to a data controller, in a structured, commonly used, and machine-readable format, and has the right to transmit those data to another controller without hindrance from the controller to whom the personal data have been provided, where:
a) the processing is based on consent or a contract; and
b) the processing is carried out by automated means.
When exercising the right to data portability, the data subject has the right to request—where technically feasible—that personal data be transferred directly from one data controller to another.
We would like to draw the data subject’s attention to the fact that if receiving the data is not technically feasible for the recipient, the right to data portability cannot be exercised.
Remedies
Data subjects may file a complaint with the National Authority for Data Protection and Freedom of Information in the event of a violation of the rules governing the processing of personal data:
Name: National Authority for Data Protection and Freedom of Information
Headquarters: Budapest, Falk Miksa St. 9-11, 1055
Mailing Address: 1363 Budapest, P.O. Box 9
Email: ugyfelszolgalat@naih.hu
Website: http://www.naih.hu
Furthermore, data subjects may initiate legal proceedings against the Data Controller or the data processors it engages—at their discretion—before the court with jurisdiction over the data subject’s place of residence or place of stay.
V. Miscellaneous Provisions
This Privacy Notice is effective as of May 18, 2026.