Adatvédelmi tájékoztató

Bevezetés

The NOEL Truck Assistance Ltd. Truck Rescue NON-STOP (registered office: Szigethalom, Rákóczi Ferenc street 147. tax number: 25750276-2-13) (hereinafter: Service Provider, data controller) submits to the following information.

We provide the following information on the protection of personal data and the free movement of such data for natural persons, as well as the repeal of Regulation (EC) No 95/46 (General Data Protection Regulation) THE EUROPEAN PARLIAMENT AND THE COUNCIL (EU) 2016/679 REGULATION (27 April 2016).

This data processing information regulates the data processing of the following pages: https://xn--kamionments-kbb.eu/

The data processing information is available at the following address: https://xn--kamionments-kbb.eu/adatvedelmi-tajekoztato/

The modifications to the information will take effect upon publication at the above address.

Data controller and contact details:

Name: NOEL Truck Assistance Ltd. Truck Rescue NON-STOP
Registered office: Szigethalom, Rákóczi Ferenc street 147.
E-mail: trucksegely@gmail.com
Phone: 0036-30-984-0684

Definitions

“personal data”: any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person;

“data processing”: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

“data controller”: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

“data processor”: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

“recipient”: a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;

“consent of the data subject”: any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

“personal data breach”: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Principles relating to processing of personal data

Personal data shall be:

processed lawfully, fairly and in a transparent manner in relation to the data subject (“lawfulness, fairness and transparency”);

collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (“purpose limitation”);

adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (“data minimization”);

accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (“accuracy”);

kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organizational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (“storage limitation”);

processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures (“integrity and confidentiality”).

The controller shall be responsible for, and be able to demonstrate compliance with, these principles (“accountability”).

Data processing activities

Hosting service provider

Activity performed by the data processor: Hosting service

Name and contact details of the data processor:
Tárhelypark Kft.
Registered office: 1122 Budapest, Gaál József út 24.
Phone number: +36 1 700 4140
Mailing address: 1122 Budapest, Gaál József út 24.
Email: info@tarhelypark.hu

The fact of the processing, the scope of the processed data: All personal data provided by the data subject.

The data subjects: All individuals using the website.

The purpose of the processing: Making the website available and ensuring its proper operation.

The duration of the processing, the deadline for erasure of the data: The processing of data shall continue until the termination of the agreement between the data controller and the hosting service provider, or until the data subject requests erasure from the hosting service provider.

The legal basis for the data processing: the consent of the user, Article 5(1) of the Infotv., Article 6(1)(a) of the Regulation, and Section 13/A(3) of Act CVIII of 2001 on certain issues of electronic commerce services and information society services.

Other data processor

Octonull Kft
Registered office: 1085 Budapest, József körút 74. I. em. 6.
Email: hello@billingo.hu

Management of cookies

Cookies typically used on websites

The fact of the processing, the scope of the processed data: Unique identifier, dates, timestamps

The data subjects: All individuals visiting the website.

The purpose of the processing: Identification of users and tracking of visitors.

The duration of the processing, the deadline for erasure of the data:

Type of cookie	Legal basis for processing	Duration of processing	Processed data
Session cookies	Article 13/A(3) of Act CVIII of 2001 on certain issues of electronic commerce services and information society services	The period until the end of the visitor’s session	connect.sid

The duration of data processing for Addthis cookies is 2 years.

The possible data processors who are authorized to access the data: The data controller does not process personal data using cookies.
Description of the data subject’s rights related to data processing: The data subject has the option to delete cookies in the Tools/Settings menu of their browser, usually under the Privacy settings.

The legal basis for data processing: The consent of the data subject is not required if the sole purpose of using cookies is the transmission of communications via electronic communications networks or if the service provider needs it for the provision of an information society service explicitly requested by the subscriber or user.

Use of Google Adwords conversion tracking

The data controller uses the online advertising program called “Google AdWords” and also uses the Google conversion tracking service within this program. Google conversion tracking is an analytics service provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”).

When a user reaches a website through a Google ad, a conversion tracking cookie is placed on their computer. These cookies have a limited validity period and do not contain any personal data, so the user cannot be identified through them.

When the user visits certain pages of the website and the cookie has not expired, both Google and the data controller can see that the user clicked on the ad.

Each Google AdWords customer receives a different cookie, so they cannot be tracked through the websites of AdWords customers.

The information obtained through the conversion tracking cookies is used to create conversion statistics for AdWords customers who have opted for conversion tracking. This allows customers to see the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they do not have access to any information that could personally identify users.

If you do not want to participate in conversion tracking, you can reject it by disabling the installation of cookies in your browser. In this case, you will not be included in the conversion tracking statistics.

For more information and Google’s privacy policy, please visit the following page: www.google.com/policies/privacy/

Application of Google Analytics

1. This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site.

1. The information generated by the cookies about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators, and providing other services relating to website activity and internet usage.

1. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

1. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Newsletter, Direct Marketing Activities

According to Section 6(1) of Act XLVIII of 2008 on the basic conditions and certain restrictions of economic advertising activity, the User may give prior and explicit consent for the Service Provider to contact them with advertising offers and other mailings at the contact details provided during registration.

Furthermore, the User, taking into account the provisions and restrictions of this information, may consent to the processing of their personal data necessary for sending advertising offers by the Service Provider.

The Service Provider does not send unsolicited advertising messages, and the User can unsubscribe from receiving offers without restriction and justification. In this case, the Service Provider will delete all personal data necessary for sending advertising messages from its records and will not contact the User with further advertising offers. The User can unsubscribe from the ads by clicking on the link in the message.

The fact of data collection, the scope of processed data, and the purpose of data processing:

Personal data	Purpose of data processing
Name, email address.	Identification, enabling subscription to the newsletter.
Subscription timestamp	Technical operation execution.
Subscription IP address	Technical operation execution.

Scope of data subjects: All data subjects subscribing to the newsletter.

Purpose of data processing: Sending electronic messages containing advertisements (email, SMS, push messages) to the data subject, providing information about current news, products, promotions, new features, etc.

Data processing period, deadline for data deletion: Data processing lasts until the consent is withdrawn, i.e., until unsubscribing.

Persons authorized to access the data, recipients of personal data: Personal data can be accessed by sales and marketing employees of the data controller, while respecting the above principles.
Description of the data subject’s rights related to data processing:

The data subject may request access to their personal data, correction, deletion, or restriction of processing from the data controller, and
may object to the processing of such personal data, and
has the right to data portability, as well as the right to withdraw consent at any time.

The data subject can initiate access to personal data, deletion, modification, or restriction of processing, data portability, and objection to data processing in the following ways:

by mail at 147 Rákóczi Ferenc Street, Szigethalom,
by email at trucksegely@gmail.com,
by phone at +36-30-984-0684.

The data subject can unsubscribe from the newsletter at any time, free of charge.

Legal basis for data processing: The data subject’s consent, Article 6(1)(a) of the GDPR, Section 5(1) of the Infotv, and Section 6(5) of Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Economic Advertising Activities:

The advertiser, the advertising service provider, or the advertiser – within the scope specified in the consent – keeps a record of the personal data of the persons making the consent. The data recorded in this register – relating to the addressee of the advertisement – may only be processed in accordance with the provisions of the consent, until its withdrawal, and may only be transferred to third parties with the prior consent of the data subject.

Please note that

data processing is based on your consent.
you are obliged to provide personal data if you want to receive newsletters from us.
failure to provide data will result in the consequences that we cannot send you newsletters.

Social media

The fact of data collection, scope of processed data: Registered name and public profile picture of the data subject on Facebook/Google+/Twitter/Pinterest/Youtube/Instagram, etc. social media platforms.

Scope of data subjects: All data subjects who have registered on Facebook/Google+/Twitter/Pinterest/Youtube/Instagram, etc. social media platforms and have “liked” the website.

Purpose of data collection: Sharing, “liking,” and promoting certain content elements, products, promotions, or the website itself on social media platforms.

Data processing period, deadline for data deletion, persons authorized to access the data, and description of the data subject’s rights related to data processing: The source of the data, its processing, and transfer, as well as its legal basis, can be found on the respective social media platform. Data processing takes place on social media platforms, so the duration, method, and possibilities for deleting and modifying data are subject to the regulations of the specific social media platform.

Legal basis for data processing: The data subject’s voluntary consent to the processing of personal data on social media platforms.

Customer contacts and other data processing

If the data subject has any questions or problems during the use of the data controller’s services, they can contact the data controller through the provided methods (phone, email, social media, etc.).

The data controller deletes received emails, messages, data provided by phone, Facebook, etc., along with the inquirer’s name, email address, and other voluntarily provided personal data, within a maximum of 2 years from the date of communication.

We provide information about data processing not listed in this notice at the time of data collection.

In exceptional cases of official requests or requests from other authorities based on legal authorization, the Service Provider is obliged to provide information, disclose, transfer, or make documents available to the requesting party.

In such cases, the Service Provider may disclose personal data to the requesting party only to the extent necessary to achieve the purpose of the request, provided that the requesting party has specified the exact purpose and scope of the data.

Rights of the data subject

Right of access

You have the right to obtain from the data controller confirmation as to whether or not personal data concerning you are being processed, and, if so, access to the personal data and the information listed in the regulation.

Right to rectification

You have the right to request the data controller to rectify inaccurate personal data concerning you without undue delay. Taking into account the purposes of the processing, you have the right to request the completion of incomplete personal data, including by means of a supplementary statement.

Right to erasure

You have the right to request the data controller to erase personal data concerning you without undue delay, and the data controller is obliged to erase such personal data without undue delay under certain conditions.

Right to be forgotten

If the data controller has made the personal data public and is obliged to erase it, taking into account the available technology and the cost of implementation, they shall take reasonable steps, including technical measures, to inform the data controllers processing the data that you have requested the erasure of any links to, or copies or replications of, the personal data.

Right to restriction of processing

You have the right to request the data controller to restrict processing if one of the following conditions is met:

You contest the accuracy of the personal data, in which case the restriction applies for a period enabling the data controller to verify the accuracy of the personal data;
the processing is unlawful, and you oppose the erasure of the personal data and request the restriction of their use instead;
the data controller no longer needs the personal data for the purposes of the processing, but you require them for the establishment, exercise, or defense of legal claims; or
you have objected to processing pending the verification whether the legitimate grounds of the data controller override your grounds.

Right to data portability

You have the right to receive the personal data concerning you, which you have provided to a data controller, in a structured, commonly used, and machine-readable format, and have the right to transmit those data to another data controller without hindrance from the data controller to which the personal data have been provided (…)

Right to object

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you based on (…) including profiling based on those provisions.

Right to object to direct marketing

If personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. If you object to the processing of personal data for direct marketing purposes, the personal data may no longer be processed for such purposes.

Automated individual decision-making, including profiling

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.

The preceding paragraph shall not apply if the decision:

is necessary for entering into, or performance of, a contract between you and the data controller;
is authorized by Union or Member State law to which the data controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
is based on your explicit consent.

Deadline for action

The data controller shall provide information on the measures taken in response to the requests within 1 month of receipt of the requests. This period may be extended by 2 months if necessary. The data controller shall inform you of any such extension within 1 month of receipt of the requests, together with the reasons for the delay. If the data controller does not take action on the requests, they shall inform you without undue delay, but no later than 1 month from receipt of the requests, of the reasons for not taking action and of your right to lodge a complaint with a supervisory authority and to seek a judicial remedy.

Security of data processing

The data controller and the data processor shall implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account the state of the art, the costs of implementation, the nature, scope, context, and purposes of processing, as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons. These measures may include, among others:

encryption of personal data;

ensuring the continuous confidentiality, integrity, availability, and resilience of systems and services used for personal data processing;

the ability to restore access to and availability of personal data in the event of a physical or technical incident;

a procedure for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of data processing.

Informing the data subject about the data protection incident

If a data protection incident is likely to result in a high risk to the rights and freedoms of natural persons, the data controller shall inform the data subject of the data protection incident without undue delay.

The information provided to the data subject shall clearly and understandably describe the nature of the data protection incident and shall include the name and contact details of the data protection officer or other contact person providing further information; it shall describe the likely consequences of the data protection incident; it shall describe the measures taken or planned by the data controller to remedy the data protection incident, including, where appropriate, measures to mitigate any adverse consequences arising from the data protection incident.

The data subject shall not be informed if any of the following conditions are met:

the data controller has implemented appropriate technical and organizational protection measures and these measures have been applied to the data affected by the data protection incident, in particular measures that make the data unintelligible to unauthorized persons, such as encryption;
the data controller has taken further measures after the data protection incident to ensure that the high risk to the rights and freedoms of the data subject is no longer likely to materialize;
the notification would require disproportionate effort. In such cases, the data subjects shall be informed by means of publicly available information or by taking similar measures to ensure effective information of the data subjects.

If the data controller has not yet informed the data subject of the data protection incident, the supervisory authority may order the data subject to be informed after considering whether the data protection incident is likely to result in a high risk.

Reporting a data protection incident to the authority

The data controller shall report the data protection incident to the supervisory authority without undue delay and, where feasible, no later than 72 hours after becoming aware of the data protection incident, unless the data protection incident is unlikely to result in a risk to the rights and freedoms of natural persons. If the notification is not made within 72 hours, the reasons for the delay shall be attached to it.

Complaint options

Complaints against the data controller’s possible infringement can be lodged with the National Data Protection and Freedom of Information Authority:

National Data Protection and Freedom of Information Authority
1125 Budapest, Szilágyi Erzsébet fasor 22/C.
Mailing address: 1530 Budapest, PO Box: 5.
Phone: +36 -1-391-1400
Fax: +36-1-391-1410
E-mail: ugyfelszolgalat@naih.hu

Closing

During the preparation of this information, we took into account the following legislation:

Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)
Act CXII of 2011 on Informational Self-Determination and Freedom of Information (hereinafter: Infotv.)
Act CVIII of 2001 on certain issues of electronic commerce services and information society services (in particular Section 13/A)
Act XLVII of 2008 on the prohibition of unfair commercial practices against consumers;
Act XLVIII of 2008 on the basic conditions and certain restrictions of commercial advertising (in particular Section 6)
Act XC of 2005 on the freedom of electronic information
Act C of 2003 on electronic communications (specifically Section 155)
Opinion 16/2011 on the EASA/IAB Recommendation on Best Practice for Online Behavioral Advertising
Recommendation of the National Data Protection and Freedom of Information Authority on the requirements for prior information
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC

Download the data protection information here:

tató

Introduction

The NOEL Truck Assistance Ltd. Kamionmentés NON – STOP (registered office: Szigethalom, Rákóczi Ferenc utca 147. tax number: 25750276-2-13) (hereinafter: Service Provider, data controller) is subject to the following information.

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), we provide the following information.

This data processing information regulates the data processing of the following pages: https://xn--kamionments-kbb.eu/

The data processing information is available at the following address: https://xn--kamionments-kbb.eu/adatvedelmi-tajekoztato/

The amendments to the information shall enter into force by publication at the above address.

The data controller and its contact details:

Name: NOEL Truck Assistance Ltd. Kamionmentés NON – STOP
Registered office: Szigethalom, Rákóczi Ferenc utca 147.
E-mail: trucksegely@gmail.com
Phone: 0036-30-984-0684

Definitions

“personal data”: any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

“data processing”: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

“data controller”: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the data controller or the specific criteria for its nomination may be provided for by Union or Member State law;

“data processor”: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the data controller;

“recipient”: a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;

“consent of the data subject”: any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

“data protection incident”: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Principles of personal data processing

Personal data shall be:

processed lawfully, fairly, and in a transparent manner in relation to the data subject (“lawfulness, fairness, and transparency”);

collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes (“purpose limitation”);

adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed (“data minimization”);

accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (“accuracy”);

kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organizational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (“storage limitation”);

processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures (“integrity and confidentiality”).

The data controller is responsible for compliance with the above, and must be able to demonstrate such compliance (“accountability”).

Data processing activities

Hosting service provider

Activity provided by the data processor: Hosting service

Name and contact details of the data processor:
Tárhelypark Kft.
Headquarters: 1122 Budapest, Gaál József út 24.
Phone number: +36 1 700 4140
Mailing address: 1122 Budapest, Gaál József út 24.
Email: info@tarhelypark.hu

The fact of data processing, the scope of processed data: All personal data provided by the data subject.

The scope of data subjects: All individuals using the website.

The purpose of data processing: Making the website available and ensuring its proper operation.

The duration of data processing, the deadline for erasure of data: The data processing lasts until the termination of the agreement between the data controller and the hosting service provider, or until the data subject’s request for erasure addressed to the hosting service provider.

The legal basis for data processing: the consent of the user, Section 5(1) of the Information Act, Article 6(1)(a) of the Regulation, and Section 13/A(3) of Act CVIII of 2001 on certain issues of electronic commerce services and information society services.

Other data processors

Octonull Kft
Headquarters: 1085 Budapest, József körút 74. I. em. 6.
Email: hello@billingo.hu

Managing Cookies

Cookies typical of websites

The fact of data processing, the scope of processed data: Unique identifier, dates, timestamps

The scope of data subjects: All individuals visiting the website.

The purpose of data processing: User identification and tracking of visitors.

The duration of data processing, the deadline for erasure of data:

Type of cookie

Legal basis for data processing

Duration of

data processing

Processed data

Session cookies

Section 13/A(3) of Act CVIII of 2001 on certain issues of electronic commerce services and information society services

Until the end of the

relevant visitor session

connect.sid

The duration of data processing for Addthis cookies is 2 years.

The possible data controllers authorized to access the data: The data controller does not process personal data using cookies.
Description of the data subject’s rights related to data processing: The data subject has the option to delete cookies in the browser’s Tools/Settings menu, usually under the Privacy settings.

The legal basis for data processing: The use of cookies does not require the data subject’s consent if the sole purpose of using cookies is the transmission of communications via the electronic communications network or if the service provider absolutely needs it to provide a service related to the information society requested by the subscriber or user.

Use of Google Adwords Conversion Tracking

The data controller uses the online advertising program called “Google AdWords” and also uses the Google conversion tracking service within this program. Google conversion tracking is an analytics service provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”).

When a user reaches a website through a Google ad, a conversion tracking cookie is placed on their computer. These cookies have a limited validity period and do not contain any personal data, so the user cannot be identified through them.

When the user browses certain pages of the website and the cookie has not expired, both Google and the data controller can see that the user clicked on the ad.

Each Google AdWords customer receives a different cookie, so they cannot be tracked through the websites of AdWords customers.

The information obtained through the conversion tracking cookies is used to create conversion statistics for AdWords customers who have chosen conversion tracking. This allows customers to learn about the number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they do not have access to information that could identify any individual user.

If you do not want to participate in conversion tracking, you can reject it by disabling the installation of cookies in your browser. After that, you will not appear in the conversion tracking statistics.

Further information and Google’s privacy policy can be found on the following page: www.google.de/policies/privacy/

Use of Google Analytics

1. This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site.

1. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators, and providing other services relating to website activity and internet usage.

1. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

1. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Newsletter, Direct Marketing Activities

According to Section 6(1) of Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Economic Advertising Activity, the User may give prior and express consent to the Service Provider to contact them with advertising offers and other mailings at the contact details provided during registration.

In addition, the User, taking into account the provisions of this information, may consent to the processing of their personal data necessary for sending advertising offers by the Service Provider.

The Service Provider does not send unsolicited advertising messages, and the User can unsubscribe from receiving offers without restriction and justification. In this case, the Service Provider will delete all personal data necessary for sending advertising messages from its records and will not contact the User with further advertising offers. The User can unsubscribe from the ads by clicking on the link in the message.

The fact of data collection, the scope of processed data, and the purpose of data processing:

Personal data	Purpose of data processing
Name, email address.	Identification, enabling subscription to the newsletter.
Time of subscription	Performing technical operation.
IP address at the time of subscription	Performing technical operation.

The circle of data subjects: All data subjects subscribing to the newsletter.

Purpose of data processing: sending electronic messages containing advertisements (email, sms, push messages) to the data subject, providing information about current information, products, promotions, new features, etc.

Duration of data processing, deadline for data deletion: data processing lasts until the withdrawal of consent, i.e., until unsubscribing.

Identity of possible data controllers authorized to access the data, recipients of personal data: Personal data can be processed by sales and marketing employees of the data controller, while respecting the above principles.
Description of the data subject’s rights related to data processing:

The data subject can request access to their personal data, their correction, deletion, or restriction of processing, and
object to the processing of such personal data, and
the data subject has the right to data portability and to withdraw consent at any time.

The data subject can initiate access to personal data, their deletion, modification, or restriction of processing, data portability, and objection to data processing in the following ways:

by mail to the address 147 Rákóczi Ferenc Street, Szigethalom,
by email to trucksegely@gmail.com,
by phone at +36-30-984-0684.

The data subject can unsubscribe from the newsletter at any time, free of charge.

The legal basis for data processing: the data subject’s consent, Article 6(1)(a) of the GDPR, Section 5(1) of Act CXII of 2011 on Informational Self-Determination and Freedom of Information, and Section 6(5) of Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Economic Advertising Activity:

The advertiser, the advertising service provider, or the publisher of the advertisement – within the scope specified in the consent – keeps a record of the personal data of the persons who have given their consent. The data recorded in this register – relating to the recipient of the advertisement – may only be processed in accordance with the provisions of the consent, until its withdrawal, and may only be transferred to a third party with the prior consent of the data subject.

Please note that

data processing is based on your consent.
providing personal data is mandatory if you want to receive newsletters from us.
failure to provide data will result in the consequences that we will not be able to send you newsletters.

Social Media

The fact of data collection, the scope of processed data: the name registered on Facebook/Google+/Twitter/Pinterest/Youtube/Instagram, as well as the user’s public profile picture.

The circle of data subjects: All data subjects who have registered on Facebook/Google+/Twitter/Pinterest/Youtube/Instagram, and have “liked” the website.

Purpose of data collection: Sharing and “liking” certain content elements, products, promotions, or the website itself on social media.

Duration of data processing, deadline for data deletion, identity of possible data controllers authorized to access the data, and description of the data subject’s rights related to data processing: The source of the data, its processing, and the method of transfer, as well as the duration of data processing, and the options for deletion and modification can be found in the regulations of the respective social media platform.

The legal basis for data processing: the voluntary consent of the data subject to the processing of personal data on social media platforms.

Customer Relations and Other Data Processing

If the data subject has any questions or problems during the use of the data controller’s services, they can contact the data controller through the provided methods (phone, email, social media, etc.).

The data controller deletes received emails, messages, data provided by phone, Facebook, etc., along with the data subject’s name and email address, and other voluntarily provided personal data, within a maximum of 2 years from the date of communication.

Information about data processing not listed in this notice will be provided at the time of data collection.

Upon exceptional official request or based on authorization by law, the Service Provider is obliged to provide information, disclose, transfer, or make documents available to other organizations.

In these cases, the Service Provider shall only disclose personal data to the requesting party to the extent necessary for the realization of the purpose of the request, provided that the requesting party has specified the exact purpose and scope of the data.

Rights of the data subjects

Right of access

Right to rectification

You have the right to obtain from the data controller without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to request the completion of incomplete personal data, including by means of a supplementary statement.

Right to erasure

You have the right to request the erasure of personal data concerning you without undue delay, and the data controller is obliged to erase personal data without undue delay under certain conditions.

Right to be forgotten

If the data controller has made the personal data public and is obliged to erase it, taking into account the available technology and the cost of implementation, it shall take reasonable steps, including technical measures, to inform the data controllers processing the data that you have requested the erasure of any links to, or copies or replications of, those personal data.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data under certain conditions:

You contest the accuracy of the personal data, in which case the restriction applies for a period enabling the data controller to verify the accuracy of the personal data;
The processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
The data controller no longer needs the personal data for the purposes of the processing, but you require them for the establishment, exercise, or defense of legal claims;
You have objected to the processing; in this case, the restriction applies for the period until it is determined whether the legitimate grounds of the data controller override your grounds.

Right to data portability

Right to object

You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you, including profiling based on the mentioned provisions.

Right to object to direct marketing

If personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. If you object to the processing of personal data for direct marketing purposes, the personal data shall no longer be processed for such purposes.

Automated individual decision-making, including profiling

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.

The preceding paragraph shall not apply if the decision:

is necessary for the conclusion or performance of a contract between you and the data controller;
is authorized by Union or Member State law to which the data controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
is based on your explicit consent.

Deadline for action

The data controller shall provide you with information on action taken on your requests without undue delay and in any event within 1 month of receipt of the request. That period may be extended by 2 months where necessary, taking into account the complexity and number of the requests. The data controller shall inform you of any such extension within 1 month of receipt of the request, together with the reasons for the delay.

If the data controller does not take action on your request, the data controller shall inform you without delay and at the latest within 1 month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.

Security of processing

The data controller and the data processor shall implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including, among others, as appropriate:

encryption of personal data;

ensuring the continuous confidentiality, integrity, availability, and resilience of systems and services used for the processing of personal data;

the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;

a procedure for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of processing.

Notification of the data subject regarding the data protection incident

If the data protection incident is likely to result in a high risk to the rights and freedoms of natural persons, the data controller shall inform the data subject of the data protection incident without undue delay.

The information provided to the data subject in the notification shall be clear and easily understandable and shall include the name and contact details of the data protection officer or other contact person providing further information; it shall describe the nature of the data protection incident and the likely consequences of the data protection incident; it shall describe the measures taken or planned by the data controller to remedy the data protection incident, including, where appropriate, measures to mitigate any adverse effects resulting from the data protection incident.

The data subject shall not be informed if any of the following conditions are met:

the data controller has implemented appropriate technical and organizational measures and these measures have been applied to the data affected by the data protection incident, in particular measures, such as encryption, that make the data unintelligible to unauthorized persons;
the data controller has taken further measures after the data protection incident to ensure that the high risk to the rights and freedoms of the data subject is no longer likely to materialize;
providing the information would require disproportionate effort. In such cases, the data subjects shall be informed by means of public communication or similar measures that ensure effective information of the data subjects.

If the data controller has not notified the data subject of the data protection incident, the supervisory authority may, after considering whether the data protection incident is likely to result in a high risk, order the data controller to inform the data subject.

Reporting a data protection incident to the authority

The data controller shall notify the supervisory authority competent under Article 55 without undue delay and, where feasible, not later than 72 hours after becoming aware of the data protection incident, unless the data protection incident is unlikely to result in a risk to the rights and freedoms of natural persons. If the notification is not made within 72 hours, it shall be accompanied by reasons for the delay.

Right to lodge a complaint

You have the right to lodge a complaint with the National Authority for Data Protection and Freedom of Information in case of any violation by the data controller:

National Authority for Data Protection and Freedom of Information
1125 Budapest, Szilágyi Erzsébet fasor 22/C.
Mailing address: 1530 Budapest, P.O. Box: 5.
Phone: +36 -1-391-1400
Fax: +36-1-391-1410
E-mail: ugyfelszolgalat@naih.hu

Closing remarks

During the preparation of this information, we took into account the following legislation:

Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)
Act CXII of 2011 on Informational Self-Determination and Freedom of Information (hereinafter: Infotv.)
Act CVIII of 2001 on certain issues of electronic commerce services and information society services (in particular Section 13/A)
Act XLVII of 2008 on the prohibition of unfair commercial practices against consumers;
Act XLVIII of 2008 on the basic conditions and certain restrictions of commercial advertising activities (in particular Section 6)
Act XC of 2005 on the freedom of electronic information
Act C of 2003 on electronic communications (specifically Section 155)
Opinion 16/2011 on EASA/IAB Recommendation on the practice of online behavioral advertising
Recommendation of the National Authority for Data Protection and Freedom of Information on the requirements for prior information
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC

Download the data protection information here: