Privacy notice
1. Introduction
MAISON Programozó Iroda Bt. (hereinafter MAISON Programozó Iroda Bt., service provider, controller, the Company), as data controller, regards the content of this legal notice as binding upon itself.
The Company undertakes that every data processing related to its activity complies with the requirements set out in this policy and in the applicable legislation.
MAISON Programozó Iroda Bt. is the operator of the maison.hu website.
MAISON Programozó Iroda Bt. reserves the right to change this notice at any time. Of course it will notify its audience of any changes in due time.
MAISON Programozó Iroda Bt. is committed to protecting the personal data of its customers and partners, and considers it of particular importance to respect its customers’ right to informational self-determination. The Controller treats personal data as confidential and takes every security, technical and organisational measure that guarantees the security of the data.
MAISON Programozó Iroda Bt. sets out below its data-processing principles and presents the requirements it has formulated for itself as controller and which it observes. Its data-processing principles are consistent with the applicable legislation on data protection, in particular the following:
- Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information;
- Act V of 2013 on the Civil Code (Ptk.);
- Act XLVIII of 2008 on the Basic Conditions of and Certain Restrictions on Commercial Advertising Activity (Grt.).
- Act CVIII of 2001 (Ekertv.) on certain issues of electronic commerce services and information society services;
- 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, hereinafter: “GDPR”)
2. Definitions
- data subject: any specified natural person who is identified or — directly or indirectly — identifiable on the basis of personal data;
- personal data: data that can be associated with the data subject — in particular the data subject’s name, identifier, and one or more pieces of knowledge characteristic of the data subject’s physical, physiological, mental, economic, cultural or social identity — as well as the conclusion that can be drawn from it concerning the data subject;
- consent: a voluntary and definite expression of the data subject’s wish, based on appropriate information, by which the data subject gives unambiguous agreement to the processing of personal data relating to him or her — in full or covering certain operations;
- controller: the natural or legal person, or organisation without legal personality, who or which, alone or jointly with others, determines the purposes of processing, takes and implements the decisions concerning processing (including the means used), or has them implemented by the processor;
- processing: regardless of the method used, any operation or set of operations performed on data, in particular collection, recording, organisation, storage, alteration, use, retrieval, transmission, disclosure, alignment or combination, blocking, erasure and destruction, as well as preventing further use of the data, taking a photograph, audio or video recording, and recording physical characteristics suitable for identifying a person (e.g. fingerprint or palm print, DNA sample, iris image);
- transfer: making the data available to a specified third party;
- disclosure: making the data available to anyone;
- erasure: making the data unrecognisable in such a way that their restoration is no longer possible;
- processing (technical): performing technical tasks related to processing operations, regardless of the method and means used to carry out the operations and of the place of application, provided that the technical task is performed on the data;
- processor: the natural or legal person, or organisation without legal personality, who or which performs the processing of data on the basis of a contract — including a contract concluded pursuant to a provision of law.
3. Company details
Our company details and contact data are as follows:
- Name: MAISON Programozó Iroda Bt.
- Postal address: 1039 Budapest, Juhász Gyula utca 9. 10. em. 98.
- Company registration number: 01 06 417840
- Tax number: 28622101-1-41
- Telephone: +36 30 932 6236
- E-mail: iroda@maison.hu
- Representative of the controller: Papp Sándor
4. The scope of personal data, the purpose, legal basis and duration of processing
We draw the attention of those providing data to MAISON Programozó Iroda Bt. that if they do not provide their own personal data, it is the duty of the person providing the data to obtain the data subject’s consent. The controller is not obliged to examine whether this exists. The controller draws the partner’s attention to the fact that if the partner fails to fulfil this obligation and the data subject therefore asserts a claim against the controller, the controller may pass on the asserted claim and the related amount of damage to the partner.
We provide the following information in connection with our individual processing operations.
4.1. Request for a quote, enquiry by direct contact
Interested parties have the opportunity to contact our Company directly by electronic mail sent to the Company’s address, or by telephone.
- Purpose of processing: contact in the interest of promoting communication between the data subject and our Company and of the closest and most efficient possible cooperation.
- Legal basis of processing: legitimate interest — GDPR Article 6(1)(f)
- Scope of personal data processed: Name of the person requesting a quote / contact person; e-mail address, telephone number and other information provided by the data subject,
- Duration of processing: for 3 years following the validity period of the quote, or until the data subject objects
- Recipients of personal data: The controller does not transfer the data learned to a third party except for the processor(s) indicated in section 7. The recorded data may be learned only by the Controller’s employees and the designated colleagues of the processor(s).
- Indication of the legitimate interest: Our Company’s legitimate interest is the processing of the data subject’s data — direct marketing
- Circle of data subjects: partners and data subjects enquiring directly (e.g. by e-mail, by telephone) about the Company’s services.
4.2. Request for a quote, enquiry via the website (maison.hu)
Our company provides the opportunity for data subjects to request a quote electronically.
- Purpose of processing: contact in the interest of promoting communication between the data subject and our Company and of the closest and most efficient possible cooperation.
- Legal basis of processing: the data subject’s voluntary consent — GDPR Article 6(1)(a).
- Scope of personal data processed: name of the interested party (first name, last name); e-mail address, telephone number, company name and other information provided by the data subject.
- Duration of processing: for 3 years following the validity period of the quote, or until withdrawal of consent.
- Recipients of personal data: The controller does not transfer the data learned to a third party except for the processor(s) indicated in section 7. The recorded data may be learned only by the Controller’s employees and the designated colleagues of the processor(s).
- Circle of data subjects: partners and data subjects enquiring via the website about the Company’s services and products.
4.3. Processing related to follow-up of a request for a quote
- Purpose of processing: the controller’s legitimate interest is to keep records of the data subject’s data beyond the validity period of the quote for the purpose of direct marketing
- Legal basis of processing: the controller’s legitimate interest, GDPR Article 6(1)(f),
- Scope of personal data processed: Contact person’s last name and first name; telephone number; e-mail address
- Recipients of personal data: The controller does not transfer the data learned to a third party except for the processor(s) indicated in section 7. The recorded data may be learned only by the Controller’s employees and the designated colleagues of the processor(s).
- Duration of processing: until the data subject objects
- Indication of the legitimate interest: establishing business relationships with partners and persons requesting quotes, accurate information and notification towards data subjects. Our Company’s legitimate interest is the processing of the data subject’s data — direct marketing
- Circle of data subjects: addressees of quotes previously issued by the Company and the contact person(s) named therein.
4.4. Newsletter registration
- Purpose of processing: sending e-mail newsletters that may also contain commercial advertising to interested parties, information about current news
- Legal basis of processing: the data subject’s prior, voluntary consent, GDPR Article 6(1)(a),
- Scope of personal data processed: name, e-mail address
- Duration of processing: until withdrawal of voluntary consent, until unsubscription from the newsletter. Our Company processes the data provided by the data subject until withdrawal of consent. On the basis of withdrawal of consent we delete the processed data from our newsletter database within 7 days at the latest, and thereafter we will not send you a newsletter.
- Recipients of personal data: The controller does not transfer the data learned to a third party except for the processor(s) indicated in section 7. The recorded data may be learned only by the Controller’s employees and the designated colleagues of the processor(s). You may unsubscribe from the newsletter at any time by a letter sent to our Company at iroda@maison.hu, or by clicking the unsubscribe icon in the newsletter.
- Circle of data subjects: partners and data subjects subscribing to the Company’s electronic newsletter.
4.5. Newsletter data (in the case of newsletters registered before 25 May 2018)
- Purpose of processing: sending e-mail newsletters that may also contain commercial advertising to interested parties, information about current news
- Legal basis of processing: the controller’s legitimate interest, GDPR Article 6(1)(f),
- Scope of personal data processed: name, e-mail address
- Duration of processing: until the data subject objects
- Indication of the legitimate interest: information towards data subjects who subscribed to the newsletter, also containing commercial advertising and business offers. Our Company’s legitimate interest is the processing of the data subject’s data, direct marketing.
- Recipients of personal data: the controller does not transfer the data learned to a third party except for the processor(s) indicated in section 7. The recorded data may be learned only by the Controller’s employees and the designated colleagues of the processor(s). You may unsubscribe from the newsletter at any time by a letter sent to our Company at iroda@maison.hu, or by clicking the unsubscribe icon in the newsletter.
- Circle of data subjects: partners and data subjects who subscribed to the Company’s electronic newsletter before 25 May 2018.
4.6. Camera system
Cameras operate on the premises operated by the controller in the interest of the personal and property security of data subjects and for other purposes. Information boards draw the attention of data subjects to their operation. The activities related to the operation of the camera system have been defined for data subjects in the premises’ “Asset-protection camera processing notice”, which is available at the premises.
4.7. Processing related to ensuring the operation of information technology services
- Purpose of processing: MAISON Programozó Iroda Bt. may use so-called “cookies” (temporary markers) on its websites, which allow faster access to them. By “cookies” we mean an information datum that is active only during the individual customer session and that is placed from the website onto the Customer’s computer for faster identification. The Customer may always request that cookies be switched off by modifying the browser settings; this switch-off, however, may slow down or prevent access to some parts of the site and the use of certain functions.
The session cookies used avoid our having to resort to other IT devices that are potentially harmful to the confidentiality of customers’ navigation and do not make it possible to obtain identifying personal data.
The user is able to delete the cookie from his or her own computer, and may disable the use of cookies in his or her browser. Cookies can generally be managed in the Tools/Settings menu of browsers, under Privacy settings, under the name cookie or süti. - Legal basis of processing: The data subject’s (User’s) voluntary consent, GDPR Article 6(1)(a).
The User gives voluntary consent to processing by accepting the pop-up notice and statement at the start of browsing the website, or by continuing to browse.
Scope of personal data processed: information technology processing concerns the range of data necessary for the operation of the “cookies” used to operate the website and for the use of log files applied by the web hosting provider. - Duration of processing: until the end of the session
- Recipients of personal data: The controller does not transfer the data learned to a third party except for the processor(s) indicated in section 7. The recorded data may be learned only by the Controller’s employees and the designated colleagues of the processor(s).
- Circle of data subjects: every User visiting the website, regardless of the use of the services available on the website.
5. Other processing
We provide information about processing not listed in this notice at the time the data are collected. We inform our customers that certain authorities, bodies performing public tasks and courts may contact our company for the purpose of communicating personal data. Our company discloses personal data to these bodies — if the body concerned has indicated the precise purpose and the scope of the data — only to the extent indispensable for achieving the purpose of the request, and if fulfilment of the request is prescribed by law.
6. Transfer of personal data to a third country or to an international organisation
Our Company does not transfer your above personal data either to a third country or to an international organisation.
7. Information on the use of a processor
During processing the controller transfers the data to the processor(s) contracted with it for the performance of the contract.
Categories of recipients: system administration service provider, accounting and payroll service provider, server hosting, web hosting provider
8. Children
Our services are not intended for persons under 16 years of age, and we ask that persons under 16 years of age not provide Personal data to the Controller.
If it comes to our knowledge that we have collected personal data from a child under 16 years of age — except for processing of data pursuant to statutory requirements — we take the steps necessary to delete the data as soon as possible.
9. Automated decision-making
Our Company does not apply automated decision-making in the course of its processing procedures and data collection.
10. The manner of storing personal data, the security of processing
Our company’s IT systems and other data storage locations are found at the registered office and on the servers provided by the processor. Our company selects and operates the IT devices used in the course of providing the service for the processing of personal data so that the processed data:
- are accessible to those authorised (availability);
- their authenticity and authentication are ensured (authenticity of processing);
- their unchanged nature can be verified (data integrity);
- are protected against unauthorised access (confidentiality of data).
We pay particular attention to the security of the data, and we also take the technical and organisational measures and establish the procedural rules that are necessary for the enforcement of the GDPR guarantees. We protect the data with appropriate measures in particular against unauthorised access, alteration, transmission, disclosure, erasure or destruction, as well as accidental destruction, damage, and becoming inaccessible as a result of a change in the applied technology.
The IT system and network of our company and our partners are equally protected against computer-assisted fraud, computer viruses, computer break-ins and attacks leading to denial of service. The operator also provides for security with server-level and application-level protection procedures. Daily backup of the data is in place. In the interest of avoiding data-protection incidents our company takes every possible measure; if such an incident occurs — according to our incident-management policy — we act without delay in the interest of minimising the risks and eliminating the damage.
11. Rights of data subjects, remedies
The data subject may request information about the processing of his or her personal data, and may request the rectification of his or her personal data, and — with the exception of mandatory processing — their erasure or withdrawal, and may exercise the right to data portability and the right to object in the manner indicated at the collection of the data, or at the controller’s contact details above.
The rights and remedies of the data subject have been defined and communicated to data subjects on the basis of Act CXII of 2011 and EU Regulation 2016/679.
The right to information, or otherwise the data subject’s “right of access”: On the basis of Act CXII of 2011 and Article 15 of EU Regulation 2016/679, upon the data subject’s request the Controller provides information about
- the data processed by it and the categories of personal data,
- the purpose of processing,
- the legal basis of processing,
- the duration of processing,
- where applicable, the period for which the data will be stored, or if that is not possible, the criteria used to determine that period,
- where applicable, if the data were not collected from the data subject, any available information as to their source,
- where applicable, automated decision-making, including profiling, as well as intelligible information about the logic involved and about the significance of such processing, and
- the envisaged consequences for the data subject,
- the processor’s data, if a processor was used, i. the circumstances of the personal data breach, its effects and the measures taken to remedy it, and
- in the event of a transfer of the data subject’s personal data, the legal basis, purpose and recipient of the transfer.
The information is free of charge if the person requesting information has not yet submitted a request for information covering the same data range to the Controller in the current year. In other cases a fee may be established. The fee already paid must be reimbursed if the data were processed unlawfully, or if the request for information led to rectification.
The Controller draws the attention of data subjects to the fact that information must be refused on the basis of Act CXII of 2011,
- if, on the basis of an act, an international treaty or a binding legal act of the European Union, the Controller receives personal data in such a way that the transferring controller indicates at the same time as the transfer the restriction of the rights of the data subject of the personal data guaranteed in the named act, or another restriction of processing.
- in the interest of the external and internal security of the state, thus national defence, national security, the prevention or prosecution of criminal offences, the security of the execution of sentences, and also for a state or municipal economic or financial interest, for a significant economic or financial interest of the European Union, and for the purpose of preventing and detecting disciplinary and ethical offences related to the practice of professions, labour-law and occupational-safety breaches of obligation — including in every case inspection and supervision as well — and also in the interest of protecting the rights of the data subject or of others.
The Controller is obliged to notify the National Authority for Data Protection and Freedom of Information of refused requests for information annually by 31 January of the year following the subject year.
The right to rectification: The data subject is entitled to obtain from the Controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject is entitled to have incomplete personal data completed, including by means of providing a supplementary statement. At the same time, if the personal data do not correspond to reality, and the personal data corresponding to reality are available to the Controller, the Controller is obliged to rectify the personal data even without the data subject’s request.
The right to erasure, or otherwise the “right to be forgotten”: The data subject is entitled to obtain from the Controller the erasure of personal data concerning him or her without undue delay, and the Controller is obliged to erase personal data concerning the data subject without undue delay, if mandatory processing does not exclude it.
In addition to the above case, the Controller is obliged to erase the data on the basis of Act CXII of 2011 and Regulation (EU) 2016/679 of the European Parliament and of the Council, if
- the processing of the data is unlawful;
- the data are incomplete or incorrect — and this state cannot be remedied lawfully — provided that erasure is not excluded by law;
- the purpose of processing has ceased, or the time limit for storage of the data specified by law has expired;
- it has been ordered by the court or the Authority.
- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- the data subject objects to the processing and there is no overriding legitimate ground for the processing;
- the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the Controller is subject;
- the personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of EU Regulation 2016/679, offered directly to a child.
If the Controller has made the personal data public for some reason, and is obliged to erase them in accordance with the above, taking into account available technology and the cost of implementation it takes reasonable steps — including technical measures — to inform other controllers processing the data that the data subject has requested the erasure of any links to, or copy or replication of, those personal data.
The Controller draws the attention of data subjects to the limitations of the right to erasure or to be forgotten arising from the EU regulation, which are as follows:
- exercising the right of freedom of expression and information;
- compliance with a legal obligation which requires processing by Union or Member State law to which the 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 controller;
- public interest in the area of public health;
- archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) of EU Regulation 2016/679, in so far as the right to erasure is likely to render impossible or seriously impair that processing; or
- the establishment, exercise or defence of legal claims.
The right to restriction of processing, or otherwise the right to blocking: The data subject is entitled to obtain from the Controller restriction of processing.
If, on the basis of the information available, it can be assumed that erasure would harm the data subject’s legitimate interests, the data must be blocked. Personal data blocked in this way may be processed only until the processing purpose that excluded erasure of the personal data exists.
If the data subject contests the accuracy or correctness of the personal data, but the incorrectness or inaccuracy of the contested personal data cannot be clearly established, the data are blocked. In this case the restriction relates to a period enabling the Controller to verify the accuracy of the personal data.
On the basis of the EU regulation the data must be blocked if
- the processing is unlawful and the data subject opposes the erasure of the data and requests the restriction of their use instead;
- the Controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; or
- the data subject has objected to processing; in this case the restriction relates to the period until it is established whether the Controller’s legitimate grounds override those of the data subject.
Where processing has been restricted (blocked), such personal data shall, with the exception of storage, only be processed with the data subject’s consent 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 reasons of important public interest of the Union or of a Member State.
The Controller hereby particularly draws the attention of data subjects to the fact that the data subject’s right to rectification, erasure and blocking may be restricted by law in the interest of the external and internal security of the state, thus national defence, national security, the prevention or prosecution of criminal offences, the security of the execution of sentences, and also for a state or municipal economic or financial interest, for a significant economic or financial interest of the European Union, and for the purpose of preventing and detecting disciplinary and ethical offences related to the practice of professions, labour-law and occupational-safety breaches of obligation — including in every case inspection and supervision as well — and also in the interest of protecting the rights of the data subject or of others.
The Controller informs the data subject without undue delay, at most within 30 days of receipt of the request, of the matters specified in the request, and/or rectifies the data, and/or erases and/or restricts (blocks) the data, or takes other steps in accordance with the request, if there is no excluding ground.
The Controller notifies the data subject in writing of the rectification, the erasure and the restriction of processing, as well as all those to whom the data were previously transferred or disclosed for the purpose of processing. Upon the data subject’s request the Controller informs the data subject of these recipients. The notification may be omitted if, having regard to the purpose of processing, it does not harm the data subject’s legitimate interest, or if the information proves impossible or would involve a disproportionate effort. The Controller is also obliged to notify the data subject in writing if the data subject’s exercise of rights cannot be realised for some reason, and is obliged to indicate precisely the factual and legal ground, as well as the remedies available to the data subject: the possibility of turning to the court and to the National Authority for Data Protection and Freedom of Information.
The “right to data portability”: The data subject is entitled to
- receive the personal data concerning him or her, which he or she has provided to the Controller, in a structured, commonly used and machine-readable format, and is entitled to
- transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
- the processing is based on consent; and
- the processing is carried out by automated means.
In exercising the right to data portability the data subject is entitled to have the personal data transmitted directly from one controller to another, where technically feasible.
Having regard to the processing carried out by the Controller, the conditions for exercising the right to data portability are not fulfilled (there is no automated processing), therefore the data subject cannot exercise this right.
The right to object: The data subject may object to the processing of his or her personal data — including profiling — if
- the processing (transfer) of personal data is necessary solely for the enforcement of the right or legitimate interest of the Controller or of the data recipient, except in the case of mandatory processing;
- the use or transfer of the personal data takes place for the purpose of direct marketing, public opinion polling or scientific research;
- the exercise of the right to object is otherwise permitted by law.
The data subject may also object under Article 21(3) of EU Regulation 2016/679 to the processing of personal data for the purpose of direct marketing; in that case the personal data may no longer be processed for this purpose.
Where personal data are processed for scientific or historical research purposes or statistical purposes, the data subject, on grounds relating to his or her particular situation, is entitled to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
The Controller — with simultaneous suspension of processing — examines the objection within the shortest time, but at most within 30 days of submission of the request, and informs the applicant of the result in writing. If the applicant’s objection is well founded, the Controller terminates the processing — including further collection and transfer of data — and blocks the data, and notifies of the objection and of the measures taken on the basis thereof all those to whom the personal data affected by the objection were previously transferred, and who are obliged to take measures in the interest of enforcing the right to object.
If the data subject does not agree with the Controller’s decision, or the Controller misses the cited deadline, the data subject is entitled — within 30 days of its communication — to turn to the court.
The data subject has the right to object in connection with automated decision-making.
Enforcement before the court: In the event of a violation of his or her rights the data subject may turn to the court. The court proceeds out of turn in the case. It is the Controller’s duty to prove that the processing complies with the provisions of the law.
In the event of a violation of the right to informational self-determination, a report or complaint may be lodged with:
National Authority for Data Protection and Freedom of Information
Address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c
Telephone: +36 (1) 391-1400, Fax: +36 (1) 391-1410
www: http://www.naih.hu
e-mail: ugyfelszolgalat@naih.hu