Privacy Policy

I.              Introductions:

Halms Hungary Korlátolt Felelősségű Társaság (4002 Debrecen, Bánki Donát u. 2., tax number: 27554870-2-09, company number: 09-09-034672), (hereinafter: Service-provider, Data processor) submits to the following policy.

The following Privacy Policy is provided in line with REGULATION (EU) 2016/679 of the EUROPEAN PARLIAMENT AND 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.
This Privacy Policy regulates the data processing of the following websites: https://halms.hu
This Privacy Policy can be found on: https://halms.hu/privacy-policy/

Modifications to the Privacy Policy become effective when they appear on the webpage above.

THE DATA CONTROLLER AND CONTACT INFORMATION:

Name: Halms Hungary Korlátolt Felelősségű Társaság
Seat: 4002 Debrecen, Bánki Donát u. 2

E-mail: customercenter@halms.com
Phone: +49 70 518 063 577

II.           Definitions:

1. “personal data”: any information relating to an identified or identifiable natural person (“data subject”); identifiable by a natural person who, directly or indirectly, in particular by virtue of one or more factors such as name, number, position, online identification or physical, physiological, genetic, intellectual, economic, cultural or social identity of the natural person;

2. “data management”: the totality of any operation or operations carried out in an automated or non-automated manner on personal data or data files, such as collecting, recording, organising, tagging, storing, modifying or modifying, querying, inspecting, using, communicating, distributing or otherwise making available, aligning or linking, limiting, deleting or destroying personal data;

3. “data controller”: any natural or legal person, public authority, agency or any other body that determines the purposes and means of handling personal data individually or with others, where the purposes and means of data processing are defined by EU or national law, the data controller or the particular aspects of the designation of the data controller may also be defined by EU or national law;

4. “data processor”: any natural or legal person, public authority, agency or any other body that manages personal data on behalf of the data controller;

5. “recipient”: a natural or legal person, a public authority, agency or any other body with whom or with which personal data is communicated, whether or not it is a third party. Public authorities which have access to personal data in an individual investigation in accordance with EU or national law shall not be considered recipients; the management of those data by those public authorities must comply with the applicable data protection rules in accordance with the purposes of data management;

6. „third party”: means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data;

7. „the contributor concerned”: a voluntary, specific and appropriate informed and explicit statement of the will of the person concerned by which he or she expresses the statement or confirmation by means of an inadvertent act of affirmation that he or she has consented to the processing of personal data concerning him or her;

8. “data protection incident”: a security breach resulting in accidental or unlawful destruction, loss, alteration, unauthorized disclosure or unauthorized access to personal data transmitted, stored or otherwise treated.

III.        Principles relating to the processing of personal data:

During the processing of personal data, the following principles shall be always respected.

Lawfulness, fairness, transparency

Personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject

Purpose limitation

Personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.

Data minimization

Personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

Accuracy

Personal data shall be 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.

Storage limitation

Personal data shall be 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.

Integrity and confidentiality

Personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

Accountability

The data controller shall be responsible for, and be able to demonstrate compliance with the principles mentioned above.

The principles of data protection shall apply to any information concerning an identified or identifiable natural person.

Every person under the effect of this Policy shall take every reasonable measure to ensure that the data processing of Company as controller is in compliance with the present principles.

IV.        Data management related to the webshop operation/use of service:

1.     Fact of data collection, the range of managed data and the aim of data management:

Personal data
Aim of data management
Legal Basis
Full name
It is necessary for contact.
Article 6 (1) (b) GDPR
E-mail address
It is necessary for contact.
Mobile
It is necessary for contact.
Company name
If necessary, the issuance of a regular invoice, the creation of the contract, the definition, modification, fulfillment of the contract, the billing of the charges arising therefrom and the enforcement of the related claims.
Article 6 (1) (c) GDPR and Article 169 (2) of Act C of 2000 on Accounting
 

2. Range of Customers: Everybody sent a message from the website.

3. Duration of data handling, deadline for data deletion: If one of the conditions set out in Article 17 (1) of the GDPR is met, the person concerned shall continue to apply for cancellation. Any deletion of any personal data provided by the data subject shall be communicated to the data subject electronically in accordance with Article 19 of the GDPR. If the data subject’s cancellation request also covers the email address specified by him / her, the data manager will also delete the email address after the notification. Except in the case of accounting documents, under § 169 (2) of Act C of 2000 on Accounting, these data must be retained for eight years.

The accounting document (including general ledger accounts, analytical and accounting records) supporting the accounts directly and indirectly must be kept in a legible form for at least 8 years, retrievable by reference to the accounting records.

4. Possible persons working as data controllers that are entitled to know the data, the recipients of personal data: Personal data may be handled by the sales and marketing staff of the data controller, respecting the above principles.

5. Rights of data subjects involved in data management:

·       The data subject may apply to the data controller for access to, correction, deletion or limitation of the personal data concerning him, and

·       the data subject has the right to data storage and to withdraw the consent at any time.

6. It is possible to initiate, delete, modify or restrict access to personal data, transferability of data, and objection to data processing in the following ways:

·       By post at the address: Halms Hungary Korlátolt Felelősségű Társaság

·       Via e-mail:  customercenter@halms.com

·       By phone:  +49 70 518 063 577

7. Legal basis for data management:

7.1. Article 6 (1) (b) and (c) of the GDPR.

7.2. Article 6 (1) (c) in the case of an invoice in accordance with accounting legislation.

7.3. In the event of the claim arising from the contract, Act V of 2013 on the Civil Code 6:22. § 5 years.

6:22. § [Limitation]

(1) Save as otherwise provided in this Act, claims shall expire in five years.

(2) The limitation period begins when the claim becomes due.

(3) An agreement to change the limitation period shall be in writing.

(4) The limitation period is null and void.

V.           Use of Cookies:

1. Webshop-specific cookies are so-called “password-protected session cookies”, “shopping cart cookies”, and “security cookies”, “Cookies required”, “Functional cookies”, and “Cookies that are responsible for managing the stats of a website”, that require no prior consent from users.

2. The fact of data handling, the range of data processed: Unique identification number, times, dates.

3. The range of customers: All the people who visiting the website.

4. Aim of data management: Identifying users, to register your “shopping cart” and tracking visitors.

5. Term of data management, deadline for deletion of data:

Type of cookie
Legal basis for data handling
Duration of data management
Session cookies or other cookies essential for the functioning of the website

 
Article 6 (1) (f) GDPR

The data controller has a legitimate interest regarding the operation of the website, to ensure the functionality and essential functions of the website and the security of the computer system.
The relevant session until the end of a visitor’s session
Permanent or saved cookies
Article 6 (1) (f) GDPR

The data controller has a legitimate interest regarding the operation of the website, to ensure the functionality and essential functions of the website and the security of the computer system.
Until the affected person is deleted
Statistical cookies
Article 6 (1) (a) GDPR
1 month – 2 years
 

6. The potential data managers entitled to know the data: With the use of cookies the service provider does not manage personal data.

7. Giving information on the rights of the Customers related to data management: Customers can delete cookies in the Tools/Settings menu of the browser generally at the menu item Data protection.

8. Legal basis of data management: No consent is required if the sole purpose of the use of cookies is the communication service provided through the electronic communications network or the provision of information society services expressly requested by the subscriber or user.

9. Most browsers that our users use allow you to set which cookies to save and allow (specified) cookies to be deleted again. If you restrict or save third-party cookies on specific websites, this may in some circumstances result in our website not being fully usable. Here is information on how to customize cookie settings for standard browsers:

Google Chrome: https://support.google.com/chrome/answer/95647?hl=en

Edge / Internet Explorer: https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox

Safari: https://support.apple.com/guide/safari/manage-cookies-sfri11471/mac

Using the Google Ads conversion tracking:

1. The online advertising program called “Google Ads” is used by the Data Controlelr and uses the Google conversion tracking feature within its framework. Google conversion tracking is Google Inc.’s analytics service (1600 Amphitheater Parkway, Mountain View, CA 94043, USA; “Google”).

2. When a User accesses a web site through a Google Ad, a conversion tracking cookie is placed on your computer. These cookies have limited validity and do not contain any personal information, so the User can not be identified by them.

3. When the User browses on certain pages of the website and the cookie has not expired, Google and the data controller will also see that the User clicked on the ad.

4. Each Google Ads customer receives a different cookie so that they can not be tracked through Ads clients’ websites.

5. The information you receive through conversion tracking cookies is intended to make conversion statistics for your Ads conversion tracking customers. Customers will then be informed about the number of users who have been submitted to their ad and click on a conversion tracking tag. However, they do not have access to information that could identify any user.

6. If you do not want to participate in conversion tracking, you can disable this by blocking cookies from being installed on your browser. Then you will not be included in conversion tracking statistics.

7. For more information and Google Privacy Statement, visit: www.google.de/policies/privacy/

Use of the Google Analytics:

1. This website uses Google Analytics, which is the webanalyser service of Google Inc. (“Google”). Google Analytics uses so called “cookies”, which are word files that are saved on your computer, and that help the analysis of the website usage of the Users.

2. The information generated by the cookies associated with the User’s use of the Site is typically stored and stored on a Google server in the US. By activating the IP anonymization web site, Google will shorten the User’s IP address within the Member States of the European Union or other States party to the European Economic Area Agreement.

3. The full IP address will only be forwarded to Google’s server in the US and shortened there only in exceptional cases. On behalf of the operator of this website, Google will use this information to evaluate how the user has used the website, to provide the website operator with reports related to the web site activity, and to provide the website operator with reports related to the activity of the website and to provide additional services related to the use of the website and the internet.

4. Within Google Analytics, the IP address transmitted by the User’s browser is not reconciled with other Google data. The User may prevent the storage of cookies by properly configuring his / her browser, however, please note that in this case not all features of this website may be fully utilized. You may also prevent Google from collecting and processing the User’s information on your use of the Website (including your IP address) by downloading and installing the browser plug-in at the following link. 

https://tools.google.com/dlpage/gaoptout?hl=hu

VI.        Recipients, addressed with the personal data:

Data management activity
Name, address, contact
 
 
 
Storage-provider
Name: Cloudways Ltd. Address: Junction Business Centre, 1st Floor Sqaq Lourdes, St Julians STJ3334, Malta; Phone: +35635500106; E-mail: […]
 

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

2. Who is affected: All data subjects who use the website.

3. Purpose of data processing: To make the website available and to ensure its proper operation.

4. Duration of data processing, deadline for deletion of data: Data processing shall continue until the termination of the agreement between the data controller and the hosting provider or until the data subject’s request for deletion to the hosting provider.

5. Legal basis for processing: Article 6(1)(b).

VII.       Social websites:

1. The fact of data collection, range of managed data: name and public profile image of the Customer registered at Meta/Instagram etc.

2. Concerning: Anyone who has registered on Meta/Instagram etc. social networking sites and “liked” the service provider’s social networking site or contacted the data controller through a social networking site.

3. Purpose of the data collection: To share, or “like”, promote certain content elements, products, actions of the web site or the website itself on social networking sites.

4. Duration of data processing, deadline for deletion of data, person of possible data controllers who are able to know the data and details of the data management rights of the data subjects: Information about the source, their handling, the method of transfer and the legal basis of the data can be consulted on the given social networking site. Data management takes place on social networking sites, so the duration of the data handling, the ways of deleting and modifying the data are governed by the rules of the respective community site.

5. Legal base of data management: voluntary consent of the Customer for the management of personal data at community sites.

VIII.   Customer services and other data management:

1. Should you have any questions or problems in using our data management services, you may contact the data controller in the ways specified on the website (phone, e-mail, social networking sites, etc.).

2. The data controller deletes the incoming emails, messages, on phone, or anything on any social media site, that contains the name and email address or any other given personal information of the customer, after 2 years from the start of the service.

3. Data handling not listed in this policy will be provided at the time of data collection.

4. The service provider is obliged to provide guidance, information, data and documents upon exceptional request of the authorities or upon request of other bodies authorised by law.

5. In these cases, the service provider will provide the requester with personal data only to the extent and to the extent necessary to fulfill the purpose of the request, provided that the exact purpose and scope of the data have been indicated.

IX.         Customer rights:

1.       The right of access

You are entitled to receive feedback from the data controller about whether your personal data is being processed and, if such processing is in progress, you have the right to have access to your personal information and the information listed in the decree.

2.       The right of rectification

You are entitled to request the data controller to rectify any inaccurate personal information that he or she is required to do without undue delay. Taking into account the purpose of data management, you are entitled to request the supplementation of incomplete personal data, including by means of a supplementary statement.

3.       The right to deletion

You are entitled to request that the data controller, without undue delay, disclose personal information about you, and that the data controller is obliged to delete personal information about you, without undue delay, under certain conditions.

4.       The right to be forgotten

If the data controller has disclosed the personal data and is required to delete it, it shall reasonable steps, including technical measures, to take into account the cost of available technology and implementation, in order to inform the data controllers handling the data that you have applied for the personal data in question pointing links or deleting a duplicate or duplicate of these personal data.

5.       The right to restrict data management

You are entitled to request that your data controller restricts your data handling if one of the following conditions is met:

·       You dispute the accuracy of your personal data; in this case, the restriction applies to the period of time that the data controller can check the accuracy of personal data;

·       Data handling is illegal and you are opposed to the deletion of data and instead asks you to restrict them;

·       The data controller no longer needs personal data for data processing, but you require them to submit, enforce, or protect legal claims;

·       You have objected to data manipulation; in this case, the restriction applies to the period when it is established that the legitimate reasons for the data controller have priority over your legitimate reasons.

6.       The right to data storage

You are entitled to receive personal data that is made available to you by a data controller in a fragmented, widely used machine-readable format and is entitled to transfer this data to another data controller without this being obstructed by the data controller whose provided personal information to you (…)

7.       The right ro protest

You are entitled to object to the handling of your personal information (…), including profiling based on these provisions, for any reason relating to your own situation.

8.       Protest in case of direct business acquisition

If your personal data is handled for direct business, you are entitled to protest at any time against the handling of personal data relating to it, including profiling, if it is related to direct business acquisition. If you object to personal data being handled for direct business purposes, your personal information can no longer be handled for that purpose.

9.       Automated decision-making in individual cases, including profiling

You are entitled to exclude the scope of any decision based solely on automated data handling, including profiling, which would have a bearing on it or affect it significantly.

The preceding paragraph shall not apply if the decision is:

·       You are required to conclude or complete a contract between you and the data controller;

·       the granting of the right to a data controller is subject to the law of the European Union or of the Member States which also lays down appropriate measures to protect your rights and freedoms and legitimate interests; or

·       based on your explicit consent.

X.            The obligations of Company connected to data processing:

1.     Security of personal data:

The personal data has to be protected with appropriate measures especially from unauthorized access, alteration, transfer, disclosure, erasure or destruction, loss, damage and becoming inaccessible due to the change of the applied technology.

During the planning and the application of the data security, the state of the technology shall be taken into account. Between more potential data processing solutions, the one has to be chosen that provides the higher level of protection, except that it would cause disproportionate difficulty to the data processor.

2.     Personal data breach:

Personal data breach is such a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

The personal data breach has to be reported to the supervisory authority without undue delay, but not later than 72 hours, except for if it can be proved that the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.

The data subject has to be informed without undue delay if the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, in order that he/she could take the necessary measures. The information sent to the data subject has to be clear and plain language and he/she has to be informed on the name and contact of the data protection officer or other contact point where more information can be obtained, the likely consequences of the personal data breach and the measures taken or proposed to be taken by the controller to address the personal data breach.

3.     The review of the personal data

In order to ensure that the storage of personal data is to be limited to a necessary period, Company determines a regular review deadline.

The regular review deadline determined by Company is 3 year.

4.     Register of processing activities

A register has to be managed about all personal data processing activities carried out by Company. The language of the register is English.

The register has to contain the following information:

–        the name and contact details of the controller and, where applicable, the joint controller, the controller’s representative and the data protection officer,

–        the purposes of the processing,

–        a description of the categories of data subjects and of the categories of personal data,

–        the categories of recipients to whom the personal data have been or will be disclosed including recipients in third countries or international organisations,

–        where applicable, transfers of personal data to a third country or an international organisation, including the identification of that third country or international organisation and the documentation of suitable safeguards,

–        where possible, the envisaged time limits for erasure of the different categories of data,

–        where possible, a general description of the technical and organisational security measures made for data security.

The register shall be updated with every change occurring in the data processing activities and with the appearance of a new data processing activity.

The content of the register shall be reviewed annually.

The person responsible for the management and the review of the register:

–        HR generalist.

The employees processing personal data shall inform the person designated above on any changes in the data processing activities carried out by them or on the appearance of a new data processing activity.

5.     Data processing for other purposes

If Company wishes to carry out such data processing that is not regulated in the present Policy, the Policy shall be modified and the rules compliant to the new purpose have to be determined first.

XI.         Enforcement possibilities connected to data processing:

In case of the violation of the rights connected to personal data processing, the data subject is entitled to submit a complaint to the Hungarian National Authority for Data Protection and Freedom of Information.

Hungarian National Authority for Data Protection and Freedom of Information

Address: 1055 Budapest, Falk Miksa utca 9-11.

Postal address: 1363 Budapest, Pf.: 9.

Phone number: +36 (1) 391-1400 

Fax: +36 (1) 391-1410 

E-mail: ugyfelszolgalat@naih.hu 

URL: https://naih.hu 

The data subject can submit a claim to the competent court in case of the violation of its rights. The court proceeds with priority in the case. The data subject – by choice – is entitled to submit the claim to the court competent according to the permanent or temporary residence of the data subject.