Privacy Policy

1. Introduction

PEM Enterprise Korlátolt Felelősségű Társaság (hereinafter PEM Enterprise Korlátolt Felelősségű Társaság, service provider, data controller, Company), as data controller, acknowledges the contents of this legal notice as binding upon itself.
The Company undertakes to ensure that all data processing related to its activities complies with the requirements set out in this policy and in the applicable legislation.
PEM Enterprise Korlátolt Felelősségű Társaság is the operator of the gyantasok.hu website.

PEM Enterprise Korlátolt Felelősségű Társaság reserves the right to amend this notice at any time. It will of course inform its audience of any changes in good time.

PEM Enterprise Korlátolt Felelősségű Társaság is committed to protecting the personal data of its clients and partners and considers it of the utmost importance to respect its clients' right to informational self-determination. The Data Controller treats personal data as confidential and takes every security, technical and organisational measure that guarantees the security of the data.

Below, PEM Enterprise Korlátolt Felelősségű Társaság sets out its data processing principles and presents the expectations it has formulated for itself as data controller and which it observes. Its data processing principles are in line with the applicable data protection legislation, in particular the following:

Act CXII of 2011 on the right to informational self-determination and on freedom of information;
Act V of 2013 on the Civil Code;
Act XLVIII of 2008 on the basic conditions and certain restrictions of commercial advertising activity;
Act CVIII of 2001 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 identified or, directly or indirectly, identifiable on the basis of personal data;
personal data: data that can be linked to the data subject — in particular the data subject's name, identification number and any information characteristic of one or more of their physical, physiological, mental, economic, cultural or social identity — as well as any conclusion about the data subject that can be drawn from such data;
consent: the voluntary and definite declaration of the data subject's wishes, based on adequate information, by which they give their unambiguous agreement to the processing — in full or in respect of individual operations — of personal data relating to them;
data controller: the natural or legal person, or organisation without legal personality, who or which alone or together with others determines the purpose of the processing of data, takes and implements decisions on the processing (including the means used), or has them implemented by a data processor;
data processing: irrespective of the procedure applied, any operation or set of operations performed on data, in particular the collection, recording, registration, organisation, storage, alteration, use, retrieval, transfer, disclosure, alignment or combination, blocking, erasure and destruction of data, as well as preventing further use of the data, taking photographs, audio or video recordings, and recording physical characteristics suitable for identifying a person (e.g. fingerprints or palm prints, DNA samples, iris images);
data transfer: making data accessible to a specified third party;
disclosure: making data accessible to anyone;
erasure of data: rendering data unrecognisable in such a way that its restoration is no longer possible;
data handling: the performance of technical tasks related to data processing operations, irrespective of the method and means used and of the place of application, provided that the technical task is performed on the data;
data processor: the natural or legal person, or organisation without legal personality, who or which processes the data under a contract — including a contract concluded on the basis of a statutory provision.

3. Company details

Our company's details and contact information are as follows:

Name: PEM Enterprise Korlátolt Felelősségű Társaság
Postal address: 8000 Székesfehérvár, Levendula utca 23., Building I
Company registration number: 14-09-313307
VAT number: 22609803-2-14
Phone: +36 30 600 9072
E-mail: info@gyantasok.hu
Representative of the data controller: Péter Palotai, managing director

4. The scope of personal data, and the purpose, legal basis and duration of processing

We draw the attention of those providing data to PEM Enterprise Korlátolt Felelősségű Társaság to the fact that if they do not provide their own personal data, it is their obligation to obtain the consent of the data subject. The data controller is not obliged to verify that such consent exists. The data controller draws the partner's attention to the fact that if the partner fails to meet this obligation and the data subject therefore asserts a claim against the data controller, the data controller may pass on the claim asserted and the amount of any related damage to the partner.

We provide the following information in relation to our individual processing activities.

4.1. Quote requests and enquiries by direct contact

Interested parties may contact our Company directly by electronic mail sent to the Company's address or by telephone.

Purpose of processing: keeping in contact, in order to promote communication between the data subject and our Company and to achieve the closest and most effective cooperation possible.
Legal basis of processing: legitimate interest — Article 6(1)(f) GDPR
Scope of personal data processed: the name of the person requesting the quote / contact person; their e-mail address, phone number and any other information provided by the data subject,
Duration of processing: for 3 years following the expiry of the validity of the quote, or until the data subject objects
Recipients of the personal data: the data controller does not disclose the data obtained to third parties, with the exception of the data processor(s) listed in point 7. The recorded data may be accessed only by the employees of the Data Controller and by the designated colleagues of the data processor(s).
Statement of the legitimate interest: our Company has a legitimate interest in processing the data subject's data — direct marketing
Data subjects concerned: partners and data subjects enquiring directly (e.g. by e-mail or telephone) about the Company's services.

4.2. Quote requests and enquiries via the website (gyantasok.hu)

Our company allows data subjects to request a quote by electronic means.

Purpose of processing: keeping in contact, in order to promote communication between the data subject and our Company and to achieve the closest and most effective cooperation possible.
Legal basis of processing: the voluntary consent of the data subject — Article 6(1)(a) GDPR.
Scope of personal data processed: the name of the enquirer (first name, surname); their e-mail address, phone number, company name and any other information provided by the data subject.
Duration of processing: for 3 years following the expiry of the validity of the quote, or until consent is withdrawn.
Recipients of the personal data: the data controller does not disclose the data obtained to third parties, with the exception of the data processor(s) listed in point 7. The recorded data may be accessed only by the employees of the Data Controller and by the designated colleagues of the data processor(s).
Data subjects concerned: partners and data subjects enquiring via the website about the Company's services and products.

4.3. Processing in connection with the follow-up of quote requests

Purpose of processing: the data controller has a legitimate interest in keeping a record of the data subject's data beyond the validity period of the quote for the purpose of direct marketing
Legal basis of processing: the legitimate interest of the data controller, Article 6(1)(f) GDPR,
Scope of personal data processed: contact person's surname and first name; phone number; e-mail address
Recipients of the personal data: the data controller does not disclose the data obtained to third parties, with the exception of the data processor(s) listed in point 7. The recorded data may be accessed only by the employees of the Data Controller and by the designated colleagues of the data processor(s).
Duration of processing: until the data subject objects
Statement of the legitimate interest: building business relationships with partners and those requesting quotes, and providing accurate information to data subjects. Our Company has a legitimate interest in processing the data subject's data — direct marketing
Data subjects concerned: the addressees of quotes previously issued by the Company and the contact person(s) named in them.

4.4. Newsletter registration

Purpose of processing: sending e-mail newsletters that also contain commercial advertising to interested parties, and providing information about current matters
Legal basis of processing: the prior, voluntary consent of the data subject, Article 6(1)(a) GDPR,
Scope of personal data processed: name, e-mail address
Duration of processing: until voluntary consent is withdrawn or the data subject unsubscribes from the newsletter. Our Company processes the data provided by the data subject until consent is withdrawn. Following the withdrawal of consent, we delete the processed data from our newsletter database within 7 days at the latest, after which we no longer send you newsletters.
Recipients of the personal data: the data controller does not disclose the data obtained to third parties, with the exception of the data processor(s) listed in point 7. The recorded data may be accessed only by the employees of the Data Controller and by the designated colleagues of the data processor(s). You may unsubscribe from the newsletter at any time by sending a message to our Company at info@gyantasok.hu, or by clicking the unsubscribe icon in the newsletter.
Data subjects concerned: partners and data subjects who subscribe to the Company's electronic newsletter.

4.5. Newsletter data (for newsletter registrations made before 25 May 2018)

Purpose of processing: sending e-mail newsletters that also contain commercial advertising to interested parties, and providing information about current matters
Legal basis of processing: the legitimate interest of the data controller, Article 6(1)(f) GDPR,
Scope of personal data processed: name, e-mail address
Duration of processing: until the data subject objects
Statement of the legitimate interest: providing information that also contains commercial advertising and business offers to data subjects who subscribed to the newsletter. Our Company has a legitimate interest in processing the data subject's data — direct marketing.
Recipients of the personal data: the data controller does not disclose the data obtained to third parties, with the exception of the data processor(s) listed in point 7. The recorded data may be accessed only by the employees of the Data Controller and by the designated colleagues of the data processor(s). You may unsubscribe from the newsletter at any time by sending a message to our Company at info@gyantasok.hu, or by clicking the unsubscribe icon in the newsletter.
Data subjects concerned: partners and data subjects who subscribed to the Company's electronic newsletter before 25 May 2018.

4.6. Camera system

Cameras operate on the site operated by the data controller in the interest of the personal and property safety of data subjects and for other purposes. Information signs draw the attention of data subjects to their operation. The activities related to the operation of the camera system are set out in the site's "Information notice on property protection camera data processing", which is available at the site.

4.7. Processing related to ensuring the operation of the information technology service

Purpose of processing: PEM Enterprise Korlátolt Felelősségű Társaság may use so-called "cookies" (temporary markers) on its websites, which allow faster access to them. By "cookies" we mean an item of information that is active only for the duration of an individual client session and that is transferred from the website to the Client's computer for the purpose of faster identification. The Client may at any time request that cookies be switched off by changing their browser settings; however, switching them off may slow down or prevent access to some parts of the site and the use of certain functions.
The session cookies used avoid the need to resort to other IT tools that are potentially harmful to the confidentiality of clients' browsing and that do not allow the identifying personal data of the user to be obtained.
Users are able to delete cookies from their own computer and to disable the use of cookies in their browser. Cookies can generally be managed in the Tools/Settings menu of browsers, under privacy settings, under the heading cookies.
Legal basis of processing: the voluntary consent of the data subject (User), Article 6(1)(a) GDPR.
The User gives their voluntary consent to the processing by accepting the pop-up notice and declaration when they begin browsing the website, or by continuing to browse.
Scope of personal data processed: the information technology processing concerns the data required for the operation of the "cookies" used to run the website and for the use of the log files applied by the web hosting provider.
Duration of processing: until the session is closed
Recipients of the personal data: the data controller does not disclose the data obtained to third parties, with the exception of the data processor(s) listed in point 7. The recorded data may be accessed only by the employees of the Data Controller and by the designated colleagues of the data processor(s).
Data subjects concerned: every User visiting the website, irrespective of whether they use the services available on the website.

5. Other processing

We provide information on processing activities not listed in this notice at the time the data is collected. We inform our clients that certain authorities, bodies performing public duties and courts may contact our company for the purpose of disclosing personal data. Our company discloses personal data to these bodies — provided that the body concerned has specified the exact purpose and the scope of the data — only to the extent and in the volume that is strictly necessary to achieve the purpose of the request, and only where the 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 personal data referred to above either to a third country or to an international organisation.

7. Information on the use of data processors

During the processing, the data controller transfers the data to the data 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 the age of 16, and we ask that persons under the age of 16 do not provide Personal data to the Data Controller.
If it comes to our attention that we have collected personal data from a child under the age of 16 — with the exception of the processing of data required by law — we will 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 its data processing procedures or data collection.

10. The manner of storing personal data, and the security of processing

Our company's IT systems and other data storage locations are located at its registered office and on the servers provided by the data processor. Our company selects and operates the IT tools used for the processing of personal data in the course of providing its services in such a way that the processed data is:

accessible to those authorised to access it (availability);
authentic and its authenticity assured (authenticity of processing);
verifiable as unaltered (data integrity);
protected against unauthorised access (confidentiality of data).

We pay particular attention to the security of data, and we also take the technical and organisational measures and establish the procedural rules necessary to give effect to the guarantees under the GDPR. We protect the data with appropriate measures, in particular against unauthorised access, alteration, transfer, disclosure, deletion or destruction, as well as against accidental destruction or damage and against becoming inaccessible as a result of changes in the technology applied.

The IT systems and networks of both our company and our partners are protected against computer-assisted fraud, computer viruses, computer intrusions and denial-of-service attacks. The operator provides for security by means of both server-level and application-level protection procedures. Daily backups of the data are in place. Our company takes every possible measure to avoid data protection incidents, and in the event of such an incident we act without delay — in accordance with our incident management policy — to minimise the risks and remedy any damage.

11. The rights of data subjects, and remedies

The data subject may request information about the processing of their personal data, and may request the rectification and — with the exception of mandatory processing — the erasure or withdrawal of their personal data; they may exercise their right to data portability and their right to object in the manner indicated at the time the data was collected, or via the contact details of the data controller given above.

The rights and remedies of data subjects are set out below and communicated to data subjects on the basis of Act CXII of 2011 and Regulation (EU) 2016/679.

The right to information, otherwise known as the data subject's "right of access": on the basis of Act CXII of 2011 and Article 15 of Regulation (EU) 2016/679, at the data subject's request the Data Controller provides information about

the data it processes and the categories of personal data,
the purpose of the processing,
the legal basis of the processing,
the duration of the processing,
where applicable, the period for which the data will be stored, or if this is not possible, the criteria used to determine that period,
where applicable, if the data was not collected from the data subject, all available information about its source,
where applicable, automated decision-making, including profiling, and comprehensible information about the logic involved, as well as the significance of such processing and
the likely consequences of such processing for the data subject,
the details of the data processor, if a data processor has been used, i. the circumstances and effects of the data protection incident and the measures taken to remedy it, and furthermore
in the case of a transfer of the data subject's personal data, the legal basis, purpose and recipient of the transfer.

The information is provided free of charge if the requesting party has not yet submitted a request for information to the Data Controller in the current year in respect of the same set of data. In other cases, a cost reimbursement may be charged. Any cost reimbursement already paid must be refunded if the data was processed unlawfully or if the request for information led to rectification.

The Data Controller draws the attention of data subjects to the fact that the provision of information must be refused under Act CXII of 2011,

if, on the basis of a provision of an act, an international treaty or a binding legal act of the European Union, the Data Controller receives personal data in such a way that the transferring data controller indicates, at the same time as the transfer, that the rights of the data subject guaranteed under the said act are restricted, or that the processing is otherwise restricted.
in the interest of the external and internal security of the State, such as national defence, national security, the prevention or prosecution of criminal offences and the security of the enforcement of penalties, and furthermore for state or local government economic or financial reasons, in the significant economic or financial interest of the European Union, as well as for the purpose of preventing and detecting disciplinary and ethical breaches, breaches of labour law and occupational safety obligations related to the practice of professions — in every case including monitoring and supervision — and furthermore in the interest of protecting the rights of the data subject or of others.

The Data Controller is obliged to notify the Hungarian National Authority for Data Protection and Freedom of Information annually, by 31 January of the year following the year in question, of requests for information that were rejected.

The right to rectification: the data subject has the right to obtain from the Data Controller, without undue delay, the rectification of inaccurate personal data concerning them. Taking into account the purpose of the processing, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement. At the same time, if the personal data does not correspond to reality and the personal data corresponding to reality is available to the Data Controller, the Data Controller is obliged to rectify the personal data, even without a request from the data subject.

The right to erasure, otherwise known as the "right to be forgotten": the data subject has the right to obtain from the Data Controller, without undue delay, the erasure of personal data concerning them, and the Data Controller is obliged to erase the personal data relating to the data subject without undue delay, unless mandatory processing precludes this.

In addition to the above case, the Data Controller is obliged to erase the data under 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 is incomplete or incorrect — and this state of affairs cannot lawfully be remedied — provided that erasure is not precluded by law;
the purpose of the processing has ceased, or the statutory time limit for storing the data has expired;
it has been ordered by a court or by the Authority;
the personal data is no longer necessary for the purpose for which it was collected or otherwise processed;
the data subject objects to the processing and there is no overriding lawful ground for the processing;
the personal data must be erased in order to comply with a legal obligation under the law applicable to the Data Controller;
the personal data was collected in relation to the offer of information society services directly to children, as referred to in Article 8(1) of Regulation (EU) 2016/679.

Where the Data Controller has, for some reason, made the personal data public and is obliged to erase it in accordance with the above, it takes the reasonably expected steps — including technical measures — taking account of available technology and the cost of implementation, in order to inform other data controllers processing the data that the data subject has requested the erasure of links to, or copies or replications of, the personal data in question.

The Data Controller draws the attention of data subjects to the limits of the right to erasure or the "right to be forgotten" arising from the EU Regulation, which are as follows:

the exercise of the right to freedom of expression and information;
compliance with an obligation under Union or Member State law applicable to the data controller requiring the processing of personal data, or the performance of a task carried out in the public interest or in the exercise of official authority vested in the data 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 Regulation (EU) 2016/679, where the right to erasure is likely to render impossible or seriously impair the achievement of that processing; or
the establishment, exercise or defence of legal claims.

The right to restriction of processing, otherwise known as the right to blocking: the data subject has the right to obtain from the Data Controller, at their request, restriction of processing.
If, on the basis of the information available, it may be assumed that erasure would harm the legitimate interests of the data subject, the data must be blocked. Personal data blocked in this way may be processed only for as long as the processing purpose that precluded the erasure of the personal data continues to exist.

If the data subject disputes the accuracy or correctness of the personal data, but the incorrectness or inaccuracy of the disputed personal data cannot be unambiguously established, the data is blocked. In this case, the restriction applies for the period that allows the Data Controller to verify the accuracy of the personal data.

Under 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 its use instead;
the Data Controller no longer needs the personal data for the purposes of the processing, but the data subject requires it for the establishment, exercise or defence of legal claims; or
the data subject has objected to the processing; in this case the restriction applies for the period until it is established whether the legitimate grounds of the Data Controller override the legitimate grounds of the data subject.

Where processing is subject to restriction (blocking), such personal data may, with the exception of storage, be processed only 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 on grounds of important public interest of the Union or of a Member State.

The Data Controller hereby expressly 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, such as national defence, national security, the prevention or prosecution of criminal offences and the security of the enforcement of penalties, and furthermore for state or local government economic or financial reasons, in the significant economic or financial interest of the European Union, as well as for the purpose of preventing and detecting disciplinary and ethical breaches, breaches of labour law and occupational safety obligations related to the practice of professions — in every case including monitoring and supervision — and furthermore in the interest of protecting the rights of the data subject or of others.
The Data Controller informs the data subject of the matters set out in their request without undue delay and at the latest within 30 days of receipt of 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, unless there is a ground precluding this.

The Data Controller notifies the data subject in writing of the rectification, the erasure and the restriction of processing, and also notifies all those to whom the data was previously transferred or handed over for the purpose of processing. At the data subject's request, the Data Controller provides information about these recipients. Notification may be omitted if, in view of the purpose of the processing, this does not harm the legitimate interests of the data subject, or if providing the information proves impossible or would require disproportionate effort. The Data Controller is also obliged to notify the data subject in writing if the exercise of the data subject's rights cannot be realised for some reason, and is obliged to state precisely the factual and legal grounds, as well as the remedies available to the data subject: the possibility of turning to the courts and to the Hungarian National Authority for Data Protection and Freedom of Information.

The "right to data portability": the data subject has the right

to receive the personal data concerning them which they have provided to the Data Controller in a structured, commonly used, machine-readable format, and furthermore has the right
to transmit that data to another data controller without hindrance from the data controller to which the personal data was 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 has the right to request that the personal data be transmitted directly between data controllers, where this is technically feasible.
In view of the processing activities carried out by the Data Controller, the conditions for exercising the right to data portability are not met (there is no automated processing), and the data subject is therefore unable to exercise this right.

The right to object: the data subject may object to the processing of their personal data — including profiling — if

the processing (transfer) of the personal data is necessary solely for the enforcement of a right or legitimate interest of the Data Controller or of the recipient of the data, except in the case of mandatory processing;
the personal data is used or transferred for the purposes of direct marketing, opinion polling or scientific research;
the exercise of the right to object is otherwise permitted by law.

The data subject may also object, on the basis of Article 21(3) of Regulation (EU) 2016/679, to the processing of personal data for the purposes of direct marketing; in that case the personal data may no longer be processed for such purposes.

Where personal data is processed for scientific or historical research purposes or statistical purposes, the data subject has the right, on grounds relating to their particular situation, to object to the processing of personal data concerning them, unless the processing is necessary for the performance of a task carried out in the public interest.
The Data Controller — suspending the processing at the same time — examines the objection within the shortest possible time from the submission of the request, but within 30 days at the latest, and informs the applicant of the outcome in writing. If the applicant's objection is well founded, the Data Controller terminates the processing — including further data collection and data transfer — and blocks the data, and notifies of the objection and of the measures taken on its basis all those to whom the personal data affected by the objection was previously transferred and who are obliged to act in order to give effect to the right to object.

If the data subject does not agree with the Data Controller's decision, or if the Data Controller fails to observe the time limit referred to, the data subject is entitled to turn to the courts within 30 days of the communication of the decision.
The data subject has the right to object in connection with automated decision-making.

Enforcement before the courts: in the event of a violation of their rights, the data subject may turn to the courts. The court deals with the case out of turn. The Data Controller bears the burden of proving that the processing complies with the statutory provisions.

In the event of a violation of your right to informational self-determination, you may submit a report or complaint to:

Hungarian National Authority for Data Protection and Freedom of Information
Address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c
Phone: +36 (1) 391-1400, Fax: +36 (1) 391-1410
www: http://www.naih.hu
e-mail: ugyfelszolgalat@naih.hu