Data Processing Information
(Newsletter)
This document contains information by ELSZÖV-Automatika Ltd. (hereinafter: Data controller) concerning the processing of the personal data of the subscribers (hereinafter: Data subject) of newsletters via website www.elszaut.hu (hereinafter: Website) or by link.
Contact information:
Address: 1106 Budapest, Kabai u. 1.
Phone: + 36 (1) 431 98 40
Email: info@elszaut.hu
- The scope of data being processed, the legal basis and duration of data processing
- Case of data processing
Data processing related to newsletters.
Legal basis and purpose of data processing
The legal basis of data processing is the data subject’s free consent as per Article 6 (1) of 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).
The purpose of data processing is to provide newsletters for subscribers, thereby getting information about goods and services of Data controller.
The scope of data being processed
Name, email address
Duration of data processing
Processing of data is carried on until unsubscribing or a request for deletion.
Data processor engaged
Host as data provider:
Your data is subject of forwarding to E.N.S. Informatikai és Rendszerintegrációs Private Ltd. Co. as the operator of Webgalamb ™ newsletter application
- Your rights in connection with data processing
You are entitled to the following rights during the period of data processing:
- access to personal data and information concerning data processing,
- right to rectification,
- right to restrict data processing,
- right to erasure,
- right to object,
- right to data portability.
Exercising your rights requires that your identity be confirmed and that you be contacted by the Data controller. For identification purposes, you may be requested to provide your personal data (however, identification may be based on data that are otherwise being processed by the Data controller), and your complaints concerning the processing of your data will be available at the mail box of the Data controller within the deadline for complaints specified in this Information.
Complaints concerning data processing will be addressed by the Data controller within 30 days at the latest.
The right to withdraw consent
You are entitled to withdraw your consent to data processing at any time, and the data provided will be erased from our systems if the consent is withdrawn.
Access to personal data and information
You are entitled to obtain from the controller confirmation as to whether or not your personal data are being processed, and, if that is the case, you are entitled to:
- access to the personal data being processed and to be informed by the Data controller of the following:
- the purposes of data processing;
- the categories of your personal data being processed;
- the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- your right to request from the controller rectification or erasure of personal data or restriction of processing of personal data of concern to you and, regarding data processing for a legitimate interest, to object to the processing of such personal data;
- the right to submit a complaint to the supervisory authority;
- regarding data that have not been collected from you, all available information concerning the sources;
- the fact of automated decision-making (if such procedure is applied), including profiling, and at least in such cases, intelligible information on the logic involved and on the significance and consequences the data processing may have on you.
The purpose of exercising this right is to determine and check whether or not data processing is lawful, therefore, for multiple requests for information, the Data controller may charge a reasonable reimbursement for providing the requested information.
The Data controller ensures access to personal data by sending you the personal data that are being processed and the information via email after confirming your identity.
Please, indicate in the request whether you request access to personal data or information concerning data processing.
Right to rectification
You are entitled to have the inaccurate personal data of concern to you rectified by the Data controller without delay.
The right to restrict data processing
You are entitled to request the Data controller to restrict data processing if any of the following conditions is met:
- you contest the accuracy of the personal data, then restriction applies to the period which enable the Data controller to verify the accuracy of the personal data;
- the data processing is unlawful, and you oppose the erasure of data and request that the use of such data be restricted instead;
- the Data controller no longer needs the personal data for the purposes of processing, but you require such data for submitting, enforcing or protecting legal claims; or
- you object to the data processing, but data processing may be founded on the Data controller’s legitimate grounds, and in this case data processing must be subject to restriction until it is decided whether the Data controller’s legitimate grounds override your legitimate grounds.
The Data controller will inform you of terminating the restriction in advance (3 working day prior to the terminating at least).
Right to erasure – right to be forgotten
You are entitled to obtain from the Data controller to erase without delay the personal data of concern to you if any of the following grounds apply:
- the personal data are no longer needed in relation to the purpose for which they were collected or proceeded otherwise by the Data controller;
- you withdraw your consent and there is no other legal basis for the data processing;
- you object to the data processing based on legitimate interest and there is no overriding legitimate ground (legitimate interest) for the data processing;
- the Data controller processed the personal data unlawfully and it has been established upon the complaint;
- the personal data are required to be erased for compliance with legal requirements set out in EU law or in the law of the Member State concerned.
If the Data controller has disclosed the personal data of concern to you and is obliged to erase the personal data for any of the aforementioned reasons, the Data controller, taking the available technology and the cost of implementation into account, is obliged to take reasonable steps, including technical measures, to inform other data controllers processing the personal data that the you have requested the erasure of any links to, or copy or replication of, those personal data.
The personal data cannot be erased if the data processing is necessary:
- for exercising the right of freedom of expression and information;
- for compliance with an obligation requiring the processing of personal data under EU law or the law of the Member State concerned applicable to the Data controller, or for performing a task carried out in the public interest or in the exercise of public authority vested in the Data controller;
- for submitting, enforcing and protecting legal claims.
Right to object
You are entitled to object to the processing of personal data of concern to you based on a legitimate interest at any time on grounds relating to your situation. In this case, the Data controller is not allowed to process the personal data of concern to you, unless it demonstrates that data processing is justified by compelling legitimate grounds which override your interests, rights and freedoms or which relate to submitting, enforcing or protecting legal claims.
Right to data portability
If the data processing is carried out by automated means or is based on your free consent, you are entitled to request the Data controller to make the data that you have provided for the Data controller available, and the Data controller must comply with the request using xml, JSON or csv formats. If technically feasible, you may request the Data controller to transmit the data in this format to other data controllers proceeding data.
Legal remedy
If you think that the Data controller has violated a statutory provision concerning data proceeding or failed to comply with any of your requests, you may initiate the investigation procedure of the Hungarian National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság) for the purpose of the termination of the alleged unlawful data processing (postal address: 1530 Budapest, Pf.: 5., e-mail: ugyfelszolgalat@naih.hu).
Be informed that you may bring a civil court action against the Data controller for violating the statutory provisions or for failing to comply with any of your requests.
- Security of data
Authorisation management, and internal organisational and technical solutions are to ensure during the operation of IT systems that unauthorised persons do not obtain your data, unauthorised persons cannot erase your data, save your data from the system or modify your data. The requirements of data protection and security are enforced against our data processors as well.
We keep a register of personal data breaches, and if necessary, you are informed of personal data breaches.
- Other provisions
The Data controller reserves the right to modify this Data Processing Information, without modifying the purpose and legal basis of data processing. By using the website after the modification, you accept the modified Data Processing Information. The Data processor, if wishing to carry out data processing for a purpose other than that indicated as the purpose of collecting those data, is oblige to inform you in advance of the purpose of the data processing and of the following information:
- the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- your right to request from the Data controller access to the personal data of concern to you, the rectification or erasure of such data or the restriction of using such data; and in the case of data processing based on a legitimate interest, you are entitled to object to the processing of personal data, and in the case of data processing based on consent or contractual relationship, you are entitled to request that the right to data portability be ensured;
- you right to withdraw your consent at any time in the case of data processing based on consent;
- the right to submit a complaint to the supervisory authority;
- as to whether providing personal data is based on law or a contractual relationship or is the precondition of concluding a contract, and as to whether you are obliged to provide personal data, and of the possible consequences of failing to provide the data concerned;
- the fact of automated decision-making (if such procedure is applied), including profiling, and at least in such cases, intelligible information on the logic involved and on the significance and consequences the data processing may have on you.
Data processing may be commenced thereafter, and if data processing is consent-based, in addition to the providing information, your consent is required as well.
This Data Processing Information is effective as of 25 May 2018.