1. What principles do we adhere to in data management? 

Our company adheres to the following principles in data management:

  1. we manage personal data in a legal and fair way, and transparently for you.
  2. we only collect personal data for specific, clearly defined and legal purposes and do not manage them in a way incompatible with such purposes.
  3. from the aspect of data management purposes, the personal data collected and managed by us are proper and relevant, and are only limited to what is necessary.
  4. our company takes all reasonable measures so that the data managed by us should be accurate and up-to-date if needed. We either delete or correct inaccurate personal data without delay.
  5. we store your personal data in a form that you may only be identified for the time necessary to achieve the objectives of personal data management
  6. we ensure the proper security of personal data against any unauthorised or illegal management, or accidental loss, destruction or damage by applying proper technical and organisational measures.

Our company manages your personal data   

  1. that is, collects, records, organises, stores and uses such data exclusively subject to your voluntary consent based on our providing information for you in advance, and only to the necessary extent and according to our purpose in every case.
  2. in some cases, the management of your data is based on legal provisions and is mandatory. In such cases, your attention is separately called to this fact.
  3. in some cases, our Company or a third party has a legitimate interest in the management of your personal data such as the operation, development and security of our webpage.

 2. Who are we?

Our Company seat is at 8000 Székesfehérvár Palánkai út 5.

Our Company premises are at 8000 Székesfehérvár Palánkai út 5.

Our company webpage is: www.seawing.hu

Contact details:

Mailing address: 8000 Székesfehérvár Palánkai út 5.

Telephone number: (+36) 22 510 170

E-mail address: sales.seawing@assaabloy.com

VAT No.: 07-09-001285

Registration No.: 10271731-2-07

Pursuant to Article 37 of the GDPR, our Company is under no obligation to appoint a data protection official. Our company has a data protection official whose contact details (e-mail address) are: Balázs Bachstetter (Balazs.Bachstetter@assaabloy.com)

Details of our chamber membership: Fejér County Chamber of Industry: FE10271731, Chamber of Bodyguards, Property Protection and Private Detectives: 0701/T/01609/2006

The authority licensing our Company’s activities and No. of license (if it is necessary to conduct activities pursuant to law): Fejér County Police Headquarters, Assembly and planning of property protection systems, 07010-822/208-48/2006

Name, address and contact details of our Company’s hosting service provider: NeoSoft Informatikai Szolgáltató Kft (’NeoSoft IT Services Ltd Co’), 8000 Székesfehérvár, Távírda utca 2/A

In data management, our company uses the following data processors in order to provide quality services for our customers:

 

 

NAME

 

ADDRESS

 

ACTIVITY

NeoSoft Informatikai Szolgáltató Kft.

8000 Székesfehérvár, Távírda utca 2/A

hosting services

 

Data processors related to our newsletter service:

 

 

NAME

 

ADDRESS

 

ACTIVITY

NeoSoft Informatikai Szolgáltató Kft.

8000 Székesfehérvár, Távírda utca 2/A

database maintenance and processing, preparation of reports

 

Should we make a change in our data processors, such changes will be reflected in this information leaflet.

Data that we manage: 

Name of activity and purpose of data management

Legal base

Data managed

Term

Visiting webpage

The purpose is to ensure the proper and quality operation of webpage,

to control and improve the quality of our services,

to identify any malicious visitors, attacking our webpage,

to measure the number of visits,

statistical purposes

Our company’s legitimate interest

IP addreess

time of visit

data of any subpages visited,

type of operation system and browser used by you

24 months

Registration on the webpage

The purpose is to achieve customer experience and provide product support

contribution

first and family names

e-mail address

until the deletion of registration or the withdrawal of consent

Newsletter service

Objective: keeping contact,

You are notified of new promotions and products

contribution

full name,

e-mail address

until unsubscribing for newsletter

 

We only ask the visitors of our webpage for their personal data if they want to register or log in.

We are not allowed to link any personal data made available to us during registration or the use of our marketing services, and basically, it is not our purpose to identify our visitors. 

You may request further information concerning your questions about data management by e-mail sales.seawing@assaabloy.com or mail. We will send you our answer without delay to the contact address provided by you.

 3. What are cookies and how do we handle them?

 

Cookies are small size data files (hereinafter referred to as cookies) which find their way to your computer via the webpage through the use of such webpage in a way that they are saved and stored by your internet browser. The majority of the most frequently used browsers (Chrome, Firefox, etc.) accept and allow the downloading and use of cookies as a default setting, however, it depends on you whether you refuse or block them by changing you browser settings, and you can also delete any cookies already stored in your computer. Further information on the use of cookies can be found in the Help menu item of the relevant browser.    

There are cookies which do not require your prior consent. Our webpage provides you with brief information about them at the start of your first visit. Such are authentication, multimedia player and load levelling cookies, session cookies helping with the customisation of the user platform and user-centred security cookies.

Provided that data management already starts upon your visiting the webpage, our Company informs you about any cookies requiring consent at the start of your first visit, and your consent is requested.

Our company does not apply or allow such cookies with the help of which any third parties may collect data without your consent.

It is not obligatory to accept cookies but our Company assumes no liability if our webpage does not operate as expected due to the lack of your permitting the use of cookies.   

 

What kind of cookies do we apply?

 

Type

Name

Contribution

Description

Purpose

Validity

system cookies

PHPSESSID

not required

for storing language settings

to ensure the operation of webpage

end of browser session

Google Analytics statistical cookies  

 (originating from third parties)

__utm.gif

 

 

not required

Tracking code of Google Analytics, which logs the data of visitor’s browser and computer

during visit to webpage, it is connected to third party Google services

end of browser

session

__utma

not required

This cookie serves to distinguish visitors and sessions. This cookie is generated every time when javascript application is already running but a _utma cookie has not been generated yet. This cookie is refreshed on every occasion when data are sent to Google Analytics.

24 months

__utmb

not required

This cookie serves to recognise new users/visits. This cookie is generated every time when javascript application is already running but _utmb cookie has not been generated yet. This cookie is refreshed on every occasion when data are sent to Google Analytics.

end of browser session

__utmc

not required

This cookie operates together with _utmb cookie, and provides data Google Analytics. Its task is to detect any new user visits.

end of browser session

__utmt

not required

         It limits the data collection of webpages with heavy traffic. It is a cookie related to Google Analytics service.

end of browser session

__utmz

not required

This cookie stores the source of every traffic or campaign, with the help of which it can be determined how the user has found the webpage.  This cookie is generated on every occasion when javascript application is already running and forwards any uploaded data to Google Analytics service.

6 months

 

Further details on third party cookies can be found at https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage and on data protection at https://www.google.com/analytics/learn/privacy.html?hl=hu.

 4.What else is there to know about data management related to our webpage?

 

You make your personal data available to us voluntarily during registration and keeping contact with our Company. Therefore, we request you to take extra care to make sure that the data you disclose are true, correct and accurate as you are responsible for them. Any incorrect, inaccurate or incomplete data may be an obstacle to the use of our services.

If you do not provide your own but another person’s personal data, we assume that you possess the necessary authorisation to do so.

You may withdraw your consent to data management free at any time

  • by initiating the deletion of registration,
  • by withdrawing your consent to data management, or
  • by withdrawing your consent to the management or use of any data to be mandatorily filled during registration or requesting the blocking thereof.

For technical reasons, we undertake to register any withdrawals of consent with a 30-day deadline. However, please, be advised that we may manage some data for the purpose of fulfilling our legal obligation or enforcing our legitimate interests even after such withdrawal.

In case of the use of any misleading personal data or if any of our visitors commits a criminal offence or attacks our Company system, we will delete such visitor’s data without delay upon the cancellation of his/her registration, and, if needed, we preserve them for the period civil law liability is determined or criminal law proceedings are conducted.

 5. What is there to know about our data management for newsletter purposes?

 

With your statement made during registration, or later, by changing your personal data stored in the newsletter database (that is, with the unambiguous declaration of your intent), you may give your consent to it that we can also use your personal data for marketing purposes. In such a case, we will also manage you data for the purpose of sending newsletters until your withdrawal of consent and we will forward newsletters to you (Art. 6, Act on the basic conditions and some restrictions on business advertising activities).   

 

With regard to the newsletters, you may both give your consent and withdraw it free and at any time.

Deletion of registration is regarded as the withdrawal of consent in every case. The withdrawal of consent to data management for newsletter purposes is not interpreted to be the withdrawal of consent to data management related to the newsletter at the same time. How is it? what do we preserve and on what grounds if you have withdrawn your consent with respect to the newsletter? In case of consents, every consent is given for a particular purpose so registration on the website and subscribing for the newsletter are two separate purposes and two separate databases, which cannot be connected. 

For technical reasons, we undertake to register the withdrawal or cancellation of consent with a 30-day deadline.

 6. Other data management issues

 

We can only forward your data pursuant to law, and in the case of our data processors, we ensure with contractual terms that they should not use your personal data for purposes contrary to your consent. For further information, see section 2.

Our company does not forward any data abroad.

Courts, public prosecutors’ offices and other authorities (e.g. the police, the tax administration, the Hungarian National Authority for Data Protection and Freedom of information) may contact our Company to request information, the disclosure of data or the provision of documents. In such cases, we must fulfil our data provision obligation but only to the extent essentially necessary for the achievement of the purpose of such request.

Any contributors and employees involved in our Company’s data management and/or data processing have the right to get to know your personal data to an extent preliminarily determined and under the obligation of confidentiality.  

We protect your personal data with appropriate technical and other measures, ensure the security and availability of such data, and protect them from any unauthorised access, modification, damage, disclosure or any other unauthorised use.  

In the framework of our organisational measures, in our buildings, we check physical access, we continuously train our employees and keep any paper-based documents locked under proper protection. Technical measures include encryption, password protection and virus protection softwares. Please, note, however, that no data transmission on the internet can be regarded completely safe data transmission. Our Company makes every reasonable effort to make processes as safe as possible, however, we cannot assume full liability for any data transmission through our webpage although we comply with strict regulations with regard to any data received by our Company for the security of your data and for the prevention of any unauthorised access.

With regard to any security issues, we request your help: please, preserve your password providing access to our webpage carefully, and do not share this password with anybody.

 7. What rights and legal remedies do you have?

 

You may

  • request information about data management,
  • request the correction, modification and supplementing of your personal data managed by us,
  • protest against data management and request the deletion or blocking of your data (with the exception of mandatory data management),
  • seek legal remedy at court, or
  • submit a complaint or initiate proceedings with the supervising authority (https://naih.hu/panaszuegyintezes-rendje.html).

Supervising authority: Hungarian National Authority for Data Protection and Freedom of Information

  • Seat: 1125 Budapest, Szilágyi Erzsébet fasor 22/c.
  • Mailing address: 1530 Budapest, Pf. 5.
  • Telephone: +36 (1) 391-1400
  • Fax: +36 (1) 391-1410
  • E-mail:ugyfelszolgalat@naih.hu
    Webpage: https://naih.hu/

Upon your request, we provide information about

  • your data managed or processed by us or processed by our appointed data processor,
  • the source thereof,
  • the purpose and legal base of such data management,
  • the term thereof, or if it is not possible, the criteria involved in the determination of such term,
  • the name, address and activities of our data processors related to data management,
  • the circumstances and effects of and our measures to avoid or prevent any data protection incidents, and
  • the legal base and addressee of data transmission in the case your personal data are transmitted.

We provide information as soon as possible, within 30 days upon the submission of request. Information provision is free except if you have already submitted a request for information concerning the same range of data in current year. The charge paid by you will be reimbursed if we have managed the data illegally or the request for information has led to correction. We may only refuse to provide information referring to the relevant legal provision and providing information about the possibility of seeking legal remedy at court or contacting the authorities.  

Our Company informs you and all those parties of any correction, blocking, marking or deletion of personal data to whom it earlier forwarded such data for the purpose of data management except if lack of such notification does not violate your legitimate interests.

If we do not fulfil your request for correction, blocking or deletion, we will give you the reasons for our refusal in writing or – subject to your consent – in electronic form within 30 days, and inform you about the possibility of seeking legal remedy and contacting the Authority.

If you protest against the management of your personal data, we will investigate such protest as soon as possible, within 30 days, and will inform you of our decision in writing. If we decide that your protest is well-founded, in such a case, we will stop data management, including any further data recording or forwarding, will block data and will inform of such protest and any measures based on it all those to whom we earlier forwarded the personal data affected by such protest, and who shall make arrangements to enforce the right of protest.

We refuse to fulfil request in such a case if we prove that data management is justified by compelling legitimate reasons which are to be given priority over your interests, rights and freedoms or which are linked to the submission, enforcement or protection of any legal claims. If you do not agree with our decision, or if we miss the deadline, you may initiate legal proceedings at court within 30 days upon the communication of decision or the last day of deadline.

It is the competence of the tribunal to pass a judgement in data protection lawsuits. Such a lawsuit may be started both at the tribunal according to the place of living or place of residence of the party concerned. Foreign citizens may also submit their complaints to the supervising authority according to their place of living.

We request you to contact our Company for negotiations and the quickest possible solution to the problem that has arisen prior to contacting the supervising authority or the court. 

 8. Which are the most important legal statutes governing our activity?

 

  • Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR) on the protection of natural persons with regard to the processing of personal data and the free movement of such data
  • Act No. CXII of 2011 on the right of informational self-determination and the freedom of information
  • Act No. V of 2013 on the Civil Code
  • Act No. CVIII of 2001 on some issues of electronic commercial services and services related to information society
  • Act No. C of 2003 on electronic communication
  • Act No. CLV of 1997 on customer protection
  • Act No. CLXV of 2013 on making complaints and reporting issues of public interest
  • Act No. XLVIII of 2008 on the basic conditions and some restrictions on business advertising activities

 9. Amendment of information sheet on data management

 

Our Company reserves the right to amend this Information sheet on data management, of which it will provide information to any parties concerned in an appropriate way. Any information concerning data management will be published on webpage www.seawing.hu/adatkezeles.

 

Dated Székesfehérvár, 25 May, 2018