IAMART Kft. (registered seat: 1063 Budapest, Szív utca 69. 3/1.; company registration number: 01-09-735166) as data controller (“Data Controller” or “Company”) respects the privacy rights of its clients and users (“Data Subject”) in the course of its retail and wholesale activities relating to the products available on the www.iamart.hu website, in particular, the privacy rights determined by Regulation (EU) 2016/679 of the European Parliament and the Council (“GDPR”), and Act CXII of 2011 on the right to information self-determination and freedom of information (“Info Act”), and shall in all cases apply and be bound by this document in the performance of its activities.

The terms used in this notice shall have the meaning specified in GDPR and the Info Act:

• „personal data” any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
• „data processing” any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
• „data controller” the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data within the framework determined by the binding act of the European Union, takes and implements the decisions concerning the processing (including the instrument used) or has a processor implement them.
• „consent of the data subject” means any freely given, specific, informed and unambiguous indication of the data subjects wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

1. PRINCIPLES OF DATA PROCESSING

1.1. The Company pays particular attention to the below detailed principles in all of its data processing activities.br> 1.2. Personal data shall be

1. processed lawfully, fairly and in a transparent manner in relation to the Data Subject (“lawfulness, fairness and transparency”);
2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (“purpose limitation”); further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (“data minimisation”); ;
4. 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 (“accuracy”);
5. 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 or statistical purposes (“storage limitation”);
6. 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 (“integrity and confidentiality”).
7. The Data Controller shall be responsible for, and be able to demonstrate compliance with the principles of data processing (“accountability”).

2. DATA CONTROLLER

The Company carries out data processing independently, and does not carry out joint processing.

Data Controller’s data
Name: IAMART Kft.
Registered seat: 1063 Budapest, Szív utca 69. 3. em. 1. ajtó
Company registration number: 01-09-735166
Data protection officer: Csaba Fehérdi
Email: info@iamart.hu

3. SCOPE OF DATA PROCESSED BY THE DATA PROCESSOR, PURPOSE AND LEGAL BASIS

3.1 The Data Controller shall process the personal data provided or made available by the Data Subjects in any way (including on documents submitted by the Data Subject to the Data Controller and in any other form) in accordance with the legal regulations relating to trade secret and data protection and only for the purposes and on the legal basis set out below:

1. Data of potential customers visiting the Company’s website with the intention to conclude a contract (name, name of the legal entity’s contact person, delivery address, phone number/phone number of the legal entity’s contact person, e-mail address/e-mail address of the legal entity’s contact person, invoicing name, invoicing address) for the purposes of performing the contract concluded with the Company, liaising with the Data Subjects (including when contacting to request a quote, register an event and purchase services and products on the Companys website), recovering the cost of services, and fulfilling legal obligations, pursuant to Article 6(1)(a), (b) and (c) of the GDPR and Section 13/A of Act CVIII of 2001 on certain aspects of electronic commerce services and information society services
2. Visitors subscribing to the Company’s newsletter (name, name of the legal entity’s contact person, delivery address, phone number/phone number of the legal entity’s contact person, e-mail address/e-mail address of the legal entity’s contact person, invoicing name, invoicing address) for the purposes of delivering the Company’s newsletter at recurring intervals (but until the Data Subject unsubscribes from the service at the latest) to the Data Subjects, pursuant to Article 6(1)(a), (b) and (c) of the GDPR and Section 13/A of Act CVIII of 2001 on certain aspects of electronic commerce services and information society services

3.2 Personal data may be processed by law, or with the consent of the Data Subject. In accordance with the above, by starting to use the service on the website, the Data Subject gives expressed consent to the use and processing of his or her personal data for the purposes set out in paragraph “purpose of data processing” above; and to the storage of the data by the Company in accordance with the conditions specified in this Notice; furthermore if expressly requested by the Data Subject, to sending newsletter, SMS by the Company directly to the Data Subject’s e-mail address, phone number.

3.3 If the Data Subject has given his or her consent to receiving newsletter to his or her e-mail address from the Company, the Data Subject may withdraw his or her consent at any time, free of charge, without any limitation and without giving any reason, by using the "unsubscribe" button at the bottom of the newsletter, by sending an e-mail to the customer service e-mail address info@iamart.hu or by sending a declaration to the Company by post to the Company’s headquarters.

3.4 The Company shall not collect any personal data from the Website without the authorisation by the Data Subject. The Company usually collects and processes anonymous data in order to improve, correct the content of the site. During such activity, the Company may incorporate so-called “cookies” which collect the first level domain name of the Data Subject and the date and time of access. “Cookies” alone cannot be used to identify a visitor.

3.5 The Data Controller does not process any sensitive personal data.

3.6 The Data Controller further informs the Data Subject that the Data Controller does not carry out automated decision-making (including profiling) with respect to data processed by it.

4. PERIOD OF DATA PROCESSING

4.1 The Data Controller processes the personal data until the purpose has been fulfilled. The period of processing the Data Subjects’ personal data is the same as the limitation period of the legal relationship with the Data Subjects, which is 5 years (except where longer limitation periods are set out by law, for example in case of damages caused by criminal offence).

4.2 Certain legal regulation may prescribe the obligation to process personal data for a longer period, for example, to comply with accounting or tax obligations, to confirm the verifiability of such obligations, or to check the lawfulness of a public procurement procedure. In such a case, the retention period relating to the personal data concerned shall correspond to the period set out by law.

4.3 The Data Controller shall at all time immediately erase the personal data of the Data Subjects, if the purpose of the data processing is fulfilled or the period for data processing has elapsed.

5. METHOD OF DATA PROCESSING

The Data Controller processes the personal data by the retention and storage of documents on paper and/or electronically. The Data Controller may make copies of the personal data only in justified cases, and shall ensure the same level of protection of personal data in this case as well.

6. PROCESSING OF DATA BY PROCESSORS

6.1 The Company shall not, in any way, provide the personal data received to any third party without the prior consent of the Data Subject, except to the extent necessary to fulfil the purposes of the processing, to a carrier or courier, with the exception of cases where the Company is obliged to transfer the data by law.

6.2 For the purpose of performing the Service, the Company provides the carrier or courier with the name, delivery address, e-mail address of the Data Subject (if necessary for delivery).

6.3 The Company may use the services of a data processor to process the personal data. The data processor shall comply with the provisions of this Notice, the legal regulations currently in force and the contract regulating its legal relationship with the Company.

6.4 Save for data transfers required by law, the personal data processed by the Company shall not be subject to data transfer.

7. DATA TRANSFER

7.1 The Data Controller shall be obliged to provide data to the courts, the prosecutor, the police, the administrative authority, the investigation authority or other bodies based on the law for information, data or document supply purposes. In this context, the data supply shall be limited to the extent necessary for the requesting authority to fulfil its purpose, if the authority has indicated the exact scope of data and the exact purpose. For the lawfulness of such data supply and any possible consequences, the authority entitled to request data shall be liable.

7.2 The Data Controller shall keep a record of data transfers carried out by it, the contents of which the Data Subject may request information, unless the possibility of providing such information is excluded by law.

8. THE DATA SUBJECT’S RIGHTS

8.1 The Data Subject may exercise the rights set out in Clause 9 of this Notice by sending a request to any of the contact details set out in Clause 2 of this Notice.

8.2 Right to transparent information and communication

The Data Controller shall take appropriate measures to provide the Data Subject with information relating to data processing in a concise, transparent, intelligible and easily accessible form, using clear and plain language, in writing.

8.3 Right to information and access to personal data

The Data Controller shall, at the time when personal data are obtained, provide the Data Subject with all of the following information:

• the identity and the contact details of the Data Controller and its representative,
• the purposes of intended data processing and the legal basis for data processing,
• the identity of the person or organisation affected by data transfer,
• the period for which the personal data will be stored,
• the right of the Data Subject to request from the Data Controller access to and rectification or erasure of personal data or restriction of processing concerning the Data Subject or to object to processing,
• the right of the Data Subject to data portability,
• the right to lodge a complaint with a supervisory authority,
• the right to withdraw the consent at any time,
• the fact whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the Data Subject is obliged to provide the personal data and of the possible consequences of failure to provide such data.

8.4 Right of access by the Data Subject

The Data Subject shall have the right to obtain from the Data Controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information.

8.5 Right to rectification

The Data Subject shall have the right to obtain from the Data Controller without undue delay the rectification of inaccurate personal data concerning him or her.

8.6 Right to erasure, “right to be forgotten”

The Data Subject shall have the right to obtain from the Data Controller the erasure of personal data concerning him or her without undue delay where any of the following grounds applies:

• the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed,
• the Data Subject withdraws consent on which the processing is based where there is no other legal ground for the processing,
• the Data Subject objects to the processing and there are no overriding legitimate grounds for the processing,
• the personal data have been unlawfully processed,
• the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the Data Controller is subject,
• the personal data have been collected in relation to the offer of information society services.
  
  

The Data Controller informs the Data Subjects that it shall not be obliged to fulfil a request for exercising the right to erasure or right to be forgotten to the extent that processing is necessary:

• for exercising the right of freedom of expression and information,
• for compliance with a legal obligation which requires processing or the performance of a task in the exercise of official authority,
• for reasons of public interest in the area of public health,
• for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes,
• for the establishment, exercise or defence of legal claims.
  
  

8.7 Right to restriction of processing

The Data Subject shall have the right to obtain from the Data Controller restriction of processing where any of the following applies:

• the accuracy of the personal data is contested by the Data Subject, for a period enabling the Data Controller to verify the accuracy of the personal data,
• the processing is unlawful and the Data Subject opposes the erasure of the personal data and requests the restriction of their use instead,
• the Data 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,
• the Data Subject has objected to processing pending the verification whether the legitimate grounds of the Data Controller override those of the Data Subject.

8.8 Right to data portability

The Data Subject shall have the right to receive the personal data concerning him or her, which he or she has provided to the Data Controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another Data Controller without hindrance from the Data 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 his or her right to data portability, the Data Subject shall have the right to have the personal data transmitted directly from one data controller to another, where technically feasible.

8.9 Right to object

The Data Subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her including profiling. In this case, the Data Controller shall no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the Data Subject or for the establishment, exercise or defence of legal claims.

8.10 Automated individual decision-making, including profiling

The Data Controller informs the Data Subject that it does not apply automated decision-making (including profiling). If the Data Controller eventually intends to apply such data processing, then the Data Subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, provided that there is no other ground for data processing.

9. RESTRICTIONS

Union or Member State law to which the Data Controller is subject may restrict the rights set out in Clause 8, when such a restriction respects the essence of the fundamental rights and freedoms and is a necessary and proportionate measure to safeguard:

• national security,
• defence,
• public security,
• the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including the safeguarding against and the prevention of threats to public security,
• other important objectives of general public interest of the Union or of a Member State, in particular an important economic or financial interest of the Union or of a Member State, including monetary, budgetary and taxation a matters, public health and social security,
• the protection of judicial independence and judicial proceedings,
• the prevention, investigation, detection and prosecution of breaches of ethics for regulated professions,
• a monitoring, inspection or regulatory function connected, even occasionally, to the exercise of official authority,
• the protection of the Data Subject or the rights and freedoms of others,
• the enforcement of civil law claims.

10. REMEDIES

10.1 In the case of an event resulting in 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 (hereinafter: “personal data breach”), the Data Controller undertakes to, without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the National Authority for Data Protection and Freedom of Information (address: 1055 Budapest, Falk Miksa u. 9-11.; phone: +36 (30) 683-5969; e-mail: ugyfelszolgalat@naih.hu; homepage: www.naih.hu) as competent authority. An exception from the notification obligation is where the personal data breach is unlikely to pose a risk to the rights and freedoms of natural persons.

10.2 If the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, the Data Controller shall communicate the personal data breach to the Data Subject without undue delay, describing in clear and plain language the nature of the personal data breach.

10.3 The Data Controller informs the Data Subject that in the case of an infringement of his or her data protection rights, the Data Subject may make a complaint to the National Authority for Data Protection and Freedom of Information (address: 1055 Budapest, Falk Miksa u. 9-11.; phone: +36 (30) 683-5969; e-mail: ugyfelszolgalat@naih.hu; homepage: www.naih.hu), and may also initiate legal proceedings before the court. The legal action may also be initiated before the competent court having jurisdiction based on the residence or domicile of the Data Subject.

10.4 If the Data Controller causes damages to another person by the unlawful processing of personal data or the infringement of data security requirements, it shall be liable to compensate such damages, and if such conduct infringes the Data Subjects right to privacy, the Data Subject may claim damage fees. The Data Controller shall be exempted from liability for damages caused or the payment of damage fees, if it can prove that the personal data breach of the Data Subject was caused by an unforeseeable event outside the scope of data processing.

11. DATA SECURITY

The Data Controller shall implement appropriate technical and organisation measures in order to ensure the level of data security corresponding to the risk level, taking into account the state of the art and the nature, scope, circumstances and purposes of data processing, as well as the risk of variable probability and severity it presents to the rights and freedom of natural persons, including:

• the continued confidentiality, integrity, availability and resilience of the systems and services used to process personal data,
• in the case of a physical or technical breach, the ability to restore access to data and the availability of data in due time,
• process for regular testing, evaluation and assessment of the efficiency of the technical and organisational measures implemented to ensure the security of data processing.

The provisions of this Privacy Notice and ensuring and facilitating the implementation thereof are the obligations of all employees of the Company and all persons who process the personal data of the Data Subjects in the course of their activities.

Budapest, May 31, 2024

IAMART Kft.