Data Protection Policy
This Policy intends to provide the visitors of www.hungarycoupon.com (hereinafter: Website) with clear and detailed information on the manner their personal data are processed and, in particular, on the types of processed data, the legal basis of data processing and their rights and legal remedies related to data processing.
Controller and Website operator:
Mobileum Kereskedelmi és Szolgáltató Kft.
Seat: H-1111 Budapest, Bartók Béla út 44
Phone: +3670 341 5786
Tax number: 12921188-2-43
Trade registry number: 01-09-710081
In the course of Website operation, we agree to comply with the provisions of all applicable data processing and data protection legislation including, in particular, Act CXII of 2011 on information self-determination and freedom of information (“Infotv.”), Act VI of 1998 on the protection of individuals with regard to automatic processing of personal data, Act CIV of 2010 on the freedom of press and the fundamental rules of media content, Act CLXXXV of 2010 on media services and mass media, Act XVIII of 2001 on certain issues of electronic commerce activities and information society services (“Ekertv.”), Act XXXVII of 2007 on value added tax (“Áfatv.”), Act C of 2000 on accounting and Act V of 2013 on the Civil Code as well as the relevant recommendations and resolutions issued by the National Authority for Data Protection and Freedom of Information. Furthermore, we agree to observe and comply with the relevant EU legislation including, in particular, Directive 95/46/EC of the European Parliament and of the Council on the processing of personal data, when such legislation is directly applicable.
Legal basis of data processing
The processing of certain personal data belonging to you (hereinafter: User) will be carried out on the basis of the User’s freely given and informed consent.
By using hungarycoupon.com, the User expressly agrees and consents to the collection and processing of his/her personal data, as specified herein, in accordance with this Policy.
Hungary Coupon will process User data both on the basis of the User’s consent and within the framework of statutory data processing.
As far as statutory data processing is concerned, the legislation allows Hungary Coupon to process certain data of the User for the purpose of providing various services and issuing regular invoices for such services.
Furthermore, Hungary Coupon will also have the right to request the User to give consent for processing such User data that may be processed within the framework of statutory data processing under the relevant legislation. Therefore this is considered primarily as the consent-based processing of such User data. However, the provision of statutory data will be a precondition for using the relevant service.
Furthermore, the User may opt to provide certain data in addition to his/her data subject to statutory data processing so that such additional data may be used by Hungary Coupon for market research and efficiency enhancement. However, the provision of such additional data will not be a precondition for using the relevant service.
The following sections of this Policy contain the breakdown of data as per above as well as the rights and legal remedies available for the consumer.
Scope of personal data and purpose of data processing
Scope of processed data:
1. Scope of data for consent-based data processing:
- User’s phone number
- User’s age
- User’s name
2. Scope of data for statutory data processing:
- User’s name
- User’s address
- Data regarding the time and date of service use
- Data regarding the duration and location of service use
- Personal data deemed technically indispensable for service provision including, in particular, the User's email address
Purpose of data processing in the case of consent-based data processing:
- market research
- service efficiency enhancement
- quality assurance
Purpose of data processing in the case of statutory data processing:
Actions regarding information society service agreements
- content specification
- performance monitoring
- invoicing of contractual fees
- exercise of legal claims
Legal basis of data processing:
1. for consent-based data processing:
- as per Section 5(1)(a) of Infotv.
- User’s consent
2. for compulsory data processing:
- Section 5(1)(b) of Infotv.
- Sections 13/A–13/B of Ekertv.
- Section 169(e) of Áfatv.
3. order of legal basis priorities:
- the User’s consent represents the primary legal basis of data processing
- all data subject to statutory data processing may and must be processed also in lack of consent, and even in the case of consent-based data processing, all data may be processed pursuant to Section 6(5) of Infotv. and in line with this Policy’s section titled Duration of data processing
Mobileum Kft. (the operator of Hungary Coupon) will be the Controller of the personal data.
Duration of data processing:
- The duration of consent-based data processing will be the time until the consent is withdrawn.
- The duration of statutory data processing will be the time specified by the Accounting Act (currently 8 years).
Data processing based on User consent:
Data processing based on User consent qualifies as data processing under Section 6(5) of Infotv. i.e. where personal data is recorded under the consumer’s consent, the Controller will, unless otherwise provided for by law, be able to process the data recorded where this is necessary:
a) for compliance with a legal obligation pertaining to the Controller, or
b) for the purposes of legitimate interests pursued by the Controller or by a third party, if enforcing these interests is considered proportionate to the limitation of the right for the protection of personal data,
without the consumer’s further consent, or after the consumer’s consent has been withdrawn.
The Controller will implement appropriate technical and organisational measures and establish adequate procedural rules to ensure, for the entire duration of data processing, the safety of personal data given or made available by the User.
Right to request the amendment, erasure or blocking of data, right to object, and right to request information or legal remedy
By sending a message to firstname.lastname@example.org, the User may request the Controller to erase, amend or block the User’s personal data. Within 30 days after the receipt of such request, the Controller will take the necessary measures and inform the User about data processing.
By sending a message to email@example.com, the User may object to data processing and request information from the Controller regarding the User’s personal data managed by the Controller.
Upon any infringement regarding the processing of personal data, the User may contact the competent court (if in Budapest, the Metropolitan Court of Budapest) or initiate an investigation at the National Authority for Data Protection and Freedom of Information (president: dr. Attila Péterfalvi, H-1024 Budapest, Szilágyi Erzsébet fasor 22/C, firstname.lastname@example.org, +36-1-3911400, www.naih.hu).
Acting as a web shop handling customer relations, Hungary Coupon will not be subject to statutory registration under Section 65(3)(a) of Infotv.
Cookies and Google Analytics
The Website uses Google Maps (“Google Maps API”), a Google service, to provide more information for the User. When in use, this service may transmit certain data to Google but this transmission concerns only anonymised data.
User means a natural person who uses the service and who is identified, or directly or indirectly identifiable, on the basis of personal data.
Service means the programme or service ordered by the User.
Processor means a natural or legal person or any other entity without legal personality which processes data under an agreement, including any agreement signed pursuant to the applicable legislation.
Consent means any freely given, firm and adequately informed indication of the User’s wish by which he/she, by a clear affirmative action, signifies his/her agreement to the full or partial processing of personal data relating to him/her.
Objection means the User’s statement by which he/she objects to the processing of his/her personal data or requests the erasure of the processed data.