Privacy Policy

1. General Principles

• We collect and process personal data only in accordance with applicable laws.
• We disclose personal data to third parties only with consent.
• We never sell the personal data we process to third parties.
• We store the data as securely as possible.
• We send newsletters only to those who have given their prior and explicit consent.
• Data subjects may request access to, correction or deletion of the data stored about them at any time.

2. Details and Contact Information of Our Company (Data Controller, Service Provider)

Name of the data controller: Phoenix Real Estate Corporation Kft.
Contact details of the data controller: 1133 Budapest, Pannónia utca 102.
Phone: +36705316538
E-mail: info@pxrecorp.hu
Web: https://www.pxrecorp.hu
Tax number: 32660892-1-41

The service provider reserves the right to amend this Privacy Policy and will inform data subjects of any such amendments in an appropriate manner. Information concerning data processing is published on the LINK GOES HERE website.

3. Definitions According to the GDPR (Regulation)

3.1. data subject/User:any identified or identifiable natural person who can be identified, directly or indirectly, by reference to personal data;

3.2. personal data: any information relating to an identified or identifiable data subject – in particular the data subject’s name, identification mark, and one or more elements characteristic of their physical, physiological, mental, economic, cultural or social identity – as well as any conclusion that can be drawn from such information concerning the data subject;

3.3. consent: the voluntary and specific expression of the data subject’s wishes, based on adequate information, by which they give unambiguous consent to the processing of personal data concerning them, either in full or for specific processing operations;

3.4.data controller:the natural or legal person or organisation without legal personality which, alone or jointly with others, determines the purposes of data processing, makes and implements decisions concerning data processing (including the means used), or has these decisions implemented by the data processor;

3.5. data processing: any operation or set of operations performed on data, regardless of the procedure used, such as collection, recording, organisation, storage, alteration, use, retrieval, transfer, disclosure, alignment or combination, restriction, erasure and destruction, 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, palm prints, DNA samples, iris images);

3.6.data transfer: making data available to a specified third party;

3.7. disclosure: making data available to anyone;

3.8. data deletion:making data unrecognisable in such a way that it can no longer be restored;

3.9.data processing operations: carrying out technical tasks related to data processing operations, regardless of the method, means or place used to perform them, provided that the technical task is carried out on the data;

3.10. data processor: the natural or legal person or organisation without legal personality which processes data on the basis of a contract, including a contract concluded pursuant to statutory provisions;

3.11. data breach: unlawful processing or processing of personal data, in particular unauthorised access, alteration, transfer, disclosure, deletion or destruction, as well as accidental destruction or damage.

4. Scope of Processed Data, Purpose and Duration of Processing, and Data Processor

Data subjects concerned: All data subjects registered on or purchasing through the webshop website.

We share personal data only with the third party indicated in the “Processor of the Relevant Personal Data” column, for the purpose of fulfilling the obligations set out in the contract.

Details and tasks of data processors used during data processing

Hosting provider
Name: InfoNetfort Kft.
Address: 7900 Szigetvár, Szent István ltp 17. IV/25.
Phone: +36-30/530-2953
E-mail: kapcsolat@netfort.hu
Web: www.netfort.hu
Tax number: 26648082-2-02
Company registration number: 02 09 084205

Accounting services
 

Courier service
 

Direct marketing, newsletter
Name: 
Address: 

4.1 Contact Form:

Data subjects concerned: Persons who contact us by telephone, e-mail or through the contact form.

We do not share personal data with third parties.

5. Newsletter and Direct Marketing Activities

We send newsletters only to Users who have given their prior and explicit consent. Consent is given through the “Newsletter Subscription” form.

Data subjects concerned: All persons subscribed to the newsletter.

Operator of the newsletter delivery system and data processor:
Name: 
Address: 

5.1 Procedure for Withdrawal of Consent (Unsubscribe)
The data subject may unsubscribe from the newsletter at any time and free of charge. Unsubscription may be carried out using the link provided in the newsletters or by e-mail sent to EMAIL ADDRESS GOES HEREby e-mail.

6. Management of Cookies

6.1 What is a cookie?

The Data Controller uses so-called cookies when the website is visited. A cookie is a package of information consisting of letters and numbers that our website sends to the data subject’s browser in order to save certain settings, facilitate the use of our website and help us collect certain relevant statistical information about our visitors. Cookies do not contain personal information and are not suitable for identifying individual users. Cookies often contain a unique identifier – a secret, randomly generated sequence of numbers – which is stored on the data subject’s device.
Some cookies expire when the website is closed, while others are stored on your computer for a longer period.

6.2. Legal Background and Legal Basis for the Use of Cookies

Cookies typically used by online stores include “password-protected session cookies”, “shopping cart cookies” and “security cookies”, the use of which does not require prior consent from data subjects.

Fact of data processing and scope of processed data: Unique identifier, dates and times

Data subjects concerned: All persons visiting the website.

Purpose of data processing: Identifying users and tracking visitors.

Legal basis for data processing: Consent of the data subject in accordance with Section 5 (1) (a) of the Infotv.

6.3 Duration of data processing and deadline for deletion of data: the website uses the following cookies:

• Security cookies: __cfduid, _biz_flagsA, _biz_nA3, _biz_pendingA, _biz_sid, _biz_uid
• Google Analytics cookies: _ga, _gid
• Cookies required for the proper functioning of the website: 

Possible data controllers authorised to access the data: The data controller does not process personal data through the use of cookies.

Information on the data subjects’ rights in relation to data processing: Data subjects can delete cookies in the Tools/Settings menu of their browsers, generally under the Privacy settings.
If a data subject does not accept the use of cookies, certain functions may not be available to them. Further information on deleting cookies can be found at the following links:
    • Internet Explorer: http://windows.microsoft.com/en-us/internet-explorer/delete-managecookies#ie=ie-11
    • Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-yourcomputer
    • Chrome: https://support.google.com/chrome/answer/95647?hl=en
    • Safari: https://support.apple.com/kb/ph21411?locale=en_US

7. Google Analytics

7.1. This website uses Google Analytics, a web analytics service provided by Google Inc. (\"Google\"). Google Analytics uses so-called \"cookies\", text files that are saved on your computer and enable analysis of how the website visited by the User is used.
7.2. Information generated by cookies relating to the website used by the User is generally transferred to and stored on one of Google’s servers in the USA. When IP anonymisation is activated on the website, Google truncates the User’s IP address beforehand within Member States of the European Union or other states party to the Agreement on the European Economic Area.
7.3. The full IP address is transferred to a Google server in the USA and truncated there only in exceptional cases. On behalf of the operator of this website, Google will use this information to evaluate how the User used the website, to prepare reports for the website operator relating to website activity, and to provide other services related to website and internet use.
7.4. Within Google Analytics, Google does not combine the IP address transmitted by the User’s browser with other Google data. The User can prevent cookies from being stored by configuring the browser accordingly; however, please note that in this case not all functions of this website may be fully usable. The User can also prevent Google from collecting and processing data relating to the User’s use of the website through cookies (including the IP address) by downloading and installing the browser plugin available at the following link. https://tools.google.com/dlpage/gaoptout?hl=hu

8. Google AdWords Conversion Tracking and Remarketing

8.1. The data controller uses the online advertising programme called \"Google AdWords\" and, within this framework, uses Google’s conversion tracking service. Google Conversion Tracking is an analytics service of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; \"Google\").
8.2. When the User reaches a website through a Google advertisement, a cookie required for conversion tracking is placed on the User’s computer. These cookies have a limited validity period and do not contain any personal data, so the User cannot be identified through them.
8.3. When the User browses certain pages of the website while the cookie has not yet expired, Google and the data controller can see that the User clicked on the advertisement.
8.4. Each Google AdWords customer receives a different cookie, so the cookies cannot be tracked across the websites of AdWords customers.
8.5. The information obtained through conversion tracking cookies is used to create conversion statistics for customers who have selected AdWords conversion tracking. This allows customers to learn how many users clicked on their advertisement and were redirected to a page containing a conversion tracking tag. However, they do not receive information that could be used to identify any individual user.
8.6. If the User does not wish to participate in conversion tracking, they can opt out by disabling the installation of cookies in their browser. The data subject will then not be included in the conversion tracking statistics.
8.7. Further information and Google’s privacy policy are available at: www.google.de/policies/privacy/

8.8. Google AdWords Remarketing

8.9. Data processing as part of remarketing is carried out using cookies.

Processed Data
Data processed by the cookies specified in the Cookie Policy.
Duration of Data Processing
The data storage period of the respective cookie; further information is available here:
Google general cookie information: https://www.google.com/policies/technologies/types/
Google Analytics information:
https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage?hl=hu
Legal Basis for Data Processing
The data subject’s voluntary consent, given to the service provider through use of the website.

9. Rights of Data Subjects

9.1 Right to Information
Upon the data subject’s request, the Service Provider, as data controller, provides information about the data processed by it or by a processor appointed by it, their source, the purpose of the data processing, its legal basis, its duration, the name and address of the data processor and its activities related to data processing, the circumstances and effects of any data breach and the measures taken to remedy it, and, in the case of data transfer, its legal basis and recipient. The data controller shall provide the information in writing, in an understandable form, as soon as possible after the request is submitted, but no later than 30 days, at the request of the data subject. This information is provided free of charge if the person requesting it has not previously submitted a request concerning the same category of data to the data controller during the current year. In other cases, the Service Provider may charge a fee.

9.2 Right to Rectification
The Service Provider shall rectify personal data if it is inaccurate and accurate personal data is available to it.

9.3 Right to Restriction of Processing
The Service Provider shall restrict the processing of personal data if the data subject requests it or if, based on the available information, it can be assumed that deletion would infringe the data subject’s legitimate interests. Restricted personal data may only be processed for as long as the purpose of processing that prevented deletion continues to exist. The Service Provider shall mark personal data it processes if the data subject disputes its correctness or accuracy, but the incorrectness or inaccuracy of the disputed personal data cannot be clearly established.

9.4 Right to Erasure
The Service Provider shall delete personal data if its processing is unlawful, the data subject requests it, the data processed is incomplete or incorrect – and this situation cannot be lawfully remedied – provided that deletion is not excluded by law, the purpose of processing has ceased, the legally prescribed retention period has expired, or deletion has been ordered by a court or by the National Authority for Data Protection and Freedom of Information.

9.5 Procedural Rules
The data controller has 30 days to delete, restrict or rectify personal data. If the data controller does not fulfil the data subject’s request for rectification, restriction or deletion, it shall communicate the reasons for refusal in writing within 30 days or electronically with the data subject’s consent. The Service Provider shall notify the data subject, as well as all persons to whom the data was previously transferred for processing purposes, of the rectification, restriction, marking or deletion. The notification may be omitted if, in view of the purpose of the processing, it does not infringe the data subject’s legitimate interests.

9.6 Right to Object
The data subject may object to the processing of their personal data if

a] the processing or transfer of personal data is necessary solely for compliance with a legal obligation applicable to the data controller or for the enforcement of the legitimate interest of the data controller, data recipient or a third party, unless the processing is required by law;

b] in other cases specified by law.

The Service Provider shall examine the objection as soon as possible after the request is submitted, but within no more than 15 days, decide on its merits and inform the applicant of its decision in writing. If the data controller determines that the data subject’s objection is justified, it shall terminate the processing, including further data collection and transfer, restrict the data, and notify all persons to whom the personal data concerned by the objection was previously transferred of the objection and the measures taken on its basis, who are obliged to take measures to enforce the right to object.

If the data subject disagrees with the decision of the data controller, they may bring legal proceedings against it within 30 days of notification of the decision.

The Service Provider may not delete the data subject’s data if processing is required by law. However, the data may not be transferred to the recipient if the data controller has agreed with the objection or the court has established that the objection is justified.

9.7 Right to Data Portability
Where data processing is carried out by automated means, or where processing is based on the data subject’s
voluntary consent, the data subject has the right to request from the Data Controller the data provided
by the data subject to the Data Controller, which the Data Controller shall make available to the data subject
in XML, JSON or CSV format, and where technically feasible, the data subject may request
that the Data Controller transfer the data in this form to another data controller.

9.8 Compensation and Damages for Infringement of Personal Rights
The Service Provider shall compensate for damage caused to another person by unlawful processing of the data subject’s data or by breach of data security requirements. In the event of infringement of the data subject’s personality rights, the data subject may claim damages for non-material loss under Section 2:52 of the Civil Code. The data controller is also liable to the data subject for damage caused by the data processor. The data controller shall be exempt from liability if the damage was caused by an unavoidable event outside the scope of the data processing.

The data controller shall not compensate for damage and no damages for non-material loss may be claimed to the extent that the damage or infringement of personality rights was caused by the data subject’s intentional or grossly negligent conduct.

9.9 Right to Bring Court Proceedings
In the event of infringement of their rights, the data subject may bring legal proceedings against the data controller. The court shall deal with the case as a matter of priority.

9.10 Complaints
Complaints may be lodged with the National Authority for Data Protection and Freedom of Information:

Name: National Authority for Data Protection and Freedom of Information
Registered office: 1125 Budapest, Szilágyi Erzsébet fasor 22/C.
Postal address: 1530 Budapest, Pf.: 5.
Phone: +361/391-1400
Fax: +361/391-1410
E-mail: ugyfelszolgalat@naih.hu
Website: http://www.naih.hu

10. Data Security

The service provider designs and carries out data processing operations in a way that ensures the protection of the privacy of data subjects.

The service provider and, within its scope of activity, the data processor ensure data security, take the technical and organisational measures and establish the procedural rules necessary to enforce the Info Act and other data and confidentiality protection rules.

The service provider protects the data through appropriate measures, in particular against unauthorised access, alteration, transfer, disclosure, deletion or destruction, accidental destruction or damage, and becoming inaccessible due to changes in the technology used.

During data processing, the service provider maintains:
    • confidentiality: protecting the information so that only authorised persons can access it
    • integrity: protecting the accuracy and completeness of the information and the processing methods
    • availability: ensuring that when an authorised user needs the information, they can actually access it and the related resources are available.

The IT systems and networks of the service provider and its partners involved in data processing
are protected against computer-assisted fraud, espionage, sabotage, vandalism, fire and flood,
as well as computer viruses, computer intrusions and
attacks resulting in denial of service. The operator ensures security through server-level and application-level protection procedures
and measures.

11. Applicable Laws Used in Preparing the Privacy Policy

    • Act CXII of 2011 on Informational Self-Determination and Freedom of Information (Infotv.)
    • Act V of 2013 on the Civil Code (Civil Code)
    • Act CLV of 1997 on Consumer Protection
    • Act XIX of 1998 on Criminal Proceedings
    • Act CVIII of 2001 on Certain Issues of Electronic Commerce Services and Information Society Services
    • Act C of 2003 on Electronic Communications
    • Act XLVIII of 2008 on the Basic Conditions and Certain Limitations of Economic Advertising Activities
    • Recommendation of the National Authority for Data Protection and Freedom of Information on the data protection requirements for prior information
    • GDPR, Regulation (EU) 2016/679 of the European Parliament and of the Council on the processing and protection of personal data of natural persons and on the free movement of such data

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