This is an English translation for information. The Hungarian version (webraketa.hu/adatvedelmi-tajekoztato/) is authoritative: in case of any discrepancy, the Hungarian version prevails.
Privacy Notice
This notice consists of two parts. The first part applies to website visitors: what happens to your data if you fill in a form, subscribe to our newsletter, or simply browse the site. The second part is the previously published privacy notice for our customers, with unchanged content.
The data controller
- Company name: Webrakéta Korlátolt Felelősségű Társaság (Webrakéta Kft.)
- Registered office: 1111 Budapest, Lágymányosi utca 12. fszt. 2.
- Company registration number: 01-09-987579
- Tax number: 23980790-2-43
- Managing director: Ernő Kiss
- Email: info@webraketa.hu
- Website: www.webraketa.hu
Part One: data processing related to website visitors
1. Requesting a quote, contact, and price calculator
What data we process: your name, email address, and, if you provide it, your phone number, as well as the information you provide about the planned project (for example, the type and scope of the website, desired functions, deadline, and the address of the current website).
Why: so that we can respond to your inquiry and provide you with a personalized quote.
On what legal basis: steps taken at your request before entering into a contract, based on Article 6(1)(b) of Regulation (EU) 2016/679 (GDPR).
For how long: for 2 years from the closure of the inquiry, so that you do not have to provide everything again in the event of a later inquiry. If a contract is concluded, retention is governed by the rules applicable to the contractual relationship. You may request the deletion of your data at any time.
2. Newsletter and downloadable materials
What data we process: your name and email address, and when and through which form you subscribed.
Why: to send you the requested material and to send you professional content and newsletters.
On what legal basis: your consent, based on Article 6(1)(a) of Regulation (EU) 2016/679 (GDPR).
For how long: until you withdraw your consent. Withdrawal can be done at any time, without giving a reason, with one click using the unsubscribe link at the bottom of each of our emails, or by writing to info@webraketa.hu. Unsubscribing does not affect the lawfulness of data processing carried out before the withdrawal.
Data processor: we send newsletters through the system of UAB MailerLite (Paupio g. 46, 11341 Vilnius, Lithuania).
3. Measuring website usage
What data we process: technical data about your visit, for example the shortened form of your IP address, the type of your browser and device, the pages opened, the time of the visit, and where you arrived from. We do not use these to identify you personally.
Why: so that we can see which content is useful, where using the site is difficult, and whether an advertisement produced results.
On what legal basis: your consent, which you provide in the cookie banner. These measurements do not start without your consent. You may withdraw your consent at any time in the cookie settings at the bottom of the website.
Who the involved service providers are:
- Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland): Google Analytics traffic measurement, Google Ads advertising measurement, embedding YouTube videos.
- Microsoft Ireland Operations Limited (One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland): Microsoft Clarity, analysis of website usability.
- Meta Platforms Ireland Limited (Merrion Road, Dublin 4, Ireland): Facebook Pixel, advertising measurement and ad targeting.
- CookieYes Limited (United Kingdom): managing and storing cookie consent.
You can read detailed information about the cookies they place, their lifespan, and how to disable them in the Cookie Notice.
4. Data transfer outside the European Union
Some of the above service providers may also process the data they receive in the United States. The lawfulness of the data transfer is ensured by the European Commission’s adequacy decision or by the standard contractual clauses adopted by the European Commission. If you do not consent to statistical and advertising cookies, no such data transfer takes place.
5. Your rights
You have the following rights in relation to your data. You can exercise them by writing to info@webraketa.hu, and we will respond to your request within one month at the latest.
- Right to information and access: you may ask whether we process data about you, and if so, what data.
- Right to rectification: you may request the correction of inaccurate data.
- Right to erasure: you may request the deletion of your data if the conditions for this are met.
- Right to restriction of processing.
- Right to data portability: you may request that you receive the data you provided in a machine-readable format.
- Right to object to processing based on legitimate interests.
- Right to withdraw consent at any time, with effect for the future.
6. Legal remedies
If you feel that a violation of law has occurred during the processing of your data, you may submit a complaint to us at info@webraketa.hu. In addition, you have the following options:
- Hungarian National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság, NAIH)
Address: 1055 Budapest, Falk Miksa utca 9-11.
Mailing address: 1363 Budapest, P.O. Box 9
Phone: +36 1 391 1400
Email: ugyfelszolgalat@naih.hu
Website: naih.hu - Court: you may also bring proceedings before the regional court competent for your place of residence or temporary residence.
7. Modification of this notice
We reserve the right to modify this notice if the operation of the website or the legal environment changes. The current effective text is available on this page, with the date indicated at the top of the page.
Part Two: privacy notice for customers
The notice below applies to the customers of Webrakéta Kft. and has been effective from May 25, 2018. We publish its text with unchanged content.
Data Controller: WEBRAKÉTA KFT.
Website: www.webraketa.hu
Scope of Data Subjects: Customers
Effective from: May 25, 2018
Webrakéta Kft., as Data Controller, informs the Customers of www.webraketa.hu, as Data Subjects…
I.
…about the declaration of consent of the Customer, as Data Subject:
- Webrakéta Kft., as Data Controller, informs the Customers, as Data Subjects, that Appendix No. 1 to this Privacy Notice is the Customer’s Declaration of Consent, by signing it and returning it to Webrakéta Kft., as Data Controller, the Customer, as Data Subject, gives voluntary, specific, properly informed and unambiguous consent, as explained below, to the processing of their personal data specified in Sections III.4. and III.5. of this Privacy Notice, acknowledging the contents of Sections III.1 to III.2 of this Privacy Notice, including that the provision of personal data is:
- in the case of the personal data specified in Section 4: a condition for providing the callback,
- in the case of the personal data specified in Section 5: a prerequisite for concluding the contract, a condition for maintaining the contractual relationship, and thereby a condition for providing the service,
- Webrakéta Kft., as Data Controller, informs the Customers, as Data Subjects, that this Customer’s Declaration of Consent does not extend to acceptance of the Cookie Notice, regarding which the Customers, as Data Subjects, are entitled to make their statements separately.
- Webrakéta Kft., as Data Controller, informs the Customers, as Data Subjects, that the Customer’s signing of the Declaration of Consent is not a condition for the processing of the Customer’s personal data as a Data Subject, considering that the Customer’s consent as a Data Subject is only one of the legal bases for processing the Customer’s personal data as a Data Subject.
II.
…about the Data Controller’s data:
- Company name: Webrakéta Korlátolt Felelősségű Társaság
- Abbreviated company name: Webrakéta Kft.
- Registered office: 1111 Budapest, Lágymányosi utca 12. fszt. 2.
- Company registration number: 01-09-987579
- Tax number: 23980790-2-43
- Statistical number: 23980790-5829-113-01
- Bank account number: 10300002-10571886-49020010 (MKB Bank Zrt.)
- Managing director: Ernő Kiss
- Electronic contact: info@webraketa.hu
III.
…about the scope of personal data processed by Webrakéta Kft., the purpose of data processing, the legal basis for data processing, the duration of data processing:
- Webrakéta Kft., as Data Controller, informs the Customers, as Data Subjects, that the provision of the data specified in Section 4 of this Privacy Notice is a condition for providing the callback. The Customer, as Data Subject, is required to provide these personal data, because the consequence of failing to provide the data is that without these personal data Webrakéta Kft., as Data Controller, cannot provide the callback to the Customer.
- Webrakéta Kft., as Data Controller, informs the Customers, as Data Subjects, that the provision of the data specified in Section 5 of this Privacy Notice is a prerequisite for concluding the contract, a condition for maintaining the contractual relationship, and thereby a condition for providing the service. The Customer, as Data Subject, is required to provide these personal data, because the consequence of failing to provide the data is that without these personal data the contractual relationship between Webrakéta Kft., as Data Controller, and the Customer, as Data Subject, is not established, or an already established contractual relationship is terminated.
- Webrakéta Kft., as Data Controller, informs the Customers, as Data Subjects, that the Customer, as Data Subject, is responsible for ensuring that the data they provide are true and accurate. Webrakéta Kft., as Data Controller, verifies the authenticity of the data provided by the Customer, as Data Subject, only to the extent that it is able to do so based on its right to access authentic public registers.
- Webrakéta Kft., as Data Controller, processes the following personal data of the Data Subject, provided for the purpose of requesting a callback:
- Name of the Data Subject
- purpose of data processing:
- Contacting the Data Subject
- Concluding the contract with the Data Subject
- legal basis for data processing:
- Formation of contract with the Data Subject: Section 6:63(2) of the Hungarian Civil Code (Ptk.)
- Consent of the Data Subject, if the Customer, as Data Subject, has signed the Declaration of Consent and sent it to Webrakéta Kft., as Data Controller
- duration of data processing: immediately after the end of the telephone conversation
- Phone number of the Data Subject
- purpose of data processing:
- Contacting the Data Subject
- Concluding the contract with the Data Subject
- legal basis for data processing:
- Formation of contract with the Data Subject: Section 6:63(2) of the Hungarian Civil Code (Ptk.)
- Consent of the Data Subject, if the Customer, as Data Subject, has signed the Declaration of Consent and sent it to Webrakéta Kft., as Data Controller
- duration of data processing: immediately after the end of the telephone conversation
- Webrakéta Kft., as Data Controller, processes the following personal data of the Customer, as Data Subject:
- Name of the Customer, as Data Subject
- purpose of data processing:
- during the existence of the contractual relationship:
- Identification of the Customer, as Data Subject
- Maintaining contact with the Customer, as Data Subject
- Concluding the contract with the Customer, as Data Subject
- Providing the service ordered by the Customer, as Data Subject, to the Customer, as Data Subject
- Issuing an invoice to the Customer, as Data Subject
- Retaining the invoice issued to the Customer, as Data Subject
- after termination of the contractual relationship:
- enforcement of possible claims arising from the contract
- retaining the invoice issued to the Customer, as Data Subject
- legal basis for data processing:
- during the existence of the contractual relationship:
- Formation of contract with the Customer, as Data Subject: Section 6:63(2) of the Hungarian Civil Code (Ptk.)
- Performance of the contract concluded with the Customer, as Data Subject: Section 6:123(1) of the Hungarian Civil Code (Ptk.)
- Fulfillment of the legal obligation applicable to Webrakéta Kft. as Controller under Section 159(1) and Section 169(e) of 2007. évi CXXVII. törvény (Act CXXVII of 2007 on Value Added Tax), according to which the taxable person is required to issue an invoice, a mandatory content element of which is the name of the recipient of the service
- A legal obligation applicable to Webrakéta Kft. as Controller under Section 169(2) of 2000. évi C. törvény (Act C of 2000 on Accounting), according to which the invoice must be retained for at least 8 years
- The consent of the Client as Data Subject, if the Client as Data Subject has signed the Consent Declaration and sent it to Webrakéta Kft. as Controller
- after termination of the contractual legal relationship:
- exercising rights and fulfilling obligations arising from the contract under Section 6:22 of the Hungarian Civil Code (Ptk.), according to which claims become time-barred after 5 years
- A legal obligation applicable to Webrakéta Kft. as Controller under Section 169(2) of 2000. évi C. törvény (Act C of 2000 on Accounting): the invoice must be retained for at least 8 years
- duration of processing: until the expiry of the 5-year limitation period following termination of the contractual legal relationship, provided that the invoice must be retained for at least 8 years for the purpose of fulfilling a legal obligation under Section 169(1) of 2000. évi C. törvény (Act C of 2000 on Accounting).
- Name of the legal representative of the Client as Data Subject:
- purpose of processing:
- during the contractual legal relationship:
- concluding the contract with the Client as Data Subject
- after termination of the contractual legal relationship:
- enforcement of any claims arising from the contract
- legal basis for processing:
- during the contractual legal relationship:
- establishment of a contract with the Client as Data Subject: Section 6:63(2) of the Hungarian Civil Code (Ptk.)
- The consent of the Client as Data Subject, if the Client as Data Subject has signed the Consent Declaration and sent it to Webrakéta Kft. as Controller
- after termination of the contractual legal relationship:
- exercising rights and fulfilling obligations arising from the contract under Section 6:22 of the Hungarian Civil Code (Ptk.), according to which claims become time-barred after 5 years
- duration of processing: until the expiry of the 5-year limitation period following termination of the contractual legal relationship
- Registered office/residence of the Client as Data Subject
- purpose of processing:
- during the contractual legal relationship:
- concluding the contract with the Client as Data Subject
- issuing an invoice to the Client as Data Subject, except if the Client’s billing address is different from its registered office/residence
- retaining the invoice issued to the Client as Data Subject, except if the Client’s billing address is different from its registered office/residence
- after termination of the contractual legal relationship:
- enforcement of any claims arising from the contract
- retaining the invoice issued to the Client as Data Subject, except if the Client’s billing address is different from its registered office/residence
- legal basis for processing:
- during the contractual legal relationship:
- establishment of a contract with the Client as Data Subject: Section 6:63(2) of the Hungarian Civil Code (Ptk.)
- Fulfillment of the legal obligation applicable to Webrakéta Kft. as Controller under Section 159(1) and Section 169(e) of 2007. évi CXXVII. törvény (Act CXXVII of 2007 on Value Added Tax), according to which the taxable person is required to issue an invoice, a mandatory content element of which is the address of the recipient of the service, except if the Client’s billing address is different from its registered office/residence
- A legal obligation applicable to Webrakéta Kft. as Controller under Section 169(2) of 2000. évi C. törvény (Act C of 2000 on Accounting), according to which the invoice must be retained for at least 8 years, except if the Client’s billing address is different from its registered office/residence
- The consent of the Client as Data Subject, if the Client as Data Subject has signed the Consent Declaration and sent it to Webrakéta Kft. as Controller
- after termination of the contractual legal relationship:
- exercising rights and fulfilling obligations arising from the contract under Section 6:22 of the Hungarian Civil Code (Ptk.), according to which claims become time-barred after 5 years
- A legal obligation applicable to Webrakéta Kft. as Controller under Section 169(2) of 2000. évi C. törvény (Act C of 2000 on Accounting): the invoice must be retained for at least 8 years
- duration of processing: until the expiry of the 5-year limitation period following termination of the contractual legal relationship, provided that, if the Client’s billing address is the same as its registered office/residence, the invoice must be retained for at least 8 years for the purpose of fulfilling a legal obligation under Section 169(1) of 2000. évi C. törvény (Act C of 2000 on Accounting).
- Tax number/tax identification number of the Client as Data Subject
- purpose of processing:
- during the contractual legal relationship:
- concluding the contract with the Client as Data Subject
- issuing an invoice to the Client as Data Subject
- retaining the invoice issued to the Client as Data Subject
- after termination of the contractual legal relationship:
- enforcement of any claims arising from the contract
- retaining the invoice issued to the Client as Data Subject
- legal basis for processing:
- during the contractual legal relationship:
- establishment of a contract with the Client as Data Subject: Section 6:63(2) of the Hungarian Civil Code (Ptk.)
- Fulfillment of the legal obligation applicable to Webrakéta Kft. as Controller under Section 159(1) and Section 169(d) of 2007. évi CXXVII. törvény (Act CXXVII of 2007 on Value Added Tax), according to which the taxable person is required to issue an invoice, a mandatory content element of which is the tax number of the recipient of the service
- A legal obligation applicable to Webrakéta Kft. as Controller under Section 169(2) of 2000. évi C. törvény (Act C of 2000 on Accounting), according to which the invoice must be retained for at least 8 years
- The consent of the Client as Data Subject, if the Client as Data Subject has signed the Consent Declaration and sent it to Webrakéta Kft. as Controller
- after termination of the contractual legal relationship:
- exercising rights and fulfilling obligations arising from the contract under Section 6:22 of the Hungarian Civil Code (Ptk.), according to which claims become time-barred after 5 years
- A legal obligation applicable to Webrakéta Kft. as Controller under Section 169(2) of 2000. évi C. törvény (Act C of 2000 on Accounting): the invoice must be retained for at least 8 years
- duration of processing: until the expiry of the 5-year limitation period following termination of the contractual legal relationship, provided that the invoice must be retained for at least 8 years for the purpose of fulfilling a legal obligation under Section 169(1) of 2000. évi C. törvény (Act C of 2000 on Accounting).
- Domain name
- purpose of processing:
- during the contractual legal relationship:
- providing the service ordered by the Client as Data Subject to the Client as Data Subject
- after termination of the contractual legal relationship:
- enforcement of any claims arising from the contract
- legal basis for processing:
- during the contractual legal relationship:
- performance of the contract concluded with the Client as Data Subject: Section 6:123(1) of the Hungarian Civil Code (Ptk.)
- The consent of the Client as Data Subject, if the Client as Data Subject has signed the Consent Declaration and sent it to Webrakéta Kft. as Controller
- after termination of the contractual legal relationship:
- exercising rights and fulfilling obligations arising from the contract under Section 6:22 of the Hungarian Civil Code (Ptk.), according to which claims become time-barred after 5 years
- duration of processing: until the expiry of the 5-year limitation period following termination of the contractual legal relationship
- Name of the contact person of the Client as Data Subject
- purpose of processing:
- during the contractual legal relationship:
- maintaining contact with the Client as Data Subject
- concluding the contract with the Client as Data Subject
- after termination of the contractual legal relationship:
- enforcement of any claims arising from the contract
- legal basis for processing:
- during the contractual legal relationship:
- establishment of a contract with the Client as Data Subject: Section 6:63(2) of the Hungarian Civil Code (Ptk.)
- The consent of the Client as Data Subject, if the Client as Data Subject has signed the Consent Declaration and sent it to Webrakéta Kft. as Controller
- after termination of the contractual legal relationship:
- exercising rights and fulfilling obligations arising from the contract under Section 6:22 of the Hungarian Civil Code (Ptk.), according to which claims become time-barred after 5 years
- duration of processing: until the expiry of the 5-year limitation period following termination of the contractual legal relationship.
- E-mail address of the Client’s contact person
- purpose of processing:
- during the contractual legal relationship:
- identification of the Client as Data Subject
- maintaining contact with the Client as Data Subject
- concluding the contract with the Client as Data Subject
- after termination of the contractual legal relationship:
- enforcement of any claims arising from the contract
- legal basis for processing:
- during the contractual legal relationship:
- establishment of a contract with the Client as Data Subject: Section 6:63(2) of the Hungarian Civil Code (Ptk.)
- The consent of the Client as Data Subject, if the Client as Data Subject has signed the Consent Declaration and sent it to Webrakéta Kft. as Controller
- after termination of the contractual legal relationship:
- exercising rights and fulfilling obligations arising from the contract under Section 6:22 of the Hungarian Civil Code (Ptk.), according to which claims become time-barred after 5 years
- duration of processing: until the expiry of the 5-year limitation period following termination of the contractual legal relationship.
- Telephone number of the Client’s contact person
- purpose of processing:
- during the contractual legal relationship:
- maintaining contact with the Client as Data Subject
- concluding the contract with the Client as Data Subject
- after termination of the contractual legal relationship:
- enforcement of any claims arising from the contract
- legal basis for processing:
- during the contractual legal relationship:
- establishment of a contract with the Client as Data Subject: Section 6:63(2) of the Hungarian Civil Code (Ptk.)
- The consent of the Client as Data Subject, if the Client as Data Subject has signed the Consent Declaration and sent it to Webrakéta Kft. as Controller
- after termination of the contractual legal relationship:
- exercising rights and fulfilling obligations arising from the contract under Section 6:22 of the Hungarian Civil Code (Ptk.), according to which claims become time-barred after 5 years
- duration of processing: until the expiry of the 5-year limitation period following termination of the contractual legal relationship.
Webrakéta Kft. as Controller informs the Clients as Data Subjects that if the person designated as the Client’s contact person is not the same as the Client as a sole proprietor, or as the person authorized to represent the Client as a company, the Client is required to obtain the consent declaration of the person acting as the Client’s contact person for the processing of his or her name, e-mail address and telephone number as personal data, if the Client has no other legal basis for processing the personal data of the person designated as contact person. In this case, the Client qualifies as the controller, and Webrakéta Kft. qualifies as the processor with respect to these personal data.
- Webrakéta Kft. as Controller informs the Clients as Data Subjects that it processes their personal data specified in Sections III.4. and III.5. exclusively electronically, and not in paper form.
IV.
….on the rights of the Clients as Data Subjects:
- By publishing this Privacy Notice, Webrakéta Kft. as Controller ensures that all information relating to the processing of personal data and all information relating to the rights of the Data Subject is available to the Data Subject in a concise, transparent, intelligible and easily accessible form, clearly and in plain language.
- Webrakéta Kft. as Controller undertakes to inform the Data Subject, as set out below, without undue delay, of the measures taken following his or her request.
- If Webrakéta Kft., as Controller, does not take action on the Data Subject’s request, as explained below, it shall inform the Data Subject without delay of the reasons for not taking action, and of the fact that the Data Subject may lodge a complaint with a supervisory authority and may exercise their right to judicial remedy.
- Webrakéta Kft., as Controller, provides the information and notifications and takes the measures free of charge. However, if the request of the Client, as Data Subject, is manifestly unfounded or excessive, in particular because of its repetitive nature, Webrakéta Kft., as Controller, may refuse to take action on the request, taking into account the administrative costs of providing the requested information or notification or taking the requested measure.
- Webrakéta Kft., as Controller, informs the Clients, as Data Subjects, that if it has reasonable doubts concerning the identity of the natural person submitting the request, it may request the provision of additional information necessary to confirm the identity of the Client, as Data Subject.
- The Client, as Data Subject, has the following rights:
- The Data Subject may request access to their personal data as follows:
Information covered by the Controller’s obligation to provide information:
The Data Subject has the right to obtain confirmation from Webrakéta Kft., as Controller, as to whether personal data concerning them is being processed, and, where such processing is being carried out, the Data Subject has the right to access the personal data and the following information:
- the purposes of processing
- the categories of personal data concerned
- the recipients or categories of recipients to whom the personal data have been or will be disclosed
- where applicable, the planned period for which the personal data will be stored, or, if this is not possible, the criteria used to determine that period
- the Data Subject’s right to request from the Controller the rectification or erasure of personal data concerning them, or restriction of the processing of such data, and to object to the processing of such personal data
- the right to lodge a complaint with a supervisory authority
- where the data were not collected from the Data Subject, any available information as to their source
- the fact of automated decision-making, including profiling, and, at least in such cases, meaningful information about the logic involved, as well as the significance and the expected consequences of such processing for the Data Subject.
Process for assessing the request:
Webrakéta Kft., as Controller, fulfills its obligation set out above by publishing this Privacy Notice, with the proviso that, at the Data Subject’s request, Webrakéta Kft., as Controller, shall provide the Data Subject with a copy of the personal data undergoing processing within 5 business days of receipt of the request at the latest.
- The Data Subject is entitled to rectify their personal data themselves:
Persons entitled to rectify personal data:
The Data Subject is entitled to rectify inaccurate personal data concerning them themselves.
Informing recipients about the rectification of personal data:
If the Data Subject has informed the Controller of the data rectification carried out by them, Webrakéta Kft., as Controller, shall inform every recipient to whom the personal data have been disclosed of each rectification within 5 business days of receipt of the information, unless this proves impossible or involves disproportionate effort.
Informing the Data Subject about recipients:
At the Data Subject’s request, Webrakéta Kft., as Controller, shall inform the Data Subject about these recipients:
- if the Data Subject submits this request together with the notification of data rectification or before the recipients are informed, then on the same day as the recipients are informed;
- if the Data Subject submits this request after the recipients have been informed, then on the business day following receipt of the request.
- The Data Subject may request erasure of their personal data (“right to be forgotten”):
The Data Subject has the right to have Webrakéta Kft., as Controller, erase personal data concerning them upon request, without undue delay.
The Controller’s obligation to erase data exists in the following cases:
Webrakéta Kft., as Controller, informs Data Subjects that Webrakéta Kft., as Controller, is obliged to erase personal data concerning the Data Subject without undue delay if one of the following grounds applies: (alternative conditions)
- the personal data are no longer necessary in relation to the purpose for which they were collected or otherwise processed
- the Data Subject withdraws the consent on which the processing is based, and there is no other legal basis for the processing
- the Data Subject objects to the processing, and there is no overriding lawful ground for the processing
- the personal data have been processed unlawfully
- the personal data must be erased for compliance with a legal obligation under Union or Member State law applicable to Webrakéta Kft., as Controller
Exceptions to the obligation to erase data:
Webrakéta Kft., as Controller, informs Data Subjects that the above provision on erasure does not apply where the processing is: (alternative conditions)
- necessary for compliance with a Union or Member State law obligation applicable to Webrakéta Kft., as Controller, which requires the processing of personal data
- necessary for statistical purposes, where the “right to be forgotten” would likely make this processing impossible or seriously impair it;
- necessary for the establishment, exercise or defense of legal claims.
Process for assessing the request:
Webrakéta Kft., as Controller, informs Data Subjects that it shall review the Data Subject’s request for the erasure of their personal data within 5 business days of receipt of the request, and shall decide on whether it is well-founded, taking into account the above provisions.
Webrakéta Kft., as Controller, shall inform the Data Subject of its decision on the business day following the decision.
Procedure if the request is well-founded
If Webrakéta Kft., as Controller, considers the Data Subject’s request for erasure to be well-founded, it shall erase the personal data on the same day as the Data Subject is informed, and, in the absence of a request to this effect from the Data Subject, shall call on the Data Subject in the notification of its decision to state within 3 business days of receipt of the notification at the latest whether they request that the Controller inform them about the recipients to whom the Controller communicated the erasure of the personal data.
Webrakéta Kft., as Controller, if this does not prove impossible or involve disproportionate effort, shall inform every recipient to whom the personal data have been disclosed at the same time as the erasure.
Webrakéta Kft., as Controller, shall inform any Data Subject who has submitted a request to this effect as described above about the recipients as follows.
- if the Data Subject submitted their request for information about the recipients together with their request for erasure of the data, or at the latest before the Controller’s decision: the Controller shall inform them about the recipients on the same day as the erasure of the data and the notification of the recipients;
- if the Data Subject submitted their request for information about the recipients only in response to the Controller’s call to do so: the Controller shall inform them about the recipients no later than the business day following receipt of the request.
Procedure if the request is unfounded:
If Webrakéta Kft., as Controller, considers the Data Subject’s request unfounded, it shall reject the request, against which decision the Data Subject may lodge a complaint with a supervisory authority and may exercise their right to judicial remedy.
- The Data Subject may request restriction of the processing of their personal data:
Obligation regarding restriction of data processing:
The Data Subject has the right to have the Controller restrict processing upon request if one of the following applies: (alternative conditions)
- the Data Subject disputes the accuracy of the personal data – in this case, the restriction applies for the period enabling the Controller to verify the accuracy of the personal data;
- Webrakéta Kft., as Controller, no longer needs the personal data for the purposes of processing, but the Data Subject requires them for the establishment, exercise or defense of legal claims;
- the Data Subject has objected to the processing – in this case, the restriction applies for the period until it is established whether the Controller’s legitimate grounds override the Data Subject’s legitimate grounds.
Webrakéta Kft., as Controller, if this does not prove impossible or involve disproportionate effort, shall, when restricting the personal data, simultaneously inform every recipient to whom the personal data have been disclosed.
In the absence of a request to this effect from the Data Subject, Webrakéta Kft., as Controller, shall call on the Data Subject on the business day following the restriction of the personal data to state within 3 business days of receipt of the call at the latest whether they request that the Controller inform them about the recipients to whom the Controller communicated the restriction of the personal data.
Webrakéta Kft., as Controller, shall inform any Data Subject who has submitted a request to this effect about the recipients.
- if the Data Subject submitted their request for information about the recipients at the same time as their request for restriction of the data: the Controller shall inform them about the recipients on the same day as the restriction of the data and the notification of the recipients;
- if the Data Subject submitted their request for information about the recipients only in response to the Controller’s call to do so: the Controller shall inform them about the recipients no later than the business day following receipt of the request.
Exceptions, meaning the Controller is entitled to process personal data subject to restriction in the following cases:
Webrakéta Kft., as Controller, informs Data Subjects that personal data in respect of which processing is subject to restriction may be processed, except for storage, only in the following cases: (alternative conditions)
- if the Data Subject has given consent to it,
- if it is necessary for the establishment, exercise or defense of legal claims,
- if it is necessary to protect the rights of another natural or legal person,
- if it is necessary for reasons of important public interest of the Union or of a Member State.
- The Data Subject may object to the processing of their personal data:
The Data Subject may object to the processing of their personal data in the following case:
Webrakéta Kft., as Controller, expressly draws the Data Subject’s attention to the fact that, on grounds relating to their particular situation, the Data Subject is entitled to object to the processing of their personal data if the processing is necessary for the enforcement of the legitimate interests of Webrakéta Kft., as Controller, or of a third party.
If the Data Subject objects, Webrakéta Kft., as Controller, may no longer process the Data Subject’s personal data.
If the Data Subject objects, Webrakéta Kft., as Controller, is entitled to process the personal data in the following cases:
Despite the Data Subject’s objection, Webrakéta Kft., as Controller, may process the Data Subject’s personal data if Webrakéta Kft., as Controller, demonstrates compelling legitimate grounds for the processing that (alternative conditions)
- override the interests, rights and freedoms of the Data Subject, or
- are related to the establishment, exercise or defense of legal claims.
Process for assessing the request:
Webrakéta Kft., as Controller, informs Data Subjects that it will examine the Data Subject’s objection within 5 business days of receipt of the request, and will decide on its validity taking the above provisions into account.
Webrakéta Kft., as Controller, will inform the Data Subject of its decision on the business day following the decision.
Procedure if the request is valid:
If Webrakéta Kft., as Controller, considers the Data Subject’s objection to be valid, it will delete the personal data on the same business day as the Data Subject is informed, and, if the Data Subject has not requested this, in the notice of its decision it will call on the Data Subject to declare, no later than within 3 business days of receipt of the notice, whether they request that the Controller inform them of the recipients to whom the Controller communicated the deletion of the personal data.
Namely, Webrakéta Kft., as Controller, will, if this does not prove impossible or require disproportionate effort, inform every recipient at the same time as the deletion to whom the personal data was disclosed.
Webrakéta Kft., as Controller, will inform the Data Subject who submitted such a request as described above about the recipients as follows:
- if the Data Subject submitted the request for information about the recipients at the same time as their objection, or no later than before the Controller’s decision: it will inform them about the recipients on the same day as the deletion of the data and notification of the recipients;
- if the Data Subject submitted the request for information about the recipients only in response to the Controller’s request to do so: it will inform them about the recipients no later than on the business day following receipt of the request.
Procedure if the request is unfounded:
If Webrakéta Kft., as Controller, considers the Data Subject’s request to be unfounded, it will reject the request. The Data Subject may file a complaint with a supervisory authority against this decision and may exercise their right to judicial remedy.
- The Data Subject has the right to data portability:
The Data Subject has the right to data portability in the following case:
The Data Subject has the right to receive the personal data concerning them that they have provided to Webrakéta Kft., as Controller, in a structured, commonly used, machine-readable format, and also has the right to transmit those data to another Controller if (cumulative conditions)
- the processing is based on consent or on a contract; and
- the processing is carried out by automated means.
The Data Subject has the right, where technically feasible, to request Webrakéta Kft., as Controller, to transmit the personal data processed by it directly to another Controller. However, this does not create an obligation for Webrakéta Kft., as Controller, or for another controller to introduce or maintain technically compatible processing systems.
Webrakéta Kft., as Controller, undertakes that if the personal data are not transmitted because communication between the two systems is not possible, Webrakéta Kft., as Controller, will inform the Data Subject of this fact and the reasons for it.
Webrakéta Kft., as Controller, informs Data Subjects that it is not responsible for whether
- the recipient controller receives and processes the data transmitted to it by Webrakéta Kft.,
- the recipient controller’s processing complies with the provisions of the applicable laws.
Exceptions to data portability:
Webrakéta Kft., as Controller, informs Data Subjects that the right to data portability:
- may not infringe the right to be forgotten, and
- may not adversely affect the rights and freedoms of others.
Process for assessing the request:
Webrakéta Kft., as Controller, informs Data Subjects that it will examine the Data Subject’s request within 5 business days of receipt of the request, and will decide on its validity taking the above provisions into account.
Webrakéta Kft., as Controller, will inform the Data Subject of its decision on the business day following the decision.
Procedure if the request is valid:
If Webrakéta Kft., as Controller, considers the Data Subject’s request to be valid, it will fulfill the Data Subject’s request within 10 business days of making the decision.
Procedure if the request is unfounded:
If Webrakéta Kft., as Controller, considers the Data Subject’s request to be unfounded, it will reject the request. The Data Subject may file a complaint with a supervisory authority against this decision and may exercise their right to judicial remedy.
- The Data Subject has the right to withdraw consent to the processing of personal data at any time:
The Data Subject has the right to withdraw their consent at any time.
Webrakéta Kft., as Controller, informs Data Subjects that withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Webrakéta Kft., as Controller, informs Data Subjects that in the event of withdrawal of consent, the Controller is obliged to delete the personal data only if it may not process the personal data on another legal basis.
Webrakéta Kft., as Controller, informs Data Subjects that it currently does not carry out any processing whose sole legal basis is the Data Subject’s consent within the meaning of Section III of this Privacy Notice.
- The Data Subject has the right not to have a decision based solely on automated processing, including profiling, apply to them, where that decision would produce legal effects concerning them or similarly significantly affect them.
Webrakéta Kft., as Controller, informs Data Subjects that it currently does not make any decision based solely on automated processing that would produce legal effects concerning the Data Subject or similarly significantly affect them.
However, if Webrakéta Kft., as Controller, intends in the future to make such a decision based solely on automated processing, it will inform Data Subjects of this in advance, and accepts the matters set out below as binding upon itself.
Webrakéta Kft., as Controller, informs Data Subjects that the Data Subject does not have the right specified in this section if the decision (alternative conditions)
- is necessary for entering into or performing a contract between the Data Subject and Webrakéta Kft., as Controller;
- is based on the Data Subject’s explicit consent;
- is authorized by European Union or Member State law applicable to Webrakéta Kft., as Controller, which also lays down suitable measures to safeguard the Data Subject’s rights and freedoms and legitimate interests.
Webrakéta Kft., as Controller, undertakes that in cases 1 and 2 it will take appropriate measures to safeguard the Data Subject’s rights, freedoms and legitimate interests, including at least the Data Subject’s right to obtain human intervention on the part of Webrakéta Kft., as Controller, to express their point of view, and to contest the decision.
- The Data Subject may file a complaint with the supervisory authority and may seek judicial remedy:
Webrakéta Kft., as Controller, informs Data Subjects that if, in the Data Subject’s opinion, their rights have been infringed in the course of processing their personal data, they have the right to
- file a complaint with the supervisory authority:
Name: Nemzeti Adatvédelmi és Információszabadság Hatóság
Postal address: 1530 Budapest, P.O. Box 5
Address: 1125 Budapest Szilágyi Erzsébet fasor 22/c.
Phone: +36 (1) 391-1400
Fax: +36 (1) 391-1410
E-mail: ugyfelszolgalat@naih.hu
URL http://naih.hu
- seek judicial remedy:
In the event of infringement of the Data Subject’s rights, the Data Subject may bring proceedings before a court against Webrakéta Kft., as Controller. The action falls within the jurisdiction of the Regional Court.
V.
…on the categories of persons who may access the personal data of Customers, as Data Subjects:
- The data of Customers, as Data Subjects, may be accessed by the employees of the Controller, Webrakéta Kft. If an employee of Webrakéta Kft., as Controller, causes damage to the Customer, as Data Subject, by virtue of the employment relationship, Webrakéta Kft., as employer, is liable toward the Customer, as Data Subject, pursuant to Section 6:540(1) of the Hungarian Civil Code (Ptk.).
- Webrakéta Kft., as Controller, informs Customers, as Data Subjects, that it uses the following Processors.
- FÉNY-ADÓ Számviteli és Kereskedelmi Korlátolt Felelősségű Társaság
- Company details:
- Short name: FÉNY-ADÓ Kft.
- Company registration number: 12-09-004267
- Registered office: 2651 Rétság, Templom u. 17.
- Tax number: 13156431-2-12
- Represented by: Beatrix Szabó, managing director
- Scope of personal data processed: Customer’s name, Customer’s registered office/residence, Customer’s tax number/tax identification code
- Purpose of processing: use by the Controller of accounting services provided by the Processor.
- Categories of Data Subjects: Customers.
- KBOSS.hu Kereskedelmi és Szolgáltató Korlátolt Felelősségű Társaság
- Company details:
- Short name: KBOSS.hu Kft.
- Company registration number: 01-09-303201
- Registered office: 1031 Budapest, Záhony u. 7.
- Tax number: 13421739-2-41
- Represented by: Balázs Ángyán, managing director
- Scope of personal data processed: Customer’s name, Customer’s registered office/residence, Customer’s tax number/tax identification code
- Purpose of processing: use by the Controller of invoicing services provided by the Processor.
- Categories of Data Subjects: Customers.
- ViaCom Informatikai Kereskedelmi és Szolgáltató Korlátolt Felelősségű Társaság
- Company details:
- Short name: ViaCom Informatikai Kft.
- Company registration number: 13-09-109794
- Registered office: 2225 Üllő, Gyár u. 8.
- Tax number: 13810359-2-13
- Represented by: László Váradi, managing director, and József Hidasi, managing director
- Scope of personal data processed: Customer’s name, Customer’s phone number, name of the Customer’s legal representative, Customer’s registered office/residence, Customer’s tax number/tax identification code, domain name, name of the Customer’s contact person, e-mail address of the Customer’s contact person, phone number of the Customer’s contact person
- Purpose of processing: use by the Controller of hosting services provided by the Processor.
- Categories of Data Subjects: Customers.
- Webrakéta Kft., as Controller, informs Customers, as Data Subjects, that if there is a change in the identity of the Processors specified above, or if the Controller engages additional Processors, it will inform Customers, as Data Subjects, of this by amending this Privacy Notice on the same day as the Data Processing Agreement is concluded.
- Webrakéta Kft., as Controller, informs the Customers, as Data Subjects, that the Processors process the personal data of the Customers, as Data Subjects, exclusively on the basis of the written instructions of Webrakéta Kft., as Controller, unless processing is required by the law applicable to the Processor.
- Webrakéta Kft., as Controller, informs the Customers, as Data Subjects, that the Processors may engage another processor only on the basis of the prior written authorization of Webrakéta Kft., as Controller.
VI.
…. about the following other provisions:
- Amendment of the Privacy Notice:
Webrakéta Kft., as Controller, reserves the right to amend this Privacy Notice, while undertaking to inform the Customers, as Data Subjects, of this 30 days before the amendment, unless the amendment is based on a statutory provision or a court/authority decision. If the amendment is based on a statutory provision or a court/authority decision, Webrakéta Kft., as Controller, undertakes to inform the Customers, as Data Subjects, of the amendment without delay, but no later than within 15 days.
- Processing for a purpose other than the original purpose:
Webrakéta Kft., as Controller, informs the Customers, as Data Subjects, that if the Controller intends to process the Customer’s personal data for a purpose other than the original purpose for which it was collected, before any further processing the Controller will inform the Customer of this other purpose and of all other necessary information, with the proviso that if the controller cannot provide the data subject with information about the source of the personal data because it comes from various sources, it will provide general information.
- Handling e-mail messages:
- Webrakéta Kft., as Controller, informs the Customers, as Data Subjects, by e-mail about:
- amendments to the General Terms and Conditions, the Privacy Notice, and the Cookie Notice
- system errors, outages, and troubleshooting;
- technical information related to use of the system.
- Webrakéta Kft., as Controller, informs the Customers, as Data Subjects, that it stores e-mail messages exchanged with the Customer, as Data Subject, for the 5-year limitation period following termination of the contractual relationship, and then deletes them.
- Data protection officer:
Webrakéta Kft., as Controller, informs the Customers, as Data Subjects, that the Controller does not appoint a data protection officer, taking into account that:
- the Controller is not a public authority or any other body performing public duties,
- the Controller’s core activities do not include processing operations which, by their nature, scope, and/or purposes, require regular and systematic monitoring of Data Subjects on a large scale,
- the Controller’s core activities do not include the large-scale processing of special categories of personal data or of data relating to criminal convictions and offences.
Budapest, May 25, 2018
Webrakéta Kft.
represented by: Ernő Kiss, managing director
- ANNEX
DATA SUBJECT’S CONSENT STATEMENT
TO THE PROCESSING OF PERSONAL DATA
FOR THE PURPOSE OF REQUESTING A CALLBACK:
I, the undersigned ………………………………………… Customer, as Data Subject, hereby give my voluntary, specific, informed and unambiguous consent, as set out in the Privacy Notice applicable to Customers, to the processing of the following personal data of mine, acknowledging the provisions of Section III.1 of the Privacy Notice: (underline which data processing you consent to)
- Customer’s name,
- Customer’s telephone number,
Date:
………………………………….
Customer
FOR THE PURPOSE OF PLACING AN ORDER:
I, the undersigned ………………………………………… Customer, as Data Subject, hereby give my voluntary, specific, informed and unambiguous consent, as set out in the Privacy Notice applicable to Customers, to the processing of the following personal data of mine, acknowledging the provisions of Section III.2 of the Privacy Notice: (underline which data processing you consent to)
- Customer’s name,
- Name of the Customer’s legal representative,
- Customer’s registered office/residence,
- Customer’s tax number/tax identification number,
- Domain name
- Name of the Customer’s contact person,
- E-mail address of the Customer’s contact person,
- Telephone number of the Customer’s contact person.
Date: ………………………………….
Customer