Table of Contents
- What is the purpose of this information?
- Data Controller's details
- What data processing activities do I carry out within the framework of my activities?
- What rights do users have?
- Notification and action obligations
- Possible recipients of personal data
- Cookies
- Google Analytics
- Other provisions
1. What is the purpose of this information?
We adopt this Information for the purpose of providing all essential information and notifications in a concise, transparent, understandable, and easily accessible form, clearly and in plain language to natural persons (hereinafter: Users) who use the services available on digby.hu (hereinafter: Website), and to assist Users in exercising their rights under point 4. Users can register themselves as buyers on the Website. Our obligation to inform is based on Article 12 of Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter: GDPR), applicable from May 25, 2018, Section 20 of Act CXII of 2011 on the right to informational self-determination and on freedom of information (hereinafter: Infotv.), and Section 4 of Act CVIII of 2001 on certain issues of electronic commerce services and services related to the information society (Elkertv.). In designing and applying this information, we have proceeded in the spirit of the principle of accountability, particularly mentioned in paragraph (2) of Article 5 of the GDPR, considering the findings of the National Authority for Data Protection and Freedom of Information's recommendation on the data protection requirements of preliminary information.
2. Data Controller's details
- Name: Digby Hungary Ltd.
- Website: digby.hu
- Company number: 1309226449
- Email: dev@digby.hu
3. What data processing activities do I carry out within the framework of my activities?
3.1. Data processing related to newsletter subscription
In order to provide Users with current information related to the use of our services, it is possible to subscribe to a newsletter through the website. The following information applies to related data processing:
3.1.1. The personal data processed and the purpose of data processing
personal data | purpose of data processing |
---|
name: | by providing this, we can identify the User in our letters |
email address: | by providing this, we get to know the User's electronic contact to which we can send our newsletter about the updates |
3.1.2. Legal basis for data processing
The consent of the User (Article 6 (1) (a) of the GDPR, Section 5 (1) (a) of the Infotv., and Section 6 (1) of Act XLVIII of 2008 on the basic conditions and certain limitations of economic advertising activity (Grt.)).
3.1.3. Duration of data processing
The Data Controller processes personal data until the withdrawal of consent. You can withdraw your consent at any time by clicking the "Unsubscribe" button found in the sent email.
3.1.4. Method of data processing
In electronic form.
3.2. Data processing related to invoicing
Following the completion of transactional orders - with regard to Sztv) - we issue an accounting document. The details of related data processing are as follows.
3.2.1. The personal data processed and the purpose of data processing
We process the names and addresses of our natural person Users, and in the case of businesses, their registered office and tax number, for the purpose of accounting for the completion of transactional orders (economic event).
3.2.2. Legal basis for data processing
Mandatory data processing based on legislation (considering Article 6 (1) c) of the GDPR, Section 5 (1) b) of the Infotv., and Sections 166 (1)-(3) of the Sztv.).
3.2.3. Duration of data processing
For 8 years following the issuance of the accounting document (considering Section 166 (6) of the Sztv. in light of Section 169 (1)).
3.2.4. Method of storage of personal data
Both on paper and in electronic form.
3.2.5. Provision of personal data
Considering that we cannot issue an accounting document without the knowledge of the personal data specified in this point, the provision of personal data is based on legislation.
4. What rights do users have?
Users can request free information about the details of their personal data processing, and under legally specified circumstances, request the rectification, deletion, blocking, or limitation of their data processing, and object to such personal data processing. Requests for information and requests mentioned in this point can be addressed to our contact details specified in point 2.
4.1. Right of access
Our User can receive feedback from us regarding the processing of their personal data and can access these personal data and their processing details.
4.2. Right to rectification
Upon the request of our User, the Data Controller shall rectify the inaccurate personal data concerning them without undue delay, and they have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
4.3. Right to erasure
Upon the request of our User, we shall delete their personal data if there is no need for us to process them, or if they withdraw their consent, or object to the data processing, or if the processing is unlawful.
4.4. Right to be forgotten
Regarding our User's request for erasure - if they wish - we strive to notify every data controller who might have become or could become acquainted with our User's data that has potentially been made public.
4.5. Right to restriction of processing
Upon our User's request, we shall restrict processing if the accuracy of the personal data is contested, or the data processing is unlawful, or our User objects to the data processing, or if we no longer need the personal data for the purposes of processing.
4.6. Right to data portability
Our User can receive the personal data concerning them, which they have provided to us, in a structured, commonly used and machine-readable format, and they have the right to transmit those data to another controller.
4.7. Response to requests
We examine the request within the shortest possible time from its submission, but at most within 30 days - in case of objection within 15 days - and make a decision regarding its validity, about which we inform the requester in writing. If we do not fulfill our User's request, in our decision, we communicate the factual and legal reasons for rejecting the request to the Users.
4.8. Enforcement of rights
The protection of personal data is important to us, and we respect our Users' right to informational self-determination, thus we strive to respond to every request fairly and within a deadline. Considering this, we kindly ask our respected Users to contact us for the purpose of filing a complaint to settle any conflicts amicably before resorting to legal action with authorities and courts.
Should the approach not lead to a result, our User can enforce their rights before a court under the Civil Code Act V of 2013 (the lawsuit can be initiated before the court competent according to the User's place of residence or stay) and according to the provisions of Infotv., can turn to the National Authority for Data Protection and Freedom of Information (1125 Budapest, Szilágyi Erzsébet fasor 22/c.;
https://www.naih.hu/panaszuegyintezes-rendje.html, hereinafter: NAIH) and file a complaint.
5. Notification and action obligations
5.1. Notification of recipients
In cases of rectification, erasure, or restriction of data processing, we always notify those recipients with whom or which we have shared the User's personal data, unless this proves impossible or requires a disproportionate effort. Upon the User's request, we provide information about these recipients.
5.2. Mode and deadline for notification
Following the requests related to point 4, we provide information about the actions taken within a maximum of one month from the receipt of the request - unless the User requests otherwise - in electronic form. This deadline may be extended by a further two months if necessary, considering the complexity of the request or the number of requests. We inform the User about the extension of the deadline and its reasons within one month of receiving the request.
Upon our User's request, oral information can also be provided, provided that they prove their identity by other means.
If we do not take action following the request, we inform our User of the reasons for this within a maximum of one month from the receipt of the request, and about the possibility of filing a complaint with NAIH and exercising their right to judicial remedy (point 4.8).
5.3. Verification
In exceptional cases, if we have justified doubts concerning the identity of the natural person submitting the request, we may request additional information necessary to confirm the identity. This measure is necessary to promote the confidentiality of data processing, that is, to prevent unauthorized access to personal data, as specified in Article 5 (1) (f) of the GDPR.
5.4. Costs of notification and action
We provide the information and take the actions related to the requests of point 4 free of charge.
If the User's request is clearly unfounded or excessive - especially due to its repetitive nature - considering the administrative costs of providing the requested information or taking the requested action, we may charge a reasonable fee or refuse to act on the request.
6. Possible recipients of personal data
6.1. In connection with the operation of our Website
Name: D250 Systems Kft.
Address: 2083 Solymár, Orgona u. 9.
6.2. In connection with invoicing
In relation to invoicing, the tax authority is entitled to know the personal data provided by the Users for this purpose. Data of the tax authority:
Name: National Tax and Customs Administration
Website, contacts:
https://www.nav.gov.hu/nav/kapcsolat
6.4. In connection with the payment services of the website
Certain services on the website can be used against credits; the payment system related to the purchase of credits is operated by the service provider mentioned in this point, thus, during its activity, it may get to know and process the bank account data provided by the Users (see: Terms and Conditions 3.2. point).
7. Cookies
For the proper operation of our Website, in some cases, we place small data files on the User's computer device, like most modern websites.
7.1.What is a cookie?
A cookie is a small text file that a website places on the User's computer device (including mobile phones). Thanks to this, the website can "remember" the User's settings (e.g., used language, font size, display, etc.), so they do not have to reset them every time they visit our website.
7.2. What do we use cookies for?
During the visit of the Website, we record visitor data (date, time, IP address of the user's computer, data related to the user's browser, and the title of the visited page) for the purpose of checking the operation of the service, personalized service, and preventing abuses. These cookies can be deleted or blocked, but in this case, the Website may not function properly.
We do not use cookies to personally identify the User. These cookies serve only the purposes described above.
7.3. How can cookies be managed?
Cookie files can be deleted (detailed information:
www.AllAboutCookies.org), or their placement can also be blocked with most modern browsers. In this case, however, certain settings must be performed again each time our website is used, and certain services may not function properly.
Detailed information on deleting or blocking cookies can be found on
www.AllAboutCookies.org (in English) and for the browser used by the User at the following links:
8. Google Analytics
8.1. The Website uses Google Analytics, a web analytics service provided by Google Inc. ("Google"). Google Analytics uses "cookies," which are text files placed on your computer, to help analyze how users use the website.
8.2. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. With IP anonymization activated on this website, Google will truncate/anonymize the last octet of the IP address for Member States of the European Union as well as for other parties to the Agreement on the European Economic Area.
8.3. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA. On behalf of the website provider, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators, and providing other services relating to website activity and internet usage to the website provider.
8.4. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of this website. Furthermore, you can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under
https://tools.google.com/dlpage/gaoptout?hl=hu.
9. Other provisions
9.1. Data processing for different purposes
If we intend to use the provided data for a purpose different from the original purpose of data collection, we will inform the Users and obtain their prior express consent, or provide them with the opportunity to prohibit such use.
9.2. Data security
We commit to ensuring the security of the data, take technical measures to ensure that the recorded, stored, or processed data are protected, and do everything possible to prevent their destruction, unauthorized use, and unauthorized alteration. In light of this and the recommendations of the National Authority for Data Protection and Freedom of Information on the data protection requirements of data processing activities performed on the websites of parties, we use the https protocol on the website, which represents a higher level of data security compared to the http protocol.
9.3. Registration obligation
We keep a record of data processing activities for which we are responsible (register of data processing activities) in accordance with Article 30 of the GDPR.
9.4. Data protection incident
A data protection incident is a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data processed. In the event of a data protection incident, we are obliged to proceed according to Articles 33 and 34 of the GDPR. We record data protection incidents, including the facts relating to the data protection incident, its effects, and the remedial actions taken.
9.5. Modification
We reserve the right to unilaterally modify this Information at any time.
Effective: 2024.03.01.
Digby Hungary Ltd.
Data Controller