Privacy Policy

GARZON BÚTOR ZRT

DATA PRIVACY NOTICE

REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter: Regulation) requires that the company as the controller shall take suitable measures to provide any information relating to processing to the data subject in a concise, transparent, intelligible and easily accessible form, using clear and plain language, and to facilitate the exercise of data subject rights.

Act CXII of 2011 on Informational Self-Determination and Freedom of Information also requires the controller to provide prior information to the data subject. With this notice, we comply with such legal obligation. The terms used in this notice shall have the meanings used in the Regulation, and any matters not covered herein shall be governed by the Regulation. The notice shall be published on the company’s website, or shall be provided or sent to the data subject.

This notice contains the data related to the controller and the processor, the legal basis and purpose of processing, your rights and the possibilities of exercising such rights.

DATA RELATED TO THE CONTROLLER

Garzon Bútor Zrt.

Registered seat: 8000 Székesfehérvár, Bakony utca 4.

company registration number: 07 10 001035

VAT number: 11105020-2-07

E-mail: sales@garzon.hu

phone: +36 22 512 220

fax: +36 22 329 403

website: www.garzonfurniture.com

(hereinafter: Company)

Data protection officer of the company:

dr. Gergely Kozma private entrepreneur 52286010

e-mail: info@adatorom.hu

Data privacy information of the whole company group is available at http://www.garzon.hu/WEBSET_DOWNLOADS/17/3x_adatkezelesi_tajekoztato.pdf.

DATA PROCESSORS OF THE COMPANY

Data processor: a natural or legal person, public authority, agency or any other body processing data on behalf of the controller (Article 4 (8) of the Regulation).

The personal data will be transferred to the next processors in order to have them process our data in accordance with our instructions and our privacy policy, in line with all other relevant privacy and security measures.

The data subject’s prior consent is not required for employing processors, but the data subject shall be informed. Accordingly, we provide the following information:

1. The company’s IT service provider

For maintaining and managing our website, the Company employs a data processor providing IT services (hosting services) and within the frameworks of this, during the term of our contract, it processes the personal data entered on our website, and it performs the storage of the personal data on the server.

Name of the data processor:

DOTROLL KFT.

Address: 1148 Budapest, Fogarasi út 3-5.

Phone: +36 - 1 - 432 - 3232
Fax: +36 - 1 - 432 - 3231
E-mail: support@dotroll.com
Customer service: between 6:00-22:00 on weekdays.
VAT number: 13962982-2-42
Community VAT number: HU 13962982

LEGAL BASIS AND PURPOSES OF PROCESSING

1. Data processing on the basis of the data subject’s consent

In case of processing based on consent, the company requests the data subject’s consent for the processing of his personal data with the content and information specified in the data privacy policy.

This could include ticking a box when visiting an internet website, choosing technical settings for information society services or another statement or conduct which clearly indicates in this context the data subject's acceptance of the proposed processing of his or her personal data. Silence, pre-ticked boxes or inactivity should not therefore constitute consent. Consent should cover all processing activities carried out for the same purpose or purposes.

If the data subject's consent is given in the context of a written declaration which also concerns other matters, e.g. the conclusion of sales or service agreement, the request for consent shall be presented in a manner which is clearly distinguishable from the other matters, in an intelligible and easily accessible form, using clear and plain language. Any part of such a declaration which constitutes an infringement of the Regulation shall not be binding.

The company may not require consent for processing personal data for concluding or performing an agreement if such data are not necessary for the performance of that contract.

It shall be as easy to withdraw as to give consent.

If the personal data were recorded with the data subject’s consent, the controller may continue processing such data for the fulfilment of legal obligations without any further consent or after the withdrawal of the data subject’s consent, unless regulated otherwise in the legal regulations.

2. Data processing based on compliance with a legal obligation

In case of data processing based on legal obligation, the personal data processed, the purpose of processing, the duration of storing the personal data and the recipients are governed by the relevant legal regulation.

Data processing based on compliance with a legal obligation does not depend on the data subject’s consent, since the data processing is required by a legal regulation. Prior to processing, the data subject shall be informed of the compulsory nature of processing, and clear and detailed information shall be provided on all facts concerning the processing of his data, especially on the legal basis and purpose of processing, the person entitled to processing, the duration of processing, on the fact if the personal data are processed on the basis of a legal obligation, and on the parties to whom the data shall be disclosed. The information shall also cover the rights and remedies available to the data subject in relation to the processing. In case of compulsory processing, the information may also be provided by publishing the reference to the legal regulation containing the aforesaid information.

3. Data processing based on legitimate interest

Concerning the camera monitoring, the company applies separate information. In relation to the camera system, it has assessed the legitimate interests of the controller and third parties.

In case of processing based on legitimate interest, the company as the employer has assessed and evaluated the legitimate interests of the controller and the employees. The company informs its employees of the data processing when establishing the employment relationship.

4. Facilitating the exercising of the data subject’s rights

The company ensures the exercising of the data subjects’ rights for all data processing. In order to exercise your rights, you may contact the company at the contact details indicated in the section “data related to the controller”.

The company provides information on action taken on a request within one month of receipt of the request.

That period may be extended by two further months. The company informs the data subject of any such extension within one month of receipt of the request, together with the reasons for the delay.

If the company does not take action on the request of the data subject, the company shall inform the data subject without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.

The data subject may exercise his rights specified herein free of charge. Where requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character, the controller may either charge a reasonable fee taking into account the administrative costs of providing the information, or refuse to act on the request.

If the purposes for which a controller processes personal data do not or do no longer require the identification of a data subject by the controller, the controller shall not be obliged to maintain, acquire or process additional information in order to identify the data subject for the sole purpose of complying with this Regulation.

Where the controller is able to demonstrate that it is not in a position to identify the data subject, the controller shall inform the data subject accordingly. In such cases, the data subject may not exercise his rights to access, erasure, restriction, notification and data portability, except where the data subject, for the purpose of exercising his or her rights under those articles, provides additional information enabling his or her identification.

Where the company has reasonable doubts concerning the data subject exercising his rights to access, erasure, restriction, notification and data portability, the controller may request the provision of additional information necessary to confirm the identity of the data subject by considering the provisions of the previous paragraph.

5. Purpose of processing, processed data

The company performs processing for the following purposes:

In case of processing related to invoicing, the company processes the names and invoicing addresses of the data subjects for complying with the legal obligation of the controller. The invoices may be transferred to an accountant performing accounting or taxation tasks. The invoices are kept for 8 years.

In case of data processing related to contracting (supplier, buyer) the data subjects are informed of the purpose and legal basis of processing and the duration of processing in the agreement.

The contact persons of agreements are employed by the contracting parties, their contact person assignments are part of their jobs, they shall be informed of this by their employers.

In case of customer service data processing (correspondence, telephone) the data of the contracting partners are processed with the legal basis of performing the contract, on the basis of the consent of the data subject concerning the data processing. We process the data of the customers specified in the agreement, the data of the contact persons and the data provided on the basis of consent, for the term specified in the agreement or until the withdrawal of the consent.

In case of persons performing and participating in company events, photos taken at events, the company offers voluntary participation to its employees. The purpose of processing is to improve workplace cohesion, team building, to improve the company’s image. After providing on-site information, mass photos may be taken of the persons performing and participating in company events, and such photos may be published on the company’s website. For taking and publishing portraits, the consent of the data subject is required. The photos are available on the company’s website for 1 year and then these are archived.

The information related to newsletters is regulated in a separate regulation, which is available on the company’s website prior to subscribing to newsletters.

In case of curriculum vitae, the company shall proceed in accordance with the data privacy policy. In the job advertisement, it shall inform the applicants that consent shall be given as part of the application, otherwise the CV will be destroyed by the company. In case of CVs received without job advertisements, if no consent is included for the processing of data for 3 months, the company is only entitled to check if it has an empty position complying with the application, and if there is no such position, the printed documentation shall be returned to the data subject if he requires so, and the electronic documentation shall be destroyed. The purpose of processing is to select and filter the potential employees of the company, and to ensure continuity in the staff.

INFORMATION CONCERNING THE DATA SUBJECT’S RIGHTS

Summary of the data subject’s rights:

1. Transparent information, communication and modalities for the exercise of the rights of the data subject

2. The right to receive prior information – if the personal data are collected from the data subject

3. Information to be provided to the data subject if the personal data were not obtained from him by the controller

4. Right of access by the data subject

5. Right to rectification

6. Right to erasure (“right to be forgotten”)

7. Right to restriction of processing

8. Notification obligation regarding rectification or erasure of personal data or restriction of processing

9. Right to data portability

10. Right to object

11. Right to object to automated individual decision-making, including profiling

12. Restrictions

13. Communication of a personal data breach to the data subject

14. Right to lodge a complaint with a supervisory authority (right to authority remedy)

15. Right to an effective judicial remedy against a supervisory authority

16. Right to an effective judicial remedy against a controller or processor

For exercising your rights, you may contact the company at the contact details indicated in the section “data related to the controller”.

Details of the data subject’s rights:

1. Transparent information, communication and modalities for the exercise of the rights of the data subject in accordance with Article 12 of the Regulation

The controller shall provide any information and any communication relating to processing to the data subject in a concise, transparent, intelligible and easily accessible form, using clear and plain language, in particular for any information addressed specifically to a child. The information shall be provided in writing, or by other means, including, where appropriate, by electronic means. When requested by the data subject, the information may be provided orally, provided that the identity of the data subject is proven by other means.

The controller shall facilitate the exercise of data subject rights, if which we have provided information above in a separate section.

2. Right to receive prior information – where personal data are collected from the data subject in accordance with Article 13 of the Regulation

This notice aims to provide prior information to the data subjects concerning processing, within the frameworks of which the data subject is entitled to receive information on the facts and information related to processing prior to commencing the data processing. In relation to this, the data subject shall be informed on the following:

- the identity and the contact details of the controller and, where applicable, of the controller's representative,

- the contact details of the data protection officer, where applicable,

- the purposes of the processing for which the personal data are intended as well as the legal basis for the processing,

- where the processing is based on legitimate interest, the legitimate interests pursued by the controller or by a third party,

- the recipients or categories of recipients of the personal data, if any;

- where applicable, the fact that the controller intends to transfer personal data to a third country or international organisation.

In addition to the information referred to above, the controller shall provide the data subject with the following further information necessary to ensure fair and transparent processing:

the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period;
the existence of the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data portability;
where the processing is based on the data subject’s consent, the existence of the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
the right to lodge a complaint with a supervisory authority;
whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the data subject is obliged to provide the personal data and of the possible consequences of failure to provide such data;
the existence of automated decision-making, including profiling, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

Where the controller intends to further process the personal data for a purpose other than that for which the personal data were collected, the controller shall provide the data subject prior to that further processing with information on that other purpose and with any relevant further information.

3. Information to be provided where personal data have not been obtained from the data subject in accordance with Article 14 of the Regulation

Where personal data have not been obtained from the data subject, the data subject shall be informed of the facts and information specified in the previous section 2, of the categories of the concerned personal data, and of the source from which the personal data originate, and if applicable, whether it came from publicly accessible sources, within one month at the latest following the obtaining of his data; if the personal data are used for contacting, at the first time when the company contacts the data subject; if the data are expected to be disclosed to other recipients, at the first time when the personal data are communicated.

The previous section 2 (right to prior information) shall apply to the other regulations.

4. Right of access by the data subject in accordance with Article 15 of the Regulation

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

the e purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
the right to lodge a complaint with a supervisory authority;
where the personal data are not collected from the data subject, any available information as to their source;
the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

The controller shall provide a copy of the personal data undergoing processing if the data subject requests so.

Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.

The company provides the copies of the personal data subject to processing after identifying the data subject. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative cost.

The right to obtain a copy shall not adversely affect the rights and freedoms of others, e.g. the personal data of other parties may not be requested, except for telephone announcements, where the records can be requested.

5. Right to rectification in accordance with Article 16 of the Regulation

The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her, and the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. Data changes, if these are identification data, shall be certified.

Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

6. Right to erasure (“right to be forgotten”) in accordance with Article 17 of the Regulation

The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

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

The right to erasure cannot be exercised to the extent that processing is necessary

for exercising the right of freedom of expression and information;
for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
for reasons of public interest in the area of public health;
for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in so far as the right is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
for the establishment, exercise or defence of legal claims.

7. Right to restriction of processing in accordance with Article 18 of the Regulation

Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.

A data subject shall be informed by the controller before the restriction of processing is lifted.

8. Notification obligation regarding rectification or erasure of personal data or restriction of processing in accordance with Article 19 of the Regulation

The controller shall communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about those recipients if the data subject requests it.

9. Right to data portability in accordance with Article 20 of the Regulation

Right to data portability: cannot be exercised because at the company, no processing is carried out by automated means.

10. Right to object in accordance with Article 21 of the Regulation

The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. This shall not apply to data processing based on consent and legal obligation.

The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

At the latest at the time of the first communication with the data subject, the right shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.

the data subject may exercise his or her right to object by automated means using technical specifications.

Where personal data are processed for scientific or historical research purposes or statistical purposes, the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

11. Automated individual decision-making, including profiling in accordance with Article 22 of the Regulation

The company does not apply automated decision-making, or profiling.

12. Restrictions in accordance with Article 23 of the Regulation

Union or Member State law to which the data controller or processor is subject may restrict by way of a legislative measure the scope of the obligations and rights in so far as its provisions correspond to the rights and obligations, when such a restriction respects the essence of the fundamental rights and freedoms.

13. Communication of a personal data breach to the data subject in accordance with Article 34 of the Regulation

When the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, the controller shall communicate the personal data breach to the data subject without undue delay. The communication to the data subject shall describe in clear and plain language the nature of the personal data breach and contain at least the information and measures:

communicate the name and contact details of the data protection officer or other contact point where more information can be obtained;
describe the likely consequences of the personal data breach;
describe the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.

The communication to the data subject shall not be required if any of the following conditions are met:

the controller has implemented appropriate technical and organisational protection measures, and those measures were applied to the personal data affected by the personal data breach, in particular those that render the personal data unintelligible to any person who is not authorised to access it, such as encryption;
the controller has taken subsequent measures which ensure that the high risk to the rights and freedoms of data subjects referred to in paragraph 1 is no longer likely to materialise;
it would involve disproportionate effort. In such a case, there shall instead be a public communication or similar measure whereby the data subjects are informed in an equally effective manner.

14. Right to lodge a complaint with a supervisory authority (right to authority remedy) in accordance with Article 77 of the Regulation

If you feel that you have suffered any infringement in relation to processing, please indicate this to the controller anytime for settling the situation at the contact details indicated in the section “data related to the controller”.

Every data subject shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes this Regulation. The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy.

Contact details of the National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság):

Registered seat: 1125 Budapest, Szilágyi Erzsébet fasor 22c

Mailing address: 1530 Budapest, Pf.: 5.

Phone: +36 (1) 391-1400

Email: ugyfelszolgalat@naih.hu

Website: www.naih.hu

15. Right to an effective judicial remedy against a supervisory authority in accordance with Article 78 of the Regulation

Without prejudice to any other administrative or non-judicial remedy, each natural or legal person shall have the right to an effective judicial remedy against a legally binding decision of a supervisory authority concerning them.

Without prejudice to any other administrative or non-judicial remedy, each data subject shall have the right to an effective judicial remedy where the supervisory authority which is competent pursuant to Articles 55 and 56 does not handle a complaint or does not inform the data subject within three months on the progress or outcome of the complaint lodged.

Proceedings against a supervisory authority shall be brought before the courts of the Member State where the supervisory authority is established.

Where proceedings are brought against a decision of a supervisory authority which was preceded by an opinion or a decision of the Board in the consistency mechanism, the supervisory authority shall forward that opinion or decision to the court.

16. Right to an effective judicial remedy against a controller or processor in accordance with Article 79 of the Regulation

Without prejudice to any available administrative or non-judicial remedy, including the right to lodge a complaint with a supervisory authority, each data subject shall have the right to an effective judicial remedy where he or she considers that his or her rights under this Regulation have been infringed as a result of the processing of his or her personal data in non-compliance with this Regulation.

Proceedings against a controller or a processor shall be brought before the courts of the Member State where the controller or processor has an establishment. Alternatively, such proceedings may be brought before the courts of the Member State where the data subject has his or her habitual residence, unless the controller or processor is a public authority of a Member State acting in the exercise of its public powers.

Disclaimer:

The company’s websites, and all images, graphics, logo, texts, data and information and the layouts are subject to copyright. It is forbidden to copy, store in electronic or other format, reproduce, transfer, distribute, print or publish any of these in whole or in part – except for the extent required for proper use – without the express prior written consent of the company. Unauthorised use violates the law, and the company may initiate legal proceedings in case of unauthorised use.

Date: Székesfehérvár, 09 March 2020