Privacy Policy
Introduction
Italia Gold Kft. (Tax number: 14092453-2-41, company registration number: 01-09-888535) (hereinafter: Service Provider, data controller) submits to the following regulations:
On the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Regulation (EC) No 95/46 (General Data Protection Regulation) REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 27.) we provide the following information.
This data protection policy regulates the data management of the following pages: https://www.pave.hu/
The privacy policy is available at: https://www.pave.hu/ ...
Amendments to the Regulations shall enter into force upon publication at the above address.
Data controller and contact details
Name: Italia Gold Kft
Headquarters: 1051 Budapest, Vigadó utca 4-6.
E-mail: info@pave.hu
Phone: +36 20 535 7947
Concept definitions
"Personal data" means any information relating to an identified or identifiable natural person ("data subject"); identify a natural person who, directly or indirectly, in particular by reference to one or more factors such as name, number, location, online identifier or physical, physiological, genetic, mental, economic, cultural or social identity of the natural person identifiable;
"Data processing" means any operation or set of operations on personal data or files, whether automated or non-automated, such as collecting, recording, organizing, segmenting, storing, transforming or altering, retrieving, viewing, using, transmitting or otherwise transmitting harmonization or interconnection, restriction, deletion or destruction;
"Controller" means the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data; where the purposes and means of the processing are defined by Union or Member State law, the controller or the specific criteria for the designation of the controller may also be determined by Union or Member State law;
"Processor" means any natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller;
"Recipient" means a natural or legal person, public authority, agency or any other body to whom personal data are disclosed, whether a third party or not. Public authorities that may have access to personal data in the framework of an individual investigation in accordance with Union or Member State law shall not be considered as recipients; the processing of such data by those public authorities must comply with the applicable data protection rules in accordance with the purposes of the processing;
"Consent of the data subject" means the voluntary, specific and well-informed and clear expression of the will of the data subject to indicate his or her consent to the processing of personal data concerning him or her by means of a statement or unambiguous statement of consent;
"Data protection incident" means a breach of security resulting in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or unauthorized access to, personal data which are transmitted, stored or otherwise handled.
Principles governing the processing of personal data
Personal information:
be processed lawfully and fairly and in a manner that is transparent to the data subject ("legality, fairness and transparency");
collected only for specified, explicit and legitimate purposes and not treated in a way incompatible with those purposes; further processing for data purposes for archiving purposes in the public interest, for scientific and historical research purposes or for statistical purposes ("purpose limitation") shall not be considered incompatible with the original purpose in accordance with Article 89 (1);
they must be appropriate, relevant and limited to what is necessary for the purposes of the processing ("data saving");
they must be accurate and, where necessary, kept up to date; all reasonable steps must be taken to ensure that personal data which are inaccurate for the purposes of data processing are erased or rectified without delay ("accuracy");
it must be stored in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for a longer period only if the processing of personal data is carried out in accordance with Article 89 (1) for archiving in the public interest, for scientific and historical research purposes or for statistical purposes, in accordance with this Regulation; subject to the implementation of appropriate technical and organizational measures to protect their freedoms ("limited storage");
shall be handled in such a way as to ensure the adequate security of personal data, including protection against unauthorized or unlawful processing, accidental loss, destruction or damage to personal data ("integrity and confidentiality"), using appropriate technical or organizational measures.
The controller is responsible for compliance with the above and must be able to demonstrate such compliance ("accountability").
The data controller declares that the data is processed in accordance with the principles set out in this section.
Data management related to the operation of the website / use of the service
The fact of data collection, the scope of data processed and the purpose of data management:
Personal data
Surname and first name
To contact, it is not necessary to enter.
E-mail address
Contact, receive newsletter
Stakeholders: All stakeholders registered on the website and registered in the store.
Duration of data processing, deadline for deletion of data: If one of the conditions set out in Article 17 (1) of the GDPR is met, it lasts until the data subject requests the deletion. The controller shall inform the data subject electronically in accordance with Article 19 of the GDPR of the deletion of any personal data provided by the data subject. If the data subject's request for cancellation includes the e-mail address provided by the data subject, the data controller will also delete the e-mail address after the notification. Except in the case of accounting documents, as this information must be kept for 8 years in accordance with Section 169 (2) of Act C of 2000 on Accounting. The data subject's contractual data may be deleted after the expiry of the civil limitation period on the basis of the data subject's request for cancellation.
Identity of potential data controllers entitled to access the data, recipients of personal data: Personal data may be processed by the data controller and its sales and marketing staff, in compliance with the above principles.
Description of data subjects' rights in relation to data processing:
The data subject may request the controller to access, rectify, delete or restrict the processing of personal data concerning him or her, and the data subject shall have the right to data portability and to withdraw consent at any time. 6. The data subject may initiate access to, deletion, modification or restriction of the processing of personal data in the following ways:
by post at 1051 Budapest, Vigadó utca 4-6. at,
by e-mail to the e-mail address info@pave.hu ,
by phone on +36 20 535 7947 .
Legal basis for data management:
Article 6 (1) (b) and (c) of the GDPR,
Act CVIII of 2001 on certain aspects of electronic commerce services and information society services. Act (hereinafter: Elker Act) 13 / A. § (3):
The service provider may process personal data that is technically necessary for the provision of the service in order to provide the service. If the other conditions are the same, the service provider must choose and in all cases operate the means used in the provision of the information society service in such a way that the processing of personal data takes place only if it is necessary for the provision of the service and other purposes specified in this Act. necessary, but in this case only to the extent and for the time necessary.
Management of cookies
The so-called "cookies used for the password-protected session", "cookies required for the shopping cart", "security cookies", "required cookies", "functional cookies" and "cookies responsible for managing website statistics" prior consent of the data subject is not required for its use.
The fact of data management, the scope of the processed data: Unique identification number, dates, times
Stakeholders: All stakeholders who visit the website.
The purpose of data management is to identify users and track visitors.
Duration of data management, deadline for deleting data:
Cookie type
Legal basis for data management
Duration of data management
Session cookie
2001 CVIII on certain issues in electronic commerce services and information society services. Act (Elkertv.) 13 / A. § (3)
The period until the end of the relevant visitor session
Permanent or saved cookies
2001 CVIII on certain issues in electronic commerce services and information society services. Act (Elkertv.) 13 / A. § (3)
until the data subject is deleted
Statistical cookies
2001 CVIII on certain issues in electronic commerce services and information society services. Act (Elkertv.) 13 / A. § (3)
1 month - 2 years
Identity of potential data controllers entitled to access the data: The data controller does not process personal data using cookies.
Description of the data management rights of the data subjects: The data subject has the possibility to delete cookies in the Tools / Settings menu of the browser, usually under the settings of the Privacy menu item.
Legal basis for data processing: The consent of the data subject is not required if the sole purpose of the use of cookies is the transmission of communications via an electronic communications network or the provision of an information society service specifically requested by the subscriber or user.
Most browsers used by our users allow you to set which cookies to save and allow (specific) cookies to be deleted again. If you restrict the storage of cookies on certain websites or do not allow third-party cookies, this may in certain circumstances mean that our website can no longer be used in its entirety. Here's how to customize your cookie settings for standard browsers:
Google Chrome (https://support.google.com/chrome/answer/95647?hl=en_US)
Internet Explorer (https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies)
Firefox (https://support.mozilla.org/en/kb/sutik-engedelyezese-es-tiltasa-amit-weboldak-haszn
Safari (https://support.apple.com/kb/PH21411?locale=en_US)
Use Google Ads Conversion Tracking
An online advertising program called "Google Ads" is used by the data controller and uses Google's conversion tracking service. Google Conversion Tracking is an analytics service provided by Google Inc. (1600 Amphitheater Parkway, Mountain View, CA 94043, USA; "Google"). When a User accesses a website through a Google ad, a cookie is placed on their computer to track conversions. These cookies have a limited validity and do not contain any personal data, so the User cannot be identified by them. When the User browses certain pages of the website and the cookie has not expired, both Google and the data controller may see that the User has clicked on the advertisement. Each Google Ads customer receives a different cookie, so they cannot be tracked through Ads customers' websites. The information obtained through conversion tracking cookies is used to generate conversion statistics for Ads conversion tracking customers. This is how customers find out the number of users who clicked on your ad and sent it to the page labeled conversion tracking. However, they do not have access to information that could identify any user. If you do not wish to participate in conversion tracking, you can disable it by disabling cookies in your browser. You will then not be included in your conversion tracking statistics. For more information and Google's privacy statement, visit www.google.de/policies/privacy/
Use Google Analytics
This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses so-called "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie associated with a website used by you is usually stored and stored on a Google server in the United States. By activating IP anonymization on the Website, Google will shorten the User's IP address within the European Union or in other states party to the Agreement on the European Economic Area. The full IP address will only be transmitted and truncated to Google's server in the United States. On behalf of the operator of this website, 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. Google Analytics does not reconcile the IP address transmitted by the User's browser with any other data held by Google. The User may prevent the storage of cookies by setting their browser appropriately, however, please note that in this case, not all functions of this website may be fully used. You may also prevent Google from collecting and processing your information about your use of the Website (including your IP address) by cookies by downloading and installing the browser plugin available at the following link. https://tools.google.com/dlpage/gaoptout?hl=en_US
Newsletter, DM activity
Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Commercial Advertising Pursuant to Section 6 of the Act, the User may consent in advance and expressly to contact the Service Provider with the advertising offers and other items provided at the time of registration.
Furthermore, the Customer may consent to the processing of the personal data of the Service Provider necessary for the sending of advertising offers, keeping in mind the provisions of this prospectus.
The Service Provider does not send unsolicited advertising messages, and the User may unsubscribe from sending offers free of charge without restriction or justification. In this case, the Service Provider will delete all personal data - necessary for sending advertising messages - from its register and will not contact the User with its further advertising offers. The user can unsubscribe from the ads by clicking on the link in the message.
The fact of data collection, the scope of data processed and the purpose of data management:
Personal data
Purpose of data management
Legal basis
Name, email address
Identification, allowing you to subscribe to the newsletter / promotions.
Consent of the data subject, Article 6 (1) (a). Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Commercial Advertising Section 6 (5) of the Act.
Date of subscription
Perform a technical operation.
Consent of the data subject, Article 6 (1) (a). Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Commercial Advertising Section 6 (5) of the Act.
The IP address at the time of subscription
Perform a technical operation.
Consent of the data subject, Article 6 (1) (a). Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Commercial Advertising Section 6 (5) of the Act.
Stakeholders: All stakeholders who subscribe to the newsletter.
The purpose of data management: to send electronic messages containing advertising (e-mail, sms, push message) to the data subject, to provide information about current information, products, promotions, new features, etc.
Duration of data processing, deadline for deleting data: data processing lasts until the withdrawal of the consent statement, ie until unsubscription.
Identity of potential data controllers entitled to access the data, recipients of personal data: Personal data may be processed by the data controller and its sales and marketing staff, in compliance with the above principles.
Description of data subjects' rights in relation to data processing:
The data subject may request the controller to access, rectify, delete or restrict the processing of personal data concerning him or her, to object to the processing of his or her personal data and to have the right to data portability and to withdraw consent at any time. 10. The data subject may initiate access to, deletion, modification or restriction of the processing of personal data, portability or protest in the following ways:
by post at 1051 Budapest, Vigadó utca 4-6. at,
by e-mail to the e-mail address info@pave.hu ,
by phone on +36 20 535 7947 .
The person concerned can unsubscribe from the newsletter at any time, free of charge.
We inform you that
data management is based on your consent and the legitimate interest of the service provider.
you are required to provide personal information if you wish to receive a newsletter from us.
Failure to provide this will result in us not being able to send you a newsletter.
we inform you that you can withdraw your consent at any time by clicking on unsubscribe.
the withdrawal of consent shall not affect the lawfulness of the data processing based on consent prior to the withdrawal.
Recipients to whom personal information is disclosed
"Recipient" means a natural or legal person, public authority, agency or any other body to whom personal data are disclosed, whether a third party or not.
Data processors (who process the data on behalf of the data controller)
The data controller uses data processors in order to facilitate its own data management activities and to fulfill its contractual or legal obligations with the data subject.
The controller places great emphasis on using only data controllers who provide adequate guarantees to implement appropriate technical and organizational measures to ensure compliance with the requirements of data processing in the GDPR and to protect the rights of data subjects.
The data processor and any person with access to personal data acting under the control of the data controller or the data processor shall process the personal data contained in these regulations only in accordance with the instructions of the data controller.
The data controller is legally responsible for the activities of the data processor. The data controller shall only be liable for damages caused by the data processing if it has not complied with the obligations specified in the GDPR, which are specifically imposed on the data processors, or if it has disregarded or acted contrary to the data controller's lawful instructions.
The data processor does not have a meaningful decision regarding the handling of the data.
The data controller may use a hosting provider to provide the IT storage and a courier service as a data processor to deliver the ordered products.
3. Transfer of data to third parties
"Third party" means any natural or legal person, public authority, agency or any other body which is not the data subject, the controller, the processor or the persons who are authorized to process personal data under the direct control of the controller or processor; they got;
Third-party data controllers process the personal data we provide on their own behalf and in accordance with their own privacy policies.
Community sites
The fact of data collection, the range of data managed: Facebook / Twitter / Pinterest / Youtube / Instagram, etc. the name registered on social networking sites or the user's public profile picture.
Stakeholders: All stakeholders who have registered on Facebook / Twitter / Pinterest / Youtube / Instagram, etc. social sites and “liked” the Service Provider's social site or contacted the data controller via the social site.
The purpose of data collection: To share, “like”, follow and promote certain content elements, products, promotions or the website itself on social media sites.
Duration of data processing, deadline for deletion of data, identity of potential data controllers entitled to access the data and data subjects' rights related to data processing: The data subject may be informed about the source of the data, their processing and the legal basis. Data management is carried out on social networking sites, so the duration and method of data management, as well as the possibilities of deleting and modifying data are regulated by the given social networking site.
Legal basis for data processing: the voluntary consent of the data subject to the processing of his or her personal data on social networking sites.
Customer relations and other data management
Should the data subject have any questions or problems during the use of our data management services, he / she may contact the data controller in the ways provided on the website (telephone, e-mail, social networking sites, etc.).
Data controller for incoming emails, messages, phone, Facebook, etc. will delete the data provided together with the name and e-mail address of the interested party and any other personal data voluntarily provided after a maximum of 2 years from the disclosure.
Information on data processing not listed in this prospectus will be provided at the time of data collection.
Upon exceptional official request, or in case of requesting other bodies based on the authorization of legal regulations, the Service Provider is obliged to provide information, disclose data, or make documents available.
In these cases, the Service Provider will provide the requester with personal data only to the extent and to the extent that is absolutely necessary to achieve the purpose of the request, provided that it has indicated the exact purpose and scope of the data.
Rights of data subjects
1. Right of access
You have the right to receive feedback from the controller as to whether the processing of your personal data is in progress and, if such processing is in progress, you have the right to access the personal data and information listed in the Regulation.
2. Right to rectification
You have the right, at the request of the data controller, to correct inaccurate personal data concerning you without undue delay. Taking into account the purpose of the data processing, you have the right to request that the incomplete personal data be supplemented, inter alia, by means of an additional statement.
3. Right of cancellation
You have the right to have your personal data deleted without undue delay at your request, and the data controller is obliged to delete your personal data without undue delay under certain conditions.
4. The right to be forgotten
If the controller has disclosed the personal data and is obliged to delete it, it shall take reasonable steps, including technical measures, taking into account the available technology and the cost of implementation, to inform the controllers that you have requested the personal data in question. deleting links or copies or duplicates of such personal data.
5. Right to restrict data processing
You have the right, at the request of the controller, to restrict the processing of data if one of the following conditions is met:
You dispute the accuracy of your personal information, in which case the restriction applies to the period of time that allows the controller to verify the accuracy of your personal information;
the processing is unlawful and you oppose the deletion of the data and instead request a restriction on its use;
the data controller no longer needs the personal data for the purpose of data processing, but you request them in order to submit, enforce or protect legal claims;
You objected to the data processing; in this case, the restriction applies for as long as it is established whether the legitimate reasons of the controller take precedence over your legitimate reasons.
6. The right to data portability
You have the right to receive personal data about you provided by you to a data controller in a structured, widely used machine-readable format and to transfer this data to another data controller without being hindered by the data controller whose provided personal data to him (...)
7. Right to protest
In the case of data processing based on a legitimate interest or a right of public authority as a legal basis, you have the right to object at any time to the processing of your personal data (...), including profiling based on these provisions, for reasons related to your situation.
8. Protest in the case of a direct acquisition
If personal data is processed for the purpose of direct business acquisition, you have the right to object at any time to the processing of personal data concerning you for this purpose, including profiling, insofar as it relates to direct business acquisition. If you object to the processing of personal data for the purpose of direct business acquisition, the personal data may no longer be processed for this purpose.
9. Automated decision making in individual cases, including profiling
You have the right not to be covered by a decision based solely on automated data processing, including profiling, which would have legal effect or similar effect on him or her.
The preceding paragraph shall not apply if the decision:
Necessary for the conclusion or performance of a contract between you and the data controller;
EU or Member State law applicable to the controller, which also lays down appropriate measures to protect your rights and freedoms and legitimate interests; obsession
It is based on your express consent.
Deadline for action
The controller shall inform you without undue delay, but in any case within 1 month of receipt of the request, of the action taken on the above requests.
If necessary, it can be extended by 2 months. The data controller shall inform you of the extension of the deadline within 1 month from the receipt of the request, indicating the reasons for the delay.
If the controller does not take action on your request, it will inform you without delay, but no later than one month after receipt of the request, of the reasons for the non-action and of the fact that you can lodge a complaint with a supervisory authority and have recourse to the courts.
Security of data management
The controller and the processor shall take appropriate technical and organizational measures to take into account the state of the art and the costs of implementation and the nature, scope, circumstances and purposes of the processing and the varying probability and severity of the risk to the rights and freedoms of natural persons. to ensure a level of data security appropriate to the degree of risk, including, where appropriate:
pseudonymisation and encryption of personal data;
ensuring the continued confidentiality, integrity, availability and resilience of the systems and services used to process personal data;
in the event of a physical or technical incident, the ability to restore access to and availability of personal data in a timely manner;
a procedure for regular testing, assessment and evaluation of the effectiveness of the technical and organizational measures taken to ensure the security of data processing.
The processed data must be stored in such a way that they cannot be accessed by unauthorized persons. In the case of paper-based data carriers, by establishing the order of physical storage and archiving, in the case of data processed in electronic form, by applying a central rights management system.
The method of storing the data by IT must be chosen in such a way that it can be erased at the end of the erasure period or, if necessary for other reasons, in view of any different erasure periods. Deletion must be irreversible.
Paper-based media must be stripped of personal data with the help of a shredder or an external shredder. In the case of electronic media, the rules on the disposal of electronic media shall ensure that they are physically destroyed and, where necessary, that the data is erased in a secure and irreversible manner.
The data controller shall take the following specific data security measures:
In order to ensure the security of personal data processed on paper, the Service Provider applies the following measures (physical protection):
Store documents in a safe, lockable, dry room.
Where personal data processed on paper are digitized, the rules governing digitally stored documents shall apply.
The employee of the Service Provider performing data management may only leave the room where data management is taking place by closing the data carriers entrusted to him or her or closing the given room.
Personal data may only be accessed by authorized persons and may not be accessed by third parties.
The building and premises of the Service Provider are equipped with fire protection and property protection equipment.
IT protection
The computers and mobile devices (other data carriers) used in the data management are the property of the Service Provider.
The computer system containing the personal data used by the Service Provider is equipped with virus protection.
In order to ensure the security of digitally stored data, the Service Provider uses data backups and archiving.
The central server machine can only be accessed by duly authorized persons.
Data on computers can only be accessed with a username and password.
Informing the data subject about the data protection incident
If the data protection incident is likely to pose a high risk to the rights and freedoms of natural persons, the controller shall inform the data subject without undue delay.
The information provided to the data subject shall clearly and intelligibly describe the nature of the data protection incident and the name and contact details of the data protection officer or other contact person for further information; the likely consequences of the data protection incident must be described; a description of the measures taken or planned by the controller to remedy the data protection incident, including, where appropriate, measures to mitigate any adverse consequences arising from the data protection incident.
The data subject need not be informed if any of the following conditions are met:
the controller has implemented appropriate technical and organizational protection measures and these measures have been applied to the data affected by the data protection incident, in particular measures such as the use of encryption which make it incomprehensible to persons not authorized to access personal data; data;
the controller has taken additional measures following the data protection incident to ensure that the high risk to the data subject's rights and freedoms is no longer likely to materialize;
the information would require a disproportionate effort. In such cases, the data subject shall be informed through publicly available information or a similar measure shall be taken to ensure that the data subject is equally effectively informed.
If the data controller has not yet notified the data subject of the data protection incident, the supervisory authority may, after considering whether the data protection incident is likely to involve a high risk, order the data subject to be informed.
Report a privacy incident to the authority
The data protection incident shall be reported by the controller to the competent supervisory authority in accordance with Article 55 without undue delay and, if possible, no later than 72 hours after becoming aware of the data protection incident, unless the data protection incident is not likely to endanger the rights of individuals. and its freedoms. If the notification is not made within 72 hours, the reasons for the delay must be provided.
Review in case of mandatory data management
If the duration of the mandatory data processing or the periodic review of its necessity is not specified by law, a local government decree or a binding legal act of the European Union, the data controller shall review at least every three years whether the data controller whether the processing of personal data is necessary for the purpose of data processing.
The conditions and results of this review shall be documented by the controller, which shall retain this documentation for a period of ten years after the review and shall make it available to the Authority upon request.
Possibility to complain
Complaints against possible breaches of the data controller can be made to the National Data Protection and Freedom of Information Authority:
National Data Protection and Freedom of Information Authority
1125 Budapest, Szilágyi Erzsébet avenue 22 / C.
Mailing address: 1530 Budapest, Mailbox: 5.
Phone: +36 -1-391-1400
Fax: + 36-1-391-1410
E-mail: ugyfelszolgalat@naih.hu
Closing remarks
During the preparation of the prospectus, we complied with the following legislation:
On the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Regulation (EC) No 95/46 (General Data Protection Regulation) REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (GDPR) ( April 27, 2016)
2011 CXII. Act on the Right to Self-Determination of Information and Freedom of Information (hereinafter: the Information Act)
CVIII of 2001 Act - on certain issues of electronic commerce services and services related to the information society (mainly Section 13 / A)
XLVII of 2008 Act on the Prohibition of Unfair Commercial Practices for Consumers;
XLVIII of 2008 Act - on the basic conditions and certain restrictions of commercial advertising (especially § 6a)
2005 XC. Electronic Freedom of Information Act
Act C of 2003 on Electronic Communications (specifically § 155a)
16/2011 s. Opinion on the EASA / IAC Recommendation on Best Practice for Behavioral Online Advertising
Recommendation of the National Authority for Data Protection and Freedom of Information on data protection requirements for prior information