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Data handling

Privacy notice


Introduction

Holes Ltd. (1047 Budapest, Baross u. 46., hereinafter referred to as the service provider, data controller), as the data controller, acknowledges the contents of this legal notice as binding. It undertakes to ensure that all data processing in relation to its activities complies with the requirements set out in this policy and the applicable legislation.

Holes Ltd reserves the right to change this policy at any time.

It will of course notify its customers of any changes in due time.

If you have a question that is not clear from this notice, please write to us and we will answer it.

Holes Ltd. is committed to protecting the personal data of its customers and partners, and attaches great importance to respecting the right to information self-determination of its customers. Holes Ltd. treats personal data confidentially and takes all security, technical and organisational measures to guarantee the security of the data.

Contact details of the data controller:

Name: Holes Ltd.
Adress: 1047 Budapest, Baross u. 46.
Company registration number: 01 09 076704
VAT number: HU10550984
Phone: +36 1 272 0848
Email: info@holes.hu

Data processing:

Visitor data for the www.holes.hu website

The website is independent from Holes Ltd., which receives traffic from and points to an external server.

The server of the external provider is directly connected to the user's computer. Please be aware that the providers of these links may collect user data due to the direct connection from their server, direct communication with the user's browser.

The independent measurement and auditing of website traffic and other web analytics data is supported by Google Analytics server as an external service provider.More information about Google's data management can be found here: https://policies.google.com/privacy?hl=hu

The website displays so-called embedded videos from YouTube services.

For more information about Youtube's data management, please visit: https://support.google.com/youtube/answer/2801895?hl=hu

The relationship between Holes Ltd. and the above services is limited to the insertion of the latter's code, so no personal data is transferred or transmitted.

The above-mentioned service providers place and read back a small data packet, a so-called cookie, on the user's computer in order to provide a personalised service. If the browser sends back a previously saved cookie, the service provider managing it has the possibility to link the user's current visit to previous visits, but only with regard to its own content.

You can delete the cookie from your computer or disable the use of cookies in your browser. You can usually manage cookies by going to the Tools/Preferences menu of your browser and selecting Privacy settings, and then selecting the cookie or cookie option.

Holes Ltd uses a data processor to operate the website.

  • Activity provided by the data processor: Hosting
  • Name and contact details of the data processor: to be provided upon request.
  • Fact of processing, scope of data processed: all personal data provided by the data subject.
  • Data subjects: all data subjects using the website.
  • Purpose of data processing: to make the website available and to ensure its proper operation.
  • Duration of data processing, time limit for deletion of data: data processing lasts until the termination of the agreement between the data controller and the hosting provider or until the data subject's request for deletion to the hosting provider.
  • The legal basis for the processing of data is Article (1) (c) and (f) and Article 13/A (3) of Act CVIII of 2001 on certain aspects of electronic commerce services and information society services.

Request for quotation

Purpose of data processing: to identify and contact customers interested in the products and services offered by Holes Ltd.

Legal basis for processing: voluntary consent of the data subject

Data processed: date, time, public IP address of the computer used by the user, surname, first name, email, telephone number, address.

Duration of data processing in the case of an offer that does not become an order: 1 year from the last processing

Duration of data processing in the case of an offer that becomes an order: 1 year from the last data processing + legal obligation (8 years pursuant to Section 169 (2) of the Act on Accounting).

Purchase of the products or services marketed

Purpose of data processing: to register and distinguish customers, to fulfil orders, to document purchases and payments, to fulfil accounting obligations, to maintain customer relations.

Legal basis for processing: Legal obligation / legitimate interest

Data processed: first name, surname, email, telephone number, address, job title, contact person, personal data stored in the event manager.

Duration of data processing: 8 years in accordance with Section 169 (2) of the Act on Accounting.

Data processor: computer administrator. Case management software developer. Postal or courier service used to deliver the ordered product.

Customer correspondence

If you have any questions or problems when using our services, please contact us using one of the contact details provided in this leaflet or on the website. Holes Ltd. will delete all incoming e-mails, including the name and e-mail address of the sender and any other personal data voluntarily provided by the sender, after a maximum of 8 years from the date of the communication.

Surveillance camera footage

The purpose of the processing is to protect the property of Holes Ltd, its customers and their assets.

Legal basis for processing: legitimate interest

Data processed: date, time, video recordings of customers and their vehicles.

Duration of processing: 3 days

Other data processing

We inform our customers that the court, the prosecutor, the investigating authority, the criminal investigation authority, the administrative authority, the National Authority for Data Protection and Freedom of Information, or other bodies authorised by law may contact the data controller to provide information, data or documents.

Holes Ltd. shall disclose personal data to public authorities only to the extent and to the extent strictly necessary for the purpose of the request, provided that the public authority has indicated the precise purpose and scope of the data.

Remedies

The data subject may request information (access) about the processing of his or her personal data, as well as the rectification, erasure or restriction of his or her personal data, except for mandatory processing, by the means indicated when the data were collected or by contacting the controller at the contact details indicated.

Complaint possibility

Complaints against possible infringements by the data controller may be lodged with the National Authority for Data Protection and Freedom of Information: 

National Authority for Data Protection and Freedom of Information
1125 Budapest, Szilágyi Erzsébet fasor 22/C.
Postal address: 1530 Budapest, P.O. Box 5. Phone: +36 -1-391-1400
Fax: +36-1-391-1410
E-mail: ugyfelszolgalat@naih.hu

Legal references

The following legislation has been taken into account in the preparation of this leaflet:

  • REGULATION (EU) No 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 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/EC (General Data Protection Regulation)
  • Act CXII of 2011 on the Right to Informational Self-Determination and the
    freedom of information (hereinafter: Infotv.)
  • Act CVIII of 2001 - on certain aspects of electronic commerce services and information society services (in particular § 13/A- a)
  • Act XLVII of 2008 - on the prohibition of unfair commercial practices against consumers;
  • Act XLVIII of 2008 - on the basic conditions and certain restrictions of economic advertising (in particular § 6)
  • Act XC of 2005 on Electronic Freedom of Information
  • Act C of 2003 on Electronic Communications (specifically § 155)
  • Opinion 16/2011 on the EASA/IAB Recommendation on best practice on behavioural online advertising
  • Recommendation of the National Authority for Data Protection and Freedom of Information on the data protection requirements for prior information
  • 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 Regulation (EC) No 95/46/EC