Privacy Policy - Voxinfo Kft.

Introduction

Voxinfo Kft. (1037 Budapest, Bécsi út 269) Tax number: 12180439-2-41, Company registration number: 01-09- 562739 (hereinafter referred to as the "Service Provider" or "Controller") hereby considers itself to be bound by the following policy:

On the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and on the repealing of Regulation (EC) No 95/46/EC (General Data Protection Regulation), the following information is provided under Regulation (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016.

This Privacy Policy applies to the processing of data on the following sites and services: the VoxPay mobile app: www.voxpay.hu, www.autopalyamatrica.hu.

VoxPay Service: VoxPay mobile app, www.voxpay.hu Website and www.autopalyamatrica.hu Website collectively.

The present Privacy Policy may be amended unilaterally by Voxinfo Ltd. at any time. This Privacy Policy is made available on the www.voxpay.hu website and is also accessible in the VoxPay Application as well as on the www.autopalyamatrica.hu website. Any amendments to this policy shall be deemed to enter into force upon being published on the above website.

The controller and its contact details:
Name: Voxinfo Kft.
Registered office: 1037 Budapest, Bécsi út 269
E-mail: info@voxinfo.hu
Phone: +36-1-225-7603

Definitions of terms

"personal data" means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

"processing" means any operation or set of operations which is performed upon personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure 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 such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

"processor" means a 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 which personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;

"consent of the data subject" means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

"personal data breach" means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Principles relating to processing of personal data

Personal data shall be

a) processed lawfully, fairly and in a transparent manner in relation to the data subject ("lawfulness, fairness and transparency”);
b) collected only for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes ("purpose limitation”);
c) be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed ("data minimisation”);
d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay ("accuracy”);
e) kept 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 longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject ("storage limitation");
f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage using appropriate technical or organisational measures ("integrity and confidentiality").

The controller shall be responsible for, and be able to demonstrate compliance with the above terms. ("accountability").

The controller declares that the processing is carried out in accordance with the principles set out in this section.

Scope of data processing

Registration - voxpay service

The fact of data collection, the scope of the data processed and the purposes of the processing:

Personal data - from the data subject	Purpose of data processing
E-mail address *	Maintaining contact, sending system messages, login to user account
Phone number for notification	Identification, contact details
Vehicle’s registration number	Performance of the service
Password *	For secure access to the user account
Invoicing name and address	The issuing of invoices in the proper manner, as well as the creation, definition of the content, modification, monitoring of the performance of the contract, invoicing of the fees resulting from it, and the enforcement of claims related to it.
Date of registration *	Performing technical operation.
IP address at the time of registration *	Performing technical operation.

Data marked with * are mandatory for registration
In the case of the e-mail address, it is not necessary to include personal data.

Scope of data subjects: all data subjects making use of the VoxPay Service.

Duration of data processing, deadline for deletion of data: until the request for deletion by the data subject. The personal data are immediately deleted upon deletion of the registration. The controller shall inform the data subject pursuant to Article 19 of the GDPR by electronic means of the deletion of any personal data provided by the data subject. In case the data subject's request for erasure extends to the e-mail address provided by the data subject, the controller shall also erase the e-mail address after the notification.

Potential controllers entitled to access the data, recipients of personal data: personal data may be processed by authorised staff of the controller on the conditions set out in this notice.

Details of data subjects' rights in connection with data processing:

The data subject concerned has the right to request the controller to access, rectify, erase or restrict the processing of personal data relating to him or her, and
the data subject concerned is entitled to data portability and the right to withdraw consent at any time.

The data subject may initiate the access, deletion, modification or restriction of the processing of personal data, or the portability of data in the following ways:

by sending a letter to Voxinfo Kft. at the address 1 Miklós tér, 1035 Budapest, 1035 Budapest,
by sending an e-mail to ugyfelszolgalat@voxpay.hu

Legal basis for data processing: consent of the data subject, Article 6(1)(b).

Please be informed that

the processing serves the purpose of taking steps at your request prior to the conclusion of the contract.
You are obliged to provide personal data so we can register you.
failing to provide the data has the consequence that we will not be able to create the user account.

Data processing in connection with the operation of the VoxPay Service

The fact of data collection, the scope of the data processed and the purpose of the processing:

Personal data - from the data subject	Purpose of data processing
Password *	For secure access to the user account
First and last name	It is necessary for contacting, purchasing and issuing invoice in the proper manner.
Vehicle’s registration number *	Performance of the service
E-mail address *	Maintaining contact, sending confirmations
Phone number	Performance of the service. Maintaining contacts, more efficient coordination of invoicing or delivery issues
Invoicing name and address	The issuing of invoices in the proper manner, as well as the creation, definition of the content, modification, monitoring of the performance of the contract, invoicing of the fees resulting from it, and the enforcement of claims related to it.
Date of purchase/registration *	Performing technical operation.
IP address at the time of purchase/registration *	Performing technical operation.

The data marked with * are mandatory, without it it is not possible to use the VoxPay Service

Parking service:

Personal data - from the data subject	Purpose of data processing
Vehicle’s registration number *	Performance of the service
Location of parking *	Performance of the service
Details of the parking ticket purchased (zone code, expiry date) *	Performance of the service

The data marked with * are mandatory, without it it is not possible to use the VoxPay Service

e-Vignette purchase

Personal data - from the data subject	Purpose of data processing
Registration number *	Performance of the service
Type of vehicle *	Performance of the service
Details of the E-vignette purchased (type, validity period) *	Performance of the service

The data marked with * are mandatory, without it it’s not possible to use the VoxPay Service

e-Vignette validity query:

Personal data - from the data subject	Purpose of data processing
E-mail address *	Performance of the service
Vehicle’s registration number *	Performance of the service

The data marked with * are mandatory, without it it’s not possible to use the VoxPay Service

No personal data is required for either the username or the e-mail address.

Scope of data subjects: all data subjects making use of the VoxPay Service.

Duration of processing, time limit for erasure of data: if any of the conditions of Article 17(1) of the GDPR apply, it lasts until the data subject's request for erasure. The controller shall inform the data subject pursuant to Article 19 of the GDPR by electronic means of the deletion of any personal data provided by the data subject. In case the data subject's request for erasure extends to the e-mail address provided by the data subject, the controller shall also erase the e-mail address after the notification. An exception is made in the case of accounting documents, since pursuant to Article 169 (2) of Act C of 2000 on Accounting, these data must be kept for 8 years. The contractual data of the data subject may be erased after the expiry of the civil liability limitation period.

Accounting documents for direct and indirect support of the accounting records (including general ledger statements, analytical and detailed records) must be kept for a minimum period of 8 years in a legible form, which can be retrieved by reference to the accounting records.

Potential controllers entitled to access the data, recipients of personal data: Personal data may be processed by the sales and marketing personnel of the controller, in full compliance with the principles set out above.

Details of data subjects' rights in connection with data processing:

The data subject concerned has the right to request the controller to access, rectify, erase or restrict the processing of personal data relating to him or her, and
the data subject concerned is entitled to data portability and the right to withdraw consent at any time.

The data subject may initiate the access, deletion, modification or restriction of the processing of personal data, or the portability of data in the following ways:

by sending a letter to Voxinfo Kft. at the address1037 Budapest Bécsi út 269.,
by sending an e-mail to ugyfelszolgalat@voxpay.hu

Legal basis for data processing:

1. Article 6(1)(b) and (c) of the GDPR,

2. Section 13/A (3) of Act CVIII of 2001 on Certain Aspects of Electronic Commerce and on Information Society Services (hereinafter: Elker Act):

The service provider may process personal data that are in a technical context indispensable for the provision of the service. Provided that the other conditions are identical, the service provider shall choose and in any event manage the means used to provide the information society service so that personal data are processed only insofar as is strictly necessary for the provision of the service and for the fulfilment of the other purposes laid down in this Act, but even in this case only to the necessary extent and for the necessary period.

3. In the case of issuing an invoice in conformity with accounting legislation, pursuant to Article 6(1)(c).

4. In the event of enforcement of claims resulting from the contract, 5 years pursuant to § 6:21 of Act V of 2013 on the Civil Code.

6:22. § [Statute of limitations]

(1) Unless otherwise provided for in this Act, claims shall lapse after five years.

(2) The period of limitation commences upon the due date of the claim.

(3) An agreement for changing the limitation period shall be executed in writing.

(4) Any agreement excluding prescription shall be null and void.

Contact

The fact of data collection, the scope of the data processed and the purpose of the processing:

Personal data	Purpose of data processing
Name *	Identification
E-mail address *	Maintaining contact, sending reply messages
Vehicle’s registration number *	Performance of the service
Phone number *	For contacting
Content of message *	Required to reply
Date of making contact	Performing technical operation.
IP address used when contacting	Performing technical operation

Data marked with * are mandatory.

In the case of the e-mail address, it is not necessary to include personal data.

Scope of data subjects: all data subjects submitting a message via the contact form.

Duration of processing, time limit for erasure of data: if any of the conditions of Article 17(1) of the GDPR apply, it lasts until the data subject's request for erasure.

Potential controllers entitled to access the data, recipients of personal data: personal data may be processed by authorised staff of the controller.

Details of data subjects' rights in connection with data processing:

The data subject concerned has the right to request the controller to access, rectify, erase or restrict the processing of personal data relating to him or her, and
the data subject concerned is entitled to data portability and the right to withdraw consent at any time.

The data subject may initiate the access, deletion, modification or restriction of the processing of personal data, or the portability of data in the following ways:

by sending a letter to Voxinfo Kft. at the address1037 Budapest Bécsi út 269.,
by sending an e-mail to ugyfelszolgalat@voxpay.hu

Legal basis for data processing: the consent of the data subject, Article 6(1)(a)(b) and (c). When you contact us, you agree to the processing of your personal data (name, telephone number, e-mail address) that we have received from you in the course of the contact in accordance with this policy.

Please note that

present data processing is carried out on the basis of your consent or, it is necessary for the purposes of making an offer or in the case of a contractual relationship, on the basis of a legal obligation (cooperation).
You are obliged to provide personal data in order to be able to contact us.
failing to provide the data will have the consequence that you will not be able to contact the Service Provider.

Customer relationship

The fact of data collection, the scope of the data processed and the purpose of the processing:

Personal data	Purpose of data processing
Name, e-mail address, phone number, vehicle’s registration number.	Communication, identification, fulfilling contracts, business purpose.

Scope of data subjects: all data subjects having contact with the data controller by phone/e-mail/personally or having a contractual relationship with the data controller.

Duration of data processing, deadline for deletion of data: data processing lasts until the termination of the legal relationship between the controller and the data subject or, in the event of a contractual relationship, until the expiry of the limitation period under civil law.

Potential controllers entitled to access the data, recipients of personal data: Personal data may be processed by the authorized personnel of the controller, in full compliance with the principles set out above.

Details of data subjects' rights in connection with data processing:

The data subject concerned has the right to request the controller to access, rectify, erase or restrict the processing of personal data relating to him or her, and
the data subject concerned is entitled to data portability and the right to withdraw consent at any time.

The data subject may initiate the access, deletion, modification or restriction of the processing of personal data, or the portability of data in the following ways:

by sending a letter to Voxinfo Kft. at the address1037 Budapest Bécsi út 269.,
by sending an e-mail to ugyfelszolgalat@voxpay.hu

Legal basis for data processing:

7.1. Article 6(1)(b) and (c) of the GDPR.

7.2. The limitation period for the enforcement of claims resulting from the contract is 5 years pursuant to § 6:21 of Act V of 2013 on the Civil Code.

6:22. § [Statute of limitations]

(1) Unless otherwise provided for in this Act, claims shall lapse after five years.

(2) The period of limitation commences upon the due date of the claims.

(3) An agreement for changing the limitation period shall be executed in writing.

(4) Any agreement excluding prescription shall be null and void.

Please note that

data processing is necessary for the purposes of performing contract and making an offer.
You are obliged to provide personal data to enable us to fulfil your order/other request.
failing to provide the data will have the consequence that we will not be able to process your order/request.

System message by e-mail or push message

The VoxPay Service sends system messages to its Users. A system message is defined as any message related to the operation of the VoxPay Service, possible service outages, maintenance, the functions of the VoxPay Service, changes to its existing and new functions, new functions, the range of services available through the VoxPay Service and the way in which they can be used, the General Terms of Use, the Privacy Policy or any modifications thereto, the rights and obligations of Users in relation to the VoxPay Service, and the services used, including confirmation messages, verifications, notifications, confirmatory messages, electronic receipts, invoices, etc. sent for each service used.

The VoxPay Service performs the following data processing to send the System Message:

Personal data from the data subject	Purpose of data processing
e-mail address *	Performance of the service
For push message VoxPay account *	Performance of the service

The data marked with * are mandatory, the system message cannot be sent without them. Legal basis for processing: Article 6(1)(b) of GDPR

Sending an invitaion

The fact of data collection, the scope of the data processed and the purpose of the processing:

Personal data	Purpose of data processing
e-mail address	Sending an invitation

You are allowed to send to the e-mail address of third parties not registered in the VoxPay Service (hereinafter: Recipient) whose e-mail address is known to you, messages, recommendations, invitations (hereinafter: Invitation) in that you encourage, recommend, promote, invite to try the VoxPay Service and all or part of the services available therein.

When sending such an Invitation, you will provide the email address of the Recipient in the dedicated interface of the VoxPay Service.

By Invitation Sending, you accept that only the name and email address of such a Recipient may be entered into the function Invitation Sending, and that you may only send an Invitation to a person from whom you have previously requested permission to use his or her name and email address for such Invitation Sending. We assume no liability if you fail to obtain the Recipient's consent to the sending of the Invitation, nor do we assume any liability if you have provided the Recipient's name or e-mail address incorrectly. By sending the Invitation, you authorise us to send the Invitation to the designated Recipient on your behalf and in your name, in such a way that due to technical reasons the VoxPay Service is indicated as the sender of the Invitation, the Invitation sent will be considered a message sent by you and not by us, and the content included in the Invitation sent will not be considered an offer, advertisement or other direct marketing communication made by us.

The personal data of the Recipient party that you have provided, i.e. the name and e-mail address of the recipient, will only be managed for the purpose of sending the Invitation to the Recipient.

The data processors involved

Payment system

SimplePay credit card payment provider: OTP Mobil Kft.
Registered office: 1143 Budapest, Hungária krt. 17-19.
Company registration number: 01-09-174466
Tax number: 24386106-2-42

I hereby acknowledge that the following personal data of me stored by Voxinfo Kft. 1037 Bécsi út 269 in the user database of the VoxPay Service (VoxPay mobile application, www.voxpay.hu, www.autopalyamatrica.hu) will be transferred to OTP Mobil Kft. as the data processor.

The data transmitted by the data controller are as follows: name, e-mail address, invoicing data. The nature and purpose of the data processing activities carried out by the data processor can be viewed in the SimplePay Privacy Policy available at the following link: https://simplepay.hu/vasarlo-aff

Barion Payment Zrt. credit card payment service provider

I acknowledge that the following personal data of me, which is stored in the user database of the data controller Voxinfo Kft. 1037 Bécsi út 269 út www.autopalyamatrica.hu, will be forwarded to Barion Payment Zrt. as the data processor. The scope of data transmitted by the data controller is as follows: name, e-mail address, billing data. Barion Payment Zrt. performs the payment service as a separate data controller on the basis of its own privacy policy available at https://www.barion.com/hu/adatvedelmi-tajekoztato

Shared web hosting service provider

Activity performed by the Data Processor: Shared web hosting service
Name and contact details of the Data Processor:
Name: 23VNet Kft.
Address: 1094 Budapest, Liliom u. 24-26.
Contact: 06 1 450 1222

Fact of data processing, scope of data processed: all personal data provided by the data subject.
Scope of data subjects: all data subjects making use of the website.
Purpose of data processing: ensuring the availability and proper functioning of the website.
Duration of data processing, deadline for deletion of data: the processing continues until the termination of the agreement between the data controller and web hosting service provider or until the data subject's request for deletion to the web hosting service provider.
Legal basis for data processing: Article 6(1)(b) and (c) of the GDPR and Section 13/A (3) of Act CVIII of 2001 on Certain Aspects of Electronic Commerce and on Information Society Services.

Rights of the data subject:
You are entitled to receive information about the circumstances of the processing,
You are entitled to receive feedback from the controller as to whether or not your personal data are being processed and you have the right to access all information relating to the processing.
You are entitled to receive your personal data stored concerning you in a format that is structured, commonly used and machine-readable.
You have the right to request the controller to correct any inaccurate personal data about you without undue delay.
You have the right to raise objections to the processing of your personal data.

Website operation

Activities performed by the data processor are as follows: website operation (monitoring, technical updates, security system development, other developments, repair tasks)
Name and contact details of the data processor:
Name: DOCCA OutSource IT Kft.
Address: Budapest Apor Vilmos tér 25-26.
E-mail: contact@docca-europe.com Phone number: +3614887490

Fact of data processing, scope of data processed: all personal data provided by the data subject.
Scope of the data subjects: all data subjects making use of the services of the website as well as all data subjects who have registered/placed an order on the website.
Purpose of data processing: operation of the website (development, monitoring, error corrections)
Duration of data processing, deadline for deletion of data: until the agreement between the Service Provider and the website operator is terminated or until the date of the data subject's request for deletion to the website operator.
The legal basis for the processing of data: article 6(1)(f) of the GDPR and Article 13/A(3) of Act CVIII of 2001 on Certain Aspects of Electronic Commerce Services and on Information Society Services.

Rights of the data subject:
You are entitled to receive information about the circumstances of the processing.
You are entitled to receive feedback from the controller as to whether or not your personal data are being processed and you have the right to access all information relating to the processing.
You are entitled to receive your personal data stored concerning you in a format that is structured, commonly used and machine-readable.
You are entitled to have inaccurate personal data corrected by the controller without undue delay upon your request.
You have the right to raise an objection to the processing of your personal data.

Accounting duties, invoicing

Activity carried out by the data processor: Accounting and invoicing
Name and contact details of the data processor:
Name: Nagy Gábor Jánosné, Zsubriga Kft. Company registration number: 01-09-976600
Address: 1174 Budapest, Szenczi Molnár Albert utca 52.
Tax number: 23752894-2-42
E-mail: ugyfelszolgalat@voxinfo.hu

Activity carried out by the data processor: Accounting and invoicing
Name and contact details of the data processor:
Name: aPlus Consulting Kft. Company registration number: 01 09 910002
Address: 1037 Budapest Bécsi út 269.
Tax number: 14571961-2-41
E-mail: penzugy@aplus.hu

Fact of data processing, scope of data processed: name, invoicing name, invoicing address.
Scope of the data subjects: all data subjects placing an order via the website.
Purpose of processing: issuing electronic invoices/accounting tasks
Duration of data processing, deadline for deletion of data: 8 years pursuant to § 169 (2) of Act C of 2000 on Accounting
The legal basis for the processing of data: article 6(1)(c) of the GDPR and § 13/A (3) of Act CVIII of 2001 on Certain Aspects of Electronic Commerce Services and on Information Society Services.

Rights of the data subject:
You are entitled to receive information about the circumstances of the processing,
You are entitled to receive feedback from the controller as to whether or not your personal data are being processed and you have the right to access all information relating to the processing
You are entitled to receive your personal data stored concerning you in a format that is structured, commonly used and machine-readable.
You are entitled to have inaccurate personal data corrected by the controller without undue delay upon your request.

Recipients to whom personal data will be communicated (Cases of data transfers):
In addition to the data processors listed above, we transfer your personal data to the following recipients on the basis of the contract entered into with them:

Recipient of data transmission	Data transmitted
Nemzeti Mobilfizetési Zártkörűen Működő Részvénytársaság (1027 Budapest, Kapás utca 6-12. Cg.: 01 10 047569; tax number: 24151667-2-4)	Upon purchase of a parking ticket or motorway e-vignette, the following data are transmitted: vehicle registration number, country code, location of the parking event, vehicle type, details of the vignette purchased (type, date of validity)
KBOSS.hu Kft., (1031 Budapest, Záhony utca 7/C.. Cg.: 01-09-303201; tax number: 13421739-2-41)	Name, invoicing details, e-mail address
OTP Mobil Kft. (1143 Budapest, Hungária krt. 17- 19. Company registration number: 01-09-174466 Tax number: 24386106-2-42)	The information transmitted is as follows: name, e-mail address, invoicing details. The nature and purpose of the data processing activities carried out by the data processor can be viewed in the SimplePay Data Privacy statement at the following link: https://simplepay.hu/vasarlo-aff/ In the event of misuse with credit card payment data, fraud, suspected fraud, the following data will be forwarded: name, invoicing data, e-mail address, IP address

Cookie management

Cookies that are typical for web shops are called "password-protected session cookies", "shopping cart cookies", "security cookies", "essential cookies", "functional cookies" and "cookies responsible for managing website statistics", for which it is not necessary to ask for the prior consent of the data subject.
Fact of processing, scope of data processed: unique identifier, dates, times
Data subjects: all data subjects accessing the website.
Purpose of data processing: identification of users, registration of the "shopping cart" and tracking of visitors.
Duration of data processing, deadline for deletion of data:

Cookie type	Legal basis for data processing	Duration of data processing	Processed data range
Session cookies (session)	Section 13/A (3) of Act CVIII of 2001 on Certain Aspects of Electronic Commerce and on Information Society Services (Elkertv.)	Period until the end of the current visitor session	connect.sid
Persistent or saved cookies	Section 13/A (3) of Act CVIII of 2001 on Certain Aspects of Electronic Commerce and on Information Society Services (Elkertv.)	until the deletion of the data subject
Statistical cookies	Section 13/A (3) of Act CVIII of 2001 on Certain Aspects of Electronic Commerce and on Information Society Services ((Elkertv.)	1-2 months

Potential controllers of the data: by using cookies, no personal data is processed by the controller.
Data subjects' rights regarding data processing: data subjects have the option to delete cookies by selecting generally the Privacy settings in the Tools/Preferences menu of their browsers.
Legal basis for data processing: The consent of the data subject is not required where the use of cookies serves the sole purpose of communicating via an electronic communications network or where the service provider strictly needs the cookies to provide a service related to information society expressly requested by the subscriber or user.

Using Google Ads conversion tracking

The data controller makes use of the online advertising program named "Google Ads" and also uses Google's conversion tracking service within its framework. Google Conversion Tracking is an analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; "Google").
When Users access a website via a Google ad, a cookie necessary for conversion tracking is placed on their computer. The validity of these cookies is limited and no personal data is included, so the User cannot be identified by them.
However, when the User browses certain pages of the website and the cookie has not yet expired, both Google and the data controller can see that the User has clicked on the ad.
As each Google AdWords client is given a different cookie, those cookies cannot be tracked through AdWords clients' websites.
The information - acquired via conversion tracking cookies - serves the purpose of generating conversion statistics for AdWords clients opting to track conversions. This allows clients to see the number of users who click on their ad and are forwarded to a page with a conversion tracking tag.
However, no information is provided to them that would allow them to identify any user.
If you prefer not to participate in conversion tracking, you can opt-out by disabling the option to set cookies in your browser. Afterwards you will not appear in the conversion tracking statistics.
Further information and Google's Privacy Policy can be accessed on the following page:
www.google.de/policies/privacy/

Using Google Analytics

This website uses Google Analytics, which is a web analytics service provided by Google Inc. ("Google"). Google Analytics uses so-called "cookies", text files that are stored on your computer to facilitate the analysis of the web page visited by the User. The information created via cookies in connection with the website used by the User is typically transferred to and stored by Google on servers in the United States. By activating the IP anonymisation on the website, Google previously shortens the User's IP address within the Member States of the European Union or in other states which party to the Agreement on the European Economic Area.
Only in exceptional cases will the entire IP address be transmitted to and shortened there by Google's server based in the USA. Google will use this information on behalf of the operator of this website for the purpose of evaluating the way in which the User has used its site, compiling reports on the activity of the website for the website operator as well as for the provision of other services relating to the activity on the website and internet usage. The IP address transmitted by the User's browser as part of Google Analytics services will not be merged with other data held by Google. The User can prevent the storage of cookies by selecting the appropriate settings on his or her browser, however please note that not all functions of this website may then be fully functional. Moreover, you can also prevent Google from collecting and processing information on your use of the website (including your IP address) through cookies by downloading and installing the browser plugin that is available at the following link:
https://tools.google.com/dlpage/gaoptout?hl=hu

Facebook pixel Barion Pixel

The Facebook pixel is a code that is used to create reports on conversions on the website, generate target audiences and it provides the site owner with detailed data analysis on how visitors use the website. By using the Facebook remarketing pixel tracking code, you can display personalised offers and ads to visitors of your website on Facebook. The Facebook remarketing list is not suitable for personal identification purposes. For more information about the Facebook Pixel, please visit the following link:
https://www.facebook.com/business/help/651294705016616

Barion Pixel

Barion Pixel: a JavaScript-based measurement code which is placed on the Merchant's Website and is used to track the activity of visitors to the Website by means of cookies placed in the browsers of Website visitors. Following the placement of the cookie on the Website visitor's device, Barion Pixel collects data about the Website visitors and their browsing behaviour and forwards the data directly to the Service Provider's server. These data are used by the Service Provider for fraud prevention purposes for risk analysis and assessment (Barion Privacy Policy 5.4) and for marketing purposes to tailor advertisements and recommendations and to examine behavioural preferences (Barion Privacy Policy 5.12) in accordance with the terms set out in the current Barion Privacy Policy.

There are two versions of Barion Pixel: Barion Pixel Basic Version and Barion Pixel Full Version

Barion Pixel Basic Version: this version of Barion Pixel gathers data for risk analysis and assessment strictly for fraud prevention purposes.
Barion Pixel Full Version: this version of Barion Pixel gathers data both for risk analysis and assessment for fraud prevention purposes and for marketing purposes to analyse behavioural patterns for tailoring advertisements and recommendations

Barion cookie information

Name of cookie	About the cookie and its purpose	Service Provider	How long is it stored on your device?
ba_vid	It is intended to detect credit card fraud based on the digital fingerprint of the device you use and your browsing habits during the use of the Barion Smart Gateway service. The use of cookies is necessary to detect fraudsters. By using a cookie, we know that the data we receive from your browsing habits comes from the same user.	Barion Payment Zrt.	For 1.5 years following the last update.
ba_vid.xxx	It is intended to detect credit card fraud based on the digital fingerprint of the device you use and your browsing habits during the use of the Barion Smart Gateway service The cookie enables us to track your browsing habits between two sessions on a particular website. The following data is recorded: ba_vid, the ID assigned to the user, which is a hash compiled from the browser properties, based on which the timestamp of your first, current and last visit to the website in question, the ID of the current session, licence for third party cookies.	Barion Payment Zrt.	For 1.5 years following the last update.
ba_sid	The Barion Smart Gateway service is designed to detect credit card fraud based on the digital fingerprint of the device you use and your browsing habits. A cookie enables us to identify your session across websites.	Barion Payment Zrt.	For 30 minutes
ba_sid.xxx	It is intended to detect credit card fraud based on the digital fingerprint of the device you use and your browsing habits during the use of the Barion Smart Gateway service. A cookie ensures that we can identify the session of your browser within a certain website.	Barion Payment Zrt.	For 30 minutes

When the cookie lifetime is defined as from the last update, this means that each visit extends the expiry date of the cookie by 1.5 years from the last visit. The collection of data resulting from the extension is not subject to consent. Data processing serves the legitimate interest of Barion Payment Zrt. for the purpose of fraud prevention. Further information can be found at the link below here.

Other technologies: Digital fingerprinting of the browser: aimed at filtering out fraudulent sessions based on visitor activity and their browser fingerprint. It helps us to identify browsers on each device. This is used on the specific website and also on other merchants' websites for users that are using the Barion Smart Gateway. Further details are available in section 5.4 of Privacy Notice.

Name of the cookie	About the cookie and its purpose	Service provider	How long is it stored on your device?
BarionMarketingConsent.xxx	It aims to store your declaration of whether you have consented to the collection of data derived from your browsing patterns and to the analysis of your shopping habits with a view to displaying personalised advertisements and offers. If you have given your consent, we will also use the data collected by cookies set for credit card fraud prevention purposes, and your browsing behaviour, to examine your shopping habits, for the purposes of displaying personalised advertisements and offers.	Barion Payment Zrt.	For 1.5 years following the last update.
Media and advertiser partners' cookie	It is intended to synchronize and pair the different user IDs of the Barion system and those of the partner's system. The above cookies, as part of their operation, send a signal to the partners' server to download its own user ID cookie to the website visitor's browser. This ensures that identifiers generated in both systems at the same time, in the same browser, are paired.	See Privacy Notice	More information on cookies may be found in each partner's cookie policy. For a list of partners who use cookies to this end, along with a link to their cookie policy, click here.

Data processing partners

as a user for Barion Marketing Cloud and Barion Pixel

DataMe Kft. 1118 Budapest, Ugron Gábor utca 35.
Dentsu Hungary Kft., 1027 Budapest, Kacsa utca 15-23.
GroupM, 1123 Budapest, Alkotás utca 53. MOM Park, B/1. emelet
Matterkind CEE, 1082 Budapest, Vajdahunyad utca 41.
Vodafone Magyarország, 1096 Budapest, Lechner Ödön fasor 6.

Hotjar

To tailor our website to the preferences of our customers, we use the Hotjar Ltd. system (www.hotjar.com), whereby data is collected and stored for marketing and optimisation purposes. This data is used to create user profiles under a pseudonym. Without the specific consent of the person concerned, the data collected will not be used to identify the website visitor individually and will not be linked to the personal data of the pseudonym bearer. In this regard, data related to your browser and the device you use to surf the Internet (your country, your IP address in an anonymised form, the type of device, screen size, browser type, type of operating system, pages accessed, time of visit) will be processed and stored. You have the option to opt-out of data collection and the storage of this data in your browser, more information on which is available at the following link: https://www.hotjar.com/

Newsletter, DM activities

Name, address of data processor: FounderBits Inc. DBA BigMailer.io
80 Theodore Fremd Avenue
Rye, New York 10580 United States
Customer service: hey@bigmailer.io

Pursuant to Article 6 of Act XLVIII of 2008 on Essential Conditions of and Certain Limitations to Business Advertising Activity the User may explicitly and in advance give his/her consent to be contacted by the Service Provider with advertising offers and other messages through the contact details provided at the time of registration or ordering.
Additionally, the Customer is entitled, in compliance with the provisions set out in this Policy, to consent to the processing of personal data by the Service Provider for the purpose of sending advertising offers.

The Service Provider will not send unsolicited advertising messages and the User can, without restriction and without giving any reason, unsubscribe from receiving such offers free of charge. In this case, the Service Provider shall delete all personal data necessary for sending advertising messages from its records and shall cease to send further advertising offers to the User. The User can unsubscribe from receiving advertising messages via the link in the message.

The fact of data collection, the scope of the data processed and the purposes of the processing:

Personal data	Purpose of data processing
Name, e-mail address.	Identification, enabling subscription to the newsletter.
Date of subscription	Performing technical operation
IP address at the time of subscription	Performing technical operation

Scope of data subjects: all data subjects subscribing to the newsletter.
The purpose of data processing: sending electronic messages (e-mails) that contain advertising to the data subject, providing information on current updates, products, promotions, new features, etc.
Duration of data processing, deadline for deletion of data: until the consent given is withdrawn, i.e., until unsubscription.
Potential controllers entitled to access the data, recipients of personal data: Personal data may be processed by sales and marketing personnel of the controller, in full compliance with the principles set out above.

Details of data subjects' rights in connection with data processing:

the data subject concerned has the right to request the controller to access, rectify, erase or restrict the processing of personal data relating to him or her,
the data subject is entitled to raise an objection to the processing of their personal data; and
the data subject concerned is entitled to data portability and the right to withdraw consent at any time

The data subject may initiate the access, deletion, modification or restriction of the processing of personal data, or the portability of data in the following ways:

by sending a letter to Voxinfo Kft. at the address1037 Budapest Bécsi út 269.,
by sending an e-mail to ugyfelszolgalat@voxpay.hu, ugyfelszolgalat@autopalyamatrica.hu

The data subject can unsubscribe from the newsletter at any time, free of charge.

Legal basis for data processing: consent of the data subject, Article 6(1)(a) and (f) and § 6(5) of Act XLVIII of 2008 on Essential Conditions of and Certain Limitations to Business Advertising Activity:
The advertiser, the advertising service provider and the publisher of the advertisement shall keep a record of the personal data of the persons making a declaration of consent with them, within the scope specified in the consent. The data recorded in this database - relating to the recipient of the advertising - may be processed only in compliance with the conditions set out in the consent form, until its withdrawal, and may be disclosed to third parties only with the prior consent of the data subject.

Please note that

the processing is carried out on the basis of your consent and the legitimate interest of the service provider.
You are obliged to provide personal data if you wish to receive newsletters from us.
failing to provide the data has the consequence that we will not be able to send you newsletters

Complaints handling and customer service

To ensure a complete communication with our customers, we provide the use of Contact Center.
The "Service Provider" or "Operator" is Daktela s.r.o., with its registered office at Vinohradská 2828/151, Praha 3 - Žižkov, 130 00, ID No. 27232263, Tax No. CZ27232263, registered in the Commercial Register kept by the Commercial Court in Prague, Section C, Insert 106338, tel. 226 211 245, http:/www.daktela.com, e-mail address: daktela@daktela.com.

The fact of data collection, the scope of the data processed and the purposes of the processing:

Personal data	Purpose of data processing
Surname and first name	Identification, maintaining contact.
E-mail address	Identification, maintaining contact.
Phone number	Identification, communication
Vehicle’s registration number	Identification
Invoicing name and address	Identification; handling of quality complaints, questions and problems with the products ordered.

Data subjects: all data subjects making a purchase on the website and all data subjects raising a complaint about quality.
Duration of data processing, deadline for deletion of data: in accordance with § 17/A (7) of Act CLV of 1997 on Consumer Protection, copies of the minutes recorded of the objection, the transcript and the reply thereto shall be kept for 5 years.

Potential controllers entitled to access the data, recipients of personal data:
Personal data may be processed by the sales and marketing personnel of the controller, in full compliance with the principles set out above.
Details of data subjects' rights in connection with data processing:

The data subject concerned has the right to request the controller to access, rectify, erase or restrict the processing of personal data relating to him or her, and
the data subject concerned is entitled to data portability and the right to withdraw consent at any time.

The data subject may initiate the access, deletion, modification or restriction of the processing of personal data, or the portability of data in the following ways:

by sending a letter to Voxinfo Kft. at the address1037 Budapest Bécsi út 269.,
by sending an e-mail to ugyfelszolgalat@voxpay.hu

Legal basis for processing: the data subject's consent, Article 6 (1) (c); and § 17/A (7) of Act CLV of 1997 on Consumer Protection.

Please note that

the provision of personal data is based on a legal obligation.
The processing of personal data constitutes a precondition for concluding a contract.
you are obliged to provide personal data, otherwise we will not be able to handle your complaint
failing to provide the data will have the consequence that we will not be able to handle your complaint submitted to us

Social media sites

The fact of data collection, the scope of the data processed: the name registered on Facebook/Google+/Twitter/Pinterest/Youtube/Instagram/TikTok etc. social networking sites, and the user's public profile picture.
Scope of the data subjects: all data subjects who have registered on Facebook/Google+/Twitter/Pinterest/Youtube/Instagram etc. social sites and who have "liked" the website.
Purpose of data collection: to share, to "like" or to promote certain contents of the website, its products, promotions or the website itself on social networking sites. Duration of data processing, deadline for deletion of data, the possible controllers who may have access to the data and the data subjects' rights in relation to data processing: the data subject has the possibility to obtain information on the source of the data, the way in which they are processed and the form and legal basis of the transfer on the relevant social networking site. The data processing takes place on the social networking sites, so the duration of the processing, the way in which the data are processed and the options for deleting and modifying the data are subject to the rules of the social networking site concerned.
Legal basis for processing: the data subject's freely given consent to the processing of his or her personal data on social networking sites.

Customer relations and other data processing activities

Should any questions arise when using the services of the data controller or should the data subject have a problem, he or she may contact the data controller via the means indicated on the website (telephone, e-mail, social networking sites, etc.).
The Data Controller shall delete the incoming e-mails, messages, data provided by telephone, Facebook, etc., together with the name and e-mail address of the data subject and any other personal data provided freely, no later than 2 years after the data have been provided.
We provide information on data processing not included in this policy at the time of data recording.
Upon exceptional request by a public authority, or upon request by other bodies on statutory authorisation, the Service Provider is obliged to provide information, to disclose data, to hand over data or to make documents available.
In such cases, provided that the requesting party has specified the exact purpose and the range of data, the Service Provider provides personal data to the requesting party only to the extent and in the volume strictly necessary for the purpose of the request.

Rights of data subjects

Right of access
You 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 information listed in the Regulation.

Right to rectification
You have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning you. 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.

Right to erasure
You 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, under certain conditions.

Right to be forgotten
Where the controller has made the personal data public and is obliged to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that You have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

Right to restriction of processing
You have the right to obtain from the controller restriction of processing where one of the following conditions applies:

You contest the accuracy of the personal data in which case the restriction applies for a period enabling the controller to verify the accuracy of the personal data;
the processing is unlawful and you oppose the erasure of the personal data and request 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 you for the establishment, exercise or defence of legal claims;
You have objected to processing pending the verification whether the legitimate grounds of the controller override those of you.

Right to data portability
You have the right to receive the personal data concerning you, which you have provided to a controller, in a structured, commonly used and machine-readable format and You have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided (...).

Right to object
Where data processing is based on legitimate interest or on the exercise of public authority as legal grounds, you have the right to object, on grounds relating to your particular situation, at any time to (...) processing of personal data concerning you including profiling based on those provisions.

Objection in case of direct marketing
Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

Automated individual decision-making, including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
The preceding paragraph shall not apply if the decision

is necessary for entering into, or performance of, a contract between you and a data controller;
is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
is based on your explicit consent.

Time limit for taking measures

The controller shall provide information on action taken in response to those requests to you without undue delay and in any event within one month of receipt of the above request.
That period may be extended by two further months where necessary. The controller shall inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.
If the controller does not take action on the request of the data subject, the controller shall inform you 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.

Security of processing

Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, the controller and the processor shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:
   a)    the pseudonymisation and encryption of personal data;
   b)    the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
   c)    the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
   d)    process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.

Communication of a personal data breach to the data subject

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 it shall contain the name and contact details of the data protection officer or other contact point where more information can be obtained; it shall describe the likely consequences of the personal data breach and it shall 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 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.

If the controller has not already communicated the personal data breach to the data subject, the supervisory authority, having considered the likelihood of the personal data breach resulting in a high risk, may order that the data subject be informed.

Notification of a personal data breach to the authority

In the case of a personal data breach, the controller shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the supervisory authority competent in accordance with Article 55, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. Where the notification to the supervisory authority is not made within 72 hours, it shall be accompanied by reasons for the delay.

Complaint option

Complaints against possible infringements committed by the data controller may be submitted to 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 number: +36 -1-391-1400
Fax: +36-1-391-1410
E-mail: ugyfelszolgalat@naih.hu

Closing remarks

The following legal provisions have been taken into account in the preparation of this policy:

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)
Act CXII of 2011 on Informational Self-Determination and Freedom of Information (hereinafter referred to as the "Privacy Act")
Act CVIII of 2001– on Certain Aspects of Electronic Commerce and on Information Society Services (in particular § 13/A)
Act XLVII of 2008 on the Prohibition of Unfair Commercial Practices against Consumers;
Act XLVIII of 2008 on Essential Conditions of and Certain Limitations to Business Advertising Activity (in particular § 6 thereof);
Act XC of 2005 on the Freedom of Electronic Information
Act No C of 2003 on Electronic Communications (specifically § 155 thereof)
Opinion 16/2011 on EASA/IAB Best Practice Recommendation on Online Behavioural Advertising
Recommendation of the National Authority for Data Protection and Freedom of Information on 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 Directive 95/46/EC

7 August 2023.
Voxinfo Kft.

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