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Privacy Notice

1 PURPOSE OF THE PRIVACY NOTICE

Turborail Kft. (1203 Budapest, Török Flóris u. 19. fsz/2., 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 processing of data related to its activities complies with the requirements set out in this Policy and in the applicable national legislation and European Union acts.

The privacy policy of Turborail Ltd. in relation to its data processing is available on an ongoing basis at www.turborail.hu/adatvedelem.

Turborail Ltd reserves the right to change this information at any time. It will of course inform its audience of any changes in due time. If you have any questions regarding this notice, please write to us and one of our colleagues will answer them. Turborail Ltd. is committed to protecting the personal data of its customers and partners, and attaches the utmost importance to respecting the right of its customers to information self-determination. Turborail Ltd. treats personal data confidentially and takes all security, technical and organizational measures to guarantee the security of the data.

Turborail Ltd. describes its data management practices below.

2 THE DATA CONTROLLER'S DATA

If you wish to contact our Company, you can contact the data controller by email and telephone. Turborail Ltd. will delete all e-mails received by it, together with the personal data, after a maximum of one year from the date of communication.

Name: turborail Ltd.
Registered office:Budapest, Török Flóris utca 19. fsz/2.
Company registration number:01-09-178980Address number
:24723121243Phone number
:+36 70 4297879 / +36 70 8846633Email
: info@turborail.hu

3 THE SCOPE OF PERSONAL DATA PROCESSED

3.1 PERSONAL DATA TO BE PROVIDED DURING REGISTRATION

  • Name of the buyer
  • Billing information (Company name, address, tax number)
  • Phone number
  • Email address
  • Delivery address

3.2 TECHNICAL DATA

Turborail Ltd. selects and operates the IT tools used to process personal data in the course of providing the service in such a way that the processed data is: accessible to those authorised to access it (availability); authenticity and authentication are ensured (authenticity of data processing); its integrity is verifiable (data integrity); it is protected against unauthorised access (data confidentiality).

Turborail Ltd. will take appropriate measures to protect the data against unauthorized access, alteration, disclosure, disclosure, deletion or destruction and against accidental destruction.

Turborail Ltd. takes technical, organisational and organisational measures to ensure the security of data processing that provide a level of protection appropriate to the risks associated with data processing.

Turborail Ltd. will maintain confidentiality in data management: protecting the information so that only those who are entitled to access it can do so; integrity: protecting the accuracy and completeness of the information and the method of processing; availability: ensuring that when the authorised user needs it, he or she can actually access the information and that the means to do so are available.

3.3 COOKIES (COOKIES)

3.3.1 THE ROLE OF COOKIES

Cookies collect information about visitors and their devices; they remember visitors' individual preferences, which are used, for example, when making online transactions, so they do not have to be re-entered; they make the website easier to use; they provide a quality user experience. In order to provide a personalised service, a small piece of data, called a cookie, is placed on the user's computer and read back during a subsequent visit. When the browser returns a previously saved cookie, the cookie provider has the possibility to link the user's current visit to previous visits, but only in relation to its own content.

3.3.2 STRICTLY NECESSARY SESSION COOKIES

The purpose of these cookies is to enable visitors to browse the www.turborail.hu website, use its features and services, and enjoy a full and seamless experience. This type of cookie is valid until the end of the session (browsing) and is automatically deleted from the computer or other browsing device when the browser is closed.

3.3.3 THIRD-PARTY COOKIES (ANALYTICS)

The www.turborail.hu website also uses Google Analytics as a third party cookie. By using Google Analytics for statistical purposes, www.turborail.hu collects information about how visitors use its websites. The data is used to improve the website and the user experience. These cookies will also remain on the visitor's computer or other browsing device, their browser until they expire or until they are deleted by the visitor.

3.4 DATA RELATED TO ONLINE ORDERING

  • Name of the buyer
  • Billing information (Company name, address, tax number)
  • Phone number
  • Email address
  • Delivery address of the ordered product

3.5 DATA RELATED TO ONLINE ADMINISTRATION

  • Name of the buyer
  • Date of the order

3.6 DATA RELATED TO THE NEWSLETTER

You can subscribe or unsubscribe to our newsletter at any time. To unsubscribe, click the unsubscribe button in the email you receive.

4 THE INTENDED USE AND RETENTION PERIOD OF THE DATA PROCESSED

Name of processing

Use of

Legal basis

Retention period

Register on the website

 

Basic data:

required: email address, phone number, default language for correspondence

 

Billing address(es):

required: first name, surname, telephone number, address country, postal code, town, street, house number

optional: tax number

 

Delivery address(es):

required: (name, surname, first name, telephone number, address (country, postal code, town, street, house number)

optional: email address

 

User-supplied password (stored in encrypted form)

online product sales,

 

documenting the purchase and payment,

 

the fulfilment of the accounting obligation,

 

identifying and contacting the user as a customer,

 

fulfilment of the ordered product (or service), invoicing,

 

the possibility to make payments, to detect suspicious transactions during online payments.

In the case of online sales of products, the data subject's consent is required, Info. tv. 5.§ (1) a) and Article 6 (1) a) GDPR, and the performance of a contract pursuant to Article 6 (1) b) GDPR

in the documentation of the purchase and payment, the fulfilment of the accounting obligation, and in the issuing of invoices and the processing of payments, the fulfilment of legal obligations pursuant to Article 6 (1) (c) of the GDPR, as well as Article 169 (2) of the Act on Accounting and VAT and Article 169 of the VAT Act

the identification of the user as a customer and the communication with him/her and the performance of the ordered product (or service),
the consent of the data subject is required for the purposes of the Info. 5.§ (1) a), Article 6 (1) a) GDPR, and the performance of a contract pursuant to Article 6 (1) b) GDPR

a legitimate interest in the detection of suspected fraudulent transactions in online payments on the basis of Article 6(1)(f) of the GDPR

Until the contract is fulfilled,

until the person's consent is withdrawn, failing which the Data Controller shall store the data after the date of purchase, in accordance with the provisions of the Civil Code. 6:22 of the Personal Data Protection Act, after 5 years. If the Data Controller is obliged to retain the data pursuant to the Invoice Act, the Data Controller shall delete the data only after 8 years following the termination of the user account, irrespective of the consent of the data subject. Consent may be withdrawn at any time by sending an e-mail to info@turborail.hu.

Personal data provided in connection with the operation of e-mail, fax and telephone customer services

 

e-mail address, name, address (country, city, postcode, street, house number), telephone number and other personal data concerning the user or other data subject received by the customer service by e-mail and the circumstances of the case.

Investigate and accurately document a case on the contact tab of the Controller's website or accurately document a telephone conversation with a customer service representative in order to provide the Controller with requests and comments relating to the Controller's activities. The email communication will be archived so that in the event of any subsequent questions or disputes, the information will be available in its original form and the Data Controller will be able to contact the user if necessary in relation to the matter.

The legal basis for the processing of data processed in the course of customer service activities is the consent of the data subject in accordance with the Info. tv. 5.§ (1) a), Article 6 (1) a) of the GDPR, and the performance of a contract pursuant to Article 6 (1) b) of the GDPR, the performance of a legal obligation pursuant to Article 6 (1) c) of the GDPR and Article 17/A of the GDPR.

Until the contract is fulfilled,

until the person's consent is withdrawn, failing which the Data Controller shall store the data after the date of purchase, in accordance with the provisions of the Civil Code. 6:22 of the Personal Data Protection Act, after 5 years. If the Data Controller is obliged to retain the data pursuant to the Invoice Act, the Data Controller shall delete the data only after 8 years following the termination of the user account, irrespective of the consent of the data subject. Consent may be withdrawn at any time by sending an email to info@turborail.hu.

The personal data provided on the Facebook page below:

 

Comments and messages on the Turborail Hungary Facebook page.

Consumers can send comments and messages to the data controller via Facebook. The Data Controller or a processor providing services to the Data Controller may respond to questions and comments where necessary. (Facebook is not an official forum for handling consumer complaints.)

the consent of the data subject, Info. tv. 5.§ (1) a), Article 6 (1) a) GDPR

Until the withdrawal of the consent of the person concerned, or failing this, the Data Controller shall store the data after the date of the communication, in accordance with the provisions of the Civil Code. 6:22 of the Personal Data Protection Act, after 5 years.

Personal data provided during the complaint handling process:

 

a) the name and address of the consumer,

 

b) the place, time and manner of lodging the complaint,

 

(c) a detailed description of the consumer's complaint, a list of the documents, records and other evidence produced by the consumer,

 

(d) a statement by the Data Controller of its position on the consumer's complaint, where an immediate investigation of the complaint is possible,

 

e) the signatures of the person who took the record and the consumer (unless the complaint was made by e-mail or telephone),

 

f) the time and place of the taking of the minutes,

 

g) the unique identification number of the complaint.

To investigate and accurately document the circumstances of a complaint received by contacting www.turborail.hu, or to accurately document a telephone conversation with a customer service representative, or to document an entry in the complaint log, in order to provide the Data Controller with requests and comments relating to the Data Controller's activities. The communication will be archived so that in the event of any subsequent queries or disputes, the information will be available in its original form and the Data Controller will be able to contact the user if necessary in relation to the matter.

The legal basis for the processing of data processed in the course of complaint handling activities is the data subject's consent to the processing of data in accordance with the Info. tv. 5.§ (1) a), Article 6 (1) a) GDPR, and the performance of a contract pursuant to Article 6 (1) b) GDPR, the performance of a legal obligation pursuant to Article 6 (1) c) GDPR and Article 17/A of the GDPR.

The Data Controller shall keep the record of the complaint and a copy of the reply for five years and shall make it available to the supervisory authorities upon request.

If the Data Controller is obliged to keep the data under the Act on the Protection of Personal Data, the Data Controller will delete the data only after 8 years from the date of the complaint, regardless of the consent of the data subject.

              

5 THE PURPOSES, MEANS AND LEGAL BASIS OF THE PROCESSING

5.1 GENERAL DATA PROCESSING POLICY

The data processing of the activities of Turborail Ltd. is based on voluntary consent and legal authorization. In the case of processing based on voluntary consent, the data subjects may withdraw their consent at any time during the processing. In some cases, the processing, storage and transmission of some of the data provided is required by law, and we will inform our customers separately.

Please note to Turborail Ltd. that if you do not provide your own personal data, it is the responsibility of the data provider to obtain the consent of the data subject. Its data management principles are in accordance with the applicable data protection legislation, in particular the following:

  • Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information (Infotv.);
  • 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 (General Data Protection Regulation, GDPR);
  • Act V of 2013 - on the Civil Code (Civil Code);
  • Act C of 2000 - on Accounting (Accounting Act);
  • Act LIII of 2017 - on the Prevention and Combating of Money Laundering and Terrorist Financing (Pmt.);
  • Act CCXXXVII of 2013 - on Credit Institutions and Financial Undertakings (Hpt.).

6 PHYSICAL STORAGE LOCATIONS OF THE DATA

Your personal data (i.e. data that can be associated with you personally) may be processed by us in the following ways: on the one hand, technical data relating to the computer, browser program, Internet address and pages visited in connection with the Internet connection are automatically generated in our computer system, and on the other hand, you may provide us with your name, contact details or other data if you wish to contact us personally when using the website.

Data technically recorded during the operation of the system: the data of the computer of the person concerned, which are generated during the registration process and which are recorded by the system of Turborail Ltd. as an automatic result of technical processes. The data that are automatically recorded are automatically logged by the system at the time of entry or exit, without any specific declaration or action by the data subject. This data cannot be linked to other personal user data, except in cases required by law. Turborail Ltd. has exclusive access to the data.

The data controller's computer systems and other data storage locations are located on the servers of Turborail Kft. (1203 Budapest, Török Flóris u. 19. fsz/2) and on the server of the webshop operator, Deninet Kft. (1188 Budapest, Bercsényi u. 79/b. ).

7 DATA TRANSFERS, DATA PROCESSING, DATA SUBJECTS

In the case of delivery of products, the name, address of the recipient and the value of the order will be forwarded to the following recipients:

  1. 1.GLS General Logistics Systems Hungary Csomag-Logisztikai Kft. (2351 Alsónémedi, Európa u. 2. info@gls-hungary.com)

Your data will not be transferred to third parties beyond the above. Transfers to third parties or recipients will only be made if we inform you in advance of the potential recipient and the customer then gives his or her prior consent or if otherwise required by law.

8 DATA SUBJECT'S RIGHTS AND MEANS OF REDRESS

The data subject may request information about the processing of his or her personal data, and may request the rectification, erasure or withdrawal of his or her personal data, except for mandatory data processing, and may exercise his or her right to data portability and objection in the manner indicated when the data were collected, or by contacting the controller at the above contact details.

8.1 RIGHT TO INFORMATION

Turborail Ltd. shall take appropriate measures to provide data subjects with all the information on the processing of personal data referred to in Articles 13 and 14 of the GDPR and all the information referred to in Articles 15 to 22 and 34 of the GDPR in a concise, transparent, intelligible and easily accessible form, in a clear and plain language.

8.2 RIGHT OF ACCESS OF THE DATA SUBJECT

The data subject shall have the right to obtain from the controller feedback as to whether or not his or her personal data are being processed and, if such processing is taking place, the right to access the personal data and the following information: the purposes of the processing; the categories of personal data concerned; the recipients or categories of recipients to whom or with which the personal data have been or will be disclosed, including in particular recipients in third countries or international organisations; the envisaged period of storage of the personal data; the right to rectification, erasure or restriction of processing and the right to object; the right to lodge a complaint with a supervisory authority; information on the data sources; the fact of automated decision-making, including profiling, and clear information on the logic used and the significance of such processing and its likely consequences for the data subject. The controller shall provide the information within a maximum of one month from the date of the request.

8.3 RIGHT OF RECTIFICATION

The data subject may request the rectification of inaccurate personal data concerning him/her processed by Turborail Ltd. and the completion of incomplete data.

8.4 RIGHT TO CANCELLATION

The data subject shall have the right to have personal data relating to him or her erased by Turborail Ltd. without undue delay upon his or her request if one of the following grounds applies:

  • the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
  • the data subject withdraws the consent on which the processing is based and there is no other legal basis for the processing;
  • the data subject objects to the processing and there are no overriding legitimate grounds for the processing;
  • the personal data have been unlawfully processed; the personal data must be erased in order to comply with a legal obligation under Union or Member State law to which the controller is subject;
  • personal data are collected in connection with the provision of information society services.

The erasure of data may not be initiated if the processing is necessary: for the exercise of the right to freedom of expression and information; for compliance with an obligation under Union or Member State law to process personal data or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; for public health purposes or for archiving, scientific or historical research purposes or statistical purposes in the public interest; or for the establishment, exercise or defence of legal claims.

8.5 RIGHT TO RESTRICTION OF PROCESSING

At the request of the data subject, Turborail Ltd. will restrict the processing of data if one of the following conditions is met:

  • the data subject contests the accuracy of the personal data, in which case the restriction applies for a period of time which allows the accuracy of the personal data to be verified;
  • the data processing is unlawful and the data subject opposes the erasure of the data and requests instead the restriction of their use;
  • the controller no longer needs the personal data for the purposes of processing, but the data subject requires them for the establishment, exercise or defence of legal claims; or
  • the data subject has objected to the processing; in this case, the restriction applies for the period until it is established whether the legitimate grounds of the controller override those of the data subject.

Where processing is restricted, personal data, other than storage, may be processed only with the consent of the data subject or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or of an important public interest of the Union or of a Member State.

8.6 RIGHT TO DATA RETENTION

The data subject has the right to receive personal data relating to him or her which he or she has provided to the controller in a structured, commonly used, machine-readable format and to transmit these data to another controller.

8.7 RIGHT TO OBJECT

The data subject shall have the right to object at any time, on grounds relating to his or her particular situation, to processing of his or her personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, or necessary for the purposes of the legitimate interests pursued by the controller or by a third party, including profiling based on those provisions. In the event of an objection, the controller may no longer process the personal data, unless there are compelling legitimate grounds for doing so which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

8.8 AUTOMATED DECISION-MAKING ON INDIVIDUAL CASES, INCLUDING PROFILING

The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

8.9 RIGHT OF WITHDRAWAL

The data subject has the right to withdraw his or her consent at any time.

8.10 RIGHT TO APPLY TO THE COURTS

The data subject may take the controller to court if his or her rights are infringed. The court shall rule on the case out of turn.

8.11 DATA PROTECTION AUTHORITY PROCEDURE

You can lodge a complaint with the National Authority for Data Protection and Freedom of Information:

Name: National Authority for Data Protection and Freedom of InformationDeposition
: 1125 Budapest, Szilágyi Erzsébet fasor 22/C.
Postal address: 1530 Budapest, Pf.: 5.
Phone: 06 1 391 1400Fax
: 06 1 391 1410Email:
ugyfelszolgalat@naih.huHonlap: http://www.naih.hu

9 OTHER PROVISIONS

Information about data processing not listed in this notice is provided at the time of collection.

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

Turborail Ltd. will only disclose personal data to the authorities to the extent and to the extent strictly necessary for the purpose of the request, provided that the authorities have indicated the exact purpose and scope of the data.