Purpose of the Privacy Notice
Webtune kft. (2200 Monor Móricz Zsigmond utca 99 A/2) (hereinafter: Service Provider, Data Controller), as data controller, acknowledges the contents of this legal notice as binding upon itself. It undertakes to ensure that all data processing related to its activities complies with the requirements set out in this policy, in the applicable national legislation, and in the legal acts of the European Union.
The privacy principles related to the Data Controller’s data processing activities are continuously available at emleksziget.hu.
The Data Controller reserves the right to amend this notice at any time. Naturally, it shall inform its audience of any changes in due time.
If you have any questions regarding this notice, please write to us and our colleague will answer your question.
The Data Controller is committed to the protection of the personal data of its customers and partners, and considers it particularly important to respect its customers’ right to informational self-determination. The Data Controller handles personal data confidentially and takes all security, technical and organizational measures necessary to guarantee the security of the data.
The Data Controller describes its data processing practices below.
Details of the Data Controller
If you wish to contact our Company, you may do so via the following e-mail address: info@wordpress-n8w0kscgs8s0k8sk4cwsw4k0.62.171.145.185.sslip.io.
The Data Controller shall delete all e-mails received by it, together with the personal data contained therein, no later than 3 years from the date of communication.
Name: Webtune kft
Registered office: 2200 Monor Móricz Zsigmond utca 99 A/2
Company registration number: 13 09 235193
Tax number: 32605958-2-13
Phone number: +36-20-427-2826
E-mail: info@wordpress-n8w0kscgs8s0k8sk4cwsw4k0.62.171.145.185.sslip.io
Data Protection Officer
Name: Vad László
Phone number: +36-20-427-2826
Scope of Personal Data Processed
Personal data required during registration
First name
Last name
Phone number
Residential address
Technical Data
The Data Controller selects and operates the IT tools used in the provision of the service in such a way that the processed data:
is accessible to those authorized to access it (availability);
its authenticity and verification are ensured (authenticity of data processing);
its integrity can be verified (data integrity);
is protected against unauthorized access (data confidentiality).
The Data Controller protects the data with appropriate measures against unauthorized access, alteration, transmission, disclosure, deletion or destruction, as well as accidental destruction.
The Data Controller ensures the security of data processing by technical, organizational and administrative measures that provide a level of protection appropriate to the risks arising in connection with the data processing.
During data processing, the Data Controller preserves:
confidentiality: it protects the information so that only those authorized may access it;
integrity: it protects the accuracy and completeness of the information and the method of processing;
availability: it ensures that when the authorized user needs it, they can actually access the desired information, and that the related tools are available.
Cookies
Purpose of cookies
They collect information about visitors and their devices;
They remember visitors’ individual settings, which may be used, for example, when using online transactions, so they do not need to be re-entered;
They make the website easier to use;
They provide a quality user experience.
In order to provide customized service, the website places a small data package, a so-called cookie, on the user’s computer and reads it back during a later visit. If the browser returns a previously saved cookie, the service provider managing the cookie has the opportunity to link the user’s current visit with previous visits, but exclusively with regard to its own content.
Duration of data processing
The storage duration of the given cookie data is available here in more detail:
Google general cookie notice:
https://www.google.com/policies/technologies/types/
Google Analytics notice:
https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage?hl=hu
Facebook notice:
https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen
Legal background and legal basis of cookies
The legal basis for data processing is your consent pursuant to Article 6(1)(a) of the Regulation.
Main characteristics of the cookies used by the website
Strictly necessary cookies for operation: These cookies are essential for the use of the website and enable the use of the website’s basic functions. Without them, many functions of the site will not be available to you. The lifespan of these cookies is limited exclusively to the duration of the session.
Cookies improving user experience: These cookies collect information about how the user uses the website, for example which pages they visit most frequently or what error messages they receive from the website. These cookies do not collect information identifying the visitor; they work with completely general, anonymous information. The data obtained from them are used to improve the performance of the website. The lifespan of these cookies is limited exclusively to the duration of the session.
Third-party cookies (analytics)
Google Adwords cookie: When someone visits our site, the visitor’s cookie ID is added to the remarketing list. Google uses cookies – such as the NID and SID cookies – to customize ads displayed in Google products, such as Google Search. These cookies are used, for example, to remember your recent searches, your previous interactions with individual advertisers’ ads or search results, and your visits to advertisers’ websites. AdWords conversion tracking uses cookies. To track sales and other conversions resulting from ads, cookies are saved on the user’s computer when that person clicks on an ad. Some common uses of cookies include: selecting ads based on what is relevant to a particular user, improving campaign performance reports, and avoiding the display of ads the user has already seen.
Google Analytics cookie: Google Analytics is Google’s analytics tool that helps website and app owners gain a more accurate picture of visitor activity. The service may use cookies to collect information and prepare reports on website usage statistics without individually identifying visitors to Google. The main cookie used by Google Analytics is the “__ga” cookie. In addition to generating reports from website usage statistics, Google Analytics may also be used, together with some of the advertising cookies described above, to display more relevant ads in Google products (such as Google Search) and across the internet.
Remarketing cookies: These may appear to previous visitors or users while they browse other websites on the Google Display Network or search for terms related to your products or services.
Session cookie: These cookies store the visitor’s location, browser language, and payment currency. Their lifetime lasts until the browser is closed, or a maximum of 2 hours.
Mobile version, design cookie: Detects the device used by the visitor and switches to full view on mobile. Lifetime: 365 days.
Cookie acceptance cookie: When arriving at the site, the visitor accepts the statement on the storage of cookies in the warning window. Lifetime: 365 days.
Facebook/Meta pixel (Facebook cookie): The Facebook pixel is code that helps generate reports about conversions on the website, create target audiences, and provide the site owner with detailed analytical data on visitors’ website usage. With the help of the Facebook pixel, the website can display personalized offers and advertisements to website visitors on the Facebook platform. Facebook’s privacy policy is available here: https://www.facebook.com/privacy/explanation
If you do not accept the use of cookies, certain functions will not be available to you. More information about deleting cookies can be found at the following links:
Internet Explorer: http://windows.microsoft.com/en-us/internet-explorer/delete-manage-cookies#ie=ie-11
Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
Mozilla: https://support.mozilla.org/hu/kb/weboldalak-altal-elhelyezett-sutik-torlese-szamito
Safari: https://support.apple.com/kb/ph21411?locale=en_US
Chrome: https://support.google.com/chrome/answer/95647
Data related to online orders
First name
Last name
Phone number
Residential address
Data related to online administration
First name
Last name
Phone number
Residential address
Data related to newsletters
First name
Last name
Phone number
Residential address
Data processing activity related to newsletter distribution
Name of the company operating the newsletter system: MailerLite
Registered office of the company operating the newsletter system: Jono Basanaviciaus str. 15, LT-03108, Vilnius, Lithuania
E-mail address of the company operating the newsletter system: info@mailerlite.com
Pursuant to the contract concluded with the Data Controller, the Data Processor cooperates in the distribution of newsletters. In the course of this, the Data Processor processes the name and e-mail address of the data subject to the extent necessary for sending the newsletter.
Purpose, method and legal basis of data processing
General data processing principles
The Data Controller’s data processing activities are based on voluntary consent or statutory authorization. In cases of data processing based on voluntary consent, data subjects may withdraw their consent at any stage of the data processing.
In certain cases, the handling, storage and transfer of a set of provided data are required by law, of which our customers are informed separately.
We draw the attention of those providing data to the Data Controller that if they provide personal data other than their own, it is the responsibility of the data provider to obtain the consent of the data subject.
The Data Controller’s principles of data processing comply with the applicable legislation on data protection, in particular the following:
Act CXII of 2011 – on informational self-determination and freedom of information (Infotv.);
Regulation (EU) 2016/679 of the European Parliament and of the Council (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 95/46/EC (General Data Protection Regulation, GDPR);
Act V of 2013 – on the Civil Code (Ptk.);
Act C of 2000 – on Accounting (Számv. tv.);
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 enterprises (Hpt.).
Physical storage locations of data
Your personal data (that is, data that may be associated with your person) may be processed by us in the following ways: on the one hand, technical data relating to the computer, browser program, internet address and visited pages used by you are automatically generated in our computer system in connection with maintaining the internet connection; on the other hand, you may also provide your name, contact details or other data if you wish to contact us personally while using the website.
Rights of the data subject and enforcement options
During the period of data processing, under the provisions of the Regulation, you are entitled to the following rights:
the right to withdraw consent
the right of access to personal data and information related to data processing
the right to rectification
restriction of processing
the right to erasure
the right to object
the right to data portability
If you wish to exercise your rights, this will involve your identification, and the Data Controller will necessarily need to communicate with you. Therefore, for identification purposes, personal data will need to be provided (but identification may only be based on data that the Data Controller already processes about you), and your complaint related to data processing will be available in the Data Controller’s e-mail account within the period specified in this notice regarding complaints. If you have been our customer and wish to identify yourself for complaint handling or warranty administration purposes, please also provide your order ID for identification. Using this, we can also identify you as a customer.
The Data Controller shall respond to complaints related to data processing no later than within 30 days.
Right to information
The Data Controller shall take appropriate measures in order to provide data subjects with all information referred to in Articles 13 and 14 of the GDPR and all information under Articles 15–22 and 34 in a concise, transparent, intelligible and easily accessible form, using clear and plain language.
Right of access of the data subject
You have the right to obtain confirmation from the Data Controller as to whether your personal data are being processed, and where that is the case, you have the right to:
gain access to the personal data processed, and
be informed by the Data Controller of the following:
the purposes of the data processing;
the categories of personal data processed about you;
information about the recipients or categories of recipients to whom the personal data have been or will be disclosed by the Data Controller;
the planned duration of storage of the personal data, or, if this is not possible, the criteria used to determine that period;
your right to request from the Data Controller rectification, erasure or restriction of processing of personal data concerning you, and, where processing is based on legitimate interest, to object to such processing;
the right to lodge a complaint with a supervisory authority;
where the data were not collected from you, all available information as to their source;
the fact of automated decision-making (if such procedure is used), including profiling, and at least in those cases, meaningful information about the logic involved and the significance and the envisaged consequences of such processing for you.
The purpose of exercising this right may be to establish and verify the lawfulness of data processing, therefore in the event of repeated requests for information, the Data Controller may charge a reasonable fee in exchange for fulfilling the information request.
The Data Controller provides access to personal data by sending you the processed personal data and information by e-mail following your identification. If you have a registration, access is provided by allowing you to view and verify the personal data processed about you by logging into your user account.
Please indicate in your request whether you are requesting access to personal data or information related to data processing.
Right to rectification
You have the right to request that the Data Controller rectify inaccurate personal data concerning you without undue delay.
Right to erasure
The data subject shall have the right to obtain from the Data Controller the erasure of personal data concerning them without undue delay where one of the following grounds applies:
the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
the data subject withdraws consent on which the processing is based and there is no other legal ground for the processing;
the data subject objects to the processing and there are no overriding legitimate grounds for the processing;
the personal data have been unlawfully processed;
the personal data must be erased for compliance with a legal obligation under Union or Member State law applicable to the Data Controller;
the personal data were collected in relation to the offer of information society services.
The erasure of data may not be initiated where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation requiring processing under Union or Member State law applicable to the Data Controller, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller; for reasons of public interest in the area of public health; for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes; or for the establishment, exercise or defense of legal claims.
Right to restriction of processing
At the request of the data subject, the Data Controller shall restrict processing 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 enabling the accuracy of the personal data to be verified;
the processing is unlawful and the data subject opposes the erasure of the data and requests the restriction of their use instead;
the Data Controller no longer needs the personal data for the purposes of processing, but the data subject requires them for the establishment, exercise or defense of legal claims; or
the data subject has objected to processing; in this case, the restriction applies for the period until it is established whether the legitimate grounds of the Data Controller override those of the data subject.
Where processing has been restricted, such personal data may, with the exception of storage, only be processed with the data subject’s consent, or for the establishment, exercise or defense of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the Union or of a Member State.
Right to data portability
Where data processing is carried out by automated means, or where the data processing is based on your voluntary consent, you have the right to request from the Data Controller that you receive the data you have provided to the Data Controller, which the Data Controller shall make available to you in xml, JSON, or csv format. If technically feasible, you may request that the Data Controller transmit the data in this format to another data controller.
Right to object
The data subject has the right to object at any time, on grounds relating to their particular situation, to the processing of their personal data carried out in the public interest or in the exercise of official authority vested in the Data Controller, or to processing necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party, including profiling based on those provisions. In the event of an objection, the Data Controller may no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or which relate to the establishment, exercise or defense of legal claims.
Automated decision-making in individual cases, including profiling
The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.
Right to withdraw consent
The data subject has the right to withdraw their consent at any time.
Right to go to court
If the data subject’s rights are violated, they may bring an action against the Data Controller before a court. The court shall proceed in the case out of turn.
Data protection authority procedure
Complaints may be lodged with the Nemzeti Adatvédelmi és Információszabadság Hatóság:
Name: Nemzeti Adatvédelmi és Információszabadság Hatóság
Registered office: 1125 Budapest, Szilágyi Erzsébet fasor 22/C.
Mailing address: 1530 Budapest, Pf.: 5.
Phone: 0613911400
Fax: 0613911410
E-mail: ugyfelszolgalat@naih.hu
Website: http://www.naih.hu
Other provisions
The Data Controller shall provide information on data processing not listed in this notice at the time the data are collected.
We inform our customers that the court, the prosecutor, the investigating authority, the authority for minor offenses, the administrative authority, the Nemzeti Adatvédelmi és Információszabadság Hatóság, the Magyar Nemzeti Bank, as well as other bodies authorized by law, may contact the Data Controller for the provision of information, the disclosure or transfer of data, or the making available of documents.
The Data Controller shall disclose personal data to the authorities only to the extent and in such scope as is strictly necessary for achieving the purpose of the request, provided that the authority has indicated the exact purpose and scope of the data requested.
