Privacy Statement
Lédem 2000 KFT (Headquater:3200, Gyöngyös, Bene út 59-61, Premise: 2490, Pusztaszabolcs, Iksola út 1, 3300 Eger, Berva valley, VAT number: 11179106-2-10) Head Officer: Lévay Sándor
The natural person private data handle protection and the free data flow, as well as the repeal of the 95/46/EK regulation and according to the European Parliament and Council new legislation 2016/679, we would like to introduce.
Present data handle introduction is controls the following websites: www.ledem.hu; http://airbrakeshop.com; http://eger.ledem.hu/ ; http://pusztaszabolcs.ledem.hu/ , and the based on the above mentioned regulation.
The data handler and the availabilities:
Name: LÉDEM 2000 KFT
Headquater: 3200, Gyöngyös, Bene út 59-61
E-Mail: export@ledem2000kft.hu
Tel: +36 37 509-185
Basic definitions:
1. „Private Data”: Relevant any information to identified natural person. idendity the person, who direct or indirect way, who has identifier such as: name, telephone number, location data, online identifier or the natural person, physically, genetically,intellectually,economically, culturally or socially can be identify with one or more factor from these ones.
2. „Data handle”: All the modifications on the private data or on the data base which can be manually or automatically. These modifications can be such as: collection, storage, modification, systematization, introspection, insertion, cencellation,annihilation,limitation.
3. „Data handler”: That person who can be natural or legal, public organisation, agency or any other organisation, which are allocate the private data handle goals and implements individually or with others. If the data management goals and inplements are controlled by the European Union or the actual state law, the data handler or with special consideration for the appointment can be chose by the european or a state law also allocate.
4. „Data processor”: That natural or legal person, public organisation, agency or any other organisation, which control the personal data on behalf of data handler.
5. „Consignee”: That natural or legal person, public organisation, agency, or any other organisation, with whom or with which gave the personal data, independetly from, third participant. Those public organisations, who has unique inspection law, in accordance with the union or state law, access the personal data, those organistaions will not consider as a consignee. The control of the above mentioned data must serve the purpose of the legal and valid data management rules.
6. „Contribution of the person”: Must be voluntary, concrete and properly inroduced and clear, and the participant gives consent permisson to use he/she personal data.
7. „Data protection incident”: The damage of the security, which the forwarded, storaged or other way treated, personal data random or illicit change such as: change, illicit access, loss.
The principles of the usage of the personal data:
Personal data:
a) Handling Legally and fairly, otherwise easily visible for the affected person.
b) Collection: Only specified, clear and legally accepted, and these goals can not be manage by the same way. Due to the 89. article first paragraph the exceptions are:
archiving, scientific and in order to historical useage, and the usage of statistic management.
c) Data management: The goals must be relevant and right and must be limited to the necessary.
d) Accurate: It need to be up-to-date if it is necessary, just and only exact and up-to-date personal data can be use.
e) Storage: The affected personal data can be reachable just and only the way of the identification. The further use of the personal data only if the application inside the 89. article first paragraph mentioned processes such as: archiving, statistic goals.
f) Management: Must be done in the way, that the personal data be in secure against illicit use, unauthorized use or random loss. The data user is the responsible, furthermore be able to verify oneself.
Data management:
Data management which connects to the webshop:
Personal Data The aim of the use
Password Responsible for the safe log in into the account
First and Surname Connects to the purchase, invoicing, contacts
E-mail Contact
Telephone Hold the contact with the invoicing or information about the transportation
Name and address on the invoice Regular way to make invoice furthermore making contracts, modification.
Delivery name and address Allow to deliver the finished goods
Purchasing/ the time of the registraion Technical processes implementation
Purchasing/ Ip address Technical processes implementation
1. In case of e-mail address is not necessary to contain personal data
2. Affected circle: All the users who has account on the webshop
3. The data management duration, the deadline of the deletion of the personal data: Immediately when the registarion deleted. Except accounting processes, according to the act C of 2000. 169. paragraph (2), we must store these informations for 8 years.
4. The consignees of the personal data and the possible data controllers: The personal data only be use by the marketing and the selling colleagues, according to the above mentioned principles.
5. The rights of the third party: The partner can ask from the data controller the modification, deletion or limitation of the useage. Protest from the usage of the personal data, as well as the third party has rights to delete the contribution in any time.
6. The access to the personal data, modification, limit of the usage, the portability of the data, the third party can contact our company in the following ways:
- by Post: 3200, Gyöngyös, Bene út 59-61
- Via E-mail: export@ledem2000kft.hu
Via Telephone: 00 36 37 509 185
7. The legal basis of data management: The contribution of the affected, 6. article (1) paragraph a)point, and Infotv. 5 article (1) paragraph, or the electrical trading services, as well as questions which connected to the informational society services based on the act CVIII of 2001.. 13/A article (3) paragraph.
8. We would like to inform you, that:
- The data management based on your consent
- Required to provide personal data, taht we can fulfill your order
- The outcome of the failure of the data service, that we can not process your order
The used data processors:
Shipping:
1. The activity by the data processor: Delivery of the goods, transportation.
2. The data processor name and accessibility:
- Lédem 2000 Kft, 3200, Gyöngyös, Bene út 59-61
- GLS General Logistics Systems Hungary Csomag- Logisztikai Kft
- TNT Express Hungary Kft
- Liegl & Dachser Szállítmányozási És Logisztikai Kft
- Kühne+Nagel Kft
- Waberer's Network Kft
- Raben Trans European Hungary kft
- Ekol Logistics Kft.
- ABL Vám Sped Kft
- AIRMAX Cargo Budapest Zrt.
- Triem Kft.
- MKM Logistik Kft.
- DSV Hungária Kft
- Jász-Plasztik Kft.
- DPD Hungária Kft.
- Timocom Gmbh.
- Navis Schiffahrts-Und-Speditions Antienges
3. The fact of the data management, the handled data circle: Delivery name, delivery address, telephone number, e-mail address.
4. The affected circle: Every partner who asks home delivery.
5. The goal of the data management: The ordered good delivery to the partner.
6. Duration of the data management, the deadline of the deletion of the data: Till the delivery finished.
7. The legal basis of the data processing: the user access, 6 article (1) paragraph a) point, and info tv 6. article (1) paragraph.
Storage-provider:
1. All the activity by the data processor: Storage-service
2. The storage provider name and accessibility:
Profitárhely Kft.
- Postal address: 6000, kecskemét, Szolnoki út 23
- Telephone: 00 36 20 254 0866
- Fax: 76/ 998 344
- E-mail: ugyfelszolgalat@profitarhely.hu
1. The facts of the data management, the circle of the handled data: All the perconal data from the affected
2. The goal of the data management: All the users who use the website.
3. The duration of the data management, the deadline of the data deletion: Till the contract is valid between the data controller and the storage-provider, or the affected requests a cencellation to the storage-provider to cancel the contract.
4. The legal basis of the data processing: The contribution of the user, the Infotv 5.article (1) paragraph, 6. article (1) paragraph a) point, or the electrical trading services, as well as the questions connected to the informational society services according to the act CVII of 2001. 13/A article (3).paragraph.
The management of the Cookies:
1. Webshop cookies: Protected by password, furthermore cookies which are necessary to the shopping cart and the safety cookies, to use it is not necessary to ask previous permisson from the user.
2. The fact of the data management, the treated data circle: Unique identification number, date, time
3. The affected circle: All the users on the website
4. The goals of the data management: To identify the users, to record the shopping cart and to track the visitors
5. The duration of the data management, the deadline of the deletion of the data
Type of the cookie Legal basis of Data management Data management duration Handled data circle
Session cookies The electrical trading services, as well as the questions about the informational society services accordind to the act CVIII of 2001. 13/A article (3) paragraph Till the related visitor session over connect.sid
6. The entitled person who can work with these data: The data processor do not handle personal data with these cookies.
7. The introduction the the rights of the affected person: The affected person has opportunity to delete the cookies in the browser inside the /settings menu usually inside the data protection menu.
8. The plea of the data management: Not necessary permission from the affected, in case of the usage of the cookies only goal is forward the message on the electrical data network,
Google Adwords conversion tracking use:
1. The data processor uses the „Google Adwords” online adware, furthermore uses the Google conversion tracker application. The Google conversion tracking app is the Google Inc analyst service. (1600 Amphitheatre Parkway, Mountain View, CA, 94043, USA; „Google”).
2. When a user reaches the website by adverts,then a cookie automatically download on the computer which is necessary for the conversion tracking. Those cookies has limited validation, and does not contain personal data, and from these data the user can not be identified.
3. When the user browse the certain parts of the web page,and the cookie still did not expired, then the Google and the data manager also see, that the user clicked onto the advert.
4. Every Google Adwords client get other cookies, so they can not be tracked through the web pages.
5. Informations, which gained with the help of the conversion tracker, these informations helps the Adwords conversion tracker to make conversion statistics. This is optional. This helps the clients to show how many people clicked onto the advert. However, informations will not get it, which helps to identify the user.
6. If you do not like take part in the conversion tracking, then you refuse them, that you block the installation of the cookies. Thereafter you will not be mentioned in the conversion tracking statics.
7. Further information as well as the Google privacy policy accessible on the following link: www.google.de/policies/pivacy/
The Google Analytics application:
1. This web page uses the Google Analytics application, which is the Google Inc. webanalyst service. Google Analytics uses „cookies” which are mainly text files, which are saved to the computer,
2. By the user visited web page’s cookies mainly saved and stored onto the Google server which is in the USA. The IP address anonimity by the Google, always shorten inside the European Union or the European Economic area.
3. The complete IP-address shortening and forwarding on to the Google USA server, only take place in exceptional case. The Google uses these information only to crate evaluation about, how the user used the website, furthermore, that create reports to the website operator about the website activity.
4. Inside the Google Analytics the forwarded IP-address by the user computer the Google will not compare other personal data. The user can block the storage of the cookies by the right settings of the browser, but we draw your attention, in this case some function on the website will not able to use it. The user can also block that the Google collect the usage of the web pages and collect the IP-address, if download and install the following plugin: https://tools.google.com/dlpage/goaptou?hl=hu
Newsletter, DM activity:
1. The economical advert activity basic conditions and individual limitation according to the act XLVIII of 2008. 6.article, the user previously and especially consent, that the provider reach on the accessibility which was given during the registration.
2. The client can also consent that the provider handle the personal data due to the offer.
3. The provider will not send SPAM, and the user can unsubscribe from the messages without limitations and without additional costs. In this case the provider will delete the personal data front he database and will not send further offers to the user.
4. The facts of data collection, the handled data circle and the goals:
Personal data The goals of data management
Name, E-mail address: Identification, Allow to subscribe ont he news letter
Time of subscription Technical processes implementation
The subscribed IP address Technical processes implementation
5. The affected circle: All the users who subscriced to the news letter
6. The aims of data management: Send messages for the affected which contains adverts such as (e-mail, sms, push notifications), give introduction about the actual informations, products, discount and about new functions.
7. Duration of the data management, the deadline of the data deletion: until cencellation of the contribution, till the unsubscribtion.
8. The register number of the data management: not applied
9. Consignees of the personal data, entitled data managers: Personal data can be handle only by the selling and the marketing employees, to respects the avobe mentioned principles.
The affected rights which connects to the data management:
- The affected can ask the data manager, accessibility of the data, can ask also the deletion or limitation of the handling.
- The affected has rights to the data mobility, furthermore has rights to delete the contribution any time.
- The affected can protest from the data management
The access to the personal data, deletion, modification, or limitation to the handling, the mobility to the data, can protest from the data management and the affected do it in the following ways:
- By Post: <company address>
- Via E-mail: <company e-mail address>
- Via Telephone <company telephone number>
The affected can unsubscribe the newsletter free.
The legal basis of the data management: The affected contest, and the 6. article (1) paragraph a)point, the Infotv 5. article (1) paragraph, and based on the act XLVIII of 2008. 6.article (5) paragraph:
The data can only send third party with a previous contribution by the affected.
We would like to inform, that:
- Data management based on your contribution
- The failure of the data service that we can not send you newsletter
- The affected must give personal data, if would like to get newsletter
Notice:
We declare that the users who registered on the LÉDEM 2000 KFT website, we will not send newsletters and DM discount letters nor.
Complaint Management:
1. The fact of data collection, the handled data circle and the aims of data management:
Personal Data The aim of data management
First and Surname Identification, contact
E-mail address Contact
Telephone number Contact
Invoicing name and address Identification, problems with the ordered products, questions and problems.
2. The affected circle: All people who purchesed and has problem with the product quality
3. The duration of the data management, the deadline of the data deletion: Plea in the protocol. According to the act CLV. of 1997. 17/A article (7) paragraph, the company must keep for 5 years.
4. Consignees of the personal data, entitled data managers: Personal data can be handle only by the selling and the marketing employees, to respects the avobe mentioned principles.
5. The affected rights related to the data management:
- The affected can ask the data manager, accessibility of the data, can ask also the deletion or limitation of the handling.
- The affected has rights to the data mobility, furthermore has rights to delete the contribution any time.
- The affected can protest from the data management
6. The access to the personal data, deletion, modification, or limitation to the handling, the mobility to the data, can protest from the data management and the affected do it in the following ways:
- By Post: 3200, Gyöngyös,Bene út 59-61
- Via E-mail: export@ledem2000kft.hu
- Via Telephone: +00 36 37 509 185
7. Legal basis of the data management: The contribution of the affected, 6.article (1) paragrapgh a)point, the Infotv 5.article (1) paragraph, and the law about the consumer protection according to the act CLV. of 1997. 17/A article (7) paragraph.
8. We would like to inform, that:
- The provision of personal data is based on a contractual obligation
- To conclude a contract preconditon to handle the personal data.
- The affected must give personal data, that we can handle the complaint.
Social sites:
1. The fact of data collection, the handled data circle: On Facebook/ Google+/ Twitter/ Pinterest/ Youtube/Instagram etc, affected registrated name and the user public profile picture.
2. Affected circle: Every user, who has registration on the mentioned sites and follow our web page,
3. Aims of data collection: To promote the website, the available products,and share the website.
4. The facts of data collection, the handled data circle and the goals: About the sources, about the handling and the handover mode, the affected can get information on the given site. The data management controlled by the given social site so the duration of the data management such as modification,deletion, controlled by the given web page rules.
5. The legal basis of the data management: The affected require voluntary contribution to menage personal data ont he social pages
Client contacts and other data managements:
1. In case of during using the data management services have questions or possibly have problem, the website can be reach on the mentioned forms: (Telephone, e-mail, social sites).
2. The data controller will delete the incoming e-mails, messages via telephone, on Facebook, with the interested name and e-mail, inside 2 years.
3. Data managements which are not mentioned, we will inform during the data recording.
4. Exceptional offical request, the provider must give introduction and the necessary information towards the authorities.
5. In this case the provider will give just so much information which is necessary.
Rights of the affecteds:
1. Right of access:
The affected entitled to, get feedback from the data controller that the personal data handling is in process or not,if yes have rights to get access to the mentioned informations
2. Rights of modification:
The affected entitled to, ask modification request from the data controller, that modify the inaccurate data without late. You entitled to, to ask to supplement the missing personal data from the data controller .
3. Rights of deletion:
The affected entitled to, that ask the data controller to delete the personal data from the system without late, and the data controller bound to do it immediately.
4. Rights of deletion of the copies:
If the data controller make the data available to the public, and the affected noticed that the data is not valid, the data controller must delete the copies.
5. Rights of the data management limitation:
The affected entitled to, ask the data controller to limitate the data management, if the following conditions are available:
- The personal data are not corrent, not valid, in this case you can ask the data controller to check the validation of the data and modify them if it is necessary.
- If data management is illicit, the affected oppose the deletion of the data, but affected can ask the data controller to limitate the usage.
- The personal data is not more necessary to the data controller, but the affected require it because of rights protection.
- Affected protest from data management, In this case the limitation refers to the duration, till the data controller rights better than the affected rights.
6. Rights of data mobility:
The affected entitled to, get all the personal data which the affected sent to the data controller, widely used, in computerized form, furthermore entitled to get access to the data without hindrance.
7. Rights to protest:
The affected entitled to protest from data management
8. Rights in case of direct marketing:
The affected entitled to, that protest from the data management in case of direct marketing, including the profiling. If the affected protest from the data management, in the following personal data can not be handle for this purpose.
9. Automatized decision make in unique cases, including profiling:
The affected entitled to, do not mentioned in the cases, which are based on automatized data management inclunding profiling, which has legal affects on the user.
The previous paragrapgh can not be applicable in case of if the choice is:
- Based on your contribution
- Have contract between the affected and the data controller, or necessary for fulfillment.
- Those Union or state laws which are related to the affected, or connects to the appropriate measures.
Deadline for action:
- The data controller must inform you about the action without late, inside 1 month from the arrival time.
- If necessary the deadline extend with 2 month. The extension of the deadline must be mention by the data controller with the reasons and this time will not be more than 1 month.
The security of the data management:
a) The incognito and encryption of the personal data
b) Ensuring the security, integrity of the used systems of the personal data handling and services,
c) The ability to back up all the necessary data in time, in case of physical or technical problems.
d) To guarantee the protection of the data management system, and the systematic tests and evaulation.
Inform the affected about data management incidents:
In the introduction clearly and understandable tell to the affected the type of the incident, and tell the name and the availability of the responsible person, must tell the consequences, and the actions to solve the actual problems.
Do not need to be inform the affected,, if either condition be realized:
- The data controller did the perfect protection action technically and organizationally. Such as make the data uninterpretable to other not permitted person.
- The data controller did the perfect action to reduce the high risk, and probably will not happen in the future again.
About data protection incident notify the authorities:
The data controller must notify the responsible authorities about the data protection incident at the latest 72 hours after occurance, based ont he 55. article. Except if the data protection incident will not be risky on the natural person rights. If the notification will not happen inside 72 hours, must attach the proof of delay too.
Possibilities to make complaint:
If the affected has problems against the data controller, it can do it in the National Authority for Data Protection and Freedom of Information
Address: 1125, Budapest, Szilágyi erzsébet fasor 22/C
Postal address: 1530, Budapest, Mailbox: 5
Telephone: + 36 1 391 1400
Fax: + 36 1 391 1410
E-mail: ugyfelszolgalat@naih.hu
Closing remarks:
During writing this document we were takes into consideration the following laws:
- The natural person private data handle protection and the free data flow, as well as the repeal of the 95/46/EK regulation and according to the European Parliament and Council new legislation 2016/679 (2016.april.27)
- Act CXII of 2011- on information self-determination and freedom of information
- Act CVIII of 2001- on certain issues of electronic commerce activities and information society services
- Act XLVII of 2008- on the Prohibition of Unfair Commercial Practices against Consumers
- Act XLVII of 2008- on the essential conditions and certain limitations of business advertising activity
- Act XC of 2005- on the freedom of electronic information
- Act C of 2003- on electronic communications (mainly 155 paragraph)
- Opinion 16/2011 about recommendation of EASA/IAB concerning the best practices of online behavioural advertising
- The prior information about data protection requirments reccommendation by the National Authority for Data Protection and Freedom of Information