User agreement

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DATA PROCESSING INFORMATION

1. Name, headquarters and representative of the data processor
Name: HOTEL CARBONA Zrt.
Headquarters: 8380 Hévíz, Attila út 1.
Legal representative: Zsuzsanna Müller-Pápai CEO
Data protection contact: Dr Boldizsár Morvay solicitor

2. Data protection officer:
– To be selected on 25 May 2018, his/her details will be published on our website

3. Specification of processed data:
– The name, e-mail address and the area of interest in thee wider sense that may be linked to the data subject from the subject of the chosen newsletter

4. Purpose of data processing:
– Sending newsletters in the selected topic, sending special offers and other items, provision of up to date information, offers, contact for the purpose of direct marketing

5. Legal basis of data processing:
– Approval of data subject

6. Legal consequences of failure to provide data:
– In this case subscription to the newsletter does not take place, data processing does not take place

7. Data forwarding:
– The data are only and exclusively forwarded to the company creating the newsletter and the companies performing the newsletter sending service.

Name of data processor producing the newsletters: Millennium Health and Leisure Travel Kft.
Headquarters: 1061 Budapest, Andrássy út 2.
Representative: Petra Réka Pais

Name of data processor performing the newsletter sending service: Mailerlite (www.mailerlite.com)
Headquarters: 11341 Litvánia, Vilnius, Paupio g. 46
Representative: Ignas Rubezius

Name of data processor performing the newsletter sending service: Protopmail Zrt.
Headquarters: 1097 Budapest, Könyves Kálmán krt. 12-14.
Representative: Gábor Koncz

– Data is not forwarded to third countries.

8. Legal basis of data forwarding:
– Approval of data subject

9. Duration of processing of personal data:
– The data are processed until the authorisation of the data subject is withdrawn. It is possible to unsubscribe from the newsletter at the end of each newsletter, which also means that the data subject requests that his/her e-mail address be erased.

10. Information about the rights of the data subject
The data subject has the right to
– obtain information from the data controller whether his/her personal data are currently being processed, and if such data processing is taking place, he/she is entitled to gain access to this personal data.
– request the rectification of inaccurate personal data relating to him/her without any undue delay.
– request that the data relating to him/her be erased without any undue delay, and the data controller is obliged to erase the personal data relating to the data subject without any undue delay in the case that other conditions are fulfilled.
– request that the data controller restrict the data processing, if
o the data subject disputes the accuracy of the personal data, /the restriction lasts until the data controller checks the accuracy of the personal data,/
o the data processing is unlawful, and the data subject does not want the data erased, instead requests the restriction of their use,
o the data processor no longer requires the personal data but the data subject demands them for the submittal, realisation or protection of legal claims,
o the person involved protested against the data processing; in this case the restriction relates to the period until it is determined whether the data controller’s legitimate grounds override the legitimate grounds of the data subject.
– receive the data relating to him/her and made available to the data controller by him/her in a structured way, in a widely used format, and transmit this data to another data controller without the data controller providing the data preventing this, if the data processing was based on voluntary approval or a contract and takes place automatically.
– if the processing of the personal data takes place in the interest of direct acquisition of business, the data subject is entitled to protest against the personal data relating to him/her being processed for this purpose, including profiling, as long as this is related to the direct acquisition of business.
– the force of decisions based exclusively on automated data processing, including profiling, not affecting him/her that would involve legal effects on him/her or affect him/her in a similarly significant way.
11. Information on profiling, automated decision-making:
– Profiling, automated decision-making do not take place

12. Data storage, data security
HOTEL CARBONA Zrt. and the organisations collaborating as data processor store the data on their own IT devices, which are located at their headquarters. HOTEL CARBONA Zrt. selects and operates the IT devices used by it so that only authorised persons have access to the processed data, that their authenticity and certification remain ensured, their integrity may be verified and are protected against unauthorised access. The data are protected against unauthorised access, alteration, forwarding, publishing, erasure or destruction, as well as against accidental destruction, damage, and against inaccessibility due to any change in the technology used, therefore with respect to the current state of the art HOTEL CARBONA Zrt. applies technical, organisational and organisation measures to ensure the protection of the security of data processing, which provide a level of protection that complies with the risk involved in connection with the data processing.

13. Right to lodge a complaint with the supervisory authority:
In the case the rights of the data subject he/she may launch a court action against the data processor. Judgement of the case belongs to the jurisdiction of the regional court (Zalaegerszeg Regional Court: 1055 Budapest, Markó u. 25. 1363 Pf.: 16.). The data subject may choose to launch the case at the regional court according to his/her registered place of residence or temporary place of residence. The court proceeds in the case without undue delay.
Requests for legal remedy, complaints may be lodged with the Hungarian National Authority for Data Protection and Freedom of Information Headquarters: 1125 Budapest, Szilágyi Erzsébet fasor 22/C. Correspondence address: 1530 Budapest, Pf.: 5. Telephone: 06.1.391.1400 Fax: 06.1.391.1410 E-mail: ugyfelszolgalat@naih.hu Website: http://www.naih.hu

14. Access to the Data Protection Regulations
HOTEL CARBONA Zrt’s complete and fully comprehensive data protection regulations may be accessed via the following link: carbona.hu/en/user-agreement.