Data confidentiality

Privacy Policy

Introduction

prestahu.com submits itself to the following policy.

We provide the following information in accordance with 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 Directive 95/46/EC ( General Data Protection Regulation).

This Privacy Policy is based on the above requirements and covers the following sites: prestahu.com

This policy is available at:

https://prestahu.com/content/8-data-confidentiality

Amendments to this policy take effect upon publication at the above address.

Name: KORELVISION SRL

Registered office: Târgu Mureș, Str. Libertății nr. 2/A, 540031

email: info@prestahu.com

Phone: +36 30 449 5588

Definitions:

1. ‘personal data’ : 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, an 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;

2. ‘processing’ : any operation or set of operations which is performed on 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;

3. ‘controller’ : the natural or legal person, public authority, agency or 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;

4. ‘processor : a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

5. ‘recipient’ : a natural or legal person, , public authority, agency or another body, to which the 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;

6. ‘ consent of the data subject’ : 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;

7. 7. ‘personal data breach’ : 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 the processing of personal data:

Personal data shall be:

1. processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);

2. collected 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’)

3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’)

4. 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’)

5. 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’)

6. 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 (‘accountability’)

Data processing activities:

Data processing related to operating the web shop

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

1. Personal data: Purpose of processing

2. Username: Identification; required to enable registration.

3. Password: Used for secure login to the user account.

4. First and last name: Required for contact, purchasing and issuing a proper invoice

5. E-mail: Required for communication.

6. Phone number: Communication, for more efficient coordination of questions related to invoicing or delivery.

7. Billing name and address: Issuing a proper invoice, as well as concluding the contract, defining and amending its content, monitoring its performance, invoicing the resulting fees and enforcing related claims.

8. Delivery address: To enable home delivery, if the purchased product is not software.

9. Time of purchase/ registration: Performing a technical operation

10. IP address at the time of purchase/registration: Performing a technical operation

Neither the username nor the e-mail address needs to contain personal data.

2. Data subjects concerned: all data subjects registered on/ purchasing on/visiting as guests the web shop website.

3. Duration of processing, deadline for erasure of data: Immediately upon deletion of the registration. Except for accounting documents, which must be retained by law.

Accounting documents directly and indirectly supporting the bookkeeping records ( including general ledger accounts and analytical or detailed records) must be retained for at least 8 years in a legible form, retrievable by reference to the accounting records.

4. Potential controllers entitled to access the data, recipients of the personal data: The personal data may be processed by the controller's sales and marketing staff, in compliance with the above principles.

5. Description of the data subjects' rights related to data processing:

1. The data subject may request from the controller access to, rectification or erasure of, or restriction of processing of personal data concerning him or her, and

2. may object to the processing of such personal data, and

3. the data subject has the right to data portability and to withdraw consent at any time.

6. The data subject may request access to, erasure, modification or restriction of processing of personal data, data portability, or object to the processing in the following ways:

7. by post: Str. Libertății nr. 2/A, 540031 Târgu Mureș, Romania.

8. by e-mail: info@prestahu.com

For the purpose of providing the service, the service provider may process personal data that are technically indispensable for providing the service. Other conditions being equal, the service provider must choose, and in all cases operate, the tools used in providing the information society service in such a way that personal data are processed only if this is strictly necessary for providing the service and for fulfilling the other purposes defined in this act, and even then only to the extent and for the duration necessary.
Please note that

1. the data processing is based on your consent

2. you are required to provide the personal data so that we can fulfil your order.

3. failure to provide the data means that we cannot process your order.

Use of cookies:

1. Cookies typical of web shops are the so-called “cookies used for password-protected sessions” and “cookies required for the shopping cart”, for which no prior consent from the data subjects is required.

2. The fact of data processing, the scope of data processed: Unique identification number, dates, times

3. Data subjects concerned: All data subjects visiting the website.

4. Purpose of processing: Identifying users, keeping track of the “shopping cart” and tracking visitors.

5. Duration of processing, deadline for erasure of data:

1. Cookie type: session cookies

2. Legal basis of processing: The laws on electronic commerce services and on certain issues of information society services

3. Duration of processing: The period until the end of the relevant visitor session

4. Data processed: connect.sid

6. Potential controllers entitled to access the data: The controller does not process personal data through the use of cookies.

7. Description of the data subjects' rights related to data processing: Data subjects can delete cookies in the Tools/Settings menu of their browsers, usually under the Privacy settings.

8. Legal basis of processing: No consent from the data subject is required if the sole purpose of using cookies is the transmission of a communication over an electronic communications network, or if the service provider strictly needs them to provide an information society service explicitly requested by the subscriber or user.

Use of Google Adwords conversion tracking

1. The controller uses the online advertising programme called “Google AdWords” and, within its framework, uses Google's conversion tracking service. Google conversion tracking is an analytics service of Google Inc. ( 1600Amphitheatre Parkway, Mountain View, CA 94043, USA; ( “ Google” )

2. When the User reaches a website through a Google ad, a cookie required for conversion tracking is placed on their computer. These cookies have limited validity and do not contain any personal data, so the User cannot be identified by them.

3. When the User browses certain pages of the website and the cookie has not yet expired, both Google and the controller can see that the User clicked on the ad.

4. Each Google AdWords customer receives a different cookie, so they cannot be tracked across the websites of AdWords customers.

5. The information – obtained using conversion tracking cookies – serves to compile conversion statistics for AdWords customers who have opted for conversion tracking. In this way, customers learn the number of users who clicked on their ad and were forwarded to a page tagged with a conversion tracking tag. However, they do not receive any information that could identify any user.

6. If you do not wish to take part in conversion tracking, you can refuse it by disabling the installation of cookies in your browser. after that, you will not be included in the conversion tracking statistics.

7. Further information and Google's privacy statement are available on the following page:

www.google.de/policies/privacy/

Use of Google Analytics

1. This website uses Google Analytics, a web analytics service of Google Inc. (“Google”). Google Analytics uses so-called “cookies”, text files that are saved on the computer and help analyse the use of the website visited by the User.

2. The information generated by cookies about the website used by the User is usually transferred to and stored on one of Google's servers in the USA. With IP anonymisation activated on the website, Google first shortens the User's IP address within the Member States of the European Union or in other states party to the Agreement on the European Economic Area.

3. Only in exceptional cases is the full IP address transferred to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate how the User has used the website, to compile reports on website activity for the website operator, and to provide further services related to website and internet use.

4. Within the framework of Google Analytics, the IP address transmitted by the User's browser is not merged with other Google data. The User can prevent the storage of cookies by adjusting the browser settings accordingly; however, please note that in this case not all functions of this website may be fully usable. You can also prevent Google from collecting and processing the data generated by cookies about the User's use of the website ( including the IP address ) by downloading and installing the browser plugin available at the following link:

https://tools.google.com/dlpade/gaoptout?hl=hu

Facebook Pixel

The Facebook pixel is a code that allows the website to report conversions, build target audiences, and give the site owner detailed analytics data on how visitors use the website. Using the Facebook remarketing pixel tracking code, the website can display personalised offers and ads to its visitors on Facebook. The Facebook remarketing list is not suitable for identifying individuals. Further information about the Facebook pixel can be found here:

https://www.facebook.com/business/help/651294705016616

Advertising audiences (Google Ads, Meta)

The controller uses the e-mail addresses of customers and newsletter subscribers to build advertising audiences in the advertising systems of Google Ads (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) and Meta (Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland) (Google Customer Match, Meta Custom Audience).

Before uploading, we convert the e-mail addresses using one-way hashing (SHA-256), so the platforms do not receive them in readable form. The platform matches the hashed data against its own users, deletes data that do not match, and the controller receives no information back about who is included in the audience. In this processing, Google and Meta act as processors.

Scope of data processed: e-mail address, in hashed form. Purpose of processing: displaying relevant offers to existing customers, excluding existing customers from ads aimed at new customers, and building similar audiences.

Legal basis of processing: for newsletter subscribers, the consent of the data subject (Article 6(1)(a) GDPR); for customers, the controller's legitimate interest in promoting its own services (Article 6(1)(f) GDPR).

Duration: until the next update of the audience list, at the latest until consent is withdrawn or an objection is made. The platforms keep list membership for a maximum of 540 days.

Objection and withdrawal: the data subject may at any time request that their e-mail address not be used for this purpose, by writing to info@prestahu.com or by unsubscribing from the newsletter. In that case, it is left out of the next list update.

Newsletter, direct marketing activity

1. Under the act on the basic conditions and certain restrictions of commercial advertising activity, the User may give prior and explicit consent for the Service Provider to contact them with advertising offers and other mailings at the contact details provided during registration.

2. Furthermore, with due regard to the provisions of this policy, the Customer may consent to the Service Provider processing the personal data required for sending advertising offers.

3. The Service Provider does not send unsolicited advertising messages, and the User may unsubscribe from receiving offers free of charge, without restriction and without giving reasons. In this case, the Service Provider deletes all personal data – required for sending advertising messages – from its records and does not contact the User with further advertising material. The User can unsubscribe from advertising by clicking the link in the message.

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

1. Name, e-mail address: identification, enabling subscription to the newsletter.

2. Time of subscription: performing a technical operation.

3. IP address at the time of subscription: performing a technical operation.

5. Data subjects concerned: All data subjects subscribing to the newsletter.

6. Purpose of processing: sending electronic messages containing advertising ( e-mail, SMS, push message )to the data subject, providing information about current news, products, promotions, etc.

7. Duration of processing, deadline for erasure of data: processing lasts until the consent is withdrawn, i.e. until unsubscription.

8. Potential controllers entitled to access the data, recipients of the personal data:The personal data may be processed by the controller's sales and marketing staff, in compliance with the above principles.

9. Description of the data subjects' rights related to data processing:

1. The data subject may request from the controller access to, rectification or erasure of, or restriction of processing of personal data concerning him or her, and

2. may object to the processing of such personal data, and

3. the data subject has the right to data portability and to withdraw consent at any time.

10. The data subject may request access to, erasure, modification or restriction of processing of personal data, data portability, or object to the processing in the following ways:

1. by post: Str. Libertății nr. 2/A, 540031 Târgu Mureș, Romania.

2. by e-mail: at the e-mail address info@prestahu.com;

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

12. Legal basis of processing: the consent of the data subject, and the act on the basic conditions and certain restrictions of commercial advertising activity.

13. Please note that

1. the data processing is based on your consent.

2. you are required to provide the personal data if you wish to receive our newsletter.

Complaint handling

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

1. First and last name: identification, contact

2. E-mail address: communication

3. Phone number: communication

4. Billing name and address: identification, and handling of quality complaints, questions and problems arising in connection with the ordered products.

2. Data subjects concerned: All data subjects who make a purchase on the web shop website and raise a quality objection or file a complaint.

3. Duration of data processing and deadline for erasure of the data.

4. Potential controllers entitled to access the data, recipients of the personal data: The personal data are processed by the sales and marketing staff of the data controller, in compliance with the principles set out above.

5. Description of the data subjects' rights in relation to data processing:

1. The data subject may request from the data controller access to, rectification or erasure of, or restriction of the processing of personal data concerning them, and

2. may object to the processing of such personal data, and

3. the data subject has the right to data portability and the right to withdraw consent at any time.

6. The data subject may request access to, erasure, modification or restriction of the processing of personal data, data portability, or object to data processing in the following ways:

7. by post at the address Str. Libertății nr. 2/A, 540031 Târgu Mureș, Romania.

8. by e-mail at the e-mail address info@prestahu.com,

9. Legal basis of data processing: the consent of the data subject.

10. Please note that

1. the provision of personal data is based on a contractual obligation.

2. the processing of personal data is a prerequisite for concluding the contract.

3. you are obliged to provide your personal data so that we can handle your complaint.

4. failure to provide the data means that we will not be able to handle the complaint you have submitted to us.

Social media sites

1. The fact of data collection and the scope of the data processed:

The name registered on social media sites such as Facebook/Google+/Twitter/Pinterest/Youtube/Instagram, and the user's public profile picture.

2. Data subjects concerned: All data subjects who have registered on Facebook/Google+/Twitter/Pinterest/Youtube/Instagram or similar sites and have "liked" the website.

3. Purpose of data collection: Sharing, "liking" and promoting, on social media sites, certain content elements, products and promotions of the website,

or the website itself.

4. Duration of data processing, deadline for erasure of the data, potential controllers entitled to access the data, and description of the data subjects' rights in relation to data processing: The data subject can obtain information about the source of the data, their processing, the method and legal basis of their transfer on the relevant social media site. The data processing takes place on the social media sites, so the duration and method of processing, as well as the options for erasing and modifying the data, are governed by the rules of the relevant social media site.

5. Legal basis of the data: the data subject's voluntary consent to the processing of their personal data on the social media sites.

Customer relations and other provisions

1. Should the data subject have any questions or problems while using the data controller's services, they may contact the data controller in the ways provided on the website (phone, e-mail, social media sites, etc.).

2. The data controller deletes received e-mails and messages, and data provided by phone, on Facebook, etc., together with the name and e-mail address of the enquirer and any other personal data provided voluntarily, no later than 2 years after the data were provided.

3. Information on any data processing not listed in this notice will be provided when the data are collected.

4. In the event of an exceptional request from an authority, or a request from other bodies authorised by law, the Service Provider is obliged to provide information, disclose and transfer data, or make documents available.

5. In such cases, the Service Provider discloses to the requesting party – provided that it has specified the exact purpose and the scope of the data – only as much personal data, and only to the extent, as is strictly necessary to achieve the purpose of the request.

Rights of data subjects:

1. Right of access

You have the right to obtain confirmation from the data controller as to whether or not your personal data are being processed, and, where that is the case, the right to access the personal data and the information listed in the Regulation.

2. Right to rectification

You have the right to have the data controller rectify inaccurate data concerning you without undue delay at your request. Taking into account the purposes of the processing, you have the right to have incomplete data completed, including by means of providing a supplementary statement.

3. Right to erasure

You have the right to have the data controller erase personal data concerning you without undue delay at your request, and the data controller is obliged to erase personal data concerning you without undue delay where certain conditions apply.

4. Right to be forgotten

Where the data controller has made the personal data public and is obliged to erase them, it shall take reasonable steps, including technical measures, taking account of available technology and the cost of implementation, to inform the controllers processing the data that you have requested the erasure of any copies or replications of those personal data.

5. Right to restriction of processing

You have the right to have the data controller restrict processing at your request where one of the following applies:

1. You contest the accuracy of the personal data; in this case the restriction applies for a period enabling the data controller to verify the accuracy of the personal data.

2. The processing is unlawful and you oppose the erasure of the data and request the restriction of their use instead.

3. The data controller no longer needs the personal data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims.

4. You have objected to the processing; in this case the restriction applies pending the verification of whether the legitimate grounds of the data controller override your legitimate grounds.

6. Right to data portability

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

7. Right to object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data (…), including profiling based on those provisions.

8. Objection to direct marketing

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

9. 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 previous paragraph does not apply if the decision:

1. is necessary for entering into, or the performance of, a contract between you and the data controller;

2. is authorised by Union or Member State law to which the data controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or

3. is based on your explicit consent.

Time limit for action

The data controller will inform you of the action taken on the above requests without undue delay, and in any event within one month of receipt of the request.

Where necessary, this period may be extended by two further months. The data controller will inform you of any such extension, together with the reasons for the delay, within one month of receipt of the request.

If the data controller does not take action on your request, it will inform you without delay, and at the latest within one month of receipt of the request, of the reasons for not taking action and of 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 and science, 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 data controller and the data processor implement appropriate technical and organisational measures to ensure a level of data security appropriate to the risk, including, among other things, as appropriate:

1. The pseudonymisation and encryption of personal data.

2. The ability to ensure the ongoing confidentiality, integrity, availability and resilience of the systems and services used for processing personal data.

3. The ability to restore the availability of and access to personal data in a timely manner in the event of a physical or technical incident.

4. A process for regularly testing, assessing and evaluating the effectiveness of the technical and organisational measures taken to ensure the security of processing.

Communication of a personal data breach to the data subject

If a personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, the data controller will inform the data subject of the personal data breach without undue delay.

The communication to the data subject must describe in clear and plain language the nature of the personal data breach, and must state the name and contact details of the data protection officer or other contact point where more information can be obtained; it must describe the likely consequences of the personal data breach; and it must describe the measures taken or proposed to be taken by the data controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.

The data subject does not need to be informed if any of the following conditions are met:

1. The data controller has implemented appropriate technical and organisational protection measures, and those measures were applied to the data affected by the personal data breach, in particular measures – such as encryption – that render the data unintelligible to any person who is not authorised to access the personal data.

2. Following the personal data breach, the data controller has taken subsequent measures which ensure that the high risk to the rights and freedoms of the data subject is no longer likely to materialise.

3. The communication would involve disproportionate effort. In such cases, the data subjects must instead be informed by means of public communication, or a similar measure must be taken whereby the data subjects are informed in an equally effective manner.

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