This Privacy Policy  contains the information on the personal data processing activities of ALLWIN  Informatika Korlátolt Felelősségű Társaság (hereinafter referred to as: “Allwin”)  in the course of its operation, the using of its website under www.allwinn.hu  (hereinafter referred to as: “Website”) and the communication on its  Website.

The data subject  (hereinafter: “Data Subject”) shall clearly agree and accept the  content of this Privacy Policy before using the functions of the Website and  the services (hereinafter: “Service”) provided by Allwin.

This Privacy Policy  is made in accordance with the provisions of 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 (hereinafter referred to as: “GDPR”). For  convenience the full text of GDPR is available here:  https://eur-lex.europa.eu/eli/reg/2016/679/oj

1.         Name and contact of the data  controller

name: ALLWIN Informatika Korlátolt Felelősségű Társaság;

registered seat: 1111 Budapest, Zenta utca 1. 1. em. 1.,  Hungary;

registering  authority: Fővárosi Törvényszék Cégbírósága;

registration  number: 01-09-200739;

represented by: Nagy István managing  director;

electronical  contact: info@allwin.hu

In relation with  this Privacy Policy Data Subject is a natural person, 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 economic, identity of that natural person.  Personal data means any information relating to an identified or identifiable  natural person.

2.         The purpose and legal basis of data processing,  the sources of the data

2.1.      Contact

By using the „Contact” menu on the Website the Data Subject can  provide his personal data. By giving his consent freely to the processing of  his personal data, the Data Subject allow his questions and queries reach  Allwin, and the Data Subject receive answers, information via his contact  data. The personal data given for contact purposes shall be processed by  Allwin until the withdrawal of the Data Subject’s consent. The withdrawal of  consent shall not affect the lawfulness of processing based on consent before  its withdrawal. In case the further processing of contact data is not  justified, Allwin shall delete such data without delay.

Purpose of the data processing:

Informing and contacting the Data Subject

Legal basis of the data processing:

the consent of the Data Subject (Article 6, Section 1 point (a) of    GDPR)

Scope of processed data:

full name, email address and phone number of the Data Subject

Storing period of data:

until the claim for erasure of the Data Subject, or the erasure of    the data by Allwin, if the further data processing is not justified

2.2.      Conclude a contract

The  Data Subject as the representative of a company or an undertaking may  conclude a contract with Allwin on using services. The personal data of the  Data Subject, as the contact person or representative of the contracting  party, are needed for the performance of such various types of contracts and  the fulfillment of the claims (e.g. complaint, payment notification) resulted  from such contracts.

Purpose of the data processing:

contact between the contracting parties, performance of the contract    

Legal basis of the data processing:

performance of a contract (Article 6, Section 1 point (b) of GDPR),

data processing is necessary for compliance with a legal obligation    to which the controller is subject (Article 6, Section 1 point (c) of    GDPR),

the legitimate interests pursued by the controller or by a third    party (Article 6, Section 1 point (f) of GDPR)

Scope of processed data:

full name, email address, phone number and position of the Data    Subject

Storing period of data:

until the expiry    of the 5 year long general limitation period of contracts set forth in    Hungarian Civil Code, and until the mandatory period set forth by legal    rules, e.g. 8 years set forth in Section 169 in Act C of 2000

2.3.      Newsletter, contact  with advertising purpose

By giving his consent freely to the processing of his personal data,  the Data Subject allow to be informed by Allwin on the actual services, discounts, promotions  and other new information via his contact data. The personal data  given for newsletter and advertising purposes shall be processed by Allwin  until the withdrawal of the Data Subject’s consent. The withdrawal of consent  shall not affect the lawfulness of processing based on consent before its  withdrawal. The Data  Subject may unsubscribe at any time without reasoning from the newsletter of  Allwin.

Purpose of the data processing:

sending newsletter and other marketing materials

Legal basis of the data processing:

the consent of the Data Subject (Article 6, Section 1 point (a) of    GDPR),

paragraph (1) of Section 6 of Act XLVIII of 2008 on the Essential Conditions and Certain    Limitations of Business Advertising Activity

Scope of processed data:

full name, email address and phone number of the Data Subject

Storing period of data:

until the withdrawal of the Data Subject’s consent, or the claim for    erasure of the Data Subject, or the erasure of the data by Allwin, if the    further data processing is not justified

2.4.      Conclude a contract  with third persons

Allwin may conclude a contract on using services or buying products.  The personal data of the contact person or representative of the contracting  parties, are needed for the performance of such various types of contracts.

Purpose of the data processing

contact between the contracting parties, performance of the contract

Legal basis of the data processing:

performance of a contract (Article 6, Section 1 point (b) of GDPR)

Scope of processed data:

full name, email address, phone number and position of the Data    Subject

Storing period of data:

until the expiry    of the 5 year long general limitation period of contracts set forth in    Hungarian Civil Code, and until the mandatory period set forth by legal    rules, e.g. 8 years set forth in Section 169 in Act C of 2000

3.         Rights of the Data Subject

Allwin  shall provide information on action taken on a request under Articles 15 to  22 of GDPR to the Data Subject without undue delay, and in any event within  one month of receipt of the request. That period may be extended by two  further months where necessary, taking into account the complexity and number  of the requests. Allwin shall inform the Data Subject of any such extension  within one month of receipt of the request, together with the reasons for the  delay. Where the Data Subject makes the request by electronic form means, the  information shall be provided by electronic means where possible, unless  otherwise requested by the Data Subject.

If Allwin  does not take action on the request of the Data Subject, Allwin shall inform  the Data Subject without delay and at the latest within one month of receipt  of the request of the reasons for not taking action and on the possibility of  lodging a complaint with a supervisory authority and seeking a judicial  remedy

Information and any  communication and any actions shall be provided free of charge. Where  requests from the Data Subject are manifestly unfounded or excessive, in  particular because of their repetitive character, Allwin may either (i)  charge a reasonable fee taking into account the administrative costs of providing  the information or communication or taking the action requested, or (ii)  refuse to act on the request.

 

Allwin shall bear the burden of demonstrating  the manifestly unfounded or excessive character of the request.

 

The Data Subject may  claim from Allwin in respect of his personal data:

(i) right of access:  the Data Subject shall have the right to obtain from Allwin confirmation as  to whether or not personal data concerning him are being processed, and,  where that is the case, access to the personal data and other information,

(ii) right to  rectification: the Data Subject shall have the right to obtain from Allwin without  undue delay the rectification or completion of inaccurate personal data  concerning him,

(iii) right to  erasure: the Data Subject shall have the right to obtain from Allwin the  erasure of personal data concerning him without undue delay and Allwin shall  have the obligation to erase personal data without undue delay.

Personal data shall  not be erasured to the extent that data processing is necessary:

-         for exercising the right of freedom of expression and information,

-         for compliance with a legal obligation by Union or Member State  law to which Allwin is subject,

-         for the establishment, exercise or defence of legal claims.

(iv) right to  restriction of processing: the Data Subject shall have the right to obtain  from Allwin restriction of processing, if, among others, the accuracy of the  personal data is contested by the Data Subject, or Allwin no longer needs the  personal data for the purposes of the processing, but they are required by  the Data Subject for the establishment, exercise or defence of legal claims;

(v) right to object:  the Data Subject shall have the right to object at any time to processing of  personal data concerning him based on GDPR,

(vi) right to data  portability: the Data Subject shall have the right to receive the personal  data concerning him, which he has provided to Allwin, in a structured,  commonly used and machine-readable format and have the right to transmit those  data to another controller without hindrance from Allwin to which the  personal data have been provided, according to GDPR.

Allwin shall  communicate any rectification or erasure of personal data or restriction of  processing to each recipient to whom the personal data have been disclosed,  unless this proves impossible or involves disproportionate effort. Allwin  shall inform the Data Subject about those recipients if the Data Subject  requests it.

If the data  processing is based on consent, the Data Subject shall have the right to  withdraw his consent at any time.

The Data Subject shall have the right to  lodge a complaint with a supervisory authority, if the Data Subject considers  that the processing of personal data relating to him infringes the GDPR.

The Data Subject can file his complaint  regarding the data processing to the Hungarian National Authority for Data  Protection and Freedom of Information (Nemzeti Adatvédelmi és  Információszabadság Hatóság), with the contact address below:

Address: 1125  Budapest, Szilágyi Erzsébet fasor 22/C, Hungary;

Postal address:  1530 Budapest, Postafiók: 5., Hungary

Tel.:  +36-1-391-1400

E-mail:ugyfelszolgalat@naih.hu; website: www.naih.hu,

 

furthermore the Data Subject shall have the  right to an effective judicial remedy.

4.         Data processing and data transfer

The employees or  contractual partners of Allwin have the right to aware the personal data of  the Data Subject with the obligation of confidentiality and they shall keep  such data confidential.

Allwin works with the following data processors, who are entitled to  recognise personal data in the course of their activity:

-        marketing: Marketera Consultancy Ltd.,21/C Andor street, H1119, Budapest, Hungary, Dominik Vári, dominik.vari@marketera.agency

-       others:

Allwin shall not  transfer any personal data to any third person out of the scope of the data  processors above, unless the Data Subject gives his explicit consent or it is  set forth by legal rules.

In addition to the  persons detailed above, Allwin works with Marketera Consultancy Ltd.,21/C Andor street, H1119, Budapest, Hungary, Dominik Vári, dominik.vari@marketera.agency as a  technical support service provider, who may recognise the personal data in  the course of its activity, but the data shall not be transferred to him by  Allwin.

Allwin does not use automated decision-making process, including  profiling in the course of its data processing.

5.         The place of data  storing

Allwin keeps the  data detailed above in its registered seat and on the servers of its server  provider.

The service provider  of Allwin is: 398 11th Street, 2nd Floor San Francisco, CA 94103

6.         Use of cookies

The Website uses  cookies in order to provide customized information to the visitors of the  Website.  Cookies are short data files  placed by the Website on the visitor’s computer.  These cookies are designed to facilitate  the browsing easier, furthermore to record information on visits and personal  settings.  These data may not be associated  with the identification data of the visitor.   Cookies may be rejected or modified in the settings of the visitor’s  browser.  If the cookies are not  rejected or the visitor clicks on the “Agree” button, the use of cookies  shall be accepted.  If visitor does not  autrorise the use of cookies, he may not be able to use certain features on  the Website

The cookie settings  of the most popular browsers are available on the following links:

Google Chrome:

https://support.google.com/accounts/answer/61416?hl=en

Internet Explorer:

https://support.microsoft.com/en-us/topic/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

Firefox:

https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer

Safari:

https://support.apple.com/en-gb/HT201265

The cookies used on the Website include those:

(i)               cookies that remember user’s choices (functionality cookies); and

(ii)             strictly necessary cookies for access and navigation

Such cookies are  strictly necessary for the functions required by the visitors, and can be  used without specific consent in accordance with relevant legal rules.  Besides, the Website uses cookies for  statistical purposes.  Such cookies  records the events of the visit of the Website, and provide anonym  statistical data to Allwin.  Such  cookies shall be used only in accordance with the consent of the  visitor.  Such cookies shall be stored  for 2 (two) years.

7.         Security measures

Allwin shall, in accordance with the  provisions of GDPR, provide the security of personal data processing and take  such technical measures which provide the security of the recorded, stored  and processed data, and shall do its outmost to prevent the destruction,  unlawful use and modification of the data.

The specific technical and information technology measures are:  protection of data on multiple levels, such as physically protecting data  storage servers, which are secured and supervised by technicians, restricted  access to server rooms by Allwin’s employees, the documents consisting data  are kept in lockers and in rooms equipped with security-alarm and fire-alarm  system. The information technology system is secured by password, firewall  and anti-virus system, an it is only accessed by the employees of Allwin, and  the system administrator as service provider.

 

This Privacy Policy  and any dispute or claim arising out of or in connection with it shall be  governed by in accordance with Hungarian law.

 

Allwin may  change this Privacy Policy at any time at its sole discretion, and such  change shall be effective by the publication on its Website, and shall be  applied for the data processing from the date of publication.