Privacy Policy
Privacy Policy
Data Controller
Name: Attila Berényi e.v.
Registered office: 1149 Budapest, Róna u. 105/A
E-mail: hello@soldeli.hu
Phone number: +3630-108-9495
Website: https://www.soldeli.hu
Hosting provider
Name: Shopify International Limited
Address: 2nd Floor, 1-2 Victoria Buildings, Haddington Road, Dublin 4, D04 XN32, IrelandE-mail address: support@shopify.com
Phone number: +44800-808-5233
Description of the data processing activities carried out in the operation of the webshop
This document contains all relevant information on data processing in connection with the operation of the webshop in accordance with the European Union's General Data Protection Regulation 2016/679 (hereinafter referred to as the Regulation, GDPR) and the 2011 Act CXII of 2011 (hereinafter referred to as the Infotv.).
Information on the use of cookies
What is a cookie?
The Data Controller uses so-called cookies when you visit the website. A cookie is a set of information consisting of letters and numbers that our website sends to your browser in order to save certain settings, facilitate the use of our website and help us to collect some relevant statistical information about our visitors.
Some of the cookies do not contain any personal information and cannot be used to identify the individual user, but some of them contain a unique identifier - a secret, randomly generated sequence of numbers - that is stored on your device, thus ensuring your identification. The duration of each cookie is described in the relevant description of each cookie.
Legal background and legal basis for cookies
The legal basis for processing is your consent pursuant to Article 6(1)(a) of the Regulation.
Main characteristics of the cookies used by the website:
Google Adwords cookie: When someone visits our site, the visitor's cookie ID is added to the remarketing list. Google uses cookies, such as NID and SID cookies, to customise the ads you see in Google products, such as Google Search. It uses such cookies, for example, to remember your recent searches, your previous interactions with advertisements from individual advertisers or search results, and your visits to advertisers' websites. The AdWords conversion tracking feature uses cookies. To track ad sales and other conversions, cookies are saved on a user's computer when they click on an ad. Some common uses of cookies include: selecting ads based on what is relevant for a particular user, improving campaign performance reporting, and avoiding displaying ads that the user has already viewed.
Google Analytics cookie: The service may use cookies to collect information and report statistics about website usage 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, together with some of the advertising cookies described above, can also be used to display more relevant ads in Google products (such as Google Search) and across the web.
Strictly necessary cookies: these cookies are essential for the use of the website and allow you to use its essential functions. Without them, many of the site's features will not be available to you. The lifetime of these types of cookies is limited to the duration of the session.
Currency: Stores the currency of the customer. The lifetime is 30 days.
Facebook pixel (Facebook cookie): A Facebook pixel is a code that allows the website to report conversions, create audiences and provide the site owner with detailed analytics on how visitors use the site. The Facebook pixel is used to display personalised offers and ads to website visitors on the Facebook interface. You can read Facebook's privacy policy here: https://www.facebook.com/privacy/explanation
If you do not accept the use of cookies, certain features will not be available to you. For more information on how to delete cookies, please follow the links below:
Data processed for the purposes of contracting and performance
There may be more than one processing operation for the purposes of contracting and performance. Please note that data processing in relation to complaint handling and warranty management will only take place if you exercise one of these rights.
If you do not make a purchase through the webshop, but are only a visitor to the webshop, the processing for marketing purposes may apply to you if you give us your consent for marketing purposes.
For more details on processing for the purposes of contracting and performance:
Contact
For example, if you contact us by email, contact form or telephone with a query about a product. You can order from the webshop at any time without prior contact.
Data processed
The data you provide when contacting us.
Duration of processingThe data will only be processed until the contact is completed.
Legal basis for processing
Your voluntary consent, which you provide to the Data Controller by contacting us. [Processing under Article 6(1)(a) of the Regulation]
Registration on the website
By storing the data provided during registration, the Data Controller can provide a more convenient service (e.g. the data subject does not have to re-enter his/her data for a new purchase). Registration is not a condition for the conclusion of a contract.
Processed data
The Data Controller processes your name, address, telephone number, e-mail address, the characteristics of the goods purchased and the date of purchase.
Duration of processing
Until your consent is withdrawn.
Legal basis for processing
Your voluntary consent, which you provide to the Data Controller by registering [processing pursuant to Article 6(1)(a) of the Regulation]
Processing of the order
The processing of orders involves processing activities necessary for the performance of the contract.
Data processed
Data processed by the Controller include your name, address, telephone number, e-mail address, the characteristics of the Goods purchased, the order number and the date of purchase.
If you have placed an order in the webshop, the processing and the provision of the data are necessary for the performance of the contract.
Duration of data processing
The data will be processed for 5 years according to the statute of limitations in civil law.
The legal basis for processing
Is the performance of the contract. [Processing under Article 6(1)(b) of the Regulation]
Issuing the invoice
The processing is carried out in order to issue an invoice in accordance with the law and to fulfil the obligation to keep accounting records. Pursuant to Article 169 (1) to (2) of the Act, companies are required to keep accounting documents which directly and indirectly support the accounting.
Processed data
The Data Controller processes your name, address, telephone number, e-mail address.
Duration of data processing
According to Section 169 (2) of the Public Provisions Act, invoices issued must be kept for 8 years from the date of issue of the invoice.
Legal basis for data processing
Pursuant to Article 159 (1) of Act CXXVII of 2007 on Value Added Tax, the issue of invoices is mandatory and must be kept for 8 years pursuant to Article 169 (2) of Act C of 2000 on Accounting [data processing pursuant to Article 6 (1) (c) of the Regulation].
Data processing related to transportation
The data processing is carried out for the purpose of delivering the ordered product.
Processed data
The Data Controller processes your name, address, telephone number, e-mail address.
Duration of processing
The Data Controller processes the data for the duration of the delivery of the ordered goods.
Legal basis for processing
Contract performance [processing under Article 6(1)(b) of the Regulation].
Processing for marketing purposes
Processing in connection with the sending of newsletters
The processing is carried out for the purpose of sending out newsletters.
Data processed
The Data Controller processes your name, address, telephone number, e-mail address.
Duration of processing
Until the data subject's consent is withdrawn.
Legal basis for processing
Your voluntary consent, which you give to the Controller by subscribing to the newsletter [processing pursuant to Article 6(1)(a) of the Regulation]
Remarketing
Data management as a remarketing activity is carried out using cookies.
Data processed
The data processed by cookies as defined in the cookie notice.
Duration of data processing
Duration of the data storage period of the cookie, more information is available here:
Google general cookie notice:https://www.google.com/policies/technologies/types/
Google Analitycs 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 basis for the processing
Your voluntary consent to the processing of your personal data by the Data Controller through the use of the website [processing in accordance with Article 6(1)(a) of the Regulation].
Other data processing
If the Data Controller intends to carry out further processing, it will provide prior information on the relevant circumstances of the processing (legal background and legal basis of the processing, purpose of the processing, scope of the data processed, duration of the processing).
Recipients of the personal data
Processing for the storage of personal data
Name of data processor: Shopify International Limited
Contact details of the data processor:
Phone number: +44800-808-5233
E-mail address: support@shopify.com
Address: 2nd Floor, 1-2 Victoria Buildings, Haddington Road, Dublin 4, D04 XN32, Ireland
Website: https://www.shopify.com/
The Data Processor stores personal data on the basis of a contract with the Data Controller. The Data Controller is not entitled to access personal data.
Data processing activities related to the sending of newsletters
Name of company operating the mailing system: Shopify International Limited
Mailing system operator headquarters: 2nd Floor, 1-2 Victoria Buildings, Haddington Road, Dublin 4, D04 XN32, Ireland
Phone number of the company operating the mailing system: +44800-808-5233
E-mail address of the company operating the mailing system: support@shopify.com
Website of the company operating the mailing system: https://www.shopify.com/
The Data Processor contributes to the sending of newsletters on the basis of a contract with the Data Controller. In doing so, the Data Processor processes the name and e-mail address of the data subject to the extent necessary to send the newsletter.
Processing of data in relation to billing
Name of the data processor: Billingo Technologies Zrt. www.billingo.hu online billing software
Data processor's registered office: 1133 Budapest, Árbóc utca 6., III. floor
Phone number of the data processor: +361-500-9491
E-mail address of the data processor: hello@billingo.hu
Website of the data processor: https://www.billingo.hu
The Data Processor contributes to the recording of accounting documents on the basis of a contract with the Data Controller. In doing so, the Data Processor shall process the name and address of the data subject to the extent necessary for the accounting records, for the period of time pursuant to Section 169 (2) of the Act, after which it shall delete them.
Data processing in connection with the operation of the CRM system
Name of the data processor: Shopify International Limited
Data Processor's registered office: 2nd Floor, 1-2 Victoria Buildings, Haddington Road, Dublin 4, D04 XN32, Ireland
Data Processor's telephone number: +440800-808-5233
E-mail address of the data processor: support@shopify.com
Website of the data processor: https://www.shopify.com/
The Data Processor shall assist in the registration of orders on the basis of a contract with the Data Controller. In doing so, the Data Processor shall process the name, address, telephone number, number and date of orders of the data subject within the limitation period of civil law.
Data processing in relation to online payments
The name of the data controller is Simple Pay, OTP Mobil Kft.
OTP Pay, OTP Pay is the Hungarian Pay Service Provider.
Phone number of the data controller: +361-5100-374
E-mail address of the data controller: ugyfelszolgalat@simple.hu
Website of the data controller: www.simplepay.hu
The payment service provider is contracted by the Data Controller to assist in the implementation of the Online Payment, for which purpose data is transferred to the online payment service provider during the purchase process. In doing so, the online payment service provider will process the billing name and address of the data subject, the order number and the date of the order in accordance with its own data processing rules.
The purpose of the data transfer is to provide the online payment service provider with the transaction data necessary for the payment transaction related to the purchase initiated with the online payment service provider.
Legal basis for the transfer: the performance of a contract between you and the Data Controller pursuant to Article 6(1)(b) of the Regulation, which includes the payment by the customer and, in the case of online payment, the transfer of data pursuant to this point is necessary for the payment.
Data processing activities related to the transport of goods
The name of the data controller: GLS General Logistics Systems Hungary Csomag-Logisztikai Kft.
Headquarters of the controller: 2351 Alsónémedi, GLS Európa utca 2.
Telephone number of the data controller: 06-29-88-67-00
E-mail address of the data controller: info@gls-hungary.com
Website of the data controller: https://gls-group.eu/HU/hu/home
The Data Processor shall cooperate in the delivery of the ordered products on the basis of a contract with the Data Controller, whereby the Data Processor may process the name, address and telephone number of the customer until the end of the calendar year following the dispatch of the postal consignment, after which it shall delete them immediately.
Your rights in the processing of your data
During the period of processing, you have the following rights under the Regulation:
- the right to withdraw your consent
- access to personal data and information relating to the processing
- the right to rectification
- restriction of processing,
- the right to access to personal data and to obtain information on the processing of personal data, including the right to access to personal data
- right to object
- the right to portability.
If you wish to exercise your rights, this will involve your identification and the necessary communication with you by the Data Controller. For this purpose, identification will require the provision of personal data (but identification will only be based on data that the Controller already holds about you) and your complaints about the processing will be available on the Controller's email account for the period of time specified in this notice in relation to complaints. If you have been a customer of ours and would like to be identified for the purposes of complaint handling or warranty handling, please also provide your order ID for identification purposes. We can use this to identify you as a customer.
The Data Controller will respond to complaints about data processing within 30 days at the latest.
Right to withdraw consent
You have the right to withdraw your consent to data processing at any time, in which case the data will be deleted from our systems. However, please note that in the case of an outstanding order, withdrawal may result in our inability to deliver to you. In addition, if the purchase has already been made, we may not be able to delete the billing data from our systems under accounting regulations, and if you have a debt to us, we may process your data in the event of withdrawal of consent on the basis of a legitimate interest in the recovery of the debt.
Access to personal data
You have the right to receive feedback from the Data Controller as to whether your personal data is being processed and, if it is being processed, the right to:
- to have access to the personal data being processed; and
- to be informed by the Controller of the following information:
- the purposes of the processing;
- the categories of personal data processed concerning you; and
- information about the recipients or categories of recipients to whom or with which the personal data have been or will be disclosed by the Controller;
- the envisaged period of storage of the personal data or, where this is not possible, the criteria for determining that period;
- your right to obtain from the Controller the rectification, erasure or restriction of the processing of personal data concerning you and, where the processing is based on legitimate interests, to object to the processing of such personal data;
- the right to lodge a complaint with a supervisory authority;
- if the data have not been collected from you, any available information about their source;
- the fact of automated decision-making (where such a process is used), including profiling, and, at least in these cases, clear information on the logic used and the significance and likely consequences for you of such processing.
The purpose of the exercise of this right may be to ascertain and verify the lawfulness of the processing, and the Data Controller may charge a reasonable fee for providing the information in exchange for repeated requests for information.
Access to personal data shall be ensured by the Controller by sending you, by email, the personal data and information processed, after you have identified yourself. If you are registered, we will provide access so that you can view and verify the personal data we process about you by logging into your account.
Please indicate in your request whether you are requesting access to personal data or information about data processing.
Right to rectification
You have the right to have inaccurate personal data relating to you corrected by the Data Controller without delay upon your request.
Right to restriction of processing
You have the right to have the Controller restrict processing at your request if one of the following conditions is met:
- You contest the accuracy of the personal data, in which case the restriction shall apply for the period of time necessary to allow the Controller to verify the accuracy of the personal data, if the accuracy of the data can be established immediately, the restriction shall not apply;
- the processing is unlawful, but you object to the erasure of the data for any reason (for example, because the data are important to you for the purposes of pursuing a legal claim) and therefore do not request the erasure of the data but instead request the restriction of their use;
- the Controller no longer needs the personal data for the purposes for which they are processed but you require them for the establishment, exercise or defence of legal claims; or
- you have objected to the processing, but the Controller may have a legitimate interest in the processing, in which case, until it is established whether the legitimate grounds of the Controller prevail over your legitimate grounds, the processing should be restricted.
Where processing is subject to restriction, such personal data, except for storage, may only be processed with the consent of the data subject or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for important public interests of the Union or of a Member State.
The controller shall inform you in advance (at least 3 working days before the restriction is lifted) of the lifting of the restriction on processing.
Right to erasure - right to be forgotten
You have the right to obtain from the Controller the erasure of personal data concerning you without undue delay where one of the following grounds applies:
- the personal data are no longer necessary for the purposes for which they were collected or otherwise processed by the Controller;
- You withdraw your consent and there is no other legal basis for the processing;
- You object to the processing based on legitimate interest and there is no overriding legitimate ground (i.e. legitimate interest) for the processing,
- the personal data have been unlawfully processed by the Controller and this has been established on the basis of the complaint,
- the personal data must be erased in order to comply with a legal obligation under Union or Member State law applicable to the Controller.
If the Data Controller has disclosed personal data about you for any lawful reason and is required to delete it for any of the reasons set out above, it shall take reasonable steps, including technical measures, taking into account the available technology and the cost of implementation, to inform other data controllers that you have requested the deletion of the links to or copies of the personal data in question.
Deletion does not apply where the processing is necessary:
- for the exercise of the right to freedom of expression and information;
- to comply with an obligation under Union or Member State law that requires the controller to process personal data (such as processing in the context of invoicing, where the storage of the invoice is required by law) or to carry out a task carried out in the public interest or in the exercise of official authority vested in the controller;
- for the establishment, exercise or defence of legal claims (e.g. where the Controller has a claim against you and has not yet settled it, or in the course of dealing with a consumer complaint or a complaint about data processing).
Right to object
You have the right to object to the processing of your personal data based on legitimate interests at any time on grounds relating to your particular situation. In such a case, the Controller may no longer process the personal data unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.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 purposes, including profiling, where it is related to direct marketing. If you object to the processing of your personal data for direct marketing purposes, your personal data may no longer be processed for those purposes.
Right to portability
If the processing is automated or if the processing is based on your voluntary consent, you have the right to request the Data Controller to receive the data you have provided to the Data Controller, which the Data Controller will make available to you in xml, JSON or csv format, and if technically feasible, you may request that the Data Controller transfer the data in this format to another controller.
Automated decision-making
You have the right not to be subject to a decision based solely on automated processing (including profiling) that would have legal effects concerning you or similarly significantly affect you. In such cases, the controller must take appropriate measures to protect the rights, freedoms and legitimate interests of the data subject, including at least the right to obtain human intervention by the controller, to express his or her point of view and to object to the decision.
The above shall not apply where the decision:
- necessary for the conclusion or performance of a contract between you and the controller;
- it is permitted by Union or Member State law applicable to the controller which also lays down appropriate measures to protect your rights and freedoms and legitimate interests; or
- is based on your explicit consent.
Registration in the data protection register
Under the provisions of the Data Protection Act, the Controller was required to notify certain of its processing to the Data Protection Register. This notification obligation ceased as of 25 May 2018.
Data security measures
The Data Controller declares that it has implemented appropriate security measures to protect personal data against unauthorised access, alteration, disclosure, transmission, disclosure, erasure or destruction, accidental destruction or accidental damage and inaccessibility resulting from changes in the technology used.
The Data Controller will make every effort to ensure that its Data Processors also take appropriate data security measures when working with your personal data, as far as organisational and technical feasibility allows.
Legal remedies
If you believe that the Data Controller has violated a legal provision on data processing or has failed to comply with a request, you may initiate an investigation procedure with the National Authority for Data Protection and Freedom of Information to stop the alleged unlawful processing (mailing address: 1363 Budapest, Pf. 9., e-mail: ugyfelszolgalat@naih.hu, telephone numbers: +36 (30) 683-5969 +36 (30) 549-6838; +36 (1) 391 1400).
You are also informed that in the event of a breach of the legal provisions governing data processing or if the Controller has not complied with any of your requests, you may bring a civil action against the Controller before a court.
Amendments to the Privacy Notice
The Data Controller reserves the right to amend this Privacy Notice in a way that does not affect the purpose and legal basis of the processing. By using the website after the amendment has entered into force, you accept the amended privacy notice.
If the Data Controller intends to carry out further processing of the collected data for purposes other than those for which they were collected, the Data Controller will inform you of the purposes of the processing and the information below prior to the further processing:
- the duration of the storage of the personal data or, where this is not possible, the criteria for determining the duration;
- the right to request the Controller to access, rectify, erase or restrict the processing of personal data concerning you and, in the case of processing based on legitimate interest, to object to the processing of personal data and, in the case of processing based on consent or a contractual relationship, to request the right to data portability;
- in the case of processing based on consent, that you may withdraw your consent at any time,
- the right to lodge a complaint with a supervisory authority;
- whether the provision of the personal data is based on a legal or contractual obligation or is a precondition for the conclusion of a contract, whether you are under an obligation to provide the personal data and the possible consequences of not providing the data;
- the fact of automated decision-making (where such a process is used), including profiling, and, at least in these cases, clear information about the logic used and the significance and likely consequences for you of such processing.
The processing may only start after this, if the legal basis for the processing is consent, to which you must give your consent in addition to the information.