DATA PROCESSING INFORMATION

The principle of fair and transparent data processing requires that the data subject should be informed of the fact and purposes of the data processing. The present Data Processing Information (hereinafter referred to as “Information”) informs the data subjects about the personal data processed in the course of the business or administrative activities of Kor-Product Kft in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter referred to as “GDPR” or “Regulation”), in particular Articles 13 and 14.

This Information is effective from 01/07/2020 until revoked.

1. NAME OF DATA CONTROLLER

data controller’s full company name:	Kor-Product Korlátolt Felelősségű Társaság (Kor-Product Limited Liability Company)
data controller’s short company name	Kor-Product Kft. (Kor-Product Ltd)
data controller’s registered office:	2040 Budaörs, Gyár utca 2
data controller’s company registration number:	Cg.13-09-115547
data controller’s tax number:	13047498-2-13
data controller’s e-mail address:	levaij@kor-product.hu; levai.gabor@kor-product.hu
data controller’s representatives:	Lévai Gábor managing director; Lévai Judit managing director

2. the purpose, legal basis and duration of data processing

2.1. Purpose and legal basis of the data processing concerning the personal name and e-mail address provided by you to ensure contact: the purpose of the data processing is to ensure the possibility of online communication between Kor-Product Kft and the customer. Online contact allows the person / customer to request a quote or other information from Kor-Product Kft about the business / industrial activities carried out by Kor-Product Kft. The purpose of electronic communication and thus related data processing is to simplify communication with customers. In order to establish electronic contact, it is essential to provide the name and e-mail address of the data subject. According to Article 6 (1) (a) of GDPR, the legal basis for data processing is based on the data subject's consent, i.e. your consent. You can choose at any time to contact Kor-Product Kft in writing or in person, electronic contact is not mandatory.

2.2. Kor-Product Kft draws your attention to the fact that it is not necessary for the e-mail address to contain personal data. For example, it is not necessary for the email address to include your name, you are therefore completely free to decide whether to provide Kor-Product Kft with an e-mail address that contains information about your identity to ensure contact. As long as no contract is concluded, you also have the option of using a different name (nickname) instead of your personal name when contacting us.

2.3. By the e-mail sent by you and delivered to Kor-Product Kft., you give your consent - based on a voluntary decision - for Kor-Product Kft to process your personal data provided by you in accordance with Section 2.1., until your consent is revoked. You can withdraw your consent at any time by sending a letter to levaij@kor-product.hu or levai.gabor@kor-product.hu.

2.4. Purpose and legal basis of the data processing concerning name, address data, electronic mailbox address and telephone number provided by you in order to fulfill the contract: the purpose of data processing that in the course of the legal relationship established between Kor-Product Kft and the customer, Kor-Product Kft should be able to fulfill its contractual obligations, in doing so, it can Kor-Product Kft should be able to contact the customer in the necessary cases and in the necessary way; and should be able to deliver the product ordered by the customer to the delivery address provided by the customer as well as should be able to issue the transport documents of the products and the accounting documents related to the completed transaction. Legal basis for data processing: based on Section (1)b) of Article 6 of GDPR. The regulation referred to considers and recognizes the data processing necessary for the performance of the contract as an appropriate legal basis. Kor-Product Kft would like to draw your attention to the provisions of section 2.2, and to the fact that - if the relevant authorization or consent is obtained from the entitled person – you are entitled to provde any phone number where you can be reached. In case of non-provision of data, the fulfillment of the contract may be impossible, in which case Kor-Product Kft may withdraw from the conclusion of the contract.

2.5. If the legal basis for data management is provided by the performance of a contract, Kor-Product Kft manages the data of the data subject after the termination of the contract in order to submit, enforce and protect the legal claims arising from the contract, as follows: Kor-Product Kft shall retain the ersonal data of the data subject which have not been deleted after the failure to conclude the contract or after the termination of the contract for five years after the failure to conclude the contract or after the termination of the contract, the general statute of limitations of Act V of 2013 on the Civil Code. n the case of certain contracts with a specific subject (eg construction and installation contracts, public procurement contracts) this period may be longer than 5 years under the provisions of the contract or the law.

2.6. Purpose and legal basis of the data processing concerning the personal name, address data and tax number provided by you in order to fulfill a legal obligation: the purpose of data processing is to perform data processing in accordance with the legislation. Kor-Product Kft is obliged to issue and keep an accounting document / invoice for all actual or future economic events. Such an obligation is laid down, inter alia by Sections 166-168 of Act C of 2000 on Accounting, Act CXXVII of 2007 on Value Added Tax (VAT Act) and regulations issued under its authority, in particular Decree No. 23/2014 (VI. 30.) NGM on the Tax Identification of Invoices and Receipts, and on the Supervision by the Tax Authority of Electronically Stored Invoices, as well as Decree 48/2013 (XI. 15.) NGM on the Technical of Cash Registers and the Turnover, Use and Maintenance of Cash Registers Capable of Issuing Invoices and the Transfer of Data Recorded by Cash Registers to the Tax Authority. Considering that the data collection and data processing - according to this point - is the legal obligation of Kor-Product Kft, the provision of personal data is mandatory, in the event of non-provision of data, the performance of the contract may be impossible, and Kor-Product Kft may become entitled to withdraw from the contract or refuse to perform the contract. The legal basis for data processing is provided by Article 6 (1) (c) of the GDPR (data processing necessary to fulfill a legal obligation applicable fot the data controller).

2.7. Kor-Product Kft is obliged to keep the data in a readable form for at least 8 years on the personal name, address data and tax number provided by you in order to issue the accounting document in accordance Section (1) of 169 of Act C of 2000 on Accounting and to process it for the purposes related to the above. Corrupted copies of strictly accounted for documents are also subject to this retention obligation. The retention period under the Accounting Act begins when the document to be retained is created.

2.8. The Cookie policy related to the use of the website of Kor-Product Kft is included in Annex 1 of this Information.

3. the source of the personal data or the scope of the processed data, if they were not made available by the data subject to the data controller

3.1. Kor-Product Kft does not process personal data that has not been collected from the data subject

4. recipients of personal data AND categories of recipients

4.1. Kor-Product Kft does not use a data processor in connection with the data management mentioned in Sections 2.1 - 2.6 of this Information and does not transfer personal data to third parties. In the scope referred to in Section 2.8, Google Inc. (1600 Amphitheater Parkway, Mountain View, CA 94043, USA) performs data processing activities.

5. data PROCESSING rights of the data subject

5.1. Right of access: The data subject is entitled to request information from Kor-Product Kft via the contact details provided in point 1. as to whether the processing of its personal data is in progress, and if such data processing is in progress, it is entitled to find out that

• - what kind of personal data of the data subject is processed by Kor-Product Kft; on what legal basis; for what data procesing purpose; and how long, as well as
• - to whom, when, under what legislation did Kor-Product Kft provide access to the ata subject’s personal data; or to whom Kor-Product Kft has transferred the personal data of the data subject;
• - what is the source of the data subject's personal data
• - does Kor-Product Kft use automated decision-making and its logic, including profiling.

5.2. Kor-Product Kft shall provie a copy of the personal data - which are the subject of the data processing - make it available free of charge for the first time at the request of the data subject, thereafter, Kor-Product Kft may charge a reasonable fee based on administrative costs. In order to meet data security requirements and protect the rights of the data subject, Kor-Product Kft is obliged to make sure that the identity of the data subject and the person wishing to exercise the right of access match, for this purpose the information, access to the data and the issuance of a copy of them are also subject to the identification of the data subject.

5.3. If the data subject has submitted its request by electronic means, the requested information shall be provided in a widely used electronic form, unless the data subject requests otherwise. Kor-Product Kft may request the data subject to clarify the content of the request and to specify the requested information and data processing activities precisely before fulfilling the request.

5.4. If the data subject's right of access under this section adversely affects the rights and freedoms of others, in particular the business secrets or intellectual property of others, Kor-Product Kft is entitled to refuse the fulfillment of the data subject's request to the necessary and proportionate extent.

5.5. In the event that the data subject requests the above information in several copies, Kor-Product Kft is entitled to charge a fee, which shall be proportionate and reasonable to the administrative costs of preparing the additional copies. If Kor-Product Kft does not manage the personal data indicated by the data subject, Kor-Product Kft is also obliged to inform the data subject in writing.

5.6. Right of correction: the data subject may request Kor-Product Kft - via the contact details provided in point 1 – to modify any of its personal data. If the data subject can reasonably prove the accuracy of the corrected data, Kor-Product Kft will fulfill the request without unjustified delay, but within a maximum of 25 days, and will notify the data subject via the contact details provided by it.

5.7. Right to block (limit data management): The data subject may request, via the contact details provided in point 1, that the processing of its personal data be restricted by Kor-Product Kft (by clearly indicating the limited nature of the data processing and ensuring separate handling from other data), if (a) the data subject disputes the accuracy of its personal data (in this case, Kor-Product Kft shall limit data processing for the time when the accuracy of the personal data is being checked); (b) the data processing is unlawful and the data subject opposes the deletion of the data and instead requests restrictions on the use of the data; (c) the controller no longer needs the personal data for the purpose of data processing, but the data subject requests them in order to submit, enforce or protect its legal claims; or (d) the data subject has objected to the data processing (in this case, the restriction shall apply for the period until it is established whether the legitimate reasons of the data controller was considered a priority over the legitimate reasons of the data subject).

5.8. Right to protest: the data subject may object to the data processing via the contact details of the data controller provided in point 1, if, in its opinion, Kor-Product Kft would not properly handle its personal data in connection with the purpose indicated in the data processing information concerning the given procedure. In this case, Kor-Product Kft must certify that the processing of personal data is justified by compelling legitimate reasons which take precedence over the interests, rights and freedoms of the data subject, or which relate to the submission, enforcement or protection of of legal claims. In connection with data processing for the purpose presented in Section 2.6 - having regard to its legal basis - the data subject does not have the right to protest.

5.9. Right to delete: The data subject is entitled to request, via the contact details of the data controller provided in Section 1, that Kor-Product Kft should delete personal data relating to it without unjustified delay, if one of the following reasons exists: (a) the personal data indicated by the data subject is not necessary for the purpose for which they were collected or otherwise processed by Kor-Product Kft; (b) Kor-Product Kft processed the personal data (including special data) on the basis of the data subject's consent, the data subject withdrew its consent in writing and there is no other legal basis for the data processing; (c) the data subject protests against the data processing with regard to data processing based on the legitimate interests of Kor-Product Kft; and there is no compelling legitimate reason for Kor-Product Kft that takes precedence over the interests, rights and freedoms of the data subject, or which are related to the submission, enforcement or protection of legal claims; (d) Kor-Product Kft has processed the personal data unlawfully; (e) the data managed by Kor-Product Kft must be deleted in order to fulfill the legal obligation prescribed by the EU or national law applicable to the data controller; (f) the data subject objects to the data processing and there is no priority reason for the data processing.

5.10. The data subject shall submit its request for deletion in writing and shall indicate which personal data it intends to delete and for what reason.

5.11. If Kor-Product Kft accepts the request of the data subject for deletion, then the processed personal data shall be deleted and the data subject shall be informed accordingly.

5.12. In the event that Kor-Product Kft is obliged to delete the personal data of the data subject, Kor-Product Kft shall take all reasonable steps - including the application of technical measures - that are necessary to inform the data controllers who have become aware of the personal data of the data subject as a result of their disclosure about the mandatory deletion of personal data. Kor-Product Kft - after fulfilling the request of the data subject to exercise its right of cancellation - immediately informs the persons to whom the personal data of the data subject was communicated, provided that this is not impossible or does not require a disproportionate effort from the data controller. At the request of the data subject, the controller shall inform it about these recipients.

5.13. Right to data transmission: The data subject is entitled to request, via the contact details of the data controller provided in Section 1, to receive the personal data concerning it, the personal data provided by it to Kor-Product Kft in a structured, widely used, machine-readable format, and has the right to transfer this data to another data controller, without this being prevented by Kor-Product Kft.

5.14. Right to legal remedy: if the data subject considers that the processing of its personal data by Kor-Product Kft violates the provisions of the data protection legislation in force at any time, in particular the regulations of GDPR, it has the right to submit a complaint to the National Authority for Data Protection and Freedom of Information.

5.15. Contact details of the National Authority for Data Protection and Freedom of Information:

Website: http://naih.hu/
Address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c.
Postal address: 1530 Budapest, Pf.: 5.
Telephone: +36-1-391-1400
Fax: +36-1-391-1410
E-mail: ugyfelszolgalat@naih.hu

5.16. The data subject also has the right to complain to another supervisory authority, in particular a supervisory authority established in the Member State of the European Union where the habitual residence, place of employment or place of the alleged infringement is situated.

5.17. Right of appeal to a judicial body (right to start a judicial action)

5.18. Irrespective of its right to complain, the data subject may apply to a judicial body if its rights under the GDPR have been violated in the processing of its personal data. The data controller - as a data controller with a domestic place of business - can be sued before a Hungarian Court. In accordance with to Section 22 (1) of Act CXII of 2011 on information self-determination and freedom of information, the data subject may also bring an action before the court of his place of residence.

5.19. The contact details of the courts in Hungary can be found at the following link: http://birosag.hu/torvenyszekek.

5.20. In view of the fact that the data controller does not constitute a public authority exercising public authority of a Member State, the data subject may also bring an action before the competent court of the Member State of habitual residence, if the data subject has its habitual residence in another Member State of the European Union.

ANNEX 1

COOKIE POLICY

Kor-Product Kft uses cookies in connection with the operation of the www.kor-product.hu website in order to offer a personalized user experience. Kor-Product Kft processes the data collected in the course of operation of the website and regarding visitors to the website and their use of the services available on the website.

The present Information is regarded as information in accordance with Article 13 of the GDPR (EU Regulation 2016/679).

What is a cookie file?
A cookie is a small file that is created when you visit a website. The purpose of cookies is to improve the user experience of websites. Of course, Kor-Product Kft respects the protection of your personal data. Therefore, we are very happy to share with you the types of cookies we use, as well as how you can prevent the cookie from being saved on your computer and the consequences for you as a user of the website. Cookies are mainly processed by servers or operators of specific websites, as well as by operators of advertising systems used on specific websites. Cookies are processed for the time required to use them, however, the maximum is 1 year from the creation of the cookie.

You do not have to accept or allow the use of cookies; you can refuse the use of cookies or delete them at any time through your browser's settings (usually found in the Privacy settings in the Tools / Settings menu).

The information collected by cookies about you or the device you use (e.g. computer, tablet, smartphone) may include, in particular:

• - the date of entering and leaving the Website;
• - the IP address you use;
• - your browser type;
• - the pages visited and the time spent there;
• - the service (s) used;
• - the address of the previously visited website.

Please note that these cookies alone cannot identify the visitor, the data collected by cookies cannot be linked to the personal data of the visitor (e.g. name, date of birth, e-mail address, address), except in cases required by law.

We use four types of cookies on our website:

Strictly necessary cookies
These cookies are strictly necessary for you to browse the www.kor-product.hu website and use the special functions of the site.

Functional cookies
These cookies collect information about the user’s behaviour. They allow the website to remember login information, to ensure the security of data and the consistency of the appearance of our pages. These cookies will not be deleted after you have finished browsing the website.

Performance cookies
Performance cookies collect information about how you use websites. These allow us to understand how visitors use our websites and then improve the look, content and functionality of our pages.

Special (targeting) cookies
Marketing cookies allow sharing and liking. In addition they sent information for other Internet sites, so that they can customize their ads to best suit your interests.

Setting cookies
Most web browsers support the use of cookies. When setting up your browser, you can manually delete, stop or completely disable the specific cookies. You can only enable cookies on certain websites. On our website, you can easily and for free disable the processing of cookies through your browser. If you allow the use of cookies in your browser, we assume that you accept the use of standard cookies used by our servers and websites.

You can find information about the cookie settings of the most popular browsers on the following pages: Google Chrome; Firefox; Microsoft Internet Explorer 11; Microsoft Internet Explorer 10; Microsoft Internet Explorer 9; Microsoft Internet Explorer 8; Microsoft Edge; Safari.
More http://www.youronlinechoices.com/hu/

Analytical tools
In the context of advertising services our websites use analytical tools. Thanks to these, we can implement advertising campaigns, evaluate the behaviour of our customers, monitor and record errors in our web interface.

Salesforce
We use the Salesforce data management platform to collect data about the use of our website and other digital interfaces. With the help of this information, we have the opportunity to determine the target audience of our online advertisements. Our goal is to offer relevant products and services for the users, at the most optimal time possible. We determine the audience of our advertisements based on interest (e.g. searchers for welded products) or other criteria.

Google Analytics
This is used for monitoring the behaviour of our customers browsing our websites. We evaluate the user based only on cookies. We do not use any other data and this ensures the anonymity of the user. You can restrict or disable your use of the tool in the “Setting up ads” menu, here:  https://www.google.com/settings/ads 
You can read about privacy and the Google Terms of Service here: https://www.google.com/intl/hu/policies/privacy/.

Facebook
A tool to measure the effectiveness of online communication in marketing and to more effectively customize online advertising on Facebook. More information: https://hu-hu.facebook.com/policies/cookies/

Most browsers automatically accept cookies by default, but these settings can usually be changed, thus, instead of automatic acceptance, it is possible for the User's web browser to offer the option for the User to decide whether or not to allow cookies.

In case of blocking or deleting the use of cookies, the User may not be able to fully use the functions of the Kor-Product Kft website or the website will work differently in the browser than planned.

The automatically collected data is stored for up to 72 hours from the time the data was recorded. Data related to the use of the Website shall be retained by the Data Controller or the Data Processor involved in the operation of the Website (see below) for the period of 6 months from the date of its recording, then delete it or anonymize it if necessary. Anonymized data can be used for statistical purposes at any time.