1. Purpose of the Privacy Policy

SOS KINCSEM Kft. (2011 Budakalász, Budai út 97. 1. ajtó, hereinafter: service provider, data controller) as data controller acknowledges the content of this legal notice as binding. It undertakes to ensure that all data processing related to its activities complies with the requirements set out in this policy, the applicable national laws, and the legal acts of the European Union. The data protection guidelines related to SOS KINCSEM Kft.'s data processing are continuously available on the website. https://soskincsem.hu/privacy-policy.

SOS KINCSEM Kft. reserves the right to change this notice at any time. Of course, any changes will be communicated to the public in due time. If you have any questions related to this notice, please write to us and our colleague will answer your question. SOS KINCSEM Kft. is committed to protecting the personal data of its clients and partners, and considers it of utmost importance to respect its clients' right to informational self-determination. SOS KINCSEM Kft. treats personal data confidentially and takes all security, technical and organizational measures that guarantee the security of the data. SOS KINCSEM Kft. describes its data management practices below.

2. Data Controller Information

If you wish to contact our company, you can reach the data controller at soskincsem@gmail.com and +36 30 300 3348. SOS KINCSEM Kft. deletes all emails received, together with the stored personal data, no later than half a year after the data is provided.

Name: SOS KINCSEM Kft.

Address: 2011 Budakalász, Budai út 97. 1. ajtó

Company Registration Number: 13-09-243243

Court of Registration: Fővárosi Törvényszék Cégbírósága

Tax Number: 32914713-2-13

Phone: +36 30 300 3348

Email: soskincsem@gmail.com

2.1. Data Protection Officer

• Name: Bánkuti Gábor
• Email: soskincsem@gmail.com
• Phone: +36 30 300 3348

3. Scope of Personal Data Processed

3.1 Data Provided During Contact

There is no registration or contact form on the website. We only process personal data if you contact us directly by phone or email. The data you provide during contact may include: name, email address, phone number, and the content of the message. These data are processed solely for the purpose of responding to your inquiry and are not forwarded to third parties.

3.2 Technical Data

SOS KINCSEM Kft. selects and operates the IT tools used for the provision of services in such a way that the processed data: is accessible to those authorized (availability); its authenticity and authentication are ensured (authenticity of data processing); its integrity is verifiable (data integrity); and it is protected against unauthorized access (data confidentiality). SOS KINCSEM Kft. protects the data with appropriate measures against unauthorized access, alteration, transmission, disclosure, deletion or destruction, as well as accidental destruction. SOS KINCSEM Kft. ensures the security of data processing with technical, organizational, and administrative measures that provide a level of protection appropriate to the risks associated with data processing. During data processing, SOS KINCSEM Kft. preserves confidentiality: protects the information so that only those authorized can access it; integrity: protects the accuracy and completeness of the information and the method of processing; availability: ensures that when an authorized user needs it, they can actually access the required information and the related tools are available.

3.3 Cookie Data

We use Google Tag Manager on the website to measure traffic and user behavior (Google Analytics). Analytical and marketing cookies (e.g. _ga) are only placed on your device after your consent. These cookies help us improve the operation of the website. You can withdraw or modify your consent at any time via the cookie manager interface. For more details on cookie management and how to give consent, please refer to our Cookie Policy.

3.4 Data Related to Online Orders

No product sales take place on the website, so we do not request data related to this.

3.5 Data Related to Online Administration

On https://soskincsem.hu, only phone or email contact is possible; there is no online administration or form.

3.6 Data Related to Newsletters

Currently, there is no newsletter subscription option on the https://soskincsem.hu website, so no personal data is stored for this purpose.

5. Purpose, Method and Legal Basis of Data Processing

5.1 General Data Processing Principles

SOS KINCSEM Kft.'s data processing activities are based on voluntary consent or statutory authorization. In the case of data processing based on voluntary consent, data subjects may withdraw their consent at any stage of the data processing. In certain cases, the processing, storage, and transmission of certain data provided is required by law, about which we inform our clients separately. We draw the attention of those providing data to SOS KINCSEM Kft. that if they provide data not of their own, it is the data provider's responsibility to obtain the consent of the data subject. Its data processing principles are in line with the applicable data protection laws, in particular the following:

• Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information (Infotv.);
• Regulation (EU) 2016/679 of the European Parliament and of the Council (April 27, 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, GDPR);
• Act V of 2013 – Civil Code (Ptk.);
• Act C of 2000 – on Accounting (Accounting Act);
• Act LIII of 2017 – on the Prevention and Combating of Money Laundering and Terrorist Financing (Pmt.);
• Act CCXXXVII of 2013 – on Credit Institutions and Financial Enterprises (Hpt.).

Data Transfer, Data Processing, Scope of Persons with Access to Data

Personal data collected through the https://soskincsem.hu website is managed by SOS KINCSEM Kft. as the data controller. The scope of employees with access to personal data is determined to the extent necessary to perform data processing operations. SOS KINCSEM Kft. transfers personal data to third parties only with the prior consent of the data subject or on the basis of statutory authorization. SOS KINCSEM Kft. uses personal data exclusively for the purposes specified in this notice.https://soskincsem.hu

7. Rights of Data Subjects and Legal Remedies

The data subject may request information about the processing of their personal data, as well as request the correction, deletion, or withdrawal of their personal data – except for mandatory data processing – and may exercise their right to data portability and objection in the manner indicated at the time of data collection or at the above contact details of the data controller.

7.1 Right to Information

SOS KINCSEM Kft. takes appropriate measures to ensure that all information relating to the processing of personal data, as referred to in Articles 13 and 14 of the GDPR, and all notifications under Articles 15–22 and 34, are provided to data subjects in a concise, transparent, intelligible and easily accessible form, using clear and plain language.

7.2 Right of Access

The data subject has the right to obtain confirmation from the data controller as to whether or not personal data concerning them are being processed, and, where that is the case, access to the personal data and the following information: the purposes of the processing; the categories of personal data concerned; the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations; the envisaged period for which the personal data will be stored; the right to request rectification, erasure or restriction of processing and to object to such processing; the right to lodge a complaint with a supervisory authority; information on the source of the data; the existence of automated decision-making, including profiling, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject. The data controller shall provide the information within one month of receipt of the request.

7.3 Right to Rectification

The data subject has the right to obtain from the data controller without undue delay the rectification of inaccurate personal data concerning them. The data subject also has the right to have incomplete personal data completed.

7.4 Right to Erasure

The data subject has the right to obtain from the data controller the erasure of personal data concerning them without undue delay where the processing is unlawful, the purpose of the processing no longer exists, or the data subject withdraws consent and there is no other legal basis for the processing.

7.5 Right to Restriction of Processing

The data subject has the right to obtain from the data controller restriction of processing where the accuracy of the data is contested, the processing is unlawful, or the data controller no longer needs the data, but the data subject requires them for the establishment, exercise or defense of legal claims.

7.6 Right to Data Portability

The data subject has the right to receive the personal data concerning them, which they have provided to a data controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another data controller where the processing is based on consent.

7.7 Right to Object

The data subject has the right to object at any time to processing of personal data concerning them which is based on the legitimate interests of the data controller.

7.8 Legal Remedies

The data subject has the right to lodge a complaint with the supervisory authority if they consider that the processing of personal data relating to them infringes the provisions of the GDPR. Contact details of the supervisory authority: National Authority for Data Protection and Freedom of Information (NAIH), 1125 Budapest, Szilágyi Erzsébet fasor 22/c, phone: +36 1 391-1400, email: naih@naih.hu

8. Other Provisions

For data processing not listed in this notice, information will be provided at the time of data collection. We inform our clients that the court, the prosecutor, the investigating authority, the authority dealing with administrative offenses, the administrative authority, the National Authority for Data Protection and Freedom of Information, the Hungarian National Bank, or other bodies authorized by law may contact the data controller for the purpose of providing information, disclosing data, transferring data, or making documents available. SOS KINCSEM Kft. will only disclose as much personal data to the authorities as is strictly necessary to achieve the purpose of the request, provided that the authority has specified the exact purpose and scope of the data.

Hosting Provider Data

• Provider: BlazeArts Kft.
• Address: 1096 Budapest, Thaly Kálmán utca 39.
• Company Registration Number: 01-09-389087
• Phone: (+36) 1 610 5506
• Email: info@blazearts.hu
• Website: https://forpsi.hu

Infrastructure Provider Data

• Provider: Vercel Inc.
• Address: 340 S Lemon Ave #4133, Walnut, CA 91789, USA
• Email: support@vercel.com
• Website: https://vercel.com