Privacy notice

Company name: PEARLSHOTS HUNGARY KFT.
Tax number: 25085107-2-42

1 Purpose of the data management information

Pearlshots Hungary Kft. (1154 Budapest, Szerencs utca 141., hereinafter, service provider, data controller) as a data controller, recognizes the content of this legal notice as binding on itself. It undertakes to ensure that all data management related to its activities meets the requirements set out in these regulations and in the applicable national legislation, as well as in the legal acts of the European Union.

The data protection guidelines arising in relation to the data management of Pearlshots Hungary Kft. are continuously available at www.pearlshots.eu/adatkezelési-tajekozato/.

Pearlshots Hungary Kft. reserves the right to change this information at any time. Of course, you will notify your audience of any changes in good time.

If you have any questions related to this announcement, please write to us at ugyfelszolgalat@pearlshots.eu and our colleague will answer your question.

Pearlshots Hungary Kft. is committed to protecting the personal data of its customers and partners, and considers it of utmost importance to respect its customers' right to self-determination of information.

Pearlshots Hungary Kft. treats personal data confidentially and takes all security, technical and organizational measures that guarantee data security.

Pearlshots Hungary Kft. describes its data management practices below.

1.1 Purpose of data management

The purposes of requesting personal data may be:

registration, request for quotation, order, conclusion of contract, invoicing, delivery, newsletter subscription, contact form, contact by e-mail, prize draw, warranty complaints, consumer protection complaints.

2 Data of the data controller

If you would like to contact our Company, you can contact the data controller using the contact details.

Pearlshots Hungary Kft. deletes all e-mails it receives, including personal data, no later than 5 years after the date of data communication.

Name: Pearlshots Hungary Kft.

Headquarters: 1154 Budapest, Szerencs utca 141.

Tax number: 25085107-2-42

Phone number: +36302527701

Email: info@pearlshots.eu

2.1 Data Protection Officer

Data Protection Officer we do not need the help of a specialist because

- data management is not carried out by some authority or organization performing a public task.

- the company's main activity does not require regular, large-scale monitoring of the stakeholders.

- our main activity requires the handling of large amounts of non-special personal data.

Our data protection officer:

Name: Gergely Lakos

Phone number: +36302527701

3 Scope of processed personal data

3.1 Personal data to be provided during registration, online ordering and administration

The personal data that we request in various cases can be seen here. In each case, the mandatory fields have been marked, here the degree of necessity of the requested data is 100%:

data management cases	personal data
	name	title	telephone number	Delivery Address	e-mail address
registration	x	x	x	x	x
Request for	x		x		x
order	x	x	x	x	x
conclusion of contract	x	x	x	x	x
invoicing	x	x	x	x	x
transport	x	x	x	x	x
Sign up for newsletter	x				x
contact form	x		x		x
contact by e-mail	x		x		x
consumer protection complaints	x	x	x	x	x
warranty complaints	x	x	x	x	x
prize draw	x				x

3.2 Technical data

Pearlshots Hungary Kft. selects and operates the IT tools used for the management of personal data in the course of providing the service in such a way that the processed data:

accessible to those authorized to do so (availability);

its authenticity and authentication are ensured (authenticity of data management);

its immutability can be verified (data integrity);

be protected against unauthorized access (data confidentiality).

Pearlshots Hungary Kft. protects the data with appropriate measures against unauthorized access, change, transmission, disclosure, deletion or destruction, as well as against accidental destruction.

Pearlshots Hungary Kft. ensures the protection of the security of data management with technical, organizational and organizational measures that provide a level of protection corresponding to the risks associated with data management.

Pearlshots Hungary Kft. preserves confidentiality during data management: it protects the information so that only those who are authorized to do so can access it; integrity: protects the accuracy and completeness of the information and the method of processing; availability: it ensures that when the authorized user needs it, he can really access the desired information and that the related tools are available.

3.3 Cookies

3.3.1 The role of cookies

Cookies collect information about visitors and their devices;

they note the individual settings of the visitors, which will be used, e.g. when using online transactions, so you don't have to type them in again;

facilitate the use of the website;

they provide a quality user experience.

In order to provide customized service, a small data package, so-called it places a cookie and reads it back during the next visit. If the browser returns a previously saved cookie, the cookie management service provider has the opportunity to connect the user's current visit with previous ones, but only with regard to its own content.

3.3.2 Absolutely necessary session cookies

The purpose of these cookies is to allow visitors to fully and smoothly browse your website, use its functions and the services available there. The validity period of this type of cookie lasts until the end of the session (browsing), when the browser is closed, this type of cookie is automatically deleted from the computer or other device used for browsing.

3.3.3 Cookies placed by third parties (analytics, Facebook)

Pearlshots Hungary Kft. uses the Google Analytics service for statistical purposes to collect information about how visitors use the website. The data is used for the purpose of developing the website and improving the user experience. These cookies also remain on the visitor's computer or other device used for browsing, in their browser, until they expire, or until the visitor deletes them.

Google's privacy policy can be found here: https://policies.google.com/?hl=hu

On the www.pearlshots.eu website, we use the Facebook "like button" as third-party cookies. When cookies are used, the data is forwarded to Facebook.

Facebook's privacy policy can be found here: https://www.facebook.com/privacy/explanation

3.4 Newsletter-related data

We would like to inform you that if you have subscribed to our newsletter on our website or provided your email address for any reason (even during a purchase), we will periodically send you newsletters that contain advertising, offers and other information, thus ensuring that you are informed of current events as soon as possible. The legal basis for the processing of your personal data defined in this point is the Data Controller's legitimate interest, given that, based on the above, it is entitled to the right of email marketing for the purpose of obtaining direct business. Your data received in this form will be processed until the newsletter service used by the Data Controller is operational, however, if you object to this and the conditions set out in the GDPR apply, we will delete your personal data specified in this point and we will no longer send you newsletters. We would also like to inform you that if you unsubscribe from the newsletter, you will be put on a special list of people who no longer wish to receive newsletters.

4 Planned use and retention period of managed data

data management cases	use of data	legal basis	shelf life
registration			3 years
Request for			1 year
order			5 years
conclusion of contract			5 years
invoicing			5 years
transport			1 year
Sign up for newsletter			until the customer unsubscribes
contact form			3 years
contact email			3 years
warranty complaints			1 year
consumer protection complaint			1 year

5 Purpose, method and legal basis of data management

5.1 General data management guidelines

The data management of Pearlshots Hungary Kft.'s activities is based on voluntary consent and legal authorization. In the case of data management based on voluntary consent, the data subjects may withdraw their consent at any stage of the data management.

In some cases, the management, storage, and transmission of a range of the provided data is made mandatory by law, of which we notify our customers separately.

For Pearlshots Hungary Kft., we would like to draw the attention of informants to the fact that if they do not provide their own personal data, the informant is obliged to obtain the consent of the data subject. Its basic data management principles are in line with the applicable legislation on data protection, and in particular with the following:

2011. year CXII. law -

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 flow of such data, as well as the repeal of Regulation 95/46/EC about its location (General Data Protection Regulation, GDPR);

2013. Act V - on the Civil Code (Ptk.);
2014. Act C - on accounting (Accounting Act);
2015. year LIII. Act - on the prevention and prevention of money laundering and terrorist financing (Pmt.);
2016. year CCXXXVII. Act - on credit institutions and financial enterprises (Hpt.).

6 Physical storage locations of data

Your personal data (that is, data that can be associated with you) may be processed by us in the following ways:

- on the one hand, in connection with maintaining the Internet connection, technical data related to the computer, browser program, Internet address, and visited pages are automatically generated in our computer system,

-on the other hand, you can also provide your name, contact information or other data if you wish to contact us personally when using the website.

Technically recorded data during the operation of the system: the data of the concerned applicant's computer, which are generated during the voting and which are recorded by the www.pearlshots.eu system as an automatic result of the technical processes. The data that is recorded automatically is automatically logged by the system upon entry and exit without a separate statement or action by the person concerned. This data cannot be combined with other personal user data, except in cases made mandatory by law. For the data only a www.pearlshots.eu interface storage is accessed.

In the event of your presence, we store your data on paper or after a computer record in our database at our headquarters or site.

7 Data transmission, data processing, the circle of those familiar with the data

The range of companies and employees that fall within the scope of data transfer:

Facebook

Google

Shipping companies that work with a case-by-case assignment contract: Cakebox Kft.

accountant: we work with a general assignment contract.

newsletter sending: Mailchimp

CRM provider: we do not use it

The range of companies and employees that fall within the scope of data processing:

packaging employee: company manager/owners

accountant: Etelka Galantai

Tax administrator: András Bohos

tenderer: Gergely Lakos

The range of companies and employees that fall within the scope of data access:

data collector: company manager/owners

The confidentiality clause of contracts with partners covers this area!

8 The rights of the affected person and the possibilities of legal enforcement

The data subject can request information about the processing of his personal data, and can request the correction of his personal data, or - with the exception of mandatory data processing - deletion or withdrawal, he can exercise his right to data portability and protest in the manner indicated when the data was collected, or at the above contact details of the data controller.

8.1 Right to information

Pearlshots Hungary Kft. takes appropriate measures in order to provide the data subjects with all the information mentioned in Articles 13 and 14 of the GDPR and Articles 15-22 regarding the handling of personal data. and provide each piece of information according to Article 34 in a concise, transparent, comprehensible and easily accessible form, clearly and comprehensibly worded.

8.2 Data subject's right of access

The data subject has the right to receive feedback from the data controller as to whether his personal data is being processed, and if such data processing is underway, he is entitled to access the personal data and the following information:

the purposes of data management;

categories of personal data concerned;

the recipients or categories of recipients to whom or to whom the personal data has been or will be communicated, including in particular recipients in third countries and international organizations;

the planned period of storage of personal data;

the right to rectification, deletion or limitation of data processing and the right to protest;

the right to submit a complaint to the supervisory authority;

information about data sources; the fact of automated decision-making, including profiling, as well as comprehensible information about the applied logic and the significance of such data management and the expected consequences for the data subject.

The data controller shall provide the information within a maximum of one month from the date of submission of the request.

8.3 Right of rectification

The data subject may request the correction of inaccurate personal data concerning him/her managed by Pearlshots Hungary Kft. and the addition of incomplete data.

8.4 Right to erasure

If one of the following reasons exists, the data subject has the right to request that Pearlshots Hungary Kft. delete his/her personal data without undue delay:

the personal data are no longer needed for the purpose for which they were collected or otherwise processed;

the data subject withdraws the consent that forms the basis of the data management, and there is no other legal basis for the data management;

the data subject objects to data processing and there is no overriding legal reason for data processing;

personal data has been processed unlawfully;

the personal data must be deleted in order to fulfill the legal obligation prescribed by the EU or Member State law applicable to the data controller;

the collection of personal data took place in connection with the offering of services related to the information society.

Data deletion cannot be initiated if data management is necessary:

for the purpose of exercising the right to freedom of expression and information;

for the purpose of fulfilling the obligation under the EU or Member State law applicable to the data controller requiring the processing of personal data, or for the execution of a task performed in the public interest or in the context of the exercise of public authority conferred on the data controller;

affecting the field of public health, or for archival, scientific and historical research purposes or for statistical purposes, on the basis of public interest;

or to submit, assert or defend legal claims.

8.5 Right to restriction of data processing

At the request of the data subject, Pearlshots Hungary Kft. restricts data processing if one of the following conditions is met:

the data subject disputes the accuracy of the personal data, in which case the limitation applies to the period that allows the accuracy of the personal data to be checked;

the data processing is illegal and the data subject opposes the deletion of the data and instead requests the restriction of its use;

the data controller no longer needs the personal data for the purpose of data management, but the data subject requires them to present, enforce or defend legal claims;

or the data subject objected to data processing; in this case, the restriction applies to the period until it is determined whether the legitimate reasons of the data controller take precedence over the legitimate reasons of the data subject.

If data management is subject to restrictions, personal data may only be processed with the consent of the data subject, with the exception of storage, or to submit, enforce or defend legal claims, or to protect the rights of another natural or legal person, or in the important public interest of the Union or a member state.

8.6 Right to data portability

The data subject has the right to receive the personal data concerning him/her provided to the data controller in a segmented, widely used, machine-readable format, and to forward this data to another data controller.

8.7 Right to protest

The data subject has the right to protest at any time for reasons related to his own situation against the processing of his personal data necessary for the performance of a task carried out in the public interest or within the framework of the exercise of public authority granted to the data controller, or for the enforcement of the legitimate interests of the data controller or a third party, including profiling based on the aforementioned provisions too. In the event of a protest, the data controller may no longer process the personal data, unless it is justified by compelling legitimate reasons that take precedence over the interests, rights and freedoms of the data subject, or that are related to the submission, enforcement or defense of legal claims.

8.8 Automated decision-making in individual cases, including profiling

The data subject has the right not to be covered by the scope of a decision based solely on automated data management, including profiling, which would have a legal effect on him or affect him to a similar extent.

8.9 Right of Withdrawal

The data subject has the right to withdraw his consent at any time.

8.10 Right to Court

In the event of a violation of their rights, the data subject may apply to the court against the data controller. The court acts out of sequence in the case.

8.11 Data protection official procedure

You can file a complaint with the National Data Protection and Freedom of Information Authority:

Name: National Data Protection and Freedom of Information Authority

Headquarters: 1125 Budapest, Szilágyi Erzsébet fasor 22/C.

Mailing address: 1530 Budapest, Pf.: 5.

Phone: 0613911400

Fax: 0613911410 8 8 +36 (1) 888-2890

E-mail: ugyfelszolgalat@naih.hu

Website: http://www.naih.hu

9 Data protection in the company

Pearlshots Hungary Kft. protects the personal data stored in the above-mentioned data management cases in the following way:

• using a firewall on a laptop, using a password,
• using a password on a mobile phone,
• storage of paper-based data at the headquarters of Pearlshots Hungary Kft. in a folder ( ), locked in a cabinet,
• storage of employment documents: at the headquarters of Pearlshots Hungary Kft. and at the accounting office

• using a password in a computerized mail system.

10 Other provisions

We provide information on data management not listed in this information when the data is collected. We inform our customers that the court, the prosecutor, the investigative authority, the infringement authority, the public administrative authority, the National Data Protection and Freedom of Information Authority, the Hungarian National Bank, or other bodies based on the authorization of the law, provide information, communicate data, transfer documents, or they can contact the data controller to make it available.

Pearlshots Hungary Kft. will release personal data to the authorities only to the extent and to the extent that is absolutely necessary to achieve the purpose of the request, if the authority has specified the exact purpose and scope of the data.

Date of entry into force of this information: August 12, 2023. Valid until withdrawn or updated.