Privacy policy

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Privacy policy

DATA PROTECTION BULLETIN

 

to inform You as visitor of our home page and auction site and as user of our services on our Company’s data management and data protection policy.

  1. What principles are following in the course of our data management? 

Our Company follows the following principles in the course of its data management:

  1. We manage personal data in a lawful and fair manner transparent for You.
  2. We collect personal data for specific, unambiguous and lawful purposes only, and do not manage such data in any way incompatible with such purposes.
  3. Personal data collected and managed by us are appropriate for and relevant to data management purposes and limited to the necessary extent only.
  4. Our Company makes every reasonable effort to have data managed by us as accurate and up-to-date if necessary, we delete or remedy any inaccurate personal data without delay.
  5. We store personal data in formats allowing Your identification only for the time required to attain the purposes of managing personal data.
  6. By employing proper technical and organisational measures, we ensure proper security of personal data against unauthorised or unlawful management, accidental loss, destruction or deterioration of data.

Your personal data will be managed by our Company

  1. on the basis of Your voluntary consent based on Your prior information, only to the extent necessary and in any case in a purpose-specific manner (i.e. collected, recorded, sorted, stored and used);
  2. in certain instances, on the basis of legislative prescriptions in a mandatory way, in which instances Your attention shall be drawn to such fact specifically;
  3. in certain instances, on the basis of the justified interest of our Company or a third party, e.g. operation, development and security of our home page or auction page.

 

  1. About us? 

Our Company’s registered seat: 6000 Kecskemét, Tinódi u. 27.

Our Company’s site: -

Our Company’s home page: https://intergavel.com

 

Contact details:

Our mailing address: 2040 Budaörs, P.O. Box 499.

Our telephone number: +36 23 200 120

Our e-mail address: info@intergavel.hu

Our tax registration number: 13442068-2-03

Our company registration number: 03-09-112279

Our Company is not obliged to designate a data protection officer pursuant to GDPR Article 37.

Our Company’s web service provider’s name, address and contact details: own server – Intergavel Ltd., 6000 Kecskemét, Tinódi u. 27., Tel.: +36 23 200 120

Our Company shall use the following data processors in the course of data management with a view to the quality servicing of our clients:

 

NAME

ADDRESS

ACTIVITY

RND Hungary LP

1222 Budapest, Őrnagy utca 9. Tt 44.

IT services

We have our own server: Intergavel Ltd.

6000 Kecskemét, Lóverseny u. 3.

storage space services

Car and Gas LP

6000 Kecskemét, Tinódi utca 27. I. em. 3.

accounting and taxation services

RND Hungary LP

1222 Budapest, Őrnagy utca 9. Tt 44.

database maintenance and processing, reporting

 

Data processors related to our direct marketing and newsletters services:

NAME

ADDRESS

ACTIVITY

RND Hungary LP

1222 Budapest, Őrnagy utca 9. Tt 44.

IT services

We have our own server: Intergavel Ltd.

6000 Kecskemét, Lóverseny u. 3.

storage space services

RND Hungary LP

1222 Budapest, Őrnagy utca 9. Tt 44.

database maintenance and processing, reporting

GOLD COMMUNICATIONS Ltd.

1112 Budapest, Cirmos u. 8.

direct marketing

 

Should we amend the scope of our data processors, this present bulletin shall be updated accordingly.


 

Data managed by us:

Description of activity and purpose of data management

Legal basis

Data managed

Duration

Registration number

Home page visiting

Purpose: ensuring quality operation of home page for its intended purpose,

controlling and improving the quality of our services,

identifying malicious visitors attacking our web page,

metering visiting,

statistical purposes

Our Company’s justified interest

IP address

date and time of visit

data on subpages visited,

type of operating system and browser You used

 

we store IP address used for registration during the term of visitor’s consent

 

Registration on home page

Purpose: provision of better user experience for our visitors

notification on downtimes, changes in our Company’s contact details, etc.

consent

company name, company details, contact details,

e-mail address

until registration is deleted or consent is withdrawn

Unique identifier

Using auction site, bidding

Purpose: visitor registration and recording,

managing and fulfilling biddings,

managing purchases (biddings) and invoicing,

handling complaints, administering call-backs

analysing purchasing habits of our Buyers

liaising with our Buyers.

consent

 

legislative provisions

(Business Advertising Act Art. 6 Para (1) c)

E-trade Act Art. 13/A,

Accounting Act Art. 169)

company name, company details, contact details,

e-mail address

for an indefinite term during the operation of the auction site, but until consent to data management is withdrawn at the latest

Period of retention of data pertaining to contract fulfilment: 5 years.

Period of retention of invoices issued and of documents on which invoicing was based: 8 years.

Unique identifier

Newsletter services

Purpose: liaising,

Notifying You on new auctions, our new products

consent

company details,

e-mail address

unsubscribing from newsletter services

registration number:

NAIH-111703/2017

 

 

Direct marketing services

based on analysing Your purchasing habits

making and sending personalised offers,

soliciting,

sending information on our auctions.

consent

company details,

e-mail address

unsubscribing from direct marketing services

registration number:

NAIH-111703/2017

 

 

 Case administration, complaints

·         responding to remarks and complaints

legal obligation

·         company details, e-mail address

·         other personal message

·         for 5 years

·          

 

Visitors of our web page are only requested personal data if they wish to register, log in or bid through our auction site.

Personal data given in relation to registration or using the services of our auction site may not be linked and identification of our visitors may not be an essential purpose.

For more information on data management, contact info@intergavel.hu by e-mail or our mailing address. Our reply will be send to You without delay (but at least within one month at the latest) to the contact You specified.

 

  1. About cookies and their use? 

Cookies are small files downloaded to Your computer through a web page when using such web page by Your web browser saving and storing them. Most widely used web browsers (Chrome, Firefox, etc.) accept and allow downloading and using of cookies by default; however, it is up to You to reject or disable them by modifying the settings of Your browser, and You are also able to delete cookies already stored on Your computer. See more on using cookies under the Help menu of Your specific browser(s).

There are cookies that do not require prior consent from You. Our web site informs You on such upon commencing Your first visit, such as session cookies facilitating authentication, multimedia player, performance optimising and user interface optimisation, and user-oriented security cookies.

Our Company informs You on cookies requiring consent upon commencing Your first visit – in case data management already begins by visiting the site – and requests Your consent.

Our Company neither applies nor authorises cookies enabling third parties to collect data without Your consent.

Acceptance of cookies is not mandatory; however, our Company does not take any responsibility for any unexpected functioning of our web site in the absence of authorising cookies.

 

What cookies do we use? 

Our web site uses cookies for logging in.

 

  1. What else is there to know about data management on our auction site?

You voluntarily provide us with Your personal data in the course of registration, purchasing or liaising with our Company; therefore, You are kindly requested to pay increased attention to the authenticity, accuracy and appropriateness of Your data when specifying them, because You are responsible for them. Inaccurate, inappropriate or incomplete data may hinder utilisation of our services.

Should You specify personal data of another entity and not of Your own, we shell assume that You have authorisation required to do so.

You may withdraw Your consent to data management at any time and free of charge by

  • deleting Your registration,
  • withdrawing consent to data management, or
  • withdrawing consent to managing or using or requesting blocking of any data to be specified obligatorily in the course of registration.

Withdrawal of Your consent will be registered with a deadline of 5 days for technical reasons; however, Your attention should be drawn to our right to manage certain data with a view to fulfilment of our legal obligations or enforcement of our justified interest even after the withdrawal of Your consent (e.g. Accounting Act Art. 169, Consumer Protection Act Art. 17/A).

In case misleading personal data is used or a visitor commits a crime or attacks our Company’s system, data on such visitor shall be deleted without delay and simultaneously with the termination of the registration of such visitor and shall be retained, if necessary, during the term of establishment of civil law liability or conducting of criminal proceedings.


 

  1. About our data management for direct marketing and newsletter purposes

Through Your statement given in the course of registration or subsequently by amending Your personal data stored via the auctioning interface (i.e. by unambiguously stating Your intent to consent), You may consent to our using Your personal data for marketing purposes as well. In this case, until Your consent is withdrawn, we shall manage Your personal data for direct marketing and/or newsletter purposes, and You will be sent advertising and other materials, bulletins and offers and/or newsletters (GRDP Act Art. 6).

You may consent to direct marketing and newsletters collectively or separately, which You may withdraw at any time and free of charge.

Deletion of Your registration shall at all times be regarded as withdrawal of Your consent. A withdrawal of Your consent to direct marketing and newsletter purposes shall not be regarded as a simultaneous withdrawal of Your consent to data management pertaining to our auction site.

Withdrawal or cancellation of Your consent will be registered with a deadline of 5 days for technical reasons.

  1. Other data management questions

Your data may be forwarded within the scope defined by law; while in case of our data processors, any use of Your personal data for any purpose in conflict with Your consent shall be ensured by stipulation of contractual terms. For more information, see Section 2.

Our Company may only forward data abroad on the basis of the relevant provisions of the GDPR and the Info Act.

Courts, public prosecutor’s offices and other authorities (e.g. the police, the tax authority, the Hungarian National Authority for Data Protection and Freedom of Information) may contact our Company for supplying them with information, data or documents. In such instances, we must fulfil our data supply obligation, but only to the extent indispensable for implementing the purpose of such requests.

Our Company’s actors and employees taking part in data management and/or data processing are authorised to become aware of Your personal data to a predefined extent under confidentiality.

Your personal data shall be protected by appropriate technical and other measures, the security and availability of such data shall be ensured; moreover, such data shall be protected against unauthorised access, alteration, impairment and disclosure, and any other unauthorised use.

Within the scope of organisational measures, physical access is controlled in our buildings, our employees are trained continually, and hardcopy documents are locked up with adequate security. Within the scope of technical measures, we use encryption, password protection and anti-virus software. Your attention, however, should be drawn to the fact that data forwarding via the internet may not be regarded as comprehensively secure data forwarding. Our Company takes every measure in order to make processes as secure as possible; nonetheless, we are in no position to take full responsibility for data forwarding vie our web page, while we adhere to strict standards in respect of data received by our Company for the sake of security of Your data and in order to prevent any unauthorised access.

In relation to security matters, we kindly request Your assistance in keeping Your access password to our home page and auction site safe, and to refrain from sharing it with anyone.

  1. Your rights and legal remedies

As regards data management, You may

  • request information;
  • request correction, modification and amendment of Your personal data managed by us;
  • object to data management and may request deletion or blocking of Your data (save for mandatory data management);
  • file for legal remedy before a court;
  • file a complaint or initiate proceedings before our supervising authority (https://naih.hu/panaszuegyintezes-rendje.html).

Supervising Authority: Hungarian National Authority for Data Protection and Freedom of Information

  • Registered seat: 1125 Budapest, Szilágyi Erzsébet fasor 22/c.
  • Mailing address: 1530 Budapest, Pf.: 5.
  • Telephone: +36 (1) 391-1400
  • Fax: +36 (1) 391-1410
  • E-mail:ugyfelszolgalat@naih.hu
    Home page: https://naih.hu/

Upon Your request, we shall inform You on

  • Your data managed by us and processed by us or our appointed data processor;
  • sources thereof;
  • purpose and legal basis of data management;
  • term thereof, or if this is not possible, then on the points of consideration of determining such term;
  • name and address of our data processor(s), and activities thereof pertaining to data management;
  • circumstances and impacts of data protection incidents, and measures taken to eliminate and prevent such; and
  • legal basis and addressee of data forwarding in case of forwarding Your personal data.

We shall give such information within the shortest period of time reckoned from filing of such request, within five (5) days (but within one month at the latest). Such information shall be free of charge unless You have already filed a request for information in respect of the same scope of data within the subject calendar year. Any costs already paid by You shall be reimbursed in case we have managed data unlawfully or a request for information has resulted in correction thereof. Such information may only be refused in statutory instances along with the specification of such legislative text and an information on the option for judicial legal remedy or appeal to the Authority.

Our Company shall notify any correction, blocking, marking and deleting of personal data to You and all others to whom such data have been forwarded for data management purposes, unless lack of such notification should not infringe Your justified interest.

In case we do not fulfil Your request for correction, blocking or deleting, we shall notify You in writing or electronically – pursuant to Your consent – on the reason(s) of our refusal within five (5) days reckoned from our receiving of Your request (but within one month at the latest); and shall inform You on Your option for judicial legal remedy or appeal to the Authority.

Should You object to management of Your personal data, we shall examine such objection and shall notify You on our decision in writing within five (5) days reckoned from Your filing of Your request (but within one month at the latest). In case we decide that Your objection was founded, we shall terminate data management, including data capturing and data forwarding, and shall block the data, and we shall notify such objection and our measures taken accordingly to all those to whom such personal data have been forwarded and are obliged to take measures with a view to enforcing such right to objection.

We shall refuse to fulfil such request if we are able to prove that data management is reasoned by coercive and justified causes having priority over Your interests, rights and freedoms, or pertains to the submission, enforcement or protection of legal claims. Should You disagree with our decision or should we fail to meet the deadline, You may appeal to a court within thirty (30) days reckoned from the last day of such deadline.

Consideration of data protection suits falls within the jurisdiction of the tribunal according to the place of residence or permanent stay of the party concerned at the choice of the party concerned. Foreign citizens may also appeal to supervising authorities with jurisdiction according to their places of residence.

You are kindly requested to contact our Company before filing Your complaint with the supervising authorities or the court with a view to conciliation and resolution of the arising issue as soon as possible.

 


 

  1. Legislation governing our activities
  • 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 (General Data Protection Regulation – GDPR)
  • Act CXII of 2011 on the right of information self-ruling and on the freedom of information (Info Act)
  • Act V of 2013 on the Civil Code (the Civil Code)
  • Act CVIII of 2001 on certain matters pertaining to electronic trading services and other services related to the information society (E-trading Act)
  • Act C of 2003 on electronic communications (Electronic Communications Act)
  • Act CLV of 1997 on consumer protection (Consumer Protection Act)
  • Act CLXV of 2013 on complaints and notices of public interests (Complaints and Notices Act)
  • Act XLVIII of 2008 on essential terms and certain limits of business advertising activities (Business Advertising Act)
  • Act C of 2000 on Accounting (Accounting Act)

 

  1. Changes to the Data Management Bulletin

Our Company reserves the right to modify the present Data Management Bulleting, of which all stakeholders shall be notified appropriately. Information related to data management shall be published via the web page: https://intergavel.com/privacy_policy.

 

22 May 2018