PRIVACY STATEMENT

Pannon Porto Korlátolt Felelősségű Társaság (hereinafter referred to as Pannon Porto Ltd.) informs you by means of this Privacy Notice (hereinafter referred to as the "Notice") about the most important information related to the processing of your personal data, in particular the purpose of the processing, the legal basis, the scope and duration of the data processed, your rights in relation to the processing and your legal remedies.

Pannon Porto Kft. as the data controller ensures that the Notice is available to you at the time of collection of your personal data and that you can access its contents. Pannon Porto Ltd. reserves the right to unilaterally amend the Information Notice. Pannon Porto Kft. will ensure that the current Privacy Policy is available and accessible on the home page of the website of Pannon Porto Kft. (https://www.kamionpura.hu). Upon request, we will of course send you a copy of the current privacy policy.

The personal data you provide to Pannon Porto Kft. will be treated confidentially and all security, technical and organisational measures will be taken to ensure the security of the data.

Personal data is any information relating to an identified or identifiable natural person ("data subject"). An identifiable natural person is a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, number, location data, an online identifier or to one or more factors specific to the physical or physiological identity of the natural person.

Please be informed that, subject to the recommendation of the National Data Protection and Information Authority dated 29 September 2015 on the data protection requirements of prior information, Pannon Porto Ltd. refrains from repeating the wording of the legislation in this Information Notice and wishes to provide you with the information in a clear and easily understandable manner.

Please note that this Information Notice has been prepared taking into account in particular the following legislation:

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, and repealing Regulation (EC) No 95/46/EC (General Data Protection Regulation, hereinafter "GDPR"), and
Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information (hereinafter referred to as the "Infotv.").
Act V of 2013 on the Civil Code (hereinafter: Civil Code)

Name of the controller
The data of Pannon Porto Kft. as the data controller:

Company name: Pannon Porto Korlátolt Felelősségű Társaság
The short name of the company is Pannon Porto Kft.
Registered office: 9200 Mosonmagyaróvár, Bástya utca 14.

Company registration number: 0809010025
Tax number: 12755374-2-08

E-mail contact: info@kamionpura.hu
Website: https://www.kamionpura.hu

Purposes, legal basis, data subjects, scope of data processed and duration of data processing
2.1. Data processing for the performance of a contract concluded with Pannon Porto Kft., if you are a natural person
Purpose of data processing: the personal data provided by you as a natural person customer will be processed by Pannon Porto Kft. as a contractor for the purpose of fulfilling the contract. Pannon Porto Kft. uses the contact details you provide for the purpose of contacting you, communicating with you and consulting you on the performance of the contract.

Legal basis for processing: processing is necessary for the performance of a contract between you and Pannon Porto Kft., to which you are one of the contracting parties [Article 6(1)(b) GDPR].

Please note that the processing of data by Pannon Porto Kft. is lawful if the processing is necessary in the context of a contract or the intention to enter into a contract. We further inform you that the provision of your personal data is necessary for the conclusion of a contract with Pannon Porto Kft., while the processing of your data is necessary for the performance of the contract.

Data subjects: natural persons contracting with Pannon Porto Kft.

Scope of the data processed:

your name
your e-mail address

Duration of data processing: the data processed by Pannon Porto Kft. Pannon Porto Kft. shall retain the data for a period of 5 (five) years from the termination of the contract with you in order to present, enforce or defend your legal claims [Article 17 (3) (e) of the GDPR].

2.2. Processing of data for the performance of a contract concluded with Pannon Porto Kft., if you are the representative or contact person of the legal entity that concluded the contract
Purpose of data processing: if you are a natural person and you are the legal representative (manager, including managing director) or contact person of a legal entity contracting with Pannon Porto Kft., Pannon Porto Kft. needs to process your data for the purpose of performing the contract. In this context, LPannon Porto Ltd. will use the contact details you provide to contact you, communicate with you and consult you on the performance of the contract.

Legal basis for processing: processing is based on your consent as the data subject [Article 6(1)(a) GDPR].

Please be informed that consent is understood as a voluntary, specific, informed and unambiguous expression of your will, by which you indicate, by means of a declaration or an unambiguous act of affirmation, that you give your consent to the processing of personal data concerning you.

Data subjects: the representative or contact person of the legal person contracting with Pannon Porto Kft.

The scope of the data processed includes the legal representative or contact person of the legal entity contracting with Pannon Porto Kft:

Name
telephone number
your e-mail address
belong to.

2.3. Data processing in connection with direct marketing
Purpose of data processing: you can request marketing offers related to online marketing services, training or consultancy from Pannon Porto Kft. by filling in a quote request form and submitting it on the pannonporto.hu website. This direct marketing activity is carried out by Pannon Porto Ltd. with your explicit consent, so we will ensure that you have access to the Information when you submit the form.

Legal basis for processing: processing is based on your consent [Article 6 (1) (a) GDPR, Article 6 (1) of Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Economic Advertising Activities].

Please note that your consent to direct marketing may be withdrawn at any time, without restriction and without giving any reason, free of charge. In the event of withdrawal, all your data processed for this purpose will be deleted immediately by Pannon Porto Kft. and no further marketing offers will be sent to you.

The data processed include your name, e-mail address, telephone number and the address of your website.

Data subjects: you as the natural person giving your consent.

Duration of processing: we process the data until your consent is withdrawn.

2.4 Data processing in connection with direct marketing, including the sending of professional newsletters by electronic means
Purpose of data processing: if you wish to subscribe to a professional newsletter on the website https://www.kamionpura.hu, your personal data necessary for sending the newsletter will be processed by Pannon Porto Kft. on the basis of your prior, explicit and express consent.

Please note that Pannon Porto Kft. provides you with the possibility to unsubscribe from the professional newsletter. Accordingly, your declaration of consent may be withdrawn at any time, without restriction and without giving reasons, free of charge. In the event of withdrawal, all your data processed for this purpose will be deleted by Pannon Porto Kft. without delay and you will no longer receive the professional newsletter.

Data subjects: you as the natural person subscribing to the professional newsletter.

The data processed: your name, e-mail address, telephone number.

Duration of processing: we process the data until your consent is withdrawn.

2.5. Processing of data related to cookies placed on the website by third parties (analytics)
Purpose of data processing: on the website https://www.kamionpura.hu Pannon Porto Ltd. uses cookies placed by third parties (e.g. Google Analytics). The cookie itself is a small, simple data package that collects information about visitors to the website.

Google Analytics is Google's analytics tool that helps Pannon Porto Ltd. as the owner of the website https://www.kamionpura.hu to get a more accurate picture of the activities of visitors to the website. These cookies help kamionpura.hu to optimise its advertising campaigns by generating detailed statistics. Importantly, these cookies generate reports of website usage statistics without identifying visitors individually to Google. Google Analytics shows where visitors clicked on the website, how long they spend on it and where they are located geographically. The main cookie used by Google Analytics is the "__ga" cookie.

In addition to the reports generated from website usage statistics, Google Analytics can also be used to help Pannon Porto Ltd. display more relevant ads on Google services (such as Google Search) and across the web, and to measure interactions with ads displayed by Google Analytics.

The Facebook Pixel cookie is a small piece of code that, by placing it in the source code of the website https://www.kamionpura.hu, Pannon Porto Kft. can track the activity of users who are also registered on Facebook. Its functionality is very similar to the Google Analytics cookie described above.

Legal basis for processing: processing is based on your consent [Article 6(1)(a) GDPR].

Please note that your consent may be withdrawn at any time, without restriction and without giving any reason, free of charge.

Data processed: your IP address, location, time, duration and frequency of your visits to https://www.kamionpura.hu

Duration of processing: we process the data until your consent is withdrawn.

2.6. Data processing in relation to the customer satisfaction questionnaire
Purpose of data processing: you can help us to improve our work and to provide you with an even higher level of professional service by filling in a customer satisfaction questionnaire regarding the activities of Pannon Porto Ltd. This customer satisfaction questionnaire is a feedback to Pannon Porto Ltd. about the quality of our work and your satisfaction with it. The data provided in the customer satisfaction questionnaire will only be processed with your prior, explicit and express consent.

Legal basis for processing: processing is based on your consent [Article 6(1)(a) GDPR].

Your consent may be withdrawn at any time, without restriction and without giving any reason, free of charge. In case of withdrawal, all your data processed for this purpose will be deleted by LPannon Porto Kft. without delay.

Data subjects: natural persons who fill in the customer satisfaction questionnaire and consent to the processing.

The data processed are: name, email address and the answers to some of the questions in the questionnaire.

Duration of data processing: your data provided in the customer satisfaction questionnaire will be deleted by Pannon Porto Kft. from its systems immediately after the expiry of the contract of engagement with you, or even earlier if you have withdrawn your consent to data processing in the meantime."

Information on the use of data processors
A data processor is a natural or legal person who processes personal data on behalf of Pannon Porto Kft. as data controller.

Pannon Porto Kft. informs you that it uses the following data processors for its data processing:

Name: Google (Google Analytics)
Activity provided: https://www.google.com/about/datacenters/ website usage data for statistical and advertising targeting purposes (third party cookies)
Scope of data processed: cookie data

Name: facebook
Activity provided: recording website usage data for statistical and advertising targeting purposes (third party cookies)
Scope of data processed: cookie data

Who is entitled to access the data, data portability, information on data security measures
The personal data provided by you may be accessed by employees of Pannon Porto Kft. who have access rights related to the purpose of the processing, namely:

office manager, sales manager, project manager, expert, executive

Please note that Pannon Porto Kft. will not transfer your personal data to third parties under any circumstances.

Pannon Porto Ltd. takes appropriate data security measures to protect the personal data you provide to us. As part of this, its IT systems, which also contain personal data stored in electronic form, are protected by multiple levels of password protection.

Your rights regarding data processing
You have the right to request from Pannon Porto Kft. access to your personal data, rectification, erasure or restriction of processing, to object to the processing of your personal data and to data portability.

Below we describe the content of some of the rights you have in relation to data processing and some of the specific features of your exercise of those rights.

5.1. Right of access
You have the right to receive feedback from Pannon Porto Kft. as the data controller on whether your personal data is being processed. If such processing is ongoing, you have the right to access your personal data and the following information:

the purposes of the processing;
the categories of personal data of the data subject;
the recipients or categories of recipients to whom or with whom the personal data have been or will be disclosed, including in particular recipients in third countries or international organisations;
the intended duration of the storage of the personal data;
your rights in relation to the processing (in particular the right to rectification, erasure or restriction of processing and the right to object);
the right to lodge a complaint with a supervisory authority;
any available information on the source of the data;
the fact of automated decision-making, including profiling, and at least the logic used and clear information about the significance of such processing and its likely consequences for you.
Pannon Porto Kft. as the data controller will provide you with a copy of the personal data subject to processing. For additional copies requested by you, Pannon Porto Kft. may charge a fee of HUF 25,000 + VAT based on administrative costs. If you have submitted your request electronically, Pannon Porto Ltd. will provide the information in electronic form unless you request otherwise. The right of access can be exercised through the contact details provided in section 5.8.

5.2. Right to rectification
You have the right to request the rectification of inaccurate personal data concerning you, which Pannon Porto Kft. is obliged to comply with without undue delay. Taking into account the purpose of the processing, you have the right to request the completion of incomplete personal data, including by means of a supplementary declaration.

5.3 Right to erasure (right to be forgotten)
You have the right to have your personal data deleted by Pannon Porto Kft. without undue delay upon your request. Pannon Porto Kft. will delete your personal data without undue delay if the purpose or legal basis for the processing ceases to exist, if you object to the processing and there are no overriding legitimate grounds for the processing, if the personal data have been unlawfully processed, or if the personal data must be erased in order to comply with a legal obligation under European Union or Member State law applicable to Pannon Porto Kft. as controller.

Please be informed that Pannon Porto Kft. may refuse to delete your personal data if the processing is necessary for the fulfilment of an obligation under EU or Member State law that requires the processing of personal data applicable to Pannon Porto Kft. or for the establishment, exercise or defence of legal claims.

5.4. Right to restriction of data
You have the right to request Pannon Porto Ltd to restrict the processing of your personal data if.

(a) you contest the accuracy of the personal data (in which case the restriction applies for the period of time that allows the controller to verify the accuracy of the personal data); or
b) Pannon Porto Kft.'s processing of your data is unlawful and you object to the deletion of the data and instead request the restriction of their use; or
c) Pannon Porto Kft. no longer needs the personal data for the purposes of processing, but you require them for the establishment, exercise or defence of legal claims; or
d) you have objected to the processing.

Please note that where the processing is restricted, such personal data, with the exception of storage, may only be processed with your consent 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.

5.5. The right to data portability
You have the right to receive the personal data concerning you that you have provided to Pannon Porto Ltd. in a structured, commonly used, machine-readable format and to transmit such personal data to another data controller, if the processing is based on consent or a contract and the processing is automated.

In exercising your right to data portability, you have the right to request, where technically feasible, the direct transfer of personal data between controllers.

5.6. The right to object
You have the right to object at any time to the processing of your personal data by Pannon Porto Kft. for legitimate interests on grounds relating to your particular situation, including profiling.

In the event of an objection, Pannon Porto Kft. may no longer process the personal data, unless Pannon Porto Kft. proves that the processing is justified by compelling legitimate grounds which override the interests, rights and freedoms of the data subject or are related to the establishment, exercise or defence of legal claims.

You also have the right to object at any time to the processing of your personal data for direct marketing purposes, including profiling, in which case your personal data will no longer be processed for these purposes.

5.7. Right to withdraw consent
You have the right to withdraw your consent at any time. Your consent constitutes the legal basis for processing for the purposes of the processing set out in points 2.2 to 2.5 of this Notice. Please note that the legal basis for consent does not affect the lawfulness of the processing prior to the withdrawal, i.e. the fact that you withdraw your consent at a later stage does not render the previous processing of Pannon Porto Ltd. based on your consent unlawful.

5.8. Procedural rules
Please note that you can notify Pannon Porto Kft. of any request to exercise your rights in relation to data processing by using the following contact details:

in person at Pannon Porto Kft., 9200 Mosonmagyaróvár, Bástya utca 14.
in writing by post: 9200 Mosonmagyaróvár, Bástya utca 14.
electronically: info@kamionpura.hu

Pannon Porto Kft. will inform you without undue delay, but at the latest within 25 days of receipt of your request, about the processing of your request and the measures taken. If you submit a large number of requests or if your request is particularly complex, Pannon Porto Ltd. may extend the 25-day time limit by a further 2 (two) months, but will inform you of the reasons and justification for the extension within 25 days of receipt of the request. Pannon Porto Ltd. will notify you of its decision in writing or, in the case of a request made by electronic means, by electronic means.

If Pannon Porto Ltd. does not take action on your request, it will inform you without delay, but at the latest within 1 (one) month of receipt of the request, of the reasons for the failure to take action, of the possibility to lodge a complaint with a supervisory authority and of your right to judicial remedy.

Pannon Porto Kft. will provide the information and action free of charge.

If your request is manifestly unfounded or excessive, in particular because of its repetitive nature, Pannon Porto Kft. as data controller, subject to the administrative costs of providing the information or information requested or of taking the action requested:

a) charge a reasonable fee; or
(b) refuse to act on the request.

The burden of proving that the application is manifestly unfounded or excessive lies with Pannon Porto Kft.

Please be informed that the detailed rules on your rights in relation to data processing are set out in GDPR Chapter III, "Data Subjects' Rights", and in Articles 14-21 of the Data Protection Act.

Enforcement options
You have two enforcement options, which are described below:

6.1 Right to lodge a complaint with a supervisory authority
You have the right to lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (hereinafter: NAIH) as supervisory authority if you consider that the processing of personal data concerning you violates the GDPR regulation.

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

Headquarters: 1125 Budapest, Szilágyi Erzsébet fasor 22/c.
Postal address: 1530 Budapest, Pf. 5
Phone number: +36 1 391 1400
Official e-mail address: ugyfelszolgalat@naih.hu
The Authority's website is https://naih.hu

However, please send your complaint to Pannon Porto Kft. as the data controller before initiating the procedure.

6.2. Right to judicial remedy
You also have the right to a judicial remedy against a legally binding decision of the supervisory authority that applies to you. You also have a right to a judicial remedy if the supervisory authority does not deal with your complaint or does not inform you within 3 (three) months of the procedural developments concerning your complaint or the outcome of the complaint. You may also bring the case before the competent court in your place of residence or domicile, if you so choose.

The data breach and its circumstances, effects, and measures taken to remedy it
Please be informed that a data breach is a breach of security that results in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Pannon Porto Ltd. will notify the data breach to the competent supervisory authority without undue delay and, if possible, no later than 72 hours after becoming aware of the data breach, unless the data breach is unlikely to pose a risk to your rights and freedoms. Pannon Porto Ltd will take all necessary measures to ensure this.

Pannon Porto Ltd. will inform you of a data breach without undue delay if it is likely to result in a high risk to your rights and freedoms. In such a case, Pannon Porto Ltd. will provide you with a clear and plain statement of the nature of the personal data breach, the likely consequences of the breach and the measures taken or envisaged to remedy the breach, including, where appropriate, measures to mitigate any adverse consequences of the breach.