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Privacy policy

Privacy notice

Introduction

Loop Looks Kft. (hereinafter: Service Provider, controller) submits itself to the following notice.

We provide the following information in accordance with 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 Directive 95/46/EC (General Data Protection Regulation).

This privacy notice governs the processing of data on the following site: https://looplooks.eu/

This privacy notice is available at: https://looplooks.eu/privacy-policy

Amendments to this notice take effect when published at the above address.

The controller and its contact details:

Name: Loop Looks Kft.
Registered office: 8151 Szabadbattyán, Jókai utca 3/C 2.
Tax number: 32081459207
Email: info@looplooks.eu

Definitions

  1. “personal data”: any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
  1. “processing”: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
  1. “controller”: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
  1. “processor”: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
  1. “recipient”: a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;
  1. “consent of the data subject”: any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
  1. “personal data breach”: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Principles relating to the processing of personal data

Personal data shall be:

  1. processed lawfully, fairly and in a transparent manner in relation to the data subject (“lawfulness, fairness and transparency”);
  1. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (“purpose limitation”);
  1. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (“data minimisation”);
  1. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (“accuracy”);
  1. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1), subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (“storage limitation”);
  1. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (“integrity and confidentiality”).

The controller shall be responsible for, and be able to demonstrate compliance with, the above (“accountability”).

Processing activities

Hosting provider

  1. Activity performed by the processor: hosting services
  1. Name and contact details of the processor:
    Tárhelypark Kft.
    Registered office: 1122 Budapest, Gaál József út 24.
    Phone: +36 1 700 4140
    Postal address: 1122 Budapest, Gaál József út 24.
    Email: info@tarhelypark.hu
  1. Fact of processing and categories of data processed: all personal data provided by the data subject.
  1. Data subjects concerned: all data subjects using the website.
  1. Purpose of processing: making the website available and operating it properly.
  1. Duration of processing and deadline for erasure: processing lasts until the agreement between the controller and the hosting provider ends, or until the data subject requests erasure from the hosting provider.
  1. Legal basis of processing: the User’s consent, Section 5(1) of the Info Act (Infotv.), Article 6(1)(a) GDPR, and Section 13/A(3) of Act CVIII of 2001 on certain issues of electronic commerce services and information society services (Ekertv.).

Use of cookies

  1. Cookies typical of websites
  1. Fact of processing and categories of data processed: unique identification number, dates, times
  1. Data subjects concerned: all data subjects visiting the website.
  1. Purpose of processing: identifying users and tracking visitors.
  1. Duration of processing and deadline for erasure:
Type of cookie Legal basis of processing Duration of processing Data processed
Session cookies Section 13/A(3) of Act CVIII of 2001 on certain issues of electronic commerce services and information society services (Elkertv.) Until the end of the visitor’s session connect.sid

For AddThis cookies, the duration of processing is 2 years.

  1. Potential controllers entitled to access the data: the controller does not process personal data through the use of cookies.
  2. Data subjects’ rights in relation to processing: data subjects can delete cookies in their browser’s Tools/Settings menu, usually under the Privacy settings.
  1. Legal basis of processing: the data subject’s consent is not required where the sole purpose of using cookies is to carry out the transmission of a communication over an electronic communications network, or where the cookie is strictly necessary for the provider to deliver an information society service explicitly requested by the subscriber or user.

Use of Google AdWords conversion tracking

  1. The controller uses the online advertising programme “Google AdWords” and, within it, Google’s conversion tracking service. Google conversion tracking is an analytics service of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”).
  1. When the User reaches a website through a Google ad, a cookie needed for conversion tracking is placed on their computer. These cookies have a limited validity, contain no personal data, and so the User cannot be identified by them.
  1. When the User browses certain pages of the website and the cookie has not yet expired, both Google and the controller can see that the User clicked on the ad.
  1. Every Google AdWords customer receives a different cookie, so they cannot be tracked across the websites of AdWords customers.
  1. The information obtained with conversion tracking cookies is used to produce conversion statistics for AdWords customers who have opted for conversion tracking. Customers thus learn the number of users who clicked on their ad and were forwarded to a page carrying a conversion tracking tag. However, they do not receive any information that could identify any user.
  1. If you do not wish to take part in conversion tracking, you can refuse it by disabling the installation of cookies in your browser. You will then not be included in the conversion tracking statistics.
  1. Further information and Google’s privacy policy are available at: www.google.de/policies/privacy/

Use of Google Analytics

    1. This website uses Google Analytics, a web analytics service of Google Inc. (“Google”). Google Analytics uses “cookies”, text files saved on your computer, which help analyse how the User uses the website visited.
    1. The information generated by the cookies about the User’s use of the website is usually transferred to and stored on a Google server in the USA. With IP anonymisation activated on the website, Google first shortens the User’s IP address within the Member States of the European Union or in other states party to the Agreement on the European Economic Area.
    1. Only in exceptional cases is the full IP address transferred to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate the User’s use of the website, to compile reports on website activity for the website operator, and to provide further services related to website and internet use.
    1. Within Google Analytics, the IP address transmitted by the User’s browser is not merged with other Google data. The User can prevent cookies from being stored by adjusting their browser settings accordingly; please note, however, that in this case not all functions of this website may be fully usable. You can also prevent Google from collecting and processing the data generated by the cookies about your use of the website (including your IP address) by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=hu

Newsletter and direct marketing

  1. Under Section 6 of Act XLVIII of 2008 on the basic conditions and certain limitations of commercial advertising activity (Grt.), the User may give prior and express consent to the Service Provider contacting them with advertising offers and other mailings at the contact details given at registration.
  1. Furthermore, having regard to the provisions of this notice, the Customer may consent to the Service Provider processing the personal data necessary for sending advertising offers.
  1. The Service Provider does not send unsolicited advertising messages, and the User may unsubscribe from offers free of charge, without limitation and without giving reasons. In that case the Service Provider deletes from its records all personal data necessary for sending advertising messages and will not contact the User with further offers. The User can unsubscribe from advertising by clicking the link in the message.
  1. Fact of data collection, categories of data processed and purpose of processing:
Personal data Purpose of processing
Name, email address. Identification; enabling subscription to the newsletter.
Time of subscription Carrying out a technical operation.
IP address at the time of subscription Carrying out a technical operation.
  1. Data subjects concerned: all data subjects subscribing to the newsletter.
  1. Purpose of processing: sending electronic messages containing advertising (email, SMS, push message) to the data subject, and informing them of current information, products, promotions, new features, etc.
  1. Duration of processing and deadline for erasure: processing lasts until the consent is withdrawn, i.e. until unsubscription.
  1. Potential controllers entitled to access the data; recipients of the personal data: the personal data may be processed by the controller’s sales and marketing staff, respecting the above principles.
  2. Data subjects’ rights in relation to processing:
  • The data subject may request from the controller access to, rectification or erasure of, or restriction of processing of, personal data concerning them, and
  • may object to the processing of such personal data, and
  • the data subject has the right to data portability and to withdraw consent at any time.

The data subject can request access to, erasure, rectification or restriction of processing of personal data, data portability, or object to processing in the following ways:

  • by post to the controller’s registered office given above,
  • by email at info@looplooks.eu.

The data subject may unsubscribe from the newsletter free of charge at any time.

Legal basis of processing: the data subject’s consent, Article 6(1)(a) GDPR, Section 5(1) of the Info Act (Infotv.), and Section 6(5) of Act XLVIII of 2008 on the basic conditions and certain limitations of commercial advertising activity:

The advertiser, the advertising service provider and the publisher of the advertisement keep a record, within the scope defined in the consent, of the personal data of persons who have given them their consent. Data recorded in this register relating to the recipient of the advertisement may be processed only in accordance with the consent, until it is withdrawn, and may be disclosed to third parties only with the prior consent of the person concerned.

Please note that

  • processing is based on your consent.
  • you are required to provide the personal data if you wish to receive our newsletter.
  • failure to provide the data has the consequence that we cannot send you the newsletter.

Social media

  1. Fact of data collection and categories of data processed: the name registered on social media sites such as Facebook/Google+/Twitter/Pinterest/YouTube/Instagram, and the user’s public profile picture.
  1. Data subjects concerned: all data subjects who have registered on social media sites such as Facebook/Google+/Twitter/Pinterest/YouTube/Instagram and “liked” the website.
  1. Purpose of data collection: sharing, “liking” and promoting certain content elements, products or promotions of the website, or the website itself, on social media sites.
  1. Duration of processing, deadline for erasure, potential controllers entitled to access the data and the data subjects’ rights in relation to processing: the data subject can find information about the source of the data, its processing, the manner and legal basis of its transfer on the social media site concerned. Processing takes place on the social media sites, so the duration and manner of processing and the options for erasing and modifying the data are governed by the rules of the social media site concerned.
  1. Legal basis of processing: the data subject’s voluntary consent to the processing of their personal data on the social media sites.

Customer relations and other processing

  1. Should any question or problem arise for the data subject while using our services, they can contact the controller in the ways given on the website (phone, email, social media, etc.).
  1. The controller deletes emails and messages received, and data provided by phone, on Facebook, etc., together with the enquirer’s name and email address and any other personal data provided voluntarily, no later than 2 years after the data were provided.
  1. We provide information about any processing not listed in this notice when the data are collected.
  1. In exceptional cases, upon request by an authority, or upon request by other bodies authorised by law, the Service Provider is obliged to provide information, disclose or transfer data, or make documents available.
  1. In such cases the Service Provider discloses to the requesting party – provided it has specified the exact purpose and the scope of the data – only as much personal data, and only to the extent, as is strictly necessary to achieve the purpose of the request.

Rights of data subjects

  1. Right of access

You have the right to obtain from the controller confirmation as to whether or not your personal data are being processed and, where that is the case, access to the personal data and to the information listed in the Regulation.

  1. Right to rectification

You have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

  1. Right to erasure

You have the right to obtain from the controller the erasure of personal data concerning you without undue delay, and the controller is obliged to erase your personal data without undue delay where certain conditions apply.

  1. Right to be forgotten

Where the controller has made the personal data public and is obliged to erase them, the controller, taking account of available technology and the cost of implementation, takes reasonable steps, including technical measures, to inform controllers which are processing the data that you have requested the erasure of any links to, or copies or replications of, those personal data.

  1. Right to restriction of processing

You have the right to obtain from the controller restriction of processing where one of the following applies:

  • you contest the accuracy of the personal data, in which case the restriction applies for a period enabling the controller to verify the accuracy of the personal data;
  • the processing is unlawful and you oppose the erasure of the data and request the restriction of their use instead;
  • the controller no longer needs the personal data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims;
  • you have objected to processing; in this case the restriction applies pending the verification whether the legitimate grounds of the controller override yours.
  1. Right to data portability

You have the right to receive the personal data concerning you, which you have provided to a controller, in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided (…)

  1. Right to object

You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data (…), including profiling based on those provisions.

  1. Objection in the case of direct marketing

Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

  1. Automated individual decision-making, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

The previous paragraph does not apply if the decision:

  • is necessary for entering into, or performance of, a contract between you and the controller;
  • is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
  • is based on your explicit consent.

Time limit for action

The controller informs you of the action taken on the above requests without undue delay and in any event within 1 month of receipt of the request.

Where necessary, this period may be extended by 2 months. The controller informs you of any such extension, together with the reasons for the delay, within 1 month of receipt of the request.

If the controller does not take action on your request, it informs you without delay and at the latest within one month of receipt of the request of the reasons for not taking action, and of the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.

Security of processing

Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing, as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, the controller and the processor implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including, inter alia, as appropriate:

  1. the encryption of personal data;
  1. the ability to ensure the ongoing confidentiality, integrity, availability and resilience of the systems and services used for processing personal data;
  1. the ability to restore the availability of and access to personal data in a timely manner in the event of a physical or technical incident;
  1. a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.

Communication of a personal data breach to the data subject

When a personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, the controller communicates the personal data breach to the data subject without undue delay.

The communication to the data subject must describe in clear and plain language the nature of the personal data breach and give the name and contact details of the data protection officer or other contact point where more information can be obtained; describe the likely consequences of the personal data breach; and describe the measures taken or proposed to be taken by the controller to address the breach, including, where appropriate, measures to mitigate its possible adverse effects.

Communication to the data subject is not required if any of the following conditions are met:

  • the controller has implemented appropriate technical and organisational protection measures, and those measures were applied to the personal data affected by the breach, in particular those that render the personal data unintelligible to any person who is not authorised to access it, such as encryption;
  • the controller has taken subsequent measures which ensure that the high risk to the rights and freedoms of data subjects is no longer likely to materialise;
  • it would involve disproportionate effort. In such a case, there shall instead be a public communication or similar measure whereby the data subjects are informed in an equally effective manner.

If the controller has not already communicated the personal data breach to the data subject, the supervisory authority, having considered the likelihood of the breach resulting in a high risk, may require it to do so.

Notification of a personal data breach to the authority

The controller notifies the personal data breach without undue delay and, where feasible, not later than 72 hours after having become aware of it, to the supervisory authority competent in accordance with Article 55, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. Where the notification is not made within 72 hours, it shall be accompanied by reasons for the delay.

Right to lodge a complaint

Complaints about any infringement by the controller can be lodged with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH):

Nemzeti Adatvédelmi és Információszabadság Hatóság
1125 Budapest, Szilágyi Erzsébet fasor 22/C.
Postal address: 1530 Budapest, Postafiók: 5.
Phone: +36 -1-391-1400
Fax: +36-1-391-1410
Email: ugyfelszolgalat@naih.hu

Final provisions

In preparing this notice we have taken into account 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 Directive 95/46/EC (General Data Protection Regulation)
  • Act CXII of 2011 on the right to informational self-determination and on freedom of information (hereinafter: Infotv.)
  • Act CVIII of 2001 on certain issues of electronic commerce services and information society services (in particular Section 13/A)
  • Act XLVII of 2008 on the prohibition of unfair commercial practices against consumers;
  • Act XLVIII of 2008 on the basic conditions and certain limitations of commercial advertising activity (in particular Section 6)
  • Act XC of 2005 on electronic freedom of information
  • Act C of 2003 on electronic communications (specifically Section 155)
  • Opinion 16/2011 on the EASA/IAB Best Practice Recommendation on online behavioural advertising
  • Recommendation of the Hungarian National Authority for Data Protection and Freedom of Information on the data protection requirements of prior information
  • 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 Directive 95/46/EC