Privacy notice
- The purpose of this notice is to make transparent the data processing procedures followed by our Company as a data controller when contacting it and the principles and rules relating to the protection of natural persons with regard to the processing of their personal data. The fundamental objective of the controller is to respect in all cases the fundamental rights and freedoms of these natural persons, in particular their right to the protection of their personal data.
1.
Name: SamCoGroup Korlátolt Felelősségű Társaság
Head office (and mailing address): 1119 Budapest, Andor utca 21/C Fsz. 1.
Company registration number: 01-09-417292
Tax number: 32308118-2-43
E-mail: office@samco-group.com
2. FOGALMAK
data management: any operation or set of operations which is performed upon 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.
VAT tv.: Act CXXVII of 2007 on Value Added Tax
Fgy. tv.: Act CLV of 1997 on Consumer Protection
GDPR: 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)
Ptk.: Act V of 2013 on the Civil Code
Invoice tv.: Act C of 2000 on accounting
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, 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
3. DATA PROCESSING OPERATIONS
3.1 Data processed during the order process
With respect to our individual customers, our Company processes data in connection with their orders as follows:
| Data managed | Purpose of data processing | Legal basis for processing | Duration of data processing |
| Name | Fulfilling a contractual obligation, selling the product and delivering the purchased product to the customer, invoicing the fees resulting from the contractual obligation and enforcing any claims related to it. | Article 6(1)(b) GDPR: performance of the contract Article 6(1)(c) GDPR: compliance with a legal obligation Article 6(1)(f) GDPR: legitimate interest (in relation to enforcement) | For 8 years after the issue of the accounting document based on the contract [Article 169 (1)-(2) of the Act on Accounting], except for personal data not required for the fulfilment of accounting obligations, for which the limitation period is 5 years after the fulfilment of the contract [general limitation period - Article 6:22 (1) of the Civil Code] |
| billing address | |||
| delivery address (if different from the billing address) | |||
| phone number | |||
| e-mail address | |||
| Screenshot from |
With regard to the processing of data for the purpose of claims and enforcement, it is in the legitimate interest of our Company to be able to develop its position and defence in the enforcement of its claims arising from contracts with customers and, if applicable, in the course of any action against our Company, For this purpose, it is essential, on the one hand, to process the customer's data, since only in this way can our Company take the necessary legal action against the specific contracting party, and, on the other hand, to process evidence in order to prove the customer's conduct and behaviour during the contractual relationship.
3.2 Registration
It is also possible to shop in our webshop without registration, but by registering, the customer gains access to additional features such as tracking the status of their order. The data required for registration is processed by our Company as follows:
| Data managed | Purpose of data processing | Legal basis for processing | Duration of data processing |
| e-mail address | Creating and managing a user account, providing additional functionality through the account. | Article 6(1)(b) GDPR: performance of the contract | Until the user account is deleted by the customer. Failing this, for a period of 1 year from the last activity in the account (the registration will be deleted after the inactivity of the above period and thus the data processing will cease). |
| password |
3.3 Marketing newsletter
Our Company offers you the opportunity to subscribe to our newsletters when placing an order in our webshop, for which we process your personal data as follows:
| Data managed | Purpose of data processing | Legal basis for processing | Duration of data processing |
| e-mail address | Sending e-mails containing commercial advertising, direct marketing or solicitations for the company's products and services. | Article 6(1)(a) GDPR: consent of the data subject | Until you withdraw your consent by clicking on the "unsubscribe" button in the emails. |
3.4 Complaints handling
In order to investigate any complaints concerning our Company's activities and products, the consumer may contact our Company by telephone, e-mail or post, in which case our Company will handle the data as follows.
| Data managed | Purpose of data processing | Legal basis for processing | Duration of data processing |
| Name | Identifying the consumer, investigating the complaint and developing our Company's position and contacting the consumer in this context. | Article 6(1)(c) GDPR: compliance with a legal obligation [Art. 17/A. of the Act on the Protection of the Rights of Persons with Disabilities] | 3 years from the date the complaint is recorded or the date of the reply [§ 17/A (7) para.] |
| Address | |||
| e-mail address | |||
| phone number | |||
| content of the complaint |
3.5 Exercise of rights of access
In the context of ensuring the exercise of the rights set out in point 5 of this notice, we process data as follows:
| Data managed | Purpose of data processing | Legal basis for processing | Duration of data processing |
| the data relating to the request to exercise the right of access, the content of the request, the measures taken in response to the request and the content of the documents drawn up in connection with the request | Examining the request, taking measures if necessary and informing the person concerned | Article 6(1)(c) GDPR: compliance with a legal obligation [Article 12 GDPR] | 5 years from our response to the request of the person concerned [general limitation period - Civil Code 6:22 (1) §] |
3.6 Contact details
For the purpose of maintaining contact with legal business partners (e.g. suppliers) and facilitating the conclusion and performance of contracts with them, our Company processes the personal data of the contact persons of the partners as follows:
| Data managed | Purpose of data processing | Legal basis for processing | Duration of data processing |
| Name | Facilitate the relationship with the business partner, the conclusion and performance of contracts, and the enforcement of claims and rights arising from the contract | Article 6(1)(f) GDPR: Legitimate interest of our company or our business partner | 5 years after the termination of the contractual relationship with the business partner [general limitation period - Civil Code, Art. 6:22 (1)] |
| e-mail address | |||
| phone number | |||
| job title |
The personal data as defined above belongs to the employee of our legal entity business partner (as the natural person acting as a contact person), and the personal data will be transmitted to our Company by our business partner or by the data subject himself to the extent necessary for the contact. In such cases, our business partner, as the employer of the data subject, shall be entitled to use the personal data of the data subject in accordance with Article 6(1)(b) GDPR and the Labour Code. Article 10 (1) of the GDPR, whereas our Company receives and processes the personal data from the data subject in accordance with Article 6 (1) (f) of the GDPR to the extent and for the duration necessary for the purposes of the GDPR in its own legitimate interests and those of our business partner.
In connection with the processing of contact details, it is in the legitimate interest of our Company or the respective partner that the designated contact person is directly available during the preparation and performance of contracts, as it would impose a disproportionate burden and cost on the parties to deal with each other via their official central telephone number or e-mail address at each contact, and during business negotiations it is essential that, if possible, the same contact person who knows the history is used for the handling of matters.
4. THE RECIPIENTS OF PERSONAL DATA AND THE TRANSFER OF DATA
The recipients of personal data are the natural or legal persons with whom or to which the personal data are disclosed. The recipients of personal data are primarily our Company, as the data controller, which in the course of its activities seeks to ensure that personal data are disclosed only to those persons who have a legitimate interest in knowing them.
In order to carry out certain activities underlying data processing operations, our Company uses the assistance of external partners to whom certain personal data of the data subject are (are) transferred. The identity of these recipients may vary, but the scope of their involvement is set out below:
- The courier service that delivers the products [currently: FoxPost Zrt. (registered office: 3300 Eger, Maklári út 119.); GLS General Logistics Systems Hungary Kft. (registered office: 2351 Alsónémedi, GLS Európa utca 2.); PACKETA HUNGARY Kft. (registered office: 1044 Budapest, Ezred utca 1-3. building B2/11.); Magyar Posta Zrt. (registered office: 1138 Budapest, Dunavirág utca 2-6.)
- Billing program partner [currently: Billingo Technologies Zrt. (registered office: 1133 Budapest, Árbóc utca 6.)]
- Web hosting partner [currently: pl S.A.(headquarters: Zbozwa, 4, 70-653 Szczecin)]
- Accounting [currently:
Our Company will not transfer any personal data of the data subject to third countries or international organisations in accordance with Chapter V of the GDPR.
5. THE RIGHTS OF THE DATA SUBJECT
The rights of data subjects are set out in detail in the relevant provisions of the GDPR (in particular Articles 12-22 and 77-80), on which our Company provides an overview below. The data subject may submit a request to exercise these rights to our Company using the contact details provided in point 1.
Our Company will inform data subjects of the measures taken in response to their request to exercise their rights within a maximum of one month of receipt of the request. The date of receipt of the request shall not count towards the time limit. If necessary, taking into account the complexity of the request and the number of requests, this time limit may be extended by a further two months. Our Company will inform the person concerned of the extension of the time limit within one month of receipt of the request, stating the reasons for the delay.
5.1 Right of access
The data subject has the right to request information as to whether or not his or her personal data are being processed and, if such processing is taking place, the right to be informed that:
- what personal data the controller processes, on what legal basis, for what purposes and for how long;
- to whom, when, under what law, to which personal data the controller has given access or to whom the controller has transferred the personal data;
- the source of your personal data;
- whether the controller uses automated decision-making and its logic, including profiling.
5.2 Right to rectification
If the data subject's details change or are incorrectly recorded, the data subject has the right to have inaccurate personal data relating to him or her corrected by our Company at his or her request.
5.3 Right to cancellation
In cases specified by law (Article 17 of the GDPR), the data subject may request that the data processed by our Company be deleted.
5.4 Right to restriction of processing
The data subject may request that the controller restricts the processing of his or her personal data (by clearly indicating the limited nature of the processing and ensuring that it is kept separate from other data) where.
- contests the accuracy of your personal data (in which case the controller will limit the processing for the time necessary to verify the accuracy of the personal data);
- the data processing is unlawful and the data subject opposes the erasure of the data and requests instead the restriction of their use;
- the controller no longer needs the personal data for the purposes of processing, but the data subject requires them for the establishment, exercise or defence of legal claims; or
- the data subject has objected to the processing (in which case the restriction applies for the period until it is established whether the legitimate grounds of the controller override those of the data subject).
5.5 Right to object
In the case of processing based on legitimate interest, the data subject may object to the processing of his or her data. In such a case, our Company may no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
5.6 Right to data portability
The data subject has the right to have his or her personal data processed by automated means transferred by our Company to him or her or to another controller designated by him or her for processing activities based on consent or the performance of a contract.
5.7 Right to redress
If the data subject considers that our Company has infringed the applicable data protection requirements in the processing of his or her personal data, he or she may:
- may lodge a complaint with the Authority (National Authority for Data Protection and Freedom of Information - headquarters: 1055 Budapest, Falk Miksa utca 9-11.; postal address: 1363 Budapest, Pf. 9.; e-mail: ugyfelszolgalat@naih.hu; website: www.naih.hu)
- have the right to apply to the courts, which will rule on the matter out of turn, to protect your data. In such a case, you are free to choose whether to bring your action before the court having jurisdiction for your domicile (permanent address) or residence (temporary address) or the court having jurisdiction for the place where our Company is established. You can find the court of your domicile or residence at http://birosag.hu/ugyfelkapcsolati-portal/birosag-kereso. The competent court for the place where our Company is domiciled is the Metropolitan Court of Budapest.
Published: 30.04.2024.
