Data protection

On the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Regulation (EC) No 95/46 (General Data Protection Regulation) REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 2016 27.) I give the following information.
This privacy statement governs the privacy of the following page:
“https://en.silvermoon.hu”
The data management information is available from the following page:
“https://en.silvermoon.hu/data-protection”
Amendments to the prospectus will take effect upon publication at the above address.

DEFINITIONS

1. “personal data” shall mean any information relating to an identified or identifiable natural person (“data subject”); identify a natural person who, directly or indirectly, in particular by an identifier such as name, number, location, online identifier or one or more factors relating to the natural person’s physical, physiological, genetic, mental, economic, cultural or social identity identifiable;
2. “processing” means any operation or set of operations on personal data or files, whether automated or non-automated, such as collection, recording, systematisation, sorting, storage, transformation or alteration, retrieval, consultation, use, communication, transmission, dissemination or otherwise made available, by coordination or interconnection, restriction, deletion or destruction;
3. “controller” means the natural or legal person, public authority, agency or any 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 the processing are determined by Union or Member State law, the controller or the specific criteria for the designation of the controller may also be determined by Union or Member State law;
4. “processor” means any natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller;
5. “recipient” means a natural or legal person, public authority, agency or any other body to whom personal data are disclosed, whether a third party or not. Public authorities that may have access to personal data in the context of an individual investigation in accordance with Union or Member State law shall not be considered as recipients; the processing of such data by these public authorities must comply with the applicable data protection rules in accordance with the purposes of the processing;
6. “data subject’s consent” means the voluntary, specific and duly informed and unambiguous statement of the data subject’s intention, by means of a statement or unequivocal statement of consent, to consent to the processing of personal data concerning him or her;
7. “data protection incident” means a breach of security which results in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or unauthorized access to, personal data which have been transmitted, stored or otherwise handled.

DATA MANAGER AND CONTACTS:

Operator: Ext-Ton Hungary Kft.
Name: Renáta Mundrák
Headquarters: Hungary, H-6000 Kecskemét, Madár street 21.
E-mail: mundrak.renata@silvermoon.hu
Telefon: +36 30 81 26 747

PRINCIPLES FOR THE PROCESSING OF PERSONAL DATA

Personal information:
(a) it must be processed lawfully and fairly and in a manner which is transparent to the data subject (“lawfulness, due process and transparency”);
(b) collected only for specified, explicit and legitimate purposes and not treated in a way incompatible with those purposes; further processing for data purposes for archiving in the public interest, for scientific and historical research purposes or for statistical purposes (“purpose limitation”) shall not be considered incompatible with the original purpose in accordance with Article 89 (1);
(c) be appropriate and relevant to the purposes for which the data are processed and limited to what is necessary (“data economy”);
(d) be accurate and, where necessary, kept up to date; all reasonable steps must be taken to ensure that personal data which are inaccurate for the purposes of the processing are erased or rectified without delay (“accuracy”);
(e) 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 a longer period only if the personal data are processed in accordance with Article 89 (1) for archiving in the public interest, for scientific and historical research purposes or for statistical purposes, in accordance with this Regulation; subject to the implementation of appropriate technical and organizational measures to protect its freedoms (“limited storage capacity”);
(f) processed in such a way as to ensure the adequate security of personal data, including the protection against unauthorized or unlawful processing, accidental loss, destruction or damage to personal data, by applying appropriate technical or organizational measures (“integrity and confidentiality”).
The controller is responsible for compliance with the above and must be able to demonstrate such compliance (“accountability”).

Hosting provider

1. Activity performed by data processor: Hosting service
2. Name and contact details of the data processor:
Tárhelypark Kft.
Postal address:
Hungary, 1126 Budapest, Tartsay Vilmos street 14.
Headquarters address:
Hungary, 1126 Budapest, Tartsay Vilmos street 14.
Telephone: +36 1 700 4140
3. Fact of data processing, scope of data processed: All personal data provided by the data subject.
4. Stakeholders: All stakeholders who use the website.
5. The purpose of data management: To make the website available and to operate it properly.
6. Duration of data processing, deadline for deletion of data: The data processing lasts until the termination of the agreement between the data controller and the hosting provider or until the data subject’s request for deletion to the hosting provider.
7. The legal basis of the data processing: the User’s consent, the Infotv. Section 5 (1), Article 6 (1) (a) and Section CVIII of 2001 on certain issues of electronic commerce services and information society services. Act 13 / A. § (3).

HANDLING COOKIE-S

1. The fact of data management, the scope of data processed: Unique identification number, dates,
appointments
2. Stakeholders: All stakeholders who visit the website.
3. Purpose of data management: Identify users and track visitors.
4. Period of data management, deadline for deletion of data: Period until the end of the relevant visitor session
5. Identity of potential data controllers entitled to access the data: The data controller cannot handle personal data with the help of cookies.
6. Description of the data subject’s rights regarding data management: Data subjects have the option to delete cookies in the Tools / Settings menu of browsers, usually under the Privacy settings setting.
7. Legal basis of the data processing: The consent of the data subject is not required, the purpose of the use of cookies is for communication via an electronic communications network or for a society defined by the subscriber or user that provides an information service to the service provider.

USING GOOGLE ADWORDS CONVERSION TRACKING

1. An online advertising program called “Google AdWords” is used by the data controller and uses Google’s conversion tracking service. Google Conversion Tracking is an analytics service provided by Google Inc. (1600 Amphitheater Parkway, Mountain View, CA 94043, USA; “Google”).
2. When a User accesses a website via a Google ad, a cookie to track conversion is placed on their computer. These cookies have a limited validity and do not contain any personal data, so the User cannot be identified by them.
3. When the User browses certain pages of the website and the cookie has not expired, both Google and the data controller can see that the User has clicked on the advertisement.
4. Each Google AdWords customer receives a different cookie, so it cannot be tracked through AdWords customers’ websites.
5. The information obtained through conversion tracking cookies is used to generate conversion statistics for AdWords conversion tracking customers. This is how customers find out the number of users who clicked on your ad and were redirected to a page with a conversion tracking tag. However, they do not have access to information that could identify any user.
6. If you do not wish to participate in conversion tracking, you can opt out by disabling cookies in your browser. You will then not be included in your conversion tracking statistics.
7. Further information and the Google Privacy Statement can be found at www.google.de/policies/privacy/

APPLYING GOOGLE ANALYTICS

1. This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses so-called “cookies”, which are text files placed on your computer, to help the website analyze how users use the site.
2. The information created by the cookie about the website used by you will normally be stored and stored on a Google server in the USA. By activating IP anonymization on the Website, Google will abbreviate 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.
3. The full IP address will be transmitted to and truncated to Google’s server in the United States only in exceptional cases. On behalf of the operator of this website, Google will use this information to evaluate how the user has used the website, to provide the website operator with reports on website activity and to provide additional services related to website and internet usage.
4. Within the framework of Google Analytics, the IP address transmitted by the User’s browser is not reconciled with other data of Google. The User may prevent the storage of cookies by setting the appropriate browser, however, please note that in this case, not all functions of this website may be fully available. You may also prevent Google from collecting and processing your information about your use of the Website (including your IP address) by cookies by downloading and installing the browser plugin available at the following link. https://tools.google.com/dlpage/gaoptout?hl=en_US

NEWSLETTER, DM ACTIVITY

1. Act XLVIII of 2008 on the basic conditions and certain restrictions of economic advertising activity. Pursuant to Section 6 of Act No. 1/2002 Coll.The User may agree in advance and expressly to contact the Service Provider with his/her advertising offers and other items at the contact details provided during registration.
2. Furthermore, keeping in mind the provisions of this prospectus, the Customer may consent to the Service Provider handling the personal data necessary for sending advertising offers.
3. The Service Provider does not send unsolicited advertising messages, and the User may unsubscribe from sending offers free of charge without restriction or justification. In this case, the Service Provider deletes all personal data – necessary for sending advertising messages – from its register and does not contact the User with its further advertising offers. The user can unsubscribe from the ads by clicking on the link in the message.
4. Fact of data collection, scope of data processed and purpose of data management:
Name, e-mail address: Identification, enabling you to subscribe to the newsletter. Date of subscription: Perform a technical operation.
IP address at the time of subscription: Perform a technical operation.
5. Stakeholders: All stakeholders who subscribe to the newsletter.
6. The purpose of data management: to send electronic messages containing advertising (e-mail, sms, push message) to the data subject, to provide information about current information, products, promotions, new features, etc.
7. Duration of the data processing, deadline for deleting the data: the data processing lasts until the withdrawal of the consent statement, ie until the unsubscription.
8. Identity of potential data controllers entitled to access the data, recipients of personal data: Personal data may be processed by the data controller’s sales and marketing staff, respecting the above principles.
9. Description of data subjects’ rights in relation to data processing:
– the data subject may request the controller to access, rectify, delete or restrict the processing of personal data concerning him or her, and
– object to the processing of such personal data, and
– the data subject has a right to data portability and must be at all times.
10. Access, delete, modify, or change your personal information
data protection, the portability of data, the protest against data processing can be initiated by the data subject in the following ways:
– by post at Hungary H-6000 Kecskemét, Madár street 21,
– by e-mail on info@silvermoon.hu address,
– by telephon on (+36 30) 812 6747 .
11. The data subject may unsubscribe from the newsletter free of charge at any time.
12. Data processor used by the data controller:
SalesAutopilot Ltd.
Headquarters: Hungary H-1024 Budapest, Margit blvd. 31-33. mezzanine 4.
Postal address: Hungary H-1538 Budapest, mailbox 515.
Tel: (+36) 1 490 0172
website: https://www.salesautopilot.hu
13. Legal basis for data processing: consent of the data subject, Article 6 (1) (a), Infotv. § 5 (1), and Act XLVIII of 2008 on the basic conditions and certain restrictions of economic advertising activity. Section 6 (5) of the Act:
The advertiser, the advertising service provider or the publisher of the advertisement shall keep records of the personal data of the persons who have made a statement to them, within the scope specified in the consent. The data contained in this register relating to the recipient of the advertisement may be processed only in accordance with the statement of consent, until it is withdrawn, and may be disclosed to third parties only with the prior consent of the person concerned.
14. Please be informed that
– data management is based on your consent.
– is obliged to provide personal data if you want to receive a newsletter from us.
– Failure to provide this will result in the inability to send you a newsletter.

COMPLAINT HANDLING

1.Facture of data collection, scope of data processed and purpose of data management:

Surname and first name: Identification, contact.
E-mail address: Contact.
Phone number: Contact.
Billing Name and Address: Identification, handling of quality complaints, questions, and issues related to the products / services ordered.

2. Stakeholders: All stakeholders who buy on the website and complain about quality complaints.
3. Duration of the data processing, deadline for deletion of the data: Copies of the report, transcript and response to the complaint have been issued in accordance with CLV Act 1997 on Consumer Protection. Act 17 / A. § (7) shall be kept for 5 years.
4. The identity of the potential data controllers entitled to access the data, the recipients of the personal data: The personal data may be processed by the sales and marketing staff of the data controller, respecting the above principles.
5. Description of data subjects’ rights in relation to data processing:
– the data subject may request the controller to access, rectify, delete or restrict the processing of personal data concerning him or her, and
– object to the processing of such personal data, and
– the data subject has the right to data portability and to withdraw his or her consent at any time.
6. Access to, deletion, modification or restriction of the processing of personal data, portability of data, protest against data processing may be initiated by the data subject in the following ways:
– by post at Hungary H-6000 Kecskemét, Madár street 21,
– by e-mail at mundrak.renata@silvermoon.hu e-mail address,
7. Legal basis for data processing: consent of the data subject, Article 6 (1) (c), Infotv. § 5 (1) and the CLV of 1997 on consumer protection. Act 17 / A. § (7).
8. Please be informed that
– the provision of personal data is based on a contractual obligation.
– the processing of personal data is a precondition for concluding a contract
– is obliged to provide personal data so that we can handle your complaint.
– Failure to provide information will result in the inability to handle your complaint.

COMMUNITY SITES

1. The fact of data collection, the range of data processed: Facebook / Google + / Twitter / Pinterest / Youtube / Instagram, etc. the name registered on social networking sites or the user’s public profile picture.
2. Stakeholders: All stakeholders who have registered on Facebook / Google + / Twitter / Pinterest / Youtube / Instagram, etc. social networking sites and “liked” the website.
3. Purpose of data collection: On social networking sites, to share or “like” certain content elements, products, promotions or the website itself.
4. Duration of data processing, deadline for deletion of data, identity of potential data controllers entitled to access the data and data subjects’ rights related to data processing: The data subject may be informed about the source of the data, their processing and the legal basis. Data management is carried out on social networking sites, so the duration and method of data management, as well as the possibilities of deleting and modifying data are regulated by the given social networking site.
5. Legal basis for data processing: the voluntary consent of the data subject to the processing of his or her personal data on social networking sites.

Data transmission, data processing, the circle of those who get to know the data

Depending on the purpose of your subscription, we will share your information with the following third-party service providers:

Newsletter and sales system management software

SalesAutopilot Ltd.
Service: MailMaster / SalesAutopilot
Address of the data processor: Hungary, 1024 Budapest, Margit krt. 31-33. mezzanine 4.
Location of data processing (website or address):salesautopilot.hu
Data processing technology: with information system
Privacy Statement: http://salesautopilot.s3.amazonaws.com/documents/SalesAutopilot-Szolgaltatoi-Szerzodes-20180525.pdf

Billing software provider

KBOSS.hu Kft.
Address of the data processor: Hungary, 2000 Szentendre, Táltos street 22/b.
Location of data processing (website or address): szamlazz.hu
Data processing technology: with information system
Privacy Statement: https://www.szamlazz.hu/adatvedelem/

Credit card acceptance systems

Barion Payment Zrt.
Address of data processor: Hungary, 1117, Budapest, Infopark sétány 1.
EE-money issuer license number: H-EN-I-1064/2013
Location of data processing (website or address): barion.hu
Data processing technology: with information system
Privacy Statement: https://secure.barion.com/Contract/GetDocument?key=akt
The range of data transmitted: username, surname, first name, country, telephone number, e-mail address.
The purpose of the transfer is to provide customer service assistance to users, confirmation of transactions and fraud monitoring to protect users.

Details of the place of acceptance:
Name of place of acceptance: Silver Moon
Public ID (POSGuid): 56310a1f-11d7-4a02-9e6b-075893bf9d45

CUSTOMER RELATIONS AND OTHER DATA MANAGEMENT

1. Should the data subject have any questions or problems during the use of our data management services, he or she may contact the data controller in the ways provided on the website (telephone, email, social networking sites, etc.).
2. Data controller for incoming emails, messages, phone, Facebook, etc. will delete the data provided together with the name and e-mail address of the interested party and any other personal data voluntarily provided after a maximum of 2 years from the date of disclosure.
3. Information on data processing not listed in this prospectus will be provided at the time of data collection.
4. Upon an exceptional official request, or in the case of contacting other bodies based on the authorization of legislation, the Service Provider is obliged to provide information, disclose data, or make documents available.
5. In such cases, the Service Provider shall provide the requester with personal data only to the extent and to the extent that is absolutely necessary for the realization of the purpose of the request, provided that it has indicated the exact purpose and scope of the data.

RIGHTS OF STAKEHOLDERS

1. Right of access
You have the right to receive feedback from the data controller as to whether the processing of your personal data is in progress and, if such processing is in progress, you have the right to access the personal data and information listed in the Regulation.
2. Right to rectification
You have the right, at the request of the data controller, to correct inaccurate personal data concerning him or her without undue delay. Taking into account the purpose of the data processing, you have the right to request that the incomplete personal data be supplemented, inter alia, by means of an additional statement.
3. Right of cancellation
You have the right to delete personal data about you without undue delay at your request, and the data controller is obliged to delete personal data about you without undue delay under certain conditions.
4. The right to be forgotten
If the controller has disclosed personal data and is obliged to delete it, it shall take reasonable steps, including technical measures, taking into account the available technology and the cost of implementation, to inform the controllers that you have requested the personal data in question. deleting links or copies or duplicates of such personal data.
5. Right to restrict data processing
You have the right, at the request of the controller, to restrict the processing of data if one of the following conditions is met:
– You dispute the accuracy of the personal data, in which case the restriction applies to the period of time that allows the data controller to verify the accuracy of the personal data;
– the processing is unlawful and you object to the deletion of the data and instead ask for a restriction on its use;
– the data controller no longer needs the personal data for the purpose of data processing, but you request them in order to submit, enforce or protect legal claims;
– You have objected to the data processing; in this case, the restriction applies for as long as it is established whether the legitimate reasons of the controller take precedence over your legitimate reasons.
6. The right to data portability
You have the right to receive personal data concerning him or her made available to a data controller in a structured, widely used machine-readable format and to transfer such data to another data controller without being hindered by the data controller whose provided personal data to him/her
7. Right to protest
You have the right to object at any time to the processing of your personal data, including profiling based on these provisions, for reasons related to your own situation.
8. Protest in the case of a direct acquisition
If your personal data is processed for the purpose of direct business acquisition, you have the right to object at any time to the processing of your personal data for this purpose, including profiling, insofar as it relates to direct business acquisition. If you object to the processing of personal data for the purpose of direct business acquisition, the personal data may no longer be processed for this purpose.
9. Automated decision making in individual cases, including profiling
You have the right not to be covered by a decision based solely on automated data processing, including profiling, which would have legal effect or similar effect on him or her.
The preceding paragraph shall not apply if the decision:
– Necessary for the conclusion or performance of a contract between you and the data controller;
– is governed by EU or Member State law applicable to the controller, which also lays down appropriate measures to protect your rights and freedoms and legitimate interests; obsession
– Based on your express consent.

DEADLINE FOR ACTION

The controller shall inform you without undue delay, but in any case within 1 month of receipt of the request, of the action taken on the above requests.
If necessary, it can be extended by 2 months. The data controller shall inform you of the extension of the deadline within 1 month from the receipt of the request, indicating the reasons for the delay.
If the controller does not take action on your request, it will inform you without delay, but no later than one month after receipt of the request, of the reasons for the non-action and of the fact that you can lodge a complaint with a supervisory authority and have recourse to the courts.

SECURITY OF DATA PROCESSING

The controller and the processor shall take appropriate technical and organizational measures to take into account the state of the art and the costs of implementation and the nature, scope, circumstances and purposes of the processing and the varying probability and severity of the risk to the rights and freedoms of natural persons. to ensure a level of data security appropriate to the degree of risk, including, where appropriate:
a) pseudonymisation and encryption of personal data;
b) ensuring the continued confidentiality, integrity, availability and resilience of the systems and services used to process personal data;
c) in the event of a physical or technical incident, the ability to restore access to and availability of personal data in a timely manner;
d) a procedure for the regular testing, assessment and evaluation of the effectiveness of the technical and organizational measures taken to ensure the security of data processing.

INFORMATION ABOUT THE DATA PROTECTION INCIDENT

If the data protection incident is likely to pose a high risk to the rights and freedoms of natural persons, the controller shall inform the data subject of the data protection incident without undue delay.
The information provided to the data subject shall clearly and intelligibly describe the nature of the data protection incident and the name and contact details of the data protection officer or other contact person who may provide further information; the likely consequences of the data protection incident must be described; a description of the measures taken or planned by the controller to remedy the data protection incident, including, where appropriate, measures to mitigate any adverse consequences arising from the data protection incident.
The data subject need not be informed if any of the following conditions are met:
– the controller has implemented appropriate technical and organizational security measures and these measures have been applied to the data affected by the data protection incident, in particular measures such as the use of encryption which make it incomprehensible to persons not authorized to access personal data the data;
– the controller has taken further measures following the data protection incident to ensure that the high risk to the data subject’s rights and freedoms is no longer likely to materialize;
– the information would require a disproportionate effort. In such cases, data subjects shall be informed through publicly available information or a similar measure shall be taken to ensure that data subjects are informed in an equally effective manner.
If the data controller has not yet notified the data subject of the data protection incident, the supervisory authority may, after considering whether the data protection incident is likely to involve a high risk, order the data subject to be informed.

REPORTING A DATA PROTECTION INCIDENT TO THE AUTHORITY

The data protection incident shall be reported by the controller to the competent supervisory authority in accordance with Article 55 without undue delay and, if possible, no later than 72 hours after becoming aware of the data protection incident, unless the data protection incident is not likely to endanger the rights of individuals. and its freedoms. If the notification is not made within 72 hours, the reasons for the delay must be provided.

POSSIBILITY TO COMPLAIN

Complaints against possible breaches of the data controller can be lodged with the National Data Protection and Freedom of Information Authority:
National Data Protection and Freedom of Information Authority
Hungary H-1125 Budapest, Szilágyi Erzsébet fasor 22/C.
Mailing address: 1530 Budapest, Mailbox: 5.
Telephone: +36 -1-391-1400
Fax: +36-1-391-1410
E-mail: ugyfelszolgalat@naih.hu

SUMMARY

During the preparation of the prospectus, I was aware of the following legislation:
– On the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Regulation (EC) No 95/46 (General Data Protection Regulation) April 27)
– 2011 CXII. Act on the Right to Self-Determination of Information and Freedom of Information (hereinafter: the Information Act)
– CVIII of 2001 Act – on certain issues of electronic commerce services and services related to the information society (mainly Section 13 / A)
– 2008 XLVII. Act on the Prohibition of Unfair Commercial Practices for Consumers;
– XLVIII of 2008 Act – on the basic conditions and certain restrictions of commercial advertising (especially § 6)
– 2005 XC. Electronic Freedom of Information Act
– Act C of 2003 on Electronic Communications (specifically Section 155)
– 16/2011. s. Opinion on the EASA / IAB Recommendation on Best Practices for Behavioral Online Advertising
– Recommendation of the National Authority for Data Protection and Freedom of Information on data protection requirements for prior information
– Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Regulation (EC) No 95/46