1. The Purpose of the Data Processing Policy:
1.1. The website https://szeretetkert.hu (hereinafter: „Website”) is operated by TOLERANCE-TRAINING Kft. (registered office: 1021 Budapest, Hűvösvölgyi út 56., hereinafter: TOLERANCE-TRAINING Kft., Service Provider or Data Controller). As Data Controller, TOLERANCE-TRAINING Kft. acknowledges that it is legally bound by the content of this Policy and undertakes to ensure that the processing of data relating to its activities always complies with the requirements set out in this Policy, as well as in the applicable national legislation and the European Union’s legal acts.
1.2. The privacy policy relating to TOLERANCE-TRAINING Kft.’s data processing activity is available at all times at https://szeretetkert.hu/adatkezelesi-tajekoztato. TOLERANCE-TRAINING Kft. reserves the right to change the content of this Policy, and will notify Users about such changes in due time.
1.3. TOLERANCE-TRAINING Kft. maintains the confidentiality of the personal data processed, and takes all the required security, technical, and organizational measures to safeguard the data. TOLERANCE-TRAINING Kft. sets out its data processing practices in this Policy.
2. The Data Controller’s Contact Details:
Users may contact TOLERANCE-TRAINING Kft. regarding data processing matters using the following contact details:
Name: TOLERANCE-TRAINING Kft.
Registered office: 1021 Budapest, Hűvösvölgyi út 56., Hungary
Company registration number: 01-09-684618
Name of the court that registered the company: Company Registry Court of Budapest-Capital Regional Court
Tax number: 11946023-2-41
Email: tolerance@tolerance.hu
3. The Scope of the Personal Data Processed:
3.1. Within the framework of its activity, TOLERANCE-TRAINING Kft. processes Data Subjects’ personal data required for using the company’s services. TOLERANCE-TRAINING Kft. informs Users about this via this Data Processing Policy.
3.2. Technical data: TOLERANCE-TRAINING Kft. selects and operates the IT tools which it uses to process personal data while it provides its service in a way that ensures that the below principles of processing are followed:
Personal data shall be:
a) processed lawfully, fairly, and in a transparent manner in relation to the Data Subject (“lawfulness, fairness, and transparency”);
b) collected for specified, explicit, and legitimate purposes, and not further processed in a manner that is incompatible with those purposes (“purpose limitation”);
c) adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed („data minimization”);
d) 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”);
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 (“storage limitation”);
f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures (“integrity and confidentiality”).
3.3. TOLERANCE-TRAINING Kft. takes adequate measures to protect data from unauthorized access, alteration, transfer, disclosure, erasure, and deliberate or accidental destruction. In order to guarantee the security of data processing, TOLERANCE-TRAINING Kft. implements technical and organizational measures that provide an adequate level of protection commensurate with the risks associated with the processing. TOLERANCE-TRAINING Kft. keeps the data processing confidential: it protects information and ensures that only authorized parties have the ability to access it; safeguards the integrity of data: protects the accuracy and completeness of the information and the method of processing; makes sure that the information is available: it takes the necessary measures to make sure that eligible Users can actually access the desired information when the need arises and makes certain that the related tools for this are available.
3.4. Cookies:
3.4.1. Cookies collect data about Users and their devices; they remember User’s preferences—these may be used during online transactions, for instance—so Users do not have to provide the information again; they make it easier to use the service; they ensure that Users have a quality experience. In order to provide a personalized experience, a small data package (“cookie”) is placed on Users’ computers, which will be read during a subsequent visit. If the browser sends back a previously saved cookie, the provider managing the cookie has the option to link the User’s current visit to previous visits—however, providers may only do so regarding their own content.
3.4.2. Strictly necessary session cookies: The purpose of these cookies is to enable Users to fully and seamlessly use the service and all of its functionalities, along with all the available services. The validity of these cookies lasts until the end of the session. Upon closing the browser, these cookies will be automatically deleted from the computer or other devices used for browsing.
3.4.3. Third-party cookies (analytics): TOLERANCE-TRAINING Kft. uses third-party (Google Analytics) cookies as well. With the help of a statistics-driven service, Google Analytics collects information on how Users use the service. TOLERANCE-TRAINING Kft. uses this data to improve the service and the user experience. These cookies will also remain on the Visitor’s computer or other device used for browsing until they expire or until the User deletes them.
4. The Records of the Data Processing Activities:
TOLERANCE-TRAINING Kft. keeps a record of the data processing activities it is responsible for. This record contains the following information:
a) the name and contact details of the Data Controller;
b) the purposes of the data processing;
c) information about the categories of Data Subjects and personal data;
d) the categories of recipients to whom personal data is or will be disclosed, including international organizations or recipients residing in third countries;
e) where applicable, information about transferring personal data to third countries or international organizations, including identifying the specific third country or international organization, and if necessary, describing the adequate safeguards in place;
f) if possible, the deadlines set out for erasing data belonging to certain categories; g) if possible, a general description of the technical and organizational measures that keep the data processing secure.
5. The Purpose, Method, and Legal Basis of Data Processing, General Data Processing Guidelines:
The purpose of the data processing related to TOLERANCE-TRAINING Kft.’s activity is the provision of services to its Users. The processing is based on the voluntary consent of Users and it is also authorized by law. When it comes to consent-based data processing, Data Subjects have the right to withdraw their consent at any stage of the processing. In some cases, we are bound by legislation to process, store and transfer certain types of data. We will notify Users about this through an additional channel if necessary. Pursuant to Paragraph (2) of Section 2:48 of the Hungarian Civil Code, visual and audio recordings created in connection with TOLERANCE-TRAINING Kft.’s interactive services requiring personal attendance (e.g. theater events) are considered recordings made of a crowd, where the consent of the Data Subject is not required for recording his/her likeness or voice, or for the use of such a recording. Users explicitly waive the right to potentially exercise their rights with regards to such events. Please note that if you are disclosing someone else’s personal data to TOLERANCE-TRAINING Kft., it is your responsibility to obtain the Data Subject’s consent. TOLERANCE-TRAINING Kft.’s data processing principles are in line with the applicable data privacy legislation, especially with the following:
- Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information (“Privacy Act”);
- 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, GDPR).
6. The Physical Location of Data Storage:
Users’ personal data (i.e. data that can be used to identify a specific User) may be processed by TOLERANCE-TRAINING Kft. in the framework of using the service provided by TOLERANCE-TRAINING Kft. Over the course of this process, certain technical data are generated automatically in the IT system, while others (e.g. name, contact details, etc.) may be provided by the User if these are required to use the services offered. We store the data on TOLERANCE-TRAINING Kft.’s own devices and the devices of the data processor engaged by TOLERANCE-TRAINING Kft.
7. Data Transfer, Data Processing, Parties to whom the Data is Disclosed
7.1. TOLERANCE-TRAINING Kft. may use the services of the following data processors: OTP Mobil Szolgáltató Kft.’s (registered office: 1143 Budapest, Hungária krt. 17–19., Hungary; company registration number: 01-09-174466;
tax number: 24386106-2-42) Simple Pay service (paying online for orders via credit or debit card). These data processors process Users’ data as set out in their own data processing policies.
7.2. Users’ personal data may be disclosed, to the degree necessary for providing the service, to TOLERANCE-TRAINING Kft.’s vendors and other parties assisting the company with the service delivery. Over the course of this process, TOLERANCE-TRAINING Kft. ensures at all times that its vendors and other parties assisting the company with the service delivery are handling Users’ personal data in accordance with the requirements set out in this Privacy Policy.
7.3. The following external plugins are integrated into the Website’s code:
Google Analytics, YouTube, Facebook, Google Play, App Store, Instagram; the list of integrated plugins may change over time.
The above-mentioned service providers are handling and/or processing data as per their own data processing policies.
8. The Rights of Data Subjects and the Options for Exercising their Rights:
8.1. Data Subjects have the right to request information on the processing of their personal data, they may request the Data Controller to rectify and—with the exception of mandatory data processing—delete their personal data, they may withdraw their consent, and they may exercise their right to data portability and to object by taking the steps indicated during the recording of the data in question or via the Data Controller’s contact details listed above.
8.2. Right to be Informed: TOLERANCE-TRAINING Kft. takes appropriate measures to provide all the necessary information pertaining to the processing of personal data as set out in Article 13 and 14, as well as Articles 15–22 and Article 34 of the GDPR to Users in a concise, transparent, intelligible, and easily accessible form, using clear and plain language.
8.3. Right of Access by the Data Subject: The Data Subject shall have the right to obtain from the Data Controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access the personal data and the following information: the purposes of the processing; the categories of personal data concerned; the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations; the envisaged period for which the personal data will be stored; the right to request the rectification or erasure of personal data or the restriction of processing or to object to such processing; the right to lodge a complaint with a supervisory authority; any available information as to the source of the collected data; the existence of automated decision-making, including profiling; meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the Data Subject. The Data Controller shall provide the necessary information within a maximum of one month after receiving the request.
8.4. Right to Rectification: In the event that the personal data processed by TOLERANCE-TRAINING Kft. is inaccurate or incomplete, the Data Subject has the right to have the data rectified or completed.
8.5. Right to Erasure: The Data Subject shall have the right to obtain from TOLERANCE-TRAINING Kft. the erasure of personal data concerning him or her without undue delay and the Data Controller shall be obligated to erase personal data without undue delay where one of the following grounds applies: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; the Data Subject withdraws consent on which the processing is based, and where there is no other legal ground for the processing; the Data Subject objects to the processing and there are no overriding legitimate grounds for the processing; the personal data have been unlawfully processed; the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the Data Controller is subject; the personal data have been collected in relation to the offer of information society services. The erasure of data may not be initiated if the processing is necessary for exercising the right of freedom of expression and information; for compliance with a legal obligation which requires processing by Union or Member State law to which the Data Controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller; for reasons of public interest in the area of public health, for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in the public interest; or for the establishment, exercise, or defense of legal claims.
8.6. Right to Restriction of Processing: The Data Subject shall have the right to obtain from TOLERANCE-TRAINING Kft. restriction of processing where one of the following applies: the accuracy of the personal data is contested by the Data Subject, restricting the processing for a period enabling the Data Controller to verify the accuracy of the personal data; the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; the Data Controller no longer needs the personal data for the purposes of the processing, but they are required by the Data Subject for the establishment, exercise, or defense of legal claims; or the Data Subject has objected to processing, thus restricting the processing pending the verification whether the legitimate grounds of the Data Controller override those of the Data Subject. Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with the Data Subject’s consent or for the establishment, exercise, or defense of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the Union or of a Member State.
8.7. Right to Data Portability: The Data Subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a Data Controller, in a structured, commonly used, and machine-readable format, and have the right to transmit those data to another Data Controller.
8.8. Right to Object: The Data Subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her if processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller, or the processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party, including profiling based on the provisions mentioned. If the Data Subjects objects to the processing, the Data Controller shall no longer process the personal data unless the Data Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the Data Subject, or for the establishment, exercise, or defense of legal claims.
8.9. Automated Individual Decision-making, including Profiling: The Data Subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
8.10. Right to Withdraw Consent: The Data Subject shall have the right to withdraw his or her consent at any time.
8.11. Right to an Effective Judicial Remedy: Should the Data Subject’s rights be infringed upon, he or she has the right to initiate legal proceedings against the Data Controller. The court shall hear the case out of turn.
8.12. Administrative Proceedings Related to Data Privacy: Data Subjects may lodge a claim with the National Authority for Data Protection and Freedom of Information: Name: National Authority for Data Protection and Freedom of Information Registered office: 1055 Budapest, Falk Miksa utca 9–11., Hungary, Mailing address: 1363 Budapest, Pf. 9., Hungary, Telephone: +3613911400, Fax: +3613911410, Email: ugyfelszolgalat@naih.hu, Website: http://www.naih.hu
8.13. Minors under the age of 16 may only provide personal data about themselves with the consent of their legal representative. The consent or subsequent approval of the legal representative of a Data Subject who is a minor of at least 16 of age is not required to consider the Data Subject’s declaration of consent valid.
9. Other Provisions
Information on data processing not listed in this Policy will be provided at the time of collecting the data in question. Please note that the Data Controller may be contacted by the courts, as well as by public prosecutors, authorities in charge of an investigation, authorities responsible for investigating violations of the law, administrative authorities, the National Authority for Data Protection and Freedom of Information, the Hungarian National Bank and—based on legal authorization—other bodies for the purpose of receiving pertinent information, data, and documents. If the authorities in question specified the precise purpose and the scope of data, TOLERANCE-TRAINING Kft. will only disclose personal data to the extent strictly necessary to fulfil the purpose of the request.
10. Registration, Newsletter:
10.1. Our Users have the option to register on our Website or sign up for our newsletter in order to use our services, receive our newsletter, or obtain information regarding our services. During this process, we may ask Users to provide the personal and other types of data listed below, and we may process the following personal and other types of data in connection with our registered Users:
- name
- username and password
- phone number
- shipping address
- email address
- products ordered
- the place, date, time, device, software and IP address connected to the order
- the User’s previous orders
- visual and audio recordings created in connection with interactive services requiring personal attendance
10.2. By registering, placing an order, or signing up for a newsletter, Data Subjects give their voluntary and explicit consent to the processing of their personal and other types of data.
10.3. Personal and other types of data provided when registering, placing an order, or signing up for our newsletter will be processed in accordance with this Data Processing Policy.
10.4. By registering, placing an order, or signing up for our newsletter, the User agrees to the free of charge processing of their personal and other types data in accordance with this Data Processing Policy.
10.5. All of our messages and newsletters inform recipients about the possibility and steps of unsubscribing.
11. Links:
11.1. A link on our Website directing Users to other webpages hosted by other providers. Our Visitors and Users should keep in mind that by using these hyperlinks, they will be redirected to webpages maintained by other service providers.
11.2. Please note that we have no control over whether other service providers comply with the legal provisions pertaining to data privacy. If deemed necessary, please read the data processing policies of the providers hosting these webpages carefully.
11.3. The privacy practices set out in this Privacy Policy are only applicable to webpages maintained by TOLERANCE-TRAINING Kft.
Effective Date: 27/07/2022
