Privacy Policy
in which we inform you, as a visitor to our website and a user of our services, about our company’s data management and data protection rules.
1. What principles do we follow during our data management?
Our company follows the following principles during its data management:
- we process personal data lawfully and fairly, and transparently for you.
- we collect personal data only for specified, explicit and legitimate purposes and do not process them in a manner incompatible with those purposes.
- the personal data we collect and process are appropriate and relevant for the purposes of data management and are limited to what is necessary.
- Our company takes all reasonable steps to ensure that the data we process is accurate and, where necessary, up-to-date, and that inaccurate personal data is deleted or corrected without delay.
- We store personal data in a form that allows you to be identified only for the time necessary to achieve the purposes for which the personal data are processed.
- We ensure the appropriate security of personal data against unauthorized or unlawful processing, accidental loss, destruction or damage of data by applying appropriate technical and organizational measures.
- Our company processes your personal data
- based on your prior informed and voluntary consent and only to the extent necessary and in all cases for a purpose, i.e. we collect, record, organize, store and use it.
- In some cases, the processing of your data is based on legal requirements and is mandatory, in such cases we specifically draw your attention to this fact.
- In some cases, our company or a third party has a legitimate interest in the processing of your personal data, for example the operation, development and security of our website.
2. Who are we?
Entrepreneur / Company name / Owner name: Probitas Hungaria Ltd.
Head office: Szolnok, Lechner Ödön utca 3., 5008
Website: https://probitas.originalhoneys.com
Postal address: Szolnok, Lechner Ödön utca 3., 5008
E-mail address: probitashungaria@gmail.com
Tax number: 238292779-2-16
Company registration number: 16-09-014008
Our company is not obliged to appoint a data protection officer under Article 37 of the GDPR
Our company’s hosting provider:
| Hosting provider name | Sybell Informatika Kft. |
| Hosting provider registered office | Budapest, Késmárk u 7/b, 1158 |
| Hosting provider website | https://sybell.hu/ |
| Hosting provider email address | hello@sybell.hu |
Our company uses the following data processors when processing data – in order to provide high-quality service to our customers:
| Data controller | Address | Responsibilities |
| Probitas Hungaria Ltd. | Szolnok, Lechner Ödön utca 3., 5008 | All activities |
If we modify the scope of our data processors, we will introduce the changes in this information.
The data we process:
| Name of activity and purpose of data processing | Legal basis | Data processed | Duration |
| Website visit Purpose To ensure the proper and high-quality operation of the website, to monitor and improve the quality of our services, to identify malicious visitors attacking our website, to measure traffic, statistical purposes IP address. | Our company’s legitimate interest | Time of visit Data on the subpages visited, type of operating system and browser used by you | 1 month |
| Website registration Purpose To provide our visitors with a more complete user experience Notification of outages, changes to our company’s contact information, etc. | consent | surname, first name date of birth (to prove that you are 16 or 18 years old) | e-mail address until the registration is cancelled or the consent is withdrawn. |
| Newsletter service Purpose: keeping in touch, we will inform you about new promotions and new products | consent | full name, date of birth (to prove that you are 16 or 18 years old) e-mail address other optional data, e.g. interests, place of residence, etc. | until you unsubscribe from the newsletter |
| Direct marketing service based on the analysis of your shopping habits, we prepare and send personalized offers, we contact you for business purposes, we send information about the products and services we sell. | consent | full name, date of birth (to prove that you are 16 or 18 years old) e-mail address, phone number (optional) other optional data, e.g. interests, place of residence, etc. | until unsubscribe from direct marketing services |
| Administration, complaint, comment, response to complaint | legal obligation | full namee-mail addresstelephone numbermailing addressother personal message for | 5 years |
We only ask our website visitors for their personal data if they wish to register, log in or participate in a prize draw.
We cannot link the personal data provided in connection with registration or the use of our marketing services and it is not our goal to identify our visitors.
If you have any questions about data management, you can request further information by email or postal address at probitashungaria@gmail.com. We will send you our response within 15 days (but no later than 1 month) to the contact information you provided.
What are cookies and how do we manage them?
Cookies are small data files (hereinafter: cookies) that are transferred to your computer through the website when you use the website, and are saved and stored by your internet browser. Most of the most commonly used internet browsers (Chrome, Firefox, etc.) accept and allow the downloading and use of cookies as a default setting, but it is up to you to refuse or block them by modifying your browser settings, or you can delete cookies already stored on your computer. The “help” menu of each browser provides more information about the use of cookies.
There are cookies that do not require your prior consent. Our website provides brief information about these at the beginning of your first visit, such as authentication, multimedia player, load balancer, session cookies that help customize the user interface, and user-centric security cookies.
Our Company will inform you about cookies that require consent – if data processing begins when you visit the site – at the beginning of your first visit and ask for your consent.
Our company does not use or allow cookies that allow third parties to collect data without your consent.
Accepting cookies is not mandatory, but our company is not responsible if our website does not function as expected if cookies are not allowed.
What cookies do we use?
| Name | Service Provider | Purpose | Expiration |
| wpEmojiSettingsSupports | probitas.originalhoneys.com/ | WordPress sets this cookie when a user interacts with emojis on a WordPress site. It helps determine if the user’s browser can display emojis properly. | session |
| cookieyes-consent | probitas.originalhoneys.com/ | CookieYes sets this cookie to remember users’ consent preferences so that their preferences are respected on subsequent visits to this site. It does not collect or store any personal information about the site visitors. | 1 year |
| _ga_* | probitas.originalhoneys.com/ | Google Analytics sets this cookie to store and count page views. | 1 year 1 month 4 days |
| _ga | probitas.originalhoneys.com/ | Google Analytics sets this cookie to calculate visitor, session and campaign data and track site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognise unique visitors. | 1 year 1 month 4 days |
You can read more about third-party cookies here https://www.google.com/policies/technologies/types/, and about data protection here https://www.google.com/analytics/learn/privacy.html?hl=hu
3. What else should you know about our data management on our website
You voluntarily provide us with personal data during registration or when contacting our Company, which is why we ask that you gradually pay attention to the truthfulness, correctness and accuracy of your data when providing it, because you are responsible for these. Incorrect, inaccurate or incomplete data may prevent you from using our services.
If you provide personal data of another person other than yourself, we assume that you have the necessary authorization to do so.
You may withdraw your consent to data processing at any time free of charge
- by cancelling your registration,
- by withdrawing your consent to data processing, or
- by withdrawing or requesting the blocking of any data that must be filled in during registration.
We undertake to register the withdrawal of consent within a 30-day period for technical reasons, however, we draw your attention to the fact that we may process certain data even after the withdrawal of consent in order to fulfill our legal obligation or to assert our legitimate interests.
In the event of the use of misleading personal data, or if one of our visitors commits a crime or attacks our Company’s system, we will immediately delete the data of the given visitor at the same time as terminating their registration, or – if necessary – we will retain them for the duration of establishing civil liability or conducting criminal proceedings.
4. What should you know about our data processing for direct marketing and newsletter purposes?
You can give your consent to us using your personal data for marketing purposes by making a statement during registration or later, by modifying your personal data stored on the newsletter and/or direct marketing registration interface (i.e. by clearly stating your intention to consent). In this case – until the consent is withdrawn – we will also process your data for the purpose of sending direct marketing and/or newsletters and will send you advertising and other mailings, as well as information and offers and/or newsletters (Grtv. § 6).
You can give your consent for direct marketing and newsletters together or separately and you can withdraw it/them free of charge and at any time.
In all cases, we consider the cancellation of the registration as a withdrawal of consent. We do not interpret the withdrawal of consent for data processing for direct marketing and/or newsletter purposes as a withdrawal of data processing consent related to our website. How is this? What and on what basis do we retain if the newsletter consent has been withdrawn? In the case of consents, each consent is for a specific purpose, so registering tomorrow and subscribing to the newsletter are two separate purposes, two separate databases, and the two cannot be related.
We undertake to register the withdrawal or cancellation of individual consents – for technical reasons – with a 15-day deadline.
5. What do you need to know about prize games?
Our company may organize prize games as a campaign, the individual conditions of which are contained in a separate regulation. The regulations of the current campaign can always be found on the opening page of our website, in a link placed centrally.
6. Other data processing issues
We may only transfer your data within the framework specified by law, and in the case of our data processors, we ensure by stipulating contractual conditions that they cannot use your personal data for purposes contrary to your consent. Further information can be found in point 2.
Our company does not transfer data abroad.
The court, the prosecutor’s office and other authorities (e.g. the police, the tax office, the National Data Protection and Freedom of Information Authority) may contact our Company to provide information, disclose data or make documents available. In these cases, we must fulfill our data provision obligation, but only to the extent necessary to achieve the purpose of the request.
Our Company’s collaborators and employees involved in data management and/or data processing are entitled to access your personal data to a predetermined extent – subject to a confidentiality obligation.
We protect your personal data with appropriate technical and other measures and ensure the security and availability of the data, and we protect them from unauthorized access, alteration, damage or disclosure and any other unauthorized use.
As part of organizational measures, we control physical access in our buildings, continuously train our employees and keep paper-based documents locked away with appropriate protection. As part of the technical measures, we use encryption, password protection and anti-virus software. However, we would like to point out that data transmission via the Internet cannot be considered as completely secure. Our company does everything possible to make the processes as secure as possible, but we cannot assume full responsibility for data transmission via our website, but we adhere to strict regulations regarding the data received by our company in order to ensure the security of your data and prevent unlawful access.
Regarding security issues, we ask for your help in carefully keeping your access password to our website and not sharing this password with anyone.
8. What are your rights and remedies?
You may
- request information about data processing,
- request the correction, modification, or completion of your personal data processed by us,
- object to data processing and request the deletion or blocking of your data (except for mandatory data processing),
- take legal action before a court,
- file a complaint with the supervisory authority or initiate proceedings (https://naih.hu/panaszuegyintezes-rendje.html)
Supervisory Authority: National Data Protection and Freedom of Information Authority
Registered at: 1125 Budapest, Szilágyi Erzsébet fasor 22/c.
Mailing address: 1530 Budapest, Pf.: 5.
Telephone: +36 (1) 391-1400
Fax: +36 (1) 391-1410
E-mail: ugyfelszolgalat@naih.hu
Website: https://naih.hu/
At your request, we will provide you with information about the data we process or that we – or our commissioned data processor – process
- their source,
- the purpose and legal basis of the data processing,
- its duration, and if this is not possible, the criteria for determining this duration,
- the name, address of our data processors and their activities related to data processing,
- the circumstances and effects of data protection incidents and the measures we have taken to prevent and combat them, and
- in the event of the transfer of your personal data, the legal basis and recipient of the data transfer.
We will provide you with our information within 15 days (but no later than 1 month) of the date of submission of the request. The information is free of charge, unless you have already submitted a request for information to us regarding the same data set in the current year. We will refund the costs you have already paid if the data has been processed unlawfully or the request for information has led to a correction. We may refuse to provide information only in cases provided for by law, indicating the legal place and informing you about the possibility of legal redress in court or contacting the Authority.
Our company will notify you and all those to whom the data has previously been forwarded for data processing purposes about the correction, blocking, marking and deletion of personal data, unless the failure to notify does not violate your legitimate interests.
If we do not comply with your request for rectification, blocking or erasure, we will inform you of the reasons for our refusal in writing or, with your consent, electronically within 15 days (but no later than 1 month) of receipt of the request and inform you of the possibility of legal remedy and of contacting the Authority.
If you object to the processing of your personal data, we will examine the objection within 15 days (but no later than 1 month) of submitting the request and inform you of our decision in writing. If we have decided that your objection is well-founded, we will terminate the data processing – including further data collection and data transfer – and block the data, and we will notify all those to whom we have previously transmitted the personal data affected by the objection and who are obliged to take measures to enforce the right to object of the objection.
We will refuse to comply with your request if we can demonstrate that the processing is justified by compelling legitimate grounds which override your interests, rights and freedoms or which are related to the establishment, exercise or defence of legal claims. If you disagree with our decision or if we miss the deadline, you may apply to the court within 30 days of the notification of the decision or the last day of the deadline.
The adjudication of data protection lawsuits falls within the jurisdiction of the court, and the lawsuit may also be initiated – at the choice of the data subject – before the court of the data subject’s place of residence or stay. Foreign citizens may also file a complaint with the supervisory authority competent for their place of residence.
We kindly ask you to contact our Company before filing a complaint with the supervisory authority or court – in order to discuss and resolve the problem as quickly as possible.
9. What are the main laws governing our activities?
- Regulation (EU) 2016/679 of the European Parliament and of the Council on the processing of personal data of natural persons (GDPR)
- Act CXII of 2011 on the right to information self-determination and freedom of information – (Info tv.)
- Act V of 2013 on the Civil Code (Ptk.)
- Act CVIII of 2001 on certain issues of electronic commerce services and services related to the information society – (Eker tv.)
- Act C of 2003 on electronic communications – (Ehtv)
- Act CLV of 1997 on consumer protection (Fogyv tv.)
- Act CLXV of 2013 on complaints and public interest notifications. (Pktv.)
- Act XLVIII of 2008 on the basic conditions and certain limitations of commercial advertising activities (Grtv.)
10. Amendment of the Data Management Information
Our company reserves the right to amend this Data Management Information, of which it will inform the data subjects in an appropriate manner. Information related to data management is published on the: https://probitas.originalhoneys.com website.