Privacy policy

Privacy Notice for Data Processing Taking Place on the Platform www.puresound.com of Pure Sound Media Ltd.

This notice lays down the data processing and data protection principles of Pure Sound Media Ltd. in accordance with the provisions of the GDPR which came into force on 27th August 2019.

1. CONTACT DETAILS OF THE CONTROLLER;

Name: Pure Sound Média Ltd.

Registered address: 2030 Érd Kutyavári utca 29.

Email: info@puresound.hu

Phone: +36 70 225-5300

Company registration number: 13-09-182948

VAT registration number: 25752979-2-13

2. INTRODUCTION:

• The Pure Sound Media Ltd. (2030 Érd Kutyavári utca 29, hereinafter referred to as service provider or controller) as controller considers itself to be bound by the provisions of this legal notice. It undertakes to ensure that all data processing in connection with its activities complies with the provisions of this policy and any applicable law.

• The data protection principles behind the data processing for the services provided by the Pure Sound Media Ltd. at the website https://www.puresound.hu are constantly available at https://www.puresound.hu/adatvedelmi_nyilatkozat/.

• The Pure Sound Media Ltd. reserves the right to change this notice at any time. Obviously, it will notify its audience about any changes in timely manner. In case a user has a question that cannot be answered clearly with the help of this notice, they should write to us and one of our colleagues will answer the question.

• The Pure Sound Media Ltd. is committed to protect the personal data of its users and partners; respecting of its customers’ right of informational self-determination is of paramount importance to it. Therefore, the Pure Sound Media Ltd. treats personal data as confidential and adopts all necessary security, technical, and organisational measures to guarantee the security of the data.

3. THE PURPOSES OF AND THE LEGAL BASIS FOR THE DATA PROCESSING

REGISTRATION

The fact and scope of data collection, and the purpose of data processing:

Personal data / The purpose of data processing
Username Identification, / to enable the registration.
Password / It serves to secure the access to the user account.
Name and surname / It is necessary for making contact, shopping, and issuing a valid invoice.
Email address / Maintaining contact.
Phone number / Maintaining contact, more efficient negotiations on questions concerning invoicing.
Billing name and address / Issuing a valid invoice as well as drawing up a contract; defining and changing its contents; monitoring its fulfilment; invoicing the fees based on the contract; and enforcing contractual claims.
Date of purchase/registration / Performing technical actions.
IP address at the time of purchase/registration / Performing technical actions.

Either the username or the email address does not need to contain personal data.
Data subjects: All registered users/customers at the website of the web shop are data subjects.
The period of data processing, the deadline for erasure of data: Upon cancelling the registration immediately. Except for accounting documents; since, according to Article 169(2) of Act C/2000 on accounting, these data must be stored for a period of 8 years.

The legal basis for the data processing:

The consent of the data subject – Article (6)(1)(a) of the GDPR –; Article 5(1) of the Act CII/2011 on the right of informational self-determination and the freedom of information (hereinafter referred to as “Infotv.”), and Article 13/A(3) of Act CVIII/2001 on certain aspects of information society services (hereinafter referred to as “Elker tv.”).
In case of issuing an invoice according to the relevant laws on accounting, Article 6(1)(c) of the GDPR.

We inform you that data processing is based on your consent. You are obliged to provide personal data so that we can fulfil your order. The consequence of failure to provide such data is that we will not able to process your order. The user can give their consent by intentionally placing a tick in the relevant – empty by default – checkbox on the website.

PLACING AN ORDER

The purpose of data processing: Recording and fulfilment of orders submitted through the website; delivery of the ordered products; maintaining contact with respect to the orders; issuing invoices; fulfilment of accounting obligations. Your order can only be fulfilled, if you provide us with your contact and billing information, which is absolutely necessary for maintaining contact and invoicing.
The legal basis for the data processing: Your consent. In case of invoicing, data processing is based on statutory provisions.
Data subjects: the registered users of the website.
The period of data processing: The data processing takes place until the statutory provisions or the consent are withdrawn. You can withdraw your consent to data processing any time by sending a mail to the email address for maintaining contact.
The erasure of data: It takes place upon withdrawing the consent to data processing. You can withdraw your consent to data processing any time by sending a mail to the email address for maintaining contact. The erasure of billing data takes place according to statutory provisions.
Subjects with access to the data the controller and its employees
The method of storing data: by electronic means.

The scope of processed data: / The purpose of data processing

Name / Identification, maintaining contact, and invoicing
Company name / Identification, maintaining contact, and invoicing
Name and surname / It is necessary for making contact, shopping, and issuing a valid invoice.
Address / Maintaining contact, more efficient negotiations on questions concerning invoicing.
Email address / Maintaining contact.
Phone number / Maintaining contact, more efficient negotiations on questions concerning invoicing.
Billing name and address / Issuing a valid invoice as well as drawing up a contract; defining and changing its contents; monitoring its fulfilment; invoicing the fees based on the contract; and enforcing contractual claims.
Data of product ordered / Identification of the product.
Date of purchase/registration / Performing technical actions.
IP address at the time of purchase/registration / Performing technical actions.

The user can give their consent by intentionally placing a tick in the relevant – empty by default – checkbox on the website.

The data subject can object to the processing of their personal data; in which case, they have the right for a procedure according to the above-mentioned data procession information and this notice as well as the laws described in this notice.

INVOICING

Purpose of data processing: issuing an electronic invoice and sending it as an email attachment.
The legal basis for the data processing: mandatory data processing based on statutory provisions.
Data subjects: customers of the service provider.
The period of data processing: The data processing takes place until the statutory provisions or the consent are withdrawn. You can withdraw your consent to data processing any time by sending a mail to the email address for maintaining contact.
The erasure of data: It takes place upon withdrawing the consent to data processing. You can withdraw your consent to data processing any time by sending a mail to the email address for maintaining contact. The erasure of billing data takes place according to statutory provisions.
Subjects with access to the data: the controller, its employees, and its accountant.
The method of storing data: by electronic means.

The scope of processed data / The purpose of data processing

Name / Identification, maintaining contact, and invoicing
Company name / Identification, maintaining contact, and invoicing
Name and surname / It is necessary for making contact, shopping, and issuing a valid invoice.
Email address / Maintaining contact.
Phone number / Maintaining contact, more efficient negotiations on questions concerning invoicing.
Billing name and address / Issuing a valid invoice as well as drawing up a contract; defining and changing its contents; monitoring its fulfilment; invoicing the fees based on the contract; and enforcing contractual claims.
Data of product ordered / Identification of the product.
VAT registration number / Identification of the customer
Billing information / Identification of the invoice
Date of invoice / Performing technical actions.

The user can give their consent by intentionally placing a tick in the relevant – empty by default – checkbox on the website.

NEWSLETTER AND DIRECT MARKETING ACTIVITIES

According to article 6(5) of Act XLVIII/2008 on the basic requirements and certain restrictions of commercial advertising, users may give their express consent in advance to being sent promotional offers and other deliveries by the service provider via the contact address provided upon registration.

Furthermore, customers, bearing in mind the provisions in this notice, may give their consent to the processing of their personal data by the service provider for the purpose of sending promotional offers.

The service provider does not send unsolicited promotional messages, and users can opt-out free of charge, without justification and limitation from being sent offers. In such cases, the service provider deletes all their personal data – which are necessary for sending promotional messages – from its records and will refrain from sending promotional offers to the users. Users can opt-out from being sent advertisements by clicking on the link in the message.

The fact and scope of data collection, and the purpose of data processing:

Personal data / The purpose of data processing

Name, email address. / Identification, to enable users to subscribe to the newsletter.
Date of subscription / Performing technical actions.
IP address at the time of subscription / Performing technical actions.

Data subjects: All subscribers to the newsletter are data subjects.
The purpose of data processing: Sending electronic messages (emails, text messages, push notifications) containing advertisements to the data subjects; providing information on news, products, promotions, new features, etc.
The period of data processing, the deadline for erasure of data: The data processing takes place until the consent is withdrawn, i.e. until unsubscribing.
Possible processors with access to the data, recipients of the personal data: The personal data can be processed by the sales and marketing staff of the controller in accordance with the above-mentioned principles.
Data subject can unsubscribe from the newsletter any time for free.
The legal basis for the data processing: The consent of the data subject – Article (6)(1)(a) of the GDPR –; Article 5(1) of Infotv.; and Article 6(5) of Act XLVIII/2008 on the basic requirements and certain restrictions of commercial advertising.

We inform you that data processing is based on your consent. You are obliged to provide personal data, if you want to receive our newsletter. The consequence of failure to provide such data is that we will not able to send you our newsletter.

PROCESSORS USED:

Online Payment

Activities carried out by the processor: Online Payment
Name and contact address of the processor: Kereskedelmi és Hitelbank Zrt.
The fact and scope of data collection: Billing name, billing address, email address.
Data subjects: All data subjects who want to pay online.
The purpose of data processing: Processing of online payment, confirmation of transactions, and monitoring fraud to protect the users. Issuing an electronic invoice and sending it as an email attachment.
The period of data processing, the deadline for erasure of data: The data processing takes place until the statutory provisions or the consent are withdrawn. You can withdraw your consent to data processing any time by sending a mail to the email address for maintaining contact.
The legal basis for the data processing: The consent of the data subject – Article (6)(1)(a) of the GDPR –, Article 5(1) of Infotv., and Article 13/A(3) of Act CVIII/2001 on certain aspects of information society services.
The erasure of data: It takes place upon withdrawing the consent to data processing. You can withdraw your consent to data processing any time by sending a mail to the email address for maintaining contact. The erasure of billing data takes place according to statutory provisions.
Subjects with access to the data: the processor, the controller and its employees.
The method of storing data: by electronic means.

Name of the processor:

OTP Mobil Szolgáltató Ltd.
Activity: Payment service “Simple”
Registered address: 1143 Budapest, Hungária körút 17-19.
Company registration number: 01-09-174466
VAT registration number: 24386106-2-43
Phone: 06-1-366-66-11
Email: ugyfelszolgalat@simple.hu
Website: https://www.simplepay.hu

Bookkeeping tasks, invoicing

Activities carried out by the processor: Entering the invoices issued via online payment into the books.
Name and contact address of the processor: Helga Gévay, individual entrepreneur, registered address:
The fact and scope of data collection: Billing name, billing address
Data subjects: All data subjects who submit an order on the website.
The purpose of data processing: Issuing electronic invoices / bookkeeping task
The period of data processing, the deadline for erasure of data: According to Article 169(2) of Act C/2000 on accounting, 8 years.
The legal basis for the data processing: The consent of the user, Article (6)(1)(c) of the GDPR, and Article 13/A(3) of Act CVIII/2001 on certain aspects of e-commerce services as well as information society services.
Subjects with access to the data: the processor, the controller and its employees.
The method of storing data: by electronic means.

HANDLING OF COOKIES

Cookies typical for online shops; so-called “password-protected session cookies”, “cookies necessary for shopping cart”, and “safety cookies” for the use of which it is not necessary to ask for the consent of data subjects in advance. Cookies are placed by the websites visited on the computers of the users and contain such information as the settings of the website or the login status. Thus, cookies are small files created by websites visited. By saving the browsing data, they improve the user experience. With the help of cookies, the website remembers your preferences and offers a locally relevant content. The website of the service provider sends a small file (cookie) to the computers of the visitors of the website in order to establish the fact and date of the visit. The visitors of the website are informed of this fact by the service provider.

The fact and scope of data processing: Unique identification numbers, dates, times
Data subjects: All data subjects who visit the website.
The purpose of data processing: Identification of users, recording the “shopping cart", and tracking of visitors.
The period of data processing, the deadline for erasure of data:
Cookie type: Session cookies
The legal basis for data processing: Article 13/A(3) of Act CVIII/2001 on certain aspects of e-commerce services as well as information society services (Elkertv.)
The period of data processing: Until the relevant session of the visitor is over
The scope of data processed: connect.sid
Possible processors with access to the data: By using cookies, the controller does not process any personal data.
Information on the rights of the data subject relating to data processing: Data subjects have the option to delete cookies in the menu Tools/Options of their browsers, usually in the menu Privacy Settings.
The legal basis for data processing: It is not necessary to seek the consent of data subjects, if the sole purpose of the use of cookies is to provide information via electronic communications networks, or if the service provider absolutely needs cookies in order to provide an information society service.
The method of storing data: by electronic means.

USING GOOGLE ADWORDS CONVERSION TRACKING

The controller uses the online advertising platform “Google AdWords” and within its limits, it also uses the conversion tracking feature of Google. Google Conversion Tracking is an analytics service provided by Google Inc. (1600 Amphitheater Parkway, Mountain View, CA 94043, USA; “Google”).

When users access a website via Google ads, a conversion tracking cookie is placed on their computers. These cookies have a limited validity and do not contain any personal data; so, the user cannot be identified based on the data stored in cookies.

When a user browses specific pages of the website and if the cookie has not expired yet, Google and the processor can see that the user clicked on the ad.

Each Google AdWords customer gets another cookie, so they cannot be tracked through the websites of the customers of Google AdWords.

The purpose of the information that is obtained by using conversion tracking cookies is to produce conversion statistics for those customers of Google AdWords who opt for conversion tracking. This is how customers obtain information on the number of customers who click on their ads and are directed to a website on which a conversion tracking tag is placed. They do not, however, obtain any information based on which any user could be identified.

If you want to opt out from conversion tracking, you can prevent the use of cookies by not permitting them in your browser. Upon doing so you will not be included in conversion tracking statistics.

For more information and Google’s Privacy Statement, see: https://policies.google.com/privacy

USING GOOGLE ANALYTICS

This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to enable an analysis of the use of the website visited by the user. The information generated by cookies on the usage of the website visited by the user is usually transferred to and saved on a server of Google in the USA. By activating IP anonymization on the website, within the member states of the European Union or other states which are parties to the Agreement on the European Economic Area, Google shortens the user's IP address.

Only in exceptional cases will the complete IP address be transmitted to and shortened on the server of Google in the USA. On behalf of the operator of this website, Google will use this information for the purpose of evaluating the use of the website by the user, compiling reports on website activity for the operator of the website, and providing other services relating to website activity and internet usage. Within the framework of Google Analytics, Google will never use the IP address transmitted by the user’s browser in connection with other data from Google. Users may prevent the installation of cookies by changing the relevant settings in their browser; however, we must point out that in this case, they may not be able to use all website functions to their fullest extent. They may also prevent Google from collecting and processing their data stored in cookies relating to the use of the website by the users (including IP addresses) by downloading and installing the plugin which is available at the following link: https://tools.google.com/dlpage/gaoptout?hl=hu

PRESENCE AND MARKETING ON SOCIAL NETWORKING SITES

The controller is present on the social networking site Facebook and on other social networking sites. The controller only communicates with the data subjects via the social networking site, if the data subjects contact the controller via the social networking site. The purpose of the presence on a social networking site, especially Facebook, and the data processing related to it is to share, publish, and marketing the contents of the website on the social networking site. With the help of the social networking site, the data subjects can also gain information about the latest promotions.

Personal data processed
a) public name of the data subject
b) public photo of the data subject
c) public email address of the data subject
d) messages sent by the data subject via social networking sites
e) ratings by the data subject, or the results of other actions

The purpose of data processing:
with respect to a)–b), identification
with respect to c)–d), maintaining contact, answering, marketing
with respect to e), improving quality, marketing

The legal basis for data processing:
voluntary consent (Article 6(1)(a) of GDPR)

Categories of data subjects:
all natural persons who registered on social networking sites such as Facebook/Google+/Twitter/Pinterest/YouTube/Instagram, etc. and “liked” these pages

Whether the controller transfers personal data to a third non-EU country:
no

Ensuring data security:
the controller stores all data on a computer protected by password

Processor who operates the server on behalf of the controller:
………………..

The prospected deadline for erasure of data:
the date for erasure as initiated by the data subject

By following or liking the contents of the controller, the data subjects – in accordance with the terms and conditions of the social networking site – voluntarily consent to processing their data. By way of example, for the newsfeed on the message board on our Facebook page, data subjects can subscribe by clicking on the link “like”. By doing so, they consent to publish the news and promotions of the controllers on their own message boards. By clicking on the same page on the link “dislike”, they can subscribe from the newsfeed. Furthermore, they can delete unwanted newsfeed published on the message board by changing the relevant settings for the message board.

Analytics, Facebook pixels

With the help of the tool Facebook pixels (formerly called “conversion tracking pixels”), the controller places a JavaScript code on its website which sends a message to Facebook, if the user visits the website or performs an action there. On the one hand, this helps to understand the return on the advertisement costs of the controller, and on the other hand, it makes easier for the controller to display its ads to users for whom a conversion outside Facebook is more likely. Facebook pixel does not collect, store, or transmit personal data. For more information about the use and functioning of Facebook pixels, see www.facebook.com.

Facebook remarketing

The controller places a code set on its website (or any subsites of that) to make the advertisements of the controller available to the users who visit the website while they are using Facebook. The Facebook remarketing code set does not collect, store, or transmit personal data. For more information about the use and functioning of the code set, see www.facebook.com.

Google AdWords remarketing

The controller places a code set on its website (or any subsites of that) to make the advertisements of the controller available to the users who visit the website while they are browsing the websites by Google Display Network, and/or are searching for a term related to the services provided by the controller in the system of Google. The code set does not collect, store, or transmit personal data. For more information about the use and functioning of the code set, see http://support.google.com. Thus, the controller does not use the analytical systems for collecting personal data.

Social Networking Sites

The fact and scope of data collection: Username and the user's public profile picture on social networking sites, such as Facebook/Google+/Twitter/Pinterest/YouTube/Instagram, etc.

Data subjects: All data subjects who registered on social networking sites such as Facebook/Google+/Twitter/Pinterest/YouTube/Instagram, etc. and “liked” the website.

The purpose of data collection: To share, “like”, or promote certain contents, products, and promotions of the website or the website itself on social networking sites.

The period of data processing, the deadline for erasure of data, possible processors with access to the data, and information on the rights of data subjects relating to data processing: Data subjects can obtain information on the source of the data, their processing, the method of transfer, and the legal basis for it on the relevant social networking site. Data processing is carried out on the social networking sites; hence, for the period of data processing, its method as well as the erasure and change of data, the regulations of the respective social networking site applies.

The legal basis for data processing: the voluntary consent of the data subjects to processing their data on the social networking sites.

COMPLAINT HANDLING

The fact and scope of data collection, and the purpose of data processing:

Personal data / The purpose of data processing
Name and surname / Identification, maintaining contact.
Email address / Maintaining contact.
Phone number / Maintaining contact.
Billing name and address / Identification, handling quality problems with the products ordered, questions, and concerns.

Data subjects: All data subjects who make a purchase on the website of the web shop and have concerns regarding quality or make a complaint.

The period of data processing, the deadline for erasure of data: In accordance with Article 17/A(7) of Act CLV/1997 on consumer protection, the minutes and the transcript of the complaint as well as the copies of the reply to the complaint must be stored for a period of 5 years.

Possible processors with access to the data, recipients of the personal data: The personal data can be processed by the sales and marketing staff of the controller in accordance with the above-mentioned principles.

Information on the rights of the data subject relating to data processing:

Data subjects have the right to request from the controller access to and rectification, erasure or restriction of processing of personal data concerning the data subject, and
to object to processing of such personal.
Furthermore, they have the right to data portability and to withdraw their consent at any time.

The legal basis for the data processing: the consent of the data subject, Article (6)(1)(a) of the GDPR, Article 5(1) of Infotv., and Article 17/A(7) of Act CLV/1997 on consumer protection.

Please note that the provision of personal data is a contractual requirement, the processing of personal data is a requirement necessary to enter a contract. You are obliged to provide your personal data so that we can handle your complaint. The possible consequence of failure to provide such data is that we will not be able to handle the complaint we received from you.

4. THE RIGHTS OF DATA SUBJECTS

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

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.

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 shall have the obligation to erase personal data without undue delay where one of the grounds listed in GDPR applies.

Right to be forgotten
Where the controller has made the personal data public and is obliged pursuant to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

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

the accuracy of the personal data is contested by you, 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 personal data and request the restriction of their use instead;
the controller no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
you have objected to processing pending the verification whether the legitimate grounds of the controller override those of yours.

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 have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided.

Right to object
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you by the Pure Sound Media Ltd., including profiling based on the above-mentioned provisions.

Objecting against direct marketing
Where personal data are processed for direct marketing purposes, you have the right to object at any time to 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.

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 preceding paragraph shall 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.

5. LODGING A COMPLAINT

If a data subject considers that while processing his or her personal data, the controller has violated the applicable data protection requirements, he or she may lodge a complaint against any possible infringement committed by the controller. According to Article 55(2) of GDPR, each supervisory authority shall be competent to handle a complaint lodged with it or a possible infringement of this Regulation, if the subject matter relates only to an establishment in its Member State or substantially affects data subjects only in its Member State.

Or you may seek a judicial remedy to protect your personal data, in which case proceedings will take place without delay. In this case you are free to decide which court you want to lodge your complaint with: the court which has jurisdiction over your domicile (permanent residence), your place of residence (temporary residence), or where the authority is established. For the court which has jurisdiction over your domicile or place of residence, see: http://birosag.hu/ugyfelkapcsolatiportal/birosag-kereso page.

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