In accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council (April 27, 2016) on the protection of natural persons regarding the processing of personal data and the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation – GDPR), we provide the following information.

This data management statement regulates the processing of data on the following website: www.bxdesign.eu

Modifications to the statement come into effect upon publication at the above address.

Data Controller and Contact Information

• Name: Brigitta Könczöl
• Registered Address: Hungary, 8600 Siófok, Damjanich street 3.
• Email: brigitta.konczol@gmail.com, info@bxdesign.eu
• Phone: +36 30 488 54 21

Definitions

• “Personal Data”: Any information relating to an identified or identifiable natural person (“Data Subject”). A person is considered identifiable if they can be directly or indirectly identified, particularly by reference to an identifier such as a name, number, location data, online identifier, or factors specific to their physical, physiological, genetic, mental, economic, cultural, or social identity.

• “Data Processing”: Any operation or set of operations performed on personal data or sets of personal data, whether automated or not, including collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.

• “Data Controller”: A natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data. If the purposes and means of data processing are determined by Union or Member State law, the Data Controller or the criteria for its designation may also be specified by Union or Member State law.

• “Data Processor”: A natural or legal person, public authority, agency, or other body that processes personal data on behalf of the Data Controller.

• “Recipient”: A natural or legal person, public authority, agency, or other body to whom or which personal data is disclosed, whether or not a third party. Public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law are not considered recipients. The processing of such data by these public authorities must comply with the applicable data protection rules.

• “Consent of the Data Subject”: Any freely given, specific, informed, and unambiguous indication of the Data Subject’s wishes, by which they, through a statement or a clear affirmative action, signify agreement to the processing of their personal data.

• “Data Breach”: A security breach that results in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to personal data that has been transmitted, stored, or otherwise processed.

Principles of Personal Data Processing

Personal data must be:

1. Processed lawfully, fairly, and transparently in relation to the Data Subject (“lawfulness, fairness, and transparency”).
2. Collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes is not considered incompatible with the initial purposes in accordance with Article 89(1) (“purpose limitation”).
3. Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed (“data minimization”).
4. Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that inaccurate personal data, in relation to the purposes for which they are processed, are erased or rectified without delay (“accuracy”).
5. Stored 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. Longer storage is allowed only if processing is for public interest archiving, scientific or historical research purposes, or statistical purposes, in accordance with Article 89(1), subject to the implementation of appropriate technical and organizational measures to safeguard the rights and freedoms of the Data Subject (“storage limitation”).
6. Processed in a manner that ensures appropriate security of 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”).

The Data Controller is responsible for compliance with these principles and must be able to demonstrate such compliance (“accountability”).

Data Processing Activities

Messaging and Contacting

1. Types of collected data and purposes of data processing:

2. Data Subjects: Any individual who sends a message via the website.

3. Duration of data processing and deletion deadline: Data processing continues until the matter is resolved.

4. Potential Data Processors authorized to access the data: The personal data is processed by the Data Controller while respecting the aforementioned principles.

5. Rights of the Data Subjects regarding data processing:

The Data Subject may request from the Data Controller:

• Access to their personal data
• Rectification of inaccurate data
• Erasure of data
• Restriction of data processing

Newsletter, Direct Marketing Activities

1. Pursuant to Section 6 of Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Economic Advertising Activities, the User may give prior and explicit consent for the Service Provider to contact them with advertising offers and other messages at the contact details provided during registration.

2. Furthermore, the Customer may consent, in consideration of the provisions of this notice, to the processing of their personal data necessary for sending advertising offers by the Service Provider.

3. The Service Provider does not send unsolicited advertising messages, and the User may unsubscribe from receiving offers at any time, without restriction, justification, and free of charge. In such cases, the Service Provider will delete all personal data necessary for sending advertising messages from its records and will no longer contact the User with advertising offers. The User can unsubscribe by clicking the link in the message.

4. The facts of data collection, the scope of processed data, and the purpose of data processing:

5. Scope of affected individuals: All individuals who subscribe to the newsletter.

6. Purpose of data processing: Sending electronic messages containing advertisements (email, push notifications) to the affected individual, providing information on current news, products, promotions, new features, etc.

7. Duration of data processing and deadline for data deletion: Data processing lasts until the withdrawal of the consent statement, i.e., until unsubscription.

8. Data processing registration number: The data protection registry maintained by the National Authority for Data Protection and Freedom of Information (as of May 25, 2018), as well as the obligation of data controllers to notify the Authority, has been discontinued.

9. Authorized data processors and recipients of personal data: Personal data may be processed by the sales and marketing employees of the data controller while respecting the above principles.

10. Explanation of the rights of affected individuals regarding data processing:

• The affected individual may request access to, correction, deletion, or restriction of processing of their personal data from the data controller,

• They may object to the processing of such personal data,

• They have the right to data portability and to withdraw their consent at any time.

11. The affected individual may initiate access to, deletion, modification, or restriction of processing of their personal data, as well as data portability and objections to data processing, through the following means:

• By mail: Hungary, 8600 Siófok, Damjanich street 3.

• By email: brigitta.konczol@gmail.com, info@bxdesign.eu

• By phone: +36 30 488 54 21

12. The affected individual may unsubscribe from the newsletter at any time, free of charge.

13. Data processor used by the data controller:

• MailChimp

• The Rocket Science Group, LLC

• 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA

14. Legal basis for data processing: The affected individual’s consent, Article 6(1)(a) of the GDPR, Section 5(1) of the Infotv., and Section 6(5) of Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Economic Advertising Activities:

• The advertiser, advertising service provider, or publisher of the advertisement shall maintain records of the personal data of individuals who have given consent within the scope of the consent provided. The data recorded in this registry related to the recipient of the advertisement may only be processed as specified in the consent statement and until its withdrawal. Such data may only be disclosed to third parties with the prior consent of the affected individual.

15. Information:

• Data processing is based on your consent.

• You are required to provide personal data if you wish to receive newsletters from us.

• Failure to provide data will result in us being unable to send you newsletters.

Social Media Pages

1. Facts of data collection and the scope of processed data: The registered name on social media sites such as Facebook, Google+, Twitter, Pinterest, YouTube, Instagram, etc., and the user’s public profile picture.

2. Scope of affected individuals: All individuals who are registered on social media platforms (Facebook, Google+, Twitter, Pinterest, YouTube, Instagram, etc.) and have “liked” the website.

3. Purpose of data collection: Sharing and “liking” certain content elements, products, promotions, or the website itself on social media platforms to increase visibility.

4. Duration of data processing, deadline for data deletion, authorized data processors, and explanation of rights regarding data processing: The affected individual can learn about the source of data, processing methods, transfer, and legal basis on the respective social media platform. Data processing takes place on social media sites, thus, the regulations of the respective platform apply regarding the duration, processing methods, and options for data deletion or modification.

5. Legal basis for data processing: The affected individual’s voluntary consent to the processing of their personal data on social media platforms.

Customer Relations and Other Data Processing

1. If any questions arise during the use of the data controller’s services or if the affected individual encounters any issues, they can contact the data controller through the provided contact options (phone, email, social media, etc.).

2. The data controller deletes emails, messages, and data provided via phone, Facebook, etc., including the inquirer’s name and email address, as well as any voluntarily provided personal data, no later than two years after the data submission.

3. For data processing activities not listed in this notice, information will be provided at the time of data collection.

4. In exceptional cases, upon a request by authorities or based on statutory authorization, the Service Provider is obligated to provide information, disclose data, or make documents available.

5. In such cases, the Service Provider shall only disclose personal data to the requesting party to the extent strictly necessary to fulfill the request, provided the request specifies the exact purpose and scope of the requested data.

Client Relations and Other Data Processing

1. If any questions arise or if the data subject encounters any issues while using our services, they may contact the data controller through the means provided on the website (phone, email, social media, etc.).

2. The data controller will delete received emails, messages, and any data provided via phone, Facebook, etc., along with the enquirer’s name, email address, and any other voluntarily provided personal data, no later than two years from the date of data disclosure.

3. Data processing activities not listed in this notice will be disclosed at the time of data collection.

4. In exceptional cases, the service provider is obligated to provide information, disclose, transfer, or make documents available upon official request from authorities or other entities authorized by law.

5. In such cases, the service provider will only disclose personal data to the requesting party to the extent and in the manner strictly necessary to achieve the purpose of the request, provided that the exact purpose and scope of the data have been specified.

Rights of Data Subjects

Right of Access

You have the right to receive confirmation from the data controller as to whether your personal data is being processed. If such processing is taking place, you are entitled to access your personal data and the information specified in the regulation.

Right to Rectification

You have the right to request that the data controller correct any inaccurate personal data concerning you without undue delay. Taking into account the purposes of data processing, you are also entitled to request the completion of incomplete personal data, including by means of a supplementary statement.

Right to Erasure

You have the right to request the data controller to delete your personal data without undue delay, and the data controller is obligated to erase such data without undue delay under certain conditions.

Right to Be Forgotten

If the data controller has made personal data public and is obliged to delete it, they will take reasonable steps—taking into account available technology and the cost of implementation—to inform other data controllers processing the data that you have requested the deletion of links, copies, or duplicates of the personal data.

Right to Restriction of Processing

You have the right to request that the data controller restrict the processing of your data if any of the following conditions apply:

• You contest the accuracy of your personal data. In this case, the restriction applies for a period that allows the data controller to verify the accuracy of the personal data;

• The processing is unlawful, and you oppose the deletion of the data and instead request the restriction of its use;

• The data controller no longer needs the personal data for processing purposes, but you require them for the establishment, exercise, or defense of legal claims;

• You have objected to processing; in this case, the restriction applies until it is determined whether the data controller’s legitimate grounds override yours.

Right to Data Portability

You have the right to receive personal data concerning you, which you have provided to a data controller, in a structured, commonly used, and machine-readable format, and you have the right to transmit those data to another data controller without hindrance from the original data controller.

Right to Object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data, including profiling based on these provisions.

Right to Object to Direct Marketing

If personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing, including profiling related to direct marketing. If you object, your personal data can no longer be processed for this purpose.

Automated Individual Decision-Making, Including Profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you.

This does not apply if the decision:

• Is necessary for entering into or performing a contract between you and the data controller;

• Is authorized by Union or Member State law applicable to the data controller and which also lays down suitable measures to protect your rights and freedoms and legitimate interests;

• Is based on your explicit consent.

Response Timeframe

The data controller will inform you without undue delay and in any event within one month of receiving your request about any actions taken in response.

If necessary, this period may be extended by two months. In such a case, the data controller will inform you of the extension and the reasons for the delay within one month of receiving the request.

If the data controller does not take action on your request, they will inform you without delay and at the latest within one month of receipt of your request of the reasons for not taking action, as well as your right to lodge a complaint with a supervisory authority and seek judicial remedy.

Data Security

The data controller and processor will implement appropriate technical and organizational measures, considering the state of the art, implementation costs, nature, scope, context, and purposes of processing, as well as the varying likelihood and severity of risks posed to the rights and freedoms of natural persons. These measures include, where appropriate:

• The pseudonymization and encryption of personal data;

• Ensuring the ongoing confidentiality, integrity, availability, and resilience of processing systems and services;

• The ability to restore availability and access to personal data in a timely manner in the event of a physical or technical incident;

• Regular testing, assessing, and evaluating the effectiveness of technical and organizational measures to ensure data processing security.

Notification of the Data Subject Regarding a Data Protection Incident

If a data protection incident is likely to result in a high risk to the rights and freedoms of natural persons, the data controller shall inform the data subject about the incident without undue delay.

The notification provided to the data subject must clearly and comprehensibly describe the nature of the data protection incident, and include the name and contact details of the data protection officer or another relevant contact person providing further information. It must also outline the likely consequences of the data protection incident and detail the measures taken or planned by the data controller to address the incident, including any measures taken to mitigate possible adverse effects.

The data subject does not need to be informed if any of the following conditions are met:

• The data controller has implemented appropriate technical and organizational security measures, which were applied to the data affected by the incident, particularly measures—such as encryption—that render the data unintelligible to unauthorized persons.
• The data controller has taken further measures following the data protection incident that ensure the high risk to the rights and freedoms of the data subject is no longer likely to materialize.
• Providing notification would require disproportionate effort. In such cases, data subjects should be informed through publicly available information or similar measures that ensure equally effective communication.

If the data controller has not yet notified the data subject about the data protection incident, the supervisory authority may, after assessing the likelihood of a high risk, require the data controller to inform the data subject.

Reporting a Data Protection Incident to the Authorities

The data controller must report the data protection incident to the supervisory authority responsible under Article 55 without undue delay and, where feasible, no later than 72 hours after becoming aware of it, unless the incident is unlikely to result in a risk to the rights and freedoms of natural persons. If the notification is not made within 72 hours, it must be accompanied by reasons for the delay.

Right to Lodge a Complaint

In case of any violation by the data controller, a complaint may be filed with the National Authority for Data Protection and Freedom of Information (NAIH):

National Authority for Data Protection and Freedom of Information
Hungary, 1125 Budapest, Szilágyi Erzsébet fasor 22/C.
Mailing address: 1530 Budapest, P.O. Box: 5.
Phone: +36-1-391-1400
Fax: +36-1-391-1410
E-mail: ugyfelszolgalat@naih.hu

Final Provisions

This notice has been prepared in compliance with the following regulations:

• Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation – GDPR) of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC
• Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information (Infotv.)
• Act CVIII of 2001 on Certain Issues of Electronic Commerce Services and Information Society Services (particularly Section 13/A)
• Act XLVII of 2008 on the Prohibition of Unfair Commercial Practices against Consumers
• Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Commercial Advertising Activities (especially Section 6)
• Act XC of 2005 on Electronic Freedom of Information
• Act C of 2003 on Electronic Communications (especially Section 155)
• Opinion No. 16/2011 on the EASA/IAB Best Practice Recommendation on Online Behavioural Advertising
• Recommendation of the National Authority for Data Protection and Freedom of Information on the Data Protection Requirements for Prior Information
• Regulation (EU) 2016/679 of the European Parliament and of the Council (April 27, 2016) on the protection of natural persons concerning the processing of personal data and the free movement of such data, repealing Directive 95/46/EC

The data processing is carried out by Bxdesign.eu