Maphammer Limited Liability Company (company number: 03-09-132593, tax number: 26697732-2-03, registered office: 6000 Kecskemét, Klauzál Gábor tér 3. 1. em. 1.), (further on: Service-provider, Data processor) subdues itself under the following policy.

REGULATION (EEC) No 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (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 Regulation (EC) No 95/46, the following information is provided.

The present privacy policy guide regulates privacy of the following websites: https://maphammer.com/

The present privacy policy guide can be found on:
https://maphammer.com/privacy-policy

Modifications to the data become effective when they appear on the webpage above.

 

The data manager and contact information:

Name: Maphammer Limited Liability Company

Seat: 6000 Kecskemét, Klauzál Gábor tér 3. 1. em. 1.

E-mail: [email protected]

Explanatory terms

1. „personal data”: any data that can be related to the Customer – especially the name, username of the customer and any knowledge characteristic for one or more physical, physiological, mental, economic, cultural, or social identity of the Customer – and any conclusion related to the Customer drawn from the data;
2. „data management”: the totality of any operation or operations carried out in an automated or non-automated manner on personal data or data files, such as collecting, recording, organizing, tagging, storing, modifying or modifying, querying, inspecting, using, communicating, distributing or otherwise making available, aligning or linking, limiting, deleting or destroying;
3. „data manager”: means any natural or legal person, public authority, agency or any other body that determines the purposes and means of handling personal data individually or with others, where the purposes and means of data management are defined by Union or national law, the data controller or the particular aspects of the designation of the data controller may also be defined by Union or national law;
4. „data processor”: means any natural or legal person, public authority, agency or any other body that manages personal data on behalf of the data controller;
5. „recipient”: is a natural or legal person, a public authority, agency or any other body with whom or with which personal data is communicated, whether or not it is a third party. Public authorities which have access to personal data in an individual investigation in accordance with Union or national law shall not be considered recipients; the management of those data by those public authorities must comply with the applicable data protection rules in accordance with the purposes of data management;
6. „the contributor concerned”: a voluntary, specific and appropriate informed and explicit statement of the will of the person concerned by which he or she expresses the statement or confirmation by means of an inadvertent act of affirmation that he or she has consented to the processing of personal data concerning him or her;
7. „dataprotection incident”: a security breach resulting in accidental or unlawful destruction, loss, alteration, unauthorized disclosure or unauthorized access to personal data transmitted, stored or otherwise treated.

The principles of personal data management

The personal data:

1. must be legally and fairly handled and transparent to the person concerned (“lawfulness, fairness and transparency”);
2. are collected for specified, clear and legitimate purposes and are not treated in a manner incompatible with these purposes; in accordance with Article 89 (1), no further data handling (“end-use”) for purposes of public interest archiving for scientific and historical research purposes or for statistical purposes shall not be considered incompatible with the original purpose;
3. must be appropriate and relevant to the purposes of data management and should be limited to the need (“saving of the data”);
4. must be accurate and, if necessary, up-to-date; all reasonable measures must be taken to correct or correct inaccurate personal data for the purposes of data management (“accuracy”);
5. must be stored in a form which permits the identification of the data subjects only for the time needed to manage the personal data; the retention of personal data may only take place if the personal data are processed in accordance with Article 89 (1) for public interest archiving, for scientific and historical research purposes or for statistical purposes, in accordance with the rights and subject to appropriate technical and organizational measures for the protection of their freedoms (“limited storage”);
6. shall be managed in such a way as to ensure adequate security of personal data, including the protection against unauthorized, unlawful, unintentional, loss or destruction of data (“integrity and confidentiality”) by means of appropriate technical or organizational measures.

The data processor is responsible for the above, and must be able to demonstrate compliance (“accountability”).

Data managements

Data management related to webshop operation

1. Fact of data collection, the range of managed data and the aim of data management: 

Personal data	The purpose of data management	Legal basis
Password	Provides secure access to the user account.	Article 6 (1) (b) GDPR and 13 / A. (3) of Certain Issues of Electronic Commerce Services and Information Society Services.
First and Last Name	Required for contacting, purchasing, issuing a proper invoice, exercising the right of withdrawal.
Email address	Necessary to keep in touch.
Telephone	Contacts, billing, or delivery issues.
Billing name and address	Issuing a regular invoice, creating a contract, defining its content, modifying it, monitoring its performance, billing the fees, and enforcing related claims.	Article 6 (1) (c) and Article 169 (2) of Act C of 2000 on Accounting
Shipping name and address	It necessary for home delivery.	Article 6 (1) (b) GDPR and 13 / A. (3) of Certain Issues of Electronic Commerce Services and Information Society Services.
Date of purchase/registration	The fulfillment of techincal operation.
IP address at the time of purchase/registration	The fulfillment of techincal operation.

 

Neither the username nor the email address is required to be personal contain data.

1. Range of Customers: All those who purchase/registrate on the webshop.
2. Time of data handling, deadline for data deletion: Upon the completion of the order. The controller shall inform the data subject electronically of the deletion of any personal data provided by the data subject pursuant to Article 19 of the GDPR. If the data subject’s cancellation request also covers the e-mail address given by him / her, the data manager will also delete the e-mail address after the notification. Except in the case of accounting documents, under § 169 (2) of Act C of 2000 on Accounting these data have to be kept for 8 years.

An accounting document that directly and indirectly supports accounting accounting (including ledger accounts, analytical and detailed records) must be retained in a legible form for at least 8 years, retrievable in the form of a reference to the accounting records.

1. Possible data managers entitled to know the data, the recipients of personal data: Personal data may be processed by sales and marketing staff of the data controller, while respecting the above principles.
2. Describe the rights of data subjects involved in data management:

• The data subject may request from the controller access, rectification, erasure or restriction of the personal data relating to him or her, and
• the data subject has the right to data storage and the withdrawal of consent at any time.

 

• It is possible to initiate, delete, modify or restrict access to personal data, transferability of data, and objection to data processing in the following ways:

• By post at the address: 6000 Kecskemét, Klauzál Gábor tér 3. 1. em. 1.
• Via e-mail: [email protected]

 

• Legal basis for data processing: 

1.  Article 6 (1) (b) of the GDPR,
2.  CVIII of 2001 on Certain Issues of Electronic Commerce Services and Information Society Services (hereinafter: Elker TV.) 13 / A. § (3):

The service provider may manage the personal data that are technically essential for the provision of the service in order to provide the service. In the case of identity of other terms, the service provider must choose and in all cases operate the means used to provide the information society service so that the processing of personal data is only necessary if it is strictly necessary for the provision of the service and for the fulfillment of other purposes specified in this Act. necessary, but in this case only to the extent and for the time necessary.

1.  Article 6 (1) (c) in the case of an invoice in accordance with accounting legislation.
2.  In the event of the claim arising from the contract, Act V of 2013 on the Civil Code 6:21. § 5 years.

6:22. § [Limitation]

1. Except as otherwise provided in this Act, claims shall expire in five years.

(2) The limitation period begins when the claim becomes due.

(3) An agreement to change the limitation period shall be in writing.

(4) The limitation period is null and void.

 

1. We inform you that:

• This data management is required for the submission of a contract

• Yor are bound to give personal data so we can fulfill your order
• Failure to provide data has the consequences that you can not fulfill your order

The data processors used 

Delivery

We have partnered with DHL as our primary shipping carrier for delivering orders placed through our webshop. By placing an order on our website, you agree to have your package shipped via DHL and abide by their terms and conditions. For more information about DHL and their services, please visit their website at https://www.dhl.com/

 

1. Data Processor Activity: Delivery of goods, transportation.
2. The fact of data management, range of data: Delivery name, delivery address, telehone number, e-mail address.
3. Range of data subjects: Anyone who wants home delivery.
4. Aim of data management: Delivery of the ordered product.
5. Term of data management, deadline for deletion of data: It lasts until the home delivery is done.

• The legal basis for data processing: Article 6 (1) (b).

Storage-provider

1. Data Processor Activity: Storage and Server Services
2. Contact of the data processor:

Rackhost Zrt.

6722 Szeged, Tisza Lajos körút 41.

E-mail: [email protected]

1. The fact of data management, range of data: Any personal data given by the User.
2. Range of data subjects: Anybody who uses the website.
3. Aim of data management: To make access to the website, and the proper actuation.
4. Term of data management, deadline for deletion of data: Until the termination of the agreement between the data controller and the hosting service provider or the request for cancellation of the data subject to the hosting service provider.

• The legal basis for data processing: Article 6 (1) (c) and (f), and CVIII of 2001 on certain aspects of electronic commerce services and information society services; Act 13 / A. (3).

 

Other data processors:

Our webshop 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 help the website analyze how users use the site. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States. For more information about Google Analytics and its privacy policy, please visit https://www.google.com/intl/en/policies/privacy/.

Facebook Inc.

Company Address, 1601 WILLOW ROAD MENLO PARK, CA 94025. 

Company Phone, 650-618-7714.

SendGrid, Inc.

1801 California St fl 5, Denver, CO 80202, United States of America

Google

1600 Amphitheatre Parkway, Mountain View, CA, 94043.

 

Other recipients with whom personal data are communicated (data transmission):

Online payment

We are working with Stripe, a leading online payment processing service, to handle all transactions made through our webshop. Stripe is responsible for processing your payment information, including encoding and ensuring the security of your payment data. By using our webshop and making purchases, you agree to the processing of your payment information by Stripe in accordance with their privacy policy and terms of service. For more information about Stripe, please visit their website at https://stripe.com/.

1. Data Processor Activity: Online payment
2. The fact of data management, range of data: Billing information, name, e-mail address.
3. Range of data subjects: Anyone who wants to pay online.
4. Aim of data management: Providing online payment, transaction confirmation and fraud-monitoring to protect users (to control abusement)
5. Term of data management, deadline for deletion of data: It runs until the online payment is made.
6. Legal basis for data processing: Article 6 (1) (b) of the GDPR. Data processing is required for online payment at the request of the data subject.
7. Rights of the person concerned:
8. You can find out about the conditions of data management,
9. You are entitled to receive feedback from the data controller about whether your personal data is being processed or access to all information about data management.
10. You are entitled to receive personal information about you in a machine-readable, widely used, machine-readable format.
11. You are entitled, at your request, to correct your inaccurate personal data without undue delay.

Use of Cookies

1. Webshop-specific cookies are so-called “password-protected session cookies”, “shopping cart cookies”, and “cookie cookies” that require no prior consent from users.
2. The fact of data handling, the range of data processed: Unique identification number, times, dates.
3. The range of customers: Everybody who visits the website.
4. Aim of data management: Identifying users, keeping track of your shopping cart, and tracking visitors.
5. Term of data management, deadline for deletion of data: 

Type of cookie	Legal basis for data handling	Duration of data management	Treated data
Session cookies	In accordance with the CVIII Act of 2001 on certain aspects of electronic commerce services and information society services, Law 13 / A. § (3)	The relevant session until the end of a visitor’s session	connect.sid

 

1. The potential data managers entitled to know the data: With the use of cookies the service provider does not manage personal data.
2. Giving information on the rights of the Customers related to data management: Customers can delete cookies in the Tools/Settings menu of the browser generally at the menu item Data protection.
3. Legal basis of data management: No consent is required if the sole purpose of the use of cookies is the communication service provided through the electronic communications network or the provision of information society services expressly requested by the subscriber or user.

Newsletter, DM activity

1. According to § 6 of Act XLVIII of 2008 on the fundamental conditions of economic advertising activity the Customer may give consent in advance to the Service Provider for sending him/her advertisement and other consignment via the addresses given at registration.
2. Furthermore, the Customer may give consent to the Service Provider for managing the personal data for sending advertisements bearing in mind the regulations of the present guide.
3. Service Provider sends no unwanted advertisement and the Customer has the option to unsubscribe the sending of advertisements without any limitations and justification. In such case the Service Provider deletes every information – required for sending the messages – from the register and sends no further offers. Customer can unsubscribe the sending of advertisement by clicking on the link in the message.
4. The fact of data collection, range of managed data and the aim of data management:

 

Personal data	Aim of data management	Claim
Name, e-mail address.	Identification, admit of subscription on the newsletter.	The consent of the data subject, Article 6 (1) (a). On the basic conditions and certain limitations of the economic advertising activity, XLVIII. Section 6 (5) of the Act.
Date of subscription	The fulfillment of technical operation.
IP address at the time of subscription	The fulfillment of technical operation.

 

1. The range of customers: All Customers subscribing for the newsletter.
2. The aim of data collection: sending electronic messages (e-mail, sms, push notification) containing advertisements to the Customer giving information on actual products, discounts, new functions, etc.
3. The time period of data management and the deadline of deletion of data: until the withdrawal of the consent, i.e. unsubscribing from the newsletter.

 

The potential data managers entitled to know the data, the recipients of personal data: Personal data can be managed by the sales and marketing staff of the data manager in respect for the above principles.

1. Describe the rights of data subjects involved in data management:

• The data subject may apply to the data controller for access to, correction, deletion or limitation of the personal data concerning him or her, and
• may object to the handling of such personal data as well
• the data subject has the right to data storage and to withdraw the consent at any time.

 

• It is possible to initiate, delete, modify or restrict access to personal data, transferability of data, and objection to data processing in the following ways:

 

• By post at the address: 6000 Kecskemét, Klauzál Gábor tér 3. 1. em. 1.
• Via e-mail: [email protected]

The guest customer or newsletter subscriber in a text item created for this purpose can request the deletion of their personal information by entering their email address.

1. The users are free to unsubscribe from the newsletters at any time, with no cost.
2. 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

[email protected]

1. We inform you that:

• Data management is based on your consent.
• You must provide personal information so that we can respond to the message.
• Failure to provide data has the consequences of not being able to complete your request.
• Withdrawal of consent does not affect the legality of the pre-revocation data management based on consent.

 

Complaint handling

1. The fact of data collection, range of managed data and the aim of data management:

 

Personal data	Aim of data management	Claim
First and last name	Identification, contact.	Article 6 (1) (c) and the CLV of 1997 on consumer protection. Act 17 / A. (7).
Name, e-mail address.	Identification, admit of subscription on the newsletter.
Date of subscription	The fulfillment of technical operation.
IP address at the time of subscription	The fulfillment of technical operation.

 

1. The range of customers: All those who buy and complain about the webshop website and complain about the quality objection.
2. The time period of data management and the deadline of deletion of data: Copies of the record of the objection, of the transcript and of the response given to it be retained for 5 years as set out in CLV 1997 on Consumer Protection. Act 17 / A. Section 7 (7) of this Act.

 

1. The potential data managers entitled to know the data, the recipients of personal data: Personal data can be managed by the sales and marketing staff of the data manager in respect for the above principles.
2. Describe the rights of data subjects involved in data management:

• The data subject may apply to the data controller for access to, correction, deletion or limitation of the personal data concerning him or her, and
• the data subject has the right to data storage and to withdraw the consent at any time.

 

• It is possible to initiate, delete, modify or restrict access to personal data, transferability of data, and objection to data processing in the following ways:

 

• By post at the address: 6000 Kecskemét, Klauzál Gábor tér 3. 1. em. 1.
• Via e-mail: [email protected]

The guest customer or newsletter subscriber in a text item created for this purpose can request the deletion of their personal information by entering their email address.

1. We inform you that:

• the provision of personal data is based on a contractual obligation.
• The processing of personal data is a prerequisite for concluding a contract.
• be obliged to provide personal information to handle your complaint.
• Failure to provide data has the consequence that we will not be able to handle your complaint.

 

Social websites

1. The fact of data collection, range of managed data: name and public profile image of the Customer registered at Facebook/Google+/Twitter/Pinterest/YouTube/Instagram etc.
2. The range of customers: All Customers registered at Facebook/Google+/Twitter/Pinterest/YouTube/Instagram etc. and gave like to the website.
3. Purpose of the data collection: To share, or “like”, promote certain content elements, products, actions of the web site or the website itself on social networking sites.
4. Duration of data processing, deadline for deletion of data, person of possible data controllers who are able to know the data and details of the data management rights of the data subjects: Information about the source, their handling, the method of transfer and the legal basis of the data can be consulted on the given social networking site. Data management takes place on social networking sites, so the duration of the data handling, the ways of deleting and modifying the data are governed by the rules of the respective community site.
5. Legal base of data management: voluntary consent of the Customer for the management of personal data at community sites.

Customer services and other data management

1. If you have question during using some of the services of the data processor, or the customer has some problem you can get in contact with the data processer on the website (on phone, e-mail, community sites, etc.).
2. The data processer deletes the incoming e-mails, messages, on phone, on any community site, etc. what contains the name and e-mail address or any other given personal information of the customer, after 2 years from the start of the service.
3. We give information about the privacy policy which is not in this guide at the start of the service.
4. For exceptional magisterial request, or in case of law accumulation the service provider is bound for guidance, information providing, transferring, or making documents available for these organisation. 
5. In these cases the service provider only gives personal informations for the request (if they pointed out the exact aim and the necessary informations) what are essentials for the aim of the request.

Customer rights

• The right of access

You are entitled to receive feedback from the data controller about whether your personal data is being processed and, if such processing is in progress, you have the right to have access to your personal information and the information listed in the decree.

• The right of rectification

You are entitled to request the data controller to rectify any inaccurate personal information that he or she is required to do without undue delay. Taking into account the purpose of data management, you are entitled to request the supplementation of incomplete personal data, including by means of a supplementary statement.

• The right to cancel

You are entitled to request that the data controller, without undue delay, disclose personal information about you, and that the data controller is obliged to delete personal information about you, without undue delay, under certain conditions.

• The right to be forgiven

If the data controller has disclosed the personal data and is required to cancel it, taking reasonable steps, including technical measures, to take into account the cost of available technology and implementation, in order to inform the data controllers handling the data that you have applied for the personal data in question pointing links or deleting a duplicate or duplicate of these personal data.

• The right to restrict data management

You are entitled to request that your data controller restricts your data handling if one of the following conditions is met:

• You dispute the accuracy of your personal data; in this case, the restriction applies to the period of time that the data controller can check the accuracy of personal data;
• Data handling is illegal and you are opposed to the deletion of data and instead asks you to restrict them;
• The data controller no longer needs personal data for data processing, but you require them to submit, enforce, or protect legal claims;
• You have objected to data manipulation; in this case, the restriction applies to the period when it is established that the legitimate reasons for the data controller have priority over your legitimate reasons.

 

• The right to data storage

You are entitled to receive personal data that is made available to you by a data controller in a fragmented, widely used machine-readable format and is entitled to transfer this data to another data controller without this being obstructed by the data controller whose provided personal information to you (…)

• The right ro protest

You are entitled to object to the handling of your personal information (…), including profiling based on these provisions, for any reason relating to your own situation.

• Protest in case of direct business acquisition

If your personal data is handled for direct business, you are entitled to protest at any time against the handling of personal data relating to it, including profiling, if it is related to direct business acquisition. If you object to personal data being handled for direct business purposes, your personal information can no longer be handled for that purpose.

• Automated decision-making in individual cases, including profiling

You are entitled to exclude the scope of any decision based solely on automated data handling, including profiling, which would have a bearing on it or affect it significantly.

The preceding paragraph shall not apply if the decision is:

• You are required to conclude or complete a contract between you and the data controller;
• the granting of the right to a data controller is subject to the law of the Union or of the Member States which also lays down appropriate measures to protect your rights and freedoms and legitimate interests; or
• you are based on your explicit consent.

Deadline for action

The data controller informs you of any measures taken in response to these requests without undue delay but in any way within 1 month of receipt of the request.

If necessary, it may be extended by 2 months. The controller will inform you about the extension of the deadline by indicating the cause of the delay within 1 month of receipt of the request.

If the data controller fails to take action upon your request, he or she will notify you without delay and at the latest within one month of the receipt of the request for reasons of non-action and whether you may file a complaint with a supervisory authority and exercise its right of appeal.

Security of data management

Our webshop is built on the WordPress platform, which handles the encoding and storage of user passwords. All user data, including passwords, is stored on secure servers provided by Rackhost. While we take reasonable measures to ensure the security of your data, we cannot guarantee its absolute security. For more information on WordPress security, please visit https://wordpress.org/about/security/.

informing the person concerned about the privacy incident

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

Information given to the data subject should be clearly and easily understood and the nature of the privacy incident must be disclosed and the name and contact details of the Data Protection Officer or other contact person providing additional information should be disclosed; the likely consequences of a data protection incident should be described; describe measures taken or planned by the data controller to remedy a data protection incident, including, where appropriate, measures to mitigate any adverse consequences of a data protection incident.

The person concerned shall not be informed if any of the following conditions are met:

•  the data controller has implemented appropriate technical and organizational protection measures and applied these measures to the data covered by the data protection incident, in particular the measures, such as the use of encryption, which make it impossible for persons who are unauthorized to access personal data the data;
•  after the data protection incident, the data controller has taken further measures to ensure that high risk for the rights and freedoms of the person concerned is no longer likely to be realized;
•  Informing would require disproportionate efforts. In such cases, the data subject shall be informed by means of publicly disclosed information or a similar measure shall be taken to ensure that such information is equally effective.

If the data controller has not yet notified the data subject of the data protection incident, the supervisory authority may, after considering whether the privacy incident is likely to pose a high risk, may inform the data subject.

reporting a privacy incident to the authority

The data protection incident shall be reported to the supervisory authority under Article 55 without undue delay and, if possible, no later than 72 hours after the data protection incident becomes known, unless the data protection incident is unlikely to pose a risk to the rights of natural persons and freedom. If the notification is not filed within 72 hours, the reasons for proving the delay must also be enclosed.

review for mandatory data management

If the period of mandatory data management or the periodic review of its necessity is not specified by law, local government regulation or a binding act of the European Union, the controller shall review at least every three years from the commencement of the data processing that it or the processor acting on its behalf or on its instructions and if the personal data management is necessary for the purpose of data management.

The circumstances and results of this review shall be documented by the Data Controller, and shall be retained for a period of ten years after the review has been conducted and made available to the Authority at the request of the National Authority for Data Protection and Freedom of Information (hereinafter referred to as the Authority).

Complaint opportunity

Complaint regarding the possible breaching of the law by the data manager can be made to the Hungarian National Authority for Data Protection and Freedom of Information:

Hungarian National Authority for Data Protection and Freedom of Information

1125 Budapest, Szilágyi Erzsébet fasor 22/C.

Mailing address: 1530 Budapest, P.O.Box: 5.

Telephone: +36 -1-391-1400

Fax: +36-1-391-1410

E-mail: [email protected]

Closing remarks

The following regulations were accounted in the course of composing the guide:

• REGULATION (EEC) No 2016/67 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (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 Regulation (EC) No 95/46
• 2011 CXII. Law on information self-determination and freedom of information (hereinafter: Infotv.)
• Act CVIII of 2001 – Act on Electronic Commerce and Information Society Services (especially Section 13 / A)
• Act XLVII of 2008 – Act on the Prohibition of Unfair Commercial Practices against Consumers;
• Act XLVIII. Of 2008 – the basic conditions and certain limitations of economic advertising activity (in particular Article 6)
• XC. Law of 2005 on Eletronic Freedom of Information
• Act C of 2003 on Electronic Communications (specifically Article 155)
• No. 16/2011. an opinion on the EASA / IAB Recommendation on Best Practice in Behavioral Online Advertising
• Recommendation of the National Data Protection and Information Authority on the data protection requirements for prior information