The purpose of this Privacy Policy is to inform you – as natural persons – in detail and in a comprehensible manner about the data processing carried out by BonsAI HorizON Kft.

Legal background:

With regard to the data processing carried out by us, our Company primarily acts in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council on data protection – hereinafter referred to as the GDPR – and in compliance with the provisions of Act CXII of 2011.

Entry into force of the Privacy Notice:

Name of the data controller: BonsAI HorizON Kft.

Registered office address: 1027 Budapest, Bem József utca 9. Door 10

Company registration number: 01-09-423317

E-mail: adatvedelem@szmodiskrisztina.hu

Website: https://szmodiskrisztina.hu/

Data of the Data Protection Officer/Data Protection Officer of the Data Controller:

Name: Krisztina Szmodis, Richárd Dávid

Direct contact details:

Phone: +36 30 512 95 00

E-mail: info@szmodiskrisztina.hu

Persons entitled to access the data:

The personal data provided are accessed by employees under the direct control of the Data Controller

(managing director, office manager) in order to perform their duties, who handle the data confidentially in accordance with the internal rules and procedures in force at the Data Controller at all times.

In the course of processing your personal data, the Data Controller uses the following data processors to whom it forwards your personal data: http://www.fullhosting.hu/

Technical operation performed by the data processor: hosting and domain service.

Third parties that store personal data:

Name of the data processor: Full Hosting, Gábor Toronyai EV

The registered office of the data processor: Hungary, 5231 Fegyvernek Dózsa György út 32.

E-mail address of the data processor: info@fullhosting.hu

Website of the data processor: https://fullhosting.hu

The purpose and legal basis of data processing, as well as the scope of the processed data and their source:

1. a) Our Company accepts inquiries, letters and inquiries from customers on the online interface of our website. We store personal data related to letters.

The purpose of data processing – based on Article 13 of the GDPR – is to administer online inquiries and requests for quotations from customers and to properly fulfil the contact process.

Legal basis of data processing:

Article 6 of the GDPR Regulation. Pursuant to Article (1)(b) of the Data Protection Act, the processing is necessary for the performance of a contract to which the data subject is a party or for the performance of steps taken at the request of the data subject prior to the conclusion of the contract.

• Scope of processed data
• Source of the processed data
• Online contact data: name, e-mail address, company name, phone number.
• The customer who initiated an inquiry on the online interface, the interested party/contracting authority.

1. b) The Company offers the possibility of subscribing to the newsletter on its website.

The purpose of data processing – based on Article 13 of the GDPR – is to facilitate the full provision of information to the Company’s customers.

Legal basis of data processing:

Article 6 of the GDPR Regulation. Pursuant to Article (1)(a) of the Criminal Code, the data subject has given his or her consent to the processing of his or her personal data for one or more specific purposes.

• Scope of processed data
• Source of the processed data
• Data of persons who have subscribed to the newsletter: e-mail address.

Customers who initiate contact on the online interface, to whom our Company offers the opportunity to subscribe to the newsletter.

1. c) The Company offers a contact option on its website.

Purpose of data processing – pursuant to Article 13 of the GDPR – The Company facilitates the communication opportunity of its customers with this opportunity.

Legal basis of data processing:

Article 6 of the GDPR Regulation. Pursuant to Article (1)(a) of the Criminal Code, the data subject has given his or her consent to the processing of his or her personal data for one or more specific purposes.

• Scope of processed data
• Source of the processed data
• Data of persons requesting contact: name, e-mail address, company name, telephone number.
• Customers who require contact on the online interface, to whom our Company provides this opportunity.

After subscribing to the newsletter, the data will be anonymized after 5 years, or will be deleted immediately at the request of the subscriber – the option to unsubscribe. Once contacted, the data will be anonymized after 5 years.

Information on data transfers:

 This information contains information on the data of the Company transmitted to its Data Processors – data transfer to Hungary – this notice.

In the course of its activities, the Company does not transfer data to third countries or international organizations. The Company declares that the transfer of the personal data of the data subjects will take place with regard to the individual data processing, only in accordance with the provisions of the Company’s Privacy Policy and if the conditions are met.

Rights of the natural persons concerned related to data processing:

Right of access:

The data subject shall have the right to request information from the Company via the contact details provided in this information as to whether the processing of his/her personal data is in progress, and if such data processing is in progress, he/she shall have the right to know what personal data the Company is processing his/her personal data; – on what legal basis; – for what purpose of data processing; – how long it will be treated; furthermore, to whom, when, on the basis of what law, which personal data the Company has provided access to or to whom it has forwarded its personal data; the source of your personal data; whether the Company uses automated decision-making and its logic, including profiling.

The Company shall provide the copy of the personal data subject to data processing free of charge for the first time at the request of the data subject, after which it may charge a reasonable fee based on administrative costs. In order to meet the data security requirements and to protect the rights of the data subject, the Company is obliged to make sure that the identity of the data subject and the person wishing to exercise his or her right of access is identical, for this purpose the information, access to the data and the issuance of copies thereof are also subject to the identification of the data subject.

Right to rectification:

 The data subject may request the Company to amend any of his or her personal data through the contact details provided in the data of the data protection officer/data controller of the data controller. If the data subject can credibly prove the accuracy of the corrected data, the Company will comply with the request within a maximum of one month and will notify the person concerned thereof at the contact details provided by the data subject.

Right to blocking (restriction of processing):

 The data subject may request that the processing of his or her personal data be restricted by the Company (by clearly indicating the restricted nature of the data processing and ensuring separate processing from other data) if: – he or she contests the accuracy of his or her personal data (in this case, the Company will limit the processing to the period during which it verifies the accuracy of the personal data); – the processing is unlawful and the data subject opposes the erasure of the data and instead requests the restriction of their use; – the controller no longer needs the personal data for the purpose of data processing, but the data subject requires them for the establishment, exercise or defence of legal claims; or – the data subject has objected to the data processing (in this case, the restriction applies for the period until it is established whether the legitimate grounds of the data controller take precedence over the legitimate grounds of the data subject).

Right to object:

 The data subject may object to data processing through the contact details provided in this Privacy Policy if he or she considers that the Company would not process his or her personal data properly in connection with the purpose specified in this Privacy Policy. In this case, the Company must prove that the processing of the personal data is justified by legitimate grounds which override the interests, rights and freedoms of the data subject or which are related to the establishment, exercise or defence of legal claims.

Right to erasure:

 The Company will delete your personal data without delay if:

• Personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
• The processing of personal data is unlawful;
• Due to the fulfilment of a legal obligation to which the Company is subject, it is necessary to delete the data;
• If the consent to the processing of the data of a child under the age of 16 in connection with the provision of information society services has not been given or authorised by the person exercising parental authority over the child;
• If the Company has disclosed the personal data.

Right to data portability:

The Company will provide you with a copy of the personal data that is the subject of data processing upon request. If you have submitted your application electronically, the information will be provided in a widely used electronic format (e.g. . in doc or .pdf format), unless you request otherwise.

Information about cookies:

 The Company’s cookie policy can be found on the www.bonsaihorizon.hu website.

When the page is displayed, the system displays a question about accepting cookies to users in the bottom bar, and detailed information can be found under the Cookie Policy link.

The natural persons concerned may seek legal remedy:

The data subject may initiate a request for legal remedy at the National Authority for Data Protection and Freedom of Information regarding the legality of the Company’s data protection measures, or may file a legal remedy with the competent Court.

National Authority for Data Protection and Freedom of Information

Contact: 1055 Budapest, Falk Miksa utca 9-11.

E-mail: ugyfelszolgalat@naih.hu

Phone: +36 (30) 683-5969, +36 (30) 549-6838.

Budapest, 01/08/2024