HYD Rákkutató és Gyógyszerfejlesztő Korlátolt Felelősségű Társaság
Seat: H-1118 Budapest, XI. ker. Villányi út 97., Hungary
Registering body: Fővárosi Törvényszék Cégbírósága
Registry number: 01-09-260799
TAX number: 10805459-2-43
I. Introduction
I.1. On www.preventa.hu you are either purchasing one or more items from the Preventa® family of products or other products offered by HYD LLC, subscribing to our newsletter service or simply visiting the website of HYD LLC. During these activities your personal information may be collected, used and analyzed. This Privacy Policy details how your personal information is being used, analyzed and occasionally shared by HYD LLC.
I.2. During the purchasing process to fulfill your order we ask you to provide your basic personal information making the delivery possible.
I.3. During the purchasing process you can subscribe to the newsletter service offered by HYD LLC. by providing your personal information defined in section I.2. No special personal information like health status, religious belief or church is being used by HYD LLC. in relation with the newsletter service.
I.4. Personal information – defined in section I.2. – you provide as a customer is used by HYD LLC. only in order to fulfill your order.
I.5. HYD LLC does not collect any information usable to identify occasional visitors of the company’s websites. Information incapable of identification is collected only for statistical purposes, and is published in a summerized form. HYD Kft. collects information about the activity of its customers, however these pieces of information are not connected either with the information provided by the customers during the registration process, nor with the information produced by visiting other websites and online services.
I.6. Protecting your personal information and informational self-determination is very important to HYD LLC. The Supplier uses personal information in a confidential manner, ensuring every detail of security, technology and organization in order to protect information.
I.7. It is your responsibility to study the privacy practices detailed in this Privac Policy. By purchasing a product or by subscribing to the newsletter service you acknowledge that you read the Privacy Policy, and that you made a decision with that in mind, with a free will, to purchase a product and thus enter a contract without the simultaneous physical presence of the parties, or to register to our online newsletter service, accepting the policies relating the use of your personal information.
II. How information is used
II.1. HYD LLC uses the information provided by its customers and partners automatically, in an electronic form; during this no data processors are being employed; personal information is shared with a third party only according to this Privacy Policy.
II.2. HYD Kft. does not collect information of your bank account: payment with debit card, PayU or PayPal is done through the payment service provider. Payment service providers use information according to their own privacy policies.
II.3. HYD LLC does not retain the personal information you already provided if you do not create an account in the Webshop operated by HYD LLC, or if you cancel your order before finishing the purchasing process. By deleting your user account your personal information will be deleted, as the Supplier concludes the deletion of the user account as the withdrawal from the privacy policy agreement. Information about the already fulfilled orders (section VII.2.) however will be retained.
II.4. When visiting the websites operated by HYD LLC the company may store anonymous identifiers, so called cookies (small text files) on your computer.
Cookies help to secure the service, optimalize the performance, provide an accessible system and offer useful information; without the use of cookies the purchasing and the online interface provided for purchasing (the „Webshop”) may not function fully. By the use of cookies the Webshop is able to track your settings and your visits, „remembering” your previous visits, making the website more user friendly. In your browser settings you can disable cookies, also you can delete previously stored cookies by emptying the cache. Deleting the cookies means that your Webshop settings (e.g., remembered password, language settings), your preferred information will be lost, and also that loading the website may take longer than before.
The usage of the cookies does not require the Customer’s agreement, providing the sole purpose of the usage is to communicate information through the electronic messaging network. The usage of the cookies requires the Customer’s agreement in the case of services associated with the information society, specifically asked for by the Customer.
Cookies used by the Supplier may belong to the following categories:
II.4.1. Temporary (session cookie): Anonymous visitor identifier (cookie) used for individual identification and collection of profil information. Stored on the Customer’s computer until browsing ends. In itself it is not able to identify the Customer, it recognizes the Customer’s computer. Name, e-mail address or any other personal information is not required, as during processes like this the Supplier does not ask for information from the Customer, information is exchanged between computers. These anonymous visitor identifiers are technical requirements of the convenient operation of the online communication (browsing) and further functions and applications provided by the website.
II.4.2. Permanent (persistent) cookie: To provide personal settings the service needs to be able to identify the Customer’s habits, demands (e.g. optimalised navigation). This requires cookies to be stored on the Customer’s computer as well, however in this case this is only possible after the visitor was informed and he/she agreed to it.
II.4.3. The Supplier does not use third-party cookies.
II.5. The Supplier tracks the website traffic of the Webshop with Google Analytics. This requires information to be shared. The website contains web beacons, also called „pixel tags”. Web beacons are often transparent image objects of a size bigger than 1x1 pixels embedded on a website or in an e-mail, in order to track the online habits of the visitor of the website or the sender of the e-mail. Web beacons are used by third parties – in the case of the Website it is Google Analytics – in order to track the activities of the visitor. This makes it possible to determine the location of the visitor of the website (country, city). The shared information is not capable of identifying the visitor.
The pieces of information collected with the use of pixel tags and cookies are anonymous and are not connected with the personal information. The pieces of information required for the analytics service are stored in the USA and in cloud servers.
For Google’s privacy policies please see: http://www.google.com/policies/privacy/ads/
III. How information is shared
III.1. If you purchase a product from HYD LLC through one of its websites, by email or by phone, HYD LLC will entrust a courier to fulfill your order and deliver your item(s).
III.2. Basic information on the entrusted courier companies (the „Courier”) and their addresses can be found in the Standard Contractual Clauses (the „Standard Contractual Clauses”).
III.3. To deliver the items you ordered HYD LLC shares the following of your personal information with the Courier:
a.name;
b.shipping address
c.phone number
d.e-mail address
Information is shared and used in order to fulfill the Customer’s order, deliver the Product, confirm the transaction and prevent any fraud. Personal information listed in section III.3. are shared with the Courier according to your will, under your consent, as an inseparable part of the purchasing process.
IV. Legal basis
IV.1. Your free consent serves as a legal basis for the use of your personal information.
IV.2. HYD LLC does not use any special personal information (personal information relating to ethnic origin, nationality, political belief, religious belief and worldview, trade union membership, sexual orientation, health status, addiction, criminal behaviour).
IV.3. Personal information on the invoice produced after purchase is used as content of the invoice produced as part of the transaction – as it is prescribed in the laws regarding taxation and accounting.
V. Purposes; types of information used
V.1. HYD LLC uses personal information to fulfill orders, serve customers, make invoices and also to develop business communication (direct marketing messages).
V.2. To fulfill your order and make an invoice HYD LLC requires you to fully provide your valid personal information. The required types of personal information are the following:
a.name (first and last name), birth name, or name of the company;
b.address or seat;
c.postal address;
d.e-mail address;
e.phone number.
HYD LLC would like to inform its customers that the laws regarding accounting (Act C of 2000 on Accounting, Section 169. (2.)) and taxation requires specific personal information (name and address) to be retained for another 8 (eight) years following the conclusion of the purchase agreement. This requirement articulated by the law means that there is no legal way to delete those types of information.
V.3. In order to develop business communication HYD LLC asks for further personal information. It is not compulsory to provide these types of personal information. By providing these pieces of personal information you give your consent to HYD LLC to send you direct marketing materials in e-mail or via post – up until your withdrawal. We ask you to provide these pieces of information only in case you agree to receive advertising. HYD LLC sends out advertising materials no more than once a week. These types of personal information are the following:
a.name;
b.postal address;
c.e-mail address;
d.phone number.
The personal information HYD LLC collected for the purpose of direct marketing is used for no more than 5 (five) years. With your withdrawal from the agreement to use your personal information for the purpose of direct marketing HYD LLC stops sending you materials both in e-mail and via post.
V.4. In addition to the types of information detailed in sections V.2. and V.3. HYD LLC collects and retains information required for the transaction, information in connection with the purchase, information provided by the Customer, and also the date, the time and the total ammount of the transaction, along with the Customer’s IP address (if possible). These types of information are used in order to develop the customer experience, and also to identify and prevent any illegal user behaviours and abuses. Information are used for 30 (thirty) days starting from the day of collection.
V.5. In order to operate the Webshop HYD LLC temporarily uses the following types of automatically collected information (not including any personal information): the computer’s IP-address, URL, access data, account file (file name and URL), HTTP code, information on the website where the request arrived from, data traffic of the visit (in bytes), time of the visit, information on the pages visited, name of the browser.
In the log files produced during the service the provider’s servers collect information on the requests sent by the visitor such as the sender computer’s dynamic IP-address, the browser’s type, time of the request, address of the requested page, etc. These pieces of information are not capable of identifying the visitor and are used for trend analysis, traffic statistics, service administration and analysis.
V.6. HYD LLC separately lists the individuals who withdraw from the use of their personal information, in order to collect the names, postal and e-mail addresses of the individuals who prohibited or, despite the direct request coming from the marketing agency, did not consent to the use of their personal information for delivering marketing materials, or prohibited the further use of their personal information for such purposes, or prohibited their personal information to be retained in the central register.
VI. Where information is used
VI.1. Information is used on the website www.preventa.hu, where you place your order, or on the servers of HYD LLC.
VI.2. The server running the website is located in Budapest, however considering the structure of the world wide web HYD Kft. cannot guarantee that information will take the shortest route to the server.
VII. Deadlines
VII.1. HYD LLC uses your personal information for marketing purposes up until you withdraw your consent.
VII.2. HYD LLC retains the personal information you provided during a purchasing process for the time prescribed by the laws regarding taxation and accounting – this overrules any requests regarding the deletion of information. Section 169. of the law on Accounting says that in case of a purchase invoices and thus the personal information they contain must be retained for 8 (eight) years.
VII.3. You can withdraw your consent to marketing uses at any of the customer service points of HYD LLC listed in the Privacy Policy.
VII.4 In order to guarantee the demonstrably correct use of your personal information HYD LLC accepts only a written statement. An e-mail sent from an e-mail address previously registered in your HYD LLC system is considered as a written statement.
VII.5. The submission of this is free of charge.
VIII. Who uses the collected information
VIII.1. It is HYD LLC that uses the collected information, that defines for what puroses the information can be used, that articulates decisions regarding the information usage (including its tools) and executes them.
VIII.2. HYD LLC does not employ data processors during the operation of its newsletter service.
VIII.3. HYD LLC does not share personal information with a third party without the consent of the provider of the information. This does not apply to the information necessary for the delivery, provided during the purchasing process through the Website, which is shared with the Courier (please see chapter III.)
VIII.3. Information about the Supplier
Company name: HYD Rákkutató és Gyógyszerfejlesztő Korlátolt Felelősségű Társaság
Seat: 1118 Budapest, XI. ker. Villányi út 97.
Phone: [+36 1 365 1660]
Email address: [ingo@preventa.org]
Registering body: Fővárosi Törvényszék Cégbírósága
Registry number: 01-09-260799
TAX number: 10805459-2-43
Information Security ID: [NAIH-66289/2013.]
VIII.4. HYD LLC informs its subscribers in case it shares their personal information with a third party for data processing purposes. In this case HYD LLC ensures that its partner is under the same obligation of confidentiality.
VIII.5. It is mandatory for all employees at HYD LLC to be aware of the laws protecting the private life and personal information of the Customers who agreed to receive marketing materials, and also to comply with these laws as well as the company’s relating regulations.
IX. Rights
IX.1. You can require to be informed about the use of your personal information, and also you can require your personal information to be deleted, locked, corrected or extended through your registered user account in the Webshop, or at any of the customer service points of HYD Kft. listed in the Privacy Policy.
IX.2. HYD LLC will…
IX.2.1. delete the collected personal information if it is used illegally, if the visitor requires it to be deleted, if the information is incomplete or false – and it cannot be corrected in a legal way –, provided this is not prohibited by any law, the purpose of the information usage is fulfilled or the deadline defined by law to retain information expired, the deletion of the information was required by court or by the Hungarian National Authority for Data Protection and Freedom of Information.
IX.2.1. lock the collected personal information if it is required by the provider of the information, or if deletion according to current knowledge would harm the interests of the provider of the information. Locked personal information may be used up until the purpose that required its use and thus prevented its deletion is fulfilled.
IX.2.3. corrects or extends the collected personal information if it is not valid, and valid personal information is at hand.
IX.2.4. mark the collected personal information, if the provider of the information claims that it is incorrect, however it is not possible to determine whether the debated information is correct or not.
IX.3. You can object against your personal information being used if (i) using or sharing your personal information is only made necessary by law, or (ii) is done in the rightful interest of the user of the information or of a third party (with the exception of mandatorily retained information), or (iii) happens as part of a marketing strategy, marketing research or scientific sampling.
IX.4. If no law prescribes the mandatory retainment of the type of information you provided, following a personal request the Supplier will delete your information.
IX.5. You can submit requests concerning the usage of your personal information free of charge. Asking for information on the usage of your personal information is free of charge only if it is the first request concerning a certain type of information in the current year. Otherwise a fee is charged for submitting a request.
IX.6. To your request HYD LLC will reply in no more than 30 days, to your objection HYD LLC will reply in no more than 15 days.
X. Information security
X.1. Usage of the information is done according to the requirements of information security. HYD LLC takes the technical and organizational precautions and lays down the fundamental regulations that are made necessary by the requirements of information security and confidentiality.
X.2. The access to the collected information, to the IT system handling the collected information and to the services provided by the Supplier must be controlled and monitored according to the demands in association with the right to access.
The right to access the collected information is decided by the management of HYD LLC, taking into consideration the level of access a user needs to finish a certain task.
X.3. Passwords must be protected.
X.4. Access must be blocked for a user after 3 (three) unsuccessfull logins, or after 30 (thirty) days without login.
X.5. For follow-up investigation every access is recorded by HYD LLC. Access to personal information is recorded (logged) to make it possible to track whether when and by which user a certain information was accessed.
X.6. The system handling the rights to access is continuously monitored by HYD LLC. If the scope of activities or duties of a certain user changes, HYD Kft. modifies the access of the user immediately (eliminating the dated access and setting up the rights granted by the new access).
X.7. It is forbidden to save personal information on data storage device – except for the sake of a backup copy or in order to create the database necessary for sending out marketing material.
X.8. The database containing the personal information is saved by the Supplier at least once a week. One backup copy can be retained for no more than 4 (four) weeks, after which the contents of the data storage device must be overwritten with the new information. Backup copies must be kept at a secured location separated from the database.
X.9. Every data entry must be preceded by a security scan.
X.10. Developer systems and their supporting settings must be kept separately from the systems handling live information. Developer systems may contain real personal information only in special cases, during which the same security regulations apply to them as to live systems.
XI. Agreement to the use of information
XI.1. During purchasing items from the Preventa® family of products you can voluntarily agree to HYD LLC to send you newsletters as detailed in this Privacy Policy.
XI.2. You can agree to receive these newsletters while placing an order or by using the „tick box” on the website. Placing an order is not a requirement of subscribing to the newsletter service. The customer relationship realized by a purchase in itself is not an agreement to sending out the newsletter.
XI.3. You subscribe to our newsletter service by free will. There is no such law that would allow us to use your personal information to send you newletters, or that would require you to agree to this.
XI.4. We are using your personal information by your voluntary agreement, with the exception of the personal information you provided during a purchasing process – please see section V.2. about our legal obligation to retain invoices for potential tax audits.
XII. Legal remedy
XII.1. Complaints about the use of your personal information must be sent to the authority of data protection:
The Hungarian National Authority for Data Protection and Freedom of Information
Postal address: 1530 Budapest, PO box: 5.
Seat: 1125 Budapest, Szilágyi Erzsébet fasor 22/c
Phone: +36 (1) 391-1400
Fax: +36 (1) 391-1410
Web: http://naih.hu
XII.2. You can make good of your rights associated with your personal information had they been abused by HYD LLC, or investigate any dispute relating the use of your personal information through judicial channels. For further information on court functions and competencies please see www.birosag.hu.
IX. Legal background for the use of personal information:
IX.1. Act LXIII of 1992 on Informational Self-Determination and Freedom of Information („Privacy Act”);
IX.2. Act LXVI of 1992 on Keeping Records on the Personal Data and Address of Citizens;
IX.3. Act CXIX of 1995 on the Use of Name and Address Information Serving the Purpose of Research and Direct Marketing;
IX.4. ACT CVIII of 2001 on Certain Issues of Electronic Commerce Activities and Information Society Services;
IX.5. Act CLIX 2012 on Postal Services;
IX.6. Act XLVIII of 2008 on the Basic Requirements and Certain Restrictions of Commercial Advertising Activities;
IX.7. Act C of 2002 on Accounting;
IX.8. Government Decree No. 335/2012 (XII.4) on the detailed rules for the provision of postal services and the postal service related to official documents, as well as on the general terms and conditions of postal operators, and on items excluded from postal services or items that may only be carried upon certain conditions.
