Newsletter privacy information

Data Controller: Wellis Magyarország Zrt., registered address: 1118 Budapest, Budaörsi út 31/C., company registration number: 01-10-048882, tax number: 25584864-2-43, e-mail address: budaorsiut@wellis.hu, ertekesitok@wellis.hu, outlet@wellis.hu, info@wellis.hu, szerviz@wellis.hu, nagyker@wellis.hu, phone number: 29/564-380, name and contact details of data protection officer: Dr. Krisztián Bölcskei, info@adatvedelmiauditor.hu)

Overview:

1. The Data Subject may subscribe to the newsletter before or during the use of the services, or otherwise, by entering its required data.

What is the legal basis of the data processing?

2. Subscription to the newsletter is based on the data subject’s consent.

Who are the data subjects?

3. Scope of the data subjects: Each natural person wishing to be informed of the news, discounts and special offers offered by the Data Controller, and subscribes to the newsletter for this purpose by entering personal data

What are the scopes and purposes of the data processed during data processing?

4. The scopes and purposes of the data processed:

   name	identification
   e-mail address	sending newsletter

What is the purpose of the data processing?

5. The purpose of the data processing related to sending newsletters is to provide general or personalized, and regular information to the recipient on the latest events, news and promotions offered by the Data Controller.

What is the duration of data processing?

6. The Data Controller and the data processor of the Data Controller will only process the personal data collected for the purpose until

   1. the Data Subject unsubscribes from the newsletter list, or
   2. in case there is a request for confirming consent, and the deadline for giving such consent passes, the data are deleted after such unsuccessful expiry.

What methods are used for data processing?

7. The methods used for data processing:

   1. subscription electronically or manually on paper
   2. automatic sending electronically
   3. unsubscription electronically or manually on paper.

What is the data source?

8. Data source: directly from the data subject.

Is there data transfer to third party?

9. The Data Controller engages a data processor as follows:

   1. Name of the data processor: Newgency Kommunikációs és Értékesítés-támogató Kft.
   2. Address: 1133 Budapest, Pozsonyi út 48.
   3. Phone number: +36 30 683 99 63
   4. E-mail address: redey.barbara@newgency.hu
   5. Data processing activity: sending newsletters, contact by phone

How is data protection ensured by the Data Controller?

10. Within the scope of its tasks related to information technology protection, the Data Controller shall in particular ensure:

    1. refusing access to the tools used for data processing (hereinafter: data-processing system) by unauthorized persons,
    2. preventing the unauthorised reading, copying, modification or removal of data media,
    3. preventing the unauthorised input of data and the unauthorised inspection, modification or deletion of personal data stored therein,
    4. preventing the use of data-processing systems by unauthorised persons using data transfer equipment,
    5. that persons authorised to use the data-processing system only have access to the data covered by their access authorisation
    6. that it is possible to verify and establish to which bodies personal data have been or may be transferred, or have been made or may be made available using data transfer equipment
    7. that it is subsequently possible to verify and establish, which personal data were, when, and by whom entered into the data-processing system
    8. preventing unauthorized disclosure, copying, modification or deletion during the transfer of personal data or during transportation of the data media
    9. the restoration of the data-processing system in case of malfunction.
    10. that data-processing remains operational, a report is created on any malfunctions during operation, and that the modification of the stored personal data can be prevented in case of a system failure.

Is there automated decision-making or profiling?

11. Automated decision-making, profiling: not performed in connection with data processing.

What are my rights?

12. Pursuant to the Information Act and Regulation (EU) 2016/679 of the European Parliament and of The Council, the rights available for the data subjects are as follows: right of access, right of rectification, right to erasure, “right to be forgotten”, right to data blocking/restriction, right to object, right to seek judicial remedy or lodge a complaint with a supervisory authority.

13. The Data Controller calls the attention of the data subjects that there may be conditions and limitations to exercising their rights in respect of certain processing activities, which factors must be examined by the Data Controller. In the event the data subject may not exercise a right in respect of a certain processing activity, then the Data Controller must notify the data subject on the factual and/or legal reasons excluding the exercising of such right.

Where and how can I request detailed information on the processing and transfer of data, and how can I exercise my rights?

14. The Data Controller draws the attention of the data subjects to the fact that they may request information or exercise their rights – unless excluded by legislation – at the e-mail addresses: budaorsiut@wellis.hu, ertekesitok@wellis.hu, outlet@wellis.hu, info@wellis.hu, szerviz@wellis.hu, nagyker@wellis.hu by sending a declaration to the above e-mail addresses, or to any other contact of the Data Controller. The Data Controller shall examine and answer such declaration as soon as possible after receipt, and takes the necessary steps in accordance with the declaration, the Policy, and other legislation.

Where can I turn in case the right to self-determination is violated?

National Authority for Data Protection and Freedom of Information
Address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c
Phone: +36 (1) 391-1400
Fax: +36 (1) 391-1410
www: http://www.naih.hu
e-mail: ugyfelszolgalat@naih.hu

15. The data subject may seek judicial remedy in case his rights are violated. Such court proceedings shall be conducted under priority. The Data Controller shall be the party to prove that the challenged data processing complies with the relevant laws.

16. In case the Data Controller violates the personality rights of the data subject by the unlawful handling of the data subject’s data, or by violating the data security requirements, the data subject may claim compensation for damages from the Data Controller.

Other

17. The data subject may unsubscribe from the newsletter at any time via the link at the bottom of the newsletter, or by sending a request to unsubscribe to any of the following e-mail addresses: budaorsiut@wellis.hu, ertekesitok@wellis.hu, outlet@wellis.hu, info@wellis.hu, szerviz@wellis.hu, nagyker@wellis.hu.

18. You can also unsubscribe by postal mail sent to the following address: Wellis Magyarország Zrt., 1118 Budapest, Budaörsi út 31/C.

19. The Data Controller reviews the newsletter list every three years, and requests consent to sending the newsletters every three years. The data of any data subject who fails to confirm its consent will be deleted from the data file by the Data Controller.

20. The Data Controller collects statistical data on the number of persons reading the newsletter by following the number of clicks on the links placed in the newsletters.

21. With respect to the data marked with: *, the Data Controller points out that in case the data subject fails to provide the Data Controller with them, the Data Controller refuses to provide the service (data processing).