Privacy Policy

Who Are We?

Address of our website: http://ztorteli.com 

Contact forms

Cookies

A cookie is a short text stored on Your computer by websites you’ve visited. This helps them store such useful information – related to the site’s visit – like your (default) preferred language or location. This makes the use of a website smoother as it makes it possible for the site to provide even tailored information. Thus cookies play an important role during internet use as without them browsing would become cumbersome.

You can read about the cookie settings of the most popular browsers through the links below:
Google Chrome 
Firefox 
Safari 
Microsoft Internet Explorer 11

Content Embedded From Other Sites

Website posts may utilize content embedded from outside sources (eg. videos, articles, etc.). Content embedded from outside sources act exactly as if you would have visited another site.

It is possible that these websites collect data on visitors, use cookies or tracking codes obtained from third parties, monitor user activity related to the embedded content in case we have a user account and are logged on to the site.

With Whom Do We Share User Information?

Period Of Data Control, Deadline For Deleting Data

Data is controlled until cease of cooperation between controller and host, or until subject has provides a request of deletion to host.

Claim For Controlling Of Data

user’s consent according to a Section 5 paragraph (1), article 6, paragraph (1), point a) of Act CXII of 2011 on information self-determination and freedom of information, and Section 13/A paragraph (3) of Act CVIII of 2001 on certain issues of electronic commerce activities and information society services.
Data forwarding is required to enforce lawful interests of Company
(Regulation (EU) 2016/679 of the European Parliament and of the Council Article 6 (1) Point f))

Where Do We Forward Data?

1. General terms of data controlling regarding website visit:

Audit is aided by Google Analytics servers as an external provider. Controller can provide detailed information on the controlling of survey data at www.google-analytics.com.

The online support chat servers are operated by PromptSaaS Inc., (K7M 2J8 Ontario, Kingston, Baiden Street 48., Canada). You can get oriented on the company’s privacy policy by visiting its website at http://ugyfelchat.hu/.

External providers place a small data package – so called cookie – on the user’s computer and read that back in order to provide a tailored service. If the browser sends a pre-saved cookie back it allows the provider to connect the user’s current visit to the user’s earlier visits, but exclusively in relation to his own content.

The user is able to delete the cookie from his own computer and he can turn off the use of cookies in his browser. Usually browsers make it possible to control cookies in the Tools/Settings menu under Privacy settings, Cookies.

Purpose of data control: identifying users, differentiating them from one another, identifying the current session of users, storing data providing during that session and preventing loss of data (PHPSESSID), the operation of chat connection (PCJSF_Processor_SURL, PCJSF_Tracker_Key, PCJSF), identifying visitors (PAPVisitorId).

Claim for the control of data: consent of subject according to Regulation (EU) 2016/679 of the European Parliament and of the Council Article 6 (1) Point a) “the data subject has given consent to the processing of his or her personal data for one or more specific purposes.”

Sphere of data controlled: identification number, date, time.
Period of data control:
• until the end of session (PHPSESSID),
• 2 hours (PCJSF_Processor_SURL)
• 1 hour (PCJSF_Tracker_Key, PCJSF), valamint
• 2 years (PAPVisitorId).

2. Using Google Adwords conversion tracking on websites

Controller is using Google Analytics survey system in order to secure proper operation of the service, to find out about website visitation data and user interest.

When user reaches a website through Google ad then a cookie required for tracking conversion is placed on his computer.

The validity of these cookies are limited and they do not contain any personal data thus the User can not be identified by them.

When User browses certain pages of the website and the cookie has not yet expired then Google and controller are both able to see that Use has clicked on the ad.

Every Google AdWords clients receives a different cookie so those can not be tracked through the websites of Google AdWords clients.

The information – collected through conversion tracking cookies – serve the purpose of creating conversion statistics for clients choosing AdWords conversion tracking. Clients get information this way on the number of users forwarded to pages provided with conversion tracking tags. However they do not obtain any information that would be suitable to identify any of the users.

If you do not wish to be part of conversion tracking you can reject that by disabling the possibility to install cookies in you browser. Following that You will not be included in the conversion tracking statistics.
Further information and Google’s privacy policy is available on this page: www.google.de/policies/privacy/

3. Google Analytics application

Websites use Google Analytics application that is a service of Google Inc. (“Google” web analysis). Google Analytics uses so-called “cookies” – text files – that are saved on the computer, thus aiding the analysis of the website visited by User.

The information created with the cookies in relation to websites used by User usually arrive to and are stored on Google’s servers in the USA.

By activating IP-anonymizing previously shortens the User’s IP address in the member states of the European Union and any other states that are part of the agreement on European Economic Area.

Only in special cases is the entire IP address forwarded to Google’s servers in the USA and is shortened there. Google will use these informations – as commissioned by the operator of this website – to evaluate how User has used the website, moreover to create reports on website activity for the operator of the website, and to accomplish further services related to website and internet use.

The IP address forwarded by the User’s browser within the Google Analytics framework is not coordinated with any other data of Google. User can prevent the storing of cookies by relevant browser settings, but we have to call to your attention that in this case it is possible not every function of this website will be entirely usable.

User can also prevent Google to collect and process – through cookies – User’s website usage related data (including IP address) by downloading and installing the browser plugin available at the following address. https://tools.google.com/dlpage/gaoptout?hl=hu

Your Rights Regarding Data Control

1. Right to be informed:
   You have the right to ask for information about the controlling of your personal data, and you can ask to have your personal data corrected, and you can also ask to have your personal data – excluding the mandatory controlled data – deleted, your consent withdrawn, you may exercise your right to carry data and to protest through the method indicated when data has been recorded and through the contact details of controller provided in this Privacy Policy.

You can exercise your right to be informed in writing, although if requested we also provide information verbally after verifying your identity.

2. Right to access:
   You have a right to receive feedback on whether the control of your data is happening, and if it is happening you have a right to access your personal information and the information listed under the directive.

Upon inquiry we provide information whether there is ongoing data control related to You in regards to the following:
1. Personal data related to You
2. purposes of data control;
3. categories of personal data;
4. persons Your data have been communicated to or will be communicated to;
5. the period of data storage;
6. the right to correction, erasure and restriction of data control;
7. the right to turn to a tribunal or authority in charge;
8. the source of the data controlled;
9. profiling and/or automatic decision making and the details and practical effects of such an application;
10. the delivery of the data controlled to a third country or international organization.

In case of your data request we are obliged to issue a copy of the data we control according to the request.
The deadline to issue requested data is 30 days from the reception of the request.

3. Right to rectify:
   You have the right to have the controller rectify inaccurate data related to You upon your request without unjustified delay. Taking the purpose of data control into account You have a right to request to have the incomplete personal data complemented – among others through a complementary statement.
4. Right to erasure:
   You have a right to have the controller upon Your request to erase without unjustified delay the personal data related to You, and controller is obliged to erase – without undue delay – the personal data related to You as soon as the following conditions are met:
   1. the personal data is no longer needed for the purpose it has been collected for a or controlled in any other way;
   2. You withdraw your consent that is the basis of controlling and thus there is no other claim for data control;
   3. You lodge a complaint against controlling and there is no prioritized claim for data control;
   4. the personal data has been controlled illicitly;
   5. the personal data has to be erased in order to meet legal obligations applied to controller by European Union or member state law;
   6. the collection of personal data happened in relation to offering services regarding informational societies.

The erasure to data can not be initiated if the data control is required: for the purposes of exercising the freedom of communication and the law relating to information; to meet legal requirements to control personal data by European Union or member state law valid to controller, and/or for the sake of public interest or to execute tasks related to practicing executive power licence commissioned to controller; for archiving, scientific and historical research or statistical reasons – based on public interest – concerning the field of public health; or to propose, endorse, and/or protect legal claims.

5. Right to restrict controlling:
   You have the right to have controller – upon your request – restrict the control of data if the any of the following conditions is met:
   1. You dispute the correctness of personal data; in this case restriction is valid for the period of time that makes it possible for controller to inspect the correctness of personal data;
   2. controlling is illicit and You object to the erasure of data and instead ask the restriction of their use;
   3. controller no longer needs the personal data for the purpose of controlling, but You require them for the proposal, endorsement or protection of legal claims;
   4. You have lodged a complaint against controlling; in this case restriction is valid for the period of time until it has been determined whether controllers legal reasons have priority over Your legal reasons.
6. Right to data portability:
   You have the right to receive the personal data related to You that You have provided a controller with in an articulated, widely used, machine readable format, moreover you have the right to forward these data to another controller without any restriction from controller you have provided the personal data with.
7. Right to lodge a complaint:
   If the controlling of personal data is for direct marketing purposes, You have the right to lodge a complaint at any time against personal data related to You being controlled for these purposes, including profiling, in case that is concerning direct marketing.

If You lodge a complaint against personal data being controlled for direct marketing purposes then personal data from there on may not be controlled for these purposes.

You have the right to – for reasons relating to Your own situation – at anytime lodge a complaint against your personal data being controlled for the sake of public interest or to execute tasks related to practicing executive power licence commissioned to controller; or for the sake of enforcing legitimate interests of controller or a third party including profiling based on mentioned directives.

In case of a complaint we as controller may not control personal data any longer, unless such legitimate obligatory measures justify that which are primary to Your interests, rights and freedoms, or which are related to proposing, endorsing or protecting legitimate interests.

8. Automated decision making in individual cases including profiling:
   You have the right to be excluded from the effects of decisions – only in case those are based on automated data controlling, including profiling – that would have a legal effect on You or would affect You significantly.

The previous paragraph is not applicable in case the decision:
1. is required for the signing or execution of contract between You and controller;
2. has been allowed by such European Union or member state law applicable to controller that set out measures to protect Your rights and freedoms and  legitimate interests; or
3. is based on Your explicit consent.

9. Right to withdraw:
   You have the right to withdraw Your consent at any time. The withdrawal of consent does not affect the legality of  consent based controlling prior to withdrawal.

Our procedure:
In case we receive a request then – as controller – as fast as possible, but latest within 30 days we inform You in writing about measures implemented based on Your request.

Should the complexity of request or any other objective circumstance justify it the above deadline may once be extended by maximum 60 days. We inform You in writing about the deadline extension including the proper justification for the extension.

The information is provided for free unless:
1. You request repeatedly for practically the same information/measures;
2. the request is unequivocally groundless;
3. the request is exaggerated.

Should You request the delivery of data on paper or on electronic data medium (CD or DVD) we deliver a copy of the data for free by the requested method (unless the selected platform would prove to be disproportionately difficult technically). For every further requested copy we charge 500 HUF administration fee per page/CD-DVD.

Of any correction, erasure, restriction done on our part we inform all those people to whom we have earlier communicated data unless informing them is impossible or would require disproportionately great effort.
In case You request it, we inform You about what people Your data has been forwarded to.

We provide reply to Your request electronically unless:
1. You specifically ask for the reply to be by a different method and that would not create an unjustified amount of extra cost for us,
2. we do not know Your electronic contact information.

Practising the right to lodge a complaint:
We investigate the complaint within the shortest time possible after the request has been submitted but latest within 15 days, we make a decision on the grounds of the complaint and we inform You in writing about this decision.

In case we determine that your complaint has grounds, we cease the controlling of data – that includes ceasing any further data collection and forwarding –, and we block the data, furthermore we inform all those about the complaint and the measures taken based on that to whom we have forwarded the personal data earlier with the complaint and who are obliged to take measures to enforce the right to lodge a complaint.

Controlling of data:
The data You have provided during contact through the website are stored in Hungary on the server of the host specified above, moreover electronically at the headquarters of out Company.

We do all measures reasonably necessary to securely store Your data and prevent unauthorized access.
Data is only accessed by our Company, we do not forward Your data.

10 Legal remedy
In case You have an objection to or a problem with our Company’s controlling of data, You may confidently contact our Company directly.

Right to turn to court:
You have the right to turn to the competent court of authority according to the Code of Civil Procedure. The court gives priority to the case.

Data protection authority procedure:
An incidental complaint may be lodged at the Hungarian National Authority for Data Protection and Freedom of Information:
Name: Hungarian National Authority for Data Protection and Freedom of Information
Headquarters: 22/C, Szilágyi Erzsébet fasor, Budapest, H-1125, Hungary
Mailing address: P.O. Box (Pf.): 5, Budapest, H-1530, Hungary
Phone: +36 (1) 391 1400; fax: +36 (1) 391 1410
E-mail: ugyfelszolgalat@naih.hu
Website: http://www.naih.hu

Our Company reserves the right to modify current Privacy Policy should it become necessary, e.g. for legal reasons or due to changes in our services.

Should this be the case we will revise the Privacy Policy.
The Privacy Policy comes into effect 30 days after the revision.

Budapest, 1st of January, 2020.
Torteli & Co Ltd