1. Who processes your data?
- Data controller: Béres Vineyard and Winery Ltd.
- Registered office: H-3932 Erdőbénye, Lőcse-dűlő
- Representative: Dávid Regéczy
- Company registration number: 05-09-009868; registered at the Miskolc Court as Court of Registration
- Tax number: 12906697-2-05;
- Registration numbers for data processing: NAIH-70411, NAIH-71980
- Website: http://www.beresbor.hu/en/
- E-mail address: firstname.lastname@example.org
The Controller respects your personal rights and has therefore prepared the below Privacy Notice, which can be viewed electronically on the Controller’s official website.
2. Our principles and legal acts that are binding to us during data processing
2.1. Legislation we are bound by during data processing:
- GDPR (General Data Protection Regulation) - REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (EU) 2016/679 (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 Directive 95/46/EC
- Data Protection Act - Act CXII of 2011 on Informational Self-determination and Freedom of Information, and legislation issued for its implementation
- Act CVIII of 2001 on Electronic Commerce Services and Certain Issues Concerning Services in an Information Society;
- Act V of 2013 on the Civil Code of Hungary;
- Act CL of 2017 on the Rules of Taxation, and legislation issued for its implementation;
- Act C of 2000 on Accounting, and legislation issued for its implementation
- Act XLVIII of 2008 on the Essential Conditions and Certain Limitations of Business Advertising Activities;
- Act CXXXIII of 2005 on the Rules of Security Services and the Activities of Private Investigators.
2.2. We abide by the following principles during data processing:
- a) Personal data will only be processed by the Controller for the purpose and duration specified herein. The Controller only processes personal data that is essential for the purpose for which they were recorded, and suitable to achieve that purpose.
- b) Personal data received by the Controller in the course of data processing shall only be disclosed to persons who are in the mandate of the Controller or are employees of the Controller, who are to perform tasks relating to the particular data processing activity.
3. What do these terms mean? (The description of terms used in the Privacy Notice):
“personal data”: Any information relating to a natural person (data subject) (e.g.: name, identification number, location data, online identifier or data specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person);
“sensitive data”: Such data include the personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation;
“data concerning health”: personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status;
“data subject”: identifiable natural person to whom the personal data relates. (E.g.: a visitor of the website, a person subscribing to the newsletter, a person responding to a job advertisement)
“processing”: means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
“controller”: a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal;
“processing by data processor”: performing technical tasks in connection with data processing operations;
“processor” - a natural or legal person, public authority, agency or other body which processes personal data on behalf of controller (under the assignment or instruction of, or according to decision of the controller).
“profiling”: any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;
“third party”: a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;
“consent of the data subject”: any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her
4. What kind of personal data do we process? (Various data processing activities)
4.1. If visiting the website (automatically recorded data and cookies):
4.1.1. Automatically recorded data
Once you visit our website certain data of your device (e.g.: laptop, PC, smartphone, tablet) are automatically recorded. Such data include the IP address, date and time of the visit, searched pages, the website from where the visit was initiated, the type of browser used, the type of the operating system and the domain name and address of the internet provider. The system logs the recorded data without any specific declaration or action on your part when the you log in or out. The system automatically generates statistical data from these data. Such data may not be connected with other personal data with the exception of cases where such interconnection is mandatory by law. We use this information only in a summarized and processed (aggregated) form, to correct any defects in our services or to improve their quality and for statistical purposes.
The purpose of data processing: The technical development of the IT system, the control of the operation of the service, its personalisation, generation of statistics and protection of the rights of the visitor. In the event of abuse, in cooperation with the internet service provider of the visitors and the authorities, the data can also be used to determine the source of the abuse.
Legal grounds of data processing: Section 13/A (3) of Act CVIII of 2001 on Electronic Commerse Services and Certain Issues Concerning Services in an Information Society.
Duration of data processing: 30 days from the viewing of the website.
What is a cookie?
How can I allow or block cookies?
Most web browsers automatically accept cookies, but visitors have the option to delete or reject them. Since each browser is different, you can customize your cookie preferences by using the toolbar of the browser. If you do not want to enable any cookies from our site, you can change the settings of your web browser to notify you of the cookies sent or simply reject all cookies. At the same time, you can delete cookies stored on your computer or mobile device at any time. For more information on these settings, visit the browser’s Help section. Please note that if you choose to disable cookies, you must forfeit some of the features of the site.
Legal grounds of data processing: Your consent
The purpose of data processing:
- Storing of personal settings
While visiting the website, the system can use the standard cookies to identify you as a unique user to remember your language preferences and note the status of your login.
- Anonymous statistical log
During your visit, the site's analytics software stores anonymous (encrypted) normal cookies to find out how many people visited the site and what content and information they are interested in. We store all analytics information without a name (or other personal data) and use it for technical and marketing purposes. For example, you can find out how many visitors a page has per month. However, we do not know the identities of our visitors.
Duration of data processing:
We differentiate between two types of cookies: ‘session cookies’ and ‘persistent cookies’.
- The ‘session cookie’ is stored temporarily by the computer, notebook or mobile device as long as you do not leave the site; these cookies help the system to record information so you do not have to re-enter or fill in that information. The session cookie validity period is limited to the user's current session only, and is intended to prevent data loss (for example, when completing a longer online form). When this session is completed or the browser is closed, these type of cookies will be automatically deleted from the visitor's computer.
- ‘Persistent cookies’ continue to be stored on your computer, notebook, or mobile device after leaving the site. Using these cookies, the site recognizes you as a returning visitor. Persistent cookies can be used to identify you through a service provider-side ID - user connection, thus, in all cases where authentication of the user is necessary - e.g. webshop, netbank, webmail - for the adequate conditions of proper operation. Persistent cookies do not carry personal data on their own, if applied correctly, and can only be used to identify the user in conjunction with the service provider’s database. The risk of such cookies is that it actually identifies the browser rather than the user, that is, if someone is in a public place, e.g. internet cafe, library, etc., and logs into a webshop and does not log out when leaving, then another person may use the same computer and gain unauthorised access to the webshop in the name of the original user.
The Controller measures the attendance data of the site using the GoogleAnalytics service. When using the service, non-personal data is transferred that are not suitable for identifying the data subject.
The Controller uses Google reCAPTCHA, which is an automatic test that is capable of distinguishing a human user from a computer. During the test, the computer generates a problem that only a person can answer correctly, but the correctness of that answer can be easily determined by the computer. Such tests are most commonly consist of the reading of distorted text, and they can be used to filter spambots.
You can read Google’s Privacy Notice here: www.google.hu/policies/privacy
4.1.4. References and links
We can be found on Facebook under names Béres Szőlőbirtok and Béres Szőlőbirtok és Pincészet Kft., and on Instagram under name Béres Szőlőbirtok.
On Béres Szőlőbirtok pages the Visitors can subscribe by clicking the ‘like’/'follow' button on the page, and can unsubscribe by clicking the ‘dislike’/'unfollow' button in the same location, and they can use the settings of the page to delete the news that they want in the news feed.
Legal grounds of data processing: Your consent.
The purpose of data processing: Your notification about current information, products, news about us, as well as sending informative articles and materials.
Duration of data processing: Our updates will only appear in your news feed as long as you allow it to do so.
Information on the data processing of the Facebook and Instagram website can be obtained from the privacy policies and policies contained on the Facebook site at www.facebook.com and www.facebook.com/help/instagram.
4.4. If you contact us:
You may contact us using any of our contact information (by email, via Facebook, by phone, by post). In such a case, we assume you have consented to the data processing of your personal data shared with us.
Complaints and queries are sent to our competent colleagues.
Legal grounds of data processing: Your consent.
The purpose of data processing: Keeping in contact with the inquirer and answer or resolve their question/request.
Period of data processing: Messages and the personal data received as a result will be erased after answering the given request, question or complaint. However, if it is required for tax or accounting purposes or for the protection of the Controller or the inquirer's rights and interests, it is archived and stored for the necessary period of time, which is determined in each case individually.
4.5. A surveillance system is operated in the offices of our company:
Cameras are operated at the registered office and sites of the Controller to ensure personal and financial security. The camera system is indicated by a pictogram and warning text.
For more information about the data processing of the surveillance system please visit the particular office building on site. We will also forward the data processing information of the surveillance system to you via email.
4.6. Our events
If you have been invited to one of our events, please note that prior to entering the event mandatory registration is carried out. When registering, please provide the following information:
- contact information (email address, address, phone number)
Legal grounds of data processing: Your consent.
The purpose of data processing: Creating the invitation lists for our events.
Period of data processing: We shall process your data until you decide to unsubscribe. If you do not wish to attend our events, please inform us and we shall erase your data.
In the case of events organised by external partners, the data forwarded to us that is necessary for the running of the event shall be erased following the event.
5. Your rights
In connection with data processing your rights are detailed in Sections 5.1 to 5.7. If you would like to exercise one of these rights, please write to us on one of the following contact details:
- Address: H-3932 Erdőbénye, Lőcse-dűlő
- Email address: email@example.com
Before completing your request, we must always identify your identity. Unfortunately, if we cannot identify you, we will not be able to meet your request.
Responding to the request
After identification, we shall give you feedback in regards to your request in writing, electronically or, upon your request, verbally. Please note that if you have submitted your request electronically, we shall respond electronically. Of course, in this case also, you have the opportunity to ask for a different response method.
We shall notify you within 1 (one) month from the receipt of your request about the measures taken in relation to your request. This deadline may, however, be extended by 2 (two) months if warranted by the complexity of the request or the number of requests, which we shall inform you about within the one-month deadline.
We are also obliged to inform you about the omission of the measure within the one-month deadline. You can file a complaint against this at NAIH (Hungarian National Authority for Data Protection and Freedom of Information) (Section 6.1) and exercise your right to legal remedy (Section 6.2).
The requested information and taken measures are free of charge. An exception is the case where the request is clearly unfounded or, in the case of its particularly repetitive nature, excessive. In this case, we may charge a fee or refuse to fulfil the request.
5.1. You may withdraw your consent
You may withdraw your consent at any time in the case of data processing based on the provision of your consent. In such a case, we shall erase your personal data in connection with the given data processing within 14 working days from the receipt of this notification.
5.2. You may request information (access)
You may request information about whether your personal data is currently being processed and, if so,
- What is its purpose?
- Precisely what data are being processed?
- Who do we forward these data to?
- How long do we store these data?
- What are your rights and options for legal remedies in relation to it?
- Where did we receive your data from?
- Do we make an automated decision regarding you by using your personal data? In such cases, you may also ask for information on what kind of logic (method) we are applying, how such data processing is relevant and what are the expected consequences.
- If you have found that your data has been transferred to an international organisation or third country (non-EU Member State), you may request that we provide you with information on how we guarantee that your personal data is adequately processed.
- You can request a copy of the personal data we are processing (We may charge a fee based on administrative costs for additional copies.)
5.3. You may request rectification
You may ask us to rectify or complete your inaccurately or incompletely recorded personal data.
5.4. You may request the erasure (“forgetting”) of your personal data
You may request us to erase your personal data.
Your request shall be fulfilled within 14 working days of the receipt of your request in the following cases:
- a) The personal data are no longer needed for the purpose they were obtained;
- b) In the case of data processing based solely on your consent;
- c) If it is established that personal data is being processed unlawfully;
- d) If required by EU or national legislation.
Please note that personal data in the cases specified in points a), c) and d) will be erased even without request.
Personal data may not be erased if it is needed:
- a) to exercise rights to freedom of expression and information;
- b) to fulfil the obligation relating to the processing of personal data by the Controller based on legislation of the European Union or a Member State thereof, or out of public interest;
- c) based on public interest that relates to public health;
- d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes if erasure is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
- e) for the establishment, exercise or defence of legal claims.
5.5. You can request us to restrict the data processing
You have the right to request the restriction of the processing if any of the following criteria apply:
- You contests the correctness of the personal data. In such cases the restriction shall only apply to the time period necessary for us to verify the correctness of the personal data
- The data processing is unlawful, and you oppose the erasure of the data and request the restriction of their use instead;
- We no longer require the personal data for data processing purposes, but you request the data for the establishment, exercise or defence of legal claims;
- You objected to data processing; in such cases the restriction shall only apply to the time period necessary to determine whether the Controller’s legitimate grounds override yours.
Should the data processing activity be subject to restriction, such personal data shall only be processed, beyond storage, with your consent or for the establishment, exercise or defence of legal claims or the protection of the rights of other natural or legal persons or in the important grounds of public interest of the European Union or a Member State thereof.
We shall inform you in advance of any potential lifting of restrictions.
5.6. You may request us to hand over your personal data (right to data portability)
You are entitled to receive your personal data processed by us in machine-readable format, and you are also entitled to transmit this data to another data controller or request us to do so, insofar as the processing of data is solely based on your consent, or on a contract concluded with you or in your interest, by automated means.
This right cannot be applied in cases where the purpose of the personal data processing activity is of public interest. It shall not prejudice the right to erasure and shall not adversely affect the rights and freedoms of others.
5.7. You may object to the processing of your personal data
You may object to the processing of your personal data if:
- The data processing is necessary for the performance of a task carried out in the public interest, or
- The processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child;
- The data is processed for direct marketing purposes (in this context, you may also object to profiling);
- The personal data is processed for scientific and historical research purposes or for statistical purposes.
- If you object to the processing of your personal data, your personal data shall be erased within 14 business days of the receipt of your objection. An exception is the case where data processing is justified by compelling legitimate reasons, including public interest or in the case where data processing is necessary for the establishment, exercise or defence of legal claims.
6. Legal remedy options
6.1. You may submit a complaint to NAIH
If you think your personal data is being processed in violation of the Data Protection Regulation, you have the right to file a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH).
- President: Dr Attila Péterfalvi
- Postal address: H-1534 Budapest, P.O. Box: 834
- Address: H-1125 Budapest, Szilágyi Erzsébet fasor 22/c
- Phone: (+36 1) 391-1400
- Fax: (+36 1) 391-1410
- Web: http://naih.hu
- Email: firstname.lastname@example.org
6.2. You may turn to the court
If you believe that your personal data is processed in violation of the Data Protection Regulation and violates your rights under the Data Protection Regulation, you are entitled to turn to a court.
The action shall be heard by the competent general court. If so requested by the data subject, the action may be brought before the general court in whose jurisdiction the data subject’s home address or temporary residence is located. Any person otherwise lacking legal capacity to be a party to legal proceedings may also be involved in such actions. The Authority may intervene in the action on the data subject’s behalf.
In addition to the provisions of the Data Protection Regulation, court proceedings are governed by Chapter 3, Title XII (Sections 2:51 to 2:54) of Book II of Act V of 2013 on the Civil Code, as well as other legal provisions governing court proceedings.
6.3. Liability and Restitution
If the Controller causes damage with the illegal processing of the data of the data subject or violates the personality right of the data subject, the Controller may be required to pay restitution for damages. The Controller shall not be liable for damages or paying restitution if they demonstrate that the damage or the violation of personal rights were brought about by reasons beyond their data processing activity.
7. Security of personal data
We will do our utmost to implement the appropriate technical and organisational measures in order to guarantee an adequate level of data security for the degree of risk, by taking into account the current state of science and technology, the costs of implementation, the nature of the data processing and the risk to the rights and freedoms of natural persons.
Personal data is always processed in a confidential manner, with limited access, encryption and the maximisation of resilience, and by ensuring restoration in the event of a problem. Our system is tested regularly to guarantee security. When determining the adequate security level, we take into consideration the risks stemming from data processing that arise from the accidental or unlawful destruction, loss, modification, unauthorised disclosure or unauthorised access to personal data, especially those forwarded, stored or processed by using other methods.
We will do our utmost to ensure that persons under our control who have access to personal data can only treat such data in accordance with our instructions unless deviation from this is required by the EU or Member State legislation.
8. Data Processors
Data processors not mentioned in the various data processing activities:
- The maintenance of the websites is carried out by InteliArt Online Marketing Korlátolt Felelősségű Társaság (registered office: H-2030 Érd, Ligetszépe utca 6/c.);
- The operation of the corporate Facebook and Instagram sites is carried out by Kóstolom Borgasztronómiai és Turisztikai Korlátolt Felelősségű Társaság (registered office: H-1087 Budapest, Könyves Kálmán krt. 76.)
- The hosting of the websites is provided by Smartsector Szolgáltató és Kereskedelmi Korlátolt Felelősségű Társaság (registered office: H-1054 Budapest, Honvéd utca 8. 1. em. 2.);
9. Data transfer
We only transfer your personal data to data processors and data controllers listed in this Privacy Notice and strictly only as provided for in this Privacy Notice. By consenting to detailed data processing, you also consent to the necessary transfer of data. The Controller, after obtaining your prior consent, may transfer your personal data to other controllers.
We reserve the right to provide the personal data processed, in the cases specified by law, to the competent authorities and courts in accordance with their request, without the consent of the data subject.
The Controller may at any time modify the terms and conditions of this Privacy Notice. Any modification will come into effect simultaneously with its publication on the website, and we shall call your attention to the change in the pop-up window on the website.
Last update: May 2018