Complete data management information for customers and contacts

This complete data management information ("Information") is provided by Tamás Troll, a sole proprietor (Address: 2112 Veresegyház, Vadvirág utca 9., 0224, hereinafter referred to as "DATA CONTROLLER" or "We"), as well as the natural person's contacts of the customers (collectively, "contacts" or "you"). DATA MANAGER acts as the responsible data controller of your personal data.

Why do we handle your personal information?
We only handle information about you that is necessary to
• keep in touch with you or your employer, principal as our customer or business partner and answer your questions;
• respond to bids and enter into and fulfill contracts;
• compliance with legal accounting and tax obligations.
• send promotional messages based on your consent.

We typically handle information about the services you provide, your name, position and contact information, such as email addresses and telephone numbers, and we will not record or otherwise retain information about you that could be considered “special information”. We will only use information about you and for purposes that are considered normal in relation to your customer or business relationship with you, your employer, such as regular contact with products or services, including information.

What personal data does the DATA MANAGER handle?
Personal information may come directly from the customer concerned, customer contacts, or other public sources (such as company records). Such personal data fall into the following broad categories:
• Personally identifiable information, including name;
• Contact information such as address, email address and phone number;
• Activity data, title and position
• Contract details, such as the subject of the contract and a description of the economic event
• Bank details, such as bank account number, tax number, payment information
• Communication data, such as email content, business letters, contract content, and other business documents.

On what legal basis do we process personal data?
We rely on different legal bases to process your personal information:
• Contract: If you are a private customer of us, the legal basis for the processing of your personal data is usually Article 6 (1) (b) of the GDPR (thus the processing of data required to channel or fulfill a contract at your request). The provision of personal information is voluntary, but in the absence of such information, we may not be able to enter into a contract with you or perform the relevant contract.
• Legitimate interest: data processing is also based on the data controller's legitimate interest in facilitating continuous contact between you and the DATA CONTROLLER in order to promote and monitor the business relationship between you (your employer, your principal) and the DATA CONTROLLER (GDPR 6 pursuant to Article 1 (1) (f).
• Consent: In some cases, consent may be required for the processing of data (pursuant to Article 6 (1) (a) of the GDPR, in particular for direct inquiries for advertising purposes).
• Legal obligation: the processing of your data may be mandatory for tax, accounting or administrative or judicial purposes (pursuant to Article 6 (1) (c) and (e) of the GDPR)

By providing personal information, you warrant that (i) you have permission to provide the personal information of the contact person you have provided (ii) you have informed the contact person of the contents of this prospectus; (iii) and you will keep and update the contact information you provide.

The data controller's legitimate interest in the processing of personal data
• Making an offer, concluding a contract, fulfilling and contacting you:
The DATA CONTROLLER, as a contracting party, has a legitimate interest in fulfilling its obligations and enforcing its rights arising from the contract. Within the framework of this, it is necessary to process the personal data of the customer and its employees, agents and senior officials who are in contact with the data controller in connection with the offer and contract, as well as in the framework of general business relations.

If you would like more detailed information about the data controller's legitimate interests and the outcome of the balance of interests, please contact us at greenwoodhungary@gmail.com.

Who has access to personal information?
Within the DATA CONTROLLER, only authorized persons may add to your personal data on the basis of the "necessary knowledge principle".

In addition to the DATA CONTROLLER, we may transfer the personal data of customers and their contacts to third parties for the following reasons:
• For certain third parties: We may transfer personal information about you to banks; we may also pass on information about you to independent external consultants (such as lawyers), such as the customer contract, in particular for the administration and payment of payments, communication with you and third parties, in order to comply with them.
• External service providers: As a data processor, you have access to the personal data we process as part of the following services and activities:
IT service provider for server and hosting services - mail system, website operation: Wix.com Ltd., 40 Namal Tel Aviv St., Tel Aviv 6350671, Israel, some of its subsidiaries and third party agents.
Billing system - data processor: Számlázz.hu, KBOSS.hu Kft., Address: 1031 Budapest, Záhony utca 7 / D.
https://www.szamlazz.hu

How long do we keep personal information?
Personal data is stored on behalf of the DATA MANAGER or our IT hosting service provider and our accountant on behalf of the DATA MANAGER, but only for as long as is necessary to fulfill our obligations and only for the time necessary to achieve the purpose for which the data was recorded. Personal information will be deleted from our records or properly anonymised if it is no longer needed. If there is a contractual relationship with you or we have made you an offer, we will keep your personal data for the duration of the civil law limitation period (ie 5 years). Personal data stored in contracts, communications and business letters are subject to statutory retention requirements, which require a retention period of at least eight years for accounting documents. However, access to personal data will then be restricted.

What are the rights of individuals?
Consent to the processing or use of personal data may be revoked at any time. Withdrawal of consent shall not affect the lawfulness of data processing prior to the withdrawal of consent. Individuals also have the following rights:

(i) Right of Access: Individuals have the right to know whether or not we have personal information about them and, if so, may request information about their personal information. Among other things, we have an obligation to answer questions about why we handle any personal information, what information we hold, and to whom we have given access to the information. However, this is not an absolute right and the interests of other persons may limit these access rights.

(ii) Right to rectification: Upon request, we have an obligation to correct inaccurate personal information or to complete incomplete personal information.

(iii) Right of Deletion (“Right to Forget”): In certain cases, we are required to delete personal data at the request of the person concerned.

(iv) Right to restrict data processing: In certain cases, we are obliged to restrict the use of personal data at the request of the data subject. In this case, the data may only be used for limited purposes specified by law.

(v) Right to data portability: Individuals have the right, under certain conditions, to receive their personal data to which they have access in a structured, commonly used and machine-readable form, and subsequently have the right to transfer such data to another data controller without to prevent them from doing so.

(vi) Right to protest:
The data subject has the right to object to the processing of his or her personal data at any time for reasons related to his or her situation, in which case we may no longer be able to process the data subject's personal data. If an individual has the right to protest and the exercise of that right is thorough, the personal data of the individual concerned will not be further processed for the purposes of the protest. There are no costs involved in exercising this right.
This right does not apply to you if the processing of personal data is necessary to take pre-contractual steps or to fulfill a contract that has already been concluded.

(vii) Right of Complaint: Individuals may also file a complaint with the National Data Protection and Freedom of Information Authority.

Contact:
We will be happy to provide further information or respond to inquiries regarding the exercise of the above rights. Such requests may be sent to the contact person designated for you or by e-mail to greenwoodhungary@gmail.com with the subject of "PRIVACY REQUEST".