Data protection statement

1. Data Controller

Name: Zalakaros Family, Experience and Spa Zrt.

Title: 8749 Zalakaros, Termál út 4.

Representative of the Data Controller: Andor János Végh CEO

Contact details of the Data Controller regarding data protection:

info@zkf.hu

This notice is a unilateral undertaking by the controller in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 and the applicable national law of the Member States. This Policy may be unilaterally amended and/or withdrawn at any time by the Data Controller, by informing the Data Subjects at the same time. The information shall be provided by publication on the website or, depending on the nature of the change, by direct notification to the Data Subjects.

2. Purpose of data processing

2.1 Provision of service(s) to and in connection with natural persons:

  • Identification of the interested party, guest, distinguishing from other guests, users, interested parties
  • Contact management, contact management and registration
  • Contact details matching and updating
  • Processing of personal data necessary for the processing of sales

Legal basis for processing: consent of the data subject, fulfilment of a legal obligation.

We will process, collect, record, organise, use and store your personal data only to the extent necessary and in any case for the purposes for which it is collected, based on your prior informed and voluntary consent. In the event of non-disclosure, the Data Controller will not be able to provide the service ordered. In some cases, the processing of your data is based on legal requirements and is mandatory. In such cases, we will draw your attention to this fact. Furthermore, in certain cases, our Company or a third party may have a legitimate interest in the processing of your personal data, such as the operation, development and security of our website.

Scope of the data processed:

  • Name
  • E-mail address
  • Phone number

2.2 Contact, guestbook, prize draw, newsletter

(1) The legal basis for the processing of data in the case of contact, guestbook, prize draw and newsletter is the consent of the data subject, which the data subject shall provide on the Company's website at the

https://zkf.hu/hirlevel-feliratkozas

https://zkf.hu/ifjusagi-szallas/form

https://zkf.hu/elerhetosegek

https://zkf.hu/vendegkonyv

https://zkf.hu/nyeremenyjatek-szabalyzat

links by ticking the box next to the text and entering a security code to provide information about the processing of your data.

(2) The data subject is any natural person who clicks on a link of the Company or registers on the website and gives his/her consent to the processing of his/her personal data.

(3) Data processed in case of contact: name, e-mail address, telephone number.

(4) Data processed in the case of a guestbook: name, e-mail address, municipality.

(5) Data processed in the case of newsletter subscriptions: name, e-mail address.

(6) The purpose of data processing: to inform the data subject about the Company's services, products, changes in them, news and events.

(7) The purpose of data processing in case of contact: information, provision of free services on the website to the data subject, access to non-public content of the website.

(8) The recipients of the data (who may have access to the data) are the contact person, the employees of the data processor operating the Company's website.

(9) The data subject may request the deletion of his/her registration (personal data) at any time.

For the maintenance and management of our website, our Company uses a data processor who provides IT services (hosting service) and, within the framework of this, processes the personal data provided on the website for the duration of our contract with him/her, and the operation performed by him/her is the storage of personal data on the server.

Our IT service provider:

Company name: MORGENS Design Kft.

Registered office: 8800 Nagykanizsa, Magyar utca 79.

Company registration number: 20 09 072782

Tax number: 23964710-2-20

Representative: managing director Zoltán Katona

Phone number: +36 30 648 0047

E-mail address: sales@morgens.hu

Website: www.morgens.hu

2.3 Issuing an invoice and the mandatory documentation related to the provision of the service.

Legal basis for processing: Compliance with the law (VAT Act, Accounting Act, Personal Income Tax Act). Provision of data is a condition for the conclusion of the contract. Failure to provide the data will result in the Data Controller being unable to provide the service ordered.

Scope of the data processed:

  • Name
  • Address
  • Email address (if remote printing of invoice or e-invoice is enabled)

Possible consequence of not providing the data: failure of the service. Intended time limit for processing: expiry of the service + rules on the time limit for keeping documents required by law.

2.4 Operation of a camera surveillance system to protect:

Operation of a camera system at the Company's headquarters and premises.

  • Security of the Data Controller's headquarters/premises
  • Safeguarding the assets of the Data Controller
  • Protect the physical integrity and property of the Data Controller's employees and visitors
  • Investigating the circumstances of any accidents or crimes that may occur

Legal basis for processing: consent of the data subject to enter the Data Controller's territory despite the invitation to be monitored by a camera. The Data Controller shall carry out the activity in accordance with the provisions of Act CXXXIII of 2005 on the Protection of Persons and Property and the Rules of Private Investigation (Act on the Protection of Persons and Property and the Rules of Private Investigation).

Scope of the data processed:

  • Image of a natural person, moving image (hereinafter together referred to as "image")
  • Possible consequences of not providing the data: if the data subject does not enter the monitored premises, he/she cannot use the services of the Data Controller.
  • Planned time limit for data processing: the data controller shall store the recordings stored in the electronic video surveillance system for the period specified in the provisions of Act CXXXIII of 2005 on the Rules of Personal and Property Protection and Private Investigation (Act on the Rules of Private Investigation).

With regard to the recordings made by the electronic surveillance system, the Data Controller applies the following retention periods:

  • 3 days in general
  • In the event of damage to or suspected damage to the controller's property, use of the recordings for the shortest period necessary to achieve the purpose

After the storage period has expired, the recordings are destroyed.

2.5 Data processing in relation to the GDPR Regulation

Data management, data transfer records, data protection incidents, Data subjects' claims, issues

Legal basis for processing: Legal obligation

  • Name
  • Data protection identifier
  • Request, date, type, content, description of event
  • Result, consequence of a request for contact
  • Incident date, documentation, outcome
  • Names of participants

3. Advertising service(s), providing information to data subjects

About services, location, programmes, catering, accommodation. Legal basis for processing: Legitimate interest - The legitimate interest of the controller is the direct marketing. Scope of data processed: e-mail address, name. By using a service, the data subject has provided the controller with the following data. The data controller informs the data subject in this notice of the data processed along the lines of the activities recorded, reclassifies the purpose of the processing on the basis of legitimate interest and uses it for direct marketing purposes. Planned deadline for data processing: Until protest.

4. Who is affected

Natural persons acting on behalf of natural persons or legal persons who use the services of the controller, and the contact persons of partners under contract with the controller.

5. Information on the use of a data processor

The data controller transfers the data to the data processor(s) contracted by the data controller for the performance of the contract. The categories of recipients are IT operators, web hosting providers, web content developers.

6. Who has access to the data

The data controller shall not disclose the data to third parties, with the exception of the data processor(s) referred to in point 5. Only employees of the controller and designated employees of the processor(s) shall have access to the recorded data. The Data Protection Officer, the IT Operator and the CEO shall have access to the recordings previously made by the electronic surveillance (camera) system. The Data Subject shall, upon request, have access only to the recordings made of him or her in the presence of one of the above-mentioned persons. In all cases, access must be requested in writing to the Data Protection Officer. The Data Controller shall in all cases draw up a record of the fact of access, which shall be kept by the Company for a period of 1 year.

6.1 Persons entitled to restrict access to images from the electronic surveillance system

Restrictions on the recordings made by the electronic surveillance system may only be implemented in cases where the Data Controller has detected an event that is likely to jeopardise the purpose of the electronic surveillance system.

At the Data Subject's request, the processing of images of him or her may be restricted to the processing of images of him or her. The Data Subject must request the blocking in writing to the Data Protection Officer, indicating the purpose and the expected duration of the blocking. The Data Controller shall keep a record of each step of the blocking process for a period of 1 year.

7. Processing of data received from third parties

If the Partner does not provide his/her own data to the Data Controller, but that of another natural person, the User/Partner shall be solely responsible for having provided the data with the consent, knowledge and due information of this natural person. The Data Controller is not obliged to verify the existence of these. The Data Controller draws the attention of the Partner to the fact that if the Data Subject fails to comply with his/her obligations and therefore asserts a claim against the Data Controller, the Data Controller may pass on the asserted claim and the amount of the related damage to the Partner.

8. Rights of data subjects

  • The Data Subject may contact the Controller at the contact details indicated in point 1.
  • may ask to be informed about the processing of your personal data,
  • request the correction, amendment or integration of your data
  • object to the processing and request the erasure and blocking of your data (except for mandatory processing)
  • have a right of appeal to a court
  • complain to the supervisory authority or initiate proceedings

The Data Subject may also send it to the Controller at one of the contact addresses indicated in point 1.

  • may request the transfer of his or her data to another controller, if the processing is based on a contract or consent and is processed by the Organization through automated procedures.
  • may provide for the withdrawal of consent previously given to the processing

The Data Controller shall process or reject (with reasons) the notification within 1 month of the request being made at the latest, or in exceptional cases within a longer period permitted by law. The Data Subject shall be informed in writing of the outcome of the investigation.

8.1 Cost of information

The Company shall, for the first time, take the measures and provide the necessary information free of charge provides. If the Data Subject requests the same data for a second time within one month and the data have not changed during this period, the Data Controller will charge an administrative fee.

  • The administrative costs are calculated on the basis of the hourly cost of the current minimum wage as an hourly rate.
  • The number of working hours used for the information is calculated at the hourly rate above.
  • In addition, in the case of a paper information request, the cost of printing the reply at cost price and postage.

8.2 Refusal to provide information

If the data subject's request is clearly unfounded, if he or she is not entitled to receive the information or if the Company as data controller can prove that the Data Subject has the requested information, the data controller shall reject the request for information. If the data subject's request is excessive, in particular because of its repetitive nature, the Company may refuse to act on the request if

  • for the third time within one month, the data subject makes a request to exercise his or her rights under Articles 15 to 22 on the same subject.

8.3 Right to object

The data subject has the right to object at any time to the processing of his or her personal data on the basis of a legitimate interest or on the basis of a legal basis involving public authority. In such a case, the Company may no longer process the personal data unless it can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims. If it finds that the grounds for the objection are justified, it shall, as soon as possible, stop the processing, including the transfer and further processing. It shall inform all those to whom it has previously transferred the Data Subject's data of the objection. The processing of the request shall be free of charge, except for unfounded or excessive requests, for which the Data Controller may charge a reasonable fee corresponding to its administrative costs. If the Data Subject disagrees with the decision taken by the Controller, he or she may take the matter to court. Data protection litigation shall be subject to the jurisdiction of the courts, which may, at the choice of the Data Subject, be brought before the courts for the place of residence or domicile of the Data Subject. A foreign national may also lodge a complaint with the competent supervisory authority in his/her country of residence.

9. Disclosure of data

The controller shall not disclose to the public the recordings of the electronic surveillance system.

10. Transfers to third countries or international organisations

The Data Controller will NOT transfer the Data Subject's personal data and records to third countries or international organisations outside the European Economic Area.

11. Information on data security measures

The Data Controller processes the data in a closed system in accordance with the requirements of the Information Security Policy. The Data Controller shall ensure default and built-in data protection. To this end, the Data Controller shall apply appropriate technical and organisational measures to ensure that:

  • precisely regulates access to data;
  • allow access only to persons who need the data to perform the task for which they are collected, and then only to the minimum necessary to perform that task;
  • carefully select the data processors it engages and ensure the security of the data through an appropriate data processing contract;
  • ensure the integrity (data integrity), authenticity and protection of the data processed.

The Data Controller shall apply reasonable physical, technical and organisational security measures to protect the Data Subject's data, in particular against accidental, unauthorised or unlawful destruction, loss, alteration, disclosure, use, access or processing. The Data Controller shall immediately notify the Data Subject of any known unauthorised access to or use of personal data which is known to be of high risk to the Data Subject. The Data Controller shall, where it is necessary to transmit the Data Subject's data, ensure adequate protection of the data transmitted, for example by encrypting the data file. The Controller shall be fully responsible for the processing of the Data Subject's data carried out by third parties. The Data Controller shall also ensure that the Data Subject's data are protected against destruction or loss by appropriate and regular backups.

12. Applicable law

The legislation governing the processing carried out by the Data Controller:

  • Regulation 2016/679 (EU) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter „GDPR”),
  • Act CXII of 2011 on the Right of Informational Self-Determination and Freedom of Information (hereinafter referred to as the „Freedom of Information Act”) and Act XXXVIII of 2018 amending Act CXII of 2011 on the Right of Informational Self-Determination and Freedom of Information in the context of the European Union data protection reform, and amending other related acts
  • Act C of 2000 on Accounting (hereinafter „the Accounting Act”),
  • Act V of 2013 on the Civil Code (hereinafter „Civil Code”),
  • Act CLV of 1997 on Consumer Protection (hereinafter referred to as the „Consumer Protection Act”)
  • Act CXXXIII of 2005 on the Rules of Personal and Property Protection and Private Investigation (hereinafter referred to as the „Property Protection Act”)
  • Act CVIII of 2001 on certain aspects of electronic commerce services and information society services (”Eker tv.")
  • Act C of 2003 on Electronic Communications („Act C of 2003 on Electronic Communications”)
  • Act CLXV of 2013 on complaints and notifications of public interest (”Pktv")
  • Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions on Commercial Advertising Activities („Grtv.”)

13. Remedies

You may request information about the processing of your personal data, request the rectification, modification or integration of your personal data processed by us, object to the processing of your data and request the erasure or blocking of your data (except for mandatory processing), seek judicial remedies, lodge a complaint with a supervisory authority or initiate proceedings (https://naih.hu/panaszugyintezes-rendje.html)

Supervisory Authority: National Authority for Data Protection and Freedom of Information

Head office: 1055 Budapest, Falk Miksa utca 9-11.

Postal address: 1363 Budapest, Pf.:9

Phone: +36 (1) 391-1400, E-mail: ugyfelszolgalat@naih.hu

Zalakaros, 1 October 2022.