1. Purpose of the Privacy Policy 1
2. Data of the Data controller 1
3. Data processing activities 2
The goal of our Privacy Policy is to provide all necessary information about processing your personal data in a concise, transparent, intelligible and easily accessible form, using clear and plain language, and assist the Data subjects in exercising their rights under Section 4.
The legal basis of our duty to communicate information is Article 12 of Regulation 2016/679 of the European Parliament and Council (hereinafter referred to as: GDPR) and the relevant Hungarian data protection regulations.
In the Privacy Policy, we may define you as “data subject” in the following.
You may find further definitions concerning your personal data within the Appendix of the current Privacy Policy.
|
Name |
GCK Korlátolt Felelősségű Társaság |
|
Website |
https://ghraouichocolate.com, https://www.ghraoui.net/hu/ |
|
Registry number |
01-10-048759 (Hungarian Company registry) |
|
Registered seat |
1054 Budapest, Szabadság tér 7. Platinum Torony. ép. 8. em |
|
|
budapest@gcmchocolate.com |
|
Telephone number |
+36 70 703 2626 |
|
Tax number |
HU17783219 |
3.1. Processing concerning newsletter
In order to provide relevant information (the list and marketing material for new and seasonal products) to you, it is possible to subscribe our newsletter both in the store and on our website’s specific interface serving for this purpose. The details of such processing are described hereunder.
3.1.1. Processed personal data and purpose of processing
|
personal data |
purpose of processing |
|
name |
to address the user |
|
e-mail address |
connecting the user by newsletter |
|
location data (city, country) |
distinction between users to provide relevant information |
|
month and day of birth (optional) |
sending birthday wishes to the user and to invite him or her to our store to give him or her present for that occasion |
|
gender (male or female) |
collecting information for the determination of the gender of our customers |
|
in case of company subscriber, information concerning the workplace of the user who subscribes in the name of the company |
identification of the company subscriber |
3.1.2. Legal basis of processing
Your consent (article 6 point (1) a of GDPR).
3.1.3. Duration of processing
We process the personal data until the withdrawal of your consent. You can anytime unsubscribe our newsletter by clicking the “Unsubscribe” box. The withdrawal of your consent does not affect the lawfulness of processing based on consent before the withdrawal.
3.1.4. Mode of processing
Personal data are collected automatically and manually, in electronic form.
3.2. Processing concerning contacting
You can both contact us by phone or e-mail or order any of our products shown in our website or come to our store personally. The details of such processing are described hereunder.
3.2.1. Processed personal data and purpose of processing
|
personal data |
purpose of processing |
|
name (first name, surname) |
identification |
|
phone number |
contacting |
|
e-mail address |
contacting |
|
in case of company partner, information concerning the workplace of the user who communicates in the name of the company |
identification of the company partner |
3.2.2. Legal basis of processing
We process your personal data on your consent (section 6 paragraph 1 point a) of GDPR).
3.2.3. Duration of the processing
Until you withdraw your consent. You have the right to withdraw your consent at any time by sending us an e-mail. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
3.2.4. Mode of processing
Personal data are collected manually, in electronic form.
3.3. Processing concerning ordering
You can order any of our products shown in our website or come to our store personally. The details of such processing are described hereunder.
3.3.1. Processed personal data and purpose of processing
|
personal data |
purpose of processing |
|
name (first name, surname, title) |
identification of the purchaser or its representative |
|
address |
identification of the place of transportation |
|
phone number |
connecting the purchaser or its representative and giving information about the services |
|
e-mail address |
connecting the purchaser or its representative and giving information about the services |
3.3.2. Legal basis of processing
If the legal person purchaser’s representative provides his or her personal data for these purposes, the legal basis of processing personal data – with regard to the relevant authorial practice – is the legitimate interest of us and the purchaser company (section 6 paragraph 1 point f of GDPR). It is each party’s legitimate interest to maintain an effective business communication and to finalize the purchase. In our view – since it is the part of the representative’s scope of duty, and in case of the children’s and partner’s personal data, we need these pieces of information to make the gifts for the event – the processing of the mentioned personal data doesn’t restrict disproportionately the Data subject’s privacy and freedom of self-determination.
All the personal data you give us during the ordering of the available products are processed for the performance of the contract concluded between you and us (article 6 b) of GDPR).
3.3.3. Duration of the processing
Until the personal data are no longer necessary in relation to the purposes for which they were collected or as long as it is possible according to the relevant acts (8 years after accounting or 5 years following performance).
3.3.4. Mode of processing
Personal data are collected automatically and manually, in electronic form.
3.3.5. Provision of processing
Since we cannot perform the order without knowing any information about you, the processing is a requirement necessary to enter into a contract.
3.4. Processing concerning invoicing
After the performing of the orders we – with regard to Act C of 2000 on accounting – make out a bill. The details of such processing are described hereunder.
3.4.1. Processed personal data and purpose of processing
|
personal data |
purpose of processing |
|
name |
confirmation of the accounting |
|
address |
confirmation of the accounting |
3.4.2. Legal basis of processing
Processing is necessary for compliance with a legal obligation; with regard to section 6 paragraph 1 point f of GDPR, section 5 article 1 point b of Information Act and section 166 paragraph 1 to 3 of Act C of 2000.
3.4.3. Duration of the processing
8 years after accounting.
3.4.4. Mode of processing
Personal data are collected manually, in electronic form.
3.4.5. Provision of processing
Since we cannot perform our accounting obligations without knowing any information about you, the processing is a statutory requirement.
3.5. Processing concerning customer service
In order to answer your questions or to inspect the circumstances you requested a complaint for, we operate customer service.
3.5.1. Processed personal data and purpose of processing
|
personal data |
purpose of processing |
|
name |
identification of the user |
|
e-mail address |
connecting with the user and providing information |
|
phone number |
connecting with the user and providing information |
3.5.2. Legal basis of processing
We process the personal data we collect from you by legal obligations (article 6 point (1) c) of GDPR).
3.5.3. Duration of processing
We process your personal data as long as the relevant consumer protection acts determine it (5 years following the complaint).
3.5.4. Mode of processing
Personal data are collected automatically and manually, in electronic and paper form.
3.6. Processing concerning the dispatch and delivery of sample products
In order to provide you with samples of our products on a half-yearly basis by regular postal service, it is possible to subscribe to our samples program both in the store and on our website’s specific interface serving for this purpose. The details of such processing are described hereunder.
3.6.1. Processed personal data and purpose of processing
|
personal data |
purpose of processing |
|
name |
to address the user |
|
location data (country, postal code, city, postal address) |
distinction between users and delivering the sample product the user requested |
3.6.2. Legal basis of processing
Your consent (article 6 point (1) a of GDPR).
3.6.3. Duration of processing
We process the personal data until the withdrawal of your consent. You can anytime unsubscribe from our sample program via our website or by visiting one of our stores. The withdrawal of your consent does not affect the lawfulness of processing based on consent before the withdrawal. All postal packages underway at the time of the withdrawal will be delivered to your given postal address. Due to the nature of postal services stopping underway packages is not possible.
3.6.4. Mode of processing
Personal data are collected automatically and manually, in electronic form.
4.1. Right to access:
You have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the information featured in point 3.
4.2. Right to rectification
You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
4.3. Right to erasure:
You have the right to obtain from us the erasure of personal data concerning you without undue delay and we shall have the obligation to erase personal data without undue delay if it is mandatory according to Article 17 of GDPR.
4.4. Right to be forgotten:
If we made the personal data public and are obliged to erase your personal data, we inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data
4.5. Right to restriction of processing:
You have the right to obtain from us restriction of processing if is obligatory according to Article 18 of GDPR.
4.6. Right to data portability:
You have the right to receive the personal data concerning you, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us if is possible according to Article 20 of GDPR.
4.7. Right to object:
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (f) of Article 6(1) of GDPR (see: point 3.3.2. of the current policy). In such case, we no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
4.8. Right to complain:
You have the right to appeal to the Hungarian courts and to make a complaint to the Hungarian Supervisory Authority (https://naih.hu/).
5.1. Informing Data subjects
We communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1) and Article 18 of GDPR to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. We also inform you about those recipients on the request of yours.
5.2. Mode and deadline of notification
We provide information on action taken on a request under Articles 15 to 22 of GDPR to you without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We inform you of any such extension within one month of receipt of the request, together with the reasons for the delay. Where you make the request by electronic form means, we provided the information by electronic means where possible, unless you request it otherwise.
If we do not take action on your request, we inform you without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy (see point 4.7.).
5.3. Monitoring
If we have reasonable doubts concerning the identity of the natural person making the request, we may request the provision of additional information necessary to confirm the identity of the data subject.
5.4. Costs of measures and notifications
We provide you information and take the necessary measures free of charge.
If your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested or we refuse to act on your request.
6.1. During transporting products and sample products
The following data processor, as our contracted service providers are responsible for delivery of the ordered products or sample products to your address.
Name: TNT Express
Contact: +36 1 431 3000
6.2 Other cases of data transfer
Except the above-mentioned cases we do not sell, rent or lease our customer lists to third parties. We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is not transferred to the third party. In addition, we may share data with trusted partners to help us perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to Ghraoui Chocolate, and they are required to maintain the confidentiality of your information.
We do not use or disclose sensitive personal information, such as race, religion, or political affiliations, without your explicit consent.
We will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Ghraoui Chocolate or the site; (b) protect and defend the rights or property of Ghraoui Chocolate; and, (c) act under exigent circumstances to protect the personal safety of users of Ghraoui Chocolate, or the public.
In case of credit card payment, the following service provider is entitled to access to your credit card data: [Stripe]
We secure your personal information from unauthorized access, use or disclosure. We secure the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When personal information (such as connection data) is transmitted to other Web sites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) or HTTPS protocol.
Our employees and the employees of the data processors have the right to get acquainted with the personal data of the User, to the extent necessary, for the performance of the tasks which belong to their job. We make all technical and organizational measures that guarantee the security of the data.
7.1. Organizational measures
We provide access to our IT systems with personalized rights. The “necessary and sufficient rights” principle applies to the allocation of accesses, consequently all employees may use our IT systems and services only to the extent necessary for the performance of their duties, with the appropriate rights and for the required time. Access to IT systems and services can only be granted to a person who is not restricted for security or other reasons (e.g. conflicts of interest) and who has the professional, business and information security knowledge required to use it securely.
We and the data processors undertake strict confidentiality rules in a written statement, and we are obliged to act in accordance with these confidentiality rules during the course of our activities.
The data is stored, with the exception of the data stored by our data processors, on our own devices, in a data center. The IT devices which store data are located in an isolated, separate closed server room, protected by a multi-stage access control system subject to authorization control.
We protect our internal network with multi-level firewall protection. In all cases, a hardware firewall (border protection device) is located at the entry points of the applied public networks. The data is stored redundantly, that is, in several places, so it is protected from destruction, loss, damage, or illegal destruction due to the failure of the IT device.
Our internal networks are protected from external attacks with a multi-level, active protection against complex malicious code (e.g. virus protection). The external access to the IT systems and databases is operated by us via an encrypted data connection (VPN).
We do steps to ensure that the IT tools and software continuously comply with the generally accepted technological solutions in the market.
We develop systems, during our development, in which logging can be used to control and monitor the operations performed, and to detect incidents, such as unauthorized access.
Our server is protected and closed, located on the dedicated servers of the hosting provider.
8.1. Cookies in general
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website.
8.2. Our cookies
The names of the cookies that we use on our website, and the purposes for which they are used, are set out below:
We use Google Analytics to analyze the use of our website.
Our analytics service provider generates statistical and other information about website use by means of cookies.
The information generated relating to our website is used to create reports about the use of our website.
Our analytics service provider's privacy policy is available at: https://unas.hu/adatkezelesi-tajekoztato
8.3. Blocking cookies
Most browsers allow you to refuse to accept cookies; for example:
in Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking "Tools", "Internet Options", "Privacy" and then "Advanced";
in Firefox (version 39) you can block all cookies by clicking "Tools", "Options", "Privacy", selecting "Use custom settings for history" from the drop-down menu, and unticking "Accept cookies from sites"; and
in Chrome (version 44), you can block all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Content settings", and then selecting "Block sites from setting any data" under the "Cookies" heading.
Blocking all cookies will have a negative impact upon the usability of many websites.
If you block cookies, you will not be able to use all the features on our website.
8.4. Deleting cookies
You can delete cookies already stored on your computer; for example:
(a) in Internet Explorer (version 11), you must manually delete cookie files (you can find instructions for doing so at http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11);
(b) in Firefox (version 39), you can delete cookies by clicking "Tools", "Options" and "Privacy", then selecting "Use custom settings for history" from the drop-down menu, clicking "Show Cookies", and then clicking "Remove All Cookies"; and
(c) in Chrome (version 44), you can delete all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Clear browsing data", and then selecting "Cookies and other site and plug-in data" before clicking "Clear browsing data".
Deleting cookies will have a negative impact on the usability of many websites.
9.1. Processing for different purpose
If we intend to further process the personal data for a purpose other than that for which the personal data were collected, we provide the you prior to that further processing with information on that other purpose and with any relevant further information.
9.2. Record of processing
To comply with section 30 of GDPR, we maintain a record of processing activities under our responsibility.
9.3. Data breaches
Data breach is a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed. In case of data breach, we act according to section 33 and 34 of GDPR.
9.4. Changes to our Privacy Policy
We will occasionally update this Privacy Policy to reflect feedback. We encourage you to periodically review this Policy to be informed of how we are protecting your information.
Effective: 13 of May 2020
|
|
GCK Korlátolt Felelősségű Társaság Controller
|
Definitions
‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
‘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;
‘restriction of processing’ means the marking of stored personal data with the aim of limiting their processing in the future;
‘profiling’ means 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;
‘pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;
‘filing system’ means any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis;
‘controller’ means the 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 data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
‘processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
‘recipient’ means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;
‘third party’ means 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 authorized to process personal data;
‘consent’ of the data subject means 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;
‘personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed;
‘genetic data’ means personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person and which result, in particular, from an analysis of a biological sample from the natural person in question;
‘biometric data’ means personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images or dactyloscopic data;
‘data concerning health’ means 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;
‘enterprise’ means a natural or legal person engaged in an economic activity, irrespective of its legal form, including partnerships or associations regularly engaged in an economic activity;
group of undertakings’ means a controlling undertaking and its controlled undertakings;
‘supervisory authority’ means an independent public authority which is established by a Member State pursuant to Article 51;
‘supervisory authority concerned’ means a supervisory authority which is concerned by the processing of personal data because:
‘relevant and reasoned objection’ means an objection to a draft decision as to whether there is an infringement of this Regulation, or whether envisaged action in relation to the controller or processor complies with this Regulation, which clearly demonstrates the significance of the risks posed by the draft decision as regards the fundamental rights and freedoms of data subjects and, where applicable, the free flow of personal data within the Union;