PRIVACY POLICY

FOR THE DATA PROTECTION PRACTICES OF KOMETA 99 ZRT. CONCERNING THE DISTRIBUTION OF NEWSLETTERS AND ORGANIZATION OF PRIZE GAMES 1. General provisions

1.1. It is the intention of Kometa 99. Zrt (hereinafter referred to as the “Data Controller”) to protect personal details to the fullest extent possible.
In performing its activities, the Data Controller protects the personal rights of its clients and complies with all applicable legal regulations including in particular the provisions of the Civil Code of Hungary and of Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information (hereinafter referred to as the “Information Act”).

1.2. The Data Controller makes all reasonable efforts in terms of information technology (IT) and human resources (HR) management to ensure that personal details are controlled safely and cannot be accessed or obtained by unauthorized third parties.

1.3. Please be advised that the disclosure of personal details in connection with the distribution of newsletters is voluntary and that, by entering their personal details, the User grants their consent for their personal details to be controlled.
With regards to the user registrations for receiving newsletters, the Data Controller performs data control as a business activity which has been reported to the Data Protection Authority. The Data Controller has been registered with NAIH under the following reference numbers: NAIH-79657/2014 and NAIH-93873/2016

2. Type of data control used in recording data submitted in connection with newsletter subscriptions and/or prize games

2.1. Purpose of the data control activity: The purpose of the data control activity is to ensure that the Data Controller may provide persons whose details are controlled (hereinafter referred to as “Users”) with information and allow them to participate in promotional prize games.

2.2. Data control activity may only be performed legally if the affected person's consent is obtained. By voluntarily entering their personal details, each User authorizes the Data Controller to record and control such personal details for the purpose of newsletter distribution and participation in prize games. Personal details obtained by the Data Controller will not be used by the Data Contoller for any purposes other than those stated to the User at the time of entering such personal details.

2.3. Scope of information subject to the data control activity: User's name, address, electronic mailing address (i.e. e-mail address) and phone number

2.4. Entities that are entitled to the controlling and processing of personal details: Kometa 99 Zrt. and its employees working in the marketing department.

2.5. Data recording method and the term of data control: Details of Users acquired either by electronic means (i.e. online) or by phone calls are recorded and stored in paper form and/or in internal computer storage spaces. Details recorded as described above shall be deleted and destroyed by the Operator immediately upon receipt of such request from the User or 50 years after the date of recording or (if it occurs later in time) the date of participation in the last prize game or the date of dispatch of the last newsletter.

2.6. Data may be transferred to the following persons/bodies in the following cases: The Data Controller agrees to not transfer data to unauthorized persons or entities.
If a User commits unlawful act in any communication associated with newsletters, the Data Controller may attempt to identify the User in order to able to initiate required legal proceedings and may (but solely in relation to the legal proceedings in question) transfer the User's details to the competent authority in charge of the particular legal proceedings.

2.7. The User shall have the option to send e-mail notice to the Data Controller to unsubscribe from newsletters and/or ask the Data Controller to terminate data control activity on their personal details.

2.8. Rights of Users to data protection and guidelines on how to exercise such rights: Users' statutory rights and obligations are set forth in Sections 14 to 21 of the Information Act. Under the aforementioned legislation, the User shall have the right to request information and/or ask for the rectification, deletion and/or restraint of their personal details. Detailed information about the rights and obligations can be found in the aforementioned sections of the Information Act available for review at: http://njt.hu/cgi_bin/njt_doc.cgi?docid=139257.296244 (Sections 14 to 21).

2.9. Legal remedies for data controlling issues: Legal remedies available for Users falling under the scope of the data control activity are set forth in Sections 22 and 23 of the Information Act: http://njt.hu/cgi_bin/njt_doc.cgi?docid=139257.296244

For more information about the data control activity, please send your inquiry to the Data Controller of the website by e-mail at kometa@kometa.hu or contact the Hungarian National Authority for Data Protection and Freedom of Information (NAIH) – registered offices: HU-1125 Budapest, Szilágyi Erzsébet fasor 22/c; mailing address: HU-1530 Budapest, Pf.: 5.; phone number: +36 (1) 391-1400.