Spa Capital Kft. (seat: H-1011 Budapest, Fő utca 14-18., registration number: 01-09-917172, email: firstname.lastname@example.org) ("we" or "us") is committed to preserving the privacy of all visitors to this website ("Website"). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
By using our Website you consent to the collection, use and transfer of the information that you provide to us in accordance with the terms of this policy.
We reserve the right to change the contents of this Website, including this policy at any time, by posting such changes on the Website. It is your responsibility to familiarise yourself with the policy regularly to ensure that you are aware of any changes. Your continued use of our Website following the posting of any such changes will constitute your acceptance of the revised policy.
When you visit, register with, or order products from our Website you may be asked to provide certain information about yourself, including your name, date of birth, gender, contact details (country, mobile phone, address, email, telephone) and size. In connection with ordering products, we will also collect payment information (e.g., credit card number and related verification information) and billing addresses. We refer to such information as “Personal Information”.
Your decision to provide Personal Information to us is voluntary, the data processing is based on consent (Section 5(1) a) of Act 112 of 2011 on the Right of Informational Self-Determination and Freedom of Information). However, if you do not provide certain information, we may not be able to accomplish some of the purposes outlined in this policy.
USE OF THE INFORMATION WE COLLECT
Your Personal Information may be used by us for any of the following purposes: (1) for account verification and to fulfil your requests for our products and services; (2) to provide you with targeted offers and advertising on email, telephone, or post, including to contact you with information and promotional materials and offers expressly addressed to you from us; (3) to contact you when necessary in connection with the sale of our products; (4) to review Website usage and operations; (5) to address problems with the Website, our business or our products and services; (6) to protect the security or integrity of the Website and our business.
If you no longer wish to be contacted in the future by us, please send an email to email@example.com and insert "unsubscribe" or "stop" as the appropriate subject heading or write to the following address: H-1011 Budapest, Fő utca 14-18. Please give your name, postal address details and your email address.
- We will retain the Personal Information provided by you for as long as is reasonably necessary for the purposes listed in this policy.
DISCLOSURE OF INFORMATION
The Personal Information you provide to us will be held on our computers in Hungary and may be accessed by or given to our staff. Access to Personal Information within our company will be limited to those who have a need to know the information for the purposes described in this policy, and may include personnel in HR, IT, Legal, Finance and Accounting and Internal Audit. All personnel within our company will generally have access to your business contact information such as name, telephone number, postal address and email address.
We may share Personal Information with the following categories of unaffiliated third parties:
Professional Advisors: accountants, auditors, lawyers, and other similar professional advisors.
Public and Governmental Authorities: entities that regulate or have jurisdiction over our company such as regulatory authorities, law enforcement, public bodies, and judicial bodies.
Corporate Transaction: a third party in connection with any proposed or actual reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of company business, assets or stock.
List of the data processors to whom we may disclose Personal Information: [*].
Similar to other commercial websites, our website utilises a standard technology called "cookies" and web server log files to collect information about how our Website is used. Information gathered through cookies and web server logs allow us to monitor Website traffic and to personalise the content of the site for you.
We employ security measures which aim to protect the information provided by you from access by unauthorised persons and against unlawful processing, accidental loss, destruction or damage. We among others implement the following security measures:
Physical: there is building security at all times plus CCTV and swipe cards before entry. Visitors are accompanied at all times. Furthermore suitable measures are in place to ensure that Personal Information is protected from accidental destruction or loss such as backups of production data stored at an alternative site and available for restore in case of failure of the primary system.
People: all staff undergo an introduction process which covers the importance of data security. All staff sign a confidentiality agreement prior to commencing employment.
Documentation: all the tasks have documented instructions. No documentation is removed from site. Printers are kept in a room with restricted access.
Technical: any electronic media requiring disposal, such as faulty hard drives or back-up tapes are disposed of securely according to the secure disposal process. Data base changes are logged in an audit trail showing the date and time of the entry /change and the user who made the entry/change.
Data: Personal Information is stored on servers located in Hungary. The virtual server is on a physical server that is stored in a closed rack in the server room. The data centre where the server is stored has ISO 270001 certification (Information Security).
ACCESSING YOUR INFORMATION, REMEDIES
You are entitled to see a copy of the Personal Information that we have collected online and that we maintain (about you). If you wish to do this, please email us at firstname.lastname@example.org. You may ask us to make changes to the Personal Information provided by you and/or held about you, to ensure that it is accurate and kept up to date. You may also request that we cease processing your Personal Information and that we delete you from our database or records.
You are also entitled to seek remedy from court or from the Hungarian National Authority for Data Protection and Freedom of Information (ügyfélszolgálat@naih.hu, 1125 Budapest, Szilágyi Erzsébet fasor 22/c, +36-1-391-1400, http://naih.hu).
- All comments, queries and other requests relating to our use of your Personal Information should be addressed the customer services team at email@example.com or by post to H-1011 Budapest, Fő utca 14-18.