Dr. Kálbori Kiropraktika Egészségügyi Szolgáltató Ltd.
(1024 Budapest, Kis Rókus utca 17-19 fszt 2., taxnumber: 13493617-2-41), (further on: Service-provider, Data processor) subdues itself under the following policy.
REGULATION (EEC) No 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (27 April 2016)
on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Regulation (EC) No 95/46, the following information is provided.
Modifications to the data become effective when they appear on the webpage above.
The data manager and contact information:
Name: Dr. Kálbori Kiropraktika Egészségügyi Szolgáltató Kft.
Seat: 1024 Budapest, Kis Rókus utca 17-19 fszt 2.
Telephone: +36 (1) 336 0720
- „personal data”: any data that can be related to the Customer – especially the name, username of the customer and any knowledge characteristic for one or more physical, physiological, mental, economic, cultural, or social identity of the Customer – and any conclusion related to the Customer drawn from the data;
- „data management”: the totality of any operation or operations carried out in an automated or non-automated manner on personal data or data files, such as collecting, recording, organizing, tagging, storing, modifying or modifying, querying, inspecting, using, communicating, distributing or otherwise making available, aligning or linking, limiting, deleting or destroying;
- „data manager”: means any natural or legal person, public authority, agency or any other body that determines the purposes and means of handling personal data individually or with others, where the purposes and means of data management are defined by Union or national law, the data controller or the particular aspects of the designation of the data controller may also be defined by Union or national law;
- „data processor”: means any natural or legal person, public authority, agency or any other body that manages personal data on behalf of the data controller;
- „recipient”: is a natural or legal person, a public authority, agency or any other body with whom or with which personal data is communicated, whether or not it is a third party. Public authorities which have access to personal data in an individual investigation in accordance with Union or national law shall not be considered recipients; the management of those data by those public authorities must comply with the applicable data protection rules in accordance with the purposes of data management;
- „the contributor concerned”: a voluntary, specific and appropriate informed and explicit statement of the will of the person concerned by which he or she expresses the statement or confirmation by means of an inadvertent act of affirmation that he or she has consented to the processing of personal data concerning him or her;
- „dataprotection incident”: a security breach resulting in accidental or unlawful destruction, loss, alteration, unauthorized disclosure or unauthorized access to personal data transmitted, stored or otherwise treated.
The principles of personal data management
The personal data:
a) must be legally and fairly handled and transparent to the person concerned (“lawfulness, fairness and transparency”);
b) are collected for specified, clear and legitimate purposes and are not treated in a manner incompatible with these purposes; in accordance with Article 89 (1), no further data handling (“end-use”) for purposes of public interest archiving for scientific and historical research purposes or for statistical purposes shall not be considered incompatible with the original purpose;
c) must be appropriate and relevant to the purposes of data management and should be limited to the need (“saving of the data”);
d) must be accurate and, if necessary, up-to-date; all reasonable measures must be taken to correct or correct inaccurate personal data for the purposes of data management (“accuracy”);
e) must be stored in a form which permits the identification of the data subjects only for the time needed to manage the personal data; the retention of personal data may only take place if the personal data are processed in accordance with Article 89 (1) for public interest archiving, for scientific and historical research purposes or for statistical purposes, in accordance with the rights and subject to appropriate technical and organizational measures for the protection of their freedoms (“limited storage”);
f) shall be managed in such a way as to ensure adequate security of personal data, including the protection against unauthorized, unlawful, unintentional, loss or destruction of data (“integrity and confidentiality”) by means of appropriate technical or organizational measures.
The data processor is responsible for the above, and must be able to demonstrate compliance (“accountability”).
The data controller declares that his / her data management is carried out in accordance with the principles of this section.
- Data Processor Activity: Storage and Server Services
- Contact of the data processor:
Üllő, Gyár u.8. 2225
Telephone: (1) 348 5000
- The fact of data management, range of data: Any personal data given by the User.
- Range of data subjects: Anybody who uses the website.
- Aim of data management: To make access to the website, and the proper actuation.
- Term of data management, deadline for deletion of data: Until the termination of the agreement between the data controller and the hosting service provider or the request for cancellation of the data subject to the hosting service provider.
- The legal basis for data processing: Article 6 (1) (f) of the GDPR, as well as the CVIII Act of 2001 on certain aspects of electronic commerce services and information society services law 13 / A. § (3).
|Type of cookie||Legal basis for data handling||Duration of data management||Treated data|
|Session cookies||In accordance with the CVIII Act of 2001 on certain aspects of electronic commerce services and information society services law 13 / A. § (3)|
session until the end of a visitor’s session
|Permanent or saved cookies||In accordance with the CVIII Act of 2001 on certain aspects of electronic commerce services and information society services law 13 / A. § (3)||Until the affected person has been deleted|
Other data processor:
Winning Solutions Kft.
2131 Göd, Balassi Bálint utca 4.
+36 1 770 7696
- The fact of data handling, the range of data processed: Unique identification number, dates, times.
- The range of customers: All the people who visiting the website.
- Aim of data management: Identifying users and tracking visitors.
- Term of data management, deadline for deletion of data:
In other cases cookies last for a maximum of 1 year.
- Giving information on the rights of the Customers related to data management: Customers can delete cookies in the Tools/Settings menu of the browser generally at the menu item Data protection.
Using the google adwords conversion tracking
The online advertising program called “Google AdWords” is used by the data handler and uses the Google conversion tracking feature within its framework. Google conversion tracking is Google Inc.’s analytics service (1600 Amphitheater Parkway, Mountain View, CA 94043, USA; “Google”).
When a User accesses a web site through a Google Ad, a conversion tracking cookie is placed on your computer. These cookies have limited validity and do not contain any personal information, so the User can not be identified by them.
When the User browses on certain pages of the website and the cookie has not expired, Google and the Data Manager will also see that the User clicked on the ad.
Each Google AdWords customer receives a different cookie so that they can not be tracked through AdWords clients’ websites.
The information you receive through conversion tracking cookies is intended to make conversion statistics for your AdWords conversion tracking customers. Customers will then be informed about the number of users who have been submitted to their ad and click on a conversion tracking tag. However, they do not have access to information that could identify any user.
If you do not want to participate in conversion tracking, you can disable this by blocking cookies from being installed on your browser. Then you will not be included in conversion tracking statistics.
For more information and Google Privacy Statement, visit: www.google.de/policies/privacy
The service of Google Analytics
- This website uses the service of Google Analytics, which is the webanalyser service of the Google Inc. („Google”). The Google Analytics uses so called „cookies”, textiles, which are saved on your computer, and they help the analysis of the website usage of the Users.
- The cookies of the websites which were visited by the User and their connecting informations are sent and stored on one of the Google’s servers in the USA. With the activation of the IP-anonymisation on the websites the Google can shorten the time of the IP-anonymisation of the Users in the European Union or in the member states of the European Economic Region.
- Only in unique cases the full IP-addresses are sent to the servers of Google in the USA and they get shorten there. Operators of these websites commit the Google to use these informations for interpretations about the usage of the website, furthermore to create reports about the activity of the website, and to do their website and internet usage related duties.
- In the Google Analytics, the forwarded IP-address of the Users will not be matched with others data by the Google. The store of the cookies can be prevented in the settings of the web browsers, but in this way it can happen, if some features of the websites will not work. You can prevent Google from collecting datas about the website usage habits of the users (including IP-addresses too), if you download and setup this web browser plugin. https://tools.google.com/dlpage/gaoptout?hl=hu
Newsletter, DM activity
- According to § 6 of Act XLVIII of 2008 on the fundamental conditions of economic advertising activity the Customer may give consent in advance to the Service Provider for sending him/her advertisement and other consignment via the addresses given at registration.
- Furthermore, the Customer may give consent to the Service Provider for managing the personal data for sending advertisements bearing in mind the regulations of the present guide.
- Service Provider sends no unwanted advertisement and the Customer has the option to unsubscribe the sending of advertisements without any limitations and justification. In such case the Service Provider deletes every information – required for sending the messages – from the register and sends no further offers. Customer can unsubscribe the sending of advertisement by clicking on the link in the message.
- The fact of data collection, range of managed data and the aim of data management:
|Personal data||Aim of data management|
|Name, e-mail address.||Identification, admit of subscription on the newsletter.|
|Date of subscription||The fulfillment of technical operation.|
|IP address at the time of subscription|
The fulfillment of technical operation.
- The range of customers: All Customers subscribing for the newsletter.
- The aim of data collection: sending electronic messages (e-mail, sms, push notification) containing advertisements to the Customer giving information on actual products, discounts, new functions, etc.
- The time period of data management and the deadline of deletion of data: until the withdrawal of the consent, i.e. unsubscribing from the newsletter.
- The potential data managers entitled to know the data, the recipients of personal data: Personal data can be managed by the sales and marketing staff of the data manager in respect for the above principles.
Describe the rights of data subjects involved in data management:
- The data subject may apply to the data controller for access to, correction, deletion or limitation of the personal data concerning him or her, and
- may object to the handling of such personal data as well
- the data subject has the right to data storage and to withdraw the consent at any time.
- It is possible to initiate, delete, modify or restrict access to personal data, transferability of data, and objection to data processing in the following ways:
- By post at the address: 1024 Budapest, Kis Rókus utca 17-19 fszt 2.,
- Via e-mail: email@example.com ,
- By telephone: +36 (1) 336 0720
- The users are free to unsubscribe from the newsletters at any time, with no cost.
- The registration number of data management: NAIH-137043/2018.
- The data processor used in data management:
Central office: 1024 Budapest, Margit krt. 31-33. félemelet 4.
Mailing address: SalesAutopilot Kft. 1538 Budapest, Pf. 515.
Tel: (+36) 30 624 39 34
- The legal basis for data processing: is the contribution of the person concerned, Article 6 (1) (a), Infotv. Section 5 (1) of the Act and the Act XLVIII of 2008 on the Fundamental Terms and Limitations of Economic Advertising Activity, section 6 (5) of the Act:
The advertiser, the advertiser or the publisher of the advertisement, in the circle specified in the consent, keeps a record of the personal data of the persons making the declaration contributing to them. The data set out in this record, concerning the recipient of the advertisement, can be handled only in accordance with the consent statement and can be handed over until its revocation, and can only be transferred to a third party with the prior consent of the person concerned.
- We inform you that:
- Data management is based on your consent.
- You must provide personal information so that we can respond to the message.
- Failure to provide data has the consequences of not being able to complete your request.
The fact of data collection, range of managed data: name and public profile image of the Customer registered at Facebook/Google+/Twitter/Pinterest/YouTube/Instagram etc.
- The range of customers: All Customers registered at Facebook/Google+/Twitter/Pinterest/YouTube/Instagram etc. and gave like to the website.
- Purpose of the data collection: To share, or “like”, promote certain content elements, products, actions of the web site or the website itself on social networking sites.
- Duration of data processing, deadline for deletion of data, person of possible data controllers who are able to know the data and details of the data management rights of the data subjects: Information about the source, their handling, the method of transfer and the legal basis of the data can be consulted on the given social networking site. Data management takes place on social networking sites, so the duration of the data handling, the ways of deleting and modifying the data are governed by the rules of the respective community site.
- Legal base of data management: voluntary consent of the Customer for the management of personal data at community sites.
Customer services and other data management
- If you have question during using some of the services of the data processor, or the customer has some problem you can get in contact with the data processer on the website (on phone, e-mail, community sites, etc.).
- The data processer deletes the incoming e-mails, messages, on phone, on Facebook, etc. what contains the name and e-mail address or any other given personal information of the customer, after 2 years from the start of the service.
- For exceptional magisterial request, or in case of law accumulation the service provider is bound for guidance, information providing, transferring, or making documents available for these organisation.
- In these cases the service provider only gives personal informations for the request (if they pointed out the exact aim and the necessary informations) what are essentials for the aim of the request.
- The right of access
You are entitled to receive feedback from the data controller about whether your personal data is being processed and, if such processing is in progress, you have the right to have access to your personal information and the information listed in the decree.
2. The right of rectification
You are entitled to request the data controller to rectify any inaccurate personal information that he or she is required to do without undue delay. Taking into account the purpose of data management, you are entitled to request the supplementation of incomplete personal data, including by means of a supplementary statement.
3. The right to cancel
You are entitled to request that the data controller, without undue delay, disclose personal information about you, and that the data controller is obliged to delete personal information about you, without undue delay, under certain conditions.
4. The right to be forgiven
If the data controller has disclosed the personal data and is required to cancel it, taking reasonable steps, including technical measures, to take into account the cost of available technology and implementation, in order to inform the data controllers handling the data that you have applied for the personal data in question pointing links or deleting a duplicate or duplicate of these personal data.
5. The right to restrict data management
You are entitled to request that your data controller restricts your data handling if one of the following conditions is met:
- You dispute the accuracy of your personal data; in this case, the restriction applies to the period of time that the data controller can check the accuracy of personal data;
- Data handling is illegal and you are opposed to the deletion of data and instead asks you to restrict them;
- The data controller no longer needs personal data for data processing, but you require them to submit, enforce, or protect legal claims;
- You have objected to data manipulation; in this case, the restriction applies to the period when it is established that the legitimate reasons for the data controller have priority over your legitimate reasons.
6. The right to data storage
You are entitled to receive personal data that is made available to you by a data controller in a fragmented, widely used machine-readable format and is entitled to transfer this data to another data controller without this being obstructed by the data controller whose provided personal information to you (…)
7. The right ro pro
You are entitled to object to the handling of your personal information (…), including profiling based on these provisions, for any reason relating to your own situation.
8. Protest in case of direct business acquisition
If your personal data is handled for direct business, you are entitled to protest at any time against the handling of personal data relating to it, including profiling, if it is related to direct business acquisition. If you object to personal data being handled for direct business purposes, your personal information can no longer be handled for that purpose.
9. Automated decision-making in individual cases, including profiling
You are entitled to exclude the scope of any decision based solely on automated data handling, including profiling, which would have a bearing on it or affect it significantly.
The preceding paragraph shall not apply if the decision is:
- You are required to conclude or complete a contract between you and the data controller;
- the granting of the right to a data controller is subject to the law of the Union or of the Member States which also lays down appropriate measures to protect your rights and freedoms and legitimate interests; or
- you are based on your explicit consent.
Deadline for action
The data controller informs you of any measures taken in response to these requests without undue delay but in any way within 1 month of receipt of the request.
If necessary, it may be extended by 2 months. The controller will inform you about the extension of the deadline by indicating the cause of the delay within 1 month of receipt of the request.
If the data controller fails to take action upon your request, he or she will notify you without delay and at the latest within one month of the receipt of the request for reasons of non-action and whether you may file a complaint with a supervisory authority and exercise its right of appeal.
Security of data management
The data controller and the data processor shall take appropriate technical and organizational measures to take into account the state of science and technology and the costs of implementation, the nature, scope, circumstances and objectives of data management and the risk of varying probability and severity of natural persons’ rights and freedoms to guarantee an adequate level of data security, including, inter alia, where appropriate:
- a) the pseudonymization and encryption of personal data;
(b) ensuring, maintaining, integrity, availability and resilience of the continuing confidentiality of systems and services used to manage personal data;
(c) in the case of a physical or technical incident, the ability to restore access to personal data and the availability of data in good time;
(d) the procedure for systematic testing, assessment and evaluation of the effectiveness of technical and organizational measures taken to ensure the security of data processing.
informing the person concerned about the privacy incident
If the privacy incident is likely to pose a high risk to the rights and freedoms of natural persons, the data controller shall inform the data subject of the privacy incident without undue delay.
Information given to the data subject should be clearly and easily understood and the nature of the privacy incident must be disclosed and the name and contact details of the Data Protection Officer or other contact person providing additional information should be disclosed; the likely consequences of a data protection incident should be described; describe measures taken or planned by the data controller to remedy a data protection incident, including, where appropriate, measures to mitigate any adverse consequences of a data protection incident.
The person concerned shall not be informed if any of the following conditions are met:
- the data controller has implemented appropriate technical and organizational protection measures and applied these measures to the data covered by the data protection incident, in particular the measures, such as the use of encryption, which make it impossible for persons who are unauthorized to access personal data the data;
- after the data protection incident, the data controller has taken further measures to ensure that high risk for the rights and freedoms of the person concerned is no longer likely to be realized;
- Informing would require disproportionate efforts. In such cases, the data subject shall be informed by means of publicly disclosed information or a similar measure shall be taken to ensure that such information is equally effective.
If the data controller has not yet notified the data subject of the data protection incident, the supervisory authority may, after considering whether the privacy incident is likely to pose a high risk, may inform the data subject.
Reporting a privacy incident to the authority
The data protection incident shall be reported to the supervisory authority under Article 55 without undue delay and, if possible, no later than 72 hours after the data protection incident becomes known, unless the data protection incident is unlikely to pose a risk to the rights of natural persons and freedom. If the notification is not filed within 72 hours, the reasons for proving the delay must also be enclosed.
Complaint regarding the possible breaching of the law by the data manager can be made to the Hungarian National Authority for Data Protection and Freedom of Information:
Hungarian National Authority for Data Protection and Freedom of Information
1125 Budapest, Szilágyi Erzsébet fasor 22/C.
Mailing address: 1530 Budapest, P.O.Box: 5.
Telephone: +36 -1-391-1400
The following regulations were accounted in the course of composing the guide:
- REGULATION (EEC) No 2016/67 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (27 April 2016) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Regulation (EC) No 95/46
- 2011 CXII. Law on information self-determination and freedom of information (hereinafter: Infotv.)
- Act CVIII of 2001 – Act on Electronic Commerce and Information Society Services (especially Section 13 / A)
- Act XLVII of 2008 – Act on the Prohibition of Unfair Commercial Practices against Consumers;
- Act XLVIII. Of 2008 – the basic conditions and certain limitations of economic advertising activity (in particular Article 6)
- XC. Law of 2005 on Eletronic Freedom of Information
- Act C of 2003 on Electronic Communications (specifically Article 155)
- No. 16/2011. an opinion on the EASA / IAB Recommendation on Best Practice in Behavioral Online Advertising
- Recommendation of the National Data Protection and Information Authority on the data protection requirements for prior information
- Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Regulation (EC) No 95/46