Vadalarm

Introduction
The Nowton Ltd. (Headquarters: 1132 Budapest, Visegrádi utca 40, hereinafter referred to as the service provider, data controller) acknowledges the content of this legal notice as binding. It undertakes that all data processing related to its activities complies with the expectations set forth in this regulation, the applicable national laws, and the legal acts of the EU. Data protection guidelines related to Nowton Ltd.'s data processing are continuously available at https://www.vadalarm.hu/adatvedelem.
Nowton Ltd. reserves the right to change this notice at any time. It will inform its clients of any changes in due time. If you have any questions regarding this notice, please write to us, and our colleague will answer your question soon!
Nowton Ltd. is committed to protecting the personal data of its clients and partners, and considers it highly important to respect its clients' right to informational self-determination. Nowton Ltd. treats personal data confidentially and takes all security, technical, and organizational measures that guarantee the security of data.
Nowton Ltd. presents its data processing practices below.
Definitions
In our regulations, data protection terms have the following meanings:
Personal data: any information related to an identified or identifiable natural person (data subject). The data subject can be identified, directly or indirectly, particularly by reference to an identifier such as a name, an identification number, location data, or an online identifier.
Consent: a 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.
Objection: a declaration by the data subject objecting to the processing of their personal data and requesting the termination of data processing and the deletion of the processed data.
Data controller: 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.
Data processing: any operation or set of operations which is performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Data transfer: making the data accessible to a specified third party.
Disclosure: making the data accessible to anyone.
Data deletion: making data unrecognizable in such a way that it can no longer be restored.
Data marking: labeling data with an identifier to distinguish it.
Data blocking: labeling data with an identifier to limit its further processing for a defined period or permanently.
Data destruction: the complete physical destruction of the data carrier containing the data.
Data processing: performing technical tasks related to data processing operations, regardless of the method and tool used to perform the operations and the location of application, provided that the technical task is performed on the data.
Data processor: a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
Data set: all data processed in a single record.
Third party: a natural or legal person, public authority, agency, or body other than the data subject, data controller, data processor, or persons who, under the direct authority of the data controller or data processor, are authorized to process personal data.
EEA state: a Member State of the European Union and any other state that is a party to the agreement on the European Economic Area, as well as any state whose nationals enjoy the same legal status as EEA state nationals by virtue of an international treaty concluded between the European Union and its Member States and a state that is not a party to the agreement on the European Economic Area.
Third country: any state that is not an EEA state.
Data protection incident: 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.
Scope of personal data, purpose, legal basis, and duration of data processing
Nowton Ltd.'s data processing activities are based on voluntary consent or statutory authorization. In the case of data processing based on voluntary consent, data subjects may withdraw their consent at any stage of data processing. In certain cases, the handling, storage, and transfer of some of the provided data are allowed by law.
Nowton Ltd.'s data processing principles are in line with applicable data protection laws, particularly the following:
1. Act CXIX of 1995 on the Management of Name and Address Data for Research and Direct Marketing Purposes
2. Act C of 2000 on Accounting
3. Act CVIII of 2001 on Certain Issues of Electronic Commerce Services and Information Society Services
4. Act XLVIII of 2008 on the Basic Requirements and Certain Restrictions of Commercial Advertising
5. Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information
6. Regulation (EU) 2016/679 of the European Parliament and of the Council of 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 Directive 95/46/EC (General Data Protection Regulation, GDPR)
7. Act V of 2013 on the Civil Code

Handling customer data

General purposes of data processing:

Legal basis for data processing:

Data provided and processed during newsletter subscription
Data provided based on the subscriber's decision:
1. Email address
2. Phone number
3. First name
4. Occupation
Deadline for data deletion: Nowton Ltd. stores personal customer data provided during voluntary subscription only as long as necessary. The data of subscribers are stored until the end of the newsletter series or until the customer unsubscribes.
Transferred data:
1. Email address
2. Phone number
3. First name
4. Occupation
Data processors
- Google Ireland Ltd. – Ireland, Dublin 4, Barrow street, Gordon House (Privacy Policy)
- SalesAutopilot Ltd. – 1024 Budapest, Margit krt. 31-33. mezzanine 4. (Privacy Policy)
- Bip Communications Ltd. – 1134 Budapest, Bulcsú utca 23/b. (Privacy Policy)
- Facebook Ireland Limited – 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (Privacy Policy)
- Zapier, Inc – 243 Buena Vista Avenue Suite 508 Sunnyvale, CA 94086 United States (Privacy Policy)
- Hotjar Ltd - Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julians STJ 3141, Malta (Privacy Policy)
- Smartlook.com, s.r.o. - Šumavská 524/31, Veveří, 602 00 Brno, Czech Republic (Privacy Policy)
- LINK Mobility Hungary Ltd. - 1062 Budapest, Andrássy út 68. ground floor C11. (Privacy Policy)
- MiniCRM Plc. - 1075 Budapest, Madách Imre út 14, (Privacy Policy)
Possible consequences of not providing data: Only subscribers will receive newsletters, information, other notifications, and discounts sent by Nowton Ltd.
Registration number of data processing: NAIH-97359/2016
Data provided and processed during orders
Data provided based on the customer's decision during order:
1. Email address
2. Phone number
3. Last name
4. First name
5. Tax number
6. Residence/Temporary address
7. Billing address
8. Place and date of birth
9. Product purchased by the User during orders
10. Payment method and, in some cases, delivery method used by the User
11. Total amount of the User's purchases
12. Frequency of subscription payments by the User
13. Serial number
14. Gender
15. Data on the economy
Deadline for data deletion: Voluntary customer data provided during the order process is stored until the completion of the GTC. The storage of legally required data is carried out in compliance with the relevant law.
Transferred data:
1. Email address
2. Phone number
3. Last name
4. First name
5. Tax number
6. Residence/Temporary address
7. Billing address
8. Place and date of birth
9. Product purchased by the User during orders
10. Payment method and, in some cases, delivery method used by the User
11. Total amount of the User's purchases
12. Frequency of subscription payments by the User
13. Serial number
14. Gender
15. Data on the economy
Data processors
- Barion Payment Ltd. – 1117 Budapest, Infopark sétány 1. (Privacy Policy)
- Energens Ltd. - 1113 Budapest, Bartók Béla út 152/F.
- KBOSS.hu Ltd. – 1031 Budapest, Záhony utca 7. (Privacy Policy)
- Hungarian Post Ltd. - 1138 Budapest, Dunavirág u. 2-6 (Privacy Policy)
- Google Ireland Ltd. – Ireland, Dublin 4, Barrow street, Gordon House (Privacy Policy)
- SalesAutopilot Ltd. – 1024 Budapest, Margit krt. 31-33. mezzanine 4. (Privacy Policy)
- Bip Communications Ltd. – 1134 Budapest, Bulcsú utca 23/b. (Privacy Policy)
- Facebook Ireland Limited – 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (Privacy Policy)
- Zapier, Inc – 243 Buena Vista Avenue Suite 508 Sunnyvale, CA 94086 United States (Privacy Policy)
- Hotjar Ltd - Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julians STJ 3141, Malta (Privacy Policy)
- Smartlook.com, s.r.o. - Šumavská 524/31, Veveří, 602 00 Brno, Czech Republic (Privacy Policy)
- LINK Mobility Hungary Ltd. - 1062 Budapest, Andrássy út 68. ground floor C11. (Privacy Policy)
- MiniCRM Plc. - 1075 Budapest, Madách Imre út 14, (Privacy Policy)
Possible consequences of not providing data: Failure to place an order
Registration number of data processing: NAIH-97359/2016

Data processing on www.vadalarm.hu
1. Logging of www.vadalarm.hu server
  When visiting the Vadalarm.hu website, the recorded data of the User's computer:
  - IP address
  - Browser data
  - Security keys
  - Identifier of the device used for browsing
  - Time spent on subpages
  Purpose of data processing: These automatically recorded data are logged by the system during login, main operations, and logout to prevent and detect unauthorized intrusions. These data cannot be linked to other user personal data and are not suitable for identification.
  Duration of data processing: 30 days
  Data processors:
  - Heatmap, inc - 6724 Monroe Ave, Eldersburg, MD 21784, USA (Privacy Policy)
  - Mouseflow – 2205 152nd Ave NE, Redmond, WA 98052, United States (Privacy Policy)
  - Google Ireland Ltd. – Ireland, Dublin 4, Barrow street, Gordon House (Privacy Policy)
  - Facebook Ireland Limited – 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (Privacy Policy)
  - Zapier, Inc – 243 Buena Vista Avenue Suite 508 Sunnyvale, CA 94086 United States (Privacy Policy)
  - Onesignal – 2194 Esper anca Avenue, Santa Clara, CA 95054 (Privacy Policy)(Only for subscription to Push notifications)
2. Cookie management on www.vadalarm.hu
  Nowton Ltd. places small data packages (so-called "cookies") on the User's computer to provide personalized content.
  Purpose of data processing: The purpose of cookies is to ensure the highest quality operation of the site to enhance user experience. The User can delete cookies from their computer or set their browser to disable the use of cookies.
  Duration of data processing: 30 days
  Possible consequences of not providing data: By disabling cookies, the User acknowledges that the operation of the site will not be fully functional without cookies, and some basic services will not be available. It is not possible to log in or automatically fill out forms without cookies.
  More information about cookies is available at: http://www.adatvedelmiszakerto.hu/cookie
3. Data provided during the completion of surveys created by www.vadalarm.hu:
  Personal data that can be used for identification are not recorded during the completion of surveys.
  1. Contact
    If you would like to contact our company, you can do so through the contact details provided in this notice or on the website. Nowton Ltd. deletes all emails received, along with the sender's name, email address, date, time, and other personal data provided in the message, after 5 years from the date of data disclosure.
  2. Other data processing
    For data processing not listed in this notice, we will provide information at the time of data collection. We inform our clients that courts, prosecutors, investigative authorities, administrative authorities, the National Authority for Data Protection and Freedom of Information, the Hungarian National Bank, or other bodies authorized by law may request information, data disclosure, transfer, or the provision of documents from the data controller.
    Nowton Ltd. only discloses personal data to authorities to the extent and to the degree necessary to achieve the purpose of the request if the authority has specified the precise purpose and the scope of the data requested.
Storage of personal data, security of data processing
Nowton Ltd.'s IT systems and other data storage locations are located at the headquarters and data processors.
Nowton Ltd. selects and operates the IT tools used for personal data processing during the provision of the service in such a way that the processed data:
- is accessible to those authorized to access it (availability)
- its authenticity and authentication are ensured (data integrity)
- its invariability can be proven (data integrity)
- is protected against unauthorized access (data confidentiality).
Nowton Ltd. protects the data with appropriate measures, particularly against unauthorized access, alteration, transmission, disclosure, deletion, destruction, accidental destruction, damage, and inaccessibility due to changes in the technology used.
Nowton Ltd. ensures by appropriate technical solutions that the stored data, except where permitted by law, cannot be directly linked to and assigned to the data subject.
Considering the current state of the technology, Nowton Ltd. takes technical, organizational, and organizational measures to ensure data processing security that provides a level of protection appropriate to the risks associated with data processing.
Nowton Ltd. maintains:
1. confidentiality: it protects the information so that only those who are authorized can access it;
2. integrity: it protects the accuracy and completeness of the information and the processing method;
3. availability: it ensures that when an authorized user needs it, they can access the required information and the related tools are available.
Nowton Ltd. and its partners' IT systems and networks are equally protected against computer-assisted fraud, espionage, sabotage, vandalism, fire and flood, as well as computer viruses, computer hacking, and denial-of-service attacks. The operator ensures security with server-level and application-level protection procedures.
We inform users that electronic messages transmitted over the internet, regardless of protocol (email, web, ftp, etc.), are vulnerable to network threats that may lead to unfair activities, contract disputes, or the disclosure or modification of information. To protect against such threats, the data controller takes all precautions expected of him. The systems are monitored to record any security deviations and provide evidence in case of any security incident. System monitoring also allows for checking the effectiveness of the precautions taken.
Data controller's details, contact information
Name: Nowton Ltd.
Headquarters: 1132 Budapest, Visegrádi u. 40.
Company registration number: 01-09-370074
Registration court: Metropolitan Court of Budapest
Tax number: 27977752-2-41
Phone number: +36 30 780 7685
Email address: nowton@nowton.hu
Data Protection Officer
Name: Peter Nowacki
Phone number: +48507213387
Email address: nowapeti@gmail.com
Rights of data subjects, legal remedies
The data subject can request information about the processing of their personal data and may request the correction, deletion, restriction of processing of personal data, except for mandatory data processing, and may exercise their right to data portability and object to data processing as specified at the time of data collection and through the contact details provided above.
1. Right to information
  Nowton Ltd. takes appropriate measures to provide the data subject with all information referred to in Articles 13 and 14 of the GDPR relating to data processing in a concise, transparent, intelligible, and easily accessible form, using clear and plain language.
  The right to information can be exercised in writing through the contact details provided in the "Introduction" and "Data controller's details, contact information" sections. Detailed requests for information can be provided orally, following the verification of the data subject's identity.
2. Right of access
  The data subject has the right to obtain confirmation from the data controller as to whether or not personal data concerning them are being processed, and, where that is the case, access to the personal data and the following information: the purposes of the processing; the categories of personal data concerned; the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations; where possible, the envisaged period for which the personal data will be stored; the existence of the right to request rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; the right to lodge a complaint with a supervisory authority; where the personal data are not collected from the data subject, any available information as to their source; the existence of automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject. Where personal data are transferred to a third country or to an international organization, the data subject has the right to be informed of the appropriate safeguards relating to the transfer.
  Nowton Ltd. provides a copy of the personal data undergoing processing to the data subject. For any further copies requested by the data subject, the data controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
  The data controller provides the information within one month of receipt of the request at the latest.
3. Right to rectification
  The data subject has the right to obtain from Nowton Ltd. without undue delay the rectification of inaccurate personal data concerning them. Taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement.
4. Right to erasure
  The data subject has the right to obtain from Nowton Ltd. the erasure of personal data concerning them without undue delay, and Nowton Ltd. has the obligation to erase personal data without undue delay where one of the following grounds applies:
  - the data subject contests the accuracy of the personal data, for a period enabling the controller to verify the accuracy of the personal data;
  - the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
  - the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise, or defense of legal claims;
  - the data subject has objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject.
  Where processing has been restricted under this paragraph, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
  Nowton Ltd. shall inform the data subject who has obtained restriction of processing before the restriction is lifted.
5. Right to data portability
  The data subject has the right to receive the personal data concerning them, which they have provided to the data controller, in a structured, commonly used, and machine-readable format, and has the right to transmit those data to another data controller without hindrance from the data controller to which the personal data have been provided.
6. Right to object
  The data subject has the right to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them which is based on public interest or the exercise of official authority vested in the controller or the legitimate interests pursued by the controller or by a third party, including profiling based on those provisions. In such cases, the data controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defense of legal claims.
  Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning them for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
7. Automated individual decision-making, including profiling
  The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.
  This shall not apply if the decision:
  - is necessary for entering into, or performance of, a contract between the data subject and a data controller;
  - is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests; or
  - is based on the data subject's explicit consent.
8. Right to withdraw consent
  The data subject has the right to withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
9. Procedural rules
  The data controller shall provide information on action taken on a request under Articles 15 to 22 to the data subject 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.
  The data controller shall inform the data subject of any such extension within one month of receipt of the request, together with the reasons for the delay. Where the data subject makes the request by electronic form means, the information shall be provided by electronic means where possible, unless otherwise requested by the data subject.
  If the data controller does not take action on the request of the data subject, the controller shall inform the data subject 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.
  Nowton Ltd. provides the information requested by the data subject free of charge. Where requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character, the data controller may either charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested, or refuse to act on the request.
  The data controller shall inform all recipients to whom personal data have been disclosed of any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1), and Article 18, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about those recipients if the data subject requests it.
  The data controller provides a copy of the personal data undergoing processing to the data subject. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
10. Right to compensation and damages
  Any person who has suffered material or non-material damage as a result of an infringement of the data protection regulation shall have the right to receive compensation from the data controller or processor for the damage suffered. The processor shall be liable for the damage caused by processing only where it has not complied with obligations of the regulation specifically directed to processors or where it has acted outside or contrary to lawful instructions of the controller.
  Where more than one controller or processor, or both a controller and a processor, are involved in the same processing and where they are responsible for any damage caused by processing, each controller or processor shall be held liable for the entire damage.
  The controller or processor shall be exempt from liability if it proves that it is not in any way responsible for the event giving rise to the damage.
11. Right to lodge a complaint with a supervisory authority
  The data subject can lodge a complaint with the National Authority for Data Protection and Freedom of Information:
  Name: National Authority for Data Protection and Freedom of Information
  Headquarters: 1125 Budapest, Szilágyi Erzsébet fasor 22/C.
  Mailing address: 1530 Budapest, Pf.: 5.
  Fax: +36-1-391-1410
  Phone number: +36-1-391-1400
  Email address: ugyfelszolgalat@naih.hu
  Website: http://www.naih.hu

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