Privacy policy

This Policy contains the internal rules of the data processing activities of VAVAVIN Limited Liability Company 6724 Szeged, Pacsirta utca 1, tax number 32682957 2 06 hereinafter VAVAVIN Ltd. for the purpose of complying with Regulation EU 2016 679 of the European Parliament and of the Council 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, hereinafter the Regulation and Act XXXIV of 2019.

I.
GENERAL PROVISIONS

1. § Introduction

VAVAVIN Ltd. declares that it carries out its data processing activities by adopting appropriate internal rules and technical and organisational measures so that under all circumstances they comply with Regulation EU 2016 679 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, hereinafter the Regulation and with Act CXII of 2011 on the Right of Informational Self Determination and Freedom of Information hereinafter the Info Act.

1. § Purpose of the Policy

The purpose of the Policy is to establish internal rules that ensure the controller activities of VAVAVIN Ltd. comply with the provisions of the Regulation and the Info Act.

1. § Scope of the Policy

The scope of this Policy extends to the processing of personal data relating to natural persons by VAVAVIN Ltd.

For the purposes of this Policy, sole traders, sole proprietorships and primary agricultural producers who are clients, customers or suppliers shall be regarded as natural persons.

The Policy does not apply to processing that relates to legal persons, in particular undertakings established as legal persons, including the name and form of the legal person and the data relating to the contact details of the legal person.

1. § Definitions

The relevant definitions are contained in Article 4 of the Regulation and in Act CVIII of 2001 on certain issues of electronic commerce services and information society services.

1. 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.

2. 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.

3. restriction of processing means the marking of stored personal data with the aim of limiting their processing in the future.

4. 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.

5. 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.

6. 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.

7. 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.

8. processor means a natural or legal person public authority agency or other body which processes personal data on behalf of the controller.

9. 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. 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.

10. 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 authorised to process personal data.

11. data subject s consent 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.

12. personal data breach means a breach of security leading to the accidental or unlawful destruction loss alteration unauthorised disclosure of or access to personal data transmitted stored or otherwise processed.

13. 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.

14. 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.

15. electronic commerce service means an information society service aimed at the businesslike sale procurement exchange or other use of a movable tangible good including money and securities and a natural force that can be utilised as a thing a service real estate or a right of pecuniary value.

16. electronic means means the use of wired radio optical or other electromagnetic devices performing electronic data processing storage or transmission.

17. information society service means a service provided at a distance by electronic means at the individual request of a recipient of services normally for remuneration.

18. service provided from the territory of Hungary means an information society service provided by a service provider having its registered office establishment or residence in the territory of Hungary and carrying out the actual activity related to the given service.

19. § Main applicable legal acts

Regulation EU 2016 679 of the European Parliament and of the Council General Data Protection Regulation

Act V of 2013 on the Civil Code

Act CVIII of 2001 on certain issues of electronic commerce services and information society services

Act CXII of 2011 on the Right of Informational Self Determination and Freedom of Information

Act C of 2000 on Accounting

II.
RIGHTS OF THE DATA SUBJECT

1. § Rights of the data subject

Right to prior information

The data subject has the right to be informed of facts and information relating to processing prior to the start of processing.

Regulation Articles 13 to 14

Right of access

The data subject has the right to obtain from the Controller confirmation as to whether or not personal data concerning him or her are being processed and where that is the case access to the personal data and to the information specified in the Regulation.

Regulation Article 15

Right to rectification

The data subject has the right to obtain from the Controller without undue delay the rectification of inaccurate personal data concerning him or her. 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.

Regulation Article 16

Right to erasure right to be forgotten

The data subject has the right to obtain from the Controller the erasure of personal data concerning him or her without undue delay and the Controller has the obligation to erase personal data without undue delay where one of the grounds set out in the Regulation applies.

Regulation Article 17

Right to restriction of processing

The data subject has the right to obtain from the Controller restriction of processing where the conditions set out in the Regulation apply.

Regulation Article 18

Notification obligation regarding rectification or erasure of personal data or restriction of processing

The Controller shall communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data have been disclosed unless this proves impossible or involves disproportionate effort. The Controller shall inform the data subject about those recipients if the data subject requests it.

Regulation Article 19

Right to data portability

Under the conditions set out in the Regulation the data subject has the right to receive the personal data concerning him or her which he or she has provided to VAVAVIN Ltd. in a structured commonly used and machine readable format and has the right to transmit those data to another controller without hindrance from the Controller to which the personal data have been provided.

Regulation Article 20

Right to object

The data subject has the right to object at any time on grounds relating to his or her particular situation to processing of personal data concerning him or her which is based on point e of Article 6 paragraph 1 processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller or point f of Article 6 paragraph 1 processing necessary for the purposes of the legitimate interests pursued by the controller or by a third party. In that case the 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 defence of legal claims.

Regulation Article 21

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 him or her or similarly significantly affects him or her.

Regulation Article 22

Restrictions

Union or Member State law to which the Controller or the processor is subject may restrict by way of a legislative measure the scope of the obligations and rights provided for in Articles 12 to 22 and Article 34 and the corresponding provisions in so far as it respects the essence of the fundamental rights and freedoms and is a necessary and proportionate measure in a democratic society for example national security defence public security prevention investigation detection or prosecution of criminal offences or the execution of criminal penalties including the safeguarding against and the prevention of threats to public security and similar grounds.

Regulation Article 23

Information to the data subject about a personal data breach

Where a personal data breach is likely to result in a high risk to the rights and freedoms of natural persons VAVAVIN Ltd. shall communicate the personal data breach to the data subject without undue delay.

Regulation Article 34

Right to lodge a complaint with a supervisory authority

The data subject has the right to lodge a complaint with a supervisory authority in particular in the Member State of his or her habitual residence place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes the Regulation.

Regulation Article 77

A complaint may be lodged with the Hungarian National Authority for Data Protection and Freedom of Information

Name National Authority for Data Protection and Freedom of Information
Address 1055 Budapest Falk Miksa utca 9 11
Mailing address 1363 Budapest Pf. 9
Telephone plus 36 30 683 5969 plus 36 30 549 6838 plus 36 1 391 1400
Fax plus 36 1 391 1410
Email ugyfelszolgalat at naih dot hu
Website http colon slash slash www dot naih dot hu

Right to an effective judicial remedy against a supervisory authority

Every natural and legal person has the right to an effective judicial remedy against a legally binding decision of a supervisory authority concerning it or where the supervisory authority does not handle a complaint or does not inform the data subject within three months on the progress or outcome of the complaint.

Regulation Article 78

Right to an effective judicial remedy against a controller or processor

Every data subject has the right to an effective judicial remedy where he or she considers that his or her rights under the Regulation have been infringed as a result of the processing of his or her personal data in non compliance with the Regulation.

Regulation Article 79

1. § Detailed information on the rights of the data subject

Right to prior information

The data subject has the right to be informed of facts and information relating to processing prior to the start of processing.

Information to be provided where personal data are collected from the data subject

1. When personal data relating to a data subject are collected from the data subject the controller shall at the time when personal data are obtained provide the data subject with all of the following information

a the identity and the contact details of the controller and where applicable of the controller s representative

b the contact details of the data protection officer where applicable

c the purposes of the processing for which the personal data are intended as well as the legal basis for the processing

d where the processing is based on point f of Article 6 paragraph 1 legitimate interests the legitimate interests pursued by the controller or by a third party

e the recipients or categories of recipients of the personal data if any

f where applicable the fact that the controller intends to transfer personal data to a third country or international organisation and the existence or absence of an adequacy decision by the Commission or in the case of transfers referred to in Article 46 or 47 or the second subparagraph of Article 49 paragraph 1 reference to the appropriate or suitable safeguards and the means by which to obtain a copy of them or where they have been made available.

1. In addition to the information referred to in point 1 the controller shall at the time when personal data are obtained provide the data subject with the following further information necessary to ensure fair and transparent processing

a the period for which the personal data will be stored or if that is not possible the criteria used to determine that period

b the existence of the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject and to object to processing as well as the right to data portability

c where the processing is based on point a of Article 6 paragraph 1 consent of the data subject or point a of Article 9 paragraph 2 consent of the data subject the existence of the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal

d the right to lodge a complaint with a supervisory authority

e whether the provision of personal data is a statutory or contractual requirement or a requirement necessary to enter into a contract as well as whether the data subject is obliged to provide the personal data and of the possible consequences of failure to provide such data

f the existence of automated decision making including profiling referred to in Article 22 paragraphs 1 and 4 and at least in those cases meaningful information about the logic involved as well as the significance and the envisaged consequences of such processing for the data subject.

1. Where VAVAVIN Ltd. intends to further process the personal data for a purpose other than that for which the personal data were collected the controller shall provide the data subject prior to that further processing with information on that other purpose and with any relevant further information as referred to in point 2.

2. Points 1 to 3 shall not apply where and insofar as the data subject already has the information.

Regulation Article 13

Information to be provided where personal data have not been obtained from the data subject

1. Where personal data have not been obtained from the data subject the controller shall provide the data subject with the following information

a the identity and the contact details of the controller and where applicable of the controller s representative
b the contact details of the data protection officer where applicable
c the purposes of the processing for which the personal data are intended as well as the legal basis for the processing
d the categories of personal data concerned
e the recipients or categories of recipients of the personal data if any
f where applicable that the controller intends to transfer personal data to a recipient in a third country or to an international organisation and the existence or absence of an adequacy decision by the Commission or reference to the appropriate or suitable safeguards and how to obtain a copy of them or where they have been made available.

1. In addition to the information referred to in point 1 the controller shall provide the data subject with the following further information necessary to ensure fair and transparent processing

a the period for which the personal data will be stored or if that is not possible the criteria used to determine that period

b where the processing is based on point f of Article 6 paragraph 1 legitimate interest the legitimate interests pursued by the controller or by a third party

c the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject and to object to processing as well as the right to data portability

d where processing is based on point a of Article 6 paragraph 1 consent of the data subject or point a of Article 9 paragraph 2 consent of the data subject the existence of the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal

e the right to lodge a complaint with a supervisory authority

f from which source the personal data originate and if applicable whether they came from publicly accessible sources and

g the existence of automated decision making including profiling referred to in Article 22 paragraphs 1 and 4 and at least in those cases meaningful information about the logic involved as well as the significance and the envisaged consequences of such processing for the data subject.

1. The controller shall provide the information referred to in points 1 and 2

a within a reasonable period after obtaining the personal data but at the latest within one month having regard to the specific circumstances in which the personal data are processed

b if the personal data are to be used for communication with the data subject at the latest at the time of the first communication to that data subject or

c if a disclosure to another recipient is envisaged at the latest when the personal data are first disclosed.

1. Where the controller intends to further process the personal data for a purpose other than that for which the personal data were obtained the controller shall provide the data subject prior to that further processing with information on that other purpose and with any relevant further information as referred to in point 2.

2. Points 1 to 5 shall not apply where and insofar as

a the data subject already has the information

b the provision of such information proves impossible or would involve a disproportionate effort in particular for processing for archiving purposes in the public interest scientific or historical research purposes or statistical purposes subject to the conditions and safeguards referred to in Article 89 paragraph 1 or in so far as the obligation referred to in that paragraph is likely to render impossible or seriously impair the achievement of the objectives of that processing. In such cases the controller shall take appropriate measures to protect the data subject s rights and freedoms and legitimate interests including making the information publicly available

c obtaining or disclosure is expressly laid down by Union or Member State law to which the controller is subject which provides appropriate measures to protect the data subject s legitimate interests or

d where the personal data must remain confidential subject to an obligation of professional secrecy regulated by Union or Member State law including a statutory obligation of secrecy.

Regulation Article 14

Right of access by the data subject

1. The data subject has the right to obtain from the Controller confirmation as to whether or not personal data concerning him or her are being processed and where that is the case access to the personal data and the following information

a the purposes of the processing

b the categories of personal data concerned

c the recipients or categories of recipients to whom the personal data have been or will be disclosed including recipients in third countries or international organisations

d where possible the envisaged period for which the personal data will be stored or if not possible the criteria used to determine that period

e the existence of the right to request from the Controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing

f the right to lodge a complaint with a supervisory authority

g where the personal data are not collected from the data subject any available information as to their source and

h the existence of automated decision making including profiling referred to in Article 22 paragraphs 1 and 4 and at least in those cases meaningful information about the logic involved as well as the significance and the envisaged consequences of such processing for the data subject.

1. Where personal data are transferred to a third country or to an international organisation the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.

2. VAVAVIN Ltd. shall provide a copy of the personal data undergoing processing. 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 the information shall be provided in a commonly used electronic form. The right to obtain a copy shall not adversely affect the rights and freedoms of others.

Regulation Article 15

Right to erasure right to be forgotten

1. The data subject shall have the right to obtain from the Controller the erasure of personal data concerning him or her without undue delay and the Controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies

a the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed

b the data subject withdraws consent on which the processing is based pursuant to point a of Article 6 paragraph 1 or point a of Article 9 paragraph 2 and where there is no other legal ground for the processing

c the data subject objects to the processing pursuant to Article 21 paragraph 1 and there are no overriding legitimate grounds for the processing or the data subject objects to the processing pursuant to Article 21 paragraph 2

d the personal data have been unlawfully processed

e the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the Controller is subject

f the personal data have been collected in relation to the offer of information society services referred to in Article 8 paragraph 1.

1. Where VAVAVIN Ltd. has made the personal data public and is obliged pursuant to point 1 to erase the personal data VAVAVIN Ltd. taking account of available technology and the cost of implementation shall take reasonable steps including technical measures to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to or copy or replication of those personal data.

2. Points 1 and 2 do not apply to the extent that processing is necessary

a for exercising the right of freedom of expression and information

b for compliance with a legal obligation which requires processing by Union or Member State law to which the Controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller

c for reasons of public interest in the area of public health in accordance with points h and i of Article 9 paragraph 2 and Article 9 paragraph 3

d for archiving purposes in the public interest scientific or historical research purposes or statistical purposes in accordance with Article 89 paragraph 1 in so far as the right referred to in point 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing or

e for the establishment exercise or defence of legal claims.

Regulation Article 17

Right to restriction of processing

1. The data subject shall have the right to obtain from VAVAVIN Ltd. restriction of processing where one of the following applies

a the accuracy of the personal data is contested by the data subject for a period enabling the Controller to verify the accuracy of the personal data

b the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead

c 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 defence of legal claims or

d the data subject has objected to processing pursuant to Article 21 paragraph 1 pending the verification whether the legitimate grounds of the Controller override those of the data subject.

1. Where processing has been restricted under point 1 such personal data shall with the exception of storage only be processed with the data subject s consent or for the establishment exercise or defence 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.

2. The Controller shall inform the data subject who has obtained restriction of processing before the restriction is lifted.

Regulation Article 18

Right to data portability

1. The data subject shall have the right to receive the personal data concerning him or her which he or she has provided to a Controller in a structured commonly used and machine readable format and have the right to transmit those data to another Controller without hindrance from the Controller to which the personal data have been provided where

a the processing is based on consent pursuant to point a of Article 6 paragraph 1 or point a of Article 9 paragraph 2 or on a contract pursuant to point b of Article 6 paragraph 1 and

b the processing is carried out by automated means.

1. In exercising his or her right to data portability the data subject shall have the right to have the personal data transmitted directly from one Controller to another where technically feasible.

The exercise of that right shall not adversely affect Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller.

1. The right referred to in point 1 shall not adversely affect the rights and freedoms of others.

Regulation Article 20

Right to object

1. The data subject has the right to object at any time on grounds relating to his or her particular situation to processing of personal data concerning him or her which is based on point e or f of Article 6 paragraph 1 including profiling based on those provisions. In that case the 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 defence of legal claims.

2. 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 him or her for such marketing which includes profiling to the extent that it is related to such direct marketing.

3. Where the data subject objects to processing for direct marketing purposes the personal data shall no longer be processed for such purposes.

4. At the latest at the time of the first communication with the data subject the right referred to in points 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.

5. In the context of the use of information society services and notwithstanding Directive 2002 58 EC the data subject may exercise his or her right to object by automated means using technical specifications.

6. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89 paragraph 1 the data subject shall on grounds relating to his or her particular situation have the right to object to processing of personal data concerning him or her unless the processing is necessary for the performance of a task carried out for reasons of public interest.

Regulation Article 21

Automated individual decision making including profiling

1. The data subject shall have the right not to be subject to a decision based solely on automated processing including profiling which produces legal effects concerning him or her or similarly significantly affects him or her.

2. Point 1 shall not apply if the decision

a is necessary for entering into or performing a contract between the data subject and the Controller

b is authorised 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

c is based on the data subject s explicit consent.

1. In the cases referred to in points a and c of paragraph 2 the Controller shall implement suitable measures to safeguard the data subject s rights and freedoms and legitimate interests at least the right to obtain human intervention on the part of the Controller to express his or her point of view and to contest the decision.

2. Decisions referred to in paragraph 2 shall not be based on special categories of personal data referred to in Article 9 paragraph 1 unless point a or g of Article 9 paragraph 2 applies and suitable measures to safeguard the data subject s rights and freedoms and legitimate interests are in place.

Regulation Article 22

Restrictions

1. Union or Member State law to which the Controller or processor is subject may restrict by legislative measures the scope of the obligations and rights provided for in Articles 12 to 22 and Article 34 and of Article 5 in so far as its provisions correspond to the rights and obligations provided for in Articles 12 to 22 where such a restriction respects the essence of the fundamental rights and freedoms and is a necessary and proportionate measure in a democratic society for the protection of

a national security

b defence

c public security

d the prevention investigation detection or prosecution of criminal offences or the execution of criminal penalties including the safeguarding against and the prevention of threats to public security

e other important objectives of general public interest of the Union or of a Member State in particular an important economic or financial interest of the Union or of a Member State including monetary budgetary and taxation matters public health and social security

f the protection of judicial independence and judicial proceedings

g the prevention investigation detection and prosecution of breaches of ethics for regulated professions

h monitoring inspection or regulatory function connected even occasionally with the exercise of official authority for the cases mentioned in points a to e and g

i the protection of the data subject or the rights and freedoms of others

j the enforcement of civil law claims.

1. Legislative measures referred to in paragraph 1 shall where relevant contain specific provisions at least as to

a the purposes of the processing or categories of processing

b the categories of personal data

c the scope of the restrictions introduced

d the safeguards to prevent abuse or unlawful access or transfer

e the specification of the controller or categories of controllers

f the storage periods and the applicable safeguards taking into account the nature scope and purposes of the processing or categories of processing

g the risks to the rights and freedoms of data subjects and

h the right of data subjects to be informed about the restriction unless this may prejudice the purpose of the restriction.

Regulation Article 23

Information to the data subject about a personal data breach

1. Where the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons the Controller shall communicate the personal data breach to the data subject without undue delay.

2. The communication to the data subject shall describe in clear and plain language the nature of the personal data breach and contain at least the information and measures referred to in points b c and d of Article 33 paragraph 3 of the Regulation.

3. The communication to the data subject referred to in paragraph 1 shall not be required if any of the following conditions are met

a the Controller has implemented appropriate technical and organisational protection measures and those measures were applied to the personal data affected by the personal data breach in particular those that render the personal data unintelligible to any person who is not authorised to access it such as encryption

b the Controller has taken subsequent measures which ensure that the high risk to the rights and freedoms of data subjects is no longer likely to materialise

c it would involve disproportionate effort. In such a case a public communication or similar measure whereby the data subjects are informed in an equally effective manner shall be issued.

d If the Controller has not already communicated the personal data breach to the data subject the supervisory authority having considered the likelihood of the personal data breach resulting in a high risk may require it to do so or may decide that any of the conditions referred to in paragraph 3 are met.

Regulation Article 34

Right to lodge a complaint with a supervisory authority

1. Without prejudice to any other administrative or judicial remedy every data subject shall have the right to lodge a complaint with a supervisory authority in particular in the Member State of his or her habitual residence place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes this Regulation.

2. The supervisory authority to which the complaint has been lodged shall inform the complainant of the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Article 78.

Regulation Article 77

Right to an effective judicial remedy against a supervisory authority

Without prejudice to any other administrative or non judicial remedy every natural and legal person shall have the right to an effective judicial remedy against a legally binding decision of a supervisory authority concerning them.

1. Without prejudice to any other administrative or non judicial remedy each data subject shall have the right to an effective judicial remedy where the supervisory authority which is competent under Articles 55 and 56 does not handle a complaint or does not inform the data subject within three months of the progress or outcome of the complaint lodged pursuant to Article 77.

2. Proceedings against a supervisory authority shall be brought before the courts of the Member State where the supervisory authority is established.

3. Where proceedings are brought against a decision of a supervisory authority which was preceded by an opinion or a decision of the Board in the consistency mechanism the supervisory authority shall forward that opinion or decision to the court. Regulation Article 78

Right to an effective judicial remedy against a controller or processor

1. Without prejudice to any available administrative or non judicial remedy including the right to lodge a complaint with a supervisory authority pursuant to Article 77 every data subject shall have the right to an effective judicial remedy where he or she considers that his or her rights under this Regulation have been infringed as a result of the processing of his or her personal data in non compliance with this Regulation.

2. Proceedings against a controller or processor shall be brought before the courts of the Member State where the controller or processor has an establishment. Alternatively such proceedings may be brought before the courts of the Member State where the data subject has his or her habitual residence except where the controller or processor is a public authority of a Member State acting in the exercise of its public powers.

Regulation Article 79

III.
MEASURES BASED ON A DATA SUBJECT REQUEST

1. § Person responsible for data protection

The person responsible for data protection is Vas Vanessza Vivien.

The data subject may contact the person responsible at the electronic address hello at vavavin dot com in order to exercise his or her rights.

1. § Measures based on the data subject s request

VAVAVIN Ltd. shall inform the data subject without undue delay and in any event within one month of receipt of the request of action taken on a request for the exercise of rights. That period may be extended by two further months where necessary taking into account the complexity and number of the requests. The 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 means the information shall be provided by electronic means where possible unless otherwise requested by the data subject. If VAVAVIN Ltd. 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. VAVAVIN Ltd. shall provide information under Articles 13 and 14 and any communication and any actions under Articles 15 to 22 and 34 free of charge.

Where requests from a data subject are manifestly unfounded or excessive in particular because of their repetitive character the Controller may 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.

It shall be for the Controller to demonstrate the manifestly unfounded or excessive character of the request. Where VAVAVIN Ltd. has reasonable doubts concerning the identity of the natural person making the request it may request the provision of additional information necessary to confirm the identity of the data subject.

IV.
ENSURING THE LAWFULNESS OF PROCESSING

1. § Lawfulness of processing

Processing shall be lawful only if and to the extent that at least one of the following applies

the data subject has given consent to the processing of his or her personal data for one or more specific purposes

processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

processing is necessary for compliance with a legal obligation to which the controller is subject

processing is necessary in order to protect the vital interests of the data subject or of another natural person

processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller

processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data in particular where the data subject is a child.

1. § Processing based on the data subject s consent

Where processing is based on consent the data subject s consent shall be requested by means of a consent statement. Consent shall cover all processing activities carried out for the same purpose or purposes. When the processing has multiple purposes consent should be given for all of them.

If the data subject s consent is to be given following a written declaration which also concerns other matters for example the conclusion of a sales or service contract the request for consent shall be presented in a manner which is clearly distinguishable from the other matters in an intelligible and easily accessible form using clear and plain language. Any part of such a declaration which constitutes an infringement of the Regulation shall not be binding.

It shall be as easy to withdraw as to give consent. Where personal data are collected with consent the Controller may process the collected data without further consent and also after withdrawal of consent for the purpose of complying with a legal obligation applicable to the Controller unless otherwise provided by law.

1. § Processing for compliance with a legal obligation

Processing based on a legal obligation is independent of the data subject s consent since the processing is prescribed by law.

Prior to the start of processing the data subject shall be informed that the processing is mandatory and shall be informed clearly and in detail of all facts relating to the processing of his or her data including the purpose and legal basis of the processing the person authorised to carry out the processing and processing operations the duration of the processing whether the Controller processes the personal data on the basis of a legal obligation and who may become familiar with the data. The information shall also cover the rights of the data subject and the remedies available. In the case of mandatory processing the information may also be provided by publishing a reference to the statutory provisions containing the above information.

1. § Processing based on legitimate interest

The legitimate interest of the Controller including a controller to whom personal data may be disclosed or of a third party may constitute a legal basis for processing provided that the interests or fundamental rights and freedoms of the data subject do not override those interests taking into account the data subject s reasonable expectations based on their relationship with the Controller. Such a legitimate interest may exist for example where there is a relevant and appropriate relationship between the data subject and the Controller for example where the data subject is a client or is in the service of the Controller. To establish the existence of a legitimate interest careful assessment is required including whether at the time and in the context of the collection of the personal data the data subject can reasonably expect processing for that purpose. The interests and fundamental rights of the data subject could override the interest of the Controller where personal data are processed in circumstances where data subjects do not reasonably expect further processing. Since it is for the legislator to provide by law the legal basis for the processing by public authorities the legitimate interest legal basis should not apply to processing carried out by public authorities in the performance of their tasks.

Processing that is strictly necessary for the purposes of preventing fraud may also constitute a legitimate interest. Processing of personal data for direct marketing purposes may also be regarded as carried out for a legitimate interest.

V.
DATA PROCESSING RELATED TO CUSTOMERS AND BUSINESS PARTNERS

VAVAVIN Ltd. operates the website https colon slash slash vavavin dot com.

In view of Section 13 A of Act CVIII of 2001 on certain issues of electronic commerce services and information society services and Government Decree 45 2014 II 26 on the detailed rules of contracts between consumers and businesses a purchase made on the website operated by VAVAVIN Ltd. constitutes a contract concluded between the data subject and VAVAVIN Ltd. For the purpose of concluding determining the content and amending the contract for the purpose of monitoring its performance for invoicing the fees arising from it and for the enforcement of the related claims VAVAVIN Ltd. may process the natural identification data and the residential address necessary to identify the natural person who registers or purchases in the Webshop on the legal basis of Section 13 A paragraph 1 of Act CVIII of 2001 and on the basis of consent may also process their telephone number email address bank account number and online identifier.

For invoicing VAVAVIN Ltd. may process the natural identification data the address and the data relating to the time duration and place of the use of the information society service on the legal basis of Section 13 A paragraph 2 of Act CVIII of 2001. VAVAVIN Ltd. may process personal data that are technically indispensable for providing the service. Under equal conditions VAVAVIN Ltd. shall select and operate the tools used in the provision of the information society service in such a way that personal data shall only be processed where this is indispensable for the provision of the service and for the attainment of other objectives defined by this Act and in such cases only to the extent and for the time necessary.

1. § Processing of data of natural person clients or business partners

Legal bases for processing
performance of a contract
voluntary consent
compliance with a legal obligation

Processing is also lawful where it is necessary in order to take steps at the request of the data subject prior to entering into a contract. Prior to the start of processing the natural person including the sole trader shall be informed that processing is based on performance of a contract. The information may be provided in the contract.

Recipients of personal data
VAVAVIN Ltd.
where applicable the courier processor
the accountant

Purposes of processing
performance of the contract
contact and communication
invoicing

Personal data processed
name
residential address billing or shipping address
email address
telephone number
any data necessary for the performance of the contract

Storage period
ten years from the order
upon a request for erasure any data that do not fall under Act C of 2000 on Accounting shall be erased without delay
data falling under Act C of 2000 on Accounting shall be stored for eight years from the date of issue of the invoice

General data processing workflow for natural person clients or business partners

Data processing workflow
VAVAVIN Ltd.
contract performance
VAVAVIN Ltd.
invoicing
VAVAVIN Ltd.
where applicable delivery
processor courier
complaint handling
VAVAVIN Ltd.

1. § Data processed in relation to legal person clients or business partners

Legal bases for processing
performance of a contract
voluntary consent
compliance with a legal obligation

Processing is also lawful where it is necessary in order to take steps at the request of the data subject prior to entering into a contract.

Recipients of personal data
VAVAVIN Ltd.
where applicable the courier processor
the accountant

Purposes of processing
performance of the contract
contact and communication
invoicing

Personal data processed
company name
registered office
tax number
telephone number
email address
any data necessary for the performance of the contract

Storage period
ten years from the order

upon a request for erasure any data that do not fall under Act C of 2000 on Accounting shall be erased without delay

data falling under Act C of 2000 on Accounting shall be stored for eight years from the date of issue of the invoice

General data processing workflow for legal person clients or business partners

Data processing workflow
VAVAVIN Ltd.
performance of the contract
VAVAVIN Ltd.
invoicing
VAVAVIN Ltd.
where applicable delivery
processor courier
complaint handling
VAVAVIN Ltd.

1. § Processing related to purchases on the website operated by VAVAVIN Ltd.

Legal bases for processing
performance of a contract
compliance with a legal obligation

Recipients of personal data
VAVAVIN Ltd.

Purpose of processing
settlement of the purchase price

Storage period

data falling under Act C of 2000 on Accounting shall be stored for eight years from the date of issue of the invoice

for other data ten years from the purchase

VAVAVIN Ltd. uses the card payment service of Stripe 510 Townsend Street San Francisco CA 94103 USA. Card payments are processed through Stripe s secure electronic payment interface.

The website does not have access to and does not store card data used for payment. However on the Stripe provided admin interface VAVAVIN Ltd. can view the following data

last four digits of the card
expiry date
type of card
card issuer
name on the card
email address
address
telephone number

Information about payment transactions is available at
https colon slash slash stripe dot com slash en hu slash privacy

The data subject is responsible for the accuracy of the card data provided. VAVAVIN Ltd. draws the attention of the data subject to enter the card data personally in the system and to always check the confirmation received to their email address. Stripe performs and ensures the proper execution of the payment transaction the processing of card data the encryption of the data and the security of the process.

1. § Visitor data processing

Cookies are short data files that the visited website places on the user s computer. The purpose of cookies is to facilitate and make more convenient the use of a given information and internet service. Under the guidelines of the European Commission cookies other than those strictly necessary for the use of the given service may be placed on the user s device only with the user s permission. For cookies that do not require consent information must be provided upon first visit to the website.

When visiting https colon slash slash vavavin dot com the user can accept with one click the use of cookies that are not suitable for identifying persons. If the user disables the installation of cookies in their own browser or deletes them this may limit the usability of the website or certain parts of it and settings previously provided on the given website may be lost.

Essential cookies
These cookies are necessary for the user to navigate between pages and where applicable to access protected content for example content available only to registered users.

Functional cookies
These cookies are needed for VAVAVIN Ltd. to collect information about the user s website usage such as language used automatic form filling. VAVAVIN Ltd. ensures that prior to and during the use of information society services provided on the website the visitor can at any time learn which categories of data are processed for which processing purposes including data that cannot be directly linked to the user.

Cookies used by VAVAVIN Ltd. do not store any visitor identifiers or passwords.

Further information
www dot allaboutcookies dot org
www dot aboutcookies dot org

1. § Use of Google Analytics

The website of VAVAVIN Ltd. https colon slash slash vavavin dot com uses Google Analytics a web analysis service of Google Inc. Google. Google Analytics uses cookies text files that are stored on the user s computer to help analyse how the User uses the website.

Information generated by cookies about the User s use of the website is usually transmitted to and stored by Google on servers in the United States. With IP anonymisation activated on the website Google truncates the User s IP address beforehand within the Member States of the European Union or other states party to the Agreement on the European Economic Area.

Only in exceptional cases will the full IP address be transmitted to a Google server in the United States and truncated there. On behalf of the website operator Google will use this information to evaluate the User s use of the website to compile reports on website activity and to provide other services relating to website and internet usage.

Within Google Analytics the IP address transmitted by the User s browser will not be merged with other Google data. The User can prevent the storage of cookies by selecting the appropriate settings of the browser software. In that case however not all functions of the website may be fully available.

The User can also prevent Google from collecting and processing data relating to website use generated by cookies including the IP address by downloading and installing the browser plug in available at

https colon slash slash tools dot google dot com slash dlpage slash gaoptout question mark hl equal hu

1. § Use of Google Ads

The website of VAVAVIN Ltd. https colon slash slash vavavin dot com uses Google Ads the search marketing service of Google Inc. Google. Google Ads primarily offers advertising opportunities on a pay per click basis.

Google Privacy Policy and Terms of Service
https colon slash slash policies dot google dot com slash privacy question mark hl equal hu and gl equal hu

1. § Data processing related to newsletter service

A user who registers for the newsletter service on the website may give voluntary consent to the processing of personal data and to subscribing to the newsletter by ticking the relevant box. The data subject may unsubscribe from the newsletter at any time by using the Unsubscribe function in the newsletter or by a written statement or by email which constitutes withdrawal of consent. In such a case all data of the unsubscribing person must be erased without delay.

Personal data that may be processed
name of the user
email address of the user

Purpose of processing
sending newsletters regarding the products and services of VAVAVIN Ltd.
promoting the products and services of VAVAVIN Ltd.

Legal basis
consent of the data subject

Recipients of personal data
VAVAVIN Ltd.

Storage period
for the duration of the registration or service
until the withdrawal of the data subject s consent

1. § Data processing on the Facebook page operated by VAVAVIN Ltd.

For the purpose of presenting and promoting its services VAVAVIN Ltd. maintains a Facebook page. A question asked on the Facebook page of VAVAVIN Ltd. does not qualify as an officially submitted complaint. VAVAVIN Ltd. does not process personal data published by visitors on its Facebook page.

Visitors are subject to the Data Policy and Terms of Service of Facebook. Facebook Terms are available at
https colon slash slash www dot facebook dot com slash legal slash terms

In the case of unlawful or offensive content VAVAVIN Ltd. may exclude the user without prior notice or delete the comment.

Facebook Data Policy is available at
https colon slash slash www dot facebook dot com slash privacy slash explanation

VAVAVIN Ltd. is not responsible for content or comments published by Facebook users that violate the law. VAVAVIN Ltd. is not responsible for any error outage or change of operation arising from Facebook.

1. § Data processing on the Instagram page operated by VAVAVIN Ltd.

For the purpose of presenting and promoting its services VAVAVIN Ltd. maintains an Instagram page. A question asked on the Instagram page of VAVAVIN Ltd. does not qualify as an officially submitted complaint. VAVAVIN Ltd. does not process personal data published by visitors on its Instagram page.

Visitors are subject to the Data Policy and Terms of Service of Instagram. Instagram Terms are available at
https colon slash slash help dot instagram dot com slash 581066165581870

In the case of unlawful or offensive content VAVAVIN Ltd. may exclude the user without prior notice or delete the comment.

Instagram Data Policy is available at
https colon slash slash help dot instagram dot com slash 519522125107875

VAVAVIN Ltd. is not responsible for content or comments published by Instagram users that violate the law. VAVAVIN Ltd. is not responsible for any error outage or change of operation arising from Instagram.

1. § Information on processors

For the purpose of fulfilling legal obligations arising from the contractual relationship and for the performance of the contract VAVAVIN Ltd. may transfer the personal data of clients to a processor under the conditions laid down by law.

For courier delivery the Controller uses the following processor

Processor name
GLS General Logistics Systems Hungary Csomag Logisztikai Korlátolt Felelősségű Társaság
Registered office
2351 Alsónémedi GLS Európa utca 2
Company number
01 10 049225
Tax number
12369410 2 44

For online payment the Controller uses the following processor

Processor name
Stripe
Registered office
510 Townsend Street San Francisco CA 94103 USA

VI.
DATA PROCESSING AS A PROCESSOR BY VAVAVIN LTD.

1. § Processing activities as a processor

VAVAVIN Ltd. acts as a processor in the following activities
marketing activities
graphic design activities

1. § Processor guarantees

As a processor VAVAVIN Ltd. guarantees in particular regarding expertise reliability and resources to implement the technical and organisational measures that meet the requirements of the Regulation including the security of processing. In the course of its activities VAVAVIN Ltd. ensures that persons authorised to access personal data undertake confidentiality obligations in relation to the personal data they become aware of if they are not otherwise under an appropriate statutory confidentiality obligation.

VAVAVIN Ltd. has appropriate hardware and software tools and undertakes to implement technical and organisational measures appropriate to ensure lawfulness and the protection of data subjects rights.

VAVAVIN Ltd. undertakes to make available to the controller all information necessary to demonstrate compliance with the legal provisions applicable to the use of a processor.

1. § Obligations and rights of VAVAVIN Ltd.

Right to instructions
In the course of its activities VAVAVIN Ltd. shall act solely on the basis of the written instructions of the Controller.

Confidentiality
VAVAVIN Ltd. ensures that persons authorised to access personal data undertake confidentiality obligations in relation to the personal data they become aware of if they are not otherwise under an appropriate statutory confidentiality obligation.

Data security
Taking into account the state of the art and the costs of implementation as well as the nature scope context and purposes of processing and the risk of varying likelihood and severity for the rights and freedoms of natural persons VAVAVIN Ltd. implements appropriate technical and organisational measures to ensure a level of security appropriate to the risk.

VAVAVIN Ltd. takes measures to ensure that the natural persons acting under its authority and who have access to personal data shall process the data only on instructions from the controller unless they are required to do so by Union or Member State law. VAVAVIN Ltd. ensures that access to stored data through the internal system or by direct access is granted only to authorised persons and solely in connection with the purpose of processing. VAVAVIN Ltd. ensures the necessary regular maintenance and development of the tools used. Equipment storing data is placed in a locked room with appropriate physical protection and its physical security is ensured. For the performance of tasks defined in the contract VAVAVIN Ltd. shall use persons who have appropriate knowledge and experience and shall ensure their training.

1. § Use of a sub processor

VAVAVIN Ltd. undertakes to use a sub processor only under the conditions laid down in the Regulation and the Info Act. The Controller grants a general authorisation to VAVAVIN Ltd. to engage another processor subcontractor.

Before engaging a sub processor VAVAVIN Ltd. shall inform the controller of the identity of the sub processor and the tasks to be performed. If the controller objects to the engagement based on this information the processor may use the sub processor only if the conditions specified in the objection are met. Where the processor engages a sub processor for carrying out specific processing activities on behalf of the controller the same data protection obligations as set out in the contract between the controller and the processor shall be imposed on that sub processor by way of a contract. The sub processor must provide sufficient guarantees to implement appropriate technical and organisational measures in such a manner that the processing meets the requirements of the Regulation. Where the sub processor fails to fulfil its data protection obligations the initial processor shall remain fully liable to the controller for the performance of the sub processor s obligations.

1. § Cooperation with the Controller

In the course of its activities VAVAVIN Ltd. assists the Controller by all appropriate means in facilitating the exercise of data subjects rights and the performance of related obligations. VAVAVIN Ltd. assists the Controller in complying with the obligations under Articles 32 to 36 of the Regulation taking into account the nature of processing and the information available to the processor.

VAVAVIN Ltd. makes available to the Controller all information necessary to demonstrate compliance with the obligations laid down in Article 28 of the Regulation and allows for and contributes to audits including inspections conducted by the controller or another auditor mandated by the controller. VAVAVIN Ltd. shall immediately inform the Controller if in its opinion an instruction infringes this Regulation or other Union or Member State data protection provisions. VAVAVIN Ltd. shall conclude a written contract with the client regarding the processing activities.

VII.
PROCESSING BASED ON LEGAL OBLIGATION

1. § Processing for the purpose of fulfilling tax and accounting obligations

On the legal basis of compliance with a legal obligation VAVAVIN Ltd. processes the data prescribed by law for the purpose of fulfilling tax and accounting obligations bookkeeping taxation of natural persons and legal persons entering into business relations with it.

Data processed under Act CXXVII of 2017 on Value Added Tax Sections 169 and 202 in particular
name
tax number
address registered office
tax status

Data processed under Act C of 2000 on Accounting Section 167 in particular
name
tax number
address registered office
designation of the person or organisation ordering the economic transaction
signature of the person authorising and the person certifying execution
signature of the recipient and the depositor

As a general rule under Section 169 paragraphs 1 and 3 of Act C of 2000 on Accounting VAVAVIN Ltd. shall retain in legible form for at least eight years the financial statements the business report and the supporting inventory valuation general ledger extract and the journal or other records that meet the requirements of the Act prepared for the financial year.

Accounting documents that directly or indirectly substantiate accounting records including general ledger accounts and analytical records shall be retained for at least eight years in a legible form and in a way that allows retrieval based on accounting references. The retention obligation also applies to spoiled copies of strictly accounted documents.

Recipients of personal data
VAVAVIN Ltd.
the accountant

1. § Processing of records of permanent value under the Archives Act

On the legal basis of compliance with a legal obligation VAVAVIN Ltd. processes its records that are considered to be of permanent value under Act LXVI of 1995 on public records public archives and the protection of private archival material the Archives Act with the aim of ensuring that the permanent part of VAVAVIN Ltd. s archival material remains intact and usable for future generations.

Storage period
until transfer to the public archives

VIII.
DATA SECURITY MEASURES

1. § Data security measures

For all processing operations regardless of purpose and legal basis VAVAVIN Ltd. shall take technical and organisational measures and establish procedural rules necessary to enforce the Regulation and the Info Act in order to ensure the security of personal data. VAVAVIN Ltd. protects data by appropriate measures against accidental or unlawful destruction loss alteration damage unauthorised disclosure or unauthorised access.

VAVAVIN Ltd. classifies and handles personal data as confidential. VAVAVIN Ltd. performs processing and record keeping both electronically by means of computer programs and on paper. Processing and record keeping meet data security requirements. VAVAVIN Ltd. protects its IT systems with a firewall and anti virus protection. The software ensures that only those persons can access data for a specific purpose and under controlled conditions who need such access for the performance of their tasks.

To protect personal data VAVAVIN Ltd. ensures the control of incoming and outgoing electronic communications. Paper based documents in particular personnel payroll and employment records and other documents containing personal data are stored in a lockable location so that only persons who need them for the performance of their tasks can access them.

During automated processing the controller and the processor ensure the following by additional measures
a prevention of unauthorised input of data
b prevention of the use of automated processing systems by unauthorised persons by means of data transmission equipment
c the possibility to verify and establish to which bodies personal data may be transmitted by means of data transmission equipment
d the possibility to verify and establish which personal data were entered into the automated processing systems when and by whom
e the possibility of restoring the installed systems in case of a malfunction and
f reporting of errors occurring during automated processing.

The appropriate physical protection of data and the devices and documents carrying them must be ensured.

IX.
MANAGEMENT OF PERSONAL DATA BREACHES

1. § Definition of personal data breach

Personal data breach means a breach of security leading to the accidental or unlawful destruction loss alteration unauthorised disclosure of or access to personal data transmitted stored or otherwise processed.

Regulation Article 4 point 12

1. § Handling of personal data breaches

Prevention and handling of personal data breaches and compliance with the applicable legal requirements are the tasks of VAVAVIN Ltd. Accesses and access attempts must be logged on IT systems and analysed on an ongoing basis. If VAVAVIN Ltd. detects a personal data breach in the performance of its tasks it shall examine it without delay and determine whether it is a real incident or a false alarm.

It shall be examined and established

a the time and place of the incident
b the description circumstances and effects of the incident
c the scope and number of compromised data
d the scope of persons affected by the compromised data
e the measures taken to eliminate the incident
f the measures taken to prevent mitigate or reduce damage.

In the event of a personal data breach affected systems persons and data must be identified and isolated and evidence supporting the occurrence of the incident must be collected and preserved. After this the restoration of damage and the return to lawful operation may start.

1. § Register of personal data breaches

A register shall be kept of personal data breaches which shall include

a the categories of personal data affected
b the scope and number of persons affected
c the time of the personal data breach
d the circumstances and effects of the personal data breach
e measures taken to remedy the personal data breach
f other data specified by the law ordering the processing.

1. § Levels of personal data breaches

Low level a case of unlawful processing where an insignificant scope of personal data is disclosed transferred altered destroyed intentionally or accidentally or otherwise unlawfully processed.

Medium level a case of unlawful processing where a small scope of personal data is disclosed transferred altered destroyed intentionally or accidentally or otherwise unlawfully processed.

High level a case where a wide scope of personal data is disclosed transferred altered destroyed intentionally or accidentally or otherwise unlawfully processed and every case where an adverse effect on the data subject is likely or certain.

Data relating to personal data breaches recorded in the register shall be retained for five years.

X.
FINAL PROVISIONS

1. § Establishment and amendment of the Policy

The Policy shall be established and amended by VAVAVIN Ltd.

1. § Entry into force of the Policy

This Policy shall be published and communicated at VAVAVIN Ltd. in the manner customary locally and shall enter into force upon such communication.

1. § Measures for the communication of the Policy

The provisions of this Policy shall be communicated to all business partners clients of VAVAVIN Ltd. and it shall be prescribed at all places where partners enter into business relations with VAVAVIN Ltd. that compliance with and enforcement of this Policy is a material obligation for every business partner client.