Privacy Policy

TABLE OF CONTENTS

 

1.Introduction
2.Data controlling
1.1.Newsletter
1.2.Contact form
1.3.Cookies
3.Data Processors
4.Data security measures
5.Rights of data subjects
1.4.Right to access
1.5.Right to rectification
1.7.Right to restriction
1.8.Right to data portability
1.9.Right of objection
1.10.Right of revocation
1.11.Procedural provisions
6.Alternatives to exercising rights
1.12.The right to lodge a complaint with the supervisory authority
1.13.The right to judicial remedy
7.Data protection incidents and their circumstances, effects and the measurements taken to prevent them

 

1.INTRODUCTION

 

1.1.A ZEBRA PEN (UK) Limited Hungarian Branch Office (hereinafter: ZEBRA PEN) notifies You of the most important information related to the controlling of personal data of data subjects by issuing this privacy policy (hereinafter: Policy), in particular, of the purpose, legal basis of data controlling, storage period and scope of controlled data, further, the rights and remedies the data subjects are entitled to regarding the data controlling.

 

1.2.This Policy applies to the online appearance of ZEBRA PEN under the domain name https://zebrapeneu.com/ and to the website of ZEBRA PEN (hereinafter: Website).

 

1.3.ZEBRA PEN as the data controller, ensures that the Policy is available to the data subjects when their data are collected and that its content is disclosed to them. ZEBRA PEN reserves the right to unilaterally amend the Policy. ZEBRA PEN ensures that the relevant privacy policy in force is continuously available and viewable on the homepage of the Website.

 

1.4.ZEBRA PEN shall control the personal data provided by the data subjects to ZEBRA PEN as confidential and shall take all security, technical and organizational measures reasonably expectable from it to ensure the security of the data.

 

1.5.By personal data we mean information, on the basis of which a natural person can undoubtedly be identified. The most important personal data are the so-called identification data, e.g., name, address, telephone number, e-mail address, online ID, however, also the image and the video footage are considered personal data.

 

1.6.We kindly inform You that the Policy has been prepared in compliance with the following legislation, in particular:
  • 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) (hereinafter: GDPR);
  • Act No. CXII of 2011 on information self-determination and freedom of information (hereinafter: Data Protection Act); and
  • Act No. V of 2013 on the Hungarian Civil Code (hereinafter: Civil Code)

 

1.7.The scope of the Policy does not extend to the services and data controlling of websites, service providers to which a link on the Website leads (e.g., Facebook, Youtube, LinkedIn). These services are governed by the provisions of the privacy policy of the third party operating the service while ZEBRA PEN shall not be liable for such data controlling.

 

1.8.The Policy does not apply to data controlling carried out after the conclusion of the individual contracts. While performing the contract, the provisions concerning each data controlling are regulated by the data controlling annex of the relevant contract.

 

1.9.Data of ZEBRA PEN as controller:

 

Company name: A ZEBRA PEN (UK) Limited Hungarian Branch Office
Company’s abbreviated name: ZEBRA PEN
Registered office: H-1039 Budapest, Pünkösdfürdő utca 52.
Postal address: H-1039 Budapest, Pünkösdfürdő utca 52.
Company registration number: 01-17-001339
Registration authority: Metropolitan Court of Registration
Tax number: 28753773-2-41
Name of representative: Lázár Szilvia, branch director
E-mail: marketing@zebrapen-eu.hu
Phone: +36 1 630 9173
Website: https://zebrapeneu.com

 

2.DATA CONTROLLING

 

2.1.Newsletter

 

ZEBRA PEN sends newsletters to subscribers by using MailChimp’s newsletter sending interface operated by The Rocket Science Group LLC.

 

2.1.1.Purpose of controlling

 

ZEBRA PEN controls the personal data of the contact persons (name, contact info) of potential new contractual partners for the purpose of direct marketing activities.

 

2.1.2.Legal basis

 

Legal basis for data controlling is the prior consent of the recipient, given by subscribing to the newsletter (Article 6 Section (1) Point a) of GDPR).

 

2.1.3.Scope of data subjects

 

Persons subscribing voluntarily to the newsletter of ZEBRA PEN.

 

2.1.4.Scope of controlled data

 

While sending the newsletter ZEBRA PEN controls the following personal data of the subscriber:

  • full name
  • email address
  • phone number

 

2.1.5.Storage period

 

Should the recipient of the newsletter unsubscribe from the newsletter, ZEBRA PEN shall consider this to be a withdrawal of the recipient’s consent and shall not send further newsletters to the recipient and as from the unsubscription is detected, the recipient shall be deleted from the recipient list.

 

2.2.Contact form

 

2.2.1.Purpose of controlling

 

ZEBRA PEN controls the personal data (name, contact info) of the contact persons of potential new contractual partners for the purpose of direct marketing and stores them in its own CRM system for a specified period of time.

 

2.2.2.Legal basis

 

Based on the expressed and voluntary consent of the concerned data subject, ZEBRA PEN contacts these data subjects with advertising materials and promotional offers (Article 6 Section (1) Point a) of GDPR).

 

2.2.3.Scope of data subjects

 

The persons filling out and sending the contact form located on the Website.

 

2.2.4.Scope of controlled data

 

During the completion of the contact form, ZEBRA PEN controls the following personal data of the persons filling out the contact form:

  • full name
  • email address
  • phone number
  • address
  • company name
 

 

2.2.5.Storage period

 

The consent given during the submission of the contact form is sent by e-mail to the e-mail address order@zebrapen-eu.hu, to which the marketing staff member shall have access. If no agreement is reached between ZEBRA PEN and the company of the data subject on the basis of the requests, ZEBRA PEN shall store the data controlled in connection with the requests for 6 months, unless the data subject expressly requests further controlling of its data, after which ZEBRA PEN shall delete them immediately.

 

The data subject is entitled to withdraw its consent to data controlling for marketing purposes at any time by sending a statement to marketing@zebrapen-eu.hu, in which case ZEBRA PEN shall delete the data subject’s personal data from its records.

 

2.3.Cookies

 

The Website uses cookies. The cookie is sent by the web server to the visitor’s browser and then is returned by the browser to the server.

 

Cookies are encrypted data sets, paths that are stored by the browser of the data subject visiting the Website and shall only be interpreted together with the given server. The user’s data itself is stored by the server, not by the cookie. The next time the data subject visits the Website, its browser will read the cookie and display the information or item on the Website that originally set the cookie. Cookies are usually stored by visiting or leaving the Website. Cookies cannot be used to identify the data subject and do not affect the performance of the data subject’s device.

 

For more information about cookie technology and how cookies work, visit e.g. www.allaboutcookies.org.

 

 

2.3.1.Purpose of controlling
  • Cookies shall be used for the following purposes:
  • measurement of a website’s performance;
  • analysis of browsing.
2.3.2.Legal basis

 

The data subject is entitled to determine the conditions for storing and accessing cookies by appropriately setting its internet browser. Most browsers generally accept cookies by default. However, the data subject may completely disable cookies or set its browser to send an alert when sending a cookie. In order to prevent the reception of cookies or to apply settings, the data subject shall change the browser settings. For information on disabling or enabling cookies the data subject shall visit its browser’s “Help” menu. For popular browsers, information on setting cookies can be found at the following links:

 

By clicking on the “Accept” button, the data subject gives its expressed consent to the storage of cookies on its device (Article 6 Section (1) Point a) of GDPR).

 

More information about the cookies used to visit the Website from a mobile device can be found on the following pages:

 

2.3.3.Scope of data subjects

 

Persons visiting the Website only when giving their consent.

 

2.3.4.Scope of controlled data

 

When using cookies, ZEBRA PEN controls the following personal data of the visitors:

 

2.3.5.Storage period

 

Depending on their type, these files shall be deleted at the end of the browsing session (temporary cookies) or after a longer period of time (permanent cookies).

 

3.DATA PROCESSORS

 

A data processor is a natural or legal person who processes personal data on behalf of ZEBRA PEN as data controller.

 

ZEBRA PEN engages the following data processors for data processing:

 

Name

Registerd office and

further contact info

Description of the activity carried out

Scope of controlled data

BlazeArts Korlátolt Felelősségű Társaság

https://www.forpsi.org/hu/home

registered office: 6090 Kunszentmiklós, Damjanich u. 36. 1/8

company registration number: 03-09-109150

tax number: 12539833-2-03

E-mail: https://webmail.forpsi.com/

Phone: (+36 1) 610 5506

The host of ZEBRA PEN own website. The information You provide is stored on a server operated by the hosting provider. The data can only be accessed by our employees and the employees operating the server, however, they shall all be responsible for the secure controlling of the data. The purpose of data controlling is to ensure the operation of the Website. The personal data provided by the data subject will be processed until the end of the operation of the Website or in accordance with the contractual agreement between the Website’s operator and the hosting provider. If necessary, the data subject may also request the deletion of its data by contacting the hosting provider. The legal basis for data controlling is the consent of the data subject and data data controlling based on law. The data center is located in Ktiš, at the headquarters of INTERNET CZ, a.s.

storage and backup of Website data (including contact form submissions)

Google (Google Analytics)

https://www.google.com/about/datacenters/

ZEBRA PEN measures the traffic of the Website by using Google Analytics. Data is transmitted during the use of the service. The data transmitted are not suitable for identifying the data subject. For more information about Google’s privacy principles, go to https://www.google.com/policies/privacy/ads/ .

cookie data

The Rocket Science Group LLC

https://mailchimp.com/

The Rocket Science Group, LLC
675 Ponce de Leon Ave NE
Suite 5000
Atlanta, GA 30308 USA Products

 

The Rocket Science Group LLC is the data processor engaged by ZEBRA PEN and ZEBRA PEN ensures the security of personal data and data controlling in accordance with the GDPR through the review of the data protection regulations of The Rocket Science Group LLC.

 

data provided by the user, based on consent, for sending newsletters or for direct marketing

iWebMa Magyarország Korlátolt Felelősségű Társaság

registered office: 1061 Budapest, Király u. 26.

company registration number: 14666641-2-41

tax number: 14666641-2-41

E-mail: webma@iwebma.com
Phone: (+36 1) 786 48 45

web-developer company

website data

 

4.DATA SECURITY MEASURES

 

ZEBRA PEN takes appropriate data security measures to protect the personal data provided by data subjects. Within this scope, its IT systems, which also contain personal data stored in electronic form, are protected by a multi-level password.

 

ZEBRA PEN protects the security of personal data controlled in relation to the operation of Website with technical, organizational and physical measures, including secure servers and firewalls.

 

5.RIGHTS OF DATA SUBJECTS

 

Data subjects shall have the right to request from ZEBRA PEN access to and rectification or erasure of personal data concerning them or restriction of data controlling and to object to data controlling as well as the right to data portability.

 

ZEBRA PEN specifies below the content of certain rights to be exercised by data subjects in accordance with data controlling and certain characteristics of exercising these rights.

 

5.1.Right to access

The data subjects shall have the right to obtain confirmation from ZEBRA PEN as data controller as to whether or not personal data concerning them are being controlled. In case their personal data are being controlled, the data subjects shall have the right to access the personal data and the following information:

  • the purposes of the data controlling;
  • the categories of personal data of the data subject;
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
  • the envisaged period for which the personal data will be stored;
  • the rights of data subject in relation to data controlling (in particular the right to rectification, erasure or restriction of data controlling and to object);
  • the right to lodge a complaint with the supervisory authority;
  • any available information as to the source of data;
  • the existence of automated decision-making, including profiling and at least meaningful information about the logic involved, as well as the significance and the envisaged consequences of such data controlling for the data subjects.
 

 

ZEBRA PEN as data controller shall provide a copy of the personal data undergoing data controlling. For any further copies requested by the data subjects, ZEBRA PEN 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 by ZEBRA PEN in electronic form. The right to access shall be exercised by using the contact details provided in Section 5.8.

 

5.2.Right to rectification

The data subjects shall have the right to request the rectification of inaccurate personal data concerning them and ZEBRA PEN shall comply with such request without undue delay. Taking into account the purposes of the data controlling, the data subjects shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

 

5.3.Right to erasure (right to be forgotten)

The data subjects shall have the right to have ZEBRA PEN erase personal data concerning them without undue delay. ZEBRA PEN shall erase the personal data of data subjects without undue delay, if:

 

(i)the purposes or the legal basis of data controlling ceased to exist;
(ii)the data subject objects to the data controlling and there are no overriding legitimate grounds for the data controlling;
(iii)the personal data have been unlawfully controlled; or
(iv)the personal data have to be erased for compliance with a legal obligation in European Union or Member State law to which ZEBRA PEN as data controller is subject.

 

ZEBRA PEN shall refuse to erase the personal data of data subjects, if the data controlling is necessary for compliance with a legal obligation which requires data controlling by European Union or Member State law to which ZEBRA PEN is subject or for the submission, assertion or defense of legal claims.

 

5.4.Right to restriction

The data subjects shall have the right to obtain from ZEBRA PEN restriction of controlling their personal data, if:

 

(i)the accuracy of the personal data is contested (in this case the restriction shall apply for a period enabling the controller to verify the accuracy of the personal data); or
(ii)the data controlling of ZEBRA PEN is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; or
(iii)ZEBRA PEN no longer needs the personal data for the purposes of the data controlling, but they are required by the data subject for the submission, assertion or defense of legal claims; or
(iv)the data subject has objected to data controlling.

 

Should data controlling be restricted, such personal data shall, with the exception of storage, only be controlled with the data subject’s consent or for the submission, assertion 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 European Union or of a Member State.

 

5.5.Right to data portability

The data subjects shall have the right to receive the personal data concerning them, which they have provided to ZEBRA PEN, in a structured, commonly used and machine-readable format and to transmit such data to another controller if the data controlling is based on consent or a contract and the data controlling is carried out by automated means.

In exercising the right to data portability, the data subjects shall have the right to have the personal data transmitted directly from one controller to another, if technically feasible.

 

5.6.Right of objection

The data subjects shall additionally have the right to object at any time to controlling of personal data concerning them for direct marketing purposes, which includes profiling. In such cases the personal data shall no longer be controlled for such purposes.

 

In case the data subject objects, ZEBRA PEN shall no longer control the personal data unless ZEBRA PEN demonstrates compelling legitimate basis for the data controlling which override the interests, rights and freedoms of the data subject or for the submission, assertion or defense of legal claims.

 

5.7.Right of revocation

The data subjects shall have the right to revoke their consent at any time. The consent of the data subjects shall be deemed as the legal basis for the data controlling in case of the data controlling purposes set forth in Section 2 of this Policy. The legal basis for the data controlling shall not affect the lawfulness of data controlling based on consent before its revocation, thus the prior data controlling of ZEBRA PEN based on consent is not rendered unlawful by the fact that the data subjects subsequently revoke their consent.

 

5.8.Procedural provisions

The data subjects can notify ZEBRA PEN of their request to exercise any of their rights related to data controlling by the following contact details:

  • personally, at the registered office of ZEBRA PEN: H-1039 Budapest, Pünkösdfürdő utca 52.
  • in writing by mail: H-1039 Budapest, Pünkösdfürdő utca 52.
  • electronically: order@zebrapen-eu.hu / marketing@zebrapen-eu.hu

 

ZEBRA PEN shall provide the data subject with information on the evaluation of the request and the measures taken without undue delay, but within 1 (one) month of receipt of the request, at the latest. In case the data subject submits a large number of requests, or his/her request is particularly complex, ZEBRA PEN may extend the 1 (one) month period by 2 (two) additional months but shall inform the data subject on the justification and reasons of such extension within 1 (one) month of receipt of the request. The data subject is notified by ZEBRA PEN on its decision in writing or by electronic means, where the request was submitted by electronic means.

 

In case ZEBRA PEN does not take measures on the request of the data subject, ZEBRA PEN shall inform the data subject without delay but within 1 (one) month of receipt of the request at the latest of the reasons for not taking measures and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.

 

The above information and measure shall be provided by ZEBRA PEN free of charge.

 

Should requests from a data subject be manifestly unfounded or excessive, in particular because of their repetitive character, ZEBRA PEN as data controller may either, considering the administrative costs of providing the information or notification or taking the measure requested:

 

(i)charge a reasonable fee; or
(ii)refuse to act on the request.

 

ZEBRA PEN is obliged to demonstrate the manifestly unfounded or excessive character of the request.

 

The detailed provisions of the rights of data subjects related to data controlling are specified in Chapter III „Rights of data subject” of GDPR and in Sections 14-21 of Data Protection Act.

 

6.ALTERNATIVES TO EXERCISING RIGHTS

 

Within the scope of alternatives to exercising rights, the data subjects may initiate two procedures, which are described by ZEBRA PEN below:

 

6.1. Right to lodge a complaint with a supervisory authority

The data subjects shall have the right to lodge a complaint with National Authority for Data Protection and Freedom of Information (hereinafter: NAIH) as supervisory authority, if the data subjects consider that the controlling of personal data concerning them infringes the provisions of GDPR.

 

The contact details of NAIH:

 

Registered office: H-1125 Budapest, Szilágyi Erzsébet fasor 22/c.
Postal address: 1530 Budapest, Pf. 5
Phone: +36 1 391 1400
Official electronic mail address: ugyfelszolgalat@naih.hu
The website of NAIH: https://naih.hu

 

6.2. Right to judicial remedy

The data subjects shall additionally have the right to judicial remedy (i) against a legally binding decision of the supervisory authority concerning them, (ii) if the supervisory authority does not handle a complaint or (iii) does not inform the data subjects within 3 (three) months on the progress or outcome of the complaint lodged. The data subjects may, at their own discretion, bring the proceedings before the competent regional court where the data subjects have their residential address or place of stay.

 

7.DATA PROTECTION INCIDENTS AND THEIR CIRCUMSTANCES, EFFECTS AND THE MEASUREMENTS TAKEN TO PREVENT THEM

 

The personal data breach shall mean 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 controlled.

 

In case of a personal data breach, ZEBRA PEN shall, without undue delay, and where feasible, not later than 72 hours after having become aware of it, notify the competent supervisory authority on the personal data breach, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of the data subjects. To ensure this, ZEBRA PEN shall take all necessary measures.

 

ZEBRA PEN shall notify the data subjects on the personal data breach without undue delay if it is likely to result in a high risk. In such case ZEBRA PEN shall, in the notification addressed to the data subjects, describe in clear and plain language the nature of the personal data breach, the likely consequences of the personal data breach and the measures taken or proposed to be taken to remedy the personal data breach, including, if applicable, measures to mitigate its possible adverse effects.

 

 

__ July 2021

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