P.K. Parking Kft

The purpose of this notice is to record the data protection and data management principles applied by PK Parking Ltd. (hereinafter referred to as: Data Controller), which the Data Controller recognizes as binding for itself, and to inform the Data Subjects of their rights regarding data processing, under Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter: GDPR Regulation) and Act CXII of 2011 on the right of informational self-determination and on freedom of information (hereinafter: Infotv.).

The Data Controller undertakes to ensure that all data processing related to its activities complies with the requirements set out in the applicable laws, handles the data confidentially, and implements technical and organizational measures to ensure secure data management and to maintain confidentiality and data integrity.

Definitions:

The terms used in this notice must be interpreted as defined in Article 4 of Chapter 1 of the GDPR Regulation, as follows:
“personal data”: any information relating to an identified or identifiable natural person (“Data Subject”); a natural person is identifiable if they can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person;
“processing”: 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, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
“data subject”: any identified or identifiable natural person based on personal data—directly or indirectly;
“restriction of processing”: the marking of stored personal data with the aim of limiting their processing in the future;
“profiling”: 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;
“pseudonymisation”: 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 organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;
“filing system”: any structured set of personal data which are accessible according to specific criteria, whether centralized, decentralized or dispersed on a functional or geographical basis;
“controller”: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; 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;
“processor”: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
“recipient”: a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, 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;
“third party”: 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 authorized to process personal data;
“data subject’s consent”: any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them;
“personal data breach”: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed;
“genetic data”: 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;
“biometric data”: 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;
“health data”: personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about their health status;
“main establishment”:
a) as regards a controller with establishments in more than one Member State, the place of its central administration in the Union, unless the decisions on the purposes and means of the processing of personal data are taken in another establishment of the controller in the Union and the latter establishment has the power to have such decisions implemented, in which case the establishment having taken such decisions is to be considered to be the main establishment;
b) as regards a processor with establishments in more than one Member State, the place of its central administration in the Union; if the processor has no central administration in the Union, the establishment of the processor in the Union where the main processing activities in the context of the activities of an establishment of the processor take place, to the extent that the processor is subject to specific obligations under this Regulation;
“representative”: a natural or legal person established in the Union who, designated in writing by the controller or processor pursuant to Article 27, represents the controller or processor with regard to their respective obligations under this Regulation;
“enterprise”: a natural or legal person engaged in an economic activity, irrespective of its legal form, including partnerships or associations regularly engaged in an economic activity;
“group of undertakings”: a controlling undertaking and its controlled undertakings;
“binding corporate rules”: personal data protection policies adhered to by a controller or processor established on the territory of a Member State for transfers or a set of transfers of personal data to a controller or processor in one or more third countries within a group of undertakings, or group of enterprises engaged in a joint economic activity;
“supervisory authority”: an independent public authority which is established by a Member State pursuant to Article 51;
“cross-border processing of personal data”:
a) processing of personal data which takes place in the context of the activities of establishments in more than one Member State of a controller or processor in the Union, where the controller or processor is established in more than one Member State; or
b) processing of personal data which takes place in the context of the activities of a single establishment of a controller or processor in the Union but which substantially affects or is likely to substantially affect data subjects in more than one Member State;
“relevant and reasoned objection”: an objection to a draft decision as to whether there is an infringement of this Regulation, or whether envisaged action in relation to the controller or processor complies with this Regulation, which clearly demonstrates the significance of the risks posed by the draft decision as regards the fundamental rights and freedoms of data subjects and, where applicable, the free movement of personal data within the Union;
“information society service”: a service as defined in Article 1(1)(b) of Directive (EU) 2015/1535;
“international organization”: an organization and its subordinate bodies governed by public international law, or any other body which is set up by, or on the basis of, an agreement between two or more countries.

Data Controller’s details:
Company name: P.K. Parking Ltd.
Registered seat: 2220 Vecsés, 0182/77. hrsz.
Tax number: 26794523-2-13
Phone: +36/70-387-6585
Email: pkparkingkft@gmail.com

Purpose of data processing:
The purpose of the processing in every case is specified in the attached “Consent to Data Processing Statement and Information.” When providing services, the collection and processing of personal data always relies on the voluntary consent of the Data Subject or on a contractual legal relationship.

The Data Controller handles all recorded personal data in accordance with the current data protection legislations—especially the GDPR Regulation and Infotv.—and processes them as described in this notice.

Principles relating to the processing of personal data:
Regarding the processing of personal data, the Data Controller observes and applies the following principles:
Lawfulness, fairness and transparency: personal data are processed lawfully, fairly and in a transparent manner.
Purpose limitation: personal data are collected for specified, explicit and legitimate purposes and not further processed in a manner incompatible with those purposes. Further processing for archiving in the public interest, scientific or historical research, or statistical purposes shall not be considered incompatible with the original purposes according to the GDPR Regulation.
Data minimization: personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
Accuracy: personal data are accurate and kept up to date. The Controller takes every reasonable step to erase or rectify inaccurate personal data without delay.
Storage limitation: personal data are stored in a form which permits the identification of Data Subjects for no longer than is necessary for the purposes for which the personal data are processed. Personal data may be stored for longer periods only if they will be processed solely for archiving in the public interest, scientific or historical research, or statistical purposes, subject to appropriate technical and organizational measures as required by the Regulation for the safeguard of the rights and freedoms of the Data Subjects.
Integrity and confidentiality: personal data are processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing, accidental loss, destruction or damage, using appropriate technical or organizational measures.
Accountability: the Data Controller is able to demonstrate compliance with the above principles.

Data transfer:
The Data Controller does not transfer the Data Subjects’ personal data within the country, within the Union, to a third country or to an international organization.

Processors used:
For its activities, the Data Controller uses the following processor:
DOSZA Accounting Office – management of partner relationships, invoicing, accounting

Duration of the processing:
The period of data retention lasts until the completion of the purposes of the processing and is specified in the “Consent to Data Processing Statement and Information.”

Scope of processed data:
During and after the provision of its services, the Data Controller may process, based on the Data Subject’s voluntary consent or a contractual legal relationship, the following personal data depending on the purpose of the processing: company name, name of the contact person/Data Subject, company/business phone numbers, company/business email addresses, company/business mailing addresses, IT equipment data of the Data Subject, Microsoft personal data, usernames, passwords.

The types of processed data listed in this notice are indicative; in case of deviation, the precise scope is set forth in the “Consent to Data Processing Statement and Information.”

Right of access of the Data Subject:
The Data Subject has the right to obtain confirmation from the Data Controller as to whether or not personal data concerning them are being processed, and, where that is the case, access to the personal data and the following information:
the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
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;
the right to lodge a complaint with a supervisory authority;
where the personal data are not collected from the Data Subject, any available information as to their source;
the existence of automated decision-making, including profiling, and, 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.

Where personal data are transferred to a third country or to an international organization, the Data Subject shall have the right to be informed of the appropriate safeguards relating to the transfer pursuant to Article 46 of the GDPR Regulation.

The Data Controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the Data Subject, the Data Controller may charge a reasonable fee based on administrative costs. Where the Data Subject makes the request by electronic means, and unless otherwise requested, the information shall be provided in a commonly used electronic form.

Right to rectification:
The Data Subject has the right to obtain without undue delay the rectification of inaccurate personal data concerning them. Taking into account the purposes of the processing, the Data Subject shall have the right to have incomplete personal data completed.

Right to erasure (‘right to be forgotten’):
The Data Subject shall have the right to obtain from the controller the erasure of personal data concerning them without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
the Data Subject withdraws consent on which the processing is based and there is no other legal ground for the processing;
the Data Subject objects to the processing and there are no overriding legitimate grounds for the processing;
the personal data have been unlawfully processed;
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;
the personal data have been collected in relation to the offer of information society services to a child.

If the Controller has made the personal data public and is obliged to erase them, the Controller, 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.

Requests for erasure do not apply if processing is necessary:
for exercising the right of freedom of expression and information;
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;
for reasons of public interest in the area of public health;
for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes;
for the establishment, exercise or defense of legal claims.

Right to restriction of processing:
The Data Subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
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;
the processing is unlawful and the Data Subject opposes the erasure of the personal data and requests the restriction of their use instead;
the controller no longer needs the personal data for the purposes of the processing, but they are required by the Data Subject for the establishment, exercise or defense of legal claims;
the Data Subject has objected to processing pending the verification whether the legitimate grounds of the controller override those of the Data Subject.

Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with the Data Subject’s consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

The Controller shall inform the Data Subject who has obtained restriction of processing before the restriction of processing is lifted.

Right to object:
Under the GDPR Regulation, the Data Subject shall have the right to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them:
where 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, or for 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, especially where the Data Subject is a child);
where personal data are processed for direct marketing purposes, including profiling to the extent that it is related to such direct marketing.

Where the Data Subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

Where personal data are processed for scientific or historical research purposes or statistical purposes, the Data Subject has the right to object at any time, on grounds relating to their particular situation, to processing of personal data concerning them, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

Objections may be submitted electronically to the Controller.

Right to data portability:
Under Article 20 of the GDPR Regulation, the Data Subject shall have the right to receive the personal data concerning them, which they have 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:
the processing is based on consent or on a contract, and
the processing is carried out by automated means.

The Controller will fulfill such requests in xml format, delivered on a data medium provided by the Data Subject.

In exercising their 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 the right to data portability shall be without prejudice to the right to erasure (‘right to be forgotten’).

The exercise of the right to data portability must not adversely affect the rights and freedoms of others.

Right to withdraw consent:
The Data Subject shall have the right to withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Before giving consent, the Data Subject shall be informed thereof. Withdrawal of consent may be made using the “Withdrawal of Consent Statement” form.

Right to lodge a complaint with a supervisory authority:
Without prejudice to any other administrative or judicial remedy, every Data Subject shall have the right to lodge a complaint with a supervisory authority—particularly in the Member State of their habitual residence, place of work, or place of the alleged infringement—if the Data Subject considers that the processing of personal data relating to them infringes the GDPR Regulation.

The supervisory authority to which the complaint has been lodged shall inform the complainant of the progress and the outcome of the complaint.

The Data Controller must comply with the decision of the Supervisory Authority.

The competent Supervisory Authority in Hungary is the National Authority for Data Protection and Freedom of Information, whose contact details are:
1125 Budapest, Szilágyi Erzsébet fasor 22/C.
Mailing address: 1530 Budapest, Pf.: 5.
Phone: +36-1-391-1400
Fax: +36-1-391-1410
E-mail: ugyfelszolgalat@naih.hu
Website: http://www.naih.hu

Automated decision-making, profiling:
The Data Controller guarantees that, in connection with the processing of personal data, Data Subjects are not subject to a decision based solely on automated processing that would produce legal effects concerning them or similarly significantly affect them. Exceptions are cases where:
it is necessary for the conclusion or performance of a contract between the Data Subject and the Data Controller;
it is authorized by Union or Member State law applicable to the Data Controller which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or
it is based on the Data Subject’s explicit consent.]