Privacy and Data Management Policy

The main goal of Warvasovszky & Warvasovszky Kft. is to fully comply with all Hungarian and European Union laws, is committed to protecting the personal data of its Customers and respects their right to informational self-determination in all cases.

Warvasovszky & Warvasovszky Kft. treats personal data confidentially and takes all security, technical and administrative measures to guarantee the security of the data.

Warvasovszky & Warvasovszky Kft. processes all personal data of its customers in compliance with the provisions of Act CXII of 2011 on the right to informational self-determination and freedom of information, as well as the provisions of the GDPR (Regulation (EU) 2016/679 of the European Parliament and of the Council).

GENERAL INFORMATION

1. The data controller and personal data

In this case, the data controller (the “Data Controller”) is: Warvasovszky & Warvasovszky Kft. (8143 Sárszentmihály, Arany János utca 16.).

2. Contact us for questions or problems

If you have any questions or comments, objections or concerns regarding the processing of your data, please write to us at hello@wnwcorp.eu. We will contact you immediately upon receipt of your request.

3. Source of data

In connection with the sale and advertising of our products and services, or in the course of other business relationships, we may obtain your personal data in various ways, primarily in the following ways:

Directly from you

• In case of establishing a contractual relationship
• In case of personal, telephone or electronic (e.g. email) inquiries or contact
• By contacting us in person, by phone, by email or by post for any other purpose

From another source

• From another person or administrator who may be acting on your behalf
• Through an electronic or offline intermediary platform or service provider
• From publicly available databases or other sources (e.g. company register data)
• When browsing the websites we operate, we may also obtain personal data via log files or cookies regarding the use of the websites and certain technical features.

4. Where the data is stored

We store your personal data electronically, primarily on our own servers or servers operated on our behalf, and on paper at our headquarters or premises.

5. Purpose and legal basis of data processing

You will find information about the purpose and legal basis of data processing below for each data processing. Please note that some data processing may have multiple purposes and legal bases at the same time. In these cases, we will process the data as long as even one legal basis exists.

6. Duration of data processing

All our data processing is governed by the purpose of the data processing, which determines the period of data processing and retention. If more than one purpose applies to a piece of data, the longer retention period applies in all cases. If the data processing is necessary for the performance of a contract to which you are a party, or if it is necessary to take steps at your request prior to the conclusion of the contract, we process the data for the duration of the customer relationship and then for the general limitation period, i.e. 5 years, after the termination of the contract or customer relationship. If the data processing is based on your consent, we process the data until you withdraw your consent or, if the purpose of the data processing is achieved earlier and there is no further data processing purpose, until the purpose is achieved. In any case, if we are required by law to retain certain documents, we store the personal data contained in them for the retention period prescribed by the relevant law. In these cases, the legal basis for data storage is compliance with our legal obligation, regardless of whether there is another legal basis for the data processing.

Such a legal provision includes, among others:

• the Accounting Act (i.e. Act C of 2000) applies to the so-called accounting documents (e.g. invoice, contract, agreement, statement, credit institution document, bank statement, etc.), which we are obliged to keep for 8 years, and
• the Act on the Taxation Procedure (i.e. the CL. Act of 2017) on tax documents, which we must retain until the right to assess the tax expires.

In other cases, for example, if the legal basis for data processing is our legitimate interest or if we deviate from the above for other reasons, we will separately inform you below about the duration of the given data processing.

7. Recipients of the data

The data is not accessible to anyone. On the one hand, we use data processors for certain reasons, and on the other hand, we regulate who can access the data within and outside the Data Controller's organization. The disclosure of personal data is strictly limited to what is necessary and reasonable to achieve the purposes listed above.

Within the Data Controller's own organization, only the holders of the relevant positions and the decision-makers or preparation levels who control or supervise them are entitled to access your personal data, whose work is necessary to achieve the purpose of the given data processing. These employees only have access to the data to the minimum extent necessary, in accordance with the principle of necessary access. We strive to ensure that the protection of your data is consistently enforced in all our business processes through internal procedural and organizational measures.

8. Your rights

You have the rights listed here in relation to data processing. These rights are granted to you by the GDPR (i.e. Regulation (EU) 2016/679 of the European Parliament and of the Council) and the Hungarian Data Protection Act (abbreviated as Infotv., i.e. Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information) as of May 25, 2018.

Right of access:

This essentially means information about what data we process about you, why and how. You have the right to receive feedback from us as to whether your personal data is being processed and, if such processing is taking place, you have the right to access the personal data itself and all relevant information about its processing. Such information includes, for example, the purposes of the processing, the categories of data concerned and your rights. You also have the right to receive a copy of the personal data processed. The first copy is free of charge, and for further copies we may charge a reasonable fee based on our administrative costs, if justified by the scope of the data request. If you have submitted your request electronically, you have the right to receive the information in a widely used electronic format (e.g. as a PDF or Word document).

Right to rectification:

You have the right to request that we rectify inaccurate personal data concerning you without undue delay. You may also request that we complete incomplete personal data, if necessary.

Right to withdraw consent / right to erasure:

If the processing in question is based on your consent, you have the right to withdraw it at any time and to have your personal data erased without undue delay upon request. This right does not apply to processing that is not based on your consent. The legal basis for the processing is indicated below in each case.

The right to restrict data processing:

You have the right to request that we restrict the processing of your data. This means that we may only store the restricted data, but may only use it in other ways with your consent or in certain legal cases. You may request the restriction of processing, among other things, if you dispute the accuracy of the data and request its verification, or if you consider our processing to be unlawful but you oppose the deletion of the data and request the restriction of processing instead.

Right to data portability:

If the processing in question is based on your consent or is related to the performance of a contract, you have the right to receive the data in a structured, commonly used and machine-readable format (e.g. PDF or Word) and to transmit it to another controller. You also have the right, where technically feasible, to request the direct transmission of personal data between controllers.

The right to protest

Please read this paragraph on the right to object carefully. If the processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party, you have the right to object to the processing at any time on grounds relating to your particular situation. In such a case, we will no longer process your data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Right to complain

If you believe that the processing of your personal data violates the GDPR or other data protection legislation, we recommend that you contact us first so that we can respond to your concern as quickly and efficiently as possible. If you do not wish to contact us, you may file a complaint with the National Data Protection and Freedom of Information Authority in case of a violation.

Contact details of the Authority:

Headquarters: 1125 Budapest, Szilágyi Erzsébet fasor 22/C.

Mailing address: 1530 Budapest, P.O. Box: 5.

Phone: (06-1) 391-1400

E-mail: ugyfelszolgalat@naih.hu

Website: http://www.naih.hu

9. Amendments and availability of the information

We may update this notice at any time if it needs to be clarified or supplemented for any reason. The date of the notice is determined by the date at the bottom of the document. Additions and amendments will take effect immediately upon the publication of the updated notice. The publication will take place on our website. We recommend that you review the notice from time to time in order to be informed of any changes that may affect you.

Effective date: January 1, 2022.

CONTRACTUAL RELATIONS

(CONTRACTS WITH DISTRIBUTORS, SUPPLIERS, ETC.)

1. Scope of processed data

Depending on the nature of the given product/service or contract:

Contact/identification data

Name, address, email address, telephone number, billing information, and company data (company registration number, name, registered office, tax number, bank account number).

2. Consequences of failure to provide data

If you do not provide the necessary information, we will not be able to sell you our products or provide you with our services, or we may not be able to purchase or use the products or services you offer. It is also possible that in the case of a business-to-business (B2B) contract, failure to provide your contact information will result in the contract not being concluded or performed.

3. Purpose and legal basis of data processing

The purpose of data processing is to sell our products or provide services to you, including, among others, the sale of movable property or services tailored to our profile. The purpose of data processing is also to enable us to fulfill our statutory warranty or guarantee obligations relating to products or services and any other additional obligations required by contract or law. If you offer us products or services, the purpose of data processing is to enable us to use them.

If you are not a contracting party, but are acting on behalf of a company or other legal entity, as its contractual representative, agent, or contact person indicated in the contract, then the purpose of data processing is the performance of the contract concluded with the contracting party related to you.

When processing personal data, Warvasovszky & Warvasovszky Kft. ensures the security of data, compliance with the rules on data management, and ensures the protection of the privacy of the data subjects! Personal information is protected by different levels of access rights to different databases within the company. As a result, only our own employees designated for this purpose are entitled to access personal data exclusively for the performance of their duties, or for the performance of the service used/wanted by the Customer, and to answer any questions or comments that may arise.

Legal basis for data processing:

The processing is necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract. If you are not a party to the contract, but are a representative or contact person in a business-to-business (B2B) contract, the processing of the data is based on our legitimate interest. This means that our interest in processing the data for the purpose of entering into and performing a contract with the organisation that employs or commissions you is overridden by your interests or fundamental rights and freedoms.

The legal basis for data processing is also the fulfillment of our legal obligation in relation to warranty and/or guarantee claims.

An additional legal basis for data processing may be legitimate interest after the termination of a contract if there is still a settlement dispute between the parties.

4. Recipients of the data

Some services (e.g. freight forwarding, accounting services) are provided by external partners, who may also be considered separate data controllers. In connection with these services, we transfer data to our partners.

If you have a contractual relationship with Warvasovszky & Warvasovszky Kft., your data will be processed by EU-TAX Consulting Limited Liability Company (6724 Szeged, Árvíz utca 4. A. ép. 1. em. 2.) with company registration number Cg.06-09-007933 in relation to accounting services, and by GLS General Logistics Systems Hungary Parcel-Logistics Limited Liability Company (2351 Alsónémedi, GLS Európa utca 2.) with company registration number Cg.13-09-111755 in relation to courier services.

In the event of a legal dispute, we will forward the data to our legal representative.

JOB APPLICATIONS

1. Scope of processed data

Contact details

• your last and first name
• your postal address
• your email address
• your phone number

CV data

• qualifications, previous jobs, experience
• data related to your current or previous salary
• any additional information that constitutes personal data, provided in your CV, cover letter or otherwise during the recruitment process

2. Consequences of failure to provide data

If you do not provide this information, we will not be able to process your application and provide feedback.

3. Purpose and legal basis of data processing

The purpose of data processing is to enable us to carry out the selection process, to verify your suitability for the advertised position and to decide to whom we will make an offer of employment. The processing of your personal data is necessary for the purposes of our legitimate interest. This means that our interest in carrying out the recruitment process takes precedence and does not materially restrict your interests or fundamental rights and freedoms.

4. Duration of data processing

In the event of an unsuccessful application, we will process your data for four months from the end of the selection process, in order to be able to reconsider your application if the employment relationship of the selected candidate is terminated during the probationary period. In the event of a successful application, we will process your data from the conclusion of the employment contract in accordance with the separate employee data processing information.

WEBSITE VISITORS (COOKIE POLICY)

When you visit our website, the system places so-called cookies (or “cookies”) in your computer’s internet browser. We process the personal data of users collected with the help of cookies. Cookies are small text files containing both letters and numbers placed on the user’s terminal device (computer, phone, other device) by the web server of the website visited by the user, which store information about the user and the connection between the user and the web server. They allow the website’s efficiency, usage, operation, errors and number of visitors to be tracked, as well as to improve the user experience, which are also the purposes of data processing.

Our web server may place the following types of cookies on your device:

Anonymous analytical cookies

Analytical cookies collect information about visitors that is necessary for our statistical analysis of website traffic. Such information includes, for example, the number of visitors to the website, the time spent on the website, navigation-related questions, i.e. how the visitor found the website (by clicking on an advertisement or otherwise). Analytical cookies therefore provide us with information about your browsing habits, which helps us to improve our website by examining visitor satisfaction and the awareness of our website.

Profiling (identification) cookies

Our website may allow the user to register by providing personal information and then log in to our website. Identification cookies thus enable the management of user identifiers, saved information, and thus the unique identification of the user during subsequent visits to the website and access to any authorized content.

Third-party advertising cookies

By using cookies on our website, which are used by third parties for behavioral advertising, the third party, for example, tracks how many users have seen the advertisement and how many times the user has seen it. Cookies used by third parties are subject to the third party's data protection regulations, the content of which we have no influence on and which we recommend that you read separately.

Other third-party cookies

The website uses third-party cookies to track visitors' browsing habits and to offer visitors various services, such as requesting a catalog or signing up for a test drive. Due to the operation of these cookies, neither we nor third parties have access to the information stored in the cookies used by the other party.

Flash cookies (local shared objects)

Our website may contain multimedia content that is played using the Adobe Flash Player program. Flash cookies, also known as local shared objects, store technical data necessary for playing video or audio content on the website (image quality, network link, speed). They are suitable for providing certain services (e.g. so-called "auto-resume") and for saving user preferences related to media content.

Data processing using cookies is based on your consent. In the absence of consent or if you withdraw your previously given consent, our website will not place cookies on your device.

How cookies are managed by users

Users can remove cookies – with the exception of flash cookies – at any time in the Settings menu of their internet browser. Users can also set the permission or prohibition of the use of cookies there. Detailed instructions for this are provided in the operating documentation of the browser you are using. Flash cookies are also stored on the user's end device, but there is no possibility to manage them in the browser. Such cookies can be deleted manually or their settings can be changed according to the current information on the Adobe website.

Date: Sárszentmihály, January 1, 2022.