DATA MANAGEMENT INFORMATION

Comp-let Party Service Kft (headquarters: 1037 Budapest, Szépvölgyi út 33.) hereinafter referred to as the Service Provider, Data Controller, acknowledges the contents of this legal notice as binding.

The following information is provided pursuant to 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 Regulation (EC) No 95/46/EC (General Data Protection Regulation) and Act CXII of 2011 on the Right to Information Self-Determination and Freedom of Information (Infotv.).

This privacy notice governs the processing of the following pages:

complet.hu

Amendments to the Prospectus will enter into force upon publication at the above address.

Comp-let Party Service Ltd. is committed to protecting the personal data of its customers and partners, attaches great importance to respecting the right of informational self-determination of its customers, treats personal data confidentially and takes all security, technical and organizational measures to ensure the security of the data.

Comp-let Party Service Ltd. describes its data management practices below.

Name, contact details of the controller

Name of the controller: COMP-LET Party Service KFT. (hereinafter referred to as the "Data Controller")

Registered office and postal address of the controller: 1037 Budapest, Szépvölgyi út 33.

Tax number of the data controller: 11829289-2-41

Company registration number of the controller: 01 09 678775

Registering authority: metropolitan commercial court

Representative: Péter Kis

E-mail address of the controller: ajanlat@complet.hu

Telephone number of the controller: +36/30-625-60-16

Website: https://complet.hu/

Interpretative provisions:

In our policy, data protection terms have the following meanings:

Personal data: any data that can be associated with a specific natural person (identified or identifiable) (hereinafter referred to as "data subject"), the inference that can be drawn from the data concerning the data subject. The personal data shall retain this quality during processing for as long as the link with the data subject can be established. In particular, a person shall be regarded as identifiable where he or she can be identified, directly or indirectly, by reference to a name, an identification mark or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity.

Contribution: a voluntary and explicit indication of the data subject's wishes, based on appropriate information, by which he or she gives his or her unambiguous consent to the processing of personal data concerning him or her, whether in full or in part.

Protest: a statement by the data subject objecting to the processing of his or her personal data and requesting the cessation of the processing or the erasure of the processed data.

Data Controller: the natural or legal person or unincorporated body which, alone or jointly with others, determines the purposes for which the data are to be processed, takes and implements the decisions concerning the processing (including the means used) or has the Processor implement them.

Data management: whatever the procedure used, any operation or set of operations which is performed upon the data, in particular any collection, recording, recording, organisation, storage, alteration, use, retrieval, disclosure, transmission, alignment or combination, blocking, erasure or destruction of data, prevention of their further use, photographing, audio or video recording, or any other act or set of operations which permits the identification of a person.

Data transmission: making the data available to a specified third party.

Disclosure: making the data available to anyone.

Data deletion: rendering the data unrecognisable in such a way that it is no longer possible to recover it.

Data marking: the marking of data with an identification mark to distinguish it.

Data storage: to identify the data for the purpose of limiting their further processing permanently or for a limited period of time.

Data destruction: the complete physical destruction of the medium containing the data.

Data processing: the performance of technical tasks related to processing operations, irrespective of the method and means used to perform the operations and the place of application, provided that the technical task is performed on the data.

Data processor: a natural or legal person or an unincorporated body which processes data on the basis of a contract, including a contract concluded pursuant to a legal provision.

Data file: the set of data managed in one register.

Third person: a natural or legal person or unincorporated body other than the data subject, the controller or the processor.

Principles governing the processing of personal data:

1. legality, fairness, transparency: the collection and processing of personal data must be fair, lawful and carried out in a transparent manner for the data subject [Infotv. § 4 (1) paragraph]

2. goal orientation: under which personal data may be processed only for specified purposes [Infotv. § 4 (1) paragraph]

3. data economy: that only personal data which is necessary for the purpose of the processing and adequate for that purpose may be processed [Infotv. § 4 (2) paragraph]

4. accuracy or data quality principle: which, in addition to the criteria of fairness and lawfulness, requires the controller to keep the data accurate, complete and up-to-date. [Infotv. § 4 (2) paragraph]

5. limited shelf life: the personal data must be deleted when the purpose of the processing has ceased to exist [Infotv. § 17 (2) paragraph]

6. integrity and confidentiality: Except for mandatory processing, personal data may only be processed on the basis of consent or on the basis of specific legal grounds as defined in Article 6 of the Data Protection Act. [Infotv. § 5-6, 14-21]

The processing must be carried out in such a way as to ensure adequate security of personal data, including against unauthorised or unlawful processing, accidental loss, destruction or damage, by implementing appropriate technical and organisational measures.

7. accountability: The controller is responsible for, and must be able to demonstrate, compliance with the above.

Legal background, legal basis, purpose, scope of personal data processed and duration of data processing on the website

A., Information about the use of cookies

What is a cookie?

The Data Controller uses so-called cookies when you visit the website. A cookie is a set of letters and numbers that our website sends to your browser to save certain settings, facilitate the use of our website and help us to collect some relevant statistical information about our visitors. Cookies do not contain any personal information and are not used to identify an individual user. Cookies often contain a unique identifier - a secret, randomly generated sequence of numbers - that is stored on your device.

Some cookies are deleted after the website is closed, some are stored on your computer for a longer period of time.

Legal background and legal basis for cookies:

The background for data processing is provided by Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information (Infotv.) and Act CVIII of 2001 on Certain Aspects of Electronic Commerce Services and Information Society Services. In accordance with Article 5 (1) (a) of the Privacy Act.

Main features of the cookies used by the website:

Cookies strictly necessary for the operation: These cookies are essential for the use of the website and allow you to use the basic functions of the website. Without them, many of the site's features will not be available to you. The lifetime of these types of cookies is limited to the duration of the session.

Cookies to improve the user experience: These cookies collect information about a user's use of the website, such as which pages they visit most often or what error messages they receive from the website. These cookies do not collect any information that identifies the visitor, i.e. they are completely general, anonymous information. We use the information they provide to improve the performance of the website. The lifetime of these types of cookies is limited to the duration of the session.

If you do not accept the use of cookies, certain features will not be available to you. For more information on how to delete cookies, please click on the links below:

• Internet Explorer: http://windows.microsoft.com/en-us/internet-explorer/delete-managecookies#ie=ie-11
• Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-yourcomputer
• Chrome: https://support.google.com/chrome/answer/95647?hl=en

B., Data processing in relation to ordering and invoicing

Legal background and legal basis for data processing:

The background of data processing is provided by the provisions of Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information (Infotv.) and Act C of 2000 on Accounting (Sztv.). In accordance with Article 5 (1) (a) of the Data Protection Act, the data processing is based on your consent and - in case of withdrawal of consent - on the fulfilment of the legal obligation of the Data Controller under Article 6 (5) (a) of the Data Protection Act.

Purpose of the processing:

Issue invoices in accordance with the law and fulfil the obligation to keep accounting records. Pursuant to Article 169 (1) to (2) of the Tax Act, companies must keep accounting documents that directly and indirectly support the accounting.

Scope of the data processed:

Name, address, e-mail address, telephone number, tax number

Duration of processing:

Invoices issued must be kept for 8 years from the date of issue of the invoice, pursuant to Section 169 (2) of the State Act. Please be informed that if you withdraw your consent to the issuing of the invoice, the Data Controller is entitled to retain your personal data obtained during the issuing of the invoice for 8 years pursuant to Section 6 (5) a) of the Information Act.

C., Data processing in relation to the transport of goods

Legal background and legal basis for data processing:

The legal basis for data processing is the provisions of Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information (Infotv.). In accordance with Article 5 (1) (a) of the Freedom of Information Act.

Purpose of the processing:

The purpose of data processing for the delivery of goods is to deliver the ordered goods to you, with the assistance of our contractual partner, in accordance with your requirements.

Scope of the data processed:

Name, address, e-mail address, telephone number.

Duration of processing:

The Data Controller shall process the data for the duration of the delivery of the ordered goods.

D., processing of data relating to quality complaints

Legal background and legal basis for data processing:

the voluntary consent of the data subject, Section 169 (2) of the Act on the Auditing of Accounts and Section 17/A (7) of the Act on the Protection of Personal Data.

Purpose of the processing:

handling quality complaints regarding the services provided or products sold by Comp-let Party Service Ltd.

Scope of the data processed:

the name and address of the customer, the name of the product, the purchase price, the date of the purchase and the date of the notification of the defect, a description of the defect, the claim the consumer wishes to assert and the means of settling the claim.

Duration of processing:

- eight years in respect of return vouchers in accordance with Section 169 (2) of the Act on Accounting,

- five years with regard to copies of the minutes recorded on the complaint and the replies to the written complaints pursuant to Paragraph (7) of Article 17/A of the Act on the Protection of the Rights of Persons with regard to the Protection of the Ombudsman,

- two years for duplicate entries in the buyers' ledger.

E., Data processing in relation to newsletter distribution

Legal background and legal basis for data processing:

The background for data processing is provided by Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information (Infotv.) and Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Economic Advertising Activities (Grt.). Article 5 (1) a) and the provisions of the Grt. 6(1) to (2) of the GDPR.

Purpose of the processing:

The purpose of processing your data is to keep you informed about the latest and best offers and promotions. Please be informed that the newsletter will contain advertisements not only from the Data Controller but also from other companies, but we will not transmit your personal data to them.

Scope of the data processed:

Name, e-mail address, telephone number

Duration of processing:

Until the data subject's consent is withdrawn.

F., Processing of data related to the sending and display of personalised advertising

Legal background and legal basis for data processing:

The background for data processing is provided by Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information (Infotv.) and Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Economic Advertising Activities (Grt.). Article 5 (1) a) and the provisions of the Grt. 6(1) to (2) of the GDPR.

Purpose of the processing:

The purpose of processing your data is to send you personalised offers that are best tailored to your needs and preferences.

Scope of the data processed:

Name, e-mail address, telephone number.

Duration of processing:

Until your consent is withdrawn.

G., Processing of data in connection with registration

Legal background and legal basis for data processing:

The background for data processing is provided by Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information (Infotv.) and Act V of 2013 on the Civil Code (Civil Code). In accordance with Article 5 (1) (a) of the Privacy Act.

Purpose of the processing:

By storing the data provided during registration, the Data Controller can provide a more convenient service (e.g. the data subject does not have to re-enter the data for a new purchase).

Scope of the data processed:

In the course of processing, the Data Controller processes your name, user name, address, telephone number, e-mail address, password, the name of the product purchased and the date of purchase.

Duration of processing:

Until your consent is withdrawn.

H., A https://complet.hu/ website visitor data

Legal background and legal basis for data processing:

the consent of the data subject, and Paragraph 13/A (3) of the Eker. tv.

Purpose of the processing:

when visiting the website, the service provider records the visitor's data in order to monitor the functioning of the services, to provide personalised service and to prevent abuse.

Scope of the data processed:

date, time start, time end, information about the visitor's operating system and browser, the IP address of his/her computer, except for the last section, and the user's geographical location.

Duration of processing:

part of the IP address of the user's computer will be deleted at the end of the visit, the rest of the data will be deleted within one month.

I., Completing the Request for Proposal form

Legal background and legal basis for data processing:

the voluntary consent of the data subject, § 13/A of the Eker. tv., § 169 (2) of the Számv. tv. and § 169 (2) of the Grt. § 6 (5).

Purpose of the processing:

Maintaining contacts, direct marketing enquiries, providing information on current information and offers.

Scope of the data processed:

name, e-mail address, telephone number, consent to be contacted for direct marketing purposes.

Duration of processing:

- with regard to direct marketing contributions, until the user's consent is withdrawn,

- eight years for the data on purchases pursuant to Section 169 (2) of the Act on Accounting.

J., Data processing related to online payment by credit card:

If you pay online by credit card, you will be automatically redirected to the Barion Payment Zrt. (head office: 1117 Budapest, Infopark sétány 1. building I. 5th floor 5; https://www.barion.com/hu/adatvedelmi-tajekoztato/).

Data transmitted: IP address, name, phone number, email address, billing information, order amount.

Purpose of the processing:

payment of the price of the product or service you want to buy.

We hereby inform you about the use of the following data processors and their activities related to data processing:

Processing for the storage of personal data (hosting provider)

Name of the data processor: Center.hu Kft.

The data processor is located at 1094 Budapest, Tompa utca 13.

Phone number of the data processor: +36/70-398-11-66

The email address of the data processor: kereskedelem@center.hu

The website of the data processor: www.center.hu

The Processor shall store the personal data on the basis of a written contract with the Controller. It is not entitled to access the personal data.

Data processing activities related to the sending of newsletters

Data processing activities related to the sending of newsletters

Name of the company operating the mailing system: Mailer Lite Ltd

The company operating the mailing system is located at 38 Mount Street Upper, Dublin 2, Co. Dublin, Ireland, D02 PR89

Phone number of the company operating the mailing system:

E-mail address of the company operating the mailing system: info@mailerlite.com

Web contact details of the company operating the newsletter system: https://mailerlite.com/

The Data Processor contributes to the sending of newsletters on the basis of a contract with the Data Controller. In doing so, the Data Processor shall process the name and e-mail address of the data subject in the MAILER LITE software to the extent necessary for sending the newsletter, and shall delete it without delay at the request of the data subject.

Data security measures

The Data Controller declares that it has implemented appropriate security, organisational and technical measures to protect personal data against unauthorised access, alteration, disclosure, transmission, disclosure, erasure or destruction, accidental destruction or accidental damage and against inaccessibility resulting from changes in the technology used.

Your rights in the processing of your data

For the duration of the processing, you are entitled to:

• the right to information,
• the right to rectify the data,
• the right to erasure,
• the right to block data,
• the right to protest.

You may request information about the processing of your personal data within the period of processing. Comp-let Party Service Ltd. will inform you in writing, in an intelligible form, within the shortest possible time from the date of the request, but not later than 25 days, about the data processed, the purposes, legal basis and duration of the processing, and, if the data have been transferred, about the persons who receive or have received the data and for what purposes.

You may request the rectification of your personal data within the period of processing, and we will amend your request within 15 days at the latest.

You have the possibility to request the deletion of your personal data, which Comp-let Party Service Kft. will comply with within 15 days at the latest. The right to erasure does not include compulsory data storage as required by law.

Remedies available

Any requests, questions or comments regarding data management should be addressed to. ajanlat@complet.hu by sending an e-mail to.

If you believe that Comp-let Party Service Ltd. has violated any legal provision on data processing or has not fulfilled a request, you can seek the cessation of alleged unlawful processing by National Authority for Data Protection and Freedom of Information initiate an investigation procedure.

Head office: 1125 Budapest, Szilágyi Erzsébet fasor 22/C.

Postal address: 1530 Budapest, Pf.: 5.

Phone: 0613911400

Fax: 0613911410

E-mail: ugyfelszolgalat@naih.hu

Website: http://www.naih.hu

AUTHOR'S RIGHTS

1. After the complet.hu as a website constitutes a copyright work, it is prohibited to download (reproduce), re-transmit to the public, otherwise use, electronically store, process and sell the content of the complet.hu website or any part thereof without the written consent of the Service Provider.
2. Even with written consent, any material from the complet.hu website and its database may only be reproduced with a link to that website.
3. The Service Provider reserves all rights to all elements of its service, its domain names, the secondary domain names formed from them, and its Internet advertising space.
4. It is prohibited to adapt or decrypt the content of the complet.hu website or parts thereof; to create user IDs and passwords in an unfair manner; to use any application that allows the complet.hu website or any part thereof to be modified or indexed.
5. The name complet.hu is protected by copyright, and its use, except for the reference, is possible only with the written consent of the Service Provider.

Budapest, 25.03.2024.