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GDPR

Data Processing Policy

 

Data of the Controller

 

Név: KLASS WAGEN HUNGARY Kft. (hereinafter referred to as: ‘KLASS WAGEN’, the ‘Controller’ or ‘we’)

Registered seat: 1132 Budapest, Váci út 30. VI. em

Registration number: 01-09-305681

Contacts:

Postal address: 1132 Budapest, Váci út 30. VI. em.

Email: [email protected]

Webpage: http://klasswagen.hu/

Phone: +36-20-3652558

 

I. PROVIDING SERVICES

Purpose of data processing

 

We record certain personal data to identify our clients, to issue invoices, to effectively resolve disputes, and for the purpose of protecting property. Providing of personal data referred to in this article is a prerequisite for concluding the rental agreement.

Legal basis of processing

we process your personal data based on the following entitlement

 

According 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 Directive 95/46/EC (GDPR) Article 6 paragraph (1) b), we may process the given personal data for the performance of a contract to which the data subject is party, and according to Article 6 paragraph (1) f), we may process certain personal data for the purposes of our legitimate interests.

 

Processed personal data

 

Klass Wagen may process the personal data described below:

name, first name, email address, postal address, phone number, number and expiry date of ID card (or passport), mother’s maiden name, sex, nationality, signature, place of birth, time of birth, picture, number and expiry date of driver’s license, number and expiry date of credit card, time of departure, time of return

Term of processing

how long we process your personal data and when we will erase it

We process personal data given at the time of the conclusion of the contract (or before) for 6 years from the conclusion for the purpose of complying with legal regulations, and settling disputes effectively. We set the term of data processing with respect to general period of limitation of claims, as well as suspension of limitation.

Persons with access to personal data

persons and enterprises who are entitled to process certain personal data

We treat the personal data confidentially, and we do not transfer personal data to third parties not described in this policy. We may transfer personal data to relevant authorities in case it is required by regulations.

Personal data is available for our colleagues who cooperate for the purpose of the data processing. Our colleagues are obliged to treat personal data confidentially.

 

We may transfer personal data for the following persons:

                Klass Wagen s.r.l.

                registered seat: Timisoara, B-dul 16. Decembrie 1989 Nr. 35. Ap. 2., Románia

                webpage: www.klasswagen.com

                email: [email protected]

the following data processors may process certain personal data:

                Accace Hungary Kft.

                registered seat: 1132 Budapest, Váci út 30. VI. em.

                webpage: www.accace.hu

                email: [email protected]

               

 

Our colleagues and contractors are aware of the obligation of treating personal data confidentially.

Legal interest

We process certain personal data based on our legal interests. We compared our legal interests with the rights of data subjects related to their personal data. Data has strong interest in identifying the driver of the vehicle and informing authorities in case of legal processes initiated by unlawful actions.

Klass Wagen processes personal data with consideration of the requirements of data security and only transfer these data in case of an infraction or suspicion of crime. In these cases, the personal data may be transferred to relevant public authorities.

 

In respect of the conditions described above, we believe that our legal interests are proportionate to the restrictions of the rights of data subjects.

 

Your rights as data subject

 

1.    Right of access:

 

you have the right to obtain confirmation using our contacts as to whether or not personal data concerning you are being processed and, where that is the case, access to the personal data and the following information:

  1. the purposes of the processing,
  2. the categories of personal data concerned,
  3. the recipients or categories of recipient to whom the personal data have been or will be disclosed,
  4. the envisaged period for which the personal data will be stored,
  5. 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,
  6. the right to lodge a complaint,
  7. the existence of automated decision-making, including profiling, and information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

Information shall be provided without undue delay, in one month from receiving your request. Primarily, we provide information in the same form as we received your request.

We provide information free for the first time in each calendar year.  For requests filed repeatedly for the same scope of data, we may charge administrational fees, provided that no infringement found and no rectification was necessary.

 

2.    Rectification of personal data

In case personal data processed by us is inaccurate, and accurate data is available or sent us, we will rectify such personal data.

 

3.    Erasure of personal data

 

We will erase processed personal data if:

  1. it has been unlawfully processed;
  2. you withdraw your consent and there is no other legal ground for the processing;
  3. you object to the processing
  4. it is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  5. it has to be erased for compliance with a legal obligation.

 

4.   Right to restriction

 

You shall have the right to obtain restriction of the processing in the following cases:

a) if you contest the accuracy of the personal data (for the period of verifying accuracy)

b) if the processing is unlawful and you do not request erasure,

c) if we do not need the personal data for the purposes of the processing any more, but they are required by you for the establishment, exercise or defence of legal claims;

d) if you object to processing (for the period of studying the objection)

In case of restriction of processing, the Klass Wagen will not process the concerned personal data (except from storage). We send prior notification before lifting restrictions.

 

5.    Objection

 

You may object to the process of your personal data, if you believe that we use or transfer such data for the purpose of direct marketing, surveillance or scientific research.

Please send your objection to any contact we provided in this policy. Please make it possible for us to identify you. We study your objection and inform you about its results without undue delay but in 15 days from reception at latest. Please provide us with your postal address or email where we can send our response. Failing this, we will send our response to your contact given before and we are not liable for the failure of receipt.

If you do not agree with the decision, or you do not receive response in time, you may go to court in 30 days from receiving our response (or from the deadline of response)

 

6.    Complaint

 

In case you believe that the processing is detrimental, you may lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság)

 

7. Data portability

 

On your request, we send you the personal data concerning you, which you has provided to us in a structured, commonly used and machine-readable format.

Compensation for damages, restitution

 

If we cause you or others any damage by unlawful or unsafe processing of personal data, you or the person suffered damage is entitled to claim compensation for damages. In case the harm affects your rights relating to personality, you are entitled to claim for restitution. We shall not bear liability if the damages are the result of an unavoidable cause beyond the course of processing or caused by your intentional or grossly negligent behavior.

 

Exercising claims

how you can enforce rights

 

1.    Contact us

If you believe that we do not act lawfully processing your personal data, please be kind to share your comment with us, as controllers first so we can deal with it the fastest and most effective way.

 

2.    Hungarian National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság, NAIH)

In case of unlawful processing, you may lodge a complaint with NAIH.

 

Contacts of NAIH:

Webpage: http://www.naih.hu/

Address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c

Postal address: 1530 Budapest, Pf.: 5.

Email [email protected]

 

3.    Going to court

 

Please note that you are entitled to exercise your claims in front of court. General courts shall have competence of the procedure. You are entitled to initiate trial on the general court that has jurisdiction either in based on our registered seat your residence.

 

II. COOKIES

 

A Klass Wagen uses ‘cookies’ in its website which means to place a small data package in the computer of the data subject and reread it at a subsequent visit.

 

Purpose of processing

 

Identifying the routine of users and recording the data provided thereof, preventing loss of data. You can find more information about cookies below:

Cookies usage policy

Legal basis of processing

Your consent – GDPR Article 6 par. (1) a)

Processed personal data

We process the time of usage and the behavior of the device as personal data.

 

III. JOB APPLICANTS

 

Purpose of data processing

 

To scrutinize job applications and fill open positions at Klass Wagen.

 

Legal basis of processing

 

While the job application is pending, Klass Wagen is entitled to process the provided personal data according to GDPR Article 6 par. (1) b) for the performance of a contract to which you are party or in order to take steps at the request of the data subject prior to entering into a contract.

After the decision on the job application, we may process personal data based on your consent if you gave so.

 

Processed personal data

 

Every information provided by you in the course of the application which is construed as personal data.

 

Persons with access to personal data

 

We treat the personal data confidentially, and we do not transfer personal data to third parties not described in this policy.

Personal data is available for our colleagues who cooperate for the purpose of the data processing. Our colleagues are obliged to treat personal data confidentially.

 

Rights of data subjects

 

Job applicants have the same rights and shall execute them in the same way as other data subjects  described in Chapter I.

 

25th May 2018.

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