Privacy Policy

1Important information and who we are, the purpose of this privacy policy

The purpose of this privacy policy is to inform you how we collect and process your personal data through your use of this website and social media, including any data you may provide through this website when you subscribe to our newsletter or purchasing service. This privacy policy also sets out how we use personal data provided by phone, email or any other alternative means of correspondence. This website is not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other terms of use or privacy notice we may provide on specific occasions when we collect or process personal data about you, so that you are fully aware of how and why we use your data. This privacy policy supplements the other notices and is not intended to override them.

DATA CONTROLLER

Markestic Korlátolt Felelősségű Társaság (Limited Liability Company) is the data controller (referred to as "we", "us" or "Markestic" in this privacy policy) and is responsible for your personal data.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

OUR CONTACT DETAILS

Markestic Korlátolt Felelősségű Társaság, company registration number: 01 09 333546. Registered office and address: H-1224 Budapest, Damjanich utca 9., Hungary

Email address: hello@markestic.com

http://www.markestic.com

You have the right at any time to lodge a complaint with the National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság, NAIH), the Hungarian data protection supervisory authority ( http://www.naih.hu ). However, we would appreciate the opportunity to address your concerns before you approach the NAIH, so please contact us first.

2The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

Identity Data includes name, username or similar identifier, marital status, title, date of birth, age, gender and nationality.

Contact Data includes billing address, delivery address, home address, email address and telephone number.

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you.

Technical Data includes IP address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technologies on the devices you use to access this website.

Usage Data includes information about how you use our website and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law, as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which we use in accordance with this privacy policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case.

3How do we collect your personal data?

We use different methods to collect data from and about you, including through:

Direct interactions. You may give us your personal data by filling in forms or by meeting with us, or by corresponding with us by post, phone, email or otherwise.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Third parties or publicly available sources. We receive personal data about you from various third parties who help us provide our services. We also receive technical and analytics data from providers such as Google. We receive identity and contact data from publicly available sources such as company registries and other records.

4How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data, although we will obtain your consent before sending third party direct marketing communications to you by email or text message. You have the right to withdraw your consent at any time by contacting us.

Purposes for which we will use your personal data

Below we set out, in table form, how we plan to use your personal data and which legal bases we rely on. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one legal basis is set out in the table below.

Purpose of the processing

Type (category) of data

Legal basis for the processing

To contact you in order to perform the contract

a) Identity

(b) Contact

Performance of a contract with you (in the case of individuals) or our legitimate interest (in the case of legal entities)

To contact you with direct marketing messages by email, phone or SMS, including sending newsletters

a) Identity

(b) Contact

Your consent

To register you as a customer and keep records

a) Identity

(b) Contact

Performance of a contract with you (in the case of individuals) or our legitimate interest (in the case of legal entities)

To process your order, including:

(a) Managing payments, fees and charges

(b) Collecting and recovering money owed to us

a) Identity

(b) Contact

(c) Financial

(d) Transaction

(a) Performance of a contract with you (in the case of individuals) or our legitimate interest (in the case of legal entities)

(b) Necessary for our legitimate interests (to recover debts owed to us)

To manage our relationship with you, e.g. notifying you about changes to our terms or privacy policy

a) Identity

(b) Contact

Performance of a contract with you (in the case of individuals) or our legitimate interest (in the case of legal entities)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

a) Identity

(b) Contact

(c) Technical

Necessary for our legitimate interests (to run our business, provide administration and IT services, ensure network security, and prevention)

To deliver relevant website content and advertisements to you and to measure or understand the effectiveness of the advertising we serve to you

a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

f) Technical

Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, services, marketing, customer relationships and experiences

a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about services that may be of interest to you

a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our services and grow our business)

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Markestic's promotional offers

We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant to you (we call this marketing).

Third-party marketing. We will get your express consent before we share your personal data with any third party for marketing purposes.

COOKIES

We use cookies on our website. You can refuse all cookies, or selectively accept certain cookies, or be warned when a website wants to place cookies on your device or access them by changing your browser settings. However, if you disable cookies, some features of our website may not be available to you and some web pages may not display properly.

You can read more about cookies on the following website: https://www.allaboutcookies.org/

We may collect information about your computer, including your IP address, operating system and browser type, where available, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns. For the same reason, we may obtain information about your general internet usage by using a cookie file stored on your computer's hard drive. They help us to improve our website and to deliver a better and more personalised service.

Disabling cookies in your browser

By changing your browser settings, you can refuse all cookies or selectively accept certain cookies. You can find information about popular browsers and how to adjust your cookie settings on the following websites:

Chrome

Firefox

Internet Explorer

Safari

Deleting cookies

With the exception of essential cookies, all cookies expire within 6 months of browsing.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation of how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5Personal data to third parties

We may share your personal data with the parties set out below for the purposes set out in the table above, namely

Service providers acting as processors who provide IT and system administration services.

Business partners and service providers who help us take or fulfil orders.

Professional advisers including lawyers, auditors and accountants who provide consultancy, legal and accounting services.

Tax and customs agents, regulators and other authorities.

Market researchers and fraud prevention agencies.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6International transfers

As a general rule, we process your personal data within the European Economic Area (EEA), but some of the independent third-party service providers we engage (e.g. IT providers) are located outside the EEA. In such cases, where a transfer of personal data outside the EEA is necessary, we ensure that the processing of the personal data outside the EEA provides an adequate level of protection in accordance with the GDPR.

7Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data incident and will notify you and any applicable regulator of an incident where we are legally required to do so.

8Data retention

How long will you retain my personal data?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

9Your legal rights

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it.

Object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your data which override your rights and freedoms.

Request restriction of the processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (i) if you want us to establish the data's accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it, as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us using the contact details provided above.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests.

10Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

11Changes to the privacy notice and your duty to inform us of changes

We keep our privacy policy under regular review. Any changes we may make to our privacy notice in the future will be posted on this page. Please check back frequently to see any updates or changes to this notice. This version was last updated on 10 June 2021. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.