Klambó Kft. Data Processing Information and Privacy Policy

This Privacy Statement expresses our firm commitment to personality rights and data protection. Klambó Kft. handles your personal data with the utmost care, in accordance with this Privacy Statement and in compliance with Hungarian and European data protection laws.

This Privacy Statement is part of the Terms of Use of Klambó Kft. and the websites operated by it (klambo.trade), which must be read thoroughly. It precisely defines your rights and how you can exercise them. Any use of the Website implies acceptance of the entire Privacy Statement.

Contact details of the Data Controller:

Klambó Média Trade Kft.
Company registration number: 17-09-011743
Tax number: 26513117-1-17
7200 Dombóvár,
Dombó Pál u. 11.
[email protected]

Legal basis for data processing:

Point a) of Section 5 (1) of Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information (the data subject's consent) | The data subject's voluntary consent (GDPR Article 6(1)(a))
performance of a contract – GDPR Article 6(1)(b)
Invoicing: fulfillment of a legal obligation (currently effective tax and accounting laws)
Act C of 2003.

Designation of data processing:

Establishing and maintaining customer relationships, building a database, electronic sales, sending newsletters, data processing for marketing purposes. Sending newsletters, marketing content messages to email addresses used in the course of the Data Controller's activities, or to the email addresses of users registered on its websites. Selling products, services.

The personal data we request/handle:

IP address, email address, phone number, name, address, personal identification number (only for domain registration)

Detailed information:
Purpose of Data Processing
Type
Legal Basis for Data Processing
Type of Personal Data Processed
Processing Time
Data Forwarding
Enabling Registration
mandatory (prerequisite for registration)
preparation for concluding a contract – GDPR Article 6(1)(b)
last name, first name, email address, username, password (stored in an non-reversible format)
Until the Registration is performed. In case of its failure, they will be deleted after 3 days.
Server Providers
Login Identification Operation
mandatory (prerequisite for registration)
username, email address, password (stored in an non-reversible format)
last name, first name, email address, username, password (stored in an non-reversible format)
Withdrawal of the Data Subject's consent (GDPR Article 17(1)(b)) So if you delete your registration, we will delete or irreversibly convert this data of yours within a 30-day deadline.
Server Providers
Data necessary for issuing invoices for compliance with legal obligation
mandatory (after using a paid service)
fulfillment of a legal obligation (currently effective tax and accounting laws)
billing name, billing address, notification email address, phone number, data supporting the realization of economic activity: ordering IP address (in case of online order)
The time interval specified in the relevant laws.
Szamlazz.hu (KBOSS.hu Kft), Partner-E Kft., Server Providers
Providing online electronic payment option
optional
the Data Subject's voluntary consent (GDPR Article 6(1)(a))
last name, first name, billing name and address, phone number, email address
Withdrawal of the Data Subject's consent (GDPR Article 17(1)(b)) So if you delete your account/terminate the contract, we will delete or irreversibly convert this data of yours within a 30-day deadline.
Server Providers, OTP Mobil Kft.
Ensuring investigation and traceability of customer service complaints
mandatory (if you contact our customer service)
fulfillment of a legal obligation - Act CLV of 1997 on Consumer Protection Section 17/A (5) and 17/B (3)
Consumer complaint, remark submitted via electronic channel or phone and the related contact details (email address, phone number or facebook identifier)
fulfillment of a legal obligation - Act CLV of 1997 on Consumer Protection Section 17/A (5) and 17/B (3)
Google LLC, Server Providers
Performance of contract/ placing domain order
mandatory (if you also order a domain)
performance of a contract – GDPR Article 6(1)(b)
domain owner name, address, email address, phone number, personal ID number
The time interval specified in the relevant laws.
Rackhost Zrt., Server Providers
Order Fulfillment
mandatory (if you order a website)
performance of a contract – GDPR Article 6(1)(b)
your name, your email address, your phone number
The time interval specified in the relevant laws.
Stifter Balázs ev. (https://stifter.hu/adatkezelesi-tajekoztato/)
Contract Performance
mandatory (if you order an SMTP package)
performance of a contract – GDPR Article 6(1)(b)
your email address (sender, recipient address)
The time interval specified in the relevant laws.
Sendinblue.com (https://www.sendinblue.com/gdpr/)

Personal Data:

Using our company's services requires a request or registration, which may involve providing personal data. Disclosing this data is voluntary and occurs solely based on the User's will. The User is responsible for the accuracy of the data provided during the request or registration. By filling out the request or registration form, the User consents to the processing of the data provided by them by the Data Controller. The purpose of data processing is to implement the identifiability of Users and to provide the possibility of personalizing the service.

History and Log Entries:

All URLs of our portals you visited, time and date of website use. Your searches on the website. Technical data related to your internet browser and computer. If you decide to provide more information about yourself, you must explicitly permit us to use it, as described in this Privacy Statement.

Automatically Processed Data (Log Files):

Analyzing log files generated during services provides important information for the provider. The server server records the date of the request, the visitor's IP address, request type, time, URL retrieved from the server, (in case of error or missing file, the URL not reached), browser type used. Such information is not suitable for personal identification. We use this data to create statistics for the site, administer the services, and analyze visitor habits, which helps improve the quality of our services. The data set generated in this way is suitable for personal identification and is not linked to information from other sources. The purpose of data processing is to ensure the secure and continuous operation of the system. Only the Data Controller has access to the data managed by the Data Controller. By using the service, the User consents to the creation and processing of the data (and log files) described above.

What do we do with your personal data?

We use your personal data for the following: We send notifications regarding the Website, as well as our other products and services. We provide you with personalized advertisements. We create anonymous statistics about the users of the Website to improve the Website's operation and to provide statistical information to third parties. By registering on the Website, you acknowledge and agree that the provided profile data and other information - including your sensitive personal data - may become available in countries outside Hungary. We draw your attention to the fact that the level of data protection in non-European countries may be lower than in Hungary.

How do we share your personal data with third parties?

We hate spam as much as you do. We will never pass your email address to a third party. We may share statistical and anonymous information about our users for marketing and advertising purposes. In such cases, we never disclose data that could be used to identify you. We never share any other personal data of yours with any third party without your explicit permission. However, we may provide access to your personal data in case of illegal use, when we receive authorization from legal organizations or when our own rights are violated.

Cookies and Web Beacons

The Website uses cookies to identify you as a user of the Website, remember your language settings, and facilitate navigation on the Website. You can disable cookies in your internet browser, but in this case, some parts of the Website may no longer function properly.

Storage Time and Location

Klambó Kft. applies the following storage conditions: We store the information you uploaded until you request its deletion or until the purpose is achieved. History and log entries: we store them for 6 months from the creation of the history or log entry. Cookies: the maximum lifespan of cookies used on the Website is 100 days. Your personal data may be stored in a country that is not part of the European Union.

Security Measures

The security measures employed at Klambó Kft. prevent the loss of data under our control, misuse or modification of it. Klambó Kft. protects the security of your personal data with industry-standard methods. Although "perfect security" does not exist in the internet world, Klambó Kft.'s IT specialists do everything to ensure your online security. The Data Controller ensures the security of the data and takes the technical and organizational measures, establishes those procedural rules that are necessary for the enforcement of the relevant legal provisions. The data is protected especially against unauthorized access, alteration, disclosure, or deletion, as well as damage and destruction.

Your Rights

Right of Access

You can access your personal data free of charge (and modify, have it modified if necessary).

Right to Rectification

In case of change, please update your data as soon as possible! You have the right to prohibit the use of your personal data for direct marketing purposes.

Right to Erasure ('Right to be Forgotten')

The data subject has the right to obtain from the controller the erasure of personal data concerning him or her without undue delay upon request, and the controller is obliged to erase personal data concerning the data subject without undue delay if the data are no longer necessary for the purposes for which they were collected,
you withdraw your consent to the data processing, you object to the data processing, your data has been processed unlawfully, the data must be deleted due to Union or Member State law applicable to us,
You cannot exercise the right to erasure if:
data processing is necessary for the fulfillment of a legal obligation, for the enforcement of legal claims. You can initiate the deletion of your data by email, all you have to do is send an email to our address below: [email protected]. In the message, state that you wish to delete your data. We cannot restore a deleted subscription, but if you change your mind later, you can subscribe again.

Right to restriction of processing (Data Request / Accessibility)

Right to data portability

You have the right to retrieve all data stored about you. You can do this from the email address you used during registration, by sending an email to our central address: [email protected], and indicating that you would like a copy of the data stored about you.

Right to object

Rights related to automated decision-making and profiling

Statement on Disabling Tracking

Disabling tracking (Do not track or DNT) is a privacy setting that users can set through their browser. Using DNT, the user can inform websites or online services that they do not want any data to be collected about their website visit. It is extremely important to us to give everyone the opportunity to choose what data they share with us. Nevertheless, we do not detect or read DNT signals, as the internet world is still working on defining the meaning of DNT and compliance with it, as well as the appropriate response to DNT.

Statistics

The Data Controller's online interfaces use the Google Analytics service provided by Google, Inc. (headquarters: 1600 Amphitheatre Parkway Mountain View CA 94043) (hereinafter: "Google"), and the webanalytics services provided by Facebook Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; hereinafter: "Facebook") (Google, Hotjar and Facebook services hereinafter collectively: "Web Analytics Services"). The Web Analytics Services also use cookies to help analyze the use of the online interfaces. By using the online interfaces, accessing them, the data subject expressly consents that the information regarding the use of the online interface created by cookies is transmitted by Google Analytics to Google's servers in the United States of America and stored there. Cookies managed by Facebook are stored on our servers within the European Union. By using the Website, the User consents to the collection and analysis of their data in the manner and for the purposes defined above. Google and Facebook use this information to evaluate, analyze the use of the online interfaces by the data subject, compile reports on activities performed on the online interfaces, and provide other services related to activities performed thereon and internet usage.

Data Transfer

We transfer the data of our private and corporate clients for accounting purposes to Partner-E Kft. (7200 Dombóvár, Ady Endre utca 6. 1/2 - +36 30 262-9089) and to the NAV (Hungarian Tax and Customs Administration). For invoicing, we use the services of szamlazz.hu, who also receive our clients' data.(KBOSS.hu Kft., Headquarters: 1031 Budapest, Záhony utca 7., Company registration number: 01-09-303201) Their detailed information notice Transferred data: full name, tax number, billing address details, phone number, email address

Web and Reseller Hosting Data Processing:

Regarding data stored on our servers by Subscribers, the Data Controller is the Subscriber themselves. In this regard, Klambó Kft. acts as a Data Processor.
Regarding reseller and hosting agreements, Klambó Kft. provides assistance to its Subscribers for secure data storage, but this does not extend to becoming acquainted with the stored data or performing further data processing operations on this data. Klambó Kft. may only become acquainted with this data to the extent absolutely necessary for technical reasons for providing the service. In practice, Klambó Kft. only provides the technical conditions necessary for storage, but otherwise does not perform data controller activities.
Klambó Kft. applies the following IT security settings to provide the data controller with secure conditions according to GDPR Article 32 for these data processings:
  • Our IT partners store the data using redundant data storage
  • We make daily backups of the data
  • Firewall, fail2ban, antivirus, and WAF operate on Plesk servers
  • We provide a secure/encrypted channel for managing the Services (SSL, TLS)
  • We manage individual Plesk hosting accounts separately; software running on them does not have permission to access other hosting accounts
  • We automatically analyze Service logs; the system tries to block attack attempts
  • We inform the Data Controller (Subscriber) of recognized successful attacks and support them in the proper handling of the incident

If the Data Controller (Subscriber) judges that the provider's measures do not provide an adequate security level for storing the data it handles, or are not proportionate to the data processing risk of the mentioned data, then it is the Data Controller's task to conclude a separate Data Processing Agreement with Klambó Kft. In such cases, Klambó Kft. is entitled, based on the recognized risks, to consider whether, aware of the changed conditions, it undertakes the further hosting service, or applies a pricing different from the usual one to provide the possibly necessary conditions.


Data Processors

Hosting Providers/Server Providers
The hosting service is provided, as data processors, by our following partners:
Namecheap Inc. (4600 East Washington Street, Suite 305, Phoenix, AZ 85034, USA).
Privacy policies are available here: https://www.namecheap.com/about/privacy-commitment.aspx, https://www.namecheap.com/legal/general/privacy-policy.aspx More information can be requested here: https://www.namecheap.com/support/

AB Plusz Bt. (Headquarters: 2049 Diósd IV. Béla király utca 48., Company registration number: 01-06-757647, contacts: [email protected], phone: +36 1 4450509) https://www.abplusz.hu/adatkezelesi_tajekoztato https://abplusz.hu/tarhely_aszf

Our VPS/VDS servers are provided by Contabo GmBH. (Contabo GmbH, Aschauer Straße 32a, 81549 Munich, Germany, Tel: +49 89 3564717 70, Fax: +49 89 216 658 62, [email protected]).
Privacy policies are available here: https://contabo.com/data_privacy.html


By using our hosting service, you accept the terms of use and data processing guidelines of Plesk International GmbH (Vordergasse 59, 8200 Schaffhausen / CH) as well.
Considering that as a reseller we only provide hosting with Plesk control panel, this is essential for the performance of the contract.
You can find Plesk's GDPR/data protection documents here: https://docs.plesk.com/gdpr/

In certain cases, the data subject provides personal data on the online interface of the service called Google Forms provided by Google. In this case, Google qualifies as a data processor. In such cases, Google's data processor activity related to data processing is the provision of the technical background. Google's document titled Privacy Policy is available at the following link: https://www.google.com/intl/hu/policies/privacy/; and its address is: 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States; more information is available here: https://www.google.com/intl/hu/contact/.

As a data processor, in certain cases (e.g., sending newsletters) we may use the Mailchimp service. In this case, Mailchimp qualifies as a data processor. In such cases, Mailchimp's data processor activity related to data processing is the provision of the technical background. Mailchimp's privacy statement is available at the following link: https://mailchimp.com/legal/privacy/, and its address is: The Rocket Science Group LLC (Mailchimp) (675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA; more information is available here: [email protected], +1 (404) 806-5843. In certain cases, we may use the Purechat service for customer communication purposes. (13835 N Northsight Blvd Suite 205 Scottsdale AZ, 85260) More information: https://purechat.com/gdpr Contact: [email protected] And in the case of the automated customer assistant: We use the services of SnatchBot.me (8 Abba Eban Blvd, Herzliya Pituach, Israel): The purpose of data processing is to facilitate customer communication. You can read more about data storage, data protection here:
https://snatchbot.me/gdpr

If you order a separate SMTP package/service, then by default we use Sendinblue.com servers to send emails. (by default - unless you insist on another provider) The purpose of data processing is to be able to perform the contract, and to provide you with the specific SMTP service separately.
https://www.sendinblue.com/gdpr/
SENDINBLUE – 7 rue de Madrid, 75008 Paris, France,Intra-community VAT number: FR80498019298

In case of domain registration:
We are obliged to provide the provided personal data to the registrar for the purpose of domain registration.
Rackhost Zrt., 6722 Szeged, Tisza Lajos körút 41., +36 1 445 1200, [email protected]
More information is available here: https://www.rackhost.hu/privacy-policy

Reporting a Data Protection Incident, Breach

Anyone, including the data subject, has the opportunity to initiate an investigation by the National Authority for Data Protection and Freedom of Information (mailing address: 1530 Budapest, P.O. Box: 5.; address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c; Phone: +36 (1) 391-1400; Fax: +36 (1) 391-1410; e-mail: [email protected], URL: http://naih.hu) by filing a report referring to that a rights infringement occurred or its direct danger exists in connection with the processing of personal data. The right to turn to court is also guaranteed for the enforcement of rights pertaining to the data subject. The data subject may choose to initiate the lawsuit at the court competent according to their place of residence or stay.

Changes to this Privacy Statement

We reserve the right to modify this Privacy Statement at any time. We will publish a notice of any changes to the Privacy Statement on the Website so that you can always be informed about the data we collect, how we use it, and the conditions of its disclosure. The changes take effect thirty (30) days after their publication on the Website.

Last modified: 2020.06.23