Privacy Policy

1, INTRODUCTION

It is very important for us to comply with the current data protection regulations and laws, so below we will discuss in detail the data protection steps and data collection processes of the scaleagency site and Varga-Márfy Ltd. The data is handled by Milán Varga-Márfy and he is responsible for the processing of personal data.

Contact information:

Full legal name: Milán Varga-Márfy

E-mail address: milan@scaleagency.hu

2, WHAT PERSONAL DATA ARE WE PROCESSING AND WHY?

Personal data are those that clearly allow an individual to be identified. On scaleagency.hu we process the following personal data, with the legal basis specified:

COMMUNICATION DATA

This includes any message you send to us via the website, email, social media or any other form of communication. This data is processed and retained to enable us to fulfil orders and to provide a basis for adjudication in the event of legal claims. Our legal basis for processing this data is the user's verifiable interest in our activities, as manifested in the messages sent to us.

CUSTOMER INFORMATION
This includes all information related to the purchase of products and services, such as the customer's name, shipping and billing address, email address, phone number, and product details purchased. This data is processed to ensure the successful fulfilment of orders and to keep legally correct records of purchases. The legal basis for storing the data is the performance of the contract between the customer and Varga-Márfy Kft.

USER DATA
This includes the data generated during the use of the website to enable the technical operation of the site, to maintain the security of the site, to keep a record of users' activities and to ensure that they have access to the most relevant content.The legal basis for processing the data is the clear interest of the user in our activities, which is necessary to ensure and maintain the technical operation of the site.

TECHNICAL DATA
This includes information generated when you use the site, such as your IP address, login information, browser information, time spent on each page, page views and navigation paths, the number and time of visits to the site, time zones, and the device you are using to view the site. The data source is our analytics software. This data is processed to analyse users' habits on the site, to maintain the secure operation of our site, and to understand the usefulness of our marketing decisions.The legal basis for processing the data is the user's clear interest in our activities, which allows us to process this data in accordance with security requirements and use it to enhance our business for more effective operation.

MARKETING DATA
Which includes the visitor's preferences, what marketing content they like to receive from us. We process this information to enable participation in sweepstakes and to send advertising related to our products/services in which the user has expressed an interest. The legal basis for processing the data is the user's clear interest in our activities, which allows us to process this data in accordance with security requirements and use it to increase business for more effective operations.We may use the data collected from time to time for purposes such as providing targeted, relevant advertising on the Facebook™ platform and various dynamic advertising platforms, and to measure the effectiveness of advertising. The legal basis for processing the data is the user's clear interest in our activities, which allows us to process this data in accordance with security requirements and use it to increase business for greater effectiveness. We do not collect sensitive data such as ethnicity, religious beliefs, sexual life and orientation, political opinions and trade union membership, or health background, and genetic or biometric information in the course of our activities.

3, HOW WE COLLECT DATA?

We may collect personal data in a way that the user provides directly to us (for example, by placing an order or sending a message).In addition, certain data is collected automatically when you use the Site, for example. "cookies" and similar technologies. For more information, please see our Cookie Statement.We receive certain data from external partners, such as analytics providers like Google (non-EU partner), advertising networks like Facebook™ (non-EU partner), and payment gateway partners like PayPal (non-EU partner) and Barion.

4, OUR PRACTICAL STEPS ON DATA PROTECTION

It is essential to protect users' data and to comply with current legislation. Therefore, after conducting a privacy impact assessment of the site, we have compiled a list of the data collected, its necessity and legal basis, and its legal compliance.

- To protect the data entered on the forms and generated on the site, we use SSL certification throughout the site (Let's Encrypt Authority X3 certification).

- To protect the site against attack, we use premium security software (iThemes Security Pro) to ensure that the so-called. "The site's databases store shopping and user data in encrypted form (pseudonymised), so that they cannot be read by third parties.

- In this privacy statement, we provide users with forms to request information about the processing of their personal data, and to modify or delete their personal data. From time to time, it is necessary for our business to provide data to our service partners (e.g. hosting provider, courier company, mailing software).In such cases, we always choose to comply with the GDPR regulation and to participate in the EU-US Privacy Shield initiative with our US-based partner and sign a data management contract with them, ensuring responsible data management.

5, MARKETING COMMUNICATIONS

Marketing communication is essential to the business. The legal basis for the processing of data in this context is the expression of interest in our services or the explicit consent of users.In accordance with the European Union's Privacy and Electronic Communications Regulations (PECR), we send marketing messages to our users if they have made a purchase from us or have explicitly consented to receive marketing messages.We always provide a prominent means of opting out and unsubscribing from these messages. You will find an unsubscribe link at the bottom of each individual email, or you can request to be removed from our database by emailing milan@scaleagancy.hu. We may also send messages to unsubscribe from marketing communications, but only in relation to the fulfilment of orders.

6, NOTE ON PERSONAL DATA

From time to time, it is necessary to share certain personal information with certain partners in order to maintain normal business operations:

- IT service providers and IT system troubleshooting and maintenance service providers

- Consulting partners such as lawyers, accountants, bankers, insurance companies

- Government agencies that request reports on our activities

- Payment service providers that securely handle credit card information

- Repail services that fulfill incoming orders to the delivery address provided

International data transfers

We sometimes need to share users' data with partners outside the European Economic Area (EEA) in order to maintain our business. Countries outside the EEA may not provide the same level of data protection, and European law prohibits the export of data unless the appropriate conditions are met. Whenever personal data is transferred outside the EEA, we will take the following steps, in addition to those discussed in section 4, to ensure the security of the data:

-We will only transfer data to countries that the European Commission considers appropriate from a data security perspective. We only use US-based services that are part of the EU-US Privacy Shield data security initiative.If the above is not met, we will ask for the explicit consent of users to opt-out of data transfers. Consent may be withdrawn at any time.

Links to external sites

This site may occasionally contain links to external sites or embedded code snippets that provide external services.Clicking on these links or using the embedded solutions may allow external partners to collect information about users.While we make every effort to screen partners appropriately, we have no control over their privacy practices and are not responsible for their privacy practices.

7, DURATION OF DATA PROCESSING

We will only ever store users' data for as long as we are required to do so by our legal/accounting/data obligations or as necessary for the operation of the service.When deciding on the length of storage, we take into account the volume, nature and sensitivity of the data and the potential impact of leakage in the event of a data breach. For tax reasons, we need to keep customer billing and purchase data for at least 8 years to comply with our legal obligations.In certain circumstances, we may use the data in anonymised form for statistical purposes, in which case we will keep the data indefinitely without notice.‍

8, RIGHTS OF THE VISITOR

As a citizen of the European Union, the General Data Protection Regulation (GDPR) gives users of the site the following rights:

a, Access to personal data: Users of the site have the right to request a copy of the personal data held by Varga-Márfy Kft. The request will generally be fulfilled free of charge within 14 days of the request.In the event of a repeated, abusive, unjustified request for data, Varga-Márfy Ltd. may charge a moderate fee for providing the data and may require additional time to provide the data.We also ask for proof of identity before providing the data to prevent misuse. To request personal data, please use the contact form below:Data Request / Data Deletion / Data Restriction

INSERT CONTACT DETAILS

b, Modification of personal data: If personal data have been modified or incorrectly provided, users have the right to request the modification of their data. To amend personal data, please contact us at gabi@marfy.hu.

c, Request deletion of personal data: Users have the right to request the deletion of all their personal data. The request will be granted free of charge within 14 days of the request. After the deletion of personal data, the user account will no longer be available, and any material purchased will also become unavailable, as the personal data associated with the user account is essential to access the service.

Varga-Márfy Ltd. requests proof of identity before deleting personal data to prevent misuse. To delete personal data, please use the contact form above.

d, Request to restrict the processing of personal data: users have the right to request to restrict the provision of their data to third parties (service partners). When submitting the request, the service partners to be restricted may be identified.

It is important to note that cooperation with certain service providers is essential for the operation of the site (e.g. Barion as a payment service provider), so in case of their limitation, the services of the site will be unavailable to the user.

Varga-Márfy Ltd. requests proof of identity before restricting the transfer of personal data to prevent misuse. To restrict the transfer of personal data, please use the contact form above:

The official data protection authority in Hungary is the National Authority for Data Protection and Freedom of Information (NAIH). Users can find out more about their data protection rights on the NAIH website,


1125 Budapest, Szilágyi Erzsébet fasor 22/C.,

Postal address: 1530 Budapest, Pf.: 5.,
Mobil: 06.1.391.1400,
Fax: 06.1.391.1410,
E-mail: ugyfelszolgalat@naih.hu
Website: http://www.naih.hu

9, ANONYMISED DATA AND "COOKIES"

On scaleagency.hu, in e-mail messages and advertisements, you use so-called. "These technologies help us to better understand the behaviour and interests of our users, thus helping us to operate at a higher and more efficient level.Our aim is to make the scaleagency.hu site as user-friendly and personal as possible. If the user wishes to prevent these technologies from collecting non-personal data, they can do so by:

- disabling the loading of these technologies by means of the cookie

- warnings displayed on the site