1. The Purpose of the Privacy Policy

The purpose of this Policy is to record Tracon Budapest Kft.’s (Registered office: 2120 Dunakeszi, Pallag street 23, registration number: 13-09-061744, registration authority: Capital Court of Budapest as registry court, tax number: 10406218-2-13) data protection and data management principles and the Company's data protection and data management policy.

According to the certificate issued by the Hungarian Ministry of Justice, TRACON Budapest Kft. (hereinafter referred to as "the Service Provider") may carry out mail-order activities according to the law. The purpose of this Policy is to ensure that all services provided by the Service Provider, regardless of their nationality or place of residence, to all individuals, are assured that their rights and fundamental freedoms, especially respect their privacy during the  data processing of their personal data (data protection).

2. The Name of the Data Controller

Name: TRACON Budapest Kft.
Headquarters and mailing address: H-2120 Dunakeszi, Pallag utca 23.
Phone number: +36 27 540 000
Data Management Registration Number: NAIH-58863/2012

3. The Scope of the Handled Personal Data

3.1. Registration. During registration, the Partner must be required to provide the following personal information:

• username,
• own e-mail address,
• password,
• invoicing address (invoicing name/company name, street, house number, city, postal code),
• delivery address (delivery name/company name, street, house number, city, postal code),
• phone number

3.2. During system operation the technically processed data are the following: data generated of a user's logged-in computer when the service is being used and recorded by the data controller as an automatic result of the technical processes. The data is automatically recorded and logged without the user's statement or action when the user logged in or exit. These data can not be linked to other personal user information, except in cases that are mandatory by the law. These data is only accessible by the data controller.

3.3 The Tracon Webshop does not collect any data that is not provided by Partners, but the Partner hereby expressly accepts that to better serve it’s needs the Service Provider can place small data packages (so-called cookies) on it’s computer. The Partner can delete these cookies from it’s computer or can set it’s computer browser to disable using these cookies. The Partner notes that Tracon Webshop is using session cookies and long term cookies. The session cookies are only temporary cookies and store information as long as the Partner uses the Webshop and after use these cookies will be deleted. The long term cookies store information for a long time or for actual manual delete. The storage time of the cookies depends on the settings of the Internet browser used by the Partner. The Partner notes that the Tracon Webshop based on their functionality uses the following cookies: conversional cookies, which allow us to analyze each of our sales channels, tracking cookies which, together with the conversion cookies, enable more accurate channel analysis; remarketing cookies, based on which the Partner receives personalized content and ads, analytical cookies, which follow the website using  habits of the Partner; and inevitable cookies, which provide data according to the basic functions (e.g. search). 

4. The Legal Basis, Purpose and Method of Data Management

4.1. Data management is based on a voluntary, properly informed statement of users of website of www.tracon.hu and www.traconelectric.com ("Tracon Webshop"), which statement contains the express consent of users to use their personal information provided during the use of the website. The legal basis for data management is according to the Law of Information Self-determination Act and Freedom of Information Act (2011 CXII. Law (Information Law) Section 5 (1) (a) point, the voluntary contribution of the person concerned. The User give this contribution for each data management with the use of Webshop, with the registration, and with the data in question given by the User on voluntary basis.

4.2. The purpose of data management is to provide the services available in Tracon Webshop. The Service Provider stores the data provided by the Partner with specific purpose, solely for order fulfillment, delivery, invoicing, and if the user is subscribed to a newsletter, the Service Provider stores the newsletter sending and the later proof of the conditions of the contract that may be come into existence in the future. The voluntary given information provided by the subscriber is stored on computing and newsletter tools and software of the Service Provider and the Service Provider making security backup and store (only occasionally due to technical necessity) of these information. The subscription can be deleted at any time by clicking the unsubscribe link in the bottom line of any email the Service Provider send. The operator provides the unsubscription in all notifications.

4.3. The aim of the automatically recorded data is the preparation of statistics, the technical development of the IT system and the protection of user’s rights.

4.4. The data handler does not use or can not use the personal data provided for purposes other than those set out in these points. Issuance of personal data to a third party or to the authorities - unless otherwise provided by law with binding force – is possible only the prior express consent of the user.

4.5. The Data Manager does not check the provided personal information. The correctness of the data given is exclusively the responsibility of the person giving it. When any Partner giving it’s e-mail is also responsible using the service from the specified e-mail address solely. With respect to this responsibility, any liability associated with an entry in a given e-mail address exclusively responsible by the user who has registered the e-mail address. 

5. Duration of Data Handling

5.1. The handling of the personal data given mandatory during registration begins with the registration and last until the deletion of it.  For non-compulsory data, the data management will last from the data is entered till it has been deleted. The cancellation of the registration by the Partner and the registration cancellation by the Service Provider can be done at any time according in cases and manner fixed in the General Terms and Conditions (hereinafter: GTC).

5.2. Logged data will be stored for 6 months after the date of the log, except for the last visit date, which is automatically overwrite the date of log.

5.3. The above provisions do not affect the fulfillment of the preservation obligations laid down in the law (eg accounting law), as well as the data processing based on further contributions during registering into the Webshop or in other ways.

6. The Range of People Familiar with Data, Data Transfer, Data Processing

6.1. The Service Provider and Service Provider’s internal staff are the authorized persons to know the data primarily, but they not publish them and not give them to third parties.

6.2. For the operation of the underlying IT system, the fulfillment of the orders, and the settlements of the accounts Service Provider is free to use data processors (e.g. system operator, carrier company, accountant). The Service Provider is not responsible for the data management practices of such external person(s)/firm(s). In order to issue an electronic invoice, the Service Provider will transmit the data provided by the Customer to the Partner. The purpose of the data transfer: to issue an electronic invoice to the Customer, which the Service Provider sends electronically to the e-mail address given by the Customer.

6.3. In addition to the above, personal data relating to the Partner transmitted only in a legally binding manner and in accordance with the consent of the Partner.

7. User Rights and Remedy Possibbilities

7.1. The Partner is entitled to request information at any time about the Personal Data handling by the Service Provider of him/her and may, at any time, modify these data in the manner specified in the GTC. The Partner is also entitled to request the deletion of the data via the contact details provided in Section 7.3.

7.2. At the request of the Partner, the Service Provider provides information of the data handled, the purpose, the legal basis and the duration of the data management, and furthermore who and for what purpose receives or received the data. The Service Provider provide the requested information in writing within 30 days of the submission of the application.

7.3. You can exercise your rights in the following contact details:

Mailing address: 2120, Dunakeszi, Pallag u. 23.

Customer service: +36 27 540 000

The Partner may contact Service Provider with any questions or claims related to the processing of data via the contact details listed in Section 7.3.

7.4. The Partner is entitled to request any time the correction or cancellation of his/her incorrectly recorded data. The Partner can modify his/her data in the Webshop by himself/herself; in other cases, the Service Provider will delete the data within 3 business days of receipt of the request, in this case these data cannot be restored in the future. The deletion does not apply to data processing required by law (eg accounting rules), which the Service Provider preserves for the required period of time.

7.5. The Partner can enforce its rights according to the to the Law of Information Self-determination Act and Freedom of Information Act and the Civil Code (Act IV of 1959) and may contact to the National Privacy and Data Protection Authority (NAIH) (1125 Budapest, Szilágyi Erzsébet fasor 22 / C) in the case of the revealed complaint regarding the data management practices of the data controller.

7.6. In case third-party information has been given during the registration process while using the Partner service or during the usage of the Tracon Webshop you caused any damage, the Service Provider is entitled to claim damages against the Partner. In such a case, the Service Provider shall provide all available assistance to the determining authorities for the purpose of establishing the identity of the wrongdoer. 

8. Use of E-mail Addresses

8.1. The Service Provider shall pay particular attention to the legality of the use of the e-mail addresses it manages, so use them to send an e-mail (for information or advertisement) as specified below.

8.2. Managing e-mail addresses primarily serves to identify the Partner and to communicate during execute orders and access the services, so that e-mails are sent primarily for this purpose.

8.3. In some cases, the Service Provider provides information in electronic form by e-mail on the changes of services or on the changing of the GTC and on the changes of other similar services of the Service Provider. You cannot unsubscribe from this "notification list", but these notifications are not used by the Service Provider for advertising purposes.

8.4. Letters of advertising or newsletters to the e-mail addresses given during the registration will be sent by the Service Provider only with the explicit consent of the Partner and according to the cases and the manner prescribed by law. The User can always unsubscribe from the newsletter clicking on the link at the bottom of the newsletter. 

9. Other Provisions

9.1. The system of the Service Provider can collect data on Partner’s activity that can not be linked to other data provided by the Partner during registration, nor to any other data generated by the use of other websites or services.

9.2. In all cases where the Service Provider intends to use the provided data for purposes other than the purpose of the original data collection, shall inform the Partner thereof, and shall obtain such a prior express consent or give the Partner the opportunity to prohibit the use.

9.3. The Service Provider commits to provide the security of the data and also to take the technical steps to ensure that the data that are recorded, stored or managed is protected and that the Service Provider does everything to prevent their destruction, unauthorized use and unauthorized modification. And the Service Provider also commits that any third party to which the data may be transmitted or handed over also calls for compliance with this obligation.

9.4. The Service Provider reserves the right to unilaterally modify this Policy without prior notification of the Partners. Upon the entry into force of this amendment, the Partner accepts the terms of the Modified Policy with the use of the service by conduct.

19^th February, 2016. Dunakeszi