DATA MANAGEMENT INFORMATION

1. Data controller's data:

MarciTrans Ltd.

ELIGIBLE:

FROM 20 APRIL 2022

UNTIL WITHDRAWAL

Name of the entrepreneur: MarciTrans Ltd.

Address: 6300 Kalocsa, Borsó str. 4.

VAT Id: 22295008-2-03

Registration number: 03-06-114184

Phone number: 06305554597

E-mail address: info@marcitrans.hu

2. Purpose of the Privacy Notice:

The controller acknowledges that it is bound by the contents of this legal notice. The purpose of this Privacy Notice is to inform its customers, partners and clients about the processing of their personal data. The data controller shall process personal data only in accordance with the provisions of applicable law and in strict compliance with the provisions of the data management and data protection regulations, taking into account the principles of lawfulness, fairness and transparency, purpose limitation, data minimisation, accuracy and limited storage. The data controller shall take all technical and organisational measures to ensure that the personal data of its partners are processed in a secure manner, as required by Regulation (EU) 2016/679 of the European Parliament and of the Council. The controller has developed its day-to-day activities, policies, records, templates and information documents in accordance with the above. The data protection policies relating to the controller's processing are permanently available at the controller's headquarters and on its website. The controller reserves the right to change this notice at any time. It will of course inform its audience of any changes in due time. The data controller is committed to protecting the personal data of its customers and partners, and attaches the utmost importance to respecting the right of information self-determination of its customers. The data controller treats personal data confidentially and takes all security, technical and organisational measures to guarantee the security of the data. The controller describes its data management practices below.

3. The personal, material and temporal scope of the Privacy Notice:

The personal scope of this Privacy Notice covers the controller and the natural persons whose data are included in the processing covered by this Notice, as well as the persons whose rights or legitimate interests are affected by the processing. The material scope of this Notice covers all processing that takes place in the course of the controller's online marketing consultancy activities. This Notice shall enter into force on the date of approval and shall remain in force indefinitely until further notice.

4: Important definitions

Personal Data: any information relating to an identified or identifiable natural person. Identifiable natural person means a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the natural person. Special Data: any data falling within special categories of personal data, i.e. personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data revealing the unique identity of natural persons, health data and personal data concerning the sex life or sexual orientation of natural persons. Data processing: any operation or set of operations which is performed upon personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, transmission, dissemination or otherwise making available, alignment or combination, restriction or destruction. Controller: a natural or legal person, public authority, agency or any other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Processor: a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller. Joint controllers: where the purposes and means of processing are determined jointly by two or more controllers, they are considered to be joint controllers. Third party: a natural or legal person, public authority, agency or any other body other than the data subject, the controller, the processor or the persons who, under the direct authority of the controller or processor, are authorised to process personal data. Consent of the data subject: a freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she signifies, by a statement or by an act unambiguously expressing his or her consent, that he or she signifies his or her agreement to the processing of personal data concerning him or her. Data breach: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

5. Lawful processing by the controller:

Personal data are processed by the controller only in the following cases:

where the data subject has given his or her consent to the processing of his or her personal data for one or more specific purposes,
processing is necessary for the performance of a contract to which the data subject is a party,
processing is necessary for compliance with a legal obligation to which the controller is subject,
processing is necessary for the protection of the vital interests of the data subject or of another natural person,
processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party.

The controller shall verify the lawfulness of processing at all stages of its activities, and shall process only data for which it can justify the purpose and legal basis and only for such time as is necessary to fulfil the legitimate interests of the data subject. In the event that the conditions of a legal basis cease to apply, the processing may only be resumed if the controller can demonstrate an adequate alternative legal basis. As a general rule, the method of justification of the legal basis is in writing, but even in the case of a legal basis established by imputability, it should be examined whether it can be clearly justified ex post. In case of doubt, for reasons of reasonableness and economy, written confirmation of the imputability should be sought. In the case of processing based on consent, the data subject gives his or her written consent to the processing of his or her personal data. Consent is not formally binding, but subsequent evidence requires written consent on paper or in electronic form. Processing based on a legal basis is independent of the data subject's consent, as the processing is defined by law. Irrespective of the mandatory nature of the processing, the private individual concerned must be informed before the processing starts that the processing is mandatory and cannot be avoided, and must be provided with clear and detailed information on all relevant facts concerning the processing of his or her data before the processing starts. According to the GDPR (General Data Protection Regulation), personal data may also be processed where the processing is necessary for the performance of a contract to which the individual concerned is a party or where the processing is necessary for the purposes of taking steps at the request of the data subject prior to entering into a contract. The controller may process personal data for the purposes of the conclusion, performance or termination of the contract on the basis of the legal basis for performance of the contract.

6. Processing of personal data by the controller:

The main profile of the data controller is road transport (international road freight, domestic road freight, moving, transport organisation etc.). The data controller comes into contact with personal data of natural persons in the course of these activities. It carries out the following processing activities:

The contractual partners of the data controller in connection with its road transport organising activities may be both natural persons and legal entities. The conclusion of a contract is preceded by a request for a quote, in the form of a message by phone or e-mail. The requesting party gives his/her name, telephone number and e-mail address to which the controller sends his/her offer. If the offer is rejected, the personal data of the interested party will be deleted without delay and at the latest within 3 working days. The legal basis for the processing of personal data is the establishment of a contract (Article 6(1)(b) of the General Data Protection Regulation). If the data subject orders the offered service, a contract is concluded. When the contracts are concluded, the controller will have access to additional personal data of individuals (partners and contacts). The legal basis for the processing is the performance of the contractual obligation (Article 6(1)(b) of the General Data Protection Regulation), and in the case of a contact person of a legal person, the consent of the data subject (Article 6(1)(a) of the General Data Protection Regulation). The controller issues an invoice for the services provided. The invoice shall contain the name, address and, where applicable, the tax number of the data subject. The issuing of the invoice is a statutory obligation of the controller. The legal basis for the processing of the personal data on the invoice is therefore the fulfilment of a legal obligation (Article 6(1)(c) of the General Data Protection Regulation). The controller shall act in accordance with the legal provisions as regards the storage of the personal data on the invoice and shall store them for a period of 5 years.
In the course of performing its tasks as an road transport organiser, the data controller may become aware of the personal data of the clients' partners. In this respect, the data controller is a data processor, as it processes personal data for the purposes specified by the client (as data controller). The data controller will always enter into a so-called data processing contract with the principal, in which it declares that it will operate in full compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council and will not process the personal data of the principal and its partners for purposes other than those documented in the mandate contract with the principal, unless such processing is required by the applicable legislation in force. The data controller shall take reasonable steps to ensure the confidentiality of any principal who may have access to the principal's personal data and shall ensure that such access is only granted to those persons who have a strictly necessary need to know or have access to the principal's personal data for the purposes of the mandate. The controller shall sign an appropriate confidentiality agreement with each such person. The controller shall keep business secrets disclosed to it in the course of its activities and essential information concerning the principal and its partners and their operations. The data controller shall use the data, procedures, methods, documents, documents or other information relating to the principal and partners only for the performance of its tasks and shall not disclose them to unauthorised persons or organisations, nor shall it disclose them to third parties or otherwise misuse them. It shall treat information, documents and analyses provided by the principal as confidential and shall not disclose them to third parties.
In the performance of its tasks, the data controller processes the e-mail addresses and telephone numbers of its partners and clients in the performance of its contractual obligations (Article 6(1)(b) of the General Data Protection Regulation) or on the basis of their individual consent (Article 6(1)(a) of the General Data Protection Regulation).
In this case, the legal basis for the processing of personal data is (in the case of an individual or sole trader) the performance of a contractual obligation (Article 6(1)(b) GDPR), and in the case of personal data of a contact of a legal person, the explicit, prior informed consent of the data subject (Article 6(1)(a) GDPR).
Personal data contained in the CV will also be processed. The legal basis for processing is the consent of the data subject (Article 6(1)(a) of the General Data Protection Regulation).
The data controller presents its activities and services primarily on its own website (website). The website informs visitors about the content and contact details of the services of the data controller. The website uses cookies in its operation, which also collect personal data from visitors. The legal basis for the processing is the data subject's consent (Article 6(1)(a) of the General Data Protection Regulation).
The data controller also operates a Facebook page for marketing purposes to present its activities and services. Here, too, the data of the page's followers are processed. The legal basis for the processing is the consent of the data subject (Article 6(1)(a) of the General Data Protection Regulation).
In the course of complaint handling in connection with the activities of the data controller, the purpose of data processing is to enable the communication of the complaint, the identification of the data subject and his/her complaint, the recording of data required by law, the investigation of the complaint and the maintenance of contact in connection with its resolution.

In case of a complaint, the processing of the complaint and thus of personal data is mandatory under Act CLV of 1997 on Consumer Protection. The legal basis for the processing of personal data is therefore the fulfilment of the legal obligation (Article 6(1)(c) of the General Data Protection Regulation). The controller keeps a register of the processing of the data described above. The register shall also contain the time limits for the erasure of personal data. The register is annexed to this Data Processing Notice.

7. Processors connected to the controller:

Where the processing is carried out on behalf of the controller, the controller may only use processors that offer adequate guarantees of compliance with the requirements of the General Data Protection Regulation or implement appropriate technical and organisational measures to ensure the protection of the rights of data subjects. The controller hereby declares that in the course of its work, it will only use processors that offer adequate guarantees of compliance with the GDPR Regulation and implement appropriate technical and organisational measures to ensure the protection of the rights of data subjects. The relevant declarations of the data processors are available to you. By reading and acknowledging this Privacy Notice, data subjects accept that the controller transfers their personal data to the processors and joint controllers listed below.

The data processor is the accounting firm employed by the controller: the controller.
The data controller's partner for the issuing of invoices:
- Clear Admin Software Kft. 1108 Budapest, Gőzmozdony utca 14. cégjegyzékszám: 01-09-983349; adószám: 23899595-2-42
The company hosting the website of the data controller is also a data processor:
o C-Host Kft. postal address: 1115 Budapest, Halmi utca 29. representative : Varga György phone nr.: +36 1 445 2040 e-mail: info@nethely.hu web: https://www.nethely.hu/

The controller's mail server is also a data processor:
- Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
Additional data processor in connection with the sending of this newsletter: none
No data processor due to the use of Google Analytics and other services on the controller's website:
- Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
Data processor and joint data controller partner for the use of the Facebook page:
- Facebook Ireland Ltd., 4 Grand CanalSquare, Grand CanalHarbour, Dublin 2 Ireland
The service provider is considered as data processor when storing data in the cloud-based online database:
- Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland

The contracted data processor and data controller partners will process the personal data of the partners solely on the basis of instructions given by the data controller (except where a legal requirement applies) and under an obligation of confidentiality.

8. Processing of data relating to contracts concluded by the controller:

Customer contracts:

The contractual partners of the controller in relation to its road freight forwarding activities may be both natural persons and legal entities. The conclusion of a contract is preceded by a request for a proposal in the form of a message by telephone or e-mail. The contracting party will provide his name, telephone number and e-mail address to which the controller will send his offer. If the offer is rejected, the controller shall delete the personal data of the interested party without delay and at the latest within 3 working days. The legal basis for the processing of personal data is the establishment of a contract (Article 6(1)(b) of the General Data Protection Regulation). If the data subject orders the offered service, a contract is concluded. When the contracts are concluded, the controller will have access to additional personal data of individuals (partners and contacts). The legal basis for the processing is the performance of the contractual obligation (Article 6(1)(b) of the General Data Protection Regulation), and in the case of a contact person of a legal person, the consent of the data subject (Article 6(1)(a) of the General Data Protection Regulation). The controller issues an invoice for the services provided. The invoice shall contain the name, address and, where applicable, the tax number of the data subject. The issuing of the invoice is a statutory obligation of the controller. The legal basis for the processing of personal data on the invoice is therefore the fulfilment of a legal obligation (Article 6(1)(c) of the General Data Protection Regulation). With regard to the storage of personal data on the invoice, the controller shall act in accordance with the provisions of Act CXLVII of 2012 on the Itemised Tax on Small Taxable Enterprises and on Small Business Tax and shall store them for a period of 5 years.

Supplier contracts:

The data controller may also process the contact details (name, e-mail address, telephone number) of suppliers and may be in contact with service providers and subcontractors. In these cases, personal data may also be processed (personal data of the contact person or of the individual or sole trader) in order to keep in contact with partners. The legal basis for the processing of personal data is the performance of a contractual obligation (Article 6(1)(b) of the General Data Protection Regulation) or the consent of the contact person (Article 6(1)(a) of the General Data Protection Regulation). The controller will fill in a consent form with the contact persons of the companies, informing them of their rights in relation to personal data and asking for their consent to process their data. In such cases, the legal basis for the processing of personal data shall be the explicit, written and informed consent of the data subject to the processing (Article 6(1)(a) of the General Data Protection Regulation). If the contract with the partner has been terminated and the legal obligation to keep the data and documents no longer applies, the telephone numbers and e-mail addresses shall be deleted. With regard to the retention of personal data contained in the contract and the invoice, it shall also act in accordance with the provisions of Act CXLVII of 2012 on the Itemised Tax on Small Taxable Enterprises and Small Business Tax and shall store them for 5 years.

Processing of invoices issued to customers and the personal data contained therein:

The controller issues invoices for the value of the services it provides. The invoice contains the name, address and possibly the tax number of the data subject. The issuance of the invoice is a legal obligation of the controller. The legal basis for the processing of personal data on the invoice is therefore the fulfilment of a legal obligation (Article 6(1)(c) of the General Data Protection Regulation). With regard to the storage of personal data on the invoice, the controller shall act in accordance with the provisions of Act CXLVII of 2012 on the Itemised Tax on Small Taxable Enterprises and on Small Business Tax and shall store them for 5 years.

11. Procedure for the retention of e-mail addresses and telephone numbers:

In the course of its activities, the controller shall also obtain the e-mail addresses and telephone numbers of its partners, clients and customers. If the contract with the partner has been terminated and there is no legal obligation to keep the data and documents, the telephone numbers and e-mail addresses will be deleted. In some cases, the data controller will still have a legitimate interest in retaining the data and will request the explicit and written consent of the data subject to the retention of his or her personal data (Article 6(1)(a) of the General Data Protection Regulation).

12. Processing of applications and CVs received by the data controller:

Natural persons applying to the controller may submit a CV to the undertaking. Where the CV is submitted because the controller is looking for an employee and has advertised the vacancy, the CV may only be used in relation to that vacancy. If the applicant does not meet the conditions for the advertised position and another candidate is selected, the CV will be immediately destroyed. The controller may only retain the application on the basis of the explicit, unambiguous and voluntary consent of the data subject (Article 6(1)(a) of the General Data Protection Regulation), provided that its retention is necessary for the purposes of the processing. The controller will not post "anonymous" job advertisements (job advertisements in which the employer does not disclose its name, so that at the time of sending the job application, the applicants may not be aware of the employer to which they are applying for the job), as this is contrary to the requirement of prior information about the identity of the controller. In any case, the controller shall inform the data subjects of his identity when advertising a job. If the applicant has voluntarily sent a CV to the controller without an advertisement, he or she shall declare whether he or she consents to the processing of personal data by the controller. The submission of a CV does not imply that the data subject consents to the controller keeping his/her application file. It is also important to note that the controller may use the CV only in relation to vacancies indicated by the job applicant. As a general rule, CVs will be kept for 3 months, unless the data subject specifies a longer period in his/her consent. The data controller will only check and obtain information from the applicant's profile page on the social networking site when assessing the application for a job if it has informed the data subject in advance. Even in such cases, only public data will be consulted and only information that is relevant to the job application or the job will be taken into account in the selection process. Under no circumstances will the job applicant's profile page be saved or stored and transmitted to third parties. If the data subject is not selected for the job in question, the controller will inform him/her of this and of the reasons for the rejection.

13. The controller's website:

The data controller presents its activities and services primarily on its own website (website). The website informs visitors about the contact details of the controller and the content of its services. The website of the controller uses cookies in its operation. The legal basis for the processing of personal data obtained from them is the consent of the visitor (Article 6(1)(a) of the General Data Protection Regulation).

Cookies (Cookies):

The function of cookies:

Collect information about visitors and their devices;
They collect information about the cookies they use;
Facilitate the use of the website;
- provide a quality user experience.

In order to provide a personalised service, a small piece of data called a cookie is placed on the user's computer and read back during a subsequent visit. If the browser returns a previously saved cookie, the cookie management service provider has the possibility to link the user's current visit to previous visits, but only for its own content. Session cookies. This type of cookie is valid until the end of the session and is automatically deleted from the computer or other browsing device when the browser is closed.

The data subject's choice in relation to the Cookie:

Web browser Cookies: in the browser settings, the data subject can accept or reject new Cookies and delete existing Cookies. You can also set your browser to notify you each time a new cookie is placed on your computer or other device. You can find more information about how to manage cookies in the "help" function of your browser. If a visitor chooses to disable some or all of the cookies, he or she will not be able to use all of the website's features. Third-party cookies (analytics). Google Analytics is a web analytics service used by the controller to collect information about how visitors use the website. The data is used to improve the website and the user experience. These cookies will also remain on the visitor's computer or other browsing device and browser until they expire or until they are deleted by the visitor. When websites or applications use Google Analytics in combination with other Google advertising products, such as Google Ads, they may also collect other advertising identifiers. Users can turn this service off or change their cookie settings in their Ads settings. Google Analytics collects users' IP addresses in order to maintain the security of the service and to allow website owners to build up a picture of which country, state or city their visitors come from (also known as "IP geolocation"). Google Analytics offers the possibility to mask the IP addresses collected, but website owners can still see users' IP addresses even if they do not use Google Analytics. The IP address transmitted by the visitor's browser in the context of Google Analytics is not merged with other Google data. You can prevent the storage of cookies by configuring your browser software accordingly, but in this case the visitor may not be able to use all the functions of the website to their full extent. In addition, the visitor can prevent the collection of data (including his IP address) generated by cookies and relating to the visitor's use of the website by Google and the processing of this data by Google by downloading and installing the browser plug-in under the link below. The current link is https://www.google.com/policies/privacy/ads//. Google acts as a data processor for Google Analytics and thus as the data controller. Google Analytics is the data processor under the provisions of the General Data Protection Regulation (GDPR), as Google Analytics collects and processes data on behalf of its clients (e.g. the data controller), under the instructions of those clients. Google may only use the data in accordance with the terms of the contracts with Google Analytics customers and the settings provided by the customers in the interface of its products. Google Analytics collects internal cookies, device/browser information, IP addresses and activity on the website/application. This data is collected so that it can be used to measure and statistically report on the actions taken by users on websites and/or applications that use Google Analytics. Clients can personalise the cookies and the data collected through features such as cookie settings, User ID, Import Data and MeasurementProtocol. For clients using the Google Analytics Application SDK, Google collects an application instance ID. This is a number generated randomly by the system when a user installs an application for the first time. Google Analytics uses IP addresses to infer the geographic location of visitors and to protect the service and its customers. Clients can enable a feature called IP masking, which allows Google Analytics to use only a subset of the IP address instead of the entire IP address collected. In addition, customers can also override IP addresses on demand using the IP override feature. Google uses the data processed in Google Analytics to provide its customers with the Google Analytics measurement service. Identifiers, such as cookies and application instance identifiers, are used to measure what actions users take on customers' websites and/or applications. It uses IP addresses to maintain the security of the service and to give website owners an overview of where their users come from around the world. The data subject declares on the controller's website that he or she is over 16 years of age when accepting the use of cookies. A person under the age of 16 may not make a declaration of acceptance or rejection of cookies used by the website, given that, pursuant to Article 8(1) of the GDPR, the validity of his/her declaration of consent to the processing requires the consent of his/her legal representative. The controller is not in a position to verify the age and entitlement of the person giving consent, so the data subject warrants that the data he or she has provided are accurate. Personal data processing in relation to the reviews on the website. The reviews include full names and a picture. The full name, image (possibly other personal data) and opinion of the reviewer will only be displayed on the website if he/she has given his/her written informed consent (Article 6(1)(a) of the General Data Protection Regulation). Personal data processing in relation to comments on posts: the controller publishes blog posts on its website. The blog posts are published on the website of the blogger. By entering the comment and personal data, the data subject gives his/her consent to the processing of his/her personal data and to the publication of the website by ticking the box provided. The legal basis for the processing of personal data is the data subject's informed consent (Article 6(1)(a) of the General Data Protection Regulation). The data subject declares that he or she has read and understood the Controller's Privacy Notice and has taken note of the information contained therein. If the data subject so requests, his or her personal data may be backed up. In this case, the data will not need to be re-entered when a subsequent post is made. The controller will not use the personal data for any other purpose and will not make them available to third parties. Only the name of the data subject will be published on the website in the post. The controller shall process personal data recorded in this way until the data subject's consent is withdrawn. If the data subject withdraws his or her consent, the controller shall delete the recorded personal data from its system without undue delay and at the latest within 3 working days. The data subject declares on the controller's website that he or she is at least 16 years of age when making comments on blog posts. A person under the age of 16 is not allowed to comment on the posts, given that, pursuant to Article 8(1) of the GDPR, the validity of his or her consent to the processing of the data requires the consent of his or her legal representative. The controller is not in a position to verify the age and entitlement of the person giving consent, so the data subject warrants that the data he or she has provided is accurate.

15: The controller's social media page

The controller also operates a Facebook page, where personal data are also processed. The controller also promotes its activities and services on Facebook. The controller uses this page for marketing purposes. https://www.facebook.com/marcitrans The controller also provides comprehensive personal support through Facebook. If you ask a question via Facebook, the controller will try to answer it as soon as possible. The data you provide on the Facebook page will only be used to answer your question and will not be used for any other advertising purposes. The purpose of using the Facebook page is to advertise and provide information on a social media platform. Facebook may also use the data for its own purposes, including profiling and targeting the data subject with advertising. To be able to contact the data controller via Facebook, you must be logged in. To do so, Facebook may also request, store and process personal data. The controller has no control over the type, scope and processing of this data and does not receive personal data from the Facebook operator. For more information on this, please visit the Facebook page. The personal data of Facebook page followers are processed by the data controller on the basis of their consent (Article 6(1)(a) of the General Data Protection Regulation), which is deemed to be given by the fact that the person concerned likes, follows or comments on the page and its posts.

16. Personal data processing in the use of cloud-based applications:

The data controller uses cloud-based services primarily for storing, backing up and sharing documents. A common feature of such services is that they are not provided by the user's computer, but by a remote server, a server centre located anywhere in the world. Such services are also provided by online hosting. A major advantage of cloud applications is that they provide a highly secure, flexible and scalable IT storage and processing capacity, essentially independent of geographical location. In these cases, the cloud service provider can be considered as a data processor, processing personal data on behalf of the data controller. Cloud service providers are obliged to keep personal data confidential and may only process personal data on the instructions of the controller. The data controller shall take the utmost care in the selection of its cloud service partners, take all measures reasonably necessary to contract with them in a manner that is compatible with the data security interests of its customers, their data processing principles are transparent to the data controller and data security is regularly monitored. Cloud storage is password protected and only the data controller has access to the data stored there. The data controller's partners expressly consent to the transfer of data necessary for the use of cloud applications by accepting this Privacy Notice. The legal basis for the processing is the consent of the data subject (Article 6(1)(a) of the General Data Protection Regulation).

17: Complaints handling regarding the controller's activities:

The purpose of the processing of complaints about the controller's activities is to enable the communication of the complaint, to identify the data subject and his/her complaint, to record the data required by law to be recorded, to investigate the complaint and to contact the controller in connection with its resolution. Once a complaint has been made, the handling of the complaint, and thus the processing of personal data, is mandatory under Act CLV of 1997 on Consumer Protection. The legal basis for the processing of personal data is therefore the fulfilment of the legal obligation (Article 6(1)(c) of the General Data Protection Regulation). The controller keeps the record of the complaint and a copy of the reply for 5 years, and therefore processes the personal data for this period.

18. Security of data processing:

The data controller undertakes to ensure the security of the data, to take technical and organisational measures and to maintain procedural rules to ensure that the data recorded, stored or processed are protected and to prevent their destruction, unauthorised use or unauthorised alteration. It also undertakes to require any third party to whom it transfers or discloses the data to comply with the requirements of data security. The controller shall ensure that the data processed cannot be accessed, disclosed, transmitted, modified or erased by unauthorised persons. The data processed may only be accessed by the controller and its data processor(s) and shall not be disclosed to third parties not entitled to access the data. The data controller shall pay particular attention to the security of the personal data of its partners, clients and customers. It shall act in full compliance with the legal provisions and shall require all its partners to do the same. The protection of personal data includes physical protection (storage of documents in a lockable room) and IT protection (use of anti-virus software, password protection). The controller shall store the personal data provided by the data subject primarily on the servers of the data processor(s) indicated in this Privacy Notice, equipped with the usual protection systems, and partly on its own IT equipment, in case of paper media, at its headquarters, in an appropriately locked manner. The data subjects acknowledge and accept that, in the event that they provide their personal data, the data protection cannot be fully guaranteed on the Internet and on the computer system. In the event of unauthorised access or disclosure, despite the efforts of the controller, it is necessary to proceed as described in this notice.

19. Rights of data subjects:

Transparent information:

The purpose of this Privacy Notice is also to provide clear, concise, transparent and understandable information about the processing activities carried out by the controller.

Right of access:

The data subject has the right to receive feedback from the controller as to whether or not his or her personal data are being processed and, if such processing is ongoing, the right to access the personal data and the following information:

the purpose of the processing,
the purpose of the processing; the categories of personal data concerned,
the categories of recipients to whom the personal data have been disclosed,
the intended storage period of the personal data.

Right to rectification:

The data subject has the right to have inaccurate personal data relating to him or her corrected by the controller at his or her request.

Right to erasure:

The data subject has the right to obtain, at his or her request, the erasure of personal data relating to him or her by the controller. The data controller is obliged to delete personal data on the basis of this request if one of the following grounds applies:

the personal data are no longer necessary for the purposes for which they were collected,
the data subject withdraws his or her prior consent and there is no other legal basis for the processing,
the data subject objects to the processing and there are no overriding legitimate grounds for the processing,
the personal data have been unlawfully processed,
the data must be erased in order to comply with a legal obligation under EU or Member State law.

Right to restriction of processing:

A data subject has the right to request the controller to restrict processing, in particular where:

the personal data have been unlawfully processed,
the data must be erased in order to comply with a legal obligation under EU or Member State law.

Right to restriction of processing:

The data subject has the right to receive personal data relating to him or her in a structured, commonly used, machine-readable format and the right to have such data transmitted to another controller.

Right to object:

The data subject has the right to object at any time, on grounds relating to his or her particular situation, to the processing of his or her personal data, as provided for in Article 21 of Regulation (EU) 2016/679 of the European Parliament and of the Council.

Right of the data subject in case of automated decision-making:

The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or significantly affects him or her. Automated decision-making is any process or methodology whereby a technical automatism evaluates personal aspects relating to the data subject and which produces legal effects concerning him or her or significantly affects him or her. The controller shall not use IT automated mechanisms, including profiling, which produce legal effects concerning the rights of the data subject

You may request information about the above data from the controller at the following address and e-mail address: MarciTrans Bt. 6300 Kalocsa, Borsó u. 4. E-mail: info@marcitrans.hu The controller hereby informs you that it will respond to your request within 30 days. The data controller shall reply to requests for information sent by post by post, and to requests sent by e-mail by e-mail. The controller undertakes to inform all recipients to whom it has disclosed personal data of requests sent to it in relation to the above rights, unless this proves impossible. It further undertakes to notify the data subject (applicant) of the decision on the processing of the above requests within 30 days at the latest.

20. Data Protection Incident:

A data breach is a breach of security that results in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed. In the event of a data breach, the level of the breach must be at a serious risk level, i.e. the breach must be of such a degree that the personal data:

destruction,
loss,
alteration,
unauthorized disclosure or
unauthorised disclosure or access.

An incident shall be deemed to occur if any of the above occurs, but this does not exclude the simultaneous occurrence of more than one of the above. This includes not only intentional, malicious conduct, but also negligent harm. An incident therefore occurs when it is caused by an accidental or unlawful act. An example of a data breach is:

the unlawful transmission of personal data on a document, portable device, storage medium or IT system (e.g. by mail),
unauthorised access to an IT system or application that processes personal data,
damage to or loss of part or all of a database containing personal data,
rendering part or all of an IT system unusable by a virus or other malicious software, etc.

A personal data breach may cause physical, material or non-material damage to natural persons, including loss of control over their personal data or restriction of their rights, discrimination, identity theft, if not addressed in an appropriate and timely manner, or misuse of identity, financial loss, unauthorised impersonation, damage to reputation, damage to the confidentiality of personal data protected by professional secrecy, or other significant economic or social disadvantages suffered by the natural persons concerned. In the event of a potential data protection incident (unless the data protection incident is unlikely to pose a risk to the rights and freedoms of natural persons), the controller shall immediately notify the National Authority for Data Protection and Freedom of Information. As soon as the controller becomes aware of the incident, it shall notify it without undue delay and, if possible, no later than 72 hours after becoming aware of the personal data breach. If the notification cannot be made within 72 hours, the notification shall state the reason for the delay and provide the required information in detail without further undue delay. The National Authority for Data Protection and Freedom of Information operates a dedicated system for the notification of a personal data breach on its website, through which notifications can be made electronically. The controller shall keep a record of personal data breaches, indicating the facts relating to the personal data breach, its effects and the measures taken to remedy it. The controller shall keep records of the data relating to the incident, including the causes, the events and the personal data involved. In addition, the record should also include the effects and consequences of the incidents and the measures taken to remedy them, and the conclusions of the controller (for example, why it thinks the incident is not reportable, or if the notification is delayed, the reason for the delay). An incident that is unlikely to pose a risk to the rights and freedoms of natural persons need not be notified to the supervisory authority. If the data protection incident is likely to present a high risk to the rights and freedoms of the data controller's partners, clients, customers, we will inform the partner concerned without delay. The information provided to the data subject shall clearly and plainly describe the nature of the personal data breach and shall include the most relevant information and measures. The data subject need not be informed as described above if any of the following conditions are met:

the controller has implemented appropriate technical and organisational protection measures and these measures have been applied to the data affected by the personal data breach, in particular measures that render the data unintelligible to persons not authorised to access the personal data;
the controller has taken additional measures following the personal data breach to ensure that the high risk to the rights and freedoms of the data subject is no longer likely to materialise;
the provision of information would require a disproportionate effort. In such cases, the data subjects shall be informed by means of publicly disclosed information or by means of a similar measure ensuring that the data subjects are informed in an equally effective manner.

21. Information on relevant legislation:

Act CXII of 2006 on the Right to Informational Self-Determination and Freedom of Information (Info. tv.);
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 Regulation (EC) No 95/46/EC (General Data Protection Regulation, GDPR);
Act V of 2006 - on the Civil Code (Civil Code);
Act CXLVII of 2008 on the Itemised Tax on Small Taxable Enterprises and on Small Business Tax.

22. Data protection authority procedure:

Complaints can be lodged with the National Authority for Data Protection and Freedom of Information:

23: Data protection authority procedure:

Complaints can be lodged with the National Authority for Data Protection and Freedom of Information:

Name National Authority for Data Protection and Freedom of Information

Address: 1125 Budapest, Szilágyi Erzsébet fasor 22/C.

Postal address: 1530 Budapest, PO Box 5

Phone 0613911400 Fax: 0613911410

Email ugyfelszolgalat@naih.hu

Website: http://www.naih.hu

24. Other provisions:

The data controller shall provide information on the processing of data not listed in this information notice at the time of recording the data. In such cases, the provisions of the legislation in force shall prevail. The data controller hereby informs its customers that the court, the prosecutor, the investigating authority, the administrative authority, the National Authority for Data Protection and Freedom of Information, the National Bank of Hungary, or other bodies authorised by law may contact the data controller to provide information, to disclose or transfer data, or to provide documents. The data controller shall disclose to the authorities - if the authority has indicated the precise purpose and scope of the data - personal data only to the extent and to the extent strictly necessary for the purpose of the request. The website of the Data Protection Authority contains further information on the data protection rights referred to in this Privacy Notice.

Kalocsa, 20 April 2022 MarciTrans Ltd. MarciTrans Ltd.

1. ANNEX 1

Snr.	Name of processing of personal data	Purpose of processing	Legal basis for processing	Time limit for deletion of personal data
1.	Personal data (name, e-mail address, telephone number) of the individual or sole trader when requesting a tender.	To make an offer, to maintain contact.	Creation of the contract (Article 6(1)(b) of the General Data Protection Regulation).	If the offer is not accepted, it will be cancelled immediately and at the latest within 3 working days.
2.	Personal data (name, e-mail address, telephone number) of the contact person of the legal entity when requesting a quote	To make an offer, to maintain contact.	Consent of the data subject (Article 6(1)(a) of the General Data Protection Regulation).	Without delay in the event of withdrawal of consent. If the offer is not accepted, it will be cancelled without delay and at the latest within 3 working days.
3.	Personal data included in the contract (name, address, e-mail address, telephone number, tax number).	Fulfilment of the contract.	Fulfilment of the contractual obligation (Article 6(1)(b) of the General Data Protection Regulation), followed by fulfilment of the legal obligation to retain data (Article 6(1)(c) of the General Data Protection Regulation).	Within 30 days of the expiry of the legal retention period (5 years).
4.	Personal data of the contact person in a contract with a legal person (name, e-mail address, telephone number).	In order to fulfil the contract.	Based on the data subject's consent (Article 6(1)(a) of the General Data Protection Regulation).	In case of withdrawal of consent, without delay. Within 10 working days after the termination of the contract, unless the law provides for an obligation to keep the contract (within 30 days after the expiry of the obligation).
5.	The personal data on the invoice issued to the recipient of the service (natural person, self-employed person).	Fulfilling a legal obligation, issuing an invoice.	Compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation)	Within 30 days of the expiry of the legal retention period (5 years).
6.	Processing of incoming emails (sender's email address), telephone numbers.	For the performance of a contractual obligation or on the basis of consent.	Performance of a contractual obligation (Article 6(1)(b) of the General Data Protection Regulation) or the data subject's consent (Article 6(1)(a) of the General Data Protection Regulation)	Within 10 working days of completion of the task, or immediately after withdrawal of consent, up to a maximum of 3 working days.
7.	Personal data of suppliers, service providers and subcontractors (in the case of an individual or sole trader).	To fulfil a contractual obligation.	Performance of a contractual obligation (Article 6(1)(b) of the General Data Protection Regulation)	Within 30 days of the expiry of the legal retention period (5 years).
8.	Personal data of contact persons of suppliers, service providers, subcontractors.	To fulfil a contractual obligation.	Based on the data subject's consent (Article 6(1)(a) of the General Data Protection Regulation).	In case of withdrawal of consent, without delay. Within 10 working days after the termination of the contract, unless the law provides for an obligation to keep the contract (within 30 days after the expiry of the obligation).
9.	Personal data on CVs of job applicants, subcontractors.	To fill the advertised vacancy or to fill a possible vacancy at a later date. Finding the right quality employee.	Consent of the data subject (Article 6(1)(a) of the General Data Protection Regulation).	In the case of an advertised vacancy, the CV of an unsuccessful applicant will be destroyed by the controller without delay. The data subject's voluntary CV will be stored with his/her consent until the deadline specified in the consent.
10.	Personal data collected when cookies are processed by the website.	To improve the user experience, the statistical objective is to improve the website.	Based on the data subject's consent (Article 6(1)(a) of the General Data Protection Regulation).	Without undue delay after withdrawal of consent, but within 3 working days at the latest.
11.
12.
13.
14.	Personal data obtained by the data controller through the use of the Facebook page.	Performance of a contractual obligation (Article 6(1)(b) of the General Data Protection Regulation).	Consent of the data subject (Article 6(1)(a) of the General Data Protection Regulation).	Immediately after the withdrawal of consent.
15.	Personal data collected in the course of complaint handling.	To identify and address the complaint.	Within 30 days of the expiry of the legal retention period (5 years).	Within 30 days of the expiry of the legal retention period (5 years).