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Acceptance Date: 2024-04-04

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Data Controller

• Name: DelLos Hungary Kft.

• Registered Office: 2233 Ecser, Rákóczi út 88-90

• Mailing Address / Complaints: 2233 Ecser, Rákóczi út 88-90

• Email: info@dellos.hu

• Phone: +36-20-947-8370, +36-30-214-7080

• Website: http://www.dellos.hu

Hosting Provider

• Name: Wix.com Ltd

• Mailing Address: Namal 40, 6350671 Tel Aviv, Israel

• Email: privacy@wix.com

• Phone: –

Description of Data Processing in Connection with the Webshop

 

This document contains all relevant information on data processing related to the operation of the webshop, in accordance with:

• Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation, “GDPR”), and

• Act CXII of 2011 on the Right of Informational Self-Determination and on the Freedom of Information (Infotv.).

Information on the Use of Cookies

 

What is a cookie?

 

The Data Controller uses so-called “cookies” during your visit to the website.

A cookie is a small package of data consisting of letters and numbers that our website sends to your browser to save certain settings, simplify the use of our website, and assist in collecting relevant, statistical data about our visitors.

 

Some cookies do not contain any personal information and are not suitable for identifying individual users. However, some cookies do contain unique identifiers – secret, randomly generated sequences of numbers – that your device stores and which can allow for user identification.

The operational duration of each cookie is defined in the respective cookie description.

Legal Background and Legal Basis of Cookies

 

Cookies can be categorized into three main types:

1. Essential cookies – Required for the proper functioning of the website

2. Statistical cookies – Used for anonymous analytics

3. Marketing cookies – Used for targeted content and advertising

 

• The legal basis for statistical and marketing cookies is your explicit consent under Article 6(1)(a) of the GDPR.

• For essential cookies, the legal basis is the legitimate interest of the website operator in ensuring its operation, as per Article 6(1)(f) of the GDPR.

Main Types of Cookies Used on the Website

 

Essential Cookies:

• Session Cookie: Stores visitor’s location, browser language, and payment currency.

Duration: Until browser is closed, max. 2 hours

• Age-Restricted Content Cookie: Records approval for viewing age-restricted content (18+).

Duration: Until browser is closed

• Recommended Products Cookie: Stores a list of products intended to be recommended via the “Recommend to a friend” function.

Duration: 60 days

• Mobile Version & Design Cookie: Detects device type and switches to full view on mobile.

Duration: 365 days

• Cookie Consent Cookie: Records user consent in the pop-up notice upon visiting the site.

Duration: 365 days

• Auto-Logout #2 Cookie: Automatically logs out users after 90 days.

Duration: 90 days

• Backend ID Cookie: Identifies the backend server handling the session.

Duration: Until browser is closed

Statistical Cookies:

• Referrer Cookie: Records from which external page the visitor arrived.

Duration: Until browser is closed

• Recently Viewed Product Cookie: Stores the most recently viewed products.

Duration: 60 days

• Recently Viewed Category Cookie: Records the last visited product category.

Duration: 60 days

• Cart Cookie: Stores products placed in the cart.

Duration: 365 days

• Smart Offer Cookie: Records criteria for displaying smart offers (e.g. return visits, existing orders).

Duration: 30 days

More on Cookie Deletion – Browser Settings:

 

You can find instructions on how to delete cookies via these links:

• Internet Explorer

• Firefox

• Mozilla (HU)

• Safari

• Chrome

• Edge

Data Processing for the Operation of the Webshop

 

Several data processing scenarios may occur in the context of concluding and fulfilling contracts.

We inform you that processing related to complaints or warranty claims is only carried out if you exercise those rights.

If you do not make a purchase through the webshop and only browse the site, then the marketing-related processingapplies to you, provided you have given your consent.

1. Contact Initiated by You

 

For example, if you contact us via email, contact form, or phone regarding a product. Prior contact is not required — you can place an order in the webshop without contacting us.

• Data processed: The data you provide during the contact

• Duration of processing: Only until the inquiry is closed

• Legal basis: Your voluntary consent under Article 6(1)(a) GDPR

2. Registration on the Website

 

By registering on the website, the Data Controller can offer a more convenient service (e.g. your data will be saved for future orders). Registration is not required for ordering.

• Data processed: Name, address, phone number, email address, purchased product details, purchase date

• Duration of processing: Until consent is withdrawn

• Legal basis: Your voluntary consent given upon registration under Article 6(1)(a) GDPR

3. Order Processing

 

Data processing is necessary for fulfilling orders placed through the webshop.

• Data processed: Name, address, phone number, email address, product details, order number, order date

• Duration of processing: 5 years, in accordance with the statute of limitations under civil law

• Legal basis: Contract performance under Article 6(1)(b) GDPR

4. Issuing Invoices

 

Data is processed to issue legally compliant invoices and fulfill accounting obligations.

According to §169 (1)-(2) of the Hungarian Accounting Act, businesses must retain documentation that directly or indirectly supports accounting records.

• Data processed: Name, address, email address, phone number

• Duration of processing: 8 years from the date of invoice issuance, in accordance with §169 (2) of the Accounting Act

• Legal basis: Legal obligation under Article 6(1)(c) GDPR and Hungarian VAT Act (2007. CXXVII. §159(1))

5. Product Delivery

 

Data is processed for the purpose of delivering ordered products.

• Data processed: Name, address, email address, phone number

• Duration of processing: Until the ordered goods are delivered

• Legal basis: Contract performance under Article 6(1)(b) GDPR

Warranty and Guarantee Claims

 

Warranty and guarantee claims are processed in accordance with Hungarian Government Decree 19/2014 (IV.29.) NGM, which also defines the procedures for handling such claims.

 

Data Processed:

 

In case of a claim, a report must be recorded, including:

• Your name and address, and your consent to process the recorded data

• The name and price of the product sold under the contract between you and us

• Date of performance (delivery)

• Date of the claim notification

• Description of the defect

• The right you wish to enforce under the warranty or guarantee

• How the claim was handled, or the reason for rejection

 

If you return the product to us, we are required to issue a receipt of return, which includes:

• Your name and address

• Identifying data of the product

• Date of return

• Date when the repaired product can be collected

 

Duration of Processing:

 

We are required to retain the claim report for 3 years from the date of issuance and present it upon request by the authorities.

 

Legal Basis:

 

Legal obligation under Decree 19/2014 (IV.29.) NGM, Article 4(1) and 6(1)

→ GDPR Article 6(1)(c)

 Other Consumer Complaints

 

Complaints unrelated to warranty or guarantee are processed to address general consumer concerns.

 

Data Processed:

 

Customer’s name, phone number, email address, content of the complaint

 

Duration of Processing:

 

Complaints are stored for 5 years, based on the Hungarian Act CLV of 1997 on Consumer Protection.

 

Legal Basis:

 

Filing a complaint is voluntary, but once submitted, we are obligated to retain it for 3 years per §17/A(7) of the Consumer Protection Act

→ GDPR Article 6(1)(c)

Verification of Consent

 

During registration, order placement, or newsletter subscription, the IT system stores technical data related to your consent in order to ensure that it can be verified at a later time.

 

Data Processed:

• Date and time of consent

• The IP address of the data subject

 

Duration of Processing:

 

Due to legal obligations, consent must be verifiable later. Therefore, the data will be stored until the end of the statutory limitation period following the termination of data processing.

 

Legal Basis:

 

Required by Article 7(1) of the GDPR

→ GDPR Article 6(1)(c)

Additional Data Processing

 

If the Data Controller intends to carry out any additional data processing, you will receive prior information including:

• The legal background and legal basis of the processing

• The purpose of the processing

• The categories of data processed

• The expected duration of data storage

Data Processor and Hosting (Wix.com)

 

Data Processor:

 

Wix.com Ltd

• Phone: –

• Email: privacy@wix.com

• Registered Office: Namal 40, 6350671 Tel Aviv, Israel

• Website: www.wix.com

 

The data processor carries out data storage based on a contract with the Data Controller and is not authorized to accessthe personal data content.

Right to Withdraw Consent

 

You may withdraw your consent to data processing at any time. Upon withdrawal, your data will be deleted from our systems.

 Please note:

• If your order is not yet fulfilled, withdrawal may result in our inability to complete the delivery.

• If your purchase is already completed, we cannot delete invoicing-related data due to accounting laws.

• In case you have an outstanding payment, your data may still be processed based on our legitimate interest in debt collection.

Right of Access

 

You have the right to request confirmation of whether your personal data is being processed. If so, you are entitled to access:

• The purpose(s) of data processing

• The categories of personal data involved

• The recipients or recipient categories to whom the data was or will be disclosed

• The planned duration of storage, or the criteria for determining it

• Your rights regarding rectification, erasure, or restriction of processing, and your right to object

• Your right to lodge a complaint with a supervisory authority

• The source of the data if not collected from you

• Information on automated decision-making (including profiling), the logic involved, and possible consequences

 

 The purpose of this right is to ensure the lawfulness and transparency of data processing.

 In case of repeated requests, the controller may charge a reasonable administrative fee.

Right to Rectification

 

You can request the immediate correction of any inaccurate personal data concerning you.

Right to Restriction of Processing

 

You may request restriction if:

• You contest the accuracy of the data (restriction applies until verification is completed)

• The processing is unlawful and you oppose erasure, opting instead for restriction

• The controller no longer needs the data, but you require it for legal claims

• You object to processing and the controller is verifying whether its legitimate interest overrides yours

 

When processing is restricted, the data may only be stored — further use requires:

• Your consent

• Legal claims

• Protection of others’ rights

• Important public interest of the EU or a Member State

 

You will be notified in advance (at least 3 working days prior) of the lifting of any restriction.

Right to Erasure (“Right to be Forgotten”)

 

You have the right to request immediate erasure of your personal data if:

• The data is no longer needed for the original purpose

• You withdraw consent and there is no other legal basis

• You object to processing and no overriding legitimate grounds exist

• The data was unlawfully processed

• Deletion is required under EU or national law

 

Exceptions apply if processing is necessary:

• For exercising the right to freedom of expression/information

• For legal compliance (e.g. accounting records)

• For the establishment, exercise, or defense of legal claims

 

If your data was made public and must be erased, we will take reasonable steps to notify other controllers accordingly.

Right to Object

 

You may object to processing based on legitimate interests at any time.

In such a case, we will stop processing unless we demonstrate compelling legitimate grounds that override your interests or the processing serves legal claims.

 

If processing is for direct marketing purposes, including profiling, your data will no longer be processed for such purposes once you object.

Right to Data Portability

 

Where data is processed automatically and based on consent or a contract, you may request:

• To receive your personal data in a structured, commonly used, machine-readable format (e.g., XML, JSON, CSV)

• Or for us to transmit the data directly to another controller, if technically feasible

Right Not to Be Subject to Automated Decision-Making

 

You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal or similarly significant effects.

 

Exceptions apply if the decision:

• Is necessary for a contract

• Is authorized by EU or national law with safeguards

• Is based on your explicit consent

 

In such cases, you may request human intervention, express your viewpoint, and contest the decision.

Legal Remedies

Right to File a Complaint

 

If you believe that the Data Controller has violated applicable data protection laws or failed to comply with any of your requests, you have the right to initiate a procedure with the National Authority for Data Protection and Freedom of Information (NAIH):

 

NAIH Contact Details:

• Mailing Address: 1363 Budapest, Pf. 9.

• Email: ugyfelszolgalat@naih.hu

• Phone: +36 (30) 683-5969, +36 (30) 549-6838, +36 (1) 391 1400

Judicial Enforcement

 

You also have the right to bring a civil lawsuit against the Data Controller before a court if your rights under applicable data protection laws have been infringed, or if your requests are not fulfilled.

Updates to the Privacy Policy

 

The Data Controller reserves the right to unilaterally amend this privacy policy, provided that such amendments do not affect the purpose or legal basis of data processing.

 

Using the website after changes take effect is deemed acceptance of the updated version.

Further Data Processing

 

If the Data Controller intends to use personal data for purposes other than those for which they were originally collected, you will be informed in advance about:

• The purpose of further processing

• The legal basis

• The data categories concerned

• The duration of data storage, or criteria for determining it

• Your rights (access, rectification, erasure, restriction, objection, portability)

• The right to withdraw consent at any time

• The right to lodge a complaint with a supervisory authority

• Whether providing data is legally or contractually required, or necessary for contract conclusion, and consequences of failure to provide it

• Whether automated decision-making or profiling is involved, including meaningful information on the logic, significance, and expected consequences

 

Further data processing will only begin if the legal basis exists and, where necessary, you have provided consent.