Privacy Policy
This Privacy Policy contains the information on the personal data processing activities of ALLWIN Informatics Inc. (hereinafter referred to as: “ALLWIN”) in the course of its operation, the using of its website under www.allwin-solutions.com (hereinafter referred to as: “Website”) and the communication on its Website.
The data subject (hereinafter: “Data Subject”) shall clearly agree and accept the content of this Privacy Policy before using the functions of the Website and the services (hereinafter: “Service”) provided by ALLWIN.
This Privacy Policy is made in accordance with the provisions of 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 (hereinafter referred to as: “GDPR”). For convenience the full text of GDPR is available here: https://eur-lex.europa.eu/eli/reg/2016/679/oj
1. Name and contact of the data controller
name: ALLWIN Informatika Korlátolt Felelősségű Társaság;
registered seat: 8The Green Ste300 Dover, DE 19901
registering authority: Fővárosi Törvényszék Cégbírósága;
registration number: 01-09-200739;
represented by: Nagy István managing director;
electronical contact: contact@allwin-solutions.com
In relation with this Privacy Policy Data Subject is a natural person, who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the economic, identity of that natural person. Personal data means any information relating to an identified or identifiable natural person.
2. The purpose and legal basis of data processing, the sources of the data
2.1. Contact
By using the „Contact” menu on the Website the Data Subject can provide his personal data. By giving his consent freely to the processing of his personal data, the Data Subject allow his questions and queries reach ALLWIN, and the Data Subject receive answers, information via his contact data. The personal data given for contact purposes shall be processed by ALLWIN until the withdrawal of the Data Subject’s consent. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. In case the further processing of contact data is not justified, ALLWIN shall delete such data without delay.
Purpose of the data processing:
Informing and contacting the Data Subject
Legal basis of the data processing:
the consent of the Data Subject (Article 6, Section 1 point (a) of GDPR)
Scope of processed data:
full name, email address and phone number of the Data Subject
Storing period of data:
until the claim for erasure of the Data Subject, or the erasure of the data by ALLWIN, if the further data processing is not justified
2.2. Conclude a contract
The Data Subject as the representative of a company or an undertaking may conclude a contract with ALLWIN on using services. The personal data of the Data Subject, as the contact person or representative of the contracting party, are needed for the performance of such various types of contracts and the fulfillment of the claims (e.g. complaint, payment notification) resulted from such contracts.
Purpose of the data processing:
contact between the contracting parties, performance of the contract
Legal basis of the data processing:
performance of a contract (Article 6, Section 1 point (b) of GDPR),
data processing is necessary for compliance with a legal obligation to which the controller is subject (Article 6, Section 1 point (c) of GDPR),
the legitimate interests pursued by the controller or by a third party (Article 6, Section 1 point (f) of GDPR)
Scope of processed data:
full name, email address, phone number and position of the Data Subject
Storing period of data:
until the expiry of the 5 year long general limitation period of contracts set forth in Hungarian Civil Code, and until the mandatory period set forth by legal rules, e.g. 8 years set forth in Section 169 in Act C of 2000
2.3. Newsletter, contact with advertising purpose
By giving his consent freely to the processing of his personal data, the Data Subject allow to be informed by ALLWIN on the actual services, discounts, promotions and other new information via his contact data. The personal data given for newsletter and advertising purposes shall be processed by ALLWIN until the withdrawal of the Data Subject’s consent. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. The Data Subject may unsubscribe at any time without reasoning from the newsletter of ALLWIN.
Purpose of the data processing:
sending newsletter and other marketing materials
Legal basis of the data processing:
the consent of the Data Subject (Article 6, Section 1 point (a) of GDPR),
paragraph (1) of Section 6 of Act XLVIII of 2008 on the Essential Conditions and Certain Limitations of Business Advertising Activity
Scope of processed data:
full name, email address and phone number of the Data Subject
Storing period of data:
until the withdrawal of the Data Subject’s consent, or the claim for erasure of the Data Subject, or the erasure of the data by ALLWIN, if the further data processing is not justified
2.4. Conclude a contract with third persons
ALLWIN may conclude a contract on using services or buying products. The personal data of the contact person or representative of the contracting parties, are needed for the performance of such various types of contracts.
Purpose of the data processing:
contact between the contracting parties, performance of the contract
Legal basis of the data processing:
performance of a contract (Article 6, Section 1 point (b) of GDPR)
Scope of processed data:
full name, email address, phone number and position of the Data Subject
Storing period of data:
until the expiry of the 5 year long general limitation period of contracts set forth in Hungarian Civil Code, and until the mandatory period set forth by legal rules, e.g. 8 years set forth in Section 169 in Act C of 2000
3. Rights of the Data Subject
ALLWIN shall provide information on action taken on a request under Articles 15 to 22 of GDPR to the Data Subject without undue delay, and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. ALLWIN shall inform the Data Subject of any such extension within one month of receipt of the request, together with the reasons for the delay. Where the Data Subject makes the request by electronic form means, the information shall be provided by electronic means where possible, unless otherwise requested by the Data Subject.
If ALLWIN does not take action on the request of the Data Subject, ALLWIN shall inform the Data Subject without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy
Information and any communication and any actions shall be provided free of charge. Where requests from the Data Subject are manifestly unfounded or excessive, in particular because of their repetitive character, ALLWIN may either (i) charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested, or (ii) refuse to act on the request.
ALLWIN shall bear the burden of demonstrating the manifestly unfounded or excessive character of the request.
The Data Subject may claim from ALLWIN in respect of his personal data:
(i) right of access: the Data Subject shall have the right to obtain from ALLWIN confirmation as to whether or not personal data concerning him are being processed, and, where that is the case, access to the personal data and other information,
(ii) right to rectification: the Data Subject shall have the right to obtain from ALLWIN without undue delay the rectification or completion of inaccurate personal data concerning him,
(iii) right to erasure: the Data Subject shall have the right to obtain from ALLWIN the erasure of personal data concerning him without undue delay and ALLWIN shall have the obligation to erase personal data without undue delay.
Personal data shall not be erasured to the extent that data processing is necessary:
- for exercising the right of freedom of expression and information,
- for compliance with a legal obligation by Union or Member State law to which ALLWIN is subject,
- for the establishment, exercise or defence of legal claims.
(iv) right to restriction of processing: the Data Subject shall have the right to obtain from ALLWIN restriction of processing, if, among others, the accuracy of the personal data is contested by the Data Subject, or ALLWIN no longer needs the personal data for the purposes of the processing, but they are required by the Data Subject for the establishment, exercise or defence of legal claims;
(v) right to object: the Data Subject shall have the right to object at any time to processing of personal data concerning him based on GDPR,
(vi) right to data portability: the Data Subject shall have the right to receive the personal data concerning him, which he has provided to ALLWIN, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from ALLWIN to which the personal data have been provided, according to GDPR.
ALLWIN shall communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. ALLWIN shall inform the Data Subject about those recipients if the Data Subject requests it.
If the data processing is based on consent, the Data Subject shall have the right to withdraw his consent at any time.
The Data Subject shall have the right to lodge a complaint with a supervisory authority, if the Data Subject considers that the processing of personal data relating to him infringes the GDPR.
The Data Subject can file his complaint regarding the data processing to the Hungarian National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság), with the contact address below:
Address: 1125 Budapest, Szilágyi Erzsébet fasor 22/C, Hungary;
Postal address: 1530 Budapest, Postafiók: 5., Hungary
Tel.: +36-1-391-1400
E-mail:ugyfelszolgalat@naih.hu; website: www.naih.hu,
furthermore the Data Subject shall have the right to an effective judicial remedy.
4. Data processing and data transfer
The employees or contractual partners of ALLWIN have the right to aware the personal data of the Data Subject with the obligation of confidentiality and they shall keep such data confidential.
ALLWIN works with the following data processors, who are entitled to recognize personal data in the course of their activity:
- marketing: Marketera Consultancy Ltd.,21/C Andor street, H1119, Budapest, Hungary, Dominik Vári, dominik.vari@marketera.agency
- others:
ALLWIN shall not transfer any personal data to any third person out of the scope of the data processors above, unless the Data Subject gives his explicit consent or it is set forth by legal rules.
In addition to the persons detailed above, ALLWIN works with Marketera Consultancy Ltd.,21/C Andor street, H1119, Budapest, Hungary, Dominik Vári, dominik.vari@marketera.agency as a technical support service provider, who may recognize the personal data in the course of its activity, but the data shall not be transferred to him by ALLWIN.
ALLWIN does not use automated decision-making process, including profiling in the course of its data processing.
5. The place of data storing
ALLWIN keeps the data detailed above in its registered seat and on the servers of its server provider.
The service provider of ALLWIN is: 398 11th Street, 2nd Floor San Francisco, CA 94103
6. Use of cookies
The Website uses cookies in order to provide customized information to the visitors of the Website. Cookies are short data files placed by the Website on the visitor’s computer. These cookies are designed to facilitate the browsing easier, furthermore to record information on visits and personal settings. These data may not be associated with the identification data of the visitor. Cookies may be rejected or modified in the settings of the visitor’s browser. If the cookies are not rejected or the visitor clicks on the “Agree” button, the use of cookies shall be accepted. If visitor does not autrorise the use of cookies, he may not be able to use certain features on the Website
The cookie settings of the most popular browsers are available on the following links:
Google Chrome:
https://support.google.com/accounts/answer/61416?hl=en
Internet Explorer:
Firefox:
https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
Safari:
https://support.apple.com/en-gb/HT201265
The cookies used on the Website include those:
(i) cookies that remember user’s choices (functionality cookies); and
(ii) strictly necessary cookies for access and navigation
Such cookies are strictly necessary for the functions required by the visitors, and can be used without specific consent in accordance with relevant legal rules. Besides, the Website uses cookies for statistical purposes. Such cookies records the events of the visit of the Website, and provide anonym statistical data to ALLWIN. Such cookies shall be used only in accordance with the consent of the visitor. Such cookies shall be stored for 2 (two) years.
7. Security measures
ALLWIN shall, in accordance with the provisions of GDPR, provide the security of personal data processing and take such technical measures which provide the security of the recorded, stored and processed data, and shall do its outmost to prevent the destruction, unlawful use and modification of the data.
The specific technical and information technology measures are: protection of data on multiple levels, such as physically protecting data storage servers, which are secured and supervised by technicians, restricted access to server rooms by ALLWIN’s employees, the documents consisting data are kept in lockers and in rooms equipped with security-alarm and fire-alarm system. The information technology system is secured by password, firewall and anti-virus system, an it is only accessed by the employees of ALLWIN, and the system administrator as service provider.
This Privacy Policy and any dispute or claim arising out of or in connection with it shall be governed by in accordance with Hungarian law.
ALLWIN may change this Privacy Policy at any time at its sole discretion, and such change shall be effective by the publication on its Website, and shall be applied for the data processing from the date of publication.