UNIX Car and Spare Parts Dealing Company Ltd. Data Processing Policy and Privacy Statement

Name of Controller: UNIX Autó és Alkatrészkereskedelmi Kft. (hereinafter referred to as: “UNIX Autó Kft.” or “Controller”)

Controller’s Address: 1139 Budapest, Frangepán utca 55-57.

Contacts: Address: 1139 Budapest, Frangepán utca 55-57. Tel: +36-1-270-8700; Fax: +36-1-270-8799;

Naming of data processing: Data processing is based on the freely given, informed and unambiguous consent of users.

Legal grounds for data processing: Having regard to Regulation (EU) 2016/679 of the European Parliament and of the Council (“General Data Protection Regulation” or GDPR) and Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information, in particular Article 5 (1) thereof, Consent of the data subject.

Definitions:

Principles relating to processing of personal data:

Controller processes personal data lawfully and fairly, only for specific purposes, without data waste, precisely, with limited storability, confidentially and accountably, as well as transparently for the data subject.

Personal data:

Range of data processed:

The vehicle’s registration number, billing name, ZIP code, street address, mobile phone number, email address, the registration’s country code, country, county, city, vehicle identification number, manufacturer’s engine code, production date (year, month), expiry of registration certificate, expiry of green card, last mileage, average distance covered per year (km), ABS, ASR, catalytic converter, air conditioning, servo.

In order to tailor the service to your needs, Controller places small packages of data (“cookies”) on your computer. The purpose of cookies is to ensure the highest possible quality operation of the given website, to provide tailored services, and to improve your customer experience. You can delete the cookies from your computer, or you can set your browser in a way to ban cookies. By banning the cookies, you accept that the operation of the given website without cookies is not of full value. While providing personalized services through the use of cookies, the Controller processes the following personal data: demographic data, fields of interest, habits, preferences (based on browsing history).

Data technically recorded during the operation of the system, video recording:

Data from the computer you use to log in, which are generated through the use of the website’s services and which are recorded automatically by the Controller’s system as an automatic result of technological processes. The automatically recorded data are logged automatically when you log in or off without any separate declaration or action on your part.

In the event of your shopping at one of our outlets, a video recording is made, which is stored by the Controller for 14 days for asset protection purposes.

Purpose of data processing:

If you fill in the registration form and provide your data, it enables us to prepare your loyalty card. With the loyalty card you are entitled to a 10% discount at our outlets; in case you consented to the processing of your data and you requested it, we send you a warning in a text message or email when your vehicle’s MOT test has expired. By registering you consent to receive emails on our promotions. Before registering the data, the Data Subject must be informed whether data provision is mandatory or voluntary. In the case of mandatory data processing, the legal regulation mandating it must also be indicated.

Controller may not use the personal data for any other purposes than those specified in this Article.

Period of data processing:

We inform you that the data necessary for issuing your invoice is stored by Controller for 5+2 years as mandated by law.

We inform you that the personal data you provided are processed until you submit a declaration withdrawing your consent or requesting their erasure.

We inform you that a video surveillance system is operated at our outlets for asset protection purposes, the recordings of which are erased after 14 days.

Erasure of personal data:

With regard to data provided by the you, in case you freely decide so, data are erased within 30 days of the receipt of your written request thereof. In case you use personal data unlawfully or deceptively or commit a crime, upon being informed about this, UNIX Autó Kft. may erase all your personal data at the same time as erasing your registration. The cancellation request must be submitted on www.unixauto.com/contacts. Data are erased within 30 days of the receipt of your written request, unless the law mandates otherwise. In the event of erasure, the profile data cannot be restored.

Personalized advertisements/content:

In line with your fields of interest, Controller may show personalized ads on the sites downloaded when visiting the website or may send personalized advertisements to you in email, which contain useful and interesting information for you. Advertising spaces and personalized contents are machine-selected, during their distribution no personal data are transmitted or processed, no analysis or examination of personal data is necessary.

Data processing for sending newsletters:

Fact and purpose of data processing: when registering at the webshop www.unixauto.hu the user gives preliminary consent to get electronic or printed newsletters about the service provider’s current offers at the contacts given during registration. Without registration Controller does not send advertising content. Registered users may unsubscribe from newsletters orally, electronically or by post. Newsletters may only be sent to users who accept the Privacy Statement provided on the website.

Range of data subjects: Visitors and customers who subscribe to the newsletter on the website.

Range of data processed: Date, time, last name, first name, email address, telephone number

Legal grounds of processing: Regarding newsletter subscription, Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information, as well as Article 6 (1)a of Regulation EU 2016/679 (“GDPR”).

Period of data processing: Data are erased within 30 days of the receipt of the Data Subject’s written request.

Rights of data subjects in relation to data processing:

Possibility of modifying the data protection policy:

UNIX Autó Kft. upholds the right to unilaterally modify this data protection policy with the prior notification of data subjects. After accepting the modified data protection policy, data subjects may continue the use of the service undisturbed.

Transferring personal data:

Data processed by UNIX Autó Kft. may only be accessed by its employees (within Hungary and abroad) as well as members of its branches. As specified in Act CXII/2011, data may only be transferred and different forms of data processing connected if the data subject has given his or her explicit consent or if the law permits it, and the conditions of data processing are upheld in relation to every piece of personal data.

Cross-border transfer of data:

Personal data may be transmitted by a data Controller covered by this Act to a data Controller or processor operating in a third country, or may be transferred to a data Controller or processor operating in a third country if: a) the data subject has given his or her explicit consent, or b) the conditions laid down in legal regulations satisfied and the adequate level of protection of the personal data have been ensured in the third country during the course of the control and processing of the data transferred. You can exercise your rights in court as specified in Act CXII/2011 and in Civil Law, and you can ask for help from a Data Protection Supervisor. If you have any further questions or comments. please contact our operator at www.unixauto.com/contacts.

Rights of the user and exercising them:

You may ask Controller to inform you whether your personal data is processed and if so, you can request access to your personal data that are processed.

You can view the personal data you provided in the settings of the access control system of the services, as well as on the profile pages related to individual services. You may request information about the processing of your personal data at any time in writing. by registered mail. or by sending a message to www.unixauto.com/contacts. The request for information in the letter will only be regarded as authentic if based on the request you are clearly identifiable. Requests for information via email will only be regarded as authentic if it is sent from your registered email address, but this does not exclude the right of the Controller to identify you in other ways as well before giving the information.

The request for information may include the data processed by Controller, the source of these data, the purpose, legal grounds, time period of data processing, the names and addresses of data processors (if any), activities related to data processing, and in the event of the transfer of personal data the recipients and purposes of the transfer of your data. You may ask for the modification or rectification of your personal data processed by Controller. Considering the purposes of data protection, you may request the completion of incomplete personal data. You can modify personal data you provided in the settings of the access control system of the services, as well as on the profile pages related to individual services. In the event of a request for the modification of personal data, the original (erased) profile data cannot be restored. You may request the erasure of your personal data processed by the Controller.

A request for erasure may be denied (i) for exercising the right of freedom of expression and information; (ii) for compliance with a legal obligation or (iii) for the establishment, exercise or defence of legal claims. In the event of denying a request for erasure, the Controller will notify you in every case, specifying the reason for denial. In the event of a fulfilling a request for the erasure of personal data, the original (erased) profile data cannot be restored.

You can unsubscribe from newsletters sent by Controller through the “unsubscribe” link provided in the newsletter. In the event of unsubscription Controller erases your personal data stored in the newsletter database.

You can request the restriction of the processing of personal data if you contest the accuracy of the personal data processed. If the accuracy of an item of personal data is contested by the data subject and its accuracy or inaccuracy cannot be ascertained beyond doubt, the Controller shall mark that personal data for the purpose of referencing, and the restriction only applies for the time until the accuracy of the data is ascertained. If you contest the accuracy or correctness but the inaccuracy or incorrectness cannot be ascertained beyond doubt, you can request the restriction of the processing of personal data. If the processing is unlawful and you oppose the erasure of the personal data, you can request the restriction of their use instead. You can also request the restriction of data processing if the Controller no longer needs the personal data for the purposes of the processing, but you need their processing for the establishment, exercise or defence of legal claims. You have the right to receive the personal data concerning you, which you have provided to a Controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another Controller.

You can object to the processing of your personal data if the data processing only serves the Controller’s or a third party’s legitimate interest; if the purpose of data processing is direct marketing, polling or scientific research; or if processing is done in relation to the performance of a task carried out in the public interest.

The Controller will examine the lawfulness of your objection, and if it is legitimate, stops processing the data and blocks the personal data, and notifies you and all recipients to whom it was transmitted for processing about the objection and the measures taken.

External data processors:

Controller guarantees that he will not transfer your personal data to external service providers.

Security of processing:

Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, the Controller and the processor shall implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:

Communication of a personal data breach to the data subject and notification of a personal data breach to the supervisory authority:

In the case of a personal data breach, the Controller shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the competent supervisory authority, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. When the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, the Controller shall communicate the personal data breach to the data subject without undue delay.

Court enforcement of claims:

In the event of any infringement of his rights, the data subject may turn to court action against the Controller. The burden of proof to show compliance with the law lies with the Controller. The competent court in the lawsuit is the one to which the seat of Controller regionally belongs. Any person otherwise lacking legal capacity to be a party to legal proceedings may also be involved in such actions. When the court’s decision is in favor of the plaintiff, the court shall order the Controller to provide the information, to rectify, block or erase the data in question, to annul the decision adopted by means of automated data-processing systems, to respect the data subject’s objection, or to disclose the data requested by the data subject. The court may order publication of its decision, indicating the identification data of the Controller as well, where this is deemed necessary for reasons of data protection or in connection with the rights of large numbers of data subjects.

Compensation:

Controllers shall be liable for any damage caused to a data subject resulting from unlawful processing or by any breach of data security requirements. The Controller may be exempted from liability if he or she proves that the damage was caused by reasons beyond his or her control. No compensation shall be paid where the damage was caused by intentional or serious negligent conduct on the part of the aggrieved party.

Privacy statement

I declare that I am familiar with the Data Protection Policy of UNIX Car and Spare Parts Dealing Company Ltd. (hereinafter referred to as UNIX Autó Kft.), and I am aware that UNIX Autó Kft. collects my personal data for the purposes of creating my loyalty card, and stores them to enable my discount purchases with the loyalty card. I consent that UNIX Autó Kft. should use my freely given personal data for the purposes specified by them and make them available to its branches, in line with the regulations of the Privacy Act.

I am aware that after becoming a registered partner of UNIX Autó Kft. I am entitled to request the erasure of any or all the personal and other data I provided. I accept that UNIX Autó Kft and its competent colleagues in Hungary and abroad, as well as car servicing facilities belonging to the network of UNIX Autó Kft in Hungary and abroad should be allowed to access my personal data, but these should not be transferred to other private or legal persons or organizations without legal personality. UNIX Autó Kft and its network of car servicing facilities are in no ways authorized to use the personal data given by me to transfer or use my personal data for any other purposes than those specified in the Data Protection Policy. I agree that unless I otherwise declare, UNIX Autó Kft and members of its network of car servicing facilities may inform me about promotions and new products on the email address I provided at registration.

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