Data protection - Privacy policy

Privacy notice
Date of adoption: 2023-08-27
Data Controller
Name: Elite Concept Ltd.

Registered office: 2724 Újlengyel, Nyári Pál u. 15.

Address for correspondence, complaints: 2724 Újlengyel, Nyári Pál u. 15.

E-mail: info@rosaliedonell.com

Phone number: +36 20 340 0335

Website: http://www.rosaliedonell.com

Hosting service
Name: mhosting

Address for correspondence: 1132 Budapest, Victor Hugo utca 18-22.

E-mail address: info@mhosting.hu

Phone number: +36 1 700 2323

Name: Websupport Hungary Kft.

Postal address: 1132 Budapest, Victor Hugo utca 18-22.

E-mail address: info@mhosting.hu

Phone number: +36 1 700 2323

Description of the data processing carried out in the course of the operation of the webshop
This document contains all relevant information on data processing in connection with the operation of the webshop in accordance with the European Union's General Data Protection Regulation 2016/679 (hereinafter referred to as the Regulation, GDPR) and the 2011 CXII Act (hereinafter referred to as the Infotv.).
Information on the use of cookies
What is a cookie?

The Data Controller uses so-called cookies when you visit the website. A cookie is a set of information consisting of letters and numbers that our website sends to your browser in order to save certain settings, facilitate the use of our website and help us to collect some relevant statistical information about our visitors.

Some of the cookies do not contain any personal information and cannot be used to identify the individual user, but some of them contain a unique identifier - a secret, randomly generated sequence of numbers - that is stored on your device, thus ensuring your identification. The duration of each cookie is described in the relevant description of each cookie.

Legal background and legal basis of cookies:

We basically distinguish between three types of cookies, cookies that are essential for the proper functioning of the Website, cookies for statistical purposes and cookies for marketing purposes.

The legal basis for the processing is your consent pursuant to Article 6(1)(a) of the Regulation in the case of statistical and marketing cookies, and the legitimate interest necessary for the functioning of the Website pursuant to Article 6(1)(f) of the Regulation in the case of cookies necessary for the functioning of the Website.

Main characteristics of the cookies used by the Website:
Cookies necessary for the functioning of the website:
If you do not accept the use of these cookies, certain functions may not be available to you.

Strictly necessary cookies: these cookies are essential for the use of the website and allow you to use its essential functions. Without them, many of the site's features will not be available to you. The lifetime of these types of cookies is limited to the duration of the session.

Session cookie.

Cookie acceptance cookie: when you arrive at the site, the warning window accepts a statement that cookies are stored. They have a lifetime of 365 days.

Cookies for statistical purposes:
Google Analytics cookie: Google Analytics is Google's analytics tool that helps website and app owners to get a more accurate picture of their visitors' activities. The service may use cookies to collect information and report statistics about website usage without individually identifying visitors to Google. The main cookie used by Google Analytics is the "__ga" cookie. In addition to generating reports from website usage statistics, Google Analytics, together with some of the advertising cookies described above, can also be used to display more relevant ads in Google products (such as Google Search) and across the web.

For more information on how to delete cookies, please see the links below:

Internet Explorer: http://windows.microsoft.com/en-us/internet-explorer/delete-manage-cookies#ie=ie-11
Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
Mozilla: https://support.mozilla.org/hu/kb/weboldalak-altal-elhelyezett-sutik-torlese-szamito
Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
Chrome: https://support.google.com/chrome/answer/95647
Edge: https://support.microsoft.com/hu-hu/help/4027947/microsoft-edge-delete-cookies
Data processed for the purposes of contracting and performance
For the purposes of contracting and performance, there may be more than one processing operation. Please note that data processing in relation to complaint handling and warranty management will only take place if you exercise one of these rights.

If you do not make a purchase through the webshop, but are only a visitor to the webshop, the processing for marketing purposes may apply to you if you give us your consent for marketing purposes.

For more details on processing for the purposes of contracting and performance:

Contact
For example, if you contact us by email, contact form or telephone with a query about a product. You can order from the webshop at any time without prior contact.



Data processed
info@rosaliedonell.com



Duration of data processing
Data will be processed only until the contact is completed!



Legal basis for data processing
Your voluntary consent, which you provide to the Data Controller by contacting us. [Processing pursuant to Article 6(1)(a) of the Regulation]

Registration on the website
By storing the data provided during registration, the Data Controller can provide a more convenient service (e.g. the data subject does not have to provide his/her data again for a new purchase). Registration is not a condition for the conclusion of a contract



Data processed
The legal background and legal basis of data processing. In accordance with Article 5(1)(a) of the GDPR and Article 6(1)(a) of the GDPR, the basis of processing is your consent and, in the event of withdrawal of consent, the fulfilment of the legal obligation incumbent on the Controller pursuant to Article 6(5)(a) of the GDPR.

Purpose of processing. The purpose of data processing is to perform the opening and operation of web shops, to maintain contact with the customer, to fulfil contractual obligations and exercise rights arising from the order, and to send information letters related to the service. The customer gives his/her voluntary consent to the processing when opening the webshop.

The data processed are: e-mail address, password, name, address, telephone number, billing data, contact details, customer service data, tax number, account number.



Duration of processing
Duration of data processing in relation to registration until your consent is withdrawn.



Legal basis for processing
Your voluntary consent given to the Data Controller by registration [processing under Article 6(1)(a) of the Regulation]

Processing of the order
The processing of orders requires processing activities in order to fulfil the contract.



Data processed
The Data Controller processes your name, address, telephone number, e-mail address, the characteristics of the Goods purchased, the order number and the date of purchase.
The full range of data processing activities of the Company is carried out exclusively by Elite Concept Ltd., 2724, Újlengyel, Nyári Pál utca 15, tax number 32175808-2-13 (hereinafter referred to as the "Data Controller").

If you have placed an order in the webshop, the processing of data and the provision of data is essential for the performance of the contract.



Duration of data processing
The data will be processed for 8 years according to the statute of limitations in civil law.
Invoices issued must be retained for 8 years from the date of issue of the invoice pursuant to Section 169 (2) of the Civil Code.



Legal basis for data processing.
Performance of the contract. [Processing pursuant to Article 6 (1) (b) of the Regulation]

Issue of the invoice
The data processing is carried out in order to issue the invoice in accordance with the law and to fulfil the obligation to keep accounting records. Pursuant to Article 169 (1) to (2) of the Act, companies are required to keep accounting documents which directly and indirectly support the accounting.



Data processed
Name, address, e-mail address, telephone number.
The processing is carried out in order to issue invoices in accordance with the law and to fulfil the obligation to keep accounting records. Pursuant to Article 169 (1) to (2) of the Tax Act, companies are required to keep accounting documents that directly and indirectly support the accounting.



Duration of data processing
Invoices issued must be kept for 8 years from the date of issue of the invoice pursuant to Section 169 (2) of the Act.



Legal basis for data processing
Pursuant to Section 159 (1) of Act CXXVII of 2007 on Value Added Tax, the issue of invoices is mandatory and must be kept for 8 years pursuant to Section 169 (2) of Act C of 2000 on Accounting [data processing pursuant to Article 6 (1) (c) of the Regulation].

Processing of data relating to the transport of goods
The data processing is carried out for the purpose of the delivery of the ordered product.



Data processed
Data processed: name of the customer, delivery address, telephone number.
Purpose of processing: performance of the contract, delivery.
The legal basis for the processing is the consent of the Customer.



Duration of processing
The Data Controller processes the data for the duration of the delivery of the ordered goods.
The data processing is carried out in order to deliver the ordered goods.



Legal basis for processing
Performance of the contract [processing under Article 6(1)(b) of the Regulation].

Recipients and processors of data processing related to the delivery of goods
The name of the recipient is GLS General Logistics Systems Hungary Csomag-Logisztikai Kft.

Address of the recipient: 2351 Alsónémedi, GLS Európa u. 2.

Telephone number of the recipient: 06-29-88-67-00

E-mail address of the addressee: info@gls-hungary.com

Addressee's website: https://gls-group.eu/HU/hu/home



The courier service will assist in the delivery of the ordered goods on the basis of a contract with the Data Controller. The courier service will process the personal data received in accordance with the Privacy Policy available on its website.



Management of warranty and guarantee claims
Warranty and guarantee claims must be handled in accordance with the rules of Decree 19/2014 (IV. 29.) NGM, which also specifies how we must handle your claim.



Data processed

When handling warranty and guarantee claims, we must act in accordance with the rules of Decree 19/2014 (IV. 29.) NGM.

Under the Regulation, we are obliged to keep a record of the warranty or guarantee claim notified to us:

your name, address and a declaration that you consent to the processing of your data recorded in the report in accordance with the Regulation,
the name of the movable property sold under the contract concluded between you and us and the purchase price,
the date of performance of the contract,
the date on which the defect was notified,
the description of the defect,
the right you wish to exercise under any warranty or guarantee claim; and
how the warranty or guarantee claim is to be settled or the grounds for refusing the claim or the right to enforce it.
If we take delivery of the Goods purchased from you, we must issue a receipt to show this:

your name and address,
your name and address, and the details necessary to identify the goods,
the date of receipt of the goods, and
the date on which you can collect the repaired item.


Duration of processing
Duration of processing: warranty complaints are processed for 5 years under the Consumer Protection Act.
We will keep your complaints for 5 years.
The legal basis for processing: whether you contact us for a warranty complaint is your voluntary decision.
However, if you contact us, you will be subject to the Consumer Protection Act CLV of 1997.
If you do so, we are obliged to keep the complaint for 5 years under Article 17/A(7) of the CLC Act [Article 6(1) of the Regulation].
paragraph 6(c)]



Legal basis for processing
The legal basis for processing is compliance with the legal obligations pursuant to the NGM Decree 19/2014 (IV. 29.) [Article 4 (1) paragraph and Article 6 (1) paragraph] [Processing pursuant to Article 6 (1) c) of the Regulation].

Handling of other consumer complaints
The processing of data is carried out in order to handle consumer complaints. If you have made a complaint to us, the processing of the data and the provision of the data is essential.



Data processed
The processing of data is carried out in order to handle consumer complaints. If you
you have made a complaint to us, the processing of the data and the provision of the data are essential.

Name, telephone number, email address, complaint content.
Duration of data processing: complaints under warranty are processed for 5 years under the Consumer Protection Act.
We will keep the data for 5 years.

Legal basis for processing: Whether you contact us with a complaint is your voluntary choice, however, we will keep your complaint for a limited period of time.
If you contact us, you are entitled to complain to us under Article 17/A(7) of the Consumer Protection Act CLV of 1997.
(Article 6(1)(c) of the Regulation).



Duration of processing
Legal basis for processing: whether you contact us with a complaint is your voluntary choice, but
If you contact us, you are entitled to complain to us on the basis of Article 17/A(7) of Act CLV of 1997 on Consumer Protection.
(Article 6(1)(c) of the Regulation).



Legal basis for processing
Whether you contact us with a complaint is a voluntary decision, but if you contact us, we are obliged to keep the complaint for 3 years pursuant to Article 17/A(7) of the Consumer Protection Act of 1997 (CLV Act of 1997, Article 6(1)(c)).

Data processed in relation to the justification of consent
When registering, ordering, subscribing to newsletters, the IT system stores the IT data relating to the consent for the purpose of subsequent provability.



Data processed
When registering, ordering, subscribing to newsletters, the IT system stores the IT data relating to the consent for the purposes of subsequent verifiability. Data processed: date of consent and IP address of the data subject.



Duration of data processing

When subscribing to the newsletter, the IT system stores the IT data relating to the consent for the purposes of subsequent verifiability.

Data processed: date of consent and IP address of the data subject.



Duration of data processing: due to legal requirements, the consent must be verifiable at a later stage, therefore the duration of data storage is stored for a period of limitation after the end of the data processing.



Legal basis for processing: Article 7(1) of the Regulation imposes the above obligation. [Data processing pursuant to Article 6(1)(c) of the Regulation].





Legal basis for processing.
Article 7(1) of the Regulation imposes this obligation. [Processing under Article 6(1)(c) of the Regulation]

Processing for marketing purposes
Processing in relation to the sending of newsletters
The processing is carried out for the purpose of sending out newsletters.



Data processed
Name,

Address,
e-mail address,
telephone number.


Duration of data processing
The data will be processed until the data subject's consent is withdrawn.



Legal basis for processing
Your voluntary consent, which you give to the Data Controller by subscribing to the newsletter [processing under Article 6(1)(a) of the Regulation]

Other processing
If the Data Controller intends to carry out further processing, it will provide prior information on the relevant circumstances of the processing (legal background and legal basis of the processing, purpose of the processing, scope of the data processed, duration of the processing).

the recipients of the personal data
Processing for the storage of personal data
Name of the data processor: mhosting

Contact details of the data processor:

Phone number: +36 1 700 2323

E-mail address: info@mhosting.hu

Address: 1132 Budapest, Victor Hugo utca 18-22.

Website: https://www.mhosting.hu

The Data Processor stores personal data on the basis of a contract with the Data Controller. The Processor is not entitled to access the personal data.

The Data Controller is Websupport Magyarország Kft.

Contact details of the Data Processor:

Phone number: +36 1 700 2323

E-mail address: info@mhosting.hu

Address.

Website: https://www.mhosting.hu

The Data Processor stores personal data on the basis of a contract with the Data Controller. The Processor is not entitled to access the personal data.

Data processing activities related to the sending of newsletters
Name of the company operating the mailing system: Shopify

Registered office of the company operating the mailing system:

Phone number of the company operating the mailing system:

E-mail address of the company operating the mailing system:

Website of the company operating the mailing system:

The Data Processor contributes to the sending of newsletters on the basis of a contract with the Data Controller. In doing so, the Data Processor processes the name and e-mail address of the data subject to the extent necessary to send the newsletter.

Data processing in relation to accounting
Name of the data processor: Judit Bézi

Data Processor's registered office.

Telephone number of the data processor: +36 30 691 2760

E-mail address of the data processor: bezijudit@gmail.com

Website of the data processor:

The Data Processor contributes to the accounting of the invoices on the basis of a written contract with the Data Controller. In doing so, the Data Processor shall process the name and address of the data subject to the extent necessary for the accounting records, for the period of time pursuant to Section 169 (2) of the Act, after which it shall delete them without delay.

Processing of data in connection with invoicing
Name of the data processor.

Data processor's registered office: 1133 Budapest, Árbóc utca 6.

Phone number of the data processor: +3615009491

E-mail address of the data processor: hello@billingo.hu

Website of the data processor: https://www.billingo.hu/

The Data Processor contributes to the recording of accounting documents on the basis of a contract with the Data Controller. In doing so, the Data Processor shall process the name and address of the data subject to the extent necessary for the accounting records, for the period of time pursuant to Section 169 (2) of the Act, after which it shall delete them.

Data processing in connection with online payment
Stripe, Inc.

354 Oyster Point Boulevard South San Francisco, California, 94080, USA.

Phone number of the controller:

E-mail address of the data controller: privacy@stripe.com

Controller's website: https://stripe.com/

The payment service provider is contracted by the Data Controller to assist in the implementation of the Online Payment, for which purpose data is transferred to the online payment service provider during the purchase process. In doing so, the online payment service provider will process the billing name and address of the data subject, the order number and the date of the order in accordance with its own data processing rules.

The purpose of the data transfer is to provide the online payment service provider with the transaction data necessary for the payment transaction related to the purchase initiated with the online payment service provider.

Legal basis for the transfer: the performance of a contract between you and the Data Controller pursuant to Article 6(1)(b) of the Regulation, which includes the payment by the customer and, in the case of online payment, the transfer of data pursuant to this point is necessary for the payment

Your rights in relation to the processing
During the period of processing, you have the following rights under the Regulation:

the right to withdraw your consent
access to personal data and information relating to the processing
the right to rectification
restriction of processing,
the right to access to personal data and to obtain information on the processing of personal data, including the right to access to personal data
right to object
the right to portability.
If you wish to exercise your rights, this will involve your identification and the necessary communication with you by the Data Controller. For this purpose, identification will require the provision of personal data (but identification may only be based on data that the Controller already holds about you) and your complaints about the processing will be available on the Controller's email account for the period of time specified in this notice in relation to complaints. If you have been a customer of ours and would like to be identified for the purposes of complaint handling or warranty handling, please also provide your order ID for identification purposes. We can use this to identify you as a customer.

The Data Controller will respond to complaints about data processing within 30 days at the latest.

Right to withdraw consent
You have the right to withdraw your consent to data processing at any time, in which case the data will be deleted from our systems. However, please note that in the case of an outstanding order, withdrawal may result in our inability to deliver to you. In addition, if the purchase has already been made, we may not be able to delete the billing data from our systems under accounting regulations, and if you have a debt to us, we may process your data in the event of withdrawal of consent on the basis of a legitimate interest in the recovery of the debt.

Access to personal data
You have the right to receive feedback from the Data Controller as to whether your personal data is being processed and, if it is being processed, the right to:

to have access to the personal data processed; and
to be informed by the Controller of the following information:
the purposes of the processing;
the categories of personal data processed concerning you; and
information about the recipients or categories of recipients to whom or with which the personal data have been or will be disclosed by the Controller;
the envisaged period of storage of the personal data or, where this is not possible, the criteria for determining that period;
your right to obtain from the Controller the rectification, erasure or restriction of the processing of personal data concerning you and, where the processing is based on legitimate interests, to object to the processing of such personal data;
the right to lodge a complaint with a supervisory authority;
if the data have not been collected from you, any available information about their source;
the fact of automated decision-making (if such a process is used), including profiling, and, at least in these cases, clear information on the logic used and the significance and likely consequences for you of such processing.
The purpose of exercising this right may be to ascertain and verify the lawfulness of the processing, and the Controller may charge reasonable fees for providing the information in exchange for repeated requests for information.

Access to personal data shall be ensured by the Controller by sending you, by email, the personal data and information processed, after you have identified yourself. If you are registered, access will be provided so that you can view and verify the personal data processed about you by logging into your account.

Please indicate in your request whether you are requesting access to personal data or information about data processing.

Right to rectification
You have the right to have inaccurate personal data relating to you corrected by the Data Controller without delay upon your request.

Right to restriction of processing
You have the right to obtain, at your request, the restriction of processing by the Controller if one of the following conditions is met:

You contest the accuracy of the personal data, in which case the restriction shall apply for the period of time necessary to allow the Controller to verify the accuracy of the personal data, if the accuracy of the data can be established immediately, the restriction shall not apply;
the processing is unlawful, but you object to the erasure of the data for any reason (for example, because the data are important to you for the purposes of pursuing a legal claim) and therefore do not request the erasure of the data but instead request the restriction of their use;

the Controller no longer needs the personal data for the purposes for which they are processed but you require them for the establishment, exercise or defence of legal claims; or

you have objected to the processing, but the Controller may have a legitimate interest in the processing, in which case, until it is established whether the legitimate grounds of the Controller prevail over your legitimate grounds, the processing should be restricted.
Where processing is subject to restriction, such personal data may be processed, except for storage, only with the consent of the data subject or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or of an important public interest of the Union or of a Member State.

The controller shall inform you in advance (at least 3 working days before the restriction is lifted) of the lifting of the restriction on processing.

Right to erasure - right to be forgotten
You have the right to obtain from the Controller the erasure of personal data concerning you without undue delay where one of the following grounds applies:

the personal data are no longer necessary for the purposes for which they were collected or otherwise processed by the Controller;
You withdraw your consent and there is no other legal basis for the processing;
You object to the processing based on legitimate interest and there is no overriding legitimate ground (i.e. legitimate interest) for the processing,
the personal data have been unlawfully processed by the Controller and this has been established on the basis of the complaint,
the personal data must be erased in order to comply with a legal obligation under Union or Member State law applicable to the Controller.
If the Controller has disclosed personal data processed about you for any lawful reason and is required to delete it for any of the reasons set out above, it shall take reasonable steps, including technical measures, taking into account the available technology and the cost of implementation, to inform other controllers that have processed the data that you have requested the deletion of the links to or copies of the personal data in question.

Deletion does not apply where the processing is necessary:

for the exercise of the right to freedom of expression and information;
to comply with an obligation under Union or Member State law that requires the controller to process personal data (such as processing in the context of invoicing, where the storage of the invoice is required by law) or to carry out a task carried out in the public interest or in the exercise of official authority vested in the controller;
for the establishment, exercise or defence of legal claims (e.g. where the Controller has a claim against you and has not yet settled it, or in the course of dealing with a consumer complaint or a complaint about data processing).
Right to object
You have the right to object to the processing of your personal data based on legitimate interests at any time on grounds relating to your particular situation. In such a case, the Controller may no longer process the personal data unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such purposes, including profiling, where it is related to direct marketing. If you object to the processing of your personal data for direct marketing purposes, your personal data may no longer be processed for those purposes.

Right to portability
If the processing is automated or if the processing is based on your voluntary consent, you have the right to request the Data Controller to receive the data you have provided to the Data Controller, which the Data Controller will make available to you in xml, JSON or csv format, and if technically feasible, you may request that the Data Controller transfer the data in this format to another controller.

Automated decision-making
You have the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects concerning you or similarly significantly affects you. In such cases, the controller must take appropriate measures to protect the rights, freedoms and legitimate interests of the data subject, including at least the right to obtain human intervention by the controller, to express his or her point of view and to object to the decision.

The above shall not apply where the decision:

necessary for the conclusion or performance of a contract between you and the controller;
it is permitted by Union or Member State law applicable to the controller which also lays down appropriate measures to protect your rights and freedoms and legitimate interests; or
is based on your explicit consent.
Registration in the data protection register
Under the provisions of the Data Protection Act, the Controller was required to notify certain of its processing to the Data Protection Register. This notification obligation ceased as of 25 May 2018.

Data security measures
The Data Controller declares that it has implemented appropriate security measures to protect personal data against unauthorised access, alteration, disclosure, transmission, disclosure, erasure or destruction, accidental destruction or accidental damage and against inaccessibility resulting from changes in the technology used.

The Data Controller will make every effort to ensure that its Data Processors also take appropriate data security measures when working with your personal data, as far as organisational and technical feasibility allows.

Remedies
If you believe that the Data Controller has violated a legal provision on data processing or has failed to comply with a request, you may initiate an investigation procedure with the National Authority for Data Protection and Freedom of Information to stop the alleged unlawful processing (mailing address: 1363 Budapest, Pf. 9., e-mail: ugyfelszolgalat@naih.hu, telephone numbers: +36 (30) 683-5969 +36 (30) 549-6838; +36 (1) 391 1400).

You are also informed that in the event of a breach of the legal provisions governing data processing or if the Controller has not complied with any of your requests, you may bring a civil action against the Controller before a court.

Amendment of the Privacy Notice
The Data Controller reserves the right to amend this Privacy Notice in a way that does not affect the purpose and legal basis of the processing. By using the website after the amendment has entered into force, you accept the amended privacy notice.

If the Data Controller intends to carry out further processing of the collected data for purposes other than those for which they were collected, the Data Controller will inform you of the purposes of the processing and the information below prior to the further processing:

the duration of the storage of the personal data or, if this is not possible, the criteria for determining the duration;
the right to request the Controller to access, rectify, erase or restrict the processing of personal data concerning you and, in the case of processing based on legitimate interest, to object to the processing of personal data and, in the case of processing based on consent or a contractual relationship, to request the right to data portability;
in the case of processing based on consent, that you may withdraw your consent at any time,
the right to lodge a complaint with a supervisory authority;
whether the provision of the personal data is based on a legal or contractual obligation or is a precondition for the conclusion of a contract, whether you are under an obligation to provide the personal data and the possible consequences of not providing the data;
the fact of automated decision-making (if such a process is used), including profiling, and, at least in these cases, clear information about the logic used and the significance of such processing and its likely consequences for you.
Processing may only start thereafter, if the legal basis for the processing is consent, to which you must give your consent in addition to the information.