Privacy Policy
Date of acceptance: 2023-01-01
Data Controller Name: Müller Mercédesz E.V.
Registered office: 1203 Budapest, Téglagyártó út 18 fsz. 9.
Correspondence address, complaints: Baláca utca 26, 8200 Veszprém
E-mail: info.borga@gmail.com
Website: http://www.borgaland.com, http://borga.land
Hosting service provider Name: Websupport Magyarország Kft.
Correspondence address: Victor Hugo utca 18-22, 1132 Budapest
E-mail address: support@websupport.hu
Phone number: +36 22 787674
Description of data processing activities carried out during the operation of the webshop This document contains all relevant data processing information regarding the operation of the webshop in accordance with the General Data Protection Regulation of the European Union (hereinafter: Regulation, GDPR) 2016/679 and Act CXII of 2011 (hereinafter: Infotv.).
Information about the use of cookies What is a cookie?
During your visit to the website, the Data Controller uses so-called cookies. A cookie is an information package consisting of letters and numbers that our website sends to your browser with the aim of saving certain settings, facilitating the use of our website, and contributing to the collection of certain relevant statistical information about our visitors.
Some of the cookies do not contain personal information and are not suitable for individual identification of users, while others contain individual identifiers, a secret, randomly generated number, which is stored on your device and ensures your identification. The description of each cookie contains the duration of their operation.
Legal background and basis for the use of cookies:
The legal basis for data processing is based on Article 6 (1) (a) of the Regulation, namely, your consent.
The main characteristics of cookies used on the website: Cookies strictly necessary for the operation: These cookies are essential for using the website and allow the use of basic functions of the website. Without these cookies, many functions of the website will not be available to you. The lifetime of these cookies is limited to the session duration.
Cookies used to improve user experience: These cookies collect information about the user’s website usage, such as the most frequently visited pages or error messages received from the website. These cookies do not collect identifying information about visitors, therefore they work with completely general, anonymous information. We use the data obtained from these cookies to improve the performance of the website. The lifetime of these cookies is limited to the session duration.
employee_login_last_email: Stores the email address during login until the browser is closed.
Ealrm, ealem, ealpw: Provides permanent login. Lifetime: 180 days
come_from performs login redirection. Its lifespan is 10 minutes.
predictionio stores a user identification cookie for personalized advertisement recommendations. Its lifespan is 3 months.
currency stores the customer’s currency. Its lifespan is 30 days.
If you do not accept the use of cookies, certain functions may not be available to you. For more information on deleting cookies, please visit the following links:
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 processing for contract conclusion and performance
 Several data processing cases may be implemented for contract conclusion and performance. Please note that data processing related to complaint handling and warranty management only occurs if you exercise one of the aforementioned rights.
If you only visit the webshop and do not make any purchases, the provisions regarding marketing data processing may apply to you if you provide us with marketing consent.
Details of data processing for contract conclusion and performance:
Contact For example, if you contact us via email, contact form, or phone with a question regarding a product. Pre-contact is not mandatory; you can still order from the webshop at any time without contacting us beforehand.
Data processed The data you provide during the contact process.
Duration of data processing The data is only processed until the contact is concluded.
Legal basis for data processing Your voluntary consent, which you give to the Data Controller by contacting us. [Data processing according 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 customer does not need to provide their data again for a new purchase). Registration is not a prerequisite for contract conclusion.
Data processed
The Data Controller processes your name, address, phone number, email address, the characteristics of the purchased product, and the time of purchase during data processing.
Duration of data processing
Until your consent is withdrawn.
Legal basis for data processing
Your voluntary consent, which you give to the Data Controller by registering. [Data processing according to Article 6 (1) (a) of the Regulation]
Order processing
During the processing of orders, data processing activities necessary for the fulfillment of the contract are required.
Processed data
During data processing, the Controller processes your name, address, telephone number, email address, the characteristics of the purchased Goods, the order number, and the time of purchase.
If you have placed an order on the webshop, data processing and providing data are essential for the fulfillment of the contract.
Duration of data processing
The data is processed for 5 years according to the civil statute of limitations.
Legal basis for data processing
Fulfillment of the contract. [Data processing based on Article 6(1)(b) of the Regulation]
Invoicing
The data processing process is carried out to issue invoices in compliance with the laws and regulations and to fulfill the accounting document retention obligation. Under Section 169(1)-(2) of Act C of 2000 on Accounting, economic companies must keep accounting documents that directly and indirectly support their accounting for a certain period.
Processed data
Name, address, email address, phone number.
Duration of data processing
Invoices issued must be kept for 8 years from the date of issuance under Section 169(2) of Act C of 2000 on Accounting.
Legal basis for data processing
Issuance of invoices is mandatory under Section 159(1) of Act CXXVII of 2007 on Value Added Tax, and they must be kept for 8 years under Section 169(2) of Act C of 2000 on Accounting [Data processing based on Article 6(1)(c) of the Regulation].
Data processing related to product delivery
The data processing process is carried out to deliver the ordered product.
Processed data
Name, address, email address, phone number.
Duration of data processing
The Controller processes the data until the ordered product is delivered.
Legal basis for data processing
Fulfillment of the contract [Data processing based on Article 6(1)(b) of the Regulation].
Recipients and processors of data processing related to product delivery
Recipient name: Magyar Posta Closed Joint-Stock Company
Recipient address: 2-6 Dunavirág Street, Budapest 1138, Hungary
Recipient phone number: +36-1/767-8200
Recipient email address: ugyfelszolgalat@posta.hu
Recipient website: posta.hu
Under a contract signed with the Controller, the courier service assists in delivering the ordered product. The courier service processes the received personal data according to the data processing information available on its website.
Recipient name: GLS General Logistics Systems Hungary Package-Logistics Ltd.
Recipient address: 2 GLS Europe Street, Alsónémedi 2351, Hungary
Recipient’s website: https://gls-group.eu/HU/hu/home
The courier service participates in the delivery of the ordered goods based on the contract concluded with the Data Controller. The courier service handles the personal data received according to the data protection information available on its website.
Recipient’s name: Packeta Hungary Kft.
Recipient’s address: 2 Ezred Street, Budapest 1044, Hungary
Recipient’s phone number: +36 1 400 8806
Recipient’s email address: info@packeta.hu
Recipient’s website: packeta.hu
The courier service participates in the delivery of the ordered goods based on the contract concluded with the Data Controller. The courier service handles the personal data received according to the data protection information available on its website.
Recipient’s name: FoxPost Zrt.
Recipient’s address: 35/A Pacsirta Street, Eger 3300, Hungary
Recipient’s phone number: +36 1/999-0-369
Recipient’s email address: info@foxpost.hu
Recipient’s website: foxpost.hu
Handling of warranty and guarantee claims We are required to handle warranty and guarantee claims in accordance with the provisions of Decree No. 19/2014 (IV. 29.) of the Ministry of National Economy, which also specifies how we must handle such claims.
Processed data
When handling warranty and guarantee claims, we must act in accordance with the provisions of Decree No. 19/2014 (IV. 29.) of the Ministry of National Economy.
In accordance with the decree, we are required to draw up a report on your warranty or guarantee claim submitted to us, in which we record:
your name and address, as well as your statement of consent to the processing of your data recorded in the report in accordance with the provisions of the decree, the name of the movable item sold under the contract between you and us, the purchase price, the date of performance of the contract, the date of notification of the defect, the description of the defect, the right you wish to assert on the basis of your warranty or guarantee claim, as well as the method of settling your warranty or guarantee claim, or the reason for rejecting your claim or the right you wish to assert. If we receive the purchased goods from you, we must issue a receipt for the goods received, which must include
your name and address, the necessary information for identifying the item, the date of receipt of the item, and the time when you can pick up the corrected item.
Duration of data processing
The company is required to keep the protocol of the consumer’s warranty or guarantee claim for three years from the date of its recording, and to present it upon request by the supervisory authority.
Legal basis for data processing
The legal basis for data processing is compliance with legal obligations according to Section 4 (1) and Section 6 (1) of Government Decree 19/2014 (IV. 29.) [data processing according to Article 6 (1) (c)].
Handling of other consumer complaints
Data processing is carried out for the purpose of handling consumer complaints. If you have submitted a complaint to us, data processing and providing the data are essential.
Processed data Customer’s name, phone number, email address, and content of the complaint.
Duration of data processing We keep consumer complaints for 3 years in accordance with the Consumer Protection Act.
Legal basis for data processing
Whether you submit a complaint to us is your voluntary decision, but if you do, we are required to keep the complaint for 3 years under Section 17/A (7) of Act CLV of 1997 on Consumer Protection [data processing according to Article 6 (1) (c)].
Data processed in connection with the provability of consent
During registration, ordering, or subscribing to a newsletter, the IT system stores the IT data related to consent for later provability purposes.
Processed data
The date of consent and the related IP address.
Duration of data processing
Due to legal requirements, consent must be provable later, so the data storage period is stored until the expiration period following the termination of data processing.
Legal basis for data processing
This obligation is provided for in Article 7(1) of the Regulation. [Data processing in accordance with Article 6(1)(c)]
Data processing for marketing purposes
Data processing related to newsletter sending The data processing process is carried out for sending newsletters.
Processed data Name, address, email address, phone number.
Duration of data processing
Until the withdrawal of the concerned party’s consent.
Legal basis for data processing
Your voluntary consent, which you give to the Data Controller by subscribing to the newsletter [Data processing in accordance with Article 6(1)(a)]
Data processing related to sending and displaying personalized advertisements
The data processing process is carried out for sending advertising content that corresponds to the interests of the concerned party.
Processed data
Name, address, email address, phone number.
Duration of data processing
Until the withdrawal of consent.
Legal basis for data processing
Your voluntary and separate consent, which you give to the Data Controller during data collection [Data processing in accordance with Article 6(1)(a)]
Further data processing
If the Data Controller wishes to perform further data processing, it shall provide prior information on the essential circumstances of the data processing (legal background and basis for data processing, purpose of data processing, scope of processed data, duration of data processing).
Recipients of personal data Data processing related to storage of personal data
Name of data processor: Websupport Magyarország Kft.
Contact details of data processor: Telephone number: +36 22 787674
Email address: support@websupport.hu
Registered office: 1132 Budapest, Victor Hugo utca 18-22
Website: https://www.websupport.hu/
The Data Processor carries out the storage of personal data based on a contract concluded with the Data Controller. The Data Processor is not entitled to access the personal data.
Data processing related to newsletter sending Name of the company operating the newsletter sending system: The Rocket Science Group LLC.
Registered office of the company operating the newsletter sending system: 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA
Telephone number of the company operating the newsletter sending system:
Email address of the company operating the newsletter sending system: privacy@mailchimp.com
Website of the company operating the newsletter sending system: mailchimp.com
The Data Processor cooperates with the Data Controller in sending newsletters based on a contract concluded with the Data Controller. During this process, the Data Processor handles the name and email address of the data subject to the extent necessary for sending the newsletter.
Data processing related to accounting Name of data processor: Proactive Bookkeeping Kft
Registered office of data processor: 1145 Budapest, Amerikai út 75. A ép. 2.
Telephone number of data processor: 06703920529
Email address of data processor: hello@proab.hu
Website of data processor: proab.hu
The Data Processor cooperates with the Data Controller in accounting the invoices based on a written contract concluded with the Data Controller. During this process, the Data Processor handles the name and address of the data subject to the extent necessary for accounting records, for the period in accordance with Section 169 (2) of the Accounting Act, and deletes it immediately thereafter.
Data processing related to invoicing Name of data processor: KBOSS.hu Kft.
Registered office of data processor: 1031 Budapest, Záhony utca 7.
Telephone number of data processor:
Email address of data processor: info@szamlazz.hu
Website of data processor: szamlazz.hu
The Data Processor cooperates with the Data Controller in keeping records of accounting documents based on a contract concluded with the Data Controller. During this process, the Data Processor handles the name and address of the data subject to the extent necessary for accounting records, for the period in accordance with Section 169 (2) of the Accounting Act, and deletes it thereafter.
Data management related to online payment Name of data controller: Paypal
Registered office of data controller: 22-24 Boulevard Royal L-2449 Luxembourg
Telephone number of data controller:
Email address of data controller: enquiry@paypal.com
Website of data controller: https://www.paypal.com/hu/
The payment service provider collaborates with the Data Controller to execute online payment during the purchase process, and therefore, data transfer to the online payment service provider takes place. During this process, the online payment service provider manages the billing name and address, order number and time according to its own data management rules.
Purpose of data transfer: Providing transactional data necessary for the payment operation initiated with the online payment service provider regarding the purchase.
Legal basis for data transfer: The performance of the contract between you and the data controller according to Article 6(1)(b) of the Regulation, which includes payment on the part of the buyer, and in the case of online payment, data transfer according to this point is necessary for payment.
Rights available to you during data management During the data management period, you are entitled to the following rights under the Regulation:
Right to withdraw consent Right to access personal data and information related to data management Right to rectification Right to restriction of data processing Right to erasure Right to object Right to data portability.
If you wish to exercise your rights, identification will be required, and the data controller will need to communicate with you as necessary. Therefore, personal data must be provided for identification purposes (but identification can only be based on data that the data controller already holds about you), and your complaints related to data management will be available in the data controller’s email account within the time period specified in this statement. If you were a buyer and would like to identify yourself for complaint handling or warranty processing, please provide your order ID for identification purposes. Using this, we can identify you as a buyer.
Data controller must respond to complaints related to data management within 30 days at the latest.
Right to withdraw consent
You have the right to withdraw consent to data processing at any time, and in this case, we will delete the provided data from our systems. However, please note that in the case of unfulfilled orders, withdrawal may result in us being unable to deliver to you. Additionally, if the purchase has already been completed, accounting regulations may require us to retain certain data related to invoicing.
Right to rectification
You have the right to request the Controller to rectify without undue delay any inaccurate personal data concerning you.
Right to restriction of processing
You have the right to obtain from the Controller restriction of processing where one of the following applies:
(a) the accuracy of the personal data is contested by you, in which case the restriction applies for a period enabling the Controller to verify the accuracy of the personal data;
(b) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
(c) the Controller no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims; or
(d) you have objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the Controller override your grounds.
Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
The Controller shall inform you before the restriction of processing is lifted.
Right to erasure
You have the right to obtain from the Controller the erasure of personal data concerning you without undue delay and the Controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
(a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
(b) you withdraw consent on which the processing is based and where there is no other legal ground for the processing;
(c) you object to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) of the GDPR;
(d) the personal data have been unlawfully processed;
(e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the Controller is subject.
If the Data Controller has disclosed personal data about you that is being processed for any lawful reason and is obliged to delete it for any of the reasons listed above, it must take reasonable steps, including technical measures, taking into account the available technology and the costs of implementation, to inform other data controllers processing the data that you have requested the deletion of links to, copies or duplicates of such personal data.
Deletion shall not apply where processing is necessary:
for exercising the right of freedom of expression and information; for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of 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. if the Data Controller has a claim against you and has not yet fulfilled it, or if there is an ongoing consumer or data protection complaint). Right to object You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data based on the legitimate interests of the Data Controller. In such a case, the Data Controller shall no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
If personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such purposes, including profiling to the extent that it is related to such direct marketing. If you object to the processing of personal data for direct marketing purposes, the personal data may no longer be processed for such purposes.
Right to data portability If the processing of personal data is carried out in an automated manner or is based on your voluntary consent, you have the right to request from the Data Controller to receive the personal data you provided to the Data Controller, in a structured, commonly used and machine-readable format, and to request that the Data Controller transmit this data to another controller, if technically feasible.
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 these cases, the Data Controller must take appropriate measures to safeguard the rights, freedoms, and legitimate interests of the data subject, including at least the right to obtain human intervention on the part of the controller, to express their point of view, and to contest the decision.
The above does not apply in the case where the decision:
- is necessary for entering into or performance of a contract between you and the Data Controller;
- is authorized by Union or Member State law to which the Data Controller is subject and which also lays down suitable measures to safeguard your rights, freedoms, and legitimate interests; or
- is based on your explicit consent.
Notification to the Data Protection Register
Under the provisions of the Information Act, the Data Controller had to report certain data processing activities to the Data Protection Register. This reporting obligation ended on May 25, 2018.
Data security measures
The Data Controller declares that appropriate security measures have been taken to protect personal data against unauthorized access, alteration, transmission, disclosure, deletion, or destruction, as well as against accidental destruction and damage, and against becoming inaccessible due to changes in technology.
The Data Controller makes every effort, within organizational and technical capabilities, to ensure that Data Processors also take appropriate data security measures when processing your personal data.
Legal remedies
If you believe that the Data Controller has violated any legal provisions regarding data processing or has failed to fulfill any of your requests, you may initiate an investigation by the National Authority for Data Protection and Freedom of Information (address: Pf. 9, 1363 Budapest, email: ugyfelszolgalat@naih.hu, phone numbers: +36 (30) 683-5969, +36 (30) 549-6838, +36 (1) 391 1400) to cease the presumed unlawful data processing.
We also inform you that in case of violation of legal provisions regarding data processing, or if the Data Controller fails to fulfill any of your requests, you may initiate a civil lawsuit against the Data Controller in court.
Modification of the Data Processing Notice The Data Controller reserves the right to modify this Data Processing Notice in a manner that does not affect the purpose and legal basis of data processing. By using the website after the modification becomes effective, you accept the modified Data Processing Notice.
If the Data Controller intends to perform further data processing for a purpose other than the purpose of the data collection, they will inform you of the purpose of the data processing and the following information before further data processing:
- The duration of personal data storage, or if this is not possible, the criteria for determining the duration;
- Your right to request access to, correction, deletion, or restriction of processing of your personal data, as well as the right to object to the processing of personal data based on legitimate interests, and the right to data portability in the case of data processing based on consent or contractual relationship;
- The fact that you may withdraw your consent to data processing based on consent at any time;
- Your right to lodge a complaint with the supervisory authority;
- Whether the provision of personal data is based on a legal or contractual obligation or is a prerequisite for entering into a contract, and whether you are obliged to provide personal data, as well as the possible consequences of not providing such data;
- Information about the fact of automated decision-making (if such a procedure is applied), including profiling, as well as understandable information on the applied logic and the expected consequences for you.
Data processing may only begin after this information is provided and, in the case of data processing based on consent, your consent is obtained in addition to the information.