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Home

Privacy Notice – FlexCom Kommunikációs Kft.

Data Controller

Company Name / Operator: FlexCom Kommunikációs Kft.

Company Registration Number: 13-09-172503

Tax ID: 23098976-2-13

VAT ID: HU23098976

Registered Office: 2151 Fót, Szent Imre utca 94., Hungary

Official Business Premises and Webshop Pickup Point: 2151 Fót, Móricz Zsigmond út 45., Hungary

Correspondence Address, Complaint Handling: 2151 Fót, Szent Imre utca 94., Hungary

E-mail: cy@gpstrackershop.eu

Phone: +36 70 333 3525

Website: cy.gpstrackershop.eu

Hosting Provider

Company Name / Operator: FlexCom Kommunikációs Kft.

Company Registration Number: 13-09-172503

Correspondence Address: 2151 Fót, Szent Imre utca 94., Hungary

E-mail: cy@gpstrackershop.eu

Phone: +36 70 333 3525

The data processor stores personal data based on a contract concluded with the Data Controller. They are not entitled to access the personal data.

Description of Data Processing Activities During Webshop Operation

This document contains all relevant data processing information regarding the operation of the webshop in accordance with the European Union General Data Protection Regulation 2016/679 (hereinafter: Regulation, GDPR) and Act CXII of 2011 (hereinafter: Infotv.).

Multiple data processing instances may occur for the purpose of concluding and fulfilling a contract. Please be informed that data processing related to complaint handling and warranty administration only occurs if you exercise any of these rights.

If you do not purchase through the webshop and are only a visitor, the provisions regarding data processing for marketing purposes may apply to you, provided you give us your consent for marketing purposes.

Information Regarding the Use of Cookies

What is a cookie?

The Data Controller uses so-called cookies during your visit to the website. A cookie is a package of information consisting of letters and numbers that our website sends to your browser to save certain settings, facilitate the use of our website, and help collect relevant statistical information.

Some cookies do not contain personal information and are not suitable for identifying the individual user; however, some contain a unique identifier—a secret, randomly generated sequence of numbers—stored by your device, thus ensuring your identifiability. The operational duration of each cookie is included in the relevant description of the specific cookie.

Legal Background and Basis for Cookies

We basically distinguish between three types of cookies:

essential cookies for operation,
statistical cookies,
marketing cookies.

The legal basis for data processing is your consent under Article 6(1)(a) of the Regulation for statistical and marketing cookies, and legitimate interest under Article 6(1)(f) of the Regulation for cookies essential for the operation of the website.

Main Characteristics of Cookies Used on the Website

Essential Cookies for Operation

If you do not accept the use of these cookies, certain functions may not be available to you.

Strictly necessary cookies: these cookies are indispensable for using the website and allow the use of basic functions. Without these, many features of the site will not be available to you. The lifespan of these types of cookies is limited solely to the session, except where a different duration is specified.

Session cookie: stores the visitor's location, browser language, and payment currency. Lifespan: until the browser is closed or a maximum of 2 hours.
Mobile version / design cookie: detects the device used by the visitor and switches to full view on mobile. Lifespan: 365 days.
Cookie acceptance cookie: stores the declaration accepted in the warning window upon arrival at the site. Lifespan: 365 days.

Statistical and Experience-Enhancing Cookies

Google Analytics cookie (__ga): Google Analytics is Google's analytical tool that helps website and application owners get a more accurate picture of their visitors' activities. The service may use cookies to collect information and report statistical data regarding website usage without identifying visitors individually. The main cookie used by Google Analytics is the "__ga" cookie.
Last viewed product cookie: records the products last viewed by the visitor. Lifespan: 60 days.
Last viewed category cookie: records the category last viewed. Lifespan: 60 days.
Cart cookie: records the products placed in the cart. Lifespan: 365 days.
Smart offer cookie: records the conditions for displaying smart offers. Lifespan: 30 days.

Marketing Cookies

Google Adwords / Remarketing cookie: when someone visits our site, the visitor's cookie ID may be added to a remarketing list. Google may use cookies to customize ads, measure campaign performance, and track conversions.
Remarketing cookies: ads may appear to previous visitors on other websites within the Google Display Network or during searches related to our products or services.
Facebook pixel: the Facebook pixel is a code used to generate reports on conversions, compile target audiences, and obtain detailed analytical data about visitors' website usage. With the help of the Facebook pixel, personalized offers and advertisements can be displayed to website visitors on the Facebook platform.

Deleting Cookies

You can find more information about deleting cookies in the following browser help guides:

Internet Explorer
Firefox
Mozilla
Safari
Chrome
Edge

Google Consent Mode v2

Our website applies Google Consent Mode v2, ensuring the accurate management of the following consent signals:

analytics_storage
ad_storage
ad_user_data
ad_personalization

The ad_user_data refers to the management of any user data that can be sent to Google for advertising purposes.

The ad_personalization controls whether user data can be used for personalized advertising purposes, such as remarketing.

The operation of these switches serves to determine whether the storage and reading of statistical or advertising cookies are permitted.

Data Processed for the Purpose of Contract Conclusion and Fulfillment

Contact

For example, if you contact us with a question about a product via email, contact form, or telephone. Prior contact is not mandatory; you can order from the webshop at any time without this step.

Data processed: name, e-mail address, phone number, content of the message, and other data provided by you during contact.

Duration of data processing: until the contact is concluded.

Legal basis for data processing: your voluntary consent [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, for example, the data subject does not have to provide their data again for a new purchase.

Data processed: name, address, phone number, e-mail address, purchase data, characteristics of the purchased product, and the time of purchase.

Duration of data processing: until consent is withdrawn.

Legal basis for data processing: your voluntary consent [Article 6(1)(a) of the Regulation].

Order Processing

During the processing of orders, data management activities are necessary for the fulfillment of the contract.

Data processed: name, address, phone number, e-mail address, characteristics of the purchased product, order number, time of purchase.

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

Duration of data processing: we process the data for 5 years according to the civil law limitation period.

Legal basis for data processing: fulfillment of the contract [Article 6(1)(b) of the Regulation].

Issuing the Invoice

The data processing process takes place to issue an invoice in accordance with the law and to fulfill the accounting document retention obligation.

Data processed: name, address, e-mail address, phone number.

Duration of data processing: issued invoices must be kept for 8 years based on Section 169 (2) of Act C of 2000 on Accounting.

Legal basis for data processing: fulfillment of a legal obligation, particularly based on Section 159 (1) of Act CXXVII of 2007 on Value Added Tax and Section 169 (2) of Act C of 2000 on Accounting [Article 6(1)(c) of the Regulation].

Data Processing Related to Goods Delivery

The data processing process takes place for the purpose of delivering the ordered product.

Data processed: name, address, e-mail address, phone number.

Duration of data processing: the Data Controller processes the data for the duration of the delivery of the ordered goods.

Legal basis for data processing: fulfillment of the contract [Article 6(1)(b) of the Regulation].

Recipients and Data Processors of Data Processing Related to Goods Delivery

Personal Pickup:Hungary, 2151 Fót, Móricz Zsigmond út 45.

Magyar Posta Zrt.

Registered Office: 1138 Budapest, Dunavirág street 2-6.

Phone: +36 1 767 8200

E-mail: ugyfelszolgalat@posta.hu

Website: posta.hu

Based on the contract concluded with the Data Controller, the courier service participates in the delivery of the ordered goods. The courier service manages the received personal data in accordance with its own privacy policy available on its website.

GLS Hungary Kft.

Registered Office: 2351 Alsónémedi, GLS Európa street 2.

Phone: +36 29 886 700

E-mail: info@gls-hungary.com

Website: https://gls-group.eu/HU/hu/home

Delivery Solutions Zrt. (Sameday)

Registered Office: 1097 Budapest, Könyves Kálmán road 34.

Phone: +36 1 374 3890

E-mail: info@sameday.hu

Website: https://sameday.hu/

DHL Express Hungary Kft.

Registered Office: 1185 Budapest, BUD Airport

Data Processing for Liability, Warranty, and Complaint Handling

Handling Liability and Warranty Claims

Liability and warranty claims must be handled according to the rules of NGM Decree 19/2014. (IV. 29.).

Data processed: customer's name, phone number, e-mail address, content of the complaint.

Duration of data processing: we retain warranty complaints for 5 years.

Legal basis for data processing: fulfillment of a legal obligation [Article 6(1)(c) of the Regulation].

Handling Other Consumer Protection Complaints

The data processing process takes place for the purpose of handling consumer protection complaints.

Data processed: customer's name, phone number, e-mail address, content of the complaint.

Duration of data processing: we retain consumer protection complaints for 3 years.

Legal basis for data processing: fulfillment of a legal obligation based on Section 17/A (7) of Act CLV of 1997 on Consumer Protection [Article 6(1)(c) of the Regulation].

Data Processed Regarding the Verifiability of Consent

During registration, ordering, or subscribing to the newsletter, the IT system stores the IT data related to the consent for future proof.

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

Duration of data processing: until the end of the limitation period following the termination of data processing.

Legal basis for data processing: the burden of proof existing under Article 7(1) of the Regulation [Article 6(1)(c) of the Regulation].

Marketing Purposes

Data Processing Related to Newsletter Sending

The data processing process takes place for the purpose of sending out newsletters.

Data processed: name, e-mail address.

Duration of data processing: until the withdrawal of the data subject's consent.

Legal basis for data processing: your voluntary consent [Article 6(1)(a) of the Regulation].

Data Processing Related to Sending and Displaying Personalized Advertisements

The data processing process takes place for the purpose of sending and displaying advertising content matching the interest of the data subject.

Data processed: name, e-mail address, phone number, address, and data related to marketing consent and interest.

Duration of data processing: until consent is withdrawn.

Legal basis for data processing: your voluntary, separate consent [Article 6(1)(a) of the Regulation].

Remarketing

Data processing as a remarketing activity is implemented with the help of cookies.

Data processed: data managed by the cookies defined in the cookie notice.

Duration of data processing: for the data storage duration of the given cookie.

Legal basis for data processing: your voluntary consent [Article 6(1)(a) of the Regulation].

Further Data Processing

If the Data Controller intends to perform further data processing, they will provide prior information on the essential circumstances of the data processing, particularly the legal background and basis, the purpose, the scope of the processed data, and the duration.

Recipients of Personal Data, Data Processors

Data Processing for the Storage of Personal Data

Data Processor: Flexcom Kommunikációs Kft.

Phone: +36 70 333 3525

E-mail Address: cy@gpstrackershop.eu

Registered Office:Hungary, 2151 Fót, Szent Imre utca 94.

Website: cy.gpstrackershop.eu

Based on the contract concluded with the Data Controller, the Data Processor performs the storage of personal data. They are not entitled to access the personal data.

Data Processing Activity Related to Newsletter Sending

Operator of the newsletter system: The Rocket Science Group LLC. (Mailchimp)

Registered Office: 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA

E-mail Address: privacy@mailchimp.com

Website: mailchimp.com

Based on the contract concluded with the Data Controller, the Data Processor participates in sending out newsletters. During this process, they handle the name and e-mail address of the data subject to the extent necessary for sending the newsletter.

Data Processing Related to Bookkeeping

Data Processor: Alexandra Kontír Kft.

Registered Office: 1156 Budapest, Drégelyvár street 3.

Phone: +36 20 502 2040

E-mail Address: alexandra.kontir@gmail.com

Website: https://alexandrakonyveles.hu/

Based on the written contract concluded with the Data Controller, the Data Processor participates in the accounting of accounting documents. During this process, they handle the name and address of the data subject to the extent necessary for accounting records, for a duration corresponding to the legal retention period.

Data Processing Related to Invoicing

Data Processor: InCash Ügyvitel Zrt.

Registered Office: 1139 Budapest, Forgách street 19.

Phone: +36 1 238 0814

E-mail Address: incash@incash.hu

Website: www.incash.hu

Based on the contract concluded with the Data Controller, the Data Processor participates in the registration of accounting documents. During this process, they handle the name and address of the data subject to the extent necessary for accounting records, for a duration corresponding to the legal retention period.

Data Processing Related to Online Payment

SimplePay Zrt.

Name of Data Controller: SimplePay Zrt.

Registered Office: 1143 Budapest, Hungária road 17-19.

E-mail Address: ugyfelszolgalat@simple.hu

Website: https://simple.hu/

Based on the contract concluded with the Data Controller, the payment service provider participates in the execution of online payment, for which data transfer to the online payment service provider occurs during the purchase process. During this, the payment service provider manages the data subject's billing name and address, order number, and time according to its own data management rules.

Purpose of data transfer: providing the transaction data necessary for the payment operation.

Legal basis for data transfer: fulfillment of the contract [Article 6(1)(b) of the Regulation].

Revolut Bank UAB

Registered Office: Konstitucijos ave. 21B, 08130 Vilnius, Lithuania

Website: https://www.revolut.com/hu-HU/

Purpose of data transfer: providing the transaction data necessary for the payment operation.

Legal basis for data transfer: fulfillment of the contract [Article 6(1)(b) of the Regulation].

PayPal

Registered Office: 2211 North First Street, San Jose, California 95131, USA

Website: https://paypal.com/

Purpose of data transfer: providing the transaction data necessary for the payment operation.

Legal basis for data transfer: fulfillment of the contract [Article 6(1)(b) of the Regulation].

Trusted Shop Program

For the purpose of the Trusted Shop Program operating on the www.arukereso.hu site, after purchases made here, the customer's e-mail address and the name of the purchased product are transferred to arukereso.hu.

Service Provider: Online Comparison Shopping Kft.

Registered Office: 1074 Budapest, Rákóczi road 70-72.

Purpose of data transfer: requesting and displaying customer feedback.

The personal data thus transferred is managed by Online Comparison Shopping Kft. according to its own privacy and data management policy.

Rights Entitled to You During Data Processing

Within the duration of the data processing, you are entitled to the following rights according to the provisions of the Regulation:

right to withdraw consent,
access to personal data and information related to data processing,
right to rectification,
right to restriction of processing,
right to erasure,
right to object,
right to data portability,
right to exemption from automated decision-making.

If you wish to exercise your rights, it involves your identification, and the Data Controller must necessarily communicate with you. The Data Controller will respond to complaints related to data processing within 30 days at the latest.

Right to Withdraw Consent

You are entitled to withdraw your consent given for data processing at any time. In such cases, we delete the provided data from our systems, unless further processing is necessary based on another legal ground.

Access to Personal Data

You are entitled to receive feedback from the Data Controller as to whether your personal data is being processed, and if so, you are entitled to receive access to the processed personal data and information regarding data processing.

Right to Rectification

You are entitled to have the Data Controller rectify inaccurate personal data concerning you without undue delay upon your request.

Right to Restriction of Processing

You are entitled to have the Data Controller restrict data processing upon your request in cases specified in the GDPR.

Right to Erasure

You are entitled to have the Data Controller delete personal data concerning you without undue delay upon your request, provided the conditions are met.

Right to Object

You are entitled to object at any time, for reasons related to your own situation, against the processing of your personal data based on legitimate interest.

Right to Data Portability

If the data processing is performed in an automated manner and is based on consent or a contract, you are entitled to receive the data you have provided to us in a structured, commonly used, machine-readable format, or request its transfer to another data controller if technically feasible.

Automated Decision-Making

You are entitled not to be subject to a decision based solely on automated data processing that would have legal effects concerning you or would similarly significantly affect you.

Data Protection Registration Number

Under previous provisions of the Infotv., the Data Controller had to report certain data processing activities to the data protection register. This reporting obligation ceased as of May 25, 2018.

NAIH number registered before May 25, 2018: NAIH-58721/2012

Data Security Measures

The Data Controller has taken appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, transfer, disclosure, erasure, or destruction, as well as against accidental destruction and damage.

The Data Controller does everything within its organizational and technical capabilities to ensure that its data processors also take appropriate data security measures when working with your personal data.

Legal Remedy

If you believe that the Data Controller has violated any legal provision regarding data processing or has not fulfilled any of your requests, you may initiate the procedure of the National Authority for Data Protection and Freedom of Information to terminate the alleged unlawful data processing.

National Authority for Data Protection and Freedom of Information

Mailing Address: 1363 Budapest, Pf. 9.

E-mail: ugyfelszolgalat@naih.hu

Furthermore, we inform you that in case of violation of legal provisions regarding data processing, or if the Data Controller has not fulfilled any of your requests, you may also initiate a civil lawsuit against the Data Controller before a court.

Modification of the Privacy Policy

The Data Controller reserves the right to modify this privacy policy. The modified version becomes accepted by using the website.

If the Data Controller intends to perform further data processing regarding the collected data for a purpose other than the purpose of their collection, they will inform you of the purpose of the data processing and the following information prior to the further processing:

the duration of personal data storage, or the criteria for determining this,
the rights entitled to you,
the possibility of withdrawing consent if the processing is based on consent,
the right to lodge a complaint with the supervisory authority,
whether the provision of personal data is based on a legal or contractual obligation,
the fact of automated decision-making, if such occurs.

Poste Restante and Post Point Delivery

Please note that Magyar Posta Zrt. identifies the recipient according to the provisions of the currently effective privacy policy; therefore, it may request your personal data upon delivery, poste restante, or Post Point pickup.