Privacy Policy

1. General information

We take the protection of personal data very seriously and adhere to the relevant legal regulations. The following declaration informs you about the type of personal data that is collected on this website, the purpose for which it is used and the extent to which this data is made available to third parties.

2. Responsible for data processing

This data protection policy applies to data processing by ALSO Hungary Kft., Kéthly Anna tér 1., 1077 Budapest, Tel.: +36 1 501 6780 (hereinafter: "ALSO" or "we"), accessible at kapcsolat.hu@also.com.

3. Data protection officer

You can address your data protection concerns to our customer service staff or directly to our data protection officer at privacy.hu@also.com or by post to ALSO Hungary Kft., Adatvédelem, Kéthly Anna tér 1., 1077 Budapest.

4. Data processing when visiting our website

When you visit our website, information is automatically sent to us by the web browser you are using to enable the structure of our website. The information provided includes the IP address of the requesting Internet-capable device, the date and time of the request and browser information. This information is temporarily stored in a so-called log file and automatically deleted after 9 weeks at the latest. The collected data does not allow any direct conclusions about your identity.

The legal basis for the processing of the IP address is Art. 6 Par. 1 S.1 lit. f General Data Protection Regulation ("GDPR"). The purpose of processing the data is to ensure the smooth establishment of connections and system security. Our legitimate interest lies in the security of your data, recognition and defence of attempted attacks, for statistical evaluation and for the optimisation and provision of our online services.

Furthermore, we use cookies and analysis services when you visit our website. For further details, please refer to points 7 and 8.

5. New customer registration and business

When registering as a new customer, we process your transmitted data in accordance with Art. 6 para. 1 lit. b or lit. f GDPR for the purpose of carrying out pre-contractual measures. During the registration process, we obtain a credit report on you from Creditreform. We process the creditworthiness information in accordance with Art. 6 para. 1 lit. f GDPR on the basis of a justified interest in a stable business relationship.

During the business relationship, we process your data on the basis of Art. 6 para. 1 lit. a GDPR, if you have given us permission to use your data, e.g. for certain marketing campaigns or incentives.

Furthermore, we process your data in accordance with Art. 6 para. 1 lit. b GDPR for pre-contractual measures such as offers or the implementation of purchase or leasing contracts.

6. Events

If you register for or participate in events, incentives, conferences or similar ALSO events, your personal data will be collected for the purpose of planning, implementing and invoicing these offers.

The legal basis for the processing of your data here is Art. 6 lit. b GDPR, i.e. the processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject.

The categories of recipients of your personal data are ALSO Hungary Kft. and, if necessary, employees of booking agencies, hotels and travel agencies.

7. Use of cookies

Cookies: We use cookies for certain offers. These are small text files that are stored on your computer. This enables us to recognise if you visit websites from the same computer repeatedly.

Session cookies are cookies that are only stored on your computer for the duration of an Internet session and are required for transactions. These session cookies are used exclusively for connection control and navigation and enable you to surf our website in a user-friendly manner (e.g. for processing a purchase while you are logged on to our shop systems). Session cookies are deleted again when you end your browser session.

For certain offers, we use persistent cookies which serve to recognise visitors and are stored on your computer for future sessions. These cookies are valid for 6 to 24 months (e.g. a persistent cookie is required to prevent your surfing behaviour from being recorded by the tracking tools used).

You have the option of setting your browser so that these cookies are not stored at all or so that the cookies are deleted at the end of your Internet session. Please note, however, that in this case you may not be able to use all the functions of our online service.

You can also manage the use of cookies in our Consent Management Tool (see section 8) at any time. You can change the decision made there at any time and subsequently grant or revoke your consent. For this purpose, you can call up the setting options here.

8. Usercentrics Consent Management Plattform

We use the Usercentrics Consent Management Platform (Usercentrics) of Usercentrics GmbH, Rosental 4, 80331 Munich, Germany. Usercentrics collects log file data and consent data using JavaScript. This JavaScript enables us to inform the user about his or her consent to certain cookies and other technologies on our website and to obtain, manage and document these.

The legal basis for processing the data is Art. 6 para. 1 lit. c GDPR. The aim is to know the preferences of users and to act accordingly.

The data is deleted as soon as it is no longer required for our logging. The durability of the cookie is 60 days. The consent data must be stored for 6 years. The revocation certificate of a previously granted consent is kept for three years. On the one hand, the storage is based on our accountability in accordance with Art. 5 para. 2 GDPR. This obliges us to comply with the processing of personal data in accordance with the General Data Protection Regulation.

You can permanently prevent the execution of JavaScript at any time by making the appropriate settings in your browser, which would also prevent Usercentrics from executing the JavaScript.

9. Google Tag Manager

This website uses the Google Tag Manager. This service allows website tags to be managed through an interface. The Google Tool Manager only implements tags. This means: no cookies are used and no personal data is collected. The Google Tool Manager triggers other tags, which in turn may collect data. However, the Google Tag Manager does not access this data. If a deactivation has been made at domain or cookie level, it will remain in effect for all tracking tags if they are implemented with the Google Tag Manager.

10. Newsletter

On the ALSO website, users are given the opportunity to subscribe to our company's newsletters. Pursuant to art. 6, par. 1 lit. a GDPR, we process your data on the basis of a granted consent.

ALSO uses ELAINE from Artegic AG for the newsletter dispatch. ALSO informs its customers and business partners at regular intervals by means of a newsletter about (if possible individual) information about products, promotions, competitions and news from ALSO. We also occasionally use the service for surveys to increase customer satisfaction. The newsletter of our company can only be received by the person concerned if (1) the person concerned has a valid e-mail address and (2) the person concerned registers to receive the newsletter. A confirmation e-mail will be sent to the e-mail address registered for the first time by a person concerned for sending the newsletter using the double opt-in procedure. This confirmation e-mail serves to check whether the owner of the e-mail address has authorised the receipt of the newsletter as a data subject.

When registering for the newsletter, we also save the IP address assigned by the Internet service provider (ISP) of the computer system used by the person concerned at the time of registration as well as the date and time of registration. The collection of this data is necessary in order to be able to trace the (possible) misuse of the e-mail address of a data subject at a later date and therefore serves to provide legal protection for the person responsible for processing.

The personal data collected during registration for the newsletter is used exclusively for sending our newsletter. In addition, subscribers to the newsletter could be informed by e-mail if this is necessary for the operation of the newsletter service or for registration, as might be the case if there are changes to the newsletter offer or if technical conditions change. The personal data collected within the scope of the newsletter service will not be passed on to third parties. The subscription to our newsletter can be cancelled by the person concerned at any time. The consent to the storage of personal data, which the person concerned has given us for the newsletter dispatch, can be revoked at any time. For the purpose of revoking this consent, there is a corresponding link to the unsubscription form in every newsletter. Furthermore, it is also possible to unsubscribe from the newsletter at any time directly on the website of the data controller or to inform the data controller in another way.

Newsletter-Tracking

The newsletter contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails sent in HTML format to enable log file recording and log file analysis. This allows a statistical evaluation of the success or failure of online marketing campaigns. By means of the embedded counting pixel, the person in charge can see whether and when an e-mail was opened by a person concerned. Adapted links can also be used to record which links in the e-mail were opened by the person concerned.

Such personal data collected via the tracking pixels and links contained in the newsletters are stored and evaluated by the data controller in order to optimise the sending of the newsletter and to adapt the content of future newsletters even better to the interests of the data subject. This personal data is not passed on to third parties. Data subjects are entitled to revoke the declaration of consent given in this regard at any time. This is equal to unsubscribing from receiving the newsletter.

ELAINE will be used on the basis of our legitimate interests in accordance with Art. 6 para. 1 lit. f. GDPR and a contract processing agreement pursuant to Art. 28 para. 3 sent. 1 GDPR.

ELAINE may use the data of the recipients in pseudonymous form, i.e. without allocation to a user, for the optimisation or improvement of its own services, e.g. for the technical optimisation of the dispatch and presentation of the newsletters or for statistical purposes. However, ELAINE does not use the data of our newsletter recipients to write to them itself or to pass on the data to third parties.

The newsletters are sent via the mailing service provider "MailChimp", a newsletter mailing platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. The Privacy Policy of the mail order service provider can be viewed here: https://mailchimp.com/legal/privacy/. Mailchimp is operated based on our legitimate interests according to art. 6 par. 1 lit. f. GDPR and an order processing contract according to art. 28 para. 3 sent. 1 GDPR.

Mailchimp can use the data of the recipients in pseudonymous form, i.e. without allocation to a user, to optimize or improve its own services, e.g. for technical optimization of the sending and presentation of the newsletter or for statistical purposes. However, Mailchimp does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.

11. Google Webfonts

Google web fonts are used to improve the visual presentation of various information on this website. The web fonts are transferred to the cache of the browser when the page is called up in order to use them for the display. If the browser does not support Google Web Fonts or prevents access, the text is displayed in a standard font. When the page is called up, no cookies are set for the website visitor. Data transmitted in connection with the page view is sent to resource-specific domains such as fonts.googleapis.com or fonts.gstatic.com. They are not associated with data that may be collected or used in connection with the parallel use of authenticated Google services such as Gmail. You can set your browser so that the fonts are not loaded from the Google servers. Information on the data protection conditions of Google Webfonts is available at: https://developers.google.com/fonts/faq#Privacy.

General information on data protection is available in the Google Privacy Center at: http://www.google.com/intl/de-DE/privacy/.

12. Youtube

We use YouTube, a service from Google, to integrate videos.

These videos are stored on www.youtube.com and can be played directly from our site. YouTube uses cookies for data collection and statistical data evaluation. YouTube uses cookies to collect reliable video statistics, prevent fraud and improve user experience, among other things. The information generated by the cookie about your use of this website (including your IP address) is transmitted to and stored on YouTube servers, including in the USA. Your IP address cannot be assigned unless you have logged in to YouTube or another Google service before visiting the site or unless you are permanently logged in. If you do not wish to do so, you must log out of your YouTube account and your other Google Accounts.

The YouTube cookies provide us with statistical data on the retrieval of individual videos embedded in the website without any reference to the individual user. YouTube's embedded videos are used to the extent permitted by YouTube, which all users must accept. If you see any copyright infringement, please report this directly to YouTube. We use embedded YouTube videos in an enhanced privacy mode. This means that YouTube does not store cookies for a user who views a website with an embedded YouTube video player, but does not click on the video to start playback. When the YouTube video player is clicked, YouTube may store cookies on the user's computer. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or of the use of these data by YouTube. For more information on YouTube's official Privacy Policy, please visit https://www.google.de/intl/de/policies/privacy/ and https://support.google.com/youtube/answer/171780?hl=de.

13. Storage period of personal data

We store personal data for the duration of the respective legal retention period or as long as the purpose of the collection exists. After expiry of the retention period, the data is routinely deleted, unless it is necessary for the initiation of a contract or for the fulfilment of a contract. If the users' data is not deleted because it is required for other and legally permissible purposes, its processing is restricted as far as possible. Accordingly, the data will be blocked where possible and not processed for other purposes. This applies, for example, to user data that must be retained for commercial or tax law reasons.

14. Contact forms and contacting

We offer you the opportunity to contact us via contact forms, telephone, e-mail and social media. The data transmitted in this way is processed for the purpose of processing the contact enquiry with the person responsible based on Art. 6 Par. 1 lit. b for contracts and pre-contractual measures such as offers and Art. 6 Par. 1 lit. f for other enquiries. Your data may be stored and processed in our CRM system.

15. Automated decision

We use automated decisions when matching shipments and personal data with export control and sanction lists of the European Union and other countries from which exports may be made. Depending on the outcome of this review, we may be required to implement appropriate measures under export control regulations imposed by the European Union and other countries from which exports may be made. The legal basis for the processing of the data is Art. 6 para. 1 lit. c GDPR. The comparison ensures compliance with applicable export law.

16. Safety information

By taking all technical and organisational measures, we make every effort to process your personal data in such a way that the regulations of the data protection laws are observed and to protect these data..

17. Modification of the Privacy Policy

ALSO reserves the right to amend this Privacy Policy at any time in accordance with the applicable data protection regulations and other statutory provisions.

18. Where will my data be processed?

Your data will be processed within the EU and the EEA. To the extent permitted by law, data processing also takes place in non-European countries.

19. Transfer of data to third parties

We pass on data to third parties if this is necessary for the fulfilment of the contract and / or we expressly state this in this data protection declaration and / or we are legally obliged and / or entitled to do so in individual cases.

Based on the legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR and with recital 48 of the GDPR, we may pass on your data to affiliated companies of the ALSO Group.

20. Rights of data subjects

In accordance with Art. 15 GDPR, you have a right to information about the processing of your personal data.

Furthermore, you are free to exercise your rights of correction, deletion or, if deletion is not possible, restriction of processing and data transferability in accordance with articles 16-18, 20 GDPR. Should you wish to exercise this right, please contact our data protection officer.

If you believe that your personal data is not being processed in compliance with the data protection laws, we would kindly ask you to contact our data protection officer.
Furthermore, you have the right to complain to the responsible supervisory authority at any time.

Competent supervisory authority of ALSO:

National Authority for Data Protection and Freedom of Information
1055 Budapest, Falk Miksa utca 9-11.
Postal address: 1530 Budapest, Pf.: 5
Phone: +36 (1) 391-1400
Fax: +36 (1) 391-1410
Internet: http://www.naih.hu
e-mail: ugyfelszolgalat@naih.hu

You also have the right to object to the processing of your personal data at any time in accordance with Art. 13 para. 2 lit. b GDPR.

Personal data which you transmit to us in the course of exercising data subject rights will be stored by us in accordance with Art. 6 para. 1 lit. f GDPR in the legitimate interest. The legitimate interest consists in the verifiability of your request.

Under the conditions of Article 21 (1) GDPR, data processing may be objected to for reasons arising from the specific situation of the data subject.

The above general right of objection applies to all processing purposes described in this Privacy Policy which are processed based on Art. 6 para. 1 sent. 1 lit. f GDPR. We are only obliged to implement such a general objection if you provide us with reasons of overriding importance (e.g. a possible danger to life or health).

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