Information security and data protection are of the utmost importance to us. This Privacy Notice details our commitment to protecting your privacy in accordance with the applicable laws and regulations.
I. Who will handle your personal data?
Handler of your data: Simotrade Kft.
Registered office: Beszédes Ferenc street 24/C, 7081 Simontornya, Hungary
Telephone: +36 74 486 408
E-mail: simotrade@simotrade.hu
Represented by: Sándor János Horváth, CEO
- General terms
2.1. What constitutes as personal information?
Any information that might be associated with you as a natural person (not a business).
| Examples include name, identification number, location data, online ID, or one or more factors related to the Employee’s physical, physiological, genetic, intellectual, economic, cultural, or social identity. |
2.2. What does data management mean?
Regardless of the process used, any operation or set of operations on the personal data described above.
| Examples include the collection, recording, systematization, storage, modification, use, querying, transference, disclosure, alignment or combination, blocking, erasure and destruction of personal data and the prevention of further use of data, the recording of photographs, sound or images, as well as the recording of physical characteristics (e.g., fingerprint or palm print, DNA sample, iris image). |
2.3. Who carries out such processing of your personal data?
Our firm may handle your personal data as a data controller.
The controller is the entity that, alone or in cooperation with others, determines the purposes for which the personal data is processed, makes the decisions regarding the processing, and carries them out (or has them carried out with a data processor).
Our company may use data processors to process your personal data.
A processor is a person or an organization that processes personal data on behalf of or under the instructions of the controller.
| Examples of such data processors include accountants, auditors, IT administrators, etc. |
2.4 What is data protection and the purpose of this notice?
The purpose of data protection regulation is to ensure that data controllers and processors handle your personal data only in compliance with the law in the course of their activities, to inform you accordingly, and to be accountable for compliance.
III. Why, how and for how long does our company process your personal data?
| Purpose of data processing | Description of data processing | Personal data processed and their source | Legal basis of data processing | Duration of data processing |
| Data management of job applications | We process the personal data contained in CVs and other documents submitted directly to us or for targeted advertised positions.
The purpose of the processing is to notify the data subject of job vacancies that best match his/her/their qualifications and interests, to arrange an appointment with the involved person, and to conduct the recruitment process. |
Personal data, contact details (e-mail address, telephone number) provided in CVs and other submitted documents.
We may access public personal data of job applicants posted on social networking sites that are relevant to the job (personal data will not be saved, stored or transmitted). |
The legal basis for processing is the legitimate interest of our company [Article 6 (1) (f) GDPR].
You can find out more about the interest assessment screening for job applications by e-mail or in person at the office. |
In connection with applying for a advertised position: in case of a successful application, the duration of the employment relationship, in case of an unsuccessful application, 3 months after the selection (probationary period) or until the person concerned applies for cancellation.
In the case of a sent-in CV: 3 months after the CV is sent or until the person concerned requests cancellation. |
| Inquiries, requests for quotes | Our company processes personal data received in connection with its business activities (via the contact form on the website or any other interface and means) or contained in questions, inquiries and requests for proposals sent by our firm to other companies. The purpose of the processing is to respond to questions, inquiries, and requests for offers from or to our company to allow a contract to be established between the inquiring entity and our company. | The personal data processed are the personal information that may be contained in the requests and replies, and necessary personal data for the conclusion of the contact between the parties (telephone number, e-mail address).
When requesting an offer through the website, it is obligatory to provide your name and e-mail address in order to be contacted by our company.
The source of the personal data is the data subject. |
The legal basis for data processing is the conclusion of a contract between our company and the contractual partner if a contract is to be concluded as a result of the request for an offer [Article 6 (1) (b) GDPR], if no contract is concluded between the parties as a result of the request for an offer, then the legitimate interest of our company [Article 6 (1) (f) GDPR]. | If the inquiry or request for proposal does not result in a contract, the period of data processing shall be 5 (five) years after the failure to conclude the contract, in accordance with the statutory provisions of limitation according to the Civil Code.
If a contract is concluded, the period of processing shall be as described below. |
| Contracts, orders | Our company handles the personal data contained in contracts concluded and to be concluded in connection with its economic activities. The purpose of the processing is the conclusion of the contract between our company and the contractual partner and its fulfilment in compliance with the legislation in force. | The personal data processed are the data provided in the order, contract, contact information (telephone number, e-mail address), and data necessary for the issue of accounting documents.
The source of the personal data is the data subject. |
The legal basis for processing is the conclusion and fulfillment of the contract between our company and the contractual partner [Article 6(1)(b) GDPR]. | The duration of the data processing is 8 (eight) years after the fulfilment of the contract, in accordance with the legal requirements for the preservation of accounting records. |
- Who can access your personal data?
Your personal data will not be shared, sold, or made available to third parties. We will not transfer your personal data to third countries or international organizations. We will only share your personal information with third parties under this policy, described below:
- Compliance with legal obligations
We may transfer personal data if such action is necessary to comply with any law or if we are required to do so by a decision or order of a competent authority or court. In this case, the legal basis for the transfer is the fulfillment of a legal obligation to which our company is subject to [Article 6(1)(c) GDPR].
- To assert our claims, demands, and legitimate interests
Our company may need to share personal data to protect the rights and interests of our enterprise following applicable law (e.g., denunciation, criminal prosecution, etc.). In this case, the legal basis for the transfer is the legitimate economic interest of our company [Article 6(1)(f) GDPR].
- Use of external service providers
We use third-party services in the course of our operations. The data processors used by our company may access your personal data only in a form and to the extent compatible with the purposes of the processing and under the legal basis of the processing, under the applicable laws, only if absolutely necessary.
- How does our company protect your personal data?
- Safety
We have taken and will continue to take appropriate technical and organizational measures to protect your personal data against loss or other forms of unlawful processing. In the course of our activities, we make every effort to comply with the best practices of information security.
- Confidentiality
In the course of its business activities, our company is bound by a confidentiality obligation with its business partners, including the data processor identified above, which covers all information relating to the contracts, including any personal data that may be processed.
- What rights do you have concerning the processing carried out by our company?
6.1. The right to request information and the right to access
You may request information from our company in writing so that we can inform you
- what personal data,
- on what legal basis,
- for which data processing purpose,
- from what source,
- how long it will handle,
- to whom, when, under what law, to which of your personal data we have given access or to whom we have transferred your personal data.
Our company will respond to your request within a maximum of 15 (fifteen) days by e-mail or post to the contact details you have provided, subject to the following:
- Our company may ask you to clarify the content of the request, indicating the exact information or processing activities requested, prior to executing such a request.
- If your right of access under this clause adversely affects the rights and liberties of others, in particular the trade secrets or intellectual property of others, we shall be entitled to refuse to comply with your request to the extent necessary and proportionate.
- (c) In the event that you request more than one copy of the above information, we shall be entitled to charge you a reasonable fee proportionate to the administrative costs of producing the additional copies.
- If the personal data you have provided is not processed by our company, we are also obliged to inform you in writing.
6.2 Right of rectification
You may request in writing that we correct personal data that is inaccurate, incorrect, or incomplete. In this case, we will promptly, and at the latest within 5 (five) days, clarify or correct the personal data indicated or, if compatible with the purposes of the processing, supplement it with additional personal data provided by you or with a statement by you on the personal data processed. You will be informed of this by e-mail or by post sent to the contact details you have provided.
Our company will be exempted from the obligation to rectify where
- accurate, correct, or complete personal data is not available to us and is not provided by you; or
- the accuracy of the personal data provided by you cannot be established beyond a reasonable doubt.
6.3. The right to deletion
You may request in writing that we delete your personal data. You must submit your request for erasure in writing, and you must specify the data and the reason why you wish to have your data erased.
We will refuse a request for erasure if
- we are required by law to continue to store the personal data; or
- our processing is justified by compelling legitimate grounds which override your interests, rights, and liberties.
If there is no such obligation or no such overriding legitimate reason on our part, we will comply with your request within a maximum of 15 (fifteen) days and will notify you by e-mail or post to the contact details provided.
6.4. The right to the restriction of processing
You may request in writing that we restrict the processing of your personal data. During the period of restriction, our company or a data processor acting on its behalf, or under its instructions may carry out processing operations other than the storing of the personal data concerned, by the restriction solely to pursue your legitimate interests or as provided by law. You may request the restriction of processing if
- You contest the accuracy of the personal data (in this case, the limitation applies for the period that allows us to verify the accuracy of the personal data);
- the processing is unlawful, and you oppose the deletion of the data and instead request the restriction of their use,
- (c) our company no longer needs the personal data for processing, but you require them for the establishment, exercise, or defense of legal claims; or
- (d) you have objected to the processing (in which case the restriction will apply onyl for a time period until it is determined whether the legitimate grounds of the controller override the legitimate ground of the data subject).
In the case of restriction, personal data – except for storage – may only be processed with your consent to the enterprise, except for the exercise or defence of legal claims or for the protection of the rights of an another natural or legal person, and for important public interests of the EU or of an EU Member State.
We will inform you in advance of the lifting of any restriction on processing.
We will promptly inform the persons to whom you have disclosed your data after we have complied with your request to exercise your right to restriction, provided that this is not impossible or involves a disproportionate effort on our part. Upon your request, we will inform you of these recipients.
6.5. The right to object
Where your data are processed on the basis of legitimate interests, you must be provided with adequate information and the right to object to the processing. This right should be explicitly brought to your attention at the latest at the time of the first contact with you.
You have the right to object to the processing of your personal data on this basis, and in such a case our company may no longer process your personal data unless it can be demonstrated that
- the processing is justified, by compelling legitimate grounds on our part which override your interests, rights, and liberties; or
- the processing relates to the establishment, exercise, or defense of legal claims by our company.
6.6 Right to data portability
You have the right to obtain the personal data concerning you that you have provided to us in a structured, commonly used, machine-readable format (e.g., by email) and to have this data transmitted directly by us to another data controller. In case you exercise your right to data portability, our company will comply with your request, primarily utilizing an email attachment in .pdf format.
6.7. The right to legal remedy
6.7.1. Settling a dispute with us
You may submit your complaints and requests regarding the processing of your personal data to us orally (in person) or in writing (in person or by means of a document delivered by another person or by post or e-mail) using the contact details provided in Section I, under the name of the Data Controller.
6.7.2. The right to file a complaint
If you have not been able to resolve your complaints or requests regarding your personal data with us in a satisfactory manner, or if you consider at any time that there has been or is an imminent risk of a breach of rights concerning the processing of your personal data, you have the right to file a complaint with the National Authority for Data Protection and Freedom of Information.
Contact details for the National Authority for Data Protection and Freedom of Information
Headquarters: 1055 Budapest, Falk Miksa utca 9-11.
Address for correspondence: 1363 Budapest, PO Box 9.
Phone: +36 (1) 3911400
Fax: +36 (1) 3911410
E-mail: ugyfelszolgalat@naih.hu
Web: www.naih.hu
6.7.3 The right to apply to the courts (right of bringing an action)
Regardless of your right to file a complaint, you can take legal action if your rights under the GDPR or the Infotv. have been violated in the processing of your personal data.
As a data controller established in Hungary, we can be sued in a Hungarian court.
You may also bring the action before the court of your country of residence. The contact details of courts in Hungary can be found at the following link: http://birosag.hu/torvenyszekek.
The legislation referred to in the privacy notice:
- GDPR: General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Regulation (EC) No 95/46/EC
- : Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information
- Civil Code: Act V of 2013 on the Civil Code
- Rules of accounting: Act C of 2000 on accounting