P-Metál Kft.
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Privacy Policy

1. Legislation governing data processing

The processing of customer data is governed by the following legislation:

2. Definitions

Data Controller (plural: Data Controllers): the natural or legal person who obtains personal data provided by Users in the course of owning, managing, storing, ensuring the operating conditions of, maintaining or programming the Website or third-party elements embedded in the Website. A Data Controller may be a primary or a third-party Data Controller.

  • primary data controller: the Website Owner;
  • third-party data controller: a natural or legal person performing data processing tasks on behalf of the Website Owner.

Data carrier: a device capable of recording digital files as electrical signals that can be read by a computer.

Third-party Data Controller: those Data Controllers who, under a contract with the Website Owner, provide services relating to operating conditions, maintenance, programming, upkeep, data collection and data storage.

Browser: the program run by the User on the Device with which the User visits the Website and navigates its pages.

User (plural: Users; unambiguous designation: Website User): the natural or legal person(s) visiting the Website using a Browser run on their Device(s). An agent of the User shall mean an IT professional or other assistant, acting for consideration or free of charge and presumed to be familiar with the settings of the Device and/or Browser, whom the User instructs to configure the Device or Browser owned or used by the User. The User is responsible for the correct settings of the Device and Browser even if these were made through an agent.

Written request: for the purposes of this Notice, the following qualify as written requests: a letter delivered by post or courier, in person or by an authorised representative, an open postcard, a telegram, or an e-mail. The following do not qualify as written requests: SMS (short text messages sent from a mobile, nomadic or landline telephone) and messages sent via a chat program or chat interface.

Device (plural: Devices): the electrically operated device and its accessories with which the User visits the Website. For the purposes of visiting the Website, Devices can be divided by type into mobile and desktop devices; this classification is used – for statistical purposes – in the anonymous data relating to browsing collected during visits to the Website.

Identified data: data relating to a User that contains any one or more of the following:

  • the User’s real name,
  • the real name of the User’s minor or juvenile child, as well as any data of the minor or juvenile child that can be clearly linked to that person and that is listed in points 1 and 3–12 of this definition with respect to an adult User,
  • the address of the User’s residence, place of stay, registered office or business premises,
  • the User’s postal address,
  • the User’s e-mail address,
  • any identifier of the User consisting of a combination of numbers and letters assigned by any Hungarian or foreign state authority (e.g. personal identification number, identity document number, etc.),
  • the User’s landline, mobile or nomadic telephone number,
  • the name and details of the User’s employer,
  • the alias used by the User for online login (nickname, commonly: username),
  • the password used by the User for online login, in plain or encrypted form,
  • the digital image of the User’s handwritten signature or a copy of it in image format,
  • the User’s authenticated electronic signature.

Non-identified data: in other words, anonymous data. Any set of data relating to a User that does not contain the data listed in the definition of identified data.

Record: the totality of data, consisting of several data items, belonging to one user.

Oral request: for the purposes of this Notice, any request made in person or by means of telecommunication that does not qualify as a written request.

Web hosting: for the purposes of this Notice, the remote unit consisting of electrical and IT equipment (hardware) and code (software), capable of serving a website remotely, on which the Web Hosting Provider provides an environment suitable for operating the Website. Geographical location of the Web hosting: Budapest, Hungary.

Web Hosting Provider: for the purposes of this Notice, the company or enterprise that provides the Web hosting to the Website Owner as its product.

Website Owner: for the purposes of this Notice, the natural or legal person designated as the Website Owner in the detailed sections of this Notice.

Website: for the purposes of this Notice, the present digital interface available at https://p-metal.hu/, accessible on the public international network (internet), providing information on the activities of P-Metál Kft. The following shall be deemed elements of the Website: the source code of the Website’s script files and the MySQL database storing variable elements.

Website visit (session), as an abstract concept: the activity of the User during which the User arrives at the Website, browses between its pages and then leaves the Website.

Webmaster: the company detailed below which, on behalf of the Website Owner, takes responsibility for the integrity and functionality of the Website’s code.

3. Data Controller

Primary data controller and website owner:

Name: P-Metál Fémkereskedelmi és Öntvénygyártó Korlátolt Felelősségű Társaság

Registered office: 2800 Tatabánya, Szigeti utca 6-8-10, Hungary

Representative: Zsigmond Pordán

Telephone: +36 70 409 4016

3.1. Third-party data controllers

3.1.1. Web Hosting Provider

Company name: DotRoll Kft.

Address: 1148 Budapest, Fogarasi út 3-5, Hungary

Tax number: 13962982-2-42

E-mail: support@dotroll.com

Data processed: anonymous data relating to browsing.
The provider’s privacy policy: https://dotroll.com/hu/adatkezelesi-szabalyzat/

3.1.2. Anonymous measurement of user behaviour (Google web analytics service)

All anonymous visitor measurement providers whose tracking code has been placed on the Website are to be listed here. In Central Europe, the service of Google Ireland Ltd. is generally used.

Name: Google Ireland Limited

Registered office: Gordon House, Barrow Street, Dublin 4 (Ireland)

Company registration number: 368047

Scope of data processed: anonymous data relating to browsing, as listed in detail in Google Ireland Limited’s privacy policy.

Google Ireland Limited’s privacy policy in English

4. Scope of data used during the use of the website and the purposes of data processing in detail

4.1. Anonymous data relating to browsing collected for statistical purposes

4.1.1. Controller of the data

The data are controlled jointly by Google Ireland Limited (Ireland) and the Website Owner.

4.1.2. Source of the data

The source of the data is data recording resulting from the User’s Website visit.

4.1.3. Scope of the data

  • the public IP address of the Device used for browsing,
  • the user agent identifier of the Browser used for browsing: this identifier provides information on the type of Device (desktop or mobile), the Device’s operating system, the type of web browser and the version number of the web browser,
  • the browsing carried out by the User on the site, from arrival at the site until the site is closed or left,
  • the type classification of the User’s Device,
  • GPS position,
  • data from the Device’s sensor(s).

4.1.4. Purpose of using the data

  • non-identified, numerical analysis of the number of Users,
  • non-identified, numerical analysis of the type classification of Devices used by Users,
  • non-identified, numerical analysis of the geographical location of Users,
  • non-identified, numerical analysis of visits to individual subpages of the Website,
  • non-identified, numerical analysis of Website traffic,
  • non-identified, factual recording of events relating to user activity on the Website operated on the Web hosting (system log).

4.1.5. Data retention

Google Ireland Limited retains the data it collects about visits to the Website in accordance with the service terms provided to the Website Owner. Detailed information on data retention is provided in Google Ireland Limited’s privacy policy.

4.2. Cookies

Cookies are small information files placed, during use of the Website, in the directory/folder in which the User’s Browser collects its temporary files, containing the website settings specified by the User.

Purpose of using cookies:

  • to make the User’s subsequent browsing easier. If the User blocks or prohibits the placement of cookies, the User will not be able to use the services provided by cookies that make browsing easier during subsequent visits to the Website.
  • to collect anonymous data for the Website Owner about Users’ browsing habits on the Website and the number of Website Users. If the User prohibits the use of these cookies, the User may continue browsing the Website without disruption; however, the Website Owner will not be informed of the User’s browsing on the Website. The Website Owner may not place Users who block cookies used to track browsing habits at any disadvantage.

The Website’s own code does not directly place cookies on the User’s computer.

The independent system embedded in the Website’s code (the provider(s) listed in section 3.1.3 to be indicated here) retains the User’s settings; in this respect, the cookie privacy notice of MotiBro Kft.’s service shall prevail. (The external provider’s privacy notice, or another equivalent legal statement, to be referenced here again.)

In the case of the Google web analytics code installed on the Website, the privacy policies of Google Ireland Limited (Ireland) apply to data retention.

5. Access to data and data security measures

5.1. Access to data and data transfer

The personal data you provide may be accessed by the Data Controller’s employees in order to perform their duties.

The Data Controller transfers the personal data it processes to the third parties listed in section 3.1 of this Notice, for the performance of its own tasks and for the purposes of maintaining the Website, maintaining its operational security, operating the web server and preserving the integrity of the data, under individual contracts or publicly available general terms and conditions.

The Data Controller discloses personal data to organisations not listed in section 3.1 of this Notice only in exceptional cases specified by law, for example:

  • if court proceedings are initiated against the User and the court conducting the proceedings requires the User’s personal data to be handed over,
  • if the competent investigating authority requests the disclosure of the User’s personal data for investigative purposes.

5.2. Data security measures

The Website Owner may store the User’s personal data relating to the Website in the following places:

  • on the Web hosting,
  • on its own data carrier not accessible to others,
  • on a data carrier attached to a computer owned by the Website Owner company or its members and not accessible to others,
  • on a remote server individually owned by the third-party data controllers mentioned in section 3.1, which may be accessed by the third-party data controller company and by the Website Owner,
  • on a data carrier owned by the third-party data controller with exclusive access by that controller.

The Website Owner as Data Controller, and the third-party Data Controllers acting on behalf of the Website Owner, shall take appropriate measures to ensure that:

  • personal or person-related, identified or non-identified data are not accessed by unauthorised persons,
  • personal or person-related, identified or non-identified data are not altered by unauthorised persons,
  • personal or person-related, identified or non-identified data can be restored to their original state, or to a state as close as possible to the original, if damaged in their original location as a result of a technical fault or malfunction.

6. The User’s rights in relation to data processing

6.1. The User’s right of access and right to information

The User, as the data subject, may access their personal data.

If the User requests confirmation from the Data Controller as to whether it processes their personal data, the Data Controller shall provide information on the following:

  • what personal data the Data Controller processes,
  • on what legal basis the Data Controller processes the personal data,
  • for what purpose the Data Controller processes the personal data,
  • from what source the Data Controller processes the personal data,
  • for how long the Data Controller processes the personal data.

The User has the right to be informed by the Data Controller whether or not the Data Controller processes their personal data (hereinafter: right to information). The User’s right to information:

  • covers identified personal data,
  • does not cover non-identified, person-related data,
  • does not cover identified or non-identified personal data relating to other Users,
  • includes pseudonymised data that can be clearly linked to the User concerned.

At the User’s request, the Data Controllers provide access to and a copy of the User’s personal data on their online interface. If the User does not wish to use the online interface, the Data Controllers may charge a reasonable administrative fee for providing the data.

The User shall notify the Data Controllers in writing of any request falling within the scope of exercising their right of access and right to information concerning their data, if the User does not wish to or is unable to use the online interfaces provided by the Data Controllers, or if the online interfaces are not suitable for exercising the User’s right.

6.2. The User’s right to rectification

The User is entitled to have their personal, identified data rectified.

The User’s right to rectification:

  • does not cover non-identified data relating to the User,
  • covers only identified data relating to the User,
  • does not cover identified data relating to other Users,
  • includes pseudonymised data that can be clearly linked to the User.

The Data Controllers correct or supplement the User’s personal data exclusively on the basis of the User’s written request.

6.3. The User’s right to erasure

Under certain conditions, the User is entitled to request the erasure of their personal data. The basis for exercising this right is the User’s written request.

The Data Controllers, individually and jointly, shall erase the User’s data without undue delay if:

  • the Data Controller processes such personal data,
  • the User requests the erasure of their personal data, and
  • the personal data are no longer necessary for the purposes for which the Data Controller processes them.

The Data Controllers, individually and jointly, shall erase the User’s data without undue delay if:

  • the Data Controller processes the User’s personal data,
  • the User requests the erasure of their personal data,
  • the User withdraws the consent on which the processing of their data is based, and
  • there is no other legal basis for processing the User’s data.

The Data Controllers, individually and jointly, shall erase the User’s data without undue delay if:

  • the processing is necessary for the purposes of the legitimate interests of the Data Controllers or a third party, and
  • the User objects to the Data Controller processing their personal data, and
  • there are no overriding legitimate grounds for processing such personal data over the User’s objection.

The Data Controllers, individually and jointly, shall erase the User’s data without undue delay if:

  • the User requests the erasure of their data, and
  • the processing of the data by the Data Controller is not unlawful, or
  • erasure is mandatory under applicable law, or
  • the User’s data are collected in relation to information society services.

The basis for exercising the right to erasure is the User’s written request.

6.4. The User’s right to restriction of processing

The User is entitled to request the restriction of the processing of their data.

The User’s right to request restriction of the processing of their personal data:

  • does not cover non-identified data,
  • covers only personal data relating to the User,
  • does not cover personal data relating to other Users,
  • includes pseudonymised data that can be clearly linked to the User.

The Data Controller restricts the processing of the User’s personal data for the period during which it verifies the accuracy of such data, if the User requests restriction of processing and contests the accuracy of their data.

The Data Controller restricts the processing of the User’s personal data if the User requests restriction of the processing of data whose processing is unlawful and the User opposes the erasure of such data.

The Data Controller restricts the processing of the User’s personal data if:

  • the User requests restriction of the processing of their personal data, and
  • the Data Controller no longer needs the User’s personal data for the purposes of processing, and
  • the User requests restriction for the establishment, exercise or defence of legal claims.

The Data Controller restricts the processing of the User’s personal data if:

  • the User objects to the processing of personal data necessary for the purposes of the legitimate interests of any or all of the Data Controllers, and
  • the User is awaiting confirmation as to whether there are legitimate grounds for the Data Controller’s processing of their personal data that do not override the User’s objection.

If the Data Controllers, individually or jointly, restrict the processing of the User’s data, the Data Controllers, individually or jointly, are entitled to:

  • store the User’s personal data,
  • process the User’s personal data with the User’s consent,
  • process the User’s personal data for the establishment, exercise or defence of legal claims or for the protection of the rights of another person.

The basis for exercising the right to restriction of processing is the User’s written request.

6.5. The User’s right to data portability

The User is entitled to receive the personal data concerning them, which they have provided to a Data Controller, in a structured, commonly used and machine-readable format.

The User is also entitled to have their personal data transmitted – with their consent – to another data controller designated by the User, where the processing is carried out by automated means.

The User’s right to data portability:

  • does not cover non-identified data,
  • covers exclusively the User’s identified personal data,
  • does not cover the personal data of other Users,
  • does not cover clearly pseudonymised data.

6.6. Form of exercising the User’s rights

The User is entitled to exercise control over the processing of their data in explicit and non-explicit form.

The non-explicit form of exercising rights is when the User configures the Browser and/or the Device in a way that prevents or prohibits the transfer or collection of data. In this case, the User cannot be obliged to notify the Website Owner or the Data Controllers.

The explicit form of exercising rights is when the User:

  • submits a written request to the Website Owner or the Data Controllers in order to exercise their rights, in compliance with the formal requirements set out in this Notice,
  • where possible, authorises the Website Owner and the Data Controllers jointly, on an online interface, to process the data. On the online interface, the data entry interface (form) must clearly indicate in text which element is required to express the User’s consent, and how the element must be handled to express the User’s consent or refusal of consent. The element expressing the User’s consent shall be programmed so that the data are transmitted if the User consents, and are not transmitted in any form if the User refuses consent.

With regard to the explicit form of exercising rights on an online interface, if the User refuses consent to data processing, the User forfeits the possibility of using those online services requiring personal data for which data are collected and transmitted on the Website.

With regard to non-identified data relating to the User as a person, the Website Owner may not cause any legal disadvantage to the User in the event of the User’s non-explicit exercise of rights concerning data collection and data transfer.

Due to technical limitations, the following adverse consequences may arise for the User as a result of the User’s activity expressing non-explicit prohibition or restriction via the Device or the Browser:

  • the User’s settings for displaying and using the Website are not retained, and the User has to specify them again and again on each Website visit,
  • undesired changes may occur in the texts or visual elements of the Website.

The Website Owner and the Data Controllers, individually and jointly, accept no liability for the settings of the Device or the Browser made by the User that express non-explicit prohibition or restriction.

6.7. Form of the User’s requests and deadline for handling them

The Data Controllers respond to written requests from the User concerning the rights set out in sections 6.1–6.5 of this Notice without undue delay, but no later than within 1 month.

The written request must contain:

  • the User’s real name,
  • at least 2 further data items of the User by which the Data Controller can identify the data unit (record) relating to the User,
  • the User’s clear request concerning their own personal data,
  • a justification of the request to exercise rights is not a required element of the written request.

If it cannot be clearly determined from the written request which data unit (record) containing personal data holds the User’s data, the Data Controller is entitled to request in writing further data from the User, drawn from the scope of the data processed.

If the User’s intention regarding the processing of their data cannot be clearly determined from the written request, the Data Controller shall request the User in writing to clarify or specify the request.

For security reasons, the Data Controllers are unable to accept oral requests.

6.8. The User’s right to lodge a complaint

If the User believes that their rights have been infringed, the Data Controllers, individually and jointly, recommend that the User first seek a resolution by contacting the Data Controllers directly. If such consultation does not lead to a result, or if the User does not wish to take part in it, the User may turn to the court or to the Hungarian National Authority for Data Protection and Freedom of Information (NAIH). If court proceedings are initiated, the User may choose to bring the proceedings before the court competent for their place of residence or place of stay.

Contact details of the NAIH: 1125 Budapest, Szilágyi Erzsébet fasor 22/c, Hungary; telephone: +36 1 391 1400; fax: +36 1 391 1410; e-mail: ugyfelszolgalat@naih.hu; website: naih.hu

7. Amendments to this Notice

The Data Controllers reserve the right to jointly amend this Notice at any time. Where applicable, the Data Controllers will inform Users of such amendments by e-mail and, in all cases, in accordance with the applicable legislation.