GREENHESS LIMITED LIABILITY COMPANY PRIVACY POLICY EFFECTIVE DATE: JANUARY 01, 2025
1. PURPOSE OF THE PRIVACY POLICY
Greenhess Limited Liability Company (registered office: 4225 Debrecen, Monostorerdő Street 98., company registration number: 09-09-032881, tax number: 29266412-2-09, represented by Tamás Veres, managing director) as data controller acknowledges the content of this legal notice as binding on itself.
It undertakes to ensure that all data processing related to its activities complies with this policy and the applicable national laws and the legal acts of the European Union, in particular:
• Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR)
• Act CXII of 2011 on the right of informational self-determination and on freedom of information (Info Act),
• Act V of 2013 on the Civil Code (Civil Code),
• Act CVIII of 2001 on certain issues of electronic commerce services and information society services (E-commerce Act).
This privacy policy applies to the following domain:
• www.greenhess.com
Data protection policies related to the data controller’s data processing activities are continuously available at www.greenhess.com/gdpr.php.
The data controller reserves the right to modify this policy at any time. Affected parties will be informed of changes in due time.
If you have any questions related to this notice, please write to us and we will answer your questions.
The data controller is committed to protecting the personal data of its clients and partners and considers it of utmost importance to respect its clients' right to informational self-determination. The data controller handles personal data confidentially and takes all necessary security, technical, and organizational measures to guarantee data security.
The data controller sets out its data processing practices below.
2. DATA CONTROLLER'S DETAILS
If you wish to contact us regarding the processing of your personal data, you can do so via the email info@greenhess.com or by phone at +36(30)570-4986.
Company name: Greenhess Ltd.
Registered office: 4225 Debrecen, Monostorerdő Street 98.
Tax number: 29266412-2-09
Company registration number: 09-09-032881
Represented by: Tamás Veres, managing director
Phone number: +36(30)570-4986
Email: info@greenhess.com
2.1 DATA PROTECTION OFFICER
The data controller does not carry out activities that would necessitate the appointment of a data protection officer.
3. SCOPE OF PERSONAL DATA PROCESSED
3.1. PERSONAL DATA PROVIDED DURING CONTACT
Personal data shared when contacting Greenhess Ltd., such as name, phone number, email address, address, as well as for companies company name, contact details, registered office, company registration number, tax number, bank account number. These data are necessary for identifying the order and contacting the client for service provision.
3.2. PERSONAL DATA PROCESSED IN CONNECTION WITH ORDER FULFILLMENT AND CONTRACTING
Multiple data processing activities may take place for the purpose of contract conclusion and fulfillment. We inform you that data processing related to complaint management or warranty claims only occurs if you exercise these rights.
Detailed data processing related to contract conclusion and fulfillment:
3.2.1. PERSONAL DATA PROCESSED IN CONNECTION WITH INVOICING AND BILL ISSUANCE
Data processing is done for the purpose of issuing invoices in accordance with applicable laws and compliance with accounting voucher retention requirements. According to Section 169 (1)-(2) of the Accounting Act, companies must retain accounting vouchers directly or indirectly supporting bookkeeping.
Processed data:
Name, address, email address, phone number.
Retention period:
Issued invoices must be kept for 8 years from the date of issuance, according to Section 169 (2) of the Accounting Act.
Legal basis of data processing:
According to Section 159 (1) of Act CXXVII of 2007 on general sales tax, invoicing is mandatory and invoices must be kept for 8 years based on Section 169 (2) of Act C of 2000 on accounting [Regulation Article 6(1)(c)].
3.2.2. PERSONAL DATA PROCESSING BY DATA PROCESSORS RELATED TO PRODUCT DELIVERY
3.2.2.1.
Recipient name: GLS General Logistics Systems Hungary Package Logistics Ltd.
Recipient headquarters: 2351 Alsónémedi, GLS Europa Street 2.
The courier service cooperates with the data controller under contract to deliver orders. The courier handles the received personal data according to their data management policy available on their website.
3.2.2.2.
Recipient name: Hungarian Post Private Limited Company
Recipient headquarters: 1138 Budapest, Dunavirág Street 2-6.
Recipient phone: +36-1/767-8200
Recipient email: ugyfelszolgalat@posta.hu
Recipient website: posta.hu
The courier service cooperates with the data controller under contract to deliver orders. The courier handles the received personal data according to their data management policy available on their website.
3.2.3. PERSONAL DATA PROCESSED FOR UTILIZING DISCOUNTS FOR RETIREES
Personal data shared when contacting Greenhess Ltd. required for providing discounts eligible to retirees, such as documents issued by pension payment or pension entitlement authorities containing the name of the entitled person, personal identification data, document number related to pension entitlement or payment, and other identification data on the document.
This data is necessary to verify eligibility for discounts for these individuals and to prevent unauthorized persons from using these discounts.
3.2.4. OTHER DATA PROCESSING
If the Data Controller wishes to perform further data processing, prior information will be provided about the essential circumstances of the data processing (legal basis and purpose, scope of data, duration).
3.3. TECHNICAL DATA
Greenhess Ltd. selects and operates IT tools during service provision to ensure that the processed data:
• are accessible to authorized persons (availability);
• authenticity and authentication of data processing is guaranteed (authenticity of data processing);
• immutability can be verified (data integrity);
• are protected against unauthorized access (data confidentiality).
Greenhess Ltd. protects data with appropriate measures against unauthorized access, alteration, transmission, disclosure, deletion or destruction, as well as accidental loss. The company maintains secrecy during processing: it protects information so that only authorized persons can access it, protects the accuracy and completeness of information and processing methods, ensures authorized users can access required information when needed, and provides related resources.
3.4. COOKIES
3.4.1 PURPOSE OF COOKIES
Cookies collect information about visitors and their devices; remember personalized settings which may be used so settings don’t have to be re-entered; facilitate website use; ensure quality user experience; and contribute to collecting certain visitor statistics.
For customized service, a small data packet called a cookie is placed on the user’s computer and may be read back on subsequent visits. If the browser sends back a previously saved cookie, the cookie provider can link the current visit with previous ones, but only regarding its own content.
Some cookies do not contain personally identifiable info; some contain a secret, randomly generated number stored by the user’s device to enable user identification.
3.4.2. STRICTLY NECESSARY, SESSION COOKIES
These cookies allow visitors to browse the www.greenhess.com website smoothly and use its functions and services. They last for the session and are deleted when the browser closes.
3.4.3. THIRD-PARTY COOKIES (ANALYTICS)
The www.greenhess.com website uses third-party cookies such as Google Analytics. Google Analytics collects information about how visitors use the website. The data is used to improve the site and user experience. These cookies remain on the user’s device until expiration or until deleted.
3.3.4. LEGAL BASIS FOR COOKIE PROCESSING
Cookie processing is based on the user’s consent pursuant to Article 6(1)(a) of the GDPR.
If you refuse cookie usage, some website functions may not be available or may malfunction.
More information about deleting cookies is available for popular browsers at:
• Firefox: Deleting cookies set by websites
• Chrome: Clear cache & cookies
• Safari: Manage cookies and website data in Safari on Mac
3.5. REGISTRATION
Registration enables access to certain functions and services at https://www.greenhess.com. By registering, the user consents to processing their registration data, primarily contact details (name, email and/or phone), during order processing as described in point 3.2.
Registration is voluntary and based on your consent, which you can withdraw anytime and request deletion of your personal data provided during registration. Registration data processing is based on GDPR Article 6(1)(a) (consent).
You can initiate deletion of your registration and related personal data through your User Account. The site will promptly process deletion and immediately stop processing the data from the deletion request date.
Purpose of registration data processing:
To identify users, communicate with them, identify user rights (services, discounts), track used services, tailor advertisements, enable convenience features, manage individual user requests, statistics, analyses, direct marketing and newsletters, enforce legitimate interests, and establish/fulfill contracts between user and data controller.
Users must provide truthful data during registration. The data controller reserves the right to delete registrations and cease processing if false or misleading data is provided.
3.6. NEWSLETTER DATA PROCESSING
The www.greenhess.com system regularly informs newsletter subscribers about news and available services. Content may differ based on data provided by users.
Newsletter subscription and thus consent to www.greenhess.com data processing is voluntary and revocable anytime via unsubscribe link. Newsletter data processing is based on GDPR Article 6(1)(a). Personal data collected for newsletters is kept until withdrawal. Email address and name are processed as personal data to send newsletters under the Electronic Commerce Act §6.
3.7. ANALYTICS DATA PROCESSING
Independent external providers (Google Analytics, Gemius) measure and audit traffic and other web analytics data. No personal data is transmitted to external providers; anonymized IP addresses are used.
3.8. IP ADDRESS PROCESSING
Like most websites, www.greenhess.com records logs including IP addresses as personal data for information security. Logs also contain browser type, timestamp, referrer, and exit page.
IP addresses of visitors/users are processed for information security, click fraud prevention, and abuse monitoring based on GDPR Article 6(1)(f) legitimate interest for 5 years. This includes sharing IP addresses with hosting providers for network security and with Google Ireland Limited for filtering robots, processed according to https://policies.google.com/privacy and /terms.
3.9. DATA PROCESSING OF DATA COLLECTED BY ADA P1 METER
Greenhess Ltd. collects and processes data via ADA P1 Meter and related online service to monitor customers' energy consumption. Purpose is to provide accurate and up-to-date consumption info and enable optimization.
Data processed:
• Energy consumption data: voltage, current, power, energy (Wh, kWh), other measured parameters.
• Device identifiers: ADA P1 Meter serial number, network identifier.
• Connection data: IP address (anonymized), device status, connection timestamps.
Purposes:
• Display real-time and historic consumption data to user.
• Provide energy efficiency analyses.
• Ensure operation of the ADA P1 Meter and related services.
Legal basis:
• Contract performance (GDPR 6(1)(b)): needed to provide ADA P1 Meter services.
• Legal obligation (GDPR 6(1)(c)): if laws mandate data retention or sharing.
• Consent (GDPR 6(1)(a)): for longer term storage and analytical use of consumption data.
Data storage & security:
• Data stored encrypted on ADA P1 Meter server.
• Only contracted users and Greenhess Ltd. access data.
• IPs and device IDs anonymized to prevent linking to personal data.
Data sharing:
• Data provided to user, third parties only with user consent or legal obligation.
• Data not sold to third parties.
Data deletion:
• Data can be deleted upon user request anytime.
• If inactive, data automatically deleted 12 months after last activity.
4. DATA PROCESSING AND TRANSFER
www.greenhess.com is committed to handling data processing internally where possible, minimizing contracted data processors. Agreements are made when involving processors and relevant info is provided here.
Data processors used for operating business:
Hosting:
Name: Greenhess Ltd.
Address: 4225 Debrecen, Monostorerdő Street 98.
Customer support: +36/305704986
Email: info@greenhess.com
Data accessed: Website content on www.greenhess.com domain, emails sent to domain-based email addresses.
Google Analytics:
Google Inc., Mountain View, California, USA
Data accessed: anonymized, non-personal IP addresses of visitors.
Your personal data is stored on servers located within the EEA (EU, Iceland, Norway, Liechtenstein) operated by www.greenhess.com or entrusted processor.
If international data transfer occurs, you will be informed and explicit consent requested if needed.
4.1. TRANSFER OF PERSONAL DATA TO AUTHORITIES
Upon official or court request with clear legal basis per GDPR Article 6(1)(c), personal data stored at www.greenhess.com may be disclosed. Only data strictly necessary to fulfill the request are shared. Prior to disclosure, compliance with all conditions is verified.
5. DATA SECURITY
The IT tools used by www.greenhess.com are selected and operated to ensure:
• availability to authorized persons;
• authenticity and authentication;
• verifiable immutability;
• protection against unauthorized access.
www.greenhess.com implements technical, organizational, and procedural measures providing a suitable protection level tailored to risks, ensuring confidentiality, integrity, and availability.
The IT system and network are protected against fraud, espionage, vandalism, fire, flood, viruses, intrusions, and denial-of-service attacks with server- and application-level safeguards.
In case of data privacy incidents, www.greenhess.com takes all GDPR-mandated actions and cooperates with users.
6. RIGHTS OF THE DATA SUBJECT AND POSSIBILITIES TO ENFORCE THEM
Data subjects may request information on their personal data processing and may request correction, deletion (except mandatory processing), withdrawal of consent, data portability, and objection following instructions and contact info above.
6.1 RIGHT TO INFORMATION
Data controller takes measures to provide all required info per GDPR Articles 13,14 and 15-22, 34 in clear, concise, transparent, understandable, and accessible form.
6.2 RIGHT OF ACCESS
Data subject is entitled to confirmation of whether personal data is being processed and, if so, to access:
• purposes of processing;
• categories of personal data;
• recipients or recipient categories including third country recipients and international organizations;
• planned storage period;
• rights to rectification, erasure, restriction and objection;
• right to lodge complaint with supervisory authority;
• source information;
• existence of automated decision-making, profiling, logic and consequences.
Response is provided within one month.
6.3 RIGHT TO RECTIFICATION
Data subject may request correction of inaccurate data and completion of incomplete data.
6.4 RIGHT TO ERASURE
Data subject may request deletion without undue delay if:
- data no longer necessary for processing purposes;
- consent withdrawn and no other legal basis for processing;
- objection to processing and no overriding legitimate grounds;
- unlawful processing;
- legal obligation mandates deletion;
- data collected related to info society services.
Deletion cannot be requested if processing is necessary for:
- freedom of expression and information;
- compliance with legal obligations or public interest tasks;
- public health, archiving, research, statistics;
- legal claims.
6.5 RIGHT TO RESTRICTION OF PROCESSING
Restriction applied upon data subject’s request if:
- accuracy contested, pending verification;
- processing unlawful and opposing deletion requests restriction instead;
- controller no longer needs data but data subject requires it for legal claims;
- objection to processing pending priority assessment.
Restricted data may only be processed with consent or for legal claims or public interest.
6.6 RIGHT TO DATA PORTABILITY
Data subject can receive personal data provided to controller in structured, commonly used, machine-readable format and transfer to another controller.
6.7 RIGHT TO OBJECT
Data subject may object anytime for reasons related to their situation to processing based on public interest or legitimate interests, including profiling. Processing must stop unless compelling legitimate grounds prevail or for legal claims.
6.8 AUTOMATED DECISION-MAKING INCLUDING PROFILING
Data subject has right not to be subject to decisions based solely on automated processing with legal or significant effects.
6.9 RIGHT TO WITHDRAW CONSENT
Consent can be withdrawn anytime.
6.10 RIGHT TO APPEAL TO COURT
If rights are violated, data subject may file suit, which will be handled with priority.
Data protection authority complaints can be filed with:
Name: National Authority for Data Protection and Freedom of Information Address: 1125 Budapest, Szilágyi Erzsébet fasor 22/C, Mailing address: 1530 Budapest, Pf. 5 Phone: 0613911400 Fax: 0613911410 Email: ugyfelszolgalat@naih.hu Website: http://www.naih.hu
7. OTHER PROVISIONS
Unlisted data processing is notified at data collection. Clients are informed that courts, prosecutors, investigative authorities, administrative authorities, the National Authority, Hungarian National Bank, or other authorized bodies may request information, data transmission, or documents. Data is provided only to the extent and for the specified purpose.
Modification of this policy is authorized by the data controller's executive.
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