Privacy Policy

GREENHESS LIMITED LIABILITY COMPANY

EFFECTIVE DATE: JANUARY 1, 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.

Undertakes 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, including in particular:

• Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR)

• Act CXII of 2011 on informational self-determination and freedom of information (Info tv.)

• Act V of 2013 on the Civil Code (Ptk.)

• Act CVIII of 2001 on electronic commerce services and certain services related to the information society (Eker tv.)

This privacy policy applies to the following domain:

• www.okosvillanyora.hu

Data protection policies arising from the data controller's processing activities are continuously available at www.okosvillanyora.hu/gdpr.php.

The data controller reserves the right to modify this policy at any time. Data subjects will be informed in a timely manner about changes.

If you have any questions regarding this notice, please send us your inquiry and we will answer your questions.

The data controller is committed to protecting the personal data of its clients and partners and attaches great importance to respecting their informational self-determination rights. The data controller handles personal data confidentially and takes all security, technical and organizational measures that guarantee the security of the data.

The data controller presents its data processing practices as follows.

2. DATA CONTROLLER'S DETAILS

If you wish to contact us regarding the processing of your personal data, you can reach us at info@okosvillanyora.hu and 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

E-mail: info@okosvillanyora.hu

2.1 DATA PROTECTION OFFICER

The data controller does not perform activities that would require the designation 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, e-mail address, home address, and for companies: company name, contact details, registered office, company registration number, tax number, bank account number. These data are needed for identifying the customer for the service and communication.

3.2. PERSONAL DATA PROCESSED IN RELATION TO ORDER FULFILLMENT AND CONTRACTING

Several data processing cases may occur for contract conclusion and fulfillment. Please note that complaint handling and warranty data processing only takes place if you exercise any related rights.

Details of data processing regarding contract conclusion and fulfillment:

3.2.1. PERSONAL DATA PROCESSED IN RELATION TO INVOICING AND BILL ISSUANCE

The data processing is carried out to issue invoices in compliance with the law and to fulfill accounting record retention obligations. According to Section 169 (1)-(2) of the Accounting Act, companies must preserve accounting documents supporting accounting directly and indirectly.

Processed data:

Name, address, e-mail address, phone number.

Data retention period

Issued invoices must be kept for 8 years from the date of issue according to Section 169 (2) of the Accounting Act.

Legal basis for processing

According to Section 159 (1) of Act CXXVII of 2007 on Value Added Tax, issuing an invoice is mandatory, and it must be preserved for 8 years according to Section 169 (2) of Act C of 2000 on Accounting [Regulation Article 6 (1) c)].

3.2.2. DATA PROCESSORS HANDLING PERSONAL DATA RELATED TO PRODUCT DELIVERY

3.2.2.1.

Recipient name: GLS General Logistics Systems Hungary Package Logistics Ltd.

Recipient registered office: 2351 Alsónémedi, GLS Europe St. 2.

Recipient phone number: 06-29-88-67-00

Recipient e-mail: info@gls-hungary.com

Recipient website: https://gls-group.eu/HU/hu/home

The courier service cooperates in the delivery of ordered goods based on a contract with the data controller. The courier handles the received personal data according to its privacy policy available on its website.

3.2.2.2.

Recipient name: Hungarian Post Closed Corporation (Magyar Posta Zártkörűen Működő Részvénytársaság)

Recipient registered office: 1138 Budapest, Dunavirág street 2-6.

Recipient phone number: +36-1/767-8200

Recipient e-mail: ugyfelszolgalat@posta.hu

Recipient website: posta.hu

3.2.3. PERSONAL DATA PROCESSED FOR SENIOR CITIZENS TO CLAIM DISCOUNTS

Personal data shared when contacting Greenhess Ltd. necessary for providing discounts available to pensioners, such as documents issued or validated by pension payment or entitlement establishing authorities, including name of eligible person, personal identification data, document references, and other identifiers on the document.

These data are needed to verify eligibility for the discounts and to prevent unauthorized persons from using them.

3.2.4. OTHER DATA PROCESSING

If the data controller intends to carry out additional processing, prior information will be provided about essential circumstances of the processing (legal basis, purpose, data scope, duration).

3.3. TECHNICAL DATA

Greenhess Ltd. selects and operates IT equipment for personal data processing in such a way that the data handled are:

• accessible to authorized persons;

• authentic and verifiable (authenticity of processing);

• verifiable for unaltered status (data integrity);

• protected against unauthorized access (data confidentiality).

Greenhess Ltd. protects data by appropriate measures against unauthorized access, alteration, transmission, disclosure, deletion or destruction, and accidental loss. It maintains confidentiality: protecting information access only for authorized persons; ensures accuracy and completeness of data and processing methods; ensures availability of information and related tools when needed by authorized users.

3.4. COOKIES

3.4.1 PURPOSE OF COOKIES

Cookies collect information about visitors and their devices; remember individual visitor settings, facilitating website use; provide a quality user experience, and participate in some visitor statistics data collection.

To provide customized service, a small data file called cookie is placed on the user’s device and accessed on subsequent visits. Returning cookies allow the service provider to link current visit with previous ones, but only within its own content.

Some cookies do not contain personally identifiable information, while others include a secret randomly generated number stored on the user device which ensures user identification.

3.4.2 ESSENTIAL SESSION COOKIES

These cookies ensure visitors can browse the website smoothly, use its functions and services. Their validity lasts for the session until browser closing, automatically deleting this type of cookies from device or browser.

3.4.3 THIRD-PARTY COOKIES (ANALYTICS)

www.okosvillanyora.hu uses Google Analytics as third-party cookies. Google Analytics collects information about how visitors use the site, used for site development and user experience improvement. These cookies remain on the visitor’s device or browser until expiration or until visitor deletes them.

3.4.4 LEGAL BASIS FOR COOKIE PROCESSING

The legal basis for cookie processing is the website visitor’s consent according to Regulation Article 6 (1) a).

If you do not accept cookies, certain website functions may be unavailable or may function improperly during use.

For instructions on cookie deletion in common browsers, please see:

• Firefox: Deleting cookies stored by websites

• Chrome: Clear cache & cookies

• Safari: Manage cookies and website data in Safari on Mac

3.5 REGISTRATION

Registration enables access to certain features and services on https://www.okosvillanyora.hu. By registering, the user consents that the contact information (name, e-mail and/or phone) provided during registration will be processed by the data controller during order processing as described in section 3.2.

Registration is voluntary and based on your consent, which you may withdraw at any time. You may request deletion of personal data provided during registration at http://www.okosvillanyora.hu. Data processing related to registration is based on GDPR Article 6 (1) a) (consent).

Account deletion and associated personal data removal can be initiated in the User Account. The website will immediately comply with deletion and cease further processing from the date of request.

Purpose of data processing related to registration:

Ensuring user identifiability, communication, identification of user rights and entitlements (services, discounts), recording user service usage, assisting advertising personalization, enabling convenience functions, handling individual user requests, preparing statistics and analyses, facilitating direct business and marketing communications, sending newsletters, enforcing data controller’s legitimate interests, creating and fulfilling contracts between controller and user.

Users must provide truthful data during registration. The data controller reserves the right to immediately delete registration and cease data processing if false or misleading data are supplied.

3.6 NEWSLETTER DATA PROCESSING

The www.okosvillanyora.hu regularly informs subscribers about news and services via newsletter. The content may vary based on user-provided data.

Newsletter subscription and consent for www.okosvillanyora.hu data processing are voluntary; consent can be withdrawn anytime via unsubscribe link in the newsletter. Newsletter data processing is based on GDPR Article 6 (1) a) (consent). Personal data collected (email, name) are processed until withdrawal. Name processing is prescribed by Act Grt. Section 6.

3.7 ANALYTICAL DATA PROCESSING

The independent measurement and audit of www.okosvillanyora.hu visits and other web analytics are performed by third-party providers (Google Analytics, Gemius). No personal data is provided to third parties; anonymized IP addresses are recorded.

3.8 IP ADDRESS PROCESSING

Like most websites, www.okosvillanyora.hu uses logs for information security, containing IP addresses as personal data. Logs also include browser type, date/time, referring and exit URLs. IP addresses are processed for information security purposes, to monitor click fraud, based on GDPR Article 6 (1) f) for 5 years. Data may be shared with hosting providers and Google Ireland Limited for security and bot filtering, managed by https://policies.google.com/privacy and https://policies.google.com/terms.

3.9 DATA PROCESSING OF ADA P1 METER COLLECTED DATA

Greenhess Ltd. collects and processes data via the ADA P1 Meter device and related online services to monitor customers’ energy consumption, providing accurate and up-to-date consumption information and enabling optimization.

Data categories:

• Energy consumption data: voltage, current, power, energy consumption (Wh, kWh), other measured parameters.

• Device identifiers: ADA P1 Meter serial number, network identifier.

• Connection data: IP address (anonymized), device status, connection times.

Purpose of processing:

• Display real-time and historical energy data to users.

• Provide energy efficiency analyses.

• Ensure ADA P1 Meter operation and related services.

Legal basis for processing:

• Contract performance (GDPR Article 6 (1) b): processing data necessary to provide ADA P1 Meter services.

• Legal obligation (GDPR Article 6 (1) c): if data retention or authority disclosures are legally required.

• Consent (GDPR Article 6 (1) a): for long-term data storage and analysis.

Data storage and security:

• Data stored encrypted on ADA P1 Meter servers.

• Access restricted to contracted users and Greenhess Ltd.

• IPs and device identifiers are anonymized to prevent linkage with personal data.

Data sharing:

• Data made available only to users; third-party transfers only with user consent or by law.

• No sale of ADA P1 Meter data to third parties.

Data deletion:

• User may request data deletion anytime.

• Data are automatically deleted after 12 months of inactivity.

4. DATA PROCESSING AND DATA TRANSFER

www.okosvillanyora.hu is committed to managing data processing itself and minimizing the number of contracted partners as processors. Processor involvement is based on contract and provided information.

Data processors used by the data controller for its business activities include:

Hosting service:

Name: Greenhess Ltd.

Address: 4225 Debrecen, Monostorerdő Street 98.

Customer service: +36/14900405

E-mail: info@greenhess.com

Data covered: www.okosvillanyora.hu web content and email received on domain-based email addresses.

Google Analytics:

Google Inc., Mountain View, California, USA

Data covered: anonymized IP addresses of www.okosvillanyora.hu visitors.

Your personal data are stored exclusively on servers located within the EEA (European Economic Area) - EU countries, Iceland, Norway, Liechtenstein. Data are stored on the website's own and its processors’ servers.

If international data transfer occurs, you will be informed and explicit consent requested if necessary.

4.1 PERSONAL DATA TRANSFER TO AUTHORITIES

In case of an official or court inquiry, if the legal basis for data transfer is specified, personal data stored at www.okosvillanyora.hu will be shared as per GDPR Article 6 (1) c). Data transferred will be limited to what is strictly necessary for the purpose. Prior to transfer, www.okosvillanyora.hu verifies compliance with requirements.

5. DATA SECURITY

The IT tools used are selected and operated ensuring that:

• authorized persons have access;

• authenticity of processing is ensured;

• data integrity (unchanged status) is verifiable;

• protection against unauthorized access (confidentiality) is maintained.

The website employs technical, organizational measures providing appropriate protection against risks related to personal data storage, maintaining confidentiality, integrity, and availability.

The IT system is protected against computer-aided fraud, espionage, sabotage, vandalism, fire, flood, viruses, intrusions, and denial of service attacks. Protection is ensured at server and application levels.

In case of data protection incidents, www.okosvillanyora.hu will take all GDPR-mandated measures and cooperate with users.

6. DATA SUBJECT RIGHTS AND ENFORCEMENT

Data subjects may request information about their personal data processing, request correction, deletion or withdrawal of consent, exercise data portability and objection rights, using contact methods listed.

6.1 RIGHT TO INFORMATION

The data controller takes measures to provide data subjects with all required information under GDPR Articles 13, 14, 15-22, and 34 in a concise, transparent, understandable and easily accessible form.

6.2 RIGHT TO ACCESS

Data subjects have the right to obtain confirmation about processing of their data and access to their personal data and related information including:

• purposes of processing;

• categories of personal data;

• recipients or categories of recipients;

• planned data retention period;

• rights related to rectification, deletion, restriction and objection;

• right to lodge complaint with supervisory authority;

• source of data;

• existence of automated decision-making including profiling and meaningful information about logic, significance, and consequences;

The controller provides such information within four months of request.

6.3 RIGHT TO RECTIFICATION

Data subjects may request correction of inaccurate and completion of incomplete personal data.

6.4 RIGHT TO ERASURE

Data subjects have the right to request deletion without undue delay for reasons including:

- Data no longer necessary for purposes collected;

- Consent withdrawn and no other legal basis;

- Objection to processing where no overriding legitimate grounds;

- Unlawful processing;

- Legal obligation to erase applies;

- Data collected in relation to information society services to children.

However, erasure is not allowed if processing is necessary:

- For freedom of expression and information rights;

- To comply with legal obligations;

- For public interest tasks or exercise of official authority;

- For public health, archival, research or statistical purposes;

- For legal claims.

6.5 RIGHT TO RESTRICTION OF PROCESSING

Data subjects may request restriction when:

- Accuracy is contested and verification ongoing;

- Processing is unlawful and deletion is opposed, restriction requested instead;

- Controller no longer needs data but required by data subject for claims;

- Objection to processing pending assessment whether legitimate grounds prevail.

Restricted data may only be processed with consent or for legal claims or protection of rights or important public interest.

6.6 RIGHT TO DATA PORTABILITY

Data subjects have the right to receive their personal data in a structured, commonly used, machine-readable format and transmit them to another controller.

6.7 RIGHT TO OBJECT

Data subjects may object at any time for reasons related to their particular situation to processing based on public interest or legitimate interests, including profiling. Processing must cease unless compelling legitimate grounds prevail or for legal claims.

6.8 AUTOMATED INDIVIDUAL DECISION-MAKING, INCLUDING PROFILING

Data subjects have the right not to be subject to decisions based solely on automated processing including profiling, which have legal or similarly significant effects.

6.9 RIGHT TO WITHDRAW CONSENT

Data subjects may withdraw consent at any time.

6.10 RIGHT TO JUDICIAL REMEDY

Data subjects may bring a court action against the data controller for rights violations. Courts will act expeditiously.

Complaints may also be filed with the National Authority for Data Protection and Freedom of Information:

Name: National Authority for Data Protection and Freedom of Information

Address: 1125 Budapest, Szilágyi Erzsébet fasor 22/C, Mailing: 1530 Budapest, P.O.Box: 5

Phone: 0613911400 Fax: 0613911410

E-mail: ugyfelszolgalat@naih.hu Website: http://www.naih.hu

7. OTHER PROVISIONS

Data processing not explicitly listed here will be explained at time of data collection. Authorities such as courts, prosecutors, investigative bodies, administrative bodies, National Authority, Hungarian National Bank, or other authorized bodies may request information, data sharing, or document provision. The controller furnishes only necessary personal data as formally requested.

Privacy Policy

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