OUR PRIVACY POLICY IN A NUTSHELL

1. WHO WE ARE? We are NINI MOLNAR KORLÁTOLT FELELŐSSÉGŰ TÁRSASÁG and we process your personal data as data controller. This means that we are responsible for processing and protecting your data according to the applicable regulation.

2. WHAT IS PERSONAL DATA? To be really specific: under the GDPR “personal data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

3. HOW DO WE COLLECT YOUR DATA? We collect your personal data when you register to our website or provide us with your contacts in our shop, when you sign up for our newsletter, when you respond to a survey or any marketing communications, when you make a purchase online or simply surf the website.

4. WHAT PURPOSES DO WE USE YOUR DATA FOR? We will use your data (collected either online or in person) among other purposes, to manage your registration as a user, to process and fulfil your order, to respond to your inquiries, and, if you wish, to send you our customised communications, including marketing materials regarding our store, our new products and any other relevant updates concerning our brand.

5. LEGAL BASIS OF DATA PROCESSING. Our legal basis to process your data may stem from various reasons. Among others, most importantly, we need to process your data to be able to perform the contract concluded between you and us, if you register and make a purchase, or if you enjoy any of our services or functionalities, although there are some other considerations to process your date, such as our interest to be able to respond to and handle your inquiries, or if you have provided us your consent to do so (especially in case of sending out our newsletter to you).

6. SHARING YOUR PERSONAL DATA. We share your data with third-party service providers residing within the European Union, with whom we reached an agreement to provide us with assistance or support.

7. YOUR RIGHTS. You have the right to access, rectify or delete your personal data. In certain cases, you are also entitled to other rights, such as, for example, to object to us using your data, or to their portability, as explained in depth below.

If you want to know more, we encourage you to read through our full Privacy Policy below, containing every relevant aspect about how we process and use your personal data and your relating rights. 

*******

 

PRIVACY POLICY

1. Our Privacy Policy
    1.1.  This document will explain how we use your personal data in compliance with the 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 (“GDPR”) and with Hungary’s Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information(hereinafter the “Privacy Act”)
    1.2.  In this Privacy Policy, you will find all relevant information applicable to our use of the personal data of our users (“Users”), regardless whether you interact with us online or personally in our shop.

    1.3.  We undertake that during the data processing procedure, we will be fully transparent and inform you what we do with your personal data, because it is really important for us that you understand the implications of the way in which we use your data, and the rights you are entitled to in relation to your data. To this end;

    (i)  we make available for you on our website this Privacy Policy containing all relevant information regarding the use of your data and your rights in connection therewith, to allow you to check when you consider appropriate, and

    (ii)  upon your request we will provide you with further information on each processing operation of your data.

    2. Who We Are?

    2.1.  If you interact with our website or if you provide us your personal data in our brick and mortar shop, Nini Molnar Korlátolt Felelősségű Társaság (seat: HU-1056 Budapest, Váci utca 71. 1. em. 1C.; company registration No.: 01-09-298468) (“We”) will act as the data controller of your data.

     2.2.  As data controllers we are entitled to determine how and for what purpose the personal data provided to us is processed. However, as you know with power there comes responsibility, consequently as data controllers we are responsible for implementing appropriate technical and organisational measures to ensure that your personal data is processes in accordance with the GDPR. 

    3. WHAT IS PERSONAL DATA AND HOW DO WE COLLECT IT?

    3.1.  GDPR defines “personal data” as any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

    3.2.  We collect your personal data when you register to our website or provide us with your contacts in our shop, when you sign up for our newsletter, when you respond to a survey or any marketing communications, when you make a purchase online or simply surf the website.

    3.3.  When we ask you to fill in your personal data before accessing to any functionality or service of our website, we always mark certain fields as compulsory. Without these data we would not be able to provide you with the required service or to afford you access to the functionality in question (e.g. if you don’t provide us with your address, we can’t organize the shipment of the purchased items thereo). Please take into account that, if you decide not to make such data available to us, you may be unable to complete your user registration or may not be able to enjoy those services or functionalities.

    4. WHAT PURPOSES DO WE USE YOUR DATA FOR?

    4.1.  Depending on the purpose for which we process your data we collect and use different kind of personal data. The personal data that we collect belongs to one of the following categories:

    (i)  personal data concerning your identity (e.g. your name, language, your contacts; etc.);

    (ii)  personal data concerning your transactions (e.g. your payments, card, information on your purchases, orders, returns, etc.);

    (iii)  personal data concerning your connection, geolocation and/or browsing data (e.g. your IP address, your location etc.);

    (iv)  commercial information about you (e.g. if you have subscribed to our newsletter),

    (v)  information about your tastes and preferences based on your browsing history on our site.

    4.2.  We collect and use your personal data for the following purposes indicated in first column of the below:

     

    PURPOSE

     

    DATA TYPE

    DESCRIPTION

    1. To manage your registration as user on the website

    Personal data concerning your identity:

    • name;
    • address;
    • e-mail;
    • phone number;
    • billing address.

    If you decide to become a registered user of our website, we need to process and store your data to identify you as a user and grant you access to its various functionalities, products and services.

     

     

    2. To perform the purchase contract that you concluded with us through the website

    Personal data concerning your identity:

    • name;
    • email;
    • address/billing address.

     

    Personal data concerning your transactions:

    • your payments;
    • credit/debit card details;
    • information on your purchases;
    • information on your returns;
    • order details.

     

    Personal data concerning your connection, geolocation and/or browsing data:

    • IP address;
    • geolocation.

    This purpose includes processing your data, mainly:

    • To contact you for updates/notices related to the contracted functionalities, products or services, including delivery notices and quality surveys to get a clear picture of your user experience;
    • To manage and facilitate the payment of the products that you purchase, regardless of the payment procedure used (e.g. to save your credit/debit card details upon your request to accelerate the future payment process);
    • To control and prevent potential fraud against you and against us during the purchase process (e.g. if someone tries to buy something from your account accessed from an unusual geolocation through our website);
    • To send you the invoices of your purchases you have made through our website;
    • To ensure that you are able to use other available functionalities or services.

     

    3. To contact you in case any question would arise in connection with your order, the ordered products, the delivery or the return.

    Personal data concerning your identity:

    • name;
    • email;
    • phone number;
    • address/billing address.

     

    Personal data concerning your transactions:

    • your payments;
    • credit/debit card details;
    • information on your purchases;
    • information on your returns;
    • order details.

     

    Should you have any concerns regarding your order or its return, our customer service is happy to assist you, however without your personal data we would not be able to get in contact with you and to meet your requests.

     

    For this purpose we restrain our data processing to the strictly necessary personal data.

     

    4. To send you newsletters, offers tailored to your interests and needs and other marketing materials

    Personal data concerning your identity:

    • name;
    • date of birth;
    • email;
    • address/billing address.

     

    Information about your tastes and preferences based on your browsing history on our site:

    • browsing history and behaviour on our website;
    • your purchase history.

    If you subscribe to our newsletter, we will process your personal data to manage your subscription and to send you customised information on our products or services via email.

     

    Furthermore, please consider that to be able to send you customized marketing materials, as part of the data processing we need to analyse your profile and browsing/purchase history to determine your preferences to understand which products and services fits your style best and send you relevant materials accordingly.  

     

    Remember that you can always unsubscribe from our newsletter at any time by sending us an email to shop@ninimolnar.com or clicking on the “unsubscribe” button on the bottom of our newsletter.

     

     

    5. To perform promotional actions (for example, to organize competitions).

    Personal information provided to us as part of the promotional action.

    On participating in any promotional action, you authorise us to process the personal data that you have shared with us depending on the promotional action and disclose them through different media such as social networks or the website itself.

     

    If we organize a promotional action, we will always make available the terms and conditions to inform you about the extent and the rule of our data processing activity related your personal data provided to us.

     

     

    6. To analyse the usability and

    quality of our website

     

    Browsing data

    If you access our website, we will process your browsing data for analytic and statistic purposes, i.e., to understand the manner in which users interact with our website and to be able to introduce improvements.

     

    In addition, we occasionally perform unanimous quality surveys and actions to know the degree of satisfaction of our customers and users and detect those areas in which we may improve.

     

     

    5. LEGAL BASIS OF DATA PROCESSING

      Pursuant to the applicable regulation, no personal data shall be processed without valid legal basis. The legal basis of our data processing depends on the purpose for which the given personal data is processed.

      We summarize the legal basis of our data processing in the following table.

      PURPOSE

      LEGAL BASIS

      1. To manage your registration as user on the website

      We process your related personal data upon your consent provided by you by accepting our Privacy Policy at registration process and because it is necessary for the performance of our contract or for taking steps at your request prior to entering into the contract.

       

      2. To perform the purchase contract that you concluded with us through the website

      We process your related personal data because consider it is necessary for the performance of our contract or for taking steps at your request prior to entering into the contract.      

       

      Certain processing of data related to the purchase process is activated only because you request or authorise it, as is the case of the storage of payment (card) data for future purchases. In these cases, our processing of your data is supported by your own consent.

       

      We consider that we have a lawful interest to carry

      out the necessary verifications to detect and prevent potential fraud when you make a purchase. We understand that the processing of these data is

      positive for all the participating parties when a

      purchase is paid and in particular for you, since this

      allows us to establish measures to protect you from

      fraud attempts by third parties.

       

       

      3. To contact you in case any question would arise in connection with your order, the ordered products, the delivery or the return.

      We consider that we have lawful interest in answering your questions concerning your order.

       

      Furthermore, the processing of these data for this purpose is also beneficial to you to the extent that it enables us to assist you adequately and answer your questions. Consequently, when you contact us – especially in connection with incidents related to your order or the product/service acquired through the website – the processing of your data is necessary to fulfil the purchase contract.

       

      When the issue is related to the exercise of your rights over your personal data or to claims on our products or services, we are legally permitted to process your data for compliance with our legal obligations.

       

      4. To send you newsletters, offers tailored to your interests and needs and other marketing materials

      We process your related personal data upon your consent provided by you by accepting to receive marketing materials and customized information through our website or personally. 

       

      In order to send you customised information, we consider that we have a lawful interest to conduct a

      profiling with the information that we have about you (such as your browsing, preferences or purchase history) and the personal data that you have provided us, such as the age range or language, since we understand that the data processing of these data is also beneficial to you because it allows you to improve your user experience and access the information in accordance with your preferences.

       

      5. To perform promotional actions (e.g. to organize competitions).

      We process your related personal data upon your consent provided by you by accepting to receive marketing materials and customized information through our website or personally. 

       

      6. To analyse the usability and quality of our website

       

      We consider that we have a lawful interest in analysing the website’s usability and the user's satisfaction degree, because we understand that that the processing of these data is also beneficial for you because the purpose is to improve the user

      experience and provide a higher quality service.

       

       

      6. HOW LONG WILL WE KEEP YOUR DATA?

        In general, we process your personal data for the time required for the purposes set out in this Privacy Policy or for the period specified by the relevant regulations. Consequently, the time for which we store your data depends on the purposes for which we process the data (and partially the legal basis of the data processing), as summarized in the below table:

        PURPOSE

        TIME OF DATA PROCESSING

        1. To manage your registration as user on the website

        We will process your data as long as you remain a registered user, until you decide to delete your account. .

                                                                          

        2. To perform the purchase contract that you concluded with us through the website

        We will process your data for the time required for the completion of the purchase contract, including potential returns, complaint period or as long as claims related to the purchase of the product in question exist.

         

        If we process your data for this purpose on the basis of your consent (e.g. the details of your credit/debit card), we will process your data up to the point of the withdrawal of your consent or the deletion of your account.

         

         

        3. To contact you in case any question would arise in connection with your order, the ordered products, the delivery or the return.

        We will process your data for the time strictly necessary to meet your request or application, but at least until the expiry of the return and warranty period.

        4. To send you newsletters, offers tailored to your interests and needs and other marketing materials

        We will process your data until you unsubscribe or

        cancel your subscription to the newsletter or until you otherwise withdraw your consent.

         

        5. To perform promotional actions (e.g. to organize competitions).

        If it is not determined differently in the specific privacy policy of the respective promotional action, then if you participate in promotional actions, we will keep the data for a six (6) months period reckoned from the last day of the promotional action.

         

        6. To analyse the usability and quality of our website

         

        We will process your data occasionally for the time during which we proceed to carry out a specific quality action or survey or until we anonymise your browsing data.

         

         

        Further to the above, please note that although we only process your data for the time strictly necessary to fulfil the respective purpose, thereafter – to serve our lawful interests - we will keep the personal data duly stored and protected in compliance with the legislation in force for the time being until our data processing-related liability may arise. Once the deadline of each potential actions expires, we will duly delete your personal data.

        7. SHARING YOUR PERSONAL DATA

        In the course of our operation to be able to provide you with our services we may utilise the services of third-party service providers, who may act as data processors in relation to your personal data, in order to handle and process your personal data for specific purposes, on our behalf and according to our instructions.

        The third-party service providers - who provide us with support in the services that we offer you - are:

        (i)  Logistic, transport and delivery partners and service providers to deliver the product that you purchased on our website;

        (ii)  Payment service providers and other financial institutions to process the payments you initiated on our website;

        (iii)  Email service provider platform, in order to facilitate communication with you after purchase and to send you marketing materials and promotional actions;

        (iv)  Technological service providers;

        (v)  Other third-party service providers involved by us for data processing.

        Our data processors shall process the personal data pursuant to the data processing agreement concluded between our company and the data processor, or until they are required to keep your data under the applicable data retention laws.  The data processor is not allowed to engage another data processor without our prior specific or general written authorisation.

        8. YOUR RIGHTS

        First of all, to ensure your rights to your personal data we undertake to keep your personal data confidential and throughout the data processing we will assist you in exercising your rights.

        If you have any data protection related questions, or if you wish to exercise your rights or file a complaint, please contact us at shop@ninimolnar.com. If we consider this necessary to be able to identify you, we may request you to provide a copy of a document evidencing your identity.

        Pursuant to the applicable regulation, regardless of the purpose or legal basis of the data processing, you have the following data processing-related rights: 

        1. Right to information

        You have right to information concerning the processing of your personal data, therefore you are entitled to request information from us about how we handle your personal data and what are your rights in this regard. 

        1. Right of Access

        You may request us any time to provide you with access to the data we have available on you.

        1. Right to rectification

        You are entitled to request us to rectify without undue delay your inaccurate personal data that we have available on you, furthermore considering the purposes of the processing, you have the right to have your incomplete personal data completed, including by means of providing a supplementary statement. 

        Further to that, please note that as a registered user you are responsible for providing your true and correct personal data. If your user information is not correct or outdated then shall access the relevant personal data section of your account and change or update your personal data through our website.

        1. Right to erasure (“right to be forgotten”)

        You may request to erase your personal data and upon your request we shall erase personal data without undue delay, if the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

        1. Right to restriction of processing

        You have the right to demand the restriction of the processing of your personal data, if:

        (i)  you have contested the accuracy of your personal data, then for a period enabling the us to verify the accuracy of the personal data;

        (ii)  the processing is unlawful, but you oppose to the erasure of your personal data and request the restriction thereof instead;

        (iii)  we no longer need your personal data for the purposes of the processing, but you request them to establish, exercise or defend legal claims; or if

        (iv)  you have exercised your right to object to the data processing, until the verification whether our legitimate grounds of the override yours.

        If the processing of your personal is restricted then such personal data shall, with the exception of storage, only be processed with the your explicit consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State. 

        1. Right to withdraw consent

        If we process your personal data based on your consent, then you also have the right to withdraw such consent at any time.

        1. Right to data portability

        Provided that we process your data based on your consent or based on its necessity for the performance of the contract or if the data processing is procured through automated means, then you have the right to request and receive your personal data that you made available to us in a structured, commonly used and machine-legible format, to be able to transmit them to another data controller.

        1. Right to object

        If the processing of your data is based on our lawful interest, you will also have the right to object to the processing of your data.

        1. Automated decision-making and profiling rights

        You are entitled to request that we do not apply any such decisions to you that is based solely on automated processing (including profiling), if such decision would have legal or other significant consequences for you.

        Finally, we inform you that you have the right to file a claim before the Hungarian Data Protection and Freedom of Information Authority (address: H-1125 Budapest, Szilágyi Erzsébet fasor 22/C.; email: ugyfélszolgalat@naih.hu; website: http://naih.hu/) the responsible data protection regulatory authority.

        9. HOW DO WE PROTECT YOUR PERSONAL DATA?

        Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the personal data confidential.

        To ensure the safety of our website, from time to time we scan the website for security holes and other vulnerabilities. We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal data.

        10. CHANGES TO THE PRIVACY POLICY

        We may amend the information contained in this Privacy Policy when we consider this appropriate. Should we do so, we will notify you by various procedures through the Platform (for example, through a banner or a pop-up), or we may even send you a notice to your e-mail address when the change in question is relevant to your privacy, for you to be able to review the changes, assess them and, as the case may be, object or unsubscribe from ay service or functionality.

        In any case, we suggest you to review this Privacy Policy from time to time in case minor changes are made or we make any interactive improvement, taking the opportunity that you will always find it as a permanent point of information on our website.

        If we wish to use your personal data for a new purpose, not covered by this document, we will provide you with a new Privacy Policy, explaining all detail to the new processing. If required, we will seek your consent before commencing the new data processing activity. 

        11. INFORMATION ON COOKIES

        We use cookies and similar devices to facilitate your browsing on the website and to understand how you interact with us and to be able to show you advertisements in accordance with your browsing habit.

        Please read our Cookies Policy to understand with greater detail the cookies and similar devices that we use, their purpose and other information of interest.