DATA MANAGEMENT INFORMATION
The present Privacy Policy provides information on how Smart Digital Ltd. as the data controller, handles and protects the information provided by the customer during the conclusion and performance of the service contract for the use of the electromobility service provided by the electric charging equipment.
Our company handles the personal data of its customers in accordance with the provisions of Act CXII of 2011 on the Right of Informational Self-Determination and Freedom of Information (hereinafter: "Info Act"), is committed to data protection and considers it extremely important to respect the right of informational self-determination of users.
Data processing means collecting, recording, recording, organisation, storing, using, and retrieving data for the purposes set out in this Privacy Policy.
1. The data controller is:
Smart Digital Kft. (registered office: 5350 Tiszafüred, Örvényi út 19.,
Company registration number: 16-09-016215, Tax number: 14523597-2-16).
Contact: emobility@smartdigital.eu, +361 4477581
2. Purpose of data processing
The primary purpose of data processing is to fulfil the contract and to ensure coordination and contact with customers, customer service, customer information, billing, complaint handling, billing and receivables management, RFID key provision, and enforcement of rights and obligations related to the contractual service. Other data processing purposes include evaluating and analysing our company's market, customers, products and services.
The Data Controller shall not use the personal data provided by the Data Subject in accordance with point 5 for any purpose other than that described in point 2.1. Unless otherwise provided by law, the disclosure of personal data to a third party or to a court or other authority shall be possible only on the basis of a relevant court or authority decision or on the basis of the Data Subject's prior explicit consent.
3. Legal basis for processing
The legal basis for data processing is, in addition to the consent of the data subjects, the performance of contracts and the data controller's legitimate interest.
4. Scope of the data processed
Personal data: any data that can be associated with a specific (identified or identifiable) natural person (the data subject), and any inference that can be drawn from the data concerning that data subject. Personal data retains this quality during processing as long as its link with the data subject can be re-established. In particular, a person may be regarded as identifiable where he or she can be identified, directly or indirectly, by reference to a name, an identification mark or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity.
Smart Digital Ltd. only processes data that is necessary for the purpose of the processing and is suitable for achieving the specified purpose. The data subjects provide the processed data to our company when registering on the website or using the services.
| Scope of data | Name of personal data processed |
|---|---|
| I. Registration details: | name, e-mail address, password, unique user identifier |
| II. Contact details: | name, e-mail address, telephone number |
| III. Billing data: | name, address, billing address, billing details, tax number |
| IV. Information required for online (credit card) payment: | credit card number, name on the credit card, expiry date of the credit card, CPV or CCV code of the credit card |
| V. Data required to request an RFID customer key: | name, delivery address, billing address |
| VI. Complaint handling data: | name, address, telephone number, transaction ID, place, time and manner of filing the complaint, a detailed description of the complaint, a list of documents and other evidence cited by the Customer (and the data contained therein), the time of recording the report and the unique identification number of the complaint, the identification of the charging equipment used, and the signature of the person who recorded the report |
| VII. Customer service | name, e-mail address, telephone number |
| VIII. Sound recording | a recording of the voice of the person concerned |
| IX. Data on charging: | filling data (location of the filling device, identification, amount of filling, time of filling) |
5. The person authorised to process the data
They are entitled to process data:
| Smart Digital Ltd. | H-5350 Tiszafüred, Örvényi út 19 | Phone number: +361 4477581 E-mail address: emobility@smartdigital.eu Postal address: 1097 Budapest, Illatos út 23. Website: <www.okostoltes.hu> | operation, maintenance, complaint handling, customer service | www.okostoltes.hu/adatvedelem |
|---|---|---|---|---|
| Smart Charging Ltd. | H-3200 Gyöngyös, Rigó utca 7. | Phone number: +36 30 774 0262 E-mail: info@smartcharging.hu Postal address: 3200 Gyöngyös, Rigó utca 7. Website: https://smartcharging.hu | application data processing for the purposes of the service | http://www.elektromotive.hu/hu/adatkezeles |
| Billingo Technologies Zrt. | 1133 Budapest, Árbóc utca 6., I. floor | Phone number: +36-1/500-9491 Email: hello@billingo.hu Postal address: 1133 Budapest, Árbóc utca 6. 1st floor Website: www.billingo.hu | Account management | https://smartcharging.hu/adatvedelem/ |
| OTP Mobil Kft.* | 1143 Budapest, Hungária krt. 17-19. | Phone +36 (1) 366-3311 E-mail: ugyfelszolgalat@simple.hu Postal address: 1143 Budapest, Hungária krt. 17-19. Website: www.simplepay.hu | Provision of SimlePay application payment service | https://www.billingo.hu/adatkezelesi-tajekoztato |
accountant: Nagy Könyv-L Tax Kft., 5350 Tiszafüred, Örvényi út 45/B, represented by Nándor Nagy, nandor.nagy.tf@gmail.com
By accepting this Policy, the User acknowledges that the following personal data stored in the user database of the mobile application managed by the Data Controller will be transferred to OTP Mobil Szolgáltató Korlátolt Felelősségű Társaság (1143 Budapest, Hungária körút 17-19.) as the data processor. The data controller transfers the following data: name, e-mail address, telephone number and billing data. The nature and purpose of the data processing activities carried out by the data processor can be found in the SimplePay Data Processing Information Notice at the following link: http://simplepay.hu/vasarlo-aff.
6. Transfers to other data controllers
In addition to the above, our company will only transfer data within limits set by law and only at the request of or pursuant to a request from a public authority or court or pursuant to a legal requirement and only to the extent required by the data request.
7. Duration of processing
The data processing is carried out until the withdrawal of the consent of the data subject, until the submission of the relevant request for erasure, or during the existence of the relevant legal relationship, and, if the Customer is in default of payment, until the settlement of the outstanding debt.
Smart Digital Ltd. may process the data without specific consent and even after the withdrawal of the Customer's consent for the purpose of complying with a legal obligation to which the Customer is subject or for the purposes of pursuing a legitimate interest pursued by our company or a third party, provided that such interests are proportionate to the restriction of the right to the protection of personal data.
8. Persons entitled to access the data
The following persons have access to the personal data processed by the controller:
Employees of Smart Digital Ltd. and any subcontractors. Our employees involved in data processing are bound by a confidentiality obligation with regard to the data they have access to.
9. Rights and remedies in relation to data processing
The Customer has the right to request information about processing his/her personal data and to request the rectification, erasure or blocking of his/her personal data. Upon request, our company shall provide information about the data processed by it or by a data processor it has appointed, their source, the purpose, legal basis and duration of the processing, the name and address of the data processor and its activities related to the processing, and, in the case of the transfer of the Customer's personal data, the legal basis and recipient of the transfer.
We shall provide the information referred to in this point in writing and in an intelligible form within the shortest possible time from the date of the request, but not later than 30 calendar days. The information shall be provided free of charge if the person requesting the information has not yet submitted a request for information to the controller for the same data set in the current year. In other cases, the fee amount shall be HUF 2.000,- per information. Smart Digital Ltd. may refuse to provide information to the data subject in the cases and in the manner provided for by law.
Smart Digital Ltd. will correct the personal data if the personal data is not accurate and the accurate personal data is available to us.
Smart Digital Kft. shall delete personal data, unless otherwise provided by law, if the processing of the data is unlawful; the data subject requests its deletion; the data is incomplete or inaccurate - and this situation cannot be lawfully remedied - provided that deletion is not excluded by law; the purpose of the processing has ceased or the statutory period for storing the data has expired; or the court or the National Authority for Data Protection and Freedom of Information has ordered it.
Instead of deletion, we block personal data if the data subject requests it or if, on the basis of the information available to us, we believe that deletion would harm the data subject's legitimate interests. Personal data blocked in this way may be processed only for as long as the processing purpose that precluded the deletion of personal data continues.
Smart Digital Ltd. will mark the personal data it processes if the data subject contests the accuracy or correctness of the personal data, but the inaccuracy or incorrectness of the contested personal data cannot be clearly established.
If our company does not comply with a data subject's request for rectification, blocking or erasure, we will provide the factual and legal grounds for refusing the request for rectification, blocking or erasure in writing or, with the data subject's consent, by electronic means within 25 days of receipt of the request. In case of refusal of a request for rectification, erasure or blocking, we will inform the data subject of the possibility of judicial remedy and of recourse to the National Authority for Data Protection and Freedom of Information.
The data subject may object to the processing of his or her personal data,
(a) where the processing or transfer of personal data is necessary for the fulfilment of a legal obligation to which the controller is subject or for the purposes of the legitimate interests pursued by the controller, the recipient or a third party, except in cases of mandatory processing;
(b) where the personal data are used or disclosed for direct marketing, public opinion polling or scientific research purposes; and
- in other cases provided by law.
Smart Digital Ltd. will examine the objection within the shortest possible time, but not later than 15 days from the submission of the request, decide on its validity, and inform the applicant in writing of its decision. If our company establishes the validity of the data subject's objection, it shall terminate the processing, including any further collection and transmission of data, block the data, and shall notify the objection and the action taken on the basis of the objection to all those to whom it has previously disclosed the personal data concerned by the objection and who are obliged to take measures to enforce the right to object. If the data subject does not agree with the decision of Smart Digital Ltd. taken in this way, or if Smart Digital Ltd. fails to comply with the time limit, the data subject may, within 30 days of the notification of the decision or the last day of the time limit, take the matter to court.
In the event of violating his/her rights, the data subject may take Smart Digital Ltd. to court. The court will rule on the case out of turn. The court has jurisdiction to hear the case. The lawsuit may also be brought before the court of the data subject's place of residence or domicile at the data subject's option.
In the cases specified in Article 21 of Act CXII of 2011 on the Right of Informational Self-Determination and Freedom of Information ("Infotv."), the person concerned may object to processing his or her personal data.
If Smart Digital Ltd., the accounting firm or the legal representative in the context of the data transfer violates the Customer's rights during data processing, the Customer may take legal action or initiate an investigation with the National Authority for Data Protection and Freedom of Information.
Anyone may file a complaint with the National Authority for Data Protection and Freedom of Information (1125 Budapest, Szilágyi Erzsébet fasor 22/C; postal address: 1530 Budapest, Pf. 5., phone: +36-1-391-1400; fax: +36-1-391-1410; e-mail: ugyfelszolgalat@naih.hu), in order to initiate an investigation on the grounds that a violation of rights has occurred or is imminent in connection with the processing of personal data or the exercise of the right to access data of public interest or data in the public interest.
10. Other provisions, contact details of the controller:
We take appropriate security measures to protect the personal data stored in our files against unauthorised access, alteration, disclosure or disclosure, deletion or destruction, accidental destruction or damage, and against inaccessibility due to changes in the technology used.
Contact details of the controller: emobility@smartdigital.eu, +361 4477581
Smart Digital Ltd. reserves the right to modify this Privacy Policy and will inform the data subjects accordingly. Information on Data Management is continuously published on the website okostoltes.hu.
Budapest, 19.07.2023.