1. Szinga Sport Kft. (registered office: H-1038 Budapest, Tündérliget utca 2..; company registration number: Cg. 01-09-370331; tax number: 10318102-2-44), as operator or the www.dorko.eu website (hereinafter: website) and the webshop operating on the website (hereinafter: webshop) (hereinafter: Service Provider) respects the fundamental constitutional right to the protection of personal data; namely, that everyone has right of disposal over the disclosure and use of his personal data.
2. In obtaining and processing the personal data required for the use of the services provided by data subject customers (hereinafter: Customer), the Service Provider pays particular attention to strict compliance with the provisions of Act VI of 1998 on the promulgation of the Convention for the protection of individuals with regard to automatic processing of personal data (signed in Strasbourg on 28 January 1981), Act CXIX of 1995 on the use of name and address information serving the purposes of research and direct marketing, and Act CXII of 2011 on the right of informational self-determination and on freedom of information (hereinafter: Privacy Act).
3. Data provided by the Customer, namely, first and last name, shipping and billing address, phone number, e-mail address and the Customer’s sex, are contained in the electronic mail transmitted through the system.
In the case of card payments, data required for the payment are not processed by the Service Provider but by OTP Bank Plc.
I acknowledge that my personal data stored by the controller – Szinga Sport Kft. (registered office: H-1038 Budapest, Tündérliget u. 2.) – in the www.playersroom.hu user database shall be transferred to OTP Mobil Kft. as data processor. The controller shall transfer the following data:
web order ID
date of the order
ordered items (product name, article number, price, quantity, VAT)
4. Controllers: the Service Provider and the delivery services specified in Section 5.
5. The Service Provider declares that the data stored in its database (name, shipping and billing address, e-mail address, phone number, Customer’s sex) shall be processed for the following purposes: enabling the provision of the services available in the webshop, displaying personalised contents and advertisements, compiling statistics, implementing technical developments for the IT system, protecting the rights of Customers. The Service Provider may use the data to create user groups and to display targeted contents and/or advertisements for the user groups on the Service Provider’s website, and to send newsletters.
The data provided by the Customer are required for the delivery of the products purchased in the webshop and shall be transferred to the shipping company (hereinafter: Delivery services) to the extent necessary for shipping.
- GLS Hungary Kft. (address: H-2351 Alsónémedi, GLS Európa u. 2.; phone number: +36 (29) 886 660);
- Sprinter Futárszolgálat Kft. (address: H-1097 Budapest, Táblás utca 39.; phone number: 06 (1) 803 6300).
- Gepárd Team Futárszolgálat Kft. (address: H-1149 Budapest, Mogyoródi út 32.; phone number: +36 (1) 399 9970).
- Hajtás Pajtás Kft. (address: H-1074 Budapest, Vörösmarty u. 20.; phone number: +36 (1) 327 9000).
- G4S Készpénzlogisztikai Kft. (address: H-1139 Budapest, Rozsnyai u. 21–25.; phone number: +36 (1) 2 380 222).
The Service Provider shall keep a data transmission log of the personal data provided by the Customer and forwarded to the delivery services in order to verify the legitimacy of the data transfer. The log shall contain the date and time of the transfer of the personal data processed by the Service Provider, the legal basis of the data transfer and the recipient, as well as the description of the personal data transmitted. The Service Provider shall retain the data stored in the data transmission log for 5 (five) years.
6. The Service Provider shall not use the personal data provided by Customer for any purposes other than those stipulated above. Personal data may not be disclosed to any third party (except for delivery services) or authority without the Customer’s express consent, unless such disclosure is required by law or a binding administrative or court order. The Service Provider shall erase the Customer’s personal data at the Customer’s request or when the purpose of the processing no longer exists.
7. The Customer’s data provision is voluntary; its legal basis is the data subject’s consent. By using the Service Provider’s services, the Customer consents to the use of his personal data for the purposes stated above (including the transfer of personal data to delivery services).
8. The Customer may request the Service Provider at any time:
information on his personal data being processed;
the rectification of his personal data;
the erasure or blocking of his personal data.
8.1 Upon the data subject’s request the Service Provider shall provide information concerning the data subject’s data processed by it, the sources from where they were obtained, the purpose, legal basis and duration of processing, the name and address of the processor and the processor’s activities relating to data processing, and – if the data subject’s data are being transferred – the legal basis and the recipients of the data transfer.
The Service Provider shall comply with the request for information as soon as possible but within thirty (30) days at the latest, and provide the information requested in an intelligible form, at the Customer’s request in writing.
The information described above shall be provided free of charge provided that the Customer has not submitted a request to the controller for the same category of data in the current year. In all other cases the information supply may be subject to a charge of HUF 700 per request. Already paid charges shall be refunded if the Service Provider processed the data unlawfully or the request resulted in rectification.
The Service Provider may only refuse the provision of information to the Customer in the cases defined in Section 9 (1) and Section 19 of the Privacy Act.
Should a request for information be denied, the Service Provider shall inform the Customer in writing as to which provision of the Privacy Act serves grounds for refusal. In the event the request for information is refused, the Customer may turn to court or to the National Authority for Data Protection and Freedom of Information (address: H-1125 Budapest, Szilágyi Erzsébet fasor 22./c; phone number: +36 (1) 391 1400; e-mail address: [email protected]; hereinafter: Authority).
8.2 Where a personal data item is deemed inaccurate and the correct personal data is at the Service Provider’s disposal, the Service Provider shall rectify the personal data in question.
Personal data shall be erased by the Service Provider if:
– the processing of the personal data is unlawful;
– the erasure of personal data is requested by the Customer;
– the personal data item is incomplete or inaccurate and this state may not be lawfully rectified, provided that the erasure is not ruled out by the Privacy Act;
– the purpose of processing no longer exists or the legal time limit for storage has expired;
– the erasure was ordered by court or by the Authority.
Instead of erasure, the Service Provider shall block the personal data if so requested by the Customer, or if there are reasonable grounds to believe that erasure could affect the legitimate interests of the Customer. Blocked data shall be processed only for the purpose which prevented their erasure.
If the accuracy of a personal data item is contested by the Customer and its accuracy or inaccuracy cannot be ascertained beyond doubt, the Service Provider shall mark that personal data for the purpose of referencing.
The Service Provider shall notify the Customer and all recipients to whom the data item has been transmitted for processing when a data item is rectified, blocked, marked or erased. Notification is not required if it does not violate the rightful interest of the data subject in light of the purpose of processing.
If the Service Provider refuses to comply with the data subject’s request for rectification, blocking or erasure, within 30 (thirty) calendar days of receipt of the request it shall communicate in writing the factual or legal reasons on which the decision for refusing the request for rectification, blocking or erasure is based. If the rectification, blocking or deletion request is rejected, the Customer may turn to court or to the Authority for remedy.
10. The Service Provider shall take no responsibility for the data provided by Customer. Should the Service Provider become aware that the data violate the personality rights of a third party or legal regulations or breach these data protection rules, or that the data’s non-conformity to the data protection rules gives rise to damages, the Service Provider shall be entitled to take the necessary legal steps in cooperation with the competent authorities. If the Customer has provided a third party’s data for using the service or has caused damage in any way by using the website, the Service Provider shall be entitled to file a claim for damages.
11. In order to avoid unauthorised access to and disclosure of data and to ensure the accuracy and the most appropriate use of the data, the Service Provider shall guard and safeguard the information collected online using appropriate physical, electronic and technical methods.
12. Under the Club card scheme, throughout the validity period of the Club card and even after the expiry thereof – if no request for erasure has been submitted –, the Service Provider shall continue to process the Customer’s data in order to encourage the Customer to become a regular customer, and to be able to notify the Customer of any promotions at the contact details provided. The data shall be processed by the Service Provider’s staff. The Customer may exercise its right of informational self-determination and freedom of information in accordance with Act CXII of 2011.
13. Web hosting service provider: Planet Express Kft.,
Registered office: H-1125 Budapest, Álom u. 43/b.
Tax number: 23587342-2-43
Company registration number: 01-09-972700
Customer service and technical support: [email protected]
14. Use of data processors
Partners providing marketing services and third parties:
- Maileon newsletter sending and remarketing - WANADIS KFT. | H-1112, BUDAPEST, BUDAÖRSI ÚT 153.
- Mailchimp.com newsletter sending – The Rocket Science Group, LLC (675 Ponce de Leon Ave NE - Suite 5000 - Atlanta, GA 30308 USA)
- SeeMe.hu SMS sending service – Dream Interactive Kft. H-1027 Budapest, Medve utca 24. [email protected]
15. Correspondence service provider:
Maileon Digital Kft.
Registered office: H-1112 Budapest Budaörsi út 153.
1. The personal data of registered Players shall be processed by the Organiser of the sweepstakes (Szinga Sport Korlátolt Felelősségű Társaság (registered office: H-1038 Budapest, Tündérliget utca 2.; company registration number: 01-09-370331; tax number: 10318102-2-44; e-mail address: [email protected]; represented by: Zoltán Gém managing director; hereinafter: Organiser). The Organiser shall be the exclusive controller of all personal data. The Organiser has registered the processing in the Data Protection Register maintained by the National Authority for Data Protection and Freedom of Information: NAIH-84718/2015.
The processing of the personal data of Players shall be governed by this Policy. The processing of personal data shall be governed by the laws of Hungary and of the European Union, in particular, Act CXII of 2011 on Informational Self-Determination and Freedom of Information (hereinafter: Privacy Act), Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and the GDPR Regulation entering into force on 25 May 2018.
3. By registering, the Player accepts the Sweepstakes Rules and this Policy. By registering and by accepting the Rules and the Policy, the Player consents to the processing of his personal data in accordance with this Policy. The legal basis of data processing is the Players’ voluntary consent (Section 5 (1) a) of the Privacy Act). This Policy constitutes information provided to the Players.
4. The Organiser shall strive to ensure that the processing is fair and legitimate and that the processing of personal data observes the principle of purpose limitation at all times. The primary purpose of the processing is the implementation of the sweepstakes and, in this context, the verification of eligibility for participation, the draw, the notification of winners, and the delivery of prizes. In addition to the above, the purpose of processing is advertising, market sounding and public opinion polling activity by using the data provided by the Player.
The Organiser is entitled to use the data for statistical purposes in a manner unsuitable for personal identification.
5. Personal data shall be processed at the Organiser’s registered office, branch, site, or at the processing venue of the processor appointed by the Organiser. Decisions concerning the processing shall be made by the Organiser in all cases.
Pursuant to the Privacy Act, the Organiser is entitled to appoint a processor. The processor may not make any decision independently. The Organiser shall publish the names of all processors in this Policy.
6. During registration, the Player shall provide the personal data required for his identification and for contact, as listed on the registration form (name, e-mail address, address, date of birth, ZIP code). Purpose of the processing: identification of Players, contact, advertising, research.
Winners are required to provide the Organiser with all data that are necessary for obtaining the prize, thus, in particular, for delivering the prize to the winner and for performing tax obligations (precise address, the natural person’s identification data, tax identification code, bank account number). If the Player fails to provide the requested data, the Organiser shall be entitled to refuse to give away the prize. The purpose of processing in the case of winners is the delivery of the prize and the performance of the tax obligation.
In the case of referrals, the purpose of the processing is to promote the sweepstake; the Organiser will send a letter to the referred person describing the sweepstakes.
7. The Organiser is entitled to use the Player’s contact information (e-mail address, postal address, phone number) for the purposes of sending promotional electronic messages to the Player in relation to the Organiser and to the Organiser’s activity, newsletters or other letters including advertisements in relation to the service or any other communication for such purposes. The Player expressly consents to the Organiser’s placement of advertisements in the communication, newsletter or any other notification sent to the Player.
By registering, the Player expressly consents to receiving direct marketing messages from the Organiser and to the Organiser’s use of the Player’s data for this particular purpose. This consent equally covers contact via e-mail, telephone, post or any other manner of communication.
The Players consent to the Organiser’s use for advertising purposes of the data generated while using the Organiser’s websites and participating in the sweepstakes so that the Organiser may communicate offers aimed at the Players and relevant to the recipients.
The Organiser is entitled to use the data processed for the purposes of public opinion polling, market sounding and the compilation of research samples, and to contact the Players for such purposes.
8. Upon visiting the Website, the Organiser’s system automatically records the IP address of the Player’s computer, the start time of the session and, in some cases depending on the computer’s settings, the type of the browser and the operating system, and the geographical location determined from the IP address. Data thus recorded may not be linked to any other personal data. The processing shall serve statistical purposes only. The Organiser retains the right to place data files (cookies) on the Player’s computer.
9. The Organiser shall not erase the data provided at the end of the sweepstakes; it shall continue to process and use the data for the purposes defined in this Policy.
The Organiser shall erase the data provided if:
- their processing is unlawful or the erasure is required by law;
- it is requested by the data subject Player;
- the data are incomplete or inaccurate and this status cannot be lawfully rectified;
- the purpose of the processing no longer exists;
- it is ordered by the Authority or court.
The Player may request the erasure of his personal data at the Organiser’s contact information (Section 1). Upon the Player’s request, the Organiser shall erase the data within five working days. Upon the erasure of personal data the data are rendered unrecognisable in such a way that the link between the data and the data subject can no longer be restored.
The Organiser shall not erase personal data even at the Player’s request if the processing of the data is required or permitted by law (thus, for example data related to tax obligations). In such cases, the Organiser shall inform the Player of the legal basis of the erasure’s rejection.
If a legal relationship is established between the Organiser and the Player and the processing is necessary for exercising the rights or performing the obligations arising from the legal relationship (e.g. enforcing claims or addressing disputes), the Organiser shall continue, pursuant to Section 6 (5) of the Privacy Act, to process the personal data despite the request for erasure.
If the Organiser excludes the Player from the sweepstakes, it shall continue, despite the request for erasure, to process the data items necessary for preventing repeated registration. In such cases, the legal basis of processing shall be Section 6 (5) of the Privacy Act.
10. The Player is entitled to rectify his data or to request the Organiser to rectify incorrect data items that the Player himself is unable to rectify. The data subject may request information about the processing of his data. The Organiser may also provide this information via e-mail. The data subject is entitled to object to the processing of data relating to him.
11. The Organiser shall take all reasonably expected measures to ensure the security of the data; it shall provide an appropriate level of protection against unauthorised access, alteration, transmission, public disclosure, erasure or destruction, as well as damage and accidental loss. The Organiser shall put in place suitable technical and organisational measures to protect the security of data.
12. Upon using the service and visiting the Website, Players may only provide their own personal data. Supplying the data of another person shall constitute unlawful processing, which may result in the consequences specified in separate legislation. In the event of identity fraud, the Organiser shall assist the competent authorities in detecting the infringement and identifying the perpetrator.
13. The Organiser shall not transfer personal data to third parties without the data subject’s explicit consent or without being required by law.
14. The Player may lodge a complaint with the Organiser in relation to the processing of his personal data, and the Organiser shall investigate the complaint and remedy the infringement as soon as possible.
In the event of a violation of the Player’s right to the protection of personal data, the Player may turn to the National Authority for Data Protection and Freedom of Information (www.naih.hu), or enforce his claim before the courts.