Last updated: 14-03-2021
Privacy Policy
1. PREAMBLE
At Günz Kft. (hereinafter as “KittenGuru”), we want to give you the best possible experience to ensure that you enjoy our service today and in the future. We appreciate that you are trusting us with information that is important for you, and we believe that transparency is the key to all of our relationship. So, we want to explain how and why we store, share and use your personal data.
The highest level of protection of personal data is a priority for Günz Kft. (seat: H-11149 Budapest, Turán tér 6.)
This Privacy Policy aims to give information to the visitors of www.KittenGuru.com website (hereinafter referred to as the “Website“) on the data processing related to the operation of KittenGuru.
NewDoggy’s data processing is in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter referred to as the “GDPR“) and the Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information (hereinafter referred to as the “Privacy Act“).
KittenGuru, as data controller, accepts the content of this legal notice as mandatory.
We hereby inform you on the main aspects of our data processing above.
2. GENERAL PROVISIONS
The principles of KittenGuru data processing comply with the existing data protection legislation, in particular:
- Directive EC/2016/679 on the European Parliament and of the Council (“GDPR”),
- Act V of 2013 on the Civil Code (“Civil Code“),
- Act CVIII of 2001 on Electronic Commerce and on Information Society Services,
- Act C of 2003 – on Electronic Communications,
- Act XLVIII of 2008 on the Basic Requirements and Certain Restrictions of Commercial Advertising Activities
- Act CLV of 1997 on Customer Protection (“Act on Consumer Protection”)
- Act C of 2000 on Accounting (“Act on Accounting”)
For processing your personal data, KittenGuru uses the following processors:
IT Data Processors:
- WebOrigo Magyarország Zrt. (9. Bem József utca, Budapest, 1027, Hungary) for providing dedicated servers and managing the website and backoffice IT inftractucture.
Financial Data Processors:
- Barion Payments Zrt. (1. Infopark stny., Budapest, 1117 Hungary) for providing card payment gateways.
- PayPal, Inc. (2211 North First Street, San Jose, California, United States) for providing card payment gateways.
Accounting Data Processors:
- EXPEDITE Kft. (Nánási út 2. A, 1031, Budapest, Hungary) for providing accounting services.
Shipping Data Processors:
- FastAir-Cargo Szállítmányozási Kft. (BUD Nemzetközi Repülőtér Cargo City, 2220, Vecsés, Hungary) for providing landline and air carge services.
- Animals First GmbH (Flughafen Wien, 1300 Schwechat, Austria) for providing landline and air carge services.
- R-CARGO Czech s.r.o. (Ukrajinská 874/3, 101 00 Praha 10, Czech Republic) for providing landline and air carge services.
Marketing Data Processors:
- Facebook Ireland Ltd. (4 Grand Canal Square Grand Canal Harbour Dublin 2 Ireland) for providing Facebook and Instagram Marketing Services.
- Pinterest Inc. (505 Brannan Street San Francisco, CA 94107 United States) for providing Pinterest Marketing Services.
- Twitter Ireland Ltd. (26 Fenian St, Dublin, D02 FX09, Ireland) for providing Pinterest Marketing Services.
- Microsoft Ireland Operations Ltd. (The Atrium Building, Block B, Carmanhall Road, Sandyford Business Estate, Dublin 18, Ireland) for providing Marketing Services.
- Linkedin Ireland Ltd. (Wilton Place, Dublin 2, Ireland) for providing Marketing Services.
- Google Ireland Ltd. (Google Building Gordon House, Barrow St, Dublin 4 Ireland) for providing Google Ads services.
KittenGuru only discloses your processed personal data to the members listed above and employees of KittenGuru, whose access to your personal data is vital to the achievement of the purpose of processing.
KittenGuru processes your personal data in confidence and implements appropriate technical and organisational measures to ensure their protection.
Furthermore, KittenGuru creates appropriate procedures provisions that are necessary to implement the regulations of the above listed directives and laws.
KittenGuru reserves the right to modify the present Privacy Policy at any time. Naturally, we will notify our partners and customers in sufficient time of any changes.
3. DATA PROCESSINGS
3.1. Processings for marketing purposes
3.1.1. New Litter Allerts
We regularly send newsletters to our clients and business partners who register on our partner portal and build a database for business purposes.
Purpose of the processing: to inform our clients on the latest news regarding our services, awareness raising and relationship management.
Scope of the processing: name, e-mail address, phone number, the name of the company and the consent of the data subject (declaration of consent)
Legal basis of processing: the legal basis of data processing is the given consent of the data subject (Article 6 (1) (a) of GDPR).
Data retention period: until it is compatible with its purposes, but no later than the withdrawal of consent by the data subject.
Please note that withdrawal of consent and the erasure or modification of personal data can be requested on the official contact details.
The scope of the processing: name, e-mail address, phone number and the consent of the data subject (declaration of consent).
KittenGuru uses the servers of the Data Processor that are located in a third country.
Due to the fact that Data Processor (above listed Marketing Data Processors) is part of the EU-U.S. Privacy Shield Framework Agreement, the appropriate level of protection of personal data is ensured.
3.1.2. Processing for the purpose of business relationship management
Purpose of the processing: client relationship management and facilitating to get in contact with KittenGuru. In case you would like to contact us, you can do it on our contact details.
Scope of the processing: name and contact details (phone number and e-mail address) of the data subjects, other personal data placed on a business card (position, company name), documents provided by the requesting party, the description of the request and the consent of the data subject (declaration of consent)
Legal basis of processing: the legal basis of data processing is the freely given consent of the data subject (Article 6 (1) (a) of GDPR).
Data retention period: until it is compatible with its purposes, but no later than the withdrawal of consent by the data subject.
3.2. Processings for customer service
Purpose of the processing: to handle quality and quantity complaints concerning KittenGuru services or products, to provide product service operation. The complaint notice can be registered through email.
Legal basis of processing: performance of service (GDPR point b) section 1 of Article 6); compliance with legal obligation (Act on Consumer Protection Article 17/A; Act on Accounting section 2 Article 169; GDPR point c) section 1 of Article 6); consent of data subject (Act on Consumer Protection Article 17/A; GDPR point a) section 1 of Article 6)
Scope of the processing: name and contact details (phone number, e-mail address) of the data subject, name and price of the product, time of the purchase and complaint notification, description of defect, claim required to be validated and the mode of settlement.
Data retention period: invoices of the returned goods: 10 years; records of the complaint and the replies: 5 years.
Consequence of refusal of data provision: it would be impossible to investigate and settle the complaint.
3.3. Contacting KittenGuru
Purpose of processing: In case data subject wishes to contact KittenGuru, it may do so through channels provided in present Policy or the website.
Legal basis of processing: The legal basis is the freely given consent of the data subject (Article 6 (1) (a) of GDPR), in case of complaint handling or sales service, compliance with legal obligation (Act on Consumer Protection Article 17/A; GDPR point c) section 1 of Article 6).
Scope of the processing: name and contact details (phone number, e-mail address) of the data subject, description of the matter, documents attached by the data subject.
Data retention period: records of the inquiry and the replies: 2 years; in other case until the withdrawal of consent.
3.4. Processings on website
3.4.1. Browsing website
When visiting our website, the webserver does not record any personal data.
Data logging for external service providers is based on cookie technology. Extrenal providers are listed above.
3.4.2. Cookies at website
KittenGuru and other service partners install cookies (which are small piece of information) in order to identify and track users and to read them back during internet usage. If your browser returns a previously saved cookie, the cookie operator has the capacity to link the user’s current visit to the previous ones for websites where KittenGuru or the external service providers’ cookies are installed.
KittenGuru also uses cookies for the technical operation of the Website, for sending targeted newsletters and for statistical purposes. We inform you that cookies do not damage your computer and they do not contain viruses. This is a commonly known, open source technology.
Cookies can be deleted from your computer and be blocked in your browser at anytime.
The following external service providers have installed cookies on our website:
- Google Analytics and Ads services
- Facebook Pixel
- Barion Pixel
- Hotjar
- SiteGround
3.4.3. Google Analytics
Our website uses Google Analytics, as an external service provider who assists in the independent measurement and audit of the visits of the website and other web analytic data on newdoggy.com.
Google Analytics uses cookies to operate the site’s web analytical system.
For further information on Google Analytics processing please visit http://www.google.com/intl/hu/policies.
Document called „How Google uses information from sites or apps that use our services” is available at the following link: http://www.google.com/intl/hu/policies/privacy/partners/.
3.4.4. Facebook Pixel
When you are accessing the company’s a Facebook page, we allow Facebook to collect cookies at your devices. We inform you that our company does not process any personal data on you, we only receive viewing statistics for our Facebook page.
Our company only determines the criteria – provided by the Facebook- upon which the Facebook provides us the statistical data.
For further information on Facebook’s cookie policy, please visit the following link: https://www.facebook.com/policy/cookies/
Our website uses Facebook’s services to provide insights about the people who like our Facebook page. The collected data are anonymous to the operator of the website, therefore no conclusion about the identity of the users can be drawn. However, the data is stored and processed by Facebook so that a connection to the uses profile is possible, and Facebook can use the data for its own advertising purposes. Our website includes plugins for the social network Facebook, Facebook plugins can be recognized by the Facebook log or the Like button on our site.
For further information on Facebook’s processing please visit: https://www.facebook.com/about/privacy
Document called „Cookies and other storage technologies” is available at the following link: https://www.facebook.com/policies/cookies/
3.4.5. Barion Pixel
Barion Pixel is a java script based assessment code placed on the website of the Merchant (similar to the operation of Google Analytics and Facebook Pixel) which follows the activities of website visitors. Barion Pixel placed on the website collects data on visitors concerning what products they have seen, clicked on, or searched for, put in the basket or purchased. It transfers data to the servers of Barion, and such data are not collected, stored or processed at the Merchant.
Detailed informantion: https://www.barion.com/sk/podpora/what-is-a-barion-pixel/
3.4.6. HotJar
To function properly, Hotjar stores first-party cookies on your visitor’s browser. Cookies are either set by the Hotjar script, or by visiting Hotjar’s website.
When you use the Hotjar script on your website, Hotjar cookies are responsible for displaying the correct content to your visitors without personally identifying anyone.
If you, as an internal user, are looking to not be tracked by Hotjar or any site that uses Hotjar, you may do so by following the steps on our Do Not Track page.
Detailed informantion: https://help.hotjar.com/hc/en-us/articles/115011789248-Hotjar-Cookie-Information
3.4.7. SiteGround
Our website uses the technology of SiteGround. Please refer to SiteGround’s cookie policy: https://www.siteground.com/viewtos/cookies_policy
3.6. Other processing
We provide information about processing that is not listed in this Privacy Policy at the time when personal data are obtained. We inform our partners and clients that courts, prosecution, investigating authorities, the authority dealing with administrative offences, administrative authorities, the National Data Protection and Freedom of Information Authority and other organs under the provisions of the applicable law may contact KittenGuru in order to receive notification or that KittenGuru discloses, transfers personal data or provides documents to them.
At KittenGuru will only provide information to the authorities -if they have indicated the exact purpose and scope of the personal data – that is strictly necessary to the purpose of the inquiry.
4. METHOD OF STORING PERSONAL DATA, SECURITY OF PROCESSING
We and our processors by taking into account the state of the technology, the costs of the execution, the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons, implement appropriate technical and organisational measures to ensure the appropriate level of data protection.
We protect your data with appropriate measures against unlawful access, alteration, transfer, disclosure, erasure or destruction, as well as accidental loss, damage, and the accidental unavailability due to the change of the used technic.
In order to protect the electronic processed personal data that are stored in our various registries, we provide appropriate technical measures to ensure that the stored personal data – unless it is permitted by law – cannot be directly linked and assigned to the data subjects.
The provided technical and organisational measures are in accordance with the current state of technology and they are compatible with the level of risks associated to ensure the security of processing.
During processing we respect and maintain
- confidentiality: protecting the information so that it can only be accessed by those who are entitled to it;
- integrity: protecting the accuracy and completeness of information and processing methods;
- availability: ensuring that when the data subject needs it, he/she can actually access the information and she/he has procedures for it.
KittenGuru IT infrastuctures are protected against computer-aided fraud, espionage, sabotage, vandalism, fire and flood, as well as computer viruses, computer intrusion and denial-of-service attacks. The operator provides security through server-level and application-level security procedures. We inform you that electronic mails apart from the protocols (email, web, ftp etc.) that are transferred through the Internet are vulnerable to network threats that may lead to fraudulent activity, challenge of the contract and disclosure or modification of information. We shall take all the precautionary measures to protect you from such threats. Systems are monitored so that we could record all security dangers and provide evidence of any security incident. System monitoring also allows the controlling of the efficiency of the precautionary measures.
We, as data controller record potential personal data breaches, including facts and effects of the personal data breach and measures taken or proposed to be taken by us to address the personal data breach. We shall notify the National Data Protection and Freedom of Information Authority on any potential personal data breach without undue delay and, where feasible, not later than 72 hours after having become aware of it.
5. RIGHTS OF THE DATA SUBJECT
We inform you that in relation to the processing of your personal data you dispose the following rights:
- Transparent information,
- Right of access by the data subject,
- Right to rectification,
- Right to erasure (‘right to be forgotten’),
- Right to restriction of processing,
- Right to data portability,
- Right to object,
- Right to withdrawal of consent,
- Right to effective remedy.
5.1. Transparent information
We are obliged to provide you with information – in accordance with the provisions of the GDPR – about the processing of your personal data. We fulfil our obligation by providing the present Privacy Policy to you. Please be aware of the fact, that if you have further questions in relation to the processing of your personal data you can exercise your right of access.
We shall notify and answer all your data privacy questions within 30 business days.
5.2. Right of access by the data subject
You have the right to get information whether we process your personal data and if so, you may demand a detailed prospectus that contains the following information:
- the reason of the data processing,
- the scope of the processed personal data,
- the source of the processed data,
- the recipient of the data,
- the term of the storage of the processed personal data,
- in case of an international transfer of your personal data, the guarantees of the transfer, and
- a repeated information on your rights in relation to the processing of your personal data and your right to lodge a complaint with a supervisory authority.
For your request we may give you a copy of your processed personal data free of charge.
For further copies we may charge you the administrative costs of providing such information.
Upon your request, the aforementioned information may be provided orally if your identity is proven genuinely.
5.3. Right to correcture
For your request we correct or complete your inaccurate personal data (e.g. your date of birth is inaccurate, your e-mail address or your name has changed).
5.4. Right to erasure
You may request that we erase your processed personal data without undue delay if,
- the purpose of the data processing no longer justifies the processing,
- consent is the legal basis of the processing and you have withdrawn your consent (and there is no other applicable legal basis),
- you object the processing and there are no overriding legitimate grounds for the processing,
- the personal data have been unlawfully processed, or
- the personal data have to be erased under legal obligation.
The right of erasure cannot be exercised if the processing is necessary for exercising the right of freedom of expression and information, the compliance with a legal obligation that KittenGuru is subject to, or for the performance of a public task, or reasons of public interest in the area of public health or archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, or for the establishment, exercise or defence of legal claims.
We also cannot erase your data is the deletion process is permitted by law.
5.5. Right to restriction of processing
If you exercise this right and according to the applicable law you shall obtain restriction of processing, we cannot process your personal data (therefore we cannot transfer or organise your data) – with the exception of storage – unless you consent or it is necessary for the establishment, exercise or defence of KittenGuru’s legal claims.
When can you exercise this right?
- If you claim that your personal data is inaccurate, for a period while we examine the accuracy of your data.
- If the processing is unlawful but instead of erasure, you request the restriction of your data.
- If we no longer need your personal data (for the purpose of the processing) however you request that we store them (e.g. for the establishment, exercise or defence of legal claims).
- If you object the processing, for a period while we verify whether our legitimate grounds override those of yours.
5.6. Right to data portability
We inform you that we do not process your personal data by automated means.
5.7. Right to object
You may object on the grounds relating to your particular situation, at any time to the processing of personal data concerning you if the legal basis of the processing is the legitimate interest of KittenGuru.
In this above mentioned case, we will no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
If we process your personal data for direct marketing purposes (e.g. newsletter) you can object the processing of your personal data concerning you at any time. We will no longer process your personal data if you object the processing.
5.8. Right to withdraw a consent
You have the right to withdraw your consent at any time during the processing.
We inform you that the withdrawal of your consent shall not affect the lawfulness of processing based on your consent before its withdrawal.
5.9. Procedural provisions
Please note that we will notify you on the action taken without undue delay, but within 30 business days of receipt of your request. We may extend the period by 60 business days if it is necessary due to the complexity and the number of the requests. We inform you on the extension within the fist period.
If you submit your request by electronic means, KittenGuru will give you the information by electronic means (unless you request otherwise).
We inform you that we provide the requested information free of charge. If your request is clearly unfounded or excessive, in particular because of its repetitive character, we can charge you with a reasonable fee for administrative costs or we can refuse to take action on your request.
We communicate any rectification or erasure of personal data or rectification of processing to each recipient with whom we have provided your personal information (unless it is impossible). Upon your request, we inform you about these recipients.
5.10. Right to compensation
KittenGuru compensates your damages that we caused by unlawful processing or breaching the data protection requirements. In case of the violation of the rights relating to your personality, you are entitled to restitution in accordance with the provisions of the Civil Code.
We inform you that KittenGuru is liable for any damages caused by a data processor that we used during the processing of your personal data. KittenGuru shall be relieved of liability if the damage occurred in consequence of unforeseen circumstances beyond our control.
KittenGuru does not compensate your damages and you cannot claim restitution insofar as damage or impairment – caused by the violation of the right relating to your personality – is caused by your intentional or gross negligent behaviour.
5.11. Remedies
5.11.1. Right to a judicial remedy
If you consider that your rights under data protection law have been infringed you may file for court action against the controller before the general court in whose jurisdiction your home address or habitual residence is located.
The court shall hear such cases in priority proceedings. We inform you that lawsuits related to personal data protection are free of charge.
5.11.2. Right to lodge a complaint with a supervisory authority
If you consider that your rights under data protection law have been infringed you can choose to lodge a complaint with the National Data Protection and Freedom of Information Authority.
Contact details of the authority:
Name: Nemzeti Adatvédelmi és Információszabadság Hatóság
Seat: 1125 Budapest, Szilágyi Erzsébet fasor 22/C.
Mailing address: 1530 Budapest, Hungary (Please refer to P.O. 5.)
