PRIVACY POLICY

This Privacy Policy sets out the terms on which we process your personal data you provide to Us in the course of using the TEQERS™ (the online store available at: eu.teqers.com), as well as our privacy obligations to you.

I. Policy-Specific Definitions

In addition to the terms already defined in the “TEQERS™ General Terms & Conditions” (available at: eu.teqers.com/terms-and-conditions), data processing terms, whether or not they are capitalized, shall be defined as in the General Data Protection Regulation [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; hereinafter referred to as “GDPR”].

II. Data Controller

The data controller for your personal data is, unless otherwise specified:

TEQBALL Kft., a company registered in Hungary at the Company Registry Court of the Budapest-Capital Regional Court, under registry n° 01-09-174699, having its registered seat at Expo tér 5-7, 1101 Budapest, Hungary, with VAT n° 24390305-2-42 (hereinafter referred to as ”Data Controller”/”We”/”Us”/”Our”, whether capitalized or not).

III. Data Processing Purposes & Legal Basis

Your personal data is processed for the purposes and according to the methods defined in the tables below, depending on the category of data and/or your relationship to us.

1) Customer Account Data

If you register to the TEQERS™, your customer account data is processed as described in the table below:

^[^1] Commission Decision 2002/2/EC of 20 December 2001 pursuant to Directive 95/46/EC of the European Parliament and of the Council on the adequate protection of personal data provided by the Canadian Personal Information Protection and Electronic Documents Act.

2) Order data

Your Data	When/Where Collected	Our Use	Your Benefit	Legal Basis	Storage Period	Data Processors and Uses
Contact Information: name; e-mail address (if you are not a registered user)	order placement / checkout	to perform order, ability to keep contact and provide all necessary information related to the purchase	ability to receive all necessary information related to the purchase, able to buy	The data is processed as it is necessary for the performance of the sales contract. The data is processed within the general limitation period of 5 (five) years prescribed by Act V of 2013 on the Hungarian Civil Code, for the purpose of the establishment, exercise or defense of (legal) claims related to the performance of the sales contract. Invoices are stored for 8 (eight) years, based on Data Controller’s legal obligation to do so under Hungarian Act C of 2000 on accounting.		Elastic Path Software Inc. (1400 - 745 Thurlow St, Vancouver, British Columbia, V6E 0C5, Canada) – website engine, shopping cart processing services (https://www.elasticpath.com/elastic-path-commerce-cloud) Twilio Inc. (101 Spear Street, First Floor, San Francisco, CA 94105, USA) – Twilio Sendgrid: transactional e-mail delivery services (https://www.twilio.com/sendgrid/email-api). The transfer of personal data to Twilio Inc. is pursuant to the EU Standard Contractual Clauses applied by Twilio Inc. (available at: https://www.twilio.com/legal/data-protection-addendum) Microsoft Corporation (98052 One Microsoft Way, Redmond, WA, USA) – Microsoft Azure cloud computing services; https://azure.microsoft.com/en-us/ Loggly Inc. (535 Mission St, Ste 2100, San Francisco, California, 94105, US) – SolarWinds Loggly data logging & troubleshooting services (https://www.loggly.com/).
Shipping Information: name; phone number; shipping address (if not provided earlier as account data)		processing the order and executing delivery	receiving the purchased TEQ Products and exercising your rights with regard to delivery			Schenker Nemzetközi Szállítmányozási Kft. (address: Leshegy u. 30., 2310 Szigetszentmiklós, Hungary) – transport & logistics brokerage (https://www.dbschenker.com/hu-en) Creals.com Kft. (1048 Budapest, Nádasdy Kálmán utca 16. 2. em. 5.) – transport & logistics brokerage (http://www.creals.com/en/) GLS General Logistics System Hungary Kft. (GLS Európa utca 2., 2351 Alsónémedi, Hungary) – transport & logistics brokerage (https://gls-group.eu/HU/en/home) Elastic Path Software Inc. (1400 - 745 Thurlow St, Vancouver, British Columbia, V6E 0C5, Canada) – website engine, shopping cart processing services (https://www.elasticpath.com/elastic-path-commerce-cloud) Microsoft Corporation (98052 One Microsoft Way, Redmond, WA, USA) – Microsoft Azure cloud computing services (https://azure.microsoft.com/en-us/) Twilio Inc. (101 Spear Street, First Floor, San Francisco, CA 94105, USA) – Twilio Sendgrid: transactional e-mail delivery services (https://www.twilio.com/sendgrid/email-api) Loggly Inc. (535 Mission St, Ste 2100, San Francisco, California, 94105, US) – SolarWinds Loggly data logging & troubleshooting services (https://www.loggly.com/)
Billing Information (if different from Shipping Information): name, phone number, billing address (if not provided earlier as account data)		processing the order and invoicing	receiving the invoice as requested and in accordance with applicable legal provisions
Order history	Order history is recorded only for Customers with a registered customer account, and is displayed on the customer account. The order history is automatically created and extended by placing the order(s).	Keeping track of Customer’s orders to enable and facilitate the handling of related inquiries, complaints, and other claims or proceedings.	Ability to keep track of current and former orders; thus enabling and facilitating the submission of inquiries, complaints, other claims, and the commencement of relevant proceedings.	Orders are stored within the general limitation period of 5 (five) years prescribed by Act V of 2013 on the Hungarian Civil Code in order to enable and facilitate the handling of related claims and proceedings, including the establishment, exercise, and defensee of (legal) claims related to the performance of the sales contract. After the passing of 5 years, the data is anonymized and deleted from the customer account. (The data may be stored further only for statistical purposes but due to the anonymization, it does not qualify as personal data anymore.)		Microsoft Corporation (98052 One Microsoft Way, Redmond, WA, USA) – Microsoft Azure cloud computing services (https://azure.microsoft.com/en-us/) Elastic Path Software Inc. (1400 - 745 Thurlow St, Vancouver, British Coludmbia, V6E 0C5, Canada) – website engine, shopping cart processing services (https://www.elasticpath.com/elastic-path-commerce-cloud) Loggly Inc. (535 Mission St, Ste 2100, San Francisco, California, 94105, US) – SolarWinds Loggly data logging & troubleshooting services (https://www.loggly.com/)
Payment and order related information except for full card information (e.g. order IDs, installment plan IDs, effected and failed transactions, installments, refund and chargeback information, etc.)	After or upon completing an order.	Keeping track of the order and the completion of certain financial processes with respect to the order (i.e. completion of payment, chargebacks, refunds).	Having the orders and payments properly processed and managed by Data Controller. With respect to chargebacks and refunds: receiving the relevant amount in due course.	The data is processed as it is necessary for the performance of the sales contract. The data is processed within the general limitation period of 5 (five) years prescribed by Act V of 2013 on the Hungarian Civil Code, for the purpose of management of the sales contract, the establishment, exercise or defense of (legal) claims related to the performance of the sales contract.		Escalion S.à r.l. (44 Avenue John F. Kennedy, L-1855 Luxembourg; https://www.escalion.com/en/) – payment processing services (excluding your full card information) Splitit Capital UK Ltd.; 1 Charterhouse Mews, London EC1M 6BB, UK; https://www.splitit.com/) – split payment services (excluding your full card information)

3) Card information

The full number of your debit/credit card that are used for online payment is neither recorded nor processed in any way by the Data Controller. The online payment service is provided by::

as relates to regular (lump sum) payments: Escalion S.à r.l. (44 Avenue John F. Kennedy, L-1855 Luxembourg; https://www.escalion.com/en/)
as relates to split payments (‘Buy Now Pay Later’ option, where applicable): (Splitit Capital UK Ltd.; 1 Charterhouse Mews, London EC1M 6BB, UK; https://www.splitit.com/)

For your financial security, upon finishing checkout, depending on the type of payment chosen (lump sum or split payment), you are redirected to a page operated by the adequate payment service provider enabling you to effectuate payment. The payment service providers do not transfer your full debit/credit card number to the Data Controller, and therefore, the Data Controller does not assume any liability for the data processing of those information abovementioned by the service providers. Data Controller only receives the last 4 digits of your card which we only use to identify the relevant transactions.

4) Customer Service data

Customer service as regards purchases of TEQ™ tables and their accessories is provided by the Data Controller. Customer service related to purchases of TEQ™ Products other than TEQ™ tables or their accessories is provided by Creals.com Kft. (registered address: Nádasdy Kálmán utca 16. 2. em. 5., 1048 Budapest, Hungary; company registry n° 01-09-977860) acting on behalf of the Data Controller, in cooperation with the Data Controller, based on the contractual relationship between the Data Controller and the abovementioned service provider (data processor).

The legal basis and details of the processing of personal data collected as part of customer service is also dependent on the nature of the inquiry, i.e. whether it entails contacting for general inquiries or the submission of complaints.

4.1. Customer Service – Contacting for general inquiries

Your Data	When / Where Collected	Our Use	Your Benefit	Legal Basis	Storage Period	Data Processors and Uses
Name	through e-mail correspondence and/or by phone	collecting the data necessary for the further contact and for answering the inquiry	ability to maintain contact with the Data Controller, and receiving a reply to the inquiry	Consent	For the time necessary for answering the inquiry but latest until the revocation of consent.	Creals.com Kft. (Nádasdy Kálmán utca 16. 2. em. 5., 1048 Budapest, Hungary) – handling of inquiries related to (the purchase of) TEQ™ Products other than TEQ™ tables or their accessories (http://www.creals.com/en/)
Contact details (e-mail address and/or phone number), where necessary
Order details, where necessary
Any other personal data provided in the course of requesting customer service

4.2. Customer Service – Complaint handling

Your Data	When / Where Collected	Our Use	Your Benefit	Legal Basis	Storage Period	Data Processors and Uses
Name*	Through e-mail correspondence and/or by phone. In case a verbal complaint is not possible to be examined immediately upon its communication, or if Customer disagrees with the remedy offered or provided, the complaint is recorded in a complaint report. The data marked with * are obligatorily recorded in the complaint report by law.	registering the complaint and all other data necessary for further contact and for the examination and remedying of the complaint	ability to maintain contact with the Data Controller, and obtaining a remedy for the complaint, where appropriate	Official complaint procedures are regulated by law. Data is processed for compliance with legal obligations under Hungarian Act CLV of 1997 on consumer protection	Complaint reports are stored for 3 years (as per law). Any other personal data collected (i.e. in case a complaint report is not drawn up) is processed for the time necessary for examining and remedying the complaint, where appropriate.	Creals.com Kft. (Nádasdy Kálmán utca 16. 2. em. 5., 1048 Budapest, Hungary) – handling of complaints related to (the purchase of) TEQ™ Products other than TEQ™ tables or their accessories (http://www.creals.com/en/)
Address*
Identifier of the complaint*
Place, date, and method of submitting the complaint*
Place and date of the recordal of the complaint report*
Contact details (e-mail address and/or phone number)
Order details, where necessary
Any other personal data provided in the course of submitting a complaint, especially in the description of the complaint, or the documents and other proofs submitted

5) Cookie Data

TEQERS™ uses cookies and similar technologies in order for the proper functionality of the website, and also for analytical, statistical, and marketing purposes. Our usage of cookies, the processing of the related data, and all other relevant information (especially related to the consent given to the usage of certain categories of cookies) is provided to you separately in pop-up windows upon accessing TEQERS™, and is also detailed in our Cookie Policy (eu.teqers.com/cookie-policy). Should you have any further questions on our cookie usage, please contact us at the following e-mail address: [email protected].

IV. YOUR RIGHTS

You have the following rights in relation to your personal data:

1) Right to access

You have the right to request access to your personal data and obtain information regarding the purpose of processing, what categories of personal data are processed, data processors, length of processing, your rights relating to our processing, your right to lodge a complaint with a supervisory authority regarding our processing, information on third party sources of your personal data communicated to us, and the existence of automated decision-making and related information, including the logic involved, as well as the significance and the envisaged consequences of such processing for you, whether your personal data is transferred outside the EEA, and the conditions of these transfers.

2) Right to rectification

You have the right to obtain rectification of inaccurate personal data and, taking into account the purposes of the processing, to have incomplete personal data completed.

3) Right to erasure

You have the right to request erasure of your personal data without delay if:

your personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
you withdraw your consent and there is no other legal grounds for processing;
you object to the processing pursuant to paragraph 5) below and there are no overriding legitimate grounds for the processing;
your personal data has been processed unlawfully;
your personal data has to be erased for compliance with a legal obligation;

Please note that the above right to erasure does not apply to the extent that processing is necessary:

for exercising the right of freedom of expression and information;
for compliance with a legal obligation or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller
for reasons of public interest in the area of public health
for achieving purposes in the public interest, scientific or historical research purposes or statistical purposes in so far as the right to erasure is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
for the establishment, exercise or defense of legal claims.

4) Right to restrict processing

You have the right to restrict processing of your personal data if:

you have contested the accuracy of your personal data, for a period enabling us to verify the accuracy of your personal data;
the processing is unlawful and you oppose the erasure of your personal data and request the restriction of its use instead;
we no longer need the personal data for the purposes for which they were collected, but they are required by you for the establishment, exercise or defense of legal claims
you have objected to the processing of your personal data pursuant to paragraph 5) below, pending the verification whether our legitimate grounds override those of yours.

Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defense of legal claims, for the protection of the rights of another natural or legal person, or for reasons of important public interest of the EU or of a Member State.

5) Right to object to processing

Where personal data is processed based on legitimate interest, you have the right to object, at any time, to the processing of your personal data, on grounds relating to your particular situation.

6) Right to data portability

Where personal data is processed based on your consent or in order to perform a contract, you have the right to receive the personal data in our possession or control in a structured, commonly used and machine-readable format, and have the right to transmit that data to another data controller without hindrance from us. You also have the right to have your personal data transmitted directly from us to another data controller, where technically feasible.

7) Right to withdraw your consent

You have the right to withdraw any consent to data processing at any time. Such withdrawal does not affect the lawfulness of processing based on your consent before its withdrawal. The costs incurred by Data Controller due to such withdrawal of consent shall be borne by you.

8) Rights related to automated decision making including profiling

No automated decision making is carried out based on your data.

9) Right to lodge a complaint with a supervisory authority & the right to an effective judicial remedy

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the data processing infringes the GDPR.

The supervisory authority having jurisdiction in the Member State where the Data Controller is established:

Name: National Authority for Data Protection and Freedom of Information
(Nemzeti Adatvédelmi és Információszabadság Hatóság)
Address: Falk Miksa u. 9-11; 1055 Budapest; Hungary
E-mail: [email protected]

Without prejudice to any administrative or non-judicial remedy, including submitting a complaint directly to us in accordance with Section VI. ‘ACCOUNTABILIY’, you have the right to an effective judicial remedy before the courts of the Member State where the Data Controller or data processor is established, or, alternatively, where you have your habitual residence.

V. DATA SECURITY

The Data Controller takes appropriate technical and organizational security precautions to protect your personal data against manipulation, loss and destruction, as well as against access by unauthorized third parties, and to ensure the protection of your rights and adherence to the applicable data protection laws and regulations. However, you are kindly reminded that the internet is an open, global network. When you transmit personal data to us via the internet, you are deemed to accept the unavoidable risks associated therewith. Despite the technical and organization security measures implemented by the Data Controller, data can get lost or be intercepted and/or manipulated by unauthorized third parties. WE DECLINE ALL LIABILITY RELATING TO LOSS OR CORRUPTION OF YOUR PERSONAL DATA DUE TO SUCH LOSS, INTERCEPTION AND/OR MANIPULATION OF YOUR DATA, AND ANY CONSEQUENCE THEREOF, unless we have breached the standards of care required of data controllers in the EU.

VI. ACCOUNTABILITY

For queries and complaints relating to our processing of your personal data or this Privacy Policy in general, please contact us at the following e-mail address: [email protected].

Effective as of: 8 February 2024