Privacy Policy

In accordance with Article 13 of the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter: GDPR), the Hungarian Association of Pharmaceutical Wholesalers (hereinafter: HAPW) informs you about the processing of your personal data that occurs during the use of the website and in the contacting processes.

I. Name and contact details of the Data Controller

The HAPW processes your personal data when you use the website and when you contact us using the contact details provided on the website.

The contact details of the HAPW:

Hungarian Association of Pharmaceutical Wholesalers

Address: H-1143 Budapest, Stefánia út 28/a.
email: gynsz@gynsz.hu
website: www.gynsz.hu
phone: +36 1 785 1988 

II. Name and contact details of the Data Protection Officer

Under Article 37 of the GDPR, the HAPW is not obliged to appoint a Data Protection Officer.

III. Information on data processing

1. Use of the website for information purposes

By default, when you visit the HAPW website, the website’s web server in Hungary saves the IP address of the internet service provider you use to access the website, the website from which you accessed the website, and the files you accessed through the website, as well as the date of your visit and general information about your browser.

These data are processed in order to deliver the content you have requested via the website, and is also necessary for the security of the web server and to optimize the outgoing data for the appropriate receiving device (e.g. phone, laptop, or other device). These data are analyzed in an anonymized form for statistical purposes only.

The legal basis for this processing is the weighing of interests, i.e. the processing is necessary for the purposes of the legitimate interests pursued by the HAPW (Article 6(1)(f) GDPR). We have a legitimate interest in providing the content of the website you request and in ensuring the security of the IT infrastructure used to operate the website.

The data are stored in server log files in a format that allows identification of the data subjects for no more than 30 days, unless a security incident (e.g. DDoS attack) occurs. In the event of a security incident, the server log files are stored until the security incident is over and the problem is completely resolved.

Please note that in addition to the above, you have the possibility to visit the HAPW website anonymously without revealing your identity (see the chapter Cookies).

When visiting the website for informational purposes, your data are addressed to TotalStudio Kft., a hosting provider acting as a data processor for HAPW, located in the EU (Hungary).

No personal data will be transferred to third country recipients in connection with the use of this website and no wholly automated individual decision-making will be carried out in relation to these data.

2. Contact via the contact details on the website

When contacting us, the HAPW may process the following personal data, depending on the form of contact, in order to respond to your request or problem, provided that you have given those: first name, last name, email address/telephone number, as well as the subject and content of your request.

The information you provide will be processed in order to manage your request. The information may also be stored for evidentiary purposes, where appropriate, in order to assert, exercise, or defend against a legal claim or to comply with mandatory legal retention periods, including in particular obligations to retain accounting legal documents.

The provision of the above data is not a legal obligation, is not based on a contractual obligation, and is not a prerequisite for the conclusion of a contract. However, without the data necessary for contact and for understanding and processing your request, your request cannot be processed and transmitted to the appropriate person.

The legal basis for the processing of personal data depends on your request, whether it is for the purposes of a contract with you or for taking pre-contractual measures (Article 6(1)(b) GDPR), your consent (Article 6(1)(a) GDPR and Article 9(2)(a) GDPR) or the legitimate interest of the HAPW to provide you with adequate information based on weighing interests (Article 6(1)(f) GDPR).

Please note that by contacting us, you consent to the processing of the personal data you provided during the contact process in order to process your request.

In the case of processing based on your consent your data will continue to be processed until your consent is withdrawn or, where processing is based on weighing interests, until you object or until your request is fulfilled.

The data will be stored for evidentiary purposes in the interest of asserting, exercising, or defending against a legal claim, for a period of five years from the end of the year in which the data were provided or, in the case of litigation, until the dispute is resolved.

In addition to the above, the data will also be retained where required by law, including in particular obligations to retain accounting legal documents. Depending on the type of document, the mandatory retention period for legal accounting documents may be 8 years.

Your personal data will only be transferred to other recipients if this is necessary to fulfil your request. The communication may only take place between HAPW member organizations (https://www.gynsz.hu/en/about-hapw/member-companies/), for example in order to provide the written information requested.

In addition to the above, data may also be transferred to third parties in the following cases:

• in accordance with legal provisions, data may be disclosed to third parties, bodies, courts, or authorities, at their express request, in order to comply with our legal obligations.
• to lawyers, other third parties, bodies, courts, or public authorities, if necessary to protect the rights, property, or safety of employees, member companies, or the HAPW.

No personal data will be transferred to third country recipients in connection with contact.

No automated, individual decision-making may take place when processing the request.

IV. Persons entitled to access the data

1. As a data processor, when you visit the website for information purposes

a, the operator and maintainer of the website and its hosting service provider on the basis of and subject to a data processing agreement between the parties (IP address, browsing time, content visited): Total Studio Kft. H-1043 Budapest, Kassai u. 11. IV/24.; Email: info@totalstudio.hu
b, the provider of the website’s hosting IT structure, on the basis of and during term of the service contract (IP address, browsing time, content visited): MODIT Informatikai és Szolgáltató Zrt. (H-1021 Budapest, Hűvösvölgyi út 54.)

2. If contacted, depending on the request, a member organization of HAPW, as data processor: https://www.gynsz.hu/en/about-hapw/member-companies/

V.Newsletter and social media

Newsletter

In order for the HAPW to provide you with information about its activities, current news, and information materials, you can subscribe to the newsletter on the HAPW website.

Your name, email address, and place of work will be provided when you subscribe to the newsletter on the website.

The provision of the above data is not a legal obligation, is not based on a contractual obligation, and is not a prerequisite for the conclusion of a contract.

The legal basis for processing your personal data is your consent (Article 6(1)(a) GDPR). Your data will be processed until your consent is withdrawn, which you can do both on the website and via the link in the newsletter.

MailerLite Limited (Ground Floor, 71 Lower Baggot Street, Dublin 2, D02 P593, Ireland) acts as data processor in the provision of the MailerLite newsletter platform. Momentum Communications Ltd. (H-1145 Budapest, Tallér utca 24.) acts as an administrator for the online delivery of newsletters.

Please note that for the MailerLite service, your data will be stored on a server within the EU. For more information about MailerLite's data management, please click on the link below: 

https://www.mailerlite.com/legal/privacy-policy

Social media

The HAPW is present on some social media platforms (Facebook, LinkedIn) and offers users the opportunity to communicate with it on these platforms.

In addition to this Privacy Policy, the terms of use and privacy policies of the relevant social media apply to the processing of data of persons who follow HAPW on facebook.com or linkedin.com or connect to HAPW through social media. Users are already aware of and have accepted these terms and conditions in order to communicate or contact you on the social networking site.

Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland) and Linkedin Ireland Unlimited Company (Wilton Place, Dublin 2, Ireland) are the joint data controllers for the presence and communication involving the social media platforms. The rules on joint data processing are available via the link below:

https://www.facebook.com/legal/terms/page_controller_addendum

As data processor, Momentum Communications Kft. (H-1145 Budapest, Tallér utca 24.) collaborates in publishing content on social media platforms. 

VI. Your rights as a data subject

Requests may be submitted to the HAPW to obtain

a) access to your personal data (Article 15 GDPR). In this context, you have the right to be informed whether your personal data are being processed, to obtain access to and a copy of the personal data processed, and to obtain information relevant from a data protection point of view (e.g. categories of recipients, retention period, guarantees for transfers to third countries, etc.).

b) rectification of your personal data (Article 16 GDPR). You can request the correction of incorrect data or the completion of incomplete data.

c) the erasure of your personal data (Article 17 GDPR).

d) or the restriction of its processing (Article 18 GDPR).

You may withdraw your consent at any time. Your consent is the legal basis for the processing of data during contact. Please note that you have the right to withdraw your consent at any time, without prejudice to the lawfulness of the processing up to the time of withdrawal.

You can submit your request for exercising these rights to the HAPW using the contact details provided above. The HAPW will comply with your request as soon as possible, but within no more than 10 days at the latest, and will inform you of the action taken or the reasons for refusing to comply with the request.

Right to file a complaint: You have the right to file a complaint at the Hungarian National Authority for Data Protection and Freedom of Information (H-1055 Budapest, Falk Miksa u. 9-11; website: naih.hu; email: ugyfelszolgalat@naih.hu; phone: + (36)-1-391-1400).

Use of court proceedings: If your rights have been violated, you may turn to a court of law against the HAPW. The regional court has jurisdiction to hear the case. You can also choose to bring the case before the court with jurisdiction at your place of residence.

VII. Cookies

1. What are cookies?

Cookies are text files that are stored on a computer or other end-user device. The use of cookies helps us to analyze the use of the website, improve the services and content offered, increase security, and prevent fraud. The following cookies can be distinguished:

• Session cookies are temporary cookies that are automatically deleted when you close your browser.
• Non-consent cookies are cookies whose sole purpose is to transmit a message over an electronic communications network or which are necessary to enable the service provider to provide a service specifically requested by the participant or user has (“strictly necessary cookies”).
• Consent cookies are cookies that can be used for purposes other than those described above. Cookies can be used for different purposes.

2. Cookies used by the HAPW

The website uses three different types of cookies:

a) Strictly necessary cookies

These cookies are necessary to provide essential services on the webpages. Without the use of these cookies, the website’s functions may be significantly limited or may be faulty. These essential cookies help make the website usable by enabling basic features such as site navigation and access to secure areas of the website. The website cannot function properly without these cookies.

b) Technical cookies (preference cookies)

Technical cookies allow the site to remember your previous preferences (such as the language you used). If you do not consent to the use of these cookies, it may lead to certain features not working properly.

c) Statistical cookies

Statistical cookies allow analyses to be performed regarding the use of the website. If you have not given your consent for your personal data to be used for this purpose, it will be used anonymously. The analysis helps to improve the services and content provided by the HAPW.

When you visit this site, you may choose to allow the use of the following cookies:

 

Manage cookie preferences

Cookie Settings

 

Cookie Policy Generated By CookieYes - Cookie Policy Generator.

3. Consent to the use of cookies, cookie settings

Where it is strictly necessary for the functioning of the site, the HAPW may store cookies on your device (“strictly necessary cookies”). Your consent is required for the use of all other types of cookies.

If your consent is required for the use of certain cookies, the HAPW will only start using these cookies during your visit to the site after you have given your prior consent.

When you visit the website, you will see a cookie banner, where you can click to give your consent to the use of cookies on this website. By clicking on the button, you have the opportunity to consent to the use of all cookies as described in detail above. You also have the option to click on the “cookie dashboard”, where you can choose which cookies to accept. You will have the opportunity to change your individual choices in the future on the website’s “Privacy policy page”.

On some pages, personal data may be stored using cookies if you have previously given your explicit consent, in which case, for example, you do not need to provide your access data again. As a general rule, you can access all the information on this website even if you have turned off cookies in your internet browser. However, if you do not accept cookies, the content may suffer from functional limitations.

The use of strictly necessary cookies cannot be turned off using the cookie manager on the website. However, as a general setting you can disable these cookies in your browser at any time.

You can also manage cookies using the settings in your browser. Cookie preferences can be set in different ways in different browsers. The cookie settings for the most commonly used browsers are available below:

Internet Explorer: 

https://support.microsoft.com/hu-hu/help/17442/windows-internet-explorer-delete-manage-cookies;

Mozzilla Firefox:

https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Google Chrome: 

https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=hu)

You can find more detailed information on this topic on the following websites, among others: 

http://www.allaboutcookies.org; http://www.youronlinechoices.com/hu/

However, please take into account that certain features on the website may not function properly or at all if you disable cookies in your browser.

4. The use of web analytics technology: Google Analytics

With your consent, the following web analytics procedures will be used by the HAPW to record and analyze user activity on the website in order to improve the website and to come closer to achieving the objectives of the site (e.g. to increase traffic to the site).

This website uses Google Analytics, a web analytics tool provided by Google LLC (1600 Amphitheatre Parkway Mountain View, CA 94043, USA; “Google”). Google Analytics helps the HAPW obtain a more accurate picture of the activities of its visitors. The service may use cookies to collect information and use the statistical data pertaining to the use of the website to prepare a report without individually revealing the identities of the visitors to Google. (See the “Cookies” section above.)

Data used by Google Analytics

- protocol data collected via Hypertext Transfer Protocol (Secure) (HTTP (S)) for technical reasons when using the Google Analytics web analytics tool. These include IP addresses, internet browser type and version, operating system, the website you visited before visiting the website (referring URL), and the date and time of your visit (Google Analytics HTTP data);

- data stored in cookies on the user's device for the Google Analytics web analytics tool. This includes, in particular, unique visitor identifiers (Google Analytics cookie data) used to recognize returning visitors;

- data stored in pseudonymized user profiles generated by the Google Analytics web analytics tool. These are data relating to the use of the website, in particular the number of visits to the site, the frequency of visits, and the time spent on the pages visited. These data are generated independently (Google Analytics profile data).

On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity, and providing other services relating to website activity and internet usage for website operators. IP addresses are used by Google Analytics to determine the geographical location of visitors and to protect the service itself.

The data used by Google Analytics are generally stored on Google server in the United States in an anonymized way.

Google acts as data processor when transferring the above data to Google. Google is based in the United States and is certified under the EU-US Privacy Shield:

 https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.

The EU Commission’s current compliance decision on the EU-US Privacy Shield: 

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32016D1250

Your IP address is anonymized on the web server before being transmitted to Google. In exceptional cases, your full IP address may be sent to a Google server in the United States, where it is then anonymized. The retention period for other Google Analytics HTTP data is 14 months. For information on the retention period of Google Analytics cookies, see the section “Cookies” above. Google Analytics profile data are stored for 14 months.

The anonymized IP address provided by Google Analytics in the context of Google Analytics will not be merged with other data from Google.

The legal basis for this processing is Article 6(1)(a) of the GDPR (consent).

 You can prevent cookies from being stored by setting your browser software appropriately; however, please note that if you do so, you will not be able to use all the features of the website to their fullest extent. You can prevent data collection by Google Analytics by clicking the link below. In this case, an opt-out cookie will be used to prevent the collection of your data when you visit this site in the future:

http://tools.google.com/dlpage/gaoptout?hl=de.

More information about the Terms of Use and data protection is available on Google's website at https://policies.google.com.

Please note that on this website, Google Analytics has been enhanced with the code "anonymizeIp" to ensure the anonymous collection of IP addresses (IP masking).

The provision of the above data is not a legal obligation, is not based on a contractual obligation, and is not a prerequisite for the conclusion of a contract. However, without this data, we are not able to perform web analytics using Google Analytics.

No automated decision-making is carried out on this data. 

VIII. Use of social media links on the website

The website includes links to the social media platforms of the HAPW.

Although the HAPW does not transmit personal data to either Meta Platforms Ireland Limited (Facebook) or LinkedIn Ireland Unlimited Company (LinkedIn), the two social media platforms may place cookies on the computers of visitors to the website in connection with links on the website.

The HAPW may transmit the personal data mentioned above to MailerLite, in connection with which the newsletter provider may place cookies on the subscribers’ computers.

These third-party cookies are called marketing cookies and are used to improve the usability of the website and to better target advertisements using web analytics methods.

Facebook cookie policy: https://www.facebook.com/policies/cookies/

LinkedIn cookie policy: https://www.linkedin.com/legal/cookie-policy

MailerLite cookie policy: https://www.mailerlite.com/legal/cookie-policy

In addition, the information in point VII above also applies to the use of social media links.

 IX. Scope and amendment of the Privacy Policy

This Privacy Policy applies solely to the use of this website. It does not apply to websites of other service providers that are accessible through links on the website. The HAPW is not responsible for statements and guidelines of third parties that are not related to the website.

The HAPW reserves the right to amend this Privacy Policy from time to time to reflect future changes in the collection and processing of personal data.