PRIVACY POLICY

  1. INTRODUCTION

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation, hereinafter: the Regulation) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, as well as repealing Directive 95/46/EC, we provide the following information.

The obligation to provide prior information to the data subject is also required by Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information (Infotv.) and the recommendation of the National Authority for Data Protection and Freedom of Information (NAIH) entitled “Requirements for Prior Information” (hereinafter: Recommendation).

This Privacy Notice serves to comply with our statutory obligations and Pandan regulates the data processing activities carried out on the Pandan website.

The Privacy Notice is available at the following link: Privacy policy - Pandan

Any amendments to this Notice shall take effect upon publication at the above address.  

DATA CONTROLLER AND CONTACT DETAILS

Name: PANDAN Plastic Processing and Environmental Technology Ltd.
Registered Office: 9771 Balogunyom, Zrínyi Street 37. Building A.
E-mail: info@pandanpack.hu
Phone: +36 94 556 042 

  1. DEFINITIONS
    1. “personal data”: any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
    2. “processing”: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, alteration or modification, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
    3. “controller”: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of processing personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
    4. "processor": a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
    5. “recipient”: a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether or not a third party. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall comply with the applicable data protection rules according to the purposes of the processing.
    6. “data subject’s consent”: any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
    7. “personal data breach”: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
    8. Special categories of data

Special data: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, and personal data concerning a natural person’s sex life or sexual orientation.

Genetic data: personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person and which result, in particular, from an analysis of a biological sample from the natural person in question.

Biometric data: personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person which allow or confirm the unique identification of that natural person (e.g. facial images or dactyloscopic data).

Health data: personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status.

  1. Profiling and automated decision-making

Profiling: any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests or behaviour.

Automated decision-making: decisions based solely on automated processing, including profiling.

  1. Pseudonymisation:

the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure non-attribution.

 

  1. PRINCIPLES RELATING TO THE PROCESSING OF PERSONAL DATA

Personal data must be:
a) processed lawfully, fairly and in a transparent manner in relation to the data subject (“lawfulness, fairness and transparency”);
b) collected for specified, explicit and legitimate purposes and not further processed in a manner incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered incompatible with the initial purposes (“purpose limitation”);
c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (“data minimisation”);
d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (“accuracy”);
e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as they are processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1), subject to the implementation of appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (“storage limitation”);
f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (“integrity and confidentiality”).

The controller shall be responsible for, and be able to demonstrate compliance with, the above principles (“accountability”).

 

  1. DATA PROCESSING ACTIVITIES  
    4.1. Data Processing Related to the Operation of the Website
    1. Facts of Data Collection, Scope of Processed Data and Purpose of Processing 

Personal data

Purpose of Processing

Full name

Necessary for contacting the data subject, completing a purchase, and issuing a legally compliant invoice

E‑mail address

Communication

Telephone number

Communication; efficient coordination regarding invoicing or delivery

Billing name and address 

Issuing a lawful invoice; establishing, defining, modifying and monitoring the performance of the contract; invoicing fees arising from the contract; enforcing related claims

Billing name and address 

Necessary for fulfilling the contract / order

 

  1. Data Subject Rights Regarding Data Processing 
  • The data subject may request access to the personal data concerning them, as well as rectification, erasure or restriction of processing;
  • object to the processing of such personal data;
  • exercise the right to data portability; withdraw consent at any time.

The data subject may initiate access, erasure, modification, restriction of processing, data portability or objection to data processing through the following channels:

  • by post: 9771 Balogunyom, Zrínyi út 37/A
  • by e‑mail: info@pandanpack.hu e-mail address
  • by phone

 

  1. DATA PROCESSORS ENGAGED  
    5.1. IT Service Provider of Our Company

For the maintenance and operation of our website, our company uses a data processor who provides IT services (hosting services) and, as part of this activity, processes the personal data provided on the website. The operation performed by the processor is the storage of personal data on the server.

Name: Websupport Magyarország Kft.

Registered office: 1119 Budapest, Fehérvári út 97-99.

Company Registration Number: 01-09-381419

Tax number: 10713796-2-18

Phone: +36 1 700 2323

E-mail: info@mhosting.hu

5.2. Postal Services, Delivery, Parcel Shipment

  1. Activity performed by the data processor: Delivery of products, transportation
  2. Name and contact details of the data processor: 
  1. Processed data: shipping name, shipping address, telephone number, e‑mail address.
  2. Scope of Data Subjects: All data subjects requesting delivery.
  3. Purpose of Data Processing: Home delivery of the ordered product.
  4. Duration of Data Processing and Deadline for Data Deletion: Processing continues until the delivery process is completed.
  5. Legal Basis for Processing: Article 6(1)(b) of the GDPR (performance of a contract).

 Rules on the Processing of Special Categories of Personal Data The company does not collect, record or process special categories of personal data. Therefore, processing such data may only occur in exceptional cases and exclusively under the supervision of the Data Protection Officer. Special categories of personal data may only be collected after the data subject has been properly informed, including information specifically referring to the rules governing such data. The data subject’s consent must be explicit and specific, and must clearly indicate that the above information has been provided and that the data subject grants consent with this understanding. Special categories of personal data collected must be handled separately and stored securely.

 

  1. COOKIE MANAGEMENT

 The website visitor must be informed on the website about the use of cookies and their consent must be requested - with the exception of technically necessary session cookies.

  1. The fact of data processing, the scope of data processed: Unique identification number, dates, times
  2. Scope of data subjects: All data subjects who visit the website.
  3. Purpose of data processing: Identifying users and tracking website visitors.
  4. Duration of Data Processing and Deadline for Data Deletion:
  • Cookie type: Session cookies
  • Legal basis for data processing: Act CVIII of 2001 on certain issues of electronic commerce services and information society services (Elkertv.) Section 13/A (3)
  • Duration of data processing: The period until the end of the relevant visitor session
  1. Potential data controllers authorized to view the data: The data controller does not process personal data using cookies.
  2. Description of the data subjects' rights regarding data processing: The data subject has the option to delete cookies in the Tools/Settings menu of the browser, usually under the settings of the Privacy menu item.

Delete cookies for the following browsers according to the information in the link marked next to them.
Please note: the browsers listed below - as well as those that are even less well-known or will be released in the future - are constantly updated, so it is recommended to visit the service provider to assess the current settings options and to familiarize yourself with their data protection policies! 

Mozilla: https://support.mozilla.org/hu/kb/weboldalak-altal-elhelyezett-sutik-torlese-szamito

Google Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.PlatformDesktop&hl=hu

Microsoft Edge: https://support.microsoft.com/hu-hu/help/4027947/windows-delete-cookies

Opera: http://help.opera.com/Windows/10.20/hu/cookies.html

Safari (iOS systems): https://support.apple.com/hu-hu/HT201265

 

Cookies are also processed by:

Google: https://policies.google.com/technologies/cookies

LinkedIn: Cookie Policy | LinkedIn

Facebook: https://hu-hu.facebook.com/policies/cookies/

 

  1. USING GOOGLE ANALYTICS

 

  1. This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses so-called “cookies”, text files that are saved on your computer, to help the website operator analyze how users use the website.
  2. The information generated by the cookie about the website used by the User is usually transmitted to and stored on a Google server in the USA. By activating IP anonymization on the website, Google will shorten the User's IP address beforehand within member states of the European Union or in other states party to the Agreement on the European Economic Area.
  3. The full IP address will only be transmitted to a Google server in the USA and shortened there in exceptional cases. On behalf of the operator of this website, Google will use this information to evaluate how the user uses the website, to compile reports on website activity for the website operator and to provide other services relating to website and internet usage. 
  4. Within the framework of Google Analytics, the IP address transmitted by the User's browser will not be merged with other data held by Google. The User can prevent the storage of cookies by setting their browser accordingly, but please note that in this case not all functions of this website may be fully usable. You can also prevent Google from collecting and processing the data generated by cookies and relating to your use of the website (including your IP address) by downloading and installing the browser plugin available at the following link. https://tools.google.com/dlpage/gaoptout?hl=hu

 

  1. COMMUNITY SITES
    1. The fact of data collection, the scope of data processed: the user's registered name on LinkedIn/Facebook/Google social networking sites and their public profile picture.
    2. Scope of data subjects: All data subjects who have registered on LinkedIn/Facebook/Google social media sites and have "liked" the website.
    3. Purpose of data collection: Sharing, "liking" and promoting certain content elements, products, promotions or the website itself on social media.
    4. Duration of data management, deadline for data deletion, possible data controllers authorized to view the data and description of the data subjects' rights related to data management: The data subject can find out about the source of the data, its management, the method of transfer and its legal basis on the given social media site. Data management is carried out on social media sites, so the duration, method of data management and the possibilities for deleting and modifying data are subject to the regulations of the given social media site.
    5. Legal basis for data processing: the data subject's voluntary consent to the processing of their personal data on social media sites.

 

  1. CUSTOMER RELATIONS AND OTHER DATA PROCESSING

 

  1. If the data controller has any questions or problems while using our services, the data subject can contact the data controller via the methods provided on the website (telephone, e-mail, social media, etc.).
  2. The data controller deletes the data received in emails, messages, telephone calls, etc., together with the name and email address of the interested party, as well as other voluntarily provided personal data, no later than 2 years after the data was disclosed.
  3. We will provide information about data processing not listed in this information when the data is collected.
  4. In the event of an exceptional official request or a request from other bodies based on legal authorization, the Service Provider is obliged to provide information, communicate and transfer data, or make documents available.
  5. In these cases, the Service Provider will only provide the requester with personal data to the extent and insofar as it is absolutely necessary to achieve the purpose of the request, provided that the requester has indicated the precise purpose and scope of the data.

 

  1. RIGHTS OF THE DATA SUBJECTS

 

  1. Right of access

You have the right to receive feedback from the controller as to whether your personal data is being processed and, if such processing is taking place, you have the right to access the personal data and the information listed in the regulation.

  1. The right to rectification

You have the right to request that the controller rectify inaccurate personal data concerning you without undue delay. Taking into account the purpose of the processing, you have the right to request that incomplete personal data be completed, including by means of a supplementary statement.

  1. The right to erasure

You have the right to request that the controller erase your personal data without undue delay, and the controller is obliged to erase your personal data without undue delay under certain conditions.

  1. The right to be forgotten

Where the controller has made the personal data public and is obliged to erase them, the controller, taking into account available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform the controllers processing the data that you have requested the erasure of links to the personal data in question or of copies or replications of those personal data.

 

  1. Right to restriction of data processing

You have the right to request that the data controller restrict data processing if one of the following conditions is met:

  • You contest the accuracy of the personal data, in which case the restriction shall apply for a period of time that allows the controller to verify the accuracy of the personal data;
  • the processing is unlawful and you oppose the erasure of the data and instead request the restriction of its use; 
    the data controller no longer needs the personal data for the purposes of data processing, but you require them for the establishment, exercise or defence of legal claims;
  • You have objected to the processing; in this case, the restriction applies for a period of time until it is determined whether the legitimate grounds of the controller override your legitimate grounds.
  1. The right to data portability

You have the right to receive the personal data concerning you, which you have provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to whom you have provided the personal data.

  1. The right to protest 

You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data, including profiling based on the aforementioned provisions.

  1. Objection to direct marketing

If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such purposes, including profiling, insofar as it is related to direct marketing. If you object to the processing of your personal data for direct marketing purposes, your personal data will no longer be processed for such purposes.

  1. Automated decision-making in individual cases, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. The previous paragraph shall not apply if the decision:

  • Necessary for the conclusion or performance of a contract between you and the data controller;
  • Necessary for the conclusion or performance of a contract between you and the data controller;
  • It is based on your express consent.

 

  1. ACTION DEADLINE

The data controller will inform you of the measures taken in response to the above requests without undue delay, but in any case within 1 month of receipt of the request.

If necessary, this can be extended by 2 months. The data controller will inform you about the extension of the deadline within 1 month of receiving the request, indicating the reasons for the delay. 

If the controller does not take action on your request, it shall inform you without delay, but no later than one month from the date of receipt of the request, of the reasons for the failure to take action and of the possibility of lodging a complaint with a supervisory authority and of exercising your right to a judicial remedy.

 

  1. SECURITY OF DATA PROCESSING

The controller and the processor shall implement appropriate technical and organizational measures to ensure a level of data security appropriate to the risk, taking into account the state of the art and the costs of implementation, the nature, scope, circumstances and purposes of the processing, and the varying likelihood and severity of the risk to the rights and freedoms of natural persons, including, where appropriate:

  • pseudonymization and encryption of personal data;
  • ensuring the continued confidentiality, integrity, availability and resilience of systems and services used to process personal data;
  • the ability to restore access to and availability of personal data in a timely manner in the event of a physical or technical incident;
  • a procedure for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures taken to guarantee the security of data processing.

 

  1. INFORMING THE DATA SUBJECT ABOUT THE DATA PROTECTION INCIDENT

 

If the data breach is likely to result in a high risk to the rights and freedoms of natural persons, the controller shall inform the data subject of the data breach without undue delay.

The information provided to the data subject must clearly and intelligibly describe the nature of the data protection incident and provide the name and contact details of the data protection officer or other contact person who can provide further information; describe the likely consequences of the data protection incident; describe the measures taken or planned by the data controller to remedy the data protection incident, including, where applicable, measures aimed at mitigating any adverse consequences resulting from the data protection incident.

The data subject does not need to be informed if any of the following conditions are met:

  • the controller has implemented appropriate technical and organisational protection measures and these measures have been applied to the data affected by the data breach, in particular measures – such as the use of encryption – that make the data unintelligible to persons not authorised to access the personal data;
  • the data controller has taken further measures following the data protection incident to ensure that the high risk to the rights and freedoms of the data subject is no longer likely to materialise;
  • information would require a disproportionate effort. In such cases, the data subjects should be informed by means of publicly published information or a similar measure should be taken to ensure that the data subjects are informed in a similarly effective manner.

If the data controller has not yet notified the data subject of the data breach, the supervisory authority may, after considering whether the data breach is likely to involve a high risk, order the data subject to be informed.

REPORTING A DATA PROTECTION INCIDENT TO THE AUTHORITY

The controller shall notify the personal data breach to the supervisory authority competent pursuant to Article 55 without undue delay and, where feasible, not later than 72 hours after having become aware of the personal data breach, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. If the notification is not made within 72 hours, it shall be accompanied by reasons justifying the delay.

 

  1. COMPLAINT POSSIBILITY

 

A complaint against a possible violation of the data controller can be filed with the National Data Protection and Freedom of Information Authority:

National Data Protection and Freedom of Information Authority
1055 Budapest, Falk Miksa utca 9-11.
Mailing address: 1363 Budapest, Pf. 9.
Phone: +36 -1-391-1400
Fax: +36-1-391-1410
E-mail: ugyfelszolgalat@naih.hu

 

  1. CONCLUSION

 

When preparing this information, we took into account the following legislation:

  • 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 Regulation 95/46/EC (General Data Protection Regulation)
  • Act CXII of 2011 – on the right to informational self-determination and freedom of information (hereinafter referred to as the Information Act)
  • Act CVIII of 2011 – on certain issues of electronic commerce services and services related to the information society (mainly Section 13/A)
  • Act XLVII of 2011 – on the prohibition of unfair commercial practices against consumers;
  • Act XLVIII of 2011 – on the basic conditions and certain limitations of economic advertising activities (especially Section 6)
  • Act XC of 2011 on Electronic Freedom of Information
  • Act C of 2011 on electronic communications (specifically Section 155)
  • Opinion No 16/2011 on the EASA/IAB Recommendation on best practice in online behavioural advertising
    – Recommendation of the National Data Protection and Freedom of Information Authority on the data protection requirements for prior information
  • 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 Regulation 95/46/EC

 

 

Last modified: February 19, 2026.

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