Terms and Conditions

Introduction

The contract concluded on the basis of this document is not recorded (it is not accessible retrospectively). It is concluded exclusively in electronic form, does not constitute a written contract, is drafted in English, and does not refer to any code of conduct. If you have any questions regarding the operation of the webshop or the ordering process, please contact us using the contact details provided.

These General Terms and Conditions also apply to the contractual relationships of the Provider’s website (https://zulupack.shop) and its subdomains.

These “General Terms and Conditions” are available on the following website: https://zulupack.shop/shop_help.php?tab=terms

Definitions

User: Any natural person, legal entity, or organization using the services of the Service Provider and entering into a contract with the Service Provider.

Consumer: A User who is a natural person acting outside the scope of their profession, independent occupation, or business activity.

Business: A person engaged in a profession, independent occupation, or business activity.

Provider: A natural person, legal entity, or organization without legal personality that provides information society services, provides services to the User, and concludes contracts with the User.

Service Provider Name: Walking Sage Kft.

Registered Office (and official place for submitting claims):
2030 Érd, Festő u. 86/1., Hungary

Provider’s contact details and the regularly used e-mail address for contacting users:
info@walkingsage.hu

Company Registration Number: 13-09-161726

Tax Number: 24247757-2-13

Name of the Registration Authority:
Company Court of the Budapest Surrounding Regional Court (Budapest Környéki Törvényszék Cégbírósága)

Telephone Number: +36-70-507-4440

Language of the Contract: English

Name and Address of the Domain Provider

UNAS Online Kft.
9400 Sopron, Kőszegi út 14., Hungary

E-mail: unas@unas.hu
Telephone: +36-99/200-200

2.1. Matters not regulated in these present Terms and Conditions, as well as the interpretation of these Terms, shall be governed by Hungarian law, with particular regard to the provisions of Act V of 2013 of the Hungarian Civil Code (“Civil Code”), Act CVIII of 2001 on certain aspects of electronic commerce services and information society services (“E-Commerce Act”), and Government Decree 45/2014 (II. 26.) on the detailed rules of contracts between consumers and businesses. The mandatory provisions of the relevant legislation shall apply to the Parties without the need for any separate stipulation.

2.2. These Terms and Conditions have been effective since 31 August 2022 and shall remain in force until revoked. The Service Provider reserves the right to amend these Terms unilaterally (circumstances giving rise to amendments may include changes in shipping costs, legislative changes, business interests, or changes within the company). The Service Provider shall publish the amendments on its website at least 11 (eleven) days before they enter into force. During this period, the User is entitled to withdraw from or terminate the contract. By using the website, the User agrees that all regulations relating to the use of the website shall automatically apply to them.

2.3. The Service Provider reserves all rights relating to the content and distribution of the website and its webpages. Downloading, storing (electronically), processing, or selling the content published on the website, or any part thereof, is strictly prohibited without the prior written consent of the Service Provider.

3.1. The User is obliged to provide their real and accurate data at the time of purchase/registration. In the event of providing false data or another person’s personal data during the purchase/registration process, the resulting electronic contract shall be deemed invalid. The Service Provider excludes all liability if the User uses its services in another person’s name or using another person’s data.

3.2. The Service Provider shall not be liable for delivery delays or any other problems or errors resulting from incorrect and/or inaccurate data provided by the User.

3.3. The Service Provider shall not be liable for any damages arising from the User forgetting their password or from unauthorized persons gaining access to it for any reason not attributable to the Service Provider (provided that the User is registered on the website).

4.1. The products displayed may only be ordered online. The prices displayed for the products are in EUR and include the statutory VAT. However, the costs of home delivery are not included in the displayed prices. No separate packaging fee will be charged.

4.2. In the webshop, the Service Provider indicates the name, description, and details of the product. The images displayed on the product data sheet may differ from the actual product and may serve illustrative purposes only.

4.3. If a product is offered at a discounted price, the Service Provider shall inform the User about the promotion and its exact duration.

4.4. If, despite the Service Provider’s due care, an incorrect price is displayed on the website and the price is obviously erroneous, the Service Provider shall not be obliged to confirm the order at the incorrect price, especially where there is a significant discrepancy. For example, in the case of a system error resulting in a price of EUR 0 or EUR 0.01, the Service Provider is not obliged to deliver the product at the incorrect price, but may instead offer delivery at the correct price, upon becoming aware of the error. In such a case, the Customer may refuse to proceed with the purchase. According to Hungarian judicial practice, a substantial discrepancy is generally considered to be a deviation of at least 50% above or below the market value of the given product or service. Consumers are hereby informed, however, that the concept of a “gross disparity in value” (Section 6:98 of the Civil Code) is not precisely defined by law.

4.5. In the event of an incorrect price as described in Section 4.4, there is a noticeable discrepancy between the actual and the displayed price of the product, which is immediately apparent to the average consumer. Pursuant to Act V of 2013 on the Civil Code (“Civil Code”), a contract is concluded through the mutual and unanimous expression of the parties’ intent. If the parties cannot agree on the contractual terms, meaning there is no mutual and concordant declaration of intent, no valid contract can be deemed to exist from which rights and obligations would arise. On this basis, an order confirmed at an incorrect/erroneous price shall be considered null and void.

5.1. After registration, the User may log in to the webshop or start shopping without registration.

5.2. The User selects the quantity of the products to be purchased.

5.3. The User places the selected products into the shopping cart. Users may view the contents of the shopping cart at any time by clicking on the “Cart” icon.

5.4. If the User does not wish to purchase any additional products, they should check the quantity of the products they wish to buy. By clicking the “Delete – X” icon, the contents of the cart can be removed. To modify the quantity, the User must click the “Update Cart” button.

5.5. The User enters the delivery address and then selects the delivery/payment method as follows:

5.5.1. Payment Methods

Online payment by credit card:
The User has the option to pay the total amount of the order online by credit card via the secure payment system used by the financial service provider contracted by the Service Provider.

5.5.2. Shipping Costs for Delivery to Austria, Croatia, Slovakia and Slovenia

GLS Courier Service:

• EUR 3.5 for orders between EUR 0 and EUR 75;

• free of charge for orders above EUR 75.

GLS ParcelShops:

• EUR 3 for orders between EUR 0 and EUR 75;

• free of charge for orders above EUR 75.

5.5.3. Shipping Costs for Delivery to the Czech Republic

GLS Courier Service:

• CZK 93 for orders between CZK 0 and CZK 1950;

• free of charge for orders above CZK 1950.

GLS ParcelShops:

• CZK 80 for orders between CZK 0 and CZK 1950;

• free of charge for orders above CZK 1950.

5.5.4. Shipping Costs for Delivery to Hungary

GLS Courier Service:

• HUF 1,350 for orders between HUF 0 and HUF 30,000;

• free of charge for orders above HUF 30,000.

GLS ParcelShops:

• HUF 1,100 for orders between HUF 0 and HUF 30,000;

• free of charge for orders above HUF 30,000.

Foxpost/Packeta ParcelShops:

• HUF 1,100 for orders between HUF 0 and HUF 30,000;

• free of charge for orders above HUF 30,000.

MPL Courier:

• HUF 1,800 for orders between HUF 0 and HUF 30,000;

• free of charge for orders above HUF 30,000.

MPL ParcelShops:

• HUF 1,100 for orders between HUF 0 and HUF 30,000;

• free of charge for orders above HUF 30,000.

5.5.5. Shipping Costs for Delivery to Poland

GLS Courier Service:

• PLN 17,5 for orders between PLN 0 and PLN 365;

• free of charge for orders above PLN 365.

GLS ParcelShops:

• PLN 15 for orders between PLN 0 and PLN 365;

• free of charge for orders above PLN 365.

5.5.6. Shipping Costs for Delivery to Romania

GLS Courier Service:

• RON 19 for orders between RON 0 and RON 19;

• free of charge for orders above RON 365.

GLS ParcelShops:

• RON 15 for orders between RON 0 and RON 395;

• free of charge for orders above RON 395.

5.6. In the event of any defects or inaccuracies relating to products or prices displayed in the webshop, the Service Provider reserves the right to make corrections. In such cases, the Service Provider shall inform the Customer of the corrected information immediately upon becoming aware of the issue or upon modification. The Customer may then reconfirm the order or withdraw from the contract.

5.7. The total amount includes all costs based on the order summary and confirmation e-mail. The invoice is included in the package. The User is obliged to inspect the package upon delivery in the presence of the courier and, in the event of any damage to the product or packaging, must request a written report. In the event of visible damage, the User is not obliged to accept the package. Any subsequent complaints not documented in an official report shall not be accepted by the Service Provider. Packages are delivered on working days between 8:00 a.m. and 5:00 p.m.

5.8. After entering the required data, the User may submit the order by clicking the “Place Order” button. Before submission, the User has the opportunity to review the entered data again, add comments regarding the order, or communicate other order-related requests via e-mail.

5.9. By placing the order, the User acknowledges that a payment obligation arises.

5.10. Correction of Input Errors:
Before completing the order process, the User may return to the previous step and correct any entered data. Specifically, during the ordering process, the User may review or modify the contents of the shopping cart. If the cart does not contain the desired quantity, the User may enter the desired quantity in the quantity field and click the “Update” button. If the User wishes to remove an item from the cart, they may click the “X – Delete” button. During the ordering process, the User continuously has the possibility to correct or delete entered data.

5.11. After submitting the order, the User/Customer will receive a confirmation e-mail. This e-mail does not constitute the conclusion of a contract. If the confirmation e-mail does not arrive within the expected time frame depending on the nature of the service, but no later than within 48 hours, the User shall be released from the binding offer or contractual obligation. The order and its confirmation shall be deemed received by the Service Provider or the User when they become accessible to the recipient. The Service Provider excludes liability for delayed confirmation if the delay is caused by the User providing an incorrect e-mail address or by the inability to receive messages due to storage limitations of the User’s account.

5.12. The User acknowledges that the confirmation referred to in the previous section is merely an automatic acknowledgment and does not constitute a contract. The contract is concluded when the Service Provider, following the aforementioned automatic confirmation, separately informs the User about the details of the order and its expected fulfillment.

6.1. Orders are processed during business hours. In addition to the stated order processing times, orders may also be placed after business hours, in which case they will be processed on the following working day. The Service Provider’s customer service will always confirm electronically when the order can be fulfilled.

6.2. The general delivery period is 5–7 working days (8–10 working days for international deliveries).

6.3. Under the purchase contract, the Service Provider transfers ownership of the product, and the User pays the purchase price and receives the product.

6.4. If the Seller is a business and the Buyer is a consumer, and the Seller undertakes to deliver the goods to the Buyer, the risk of loss or damage passes to the Buyer when the Buyer or a third party designated by the Buyer takes possession of the goods. The risk passes to the Buyer upon delivery to the courier if the courier was commissioned by the Buyer, unless the courier was recommended by the Seller.

6.5. If the Seller is a business and the Buyer is a consumer, then unless otherwise agreed by the Parties, the Seller (under these Terms and Conditions: the Service Provider) is obliged to make the product available to the Buyer (User) without undue delay following the conclusion of the contract, and no later than within 30 days.

6.6. If the Service Provider fails to provide the product within the agreed time, the User is entitled to set an additional deadline for performance. If the Seller fails to perform within this additional period, the Buyer shall be entitled to withdraw from the contract.

6.7. The User is entitled to withdraw from the contract without setting an additional deadline if:

a) the Service Provider has refused to perform the contract; or

b) according to the agreement of the Parties or the evident purpose of the service, the contract should have been performed at a specific time and not otherwise.

6.8. If the Service Provider is unable to fulfill its contractual obligation because the product or one of its components is unavailable, the Service Provider shall immediately inform the User and promptly refund any amount paid by the User.

7.1. Pursuant to Directive 2011/83/EU of the European Parliament and of the Council and Government Decree 45/2014 (II.26.) on contracts between consumers and businesses, the Consumer may withdraw from the contract without giving any reason within 14 days from the date of delivery and may return the ordered product(s). In the absence of this information, the Consumer shall be entitled to exercise the right of withdrawal within one year. If the Service Provider provides the required information within 14 days from receipt of the product or from the conclusion of the contract, but within 12 months, the withdrawal period shall be 14 days from the date on which such information was communicated.

7.2. The Consumer may exercise the right of withdrawal by means of a clear statement to that effect or by using the model withdrawal form set out in Annex 2 of Government Decree 45/2014 (II.26.).

7.3. The period for exercising the right of withdrawal expires 14 days after the day on which the Consumer, or a third party other than the carrier designated by the Consumer, takes possession of the product.

7.4. The Consumer may exercise the right of withdrawal between the date of conclusion of the contract and the date of receipt of the product.

7.5. The direct cost of returning the product shall be borne by the Consumer. The Company has not undertaken to bear these costs.

7.6. In the event of exercising the right of withdrawal, the Consumer shall not incur any costs other than the direct cost of returning the product.

7.7. The Consumer shall not have the right of withdrawal in the case of products that are not prefabricated and which have been manufactured on the basis of the Consumer’s instructions or at the Consumer’s express request, or products clearly personalized for the Consumer.

7.8. The Consumer may also not exercise the right of withdrawal in relation to:

a) contracts for the provision of services after the service has been fully performed, if the Company began performance with the Consumer’s express prior consent and the Consumer acknowledged that they would lose their right of withdrawal once the service had been fully performed;

b) products or services whose price or fee depends on fluctuations in the financial market beyond the Company’s control and which may occur within the withdrawal period;

c) perishable goods or products with a short shelf life;

d) sealed products which are not suitable for return due to health protection or hygiene reasons once unsealed after delivery;

e) products which, after delivery, are inseparably mixed with other items by their nature;

f) alcoholic beverages whose actual value depends on market fluctuations beyond the Company’s control and whose price was agreed upon at the time of conclusion of the sales contract, but delivery takes place only after 30 days from the conclusion of the contract;

g) business contracts where the Company visits the Consumer at the Consumer’s explicit request for urgent repair or maintenance work;

h) the sale or purchase of sealed audio or video recordings and computer software if the packaging has been opened after delivery;

i) newspapers, periodicals, and magazines, with the exception of subscription contracts;

j) contracts concluded at public auctions;

k) contracts for accommodation services other than for residential purposes, transport of goods, car rental, catering, or leisure-related services where the contract provides for a specific performance date or period;

l) digital content not supplied on a tangible medium, if the Company has begun performance with the Consumer’s express prior consent and the Consumer has acknowledged that they lose their right of withdrawal once performance has begun.

7.9. The Service Provider shall reimburse the Consumer for all amounts paid, including delivery costs, immediately after receipt of the product or the withdrawal statement pursuant to the above legislation, but no later than within 14 days of becoming aware of the withdrawal.

7.10. Reimbursement shall be made using the same payment method used for the original transaction unless the Consumer expressly agrees otherwise. The Consumer shall not incur any additional costs as a result of the chosen reimbursement method.

7.11. The Consumer is obliged to return or hand over the goods to the Service Provider without undue delay and in any event no later than 14 days from the date of sending the withdrawal notice.

7.12. In the case of written withdrawal, it is sufficient for the Consumer to send the withdrawal notice within 14 days.

7.13. The Consumer shall be deemed to have complied with the return deadline if the goods are returned or dispatched within 14 days. The return shall be considered timely if the Consumer sends the goods before the expiry of the deadline.

7.14. The Consumer shall bear only the direct costs of returning the product unless the Company has agreed to bear those costs.

7.15. The Service Provider is not obliged to reimburse additional costs incurred if the Consumer expressly chooses a delivery method other than the least expensive standard delivery method offered.

7.16. The Service Provider may withhold reimbursement until it has received the goods back or until the Consumer has supplied evidence of having returned the goods, whichever occurs earlier.

7.17. If the Consumer wishes to exercise the right of withdrawal, they must communicate this intention to the Service Provider either in writing (using the attached form) or by telephone via one of the contact methods provided by the Service Provider. In the case of written communication sent by post, the date of dispatch shall be taken into account; in the case of telephone communication, the date of the phone call shall apply. Notifications sent by post should be made via registered mail or parcel service. The Consumer may return the ordered product to the Service Provider either by post or courier service.

7.18. The Consumer shall only be liable for any diminished value of the product resulting from handling beyond what is necessary to establish the nature, characteristics, and functioning of the product.

7.19. Further information regarding the rules governing contracts between Consumers and businesses can be found in Government Decree 45/2014 (II.26.).

7.20. Further information regarding Directive 2011/83/EU of the European Parliament and of the Council can be found here.

7.21. Consumers may contact the Service Provider with complaints using the contact details provided here.

7.22. The right of withdrawal applies only to Users who qualify as Consumers under the Civil Code.

7.23. The right of withdrawal does not apply to businesses, i.e. persons acting within the scope of their profession, self-employed occupation, or business activity.

7.24. Procedure for Exercising the Right of Withdrawal

7.24.1. If the Consumer wishes to exercise the right of withdrawal, they must send a declaration of withdrawal to one of the Service Provider’s contact details.

7.24.2. The Consumer exercises the right of withdrawal within the deadline if the withdrawal notice is sent within 14 days from receipt of the product. In the case of written withdrawal, it is sufficient to send the withdrawal notice within 14 days.

In the case of postal notification, the date of posting shall be considered; in the case of notification by e-mail or fax, the date of sending the e-mail or fax shall apply.

7.24.3. In the event of withdrawal, the Consumer must return the ordered product to the Service Provider’s address without undue delay, but no later than 14 days after communicating the withdrawal notice. The deadline shall be deemed met if the product is dispatched before the expiry of the 14-day period (i.e. it does not need to arrive within 14 days). The Consumer shall bear the costs of returning the goods as a result of exercising the right of withdrawal.

7.24.4. The Service Provider is not obliged to reimburse additional costs incurred by the Consumer if the Consumer chooses a means of transport other than the usual and least expensive delivery method offered by the Service Provider. The Consumer may also exercise the right of withdrawal between the date of conclusion of the contract and the date of receipt of the goods.

7.24.5. If the Consumer purchases multiple products and the delivery of the products does not occur simultaneously, or if the ordered products are delivered in several installments, the right of withdrawal may be exercised within 14 days from receipt of the final product or installment.

Defective Performance

The Supplier performs defectively if the service provided does not meet the quality requirements set out in the contract or by law at the time of performance. The Supplier shall not be deemed to have performed defectively if the Recipient knew of the defect at the time of concluding the contract or should reasonably have known of it at that time.

Any contractual provision between a Consumer and a business that deviates from the provisions of this section regarding warranty and guarantees to the detriment of the Consumer shall be null and void.

Certain warranty rights apply only to Users who qualify as Consumers under the Hungarian Civil Code.

User acting as a business: A person acting within the scope of their trade, profession, or business activity.

Warranty Claim

8.1. In what cases may the User exercise a warranty claim?

In the event of defective performance by the Company, the User may assert a warranty claim against the Company in accordance with the provisions of the Hungarian Civil Code.

8.2. What rights does the User have under a warranty claim?

At the User’s choice, the following warranty claims may be asserted:

• request repair or replacement, unless fulfilling the User’s chosen remedy is impossible or would involve disproportionate additional costs for the Company compared to another remedy;

• if repair or replacement is not requested or cannot be provided, the User may request a proportional reduction in the price, remedy the defect at the Company’s expense, or terminate the contract.

The User may switch from one chosen warranty right to another; however, the costs of such a switch shall be borne by the User unless the switch was justified or caused by the Company.

8.3. Within what time limit may the User enforce a warranty claim?

The User is obliged to notify the defect immediately after discovering it, but no later than within two months from the date of discovery. Please note, however, that no warranty claim may be enforced after the expiration of the two-year limitation period (one year in the case of business users).

8.4. Against whom may the warranty claim be enforced?

The User may enforce the warranty claim against the Service Provider.

8.5. What other conditions apply to the enforcement of a warranty claim (if the User qualifies as a Consumer)?

Within one year from the date of delivery, no additional conditions apply for enforcing a warranty claim other than proving that the product or service was supplied by the Company operating the webshop. However, after one year from the date of performance, the User must prove that the defect already existed at the time of performance.

Product Warranty

8.6. In what cases may the User exercise product warranty rights?

In the event of a defect in a movable item (product), the User may choose between enforcing a warranty claim or a product warranty claim.

8.7. What rights does the User have under a product warranty?

The User may request the repair or replacement of the defective product.

8.8. When is a product considered defective?

A product is considered defective if it does not meet the quality requirements in force at the time it was placed on the market or if it does not possess the characteristics described by the manufacturer.

8.9. Within what time limit may the User enforce a product warranty claim?

The Consumer may enforce a product warranty claim within two years from the date the product was placed on the market. After this period, the right to enforce a product warranty claim shall expire.

8.10. Against whom and under what additional conditions may a product warranty claim be enforced?

A product warranty claim may be enforced against the manufacturer or distributor of the product. In the case of enforcing a product warranty claim, the User must prove the defect in the product.

8.11. In what cases is the manufacturer (distributor) exempt from product warranty liability?

The manufacturer (distributor) shall not be liable under product warranty if it can prove that:

• the product was not manufactured or placed on the market within the scope of its business activities; or

• according to the state of scientific and technical knowledge at the time the product was placed on the market, the defect could not have been detected; or

• the defect in the product resulted from compliance with a legal or mandatory regulatory requirement.

The manufacturer (distributor) need only prove one of the above grounds for exemption.

Please note that it is not possible to simultaneously enforce both a warranty claim and a product warranty claim for the same defect. However, if a product warranty claim is successfully enforced, the User may still enforce a warranty claim against the manufacturer for the replaced product or component.

9.1. In contracts concluded between a Consumer and a business, the agreement may not deviate from statutory provisions to the detriment of the Consumer.

9.2. The Consumer is responsible for proving the conclusion of the contract (for example, by presenting an invoice or receipt).

9.3. The Service Provider shall bear the costs related to the fulfillment of warranty obligations. (Section 6:166 of the Hungarian Civil Code)

9.4. The Service Provider shall prepare a report regarding the Consumer’s warranty or guarantee claim.

9.5. A copy of the report shall be provided to the Consumer without delay.

9.6. If the Service Provider is unable to declare, upon notification, whether the Consumer’s warranty or guarantee claim can be fulfilled, the Service Provider shall inform the Consumer within five working days, in a verifiable manner, of its position, including the reason for rejection and the possibility of seeking redress before a conciliation body.

9.7. The Service Provider shall retain the report for three years from the date of its recording and shall present it upon request by the supervisory authority.

9.8. The Service Provider shall endeavor to complete the repair or replacement within a maximum of fifteen days. If the duration of the repair or replacement exceeds 15 days, the Service Provider is obliged to inform the Consumer of the expected duration of the repair or replacement. Such information shall be provided electronically with the prior consent of the Consumer or by any other method suitable for receipt by the Consumer.

10.1. The Service Provider is entitled to use contributors or subcontractors in the fulfillment of its obligations. The Service Provider shall be liable for the unlawful conduct of such contributors as if it had committed the unlawful conduct itself.

10.2. The invalidity, unlawfulness, or unenforceability of any provision of these Terms and Conditions shall not affect the validity, lawfulness, or enforceability of the remaining provisions.

10.3. The failure of the Service Provider to exercise any right provided under these Terms and Conditions shall not constitute a waiver of such right. Any waiver of rights shall only be valid if expressly declared in writing. The fact that the Service Provider does not strictly enforce any essential provision or condition of these Terms on one occasion shall not constitute a waiver of the right to require strict compliance with that provision or condition in the future.

10.4. The Service Provider and the Consumer shall endeavor to settle disputes amicably and out of court.

10.5. The Parties declare that the webshop operated by the Service Provider is maintained and operated in Hungary. Since the website may also be accessed from other countries, Users expressly acknowledge that the governing law between the User and the Service Provider shall be Hungarian law. If the User is a Consumer, Section 26 (1) of the Hungarian Code of Civil Procedure shall apply, under which the court having jurisdiction over disputes arising from this contract shall be the court of the defendant’s place of residence.

10.6. The Service Provider shall not apply different general access conditions regarding access to products in the webshop based on the User’s nationality, place of residence, or place of establishment.

10.7. The Service Provider shall not apply different conditions to payment transactions with respect to accepted payment methods based on the User’s nationality, place of residence or establishment, the location of the payment account, the place of establishment of the payment service provider, or the place of issue of the payment instrument within the European Union.

10.8. The Service Provider complies with the requirements of the internal market relating to unjustified geo-blocking and other forms of discrimination based on customers’ nationality, place of residence, or place of establishment, in accordance with Regulation (EC) No. 2006/2004, Regulation (EU) 2017/2394, and Regulation (EU) 2018/302 of the European Parliament and of the Council.

11.1. The purpose of our website is to fulfill all orders in proper quality and to the complete satisfaction of the Customer. If the User still has any complaints regarding the contract or its performance, they may submit their complaint using the telephone number, e-mail address, or postal address provided above.

11.2. The Service Provider shall immediately investigate any oral complaint and remedy it if necessary. If the Consumer does not agree with the handling of the complaint, or if immediate investigation of the complaint is not possible, the Service Provider shall immediately record the complaint and its position regarding the complaint and provide a copy to the Consumer.

11.3. The Service Provider shall respond to the complaint in writing within 30 days. In the event of rejection of the complaint, the reasons for the rejection shall be stated. The Service Provider shall retain the complaint report and a copy of the response for five years and shall present them to the supervisory authorities upon request.

11.4. The Consumer is informed that if their complaint is rejected, they may initiate proceedings before an authority or conciliation body as follows:

11.5. The Consumer may file a complaint with the Hungarian Consumer Protection Authority:

Pursuant to Section 45/A (1)-(3) of the Consumer Protection Act and Government Decree 387/2016 (XII.2.) on the designation of the consumer protection authority, the Government Office acts as the general consumer protection authority:
http://www.kormanyhivatal.hu/hu/elerhetosegek

11.6. In the event of a consumer dispute, the Consumer may also turn to a Conciliation Body, available at the following contact details:

Baranya County Conciliation Body

Address: 7625 Pécs, Majorossiy Imre u. 36.
Telephone: (72) 507-154; (20) 283-3422
Fax: (72) 507-152
President: Dr. Ferenc Bércesi
Website: www.baranyabekeltetes.hu
E-mail: info@baranyabekeltetes.hu; kerelem@baranyabekeltetes.hu

Bács-Kiskun County Conciliation Body

Address: 6000 Kecskemét, Árpád krt. 4.
Postal address: 6001 Kecskemét Pf. 228.
Telephone: (76) 501-525; (76) 501-532; (70) 702-8403
Fax: (76) 501-538
President: Dr. Zsuzsanna Horváth
Website: www.bacsbekeltetes.hu
E-mail: bekeltetes@bacsbekeltetes.hu

Békés County Conciliation Body

Address: 5600 Békéscsaba, Penza ltp. 5.
Telephone/Fax: (66) 324-976
President: Dr. László Bagdi
Website: www.bmkik.hu
E-mail: bekeltetes@bmkik.hu

Borsod-Abaúj-Zemplén County Conciliation Body

Address: 3525 Miskolc, Szentpáli u. 1.
Telephone: (46) 501-091 (new cases); 501-871 (pending cases)
President: Dr. Péter Tulipán
Website: www.bekeltetes.borsodmegye.hu
E-mail: bekeltetes@bokik.hu

Budapest Conciliation Board

Address: 1016 Budapest, Krisztina krt. 99.
Telephone: (1) 488-2131
Fax: (1) 488-2186
President: Dr. Éva Veronika Inzelt
Website: www.bekeltet.hu
E-mail: bekelteto.testulet@bkik.hu

Csongrád-Csanád County Conciliation Body

Address: 6721 Szeged, Párizsi krt. 8-12.
Telephone: (62) 554-250 / ext. 118
Fax: (62) 426-149
President: Dr. Károly Horváth
Website: www.bekeltetes-csongrad.hu
E-mail: bekelteto.testulet@csmkik.hu

Fejér County Conciliation Body

Address: Hosszúséta tér 4-6, 8000 Székesfehérvár
Telephone: (22) 510-310
Fax: (22) 510-312
President: Dr. József Vári Kovács
Website: www.bekeltetesfejer.hu
E-mail: bekeltetes@fmkik.hu; fmkik@fmkik.hu

Győr-Moson-Sopron County Conciliation Body

Address: Szent István út 10/a, 9021 Győr
Telephone: (96) 520-217
President: Dr. Beáta Bagoly
Website: https://gymsmkik.hu/bekelteto
E-mail: bekeltetotestulet@gymskik.hu

Hajdú-Bihar County Conciliation Body

Head office: 4025 Debrecen, Petőfi tér 10.
Administrative office: 4025 Debrecen, Vörösmarty u. 13-15.
Telephone: (52) 500-710; (52) 500-745
Fax: (52) 500-720
President: Dr. Zsolt Hajnal
Website: https://www.hbmbekeltetes.hu
E-mail: bekelteto@hbkik.hu

Heves County Conciliation Body

Postal address: 3300 Eger, Pf. 440.
Customer service: 3300 Eger, Hadnagy u. 6. Ground floor
Telephone: (36) 416-660 / ext. 105
Fax: (36) 323-615
President: Dr. István Gondos
Website: www.hkik.hu/hu/content/bekelteto-testulet
E-mail: bekeltetes@hkik.hu

Jász-Nagykun-Szolnok County Conciliation Body

Address: 5000 Szolnok, Verseghy Park 8. 3rd floor
Telephone: (20) 373-2570
Fax: (56) 370-005
President: Dr. Lajkóné dr. Lache Judith
Website: http://www.iparkamaraszolnok.hu/ugyintezes/bekelteto-testulet
E-mail: bekeltetotestulet@iparkamaraszolnok.hu

Komárom-Esztergom County Conciliation Body

Address: 2800 Tatabánya, Fő tér 36.
Telephone: (34) 513-010
Fax: (34) 316-259
President: Dr. Gabriella Bures
Website: www.kemkik.hu/hu/bekeltet-otilde-testulet
E-mail: bekeltetes@kemkik.hu

Nógrád County Conciliation Body

Address: 3100 Salgótarján, Alkotmány u. 9/a
Telephone: (32) 520-860
Fax: (32) 520-862
President: Dr. Erik Pongó
Website: www.nkik.hu
E-mail: nkik@nkik.hu

Pest County Conciliation Body

Head office: 1119 Budapest, Etele út 59-61. 2nd floor 240.
Postal address: 1364 Budapest, Pf.: 81
Telephone/Fax: (1) 269-0703
President: Dr. Pál Koncz
Website: www.pestmegyeibekelteto.hu; www.panaszrendezes.hu
E-mail: pmbekelteto@pmkik.hu

Somogy County Conciliation Body

Address: Anna utca 6, 7400 Kaposvár
Telephone: (82) 501-000
Fax: (82) 501-046
President: Dr. Imre Csapláros
Website: www.skik.hu/hu/bekelteto-testulet
E-mail: skik@skik.hu

Szabolcs-Szatmár-Bereg County Conciliation Body

Address: 4400 Nyíregyháza, Széchenyi u. 2.
Telephone/Fax: (42) 420-180
President: Dr. Görömbeiné Katalin Balmaz
Website: www.bekeltetes-szabolcs.hu
E-mail: bekelteto@szabkam.hu

Tolna County Conciliation Body

Address: 7100 Szekszárd, Arany J. u. 23-25.
Telephone: (74) 411-661; (30) 664-2130
Fax: (74) 411-456
President: Gréta Mónus
Website: https://www.tmkik.hu/hu/bekelteto-testulet_2
E-mail: bekeltett@tmkik.hu; kamara@tmkik.hu

Vas County Conciliation Body

Customer service: 9700 Szombathely, Rákóczi Ferenc u. 23.
Telephone: (94) 312-356; (94) 506-645; (30) 956-6708
Fax: (94) 316-936
President: Dr. Zoltán Kövesdi
Website: www.vasibekelteto.hu
E-mail: pergel.bea@vmkik.hu

Veszprém County Conciliation Body

Address: 8200 Veszprém, Radnóti tér 1.
Telephone: (88) 814-121; (88) 814-111
Fax: (88) 412-150
President: Dr. Klara Herjavecz
Website: www.bekeltetesveszprem.hu
E-mail: info@bekeltetesveszprem.hu

Zala County Conciliation Body

Address: 8900 Zalaegerszeg, Petőfi utca 24.
Telephone: (92) 550-513
Fax: (92) 550-525
President: Dr. Sándor Molnár
Website: www.bekelteteszala.hu
E-mail: zmbekelteto@zmkik.hu

11.7. The Conciliation Body is responsible for the out-of-court settlement of consumer disputes. The purpose of the Conciliation Body is to attempt to reach an agreement between the parties in order to resolve consumer disputes. If no agreement can be reached, the Conciliation Body shall decide the matter in order to ensure the simple, fast, effective, and cost-efficient enforcement of consumer rights. Upon request, the Conciliation Body shall provide advice to the Consumer or the Service Provider regarding their rights and obligations.

11.8. In the case of cross-border consumer disputes arising from online sales or service contracts, only the Conciliation Body operated by the Budapest Chamber of Commerce and Industry shall have jurisdiction.

11.9. In the event of a consumer complaint, the Consumer may use the EU Online Dispute Resolution (ODR) platform. Access to the platform requires a simple registration with the European Commission. After registration, the Consumer may submit a complaint through the online platform available at:
http://ec.europa.eu/odr

11.10. The Service Provider is obliged to cooperate in conciliation proceedings. It is required to send its written response to the Conciliation Body and ensure the participation of a person authorized to conclude settlements at the hearing. If the business activity or registered office of the Company is not located in the county where the competent Conciliation Body operates, the Company’s obligation to cooperate also includes offering the possibility of a written settlement in accordance with the Consumer’s request.

11.11. If the Consumer does not initiate conciliation proceedings or if the proceedings are unsuccessful, the Consumer has the right to take the matter to court.

The lawsuit must be filed by means of a statement of claim containing the following:

• the competent court;

• the names of the parties and their representatives, their place of residence, and legal status;

• the right sought to be enforced, including the underlying facts and supporting evidence;

• the facts establishing the jurisdiction and competence of the court;

• a clear and final request for the court’s decision.

The statement of claim must be accompanied by the relevant documents and copies referred to as evidence.

12.1. Since the website
https://zulupack.shop
constitutes a copyrighted work, it is prohibited to download (copy), republish, otherwise use, electronically store, process, or sell the content of the website or any part thereof without the prior written consent of the Service Provider.

12.2. No material may be transferred from
https://zulupack.shop
or its database, even with written consent, by referring to this website.

12.3. The Service Provider reserves all rights to all elements of its services, its domain names, related secondary domain names, and internet advertising spaces.

12.4. The following actions are prohibited:

• adapting or reverse engineering the content of
  https://zulupack.shop
  or any part thereof;

• fraudulently creating user IDs or passwords;

• using any application to modify or index any part or all of
  https://zulupack.shop.

12.5. The name
https://zulupack.shop
is protected by copyright and may only be used with the prior written permission of the Service Provider.

12.6. The User acknowledges that, in the event of unauthorized use, the Service Provider shall be entitled to claim a contractual penalty. The amount of the contractual penalty is EUR 200 gross per image and EUR 60 gross per word. In the event of copyright infringement, the Service Provider shall apply notarial certification, and the related costs shall also be charged to the infringing User.

(Please complete and return this form only if you wish to withdraw from the contract.)

Addressee:

Walking Sage Kft.
2030 Érd, Festő u. 86/1., Hungary
info@walkingsage.hu
+36-70-507-4440

I/We, the undersigned, hereby declare that I/we withdraw from the contract for the sale of the following goods:

Order / Receipt date:

Name of the Consumer(s):

Address of the Consumer(s):

Signature of the Consumer(s) (only in the case of written notification):

Date:

Walking Sage Kft. (2030 Érd, Festő u. 86/1., Tax Number: 24247757-2-13, Company Registration Number: 13-09-161726), (hereinafter referred to as: Service Provider, Data Controller) adopts the following policy.

The following Privacy Policy is provided in accordance with 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 – GDPR).

This Privacy Policy governs the data processing activities of the following website:

https://zulupack.shop

This Privacy Policy is available at:
https://zulupack.shop/shop_help.php?tab=privacy_policy

Changes to this Privacy Policy shall become effective upon publication on the above-mentioned website.

DATA CONTROLLER AND CONTACT DETAILS

Name: Walking Sage Kft.
Registered Office: 2030 Érd, Festő u. 86/1., Hungary
E-mail: info@walkingsage.hu
Telephone: +36-70-507-4440

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 one or more factors such as a name, identification number, location data, online identifier, or factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

2. “Data Processing”: any operation or set of operations performed on personal data or data files, whether by automated means or not, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

3. “Data Controller”: any natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of 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. “Data Processor”: any natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.

5. “Recipient”: any natural or legal person, public authority, agency, or other body to whom personal data are disclosed, regardless of whether they are a third party or not. Public authorities which may receive personal data within the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of such data by those public authorities shall comply with the applicable data protection rules according to the purposes of the processing.

6. “Consent of the Data Subject”: any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.

7. “Data Breach”: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed

Personal data:

1. must be processed lawfully, fairly, and in a transparent manner in relation to the data subject (“lawfulness, fairness and transparency”);

2. must be 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 in accordance with Article 89(1) shall not be considered incompatible with the original purposes (“purpose limitation”);

3. must be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed (“data minimization”);

4. must be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that inaccurate personal data are erased or rectified without delay, having regard to the purposes for which they are processed (“accuracy”);

5. must be 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 organizational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (“storage limitation”);

6. must be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures (“integrity and confidentiality”).

The Data Controller shall be responsible for compliance with the above principles and must be able to demonstrate such compliance (“accountability”).

The Data Controller declares that data processing is carried out in accordance with the principles set out in this section.

1. Fact of Data Collection, Scope of Managed Data, and Purpose of Data Processing

It is not necessary for the username or e-mail address to contain personal data.

2. Scope of Data Subjects

All persons registering or purchasing on the website.

3. Duration of Data Processing, Deadline for Data Deletion

If any of the conditions set out in Article 17(1) GDPR are met, the data subject may request the deletion of their personal data. The Data Controller shall notify the data subject electronically of the deletion of the personal data provided by them pursuant to Article 19 GDPR. If the deletion request also concerns the e-mail address provided by the data subject, the Data Controller shall delete the e-mail address following notification.

Accounting documents must be retained for eight years pursuant to Section 169(2) of Act C of 2000 on Accounting.

Accounting records (including general ledger accounts, analytical and accounting records) directly and indirectly supporting the accounts must be retained in a readable format and retrievable by reference to the accounting records for at least eight years.

4. Persons Authorized to Process the Data and Access the Personal Data

Personal data may be processed by the sales and marketing staff of the Data Controller in compliance with the above principles.

5. Rights of Data Subjects

The data subject may request from the Data Controller:

• access to personal data concerning them;

• rectification, deletion, or restriction of processing of personal data;

• the right to data portability;

• withdrawal of consent at any time.

6. Methods for Initiating Access, Deletion, Modification, Restriction of Processing, Data Portability, and Objection to Data Processing

By post:
2030 Érd, Festő u. 86., Hungary

By e-mail:
info@walkingsage.hu

By telephone:
+36-70-507-4440

7. Legal Basis for Data Processing

Article 6(1)(b) and (c) GDPR.

Pursuant to Section 13/A(3) of Act CVIII of 2001 on Certain Issues of Electronic Commerce Services and Information Society Services (hereinafter: Electronic Commerce Act):

For the purpose of providing the service, the service provider may process those personal data that are technically indispensable for the provision of the service. The service provider shall, where other conditions are equal, choose and in all cases operate the tools used in providing information society services in such a way that personal data are processed only if this is strictly necessary for the provision of the service and only to the extent and for the duration necessary.

Article 6(1)(c) GDPR in relation to invoicing obligations under accounting legislation.

In the case of claims arising from the contract, Section 6:21 of Act V of 2013 on the Civil Code applies with a limitation period of five years.

Section 6:22 [Limitation Period]

1. Unless otherwise provided by law, claims shall become time-barred after five years.

2. The limitation period begins when the claim becomes due.

3. An agreement modifying the limitation period must be made in writing.

4. Agreements excluding limitation periods shall be null and void.

8. Please Note

• Data processing is necessary for the performance of the contract and for providing a quotation.

• Providing personal data is necessary in order for us to process your order.

• Failure to provide the required data will result in the inability to process your order.

1. Pursuant to Section 6 of Act XLVIII of 2008 on the Basic Requirements and Certain Restrictions of Commercial Advertising Activities, the Customer may give prior consent to the Service Provider to send advertising and other communications to the contact details provided during registration.

2. Furthermore, the Customer may consent to the Service Provider processing their personal data for the purpose of sending advertising messages, taking into account the provisions of this Privacy Policy.

3. The Service Provider does not send unsolicited advertising, and the Customer may unsubscribe from advertising messages at any time, free of charge and without providing any reason. In such a case, the Service Provider shall delete all personal data necessary for sending the advertising messages from its records and shall cease sending further advertising offers. The Customer may unsubscribe from advertisements by clicking the unsubscribe link contained in the message.

4. Fact of Data Collection, Scope of Managed Data, and Purpose of Data Processing

5. Scope of Data Subjects

All data subjects subscribing to the newsletter.

6. Purpose of Data Collection

Sending electronic advertising messages (e-mail, SMS, push notifications) to the Customer containing information about current products, discounts, new features, and similar promotional content.

7. Duration of Data Processing and Deadline for Data Deletion

Until the withdrawal of consent, i.e. until unsubscribing from the newsletter.

8. Persons Authorized to Process the Data and Access the Personal Data

Personal data may be processed by the sales and marketing staff of the Data Controller in compliance with the above principles.

9. Rights of Data Subjects

The data subject may request from the Data Controller:

• access to personal data concerning them;
• rectification, deletion, or restriction of processing of personal data;
• objection to the processing of such personal data;
• the right to data portability;
• withdrawal of consent at any time.

10. Methods for Initiating Access, Deletion, Modification, Restriction of Processing, Data Portability, and Objection to Data Processing

By post:
2030 Érd, Festő u. 86., Hungary

By e-mail:
info@walkingsage.hu

By telephone:
+36-70-507-4440

11. Unsubscribing from the Newsletter

Users may unsubscribe from the newsletter at any time, free of charge.

12. Please Note

• Data processing is based on your consent.
• You are required to provide personal data so that we can respond to your message.
• Failure to provide the required data will result in the inability to process your request.
• Please note that you may withdraw your consent at any time by clicking the “Unsubscribe” link.
• Withdrawal of consent shall not affect the lawfulness of data processing carried out on the basis of consent prior to its withdrawal.

1. Fact of Data Collection, Scope of Managed Data, and Purpose of Data Processing

2. Scope of Data Subjects

All persons purchasing on the website and submitting a legitimate complaint regarding quality.

3. Duration of Data Processing and Deadline for Data Deletion

Copies of the complaint record, report, and response thereto shall be retained for five years pursuant to Section 17/A(7) of Act CLV of 1997 on Consumer Protection.

4. Persons Authorized to Process the Data and Access the Personal Data

Personal data may be processed by the sales and marketing staff of the Data Controller in compliance with the above principles.

5. Rights of Data Subjects

• The data subject may request from the Data Controller access to personal data concerning them, as well as rectification, deletion, or restriction of processing.

• The data subject has the right to data portability and the right to withdraw consent at any time.

6. Methods for Initiating Access, Deletion, Modification, Restriction of Processing, and Data Portability

• By post: 2030 Érd, Festő u. 86., Hungary

• By e-mail: info@walkingsage.hu

• By telephone: +36-70-507-4440

7. Please Note

• The provision of personal data is based on a legal obligation.

• The processing of personal data is a prerequisite for concluding a contract.

• You are required to provide personal data in order for us to process your complaint.

• Failure to provide the required data will result in the inability to process your complaint.

1. Webshop-specific cookies include so-called “password-protected session cookies,” “shopping cart cookies,” “security cookies,” “necessary cookies,” “functional cookies,” and “cookies responsible for website statistics,” which do not require the prior consent of users.

2. Fact of data processing and scope of processed data: unique identification number, timestamps, and data.

3. Scope of data subjects: all persons visiting the website.

4. Purpose of data processing: identification of users, registration of the “shopping cart,” and tracking of visitors.

5. Duration of Data Processing and Deadline for Data Deletion

6. Potential Data Controllers Authorized to Access the Data

The Service Provider does not process personal data through the use of cookies.

7. Information on the Rights of Data Subjects in Relation to Data Processing

Users may delete cookies through the “Tools/Settings” menu of their browser, generally under the “Privacy” settings.

8. Legal Basis for Data Processing

Consent is not required if the sole purpose of the use of cookies is to carry out the transmission of communications over an electronic communications network or to provide an information society service explicitly requested by the subscriber or user.

9. Cookie Settings in Browsers

Most browsers used by our users allow users to determine which cookies may be stored and to delete specific cookies again. Restricting or disabling third-party cookies on certain websites may result in the website not being fully usable.

Information on adjusting cookie settings in standard browsers can be found here:

• Google Chrome: https://support.google.com/chrome/answer/95647?hl=en

• Edge / Internet Explorer: https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

• Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox

• Safari: https://support.apple.com/guide/safari/manage-cookies-sfri11471/mac

1. The Data Controller uses the online advertising program “Google Ads” and, within its framework, utilizes Google’s conversion tracking service. Google Conversion Tracking is an analytics service provided by Google (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA).

2. When a User accesses a website via a Google advertisement, a conversion tracking cookie is placed on the User’s computer. These cookies have a limited validity period and do not contain personal data, therefore the User cannot be personally identified through them.

3. When the User visits certain pages of the website and the cookie has not yet expired, Google and the Data Controller may recognize that the User clicked on the advertisement.

4. Each Google Ads customer receives a different cookie, therefore they cannot be tracked across the websites of other Google Ads customers.

5. The information obtained through conversion tracking cookies is used to compile conversion statistics for customers using Google Ads conversion tracking. Customers are informed about the number of users who clicked on their advertisement and were redirected to a page containing a conversion tracking tag. However, they do not receive any information that could personally identify users.

6. If you do not wish to participate in conversion tracking, you may disable it by blocking the installation of cookies in your browser settings. In this case, you will not be included in conversion tracking statistics.

7. Further information and Google’s Privacy Policy are available at:
   Google Privacy Policy

1. This website uses Google Analytics, a web analytics service provided by Google (“Google”). Google Analytics uses so-called “cookies,” which are text files stored on the User’s computer to help analyze how Users use the website.

2. The information generated by the cookies regarding the User’s use of the website is generally transmitted to and stored on a Google server in the United States. If IP anonymization is activated on the website, Google will truncate the User’s IP address within Member States of the European Union or in other states party to the Agreement on the European Economic Area before transmission.

3. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. On behalf of the operator of this website, Google will use this information to evaluate the User’s use of the website, compile reports on website activity for the website operator, and provide additional services related 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 Google data. The User may prevent the storage of cookies by selecting the appropriate settings in their browser; however, please note that in this case not all functions of the website may be fully available. Furthermore, the User may prevent Google from collecting and processing data generated by cookies related to their use of the website (including their IP address) by downloading and installing the browser plugin available at the following link:
   Google Analytics Opt-out Browser Add-on

The Data Controller places great emphasis on using only data processors that provide sufficient guarantees for implementing data processing in compliance with the requirements of the GDPR and ensuring the application of appropriate technical and organizational measures to protect the rights of data subjects.

The Data Processor, and any person acting under the authority of the Data Controller or the Data Processor who has access to personal data, shall process the personal data covered by these rules only in accordance with the instructions of the Data Controller.

The Data Controller is responsible for the lawfulness of data processing. The Data Processor shall only be liable for damages caused by data processing if it has failed to comply with obligations specifically imposed on data processors by the GDPR or if it has ignored or acted contrary to the lawful instructions of the Data Controller.

The Data Processor shall not make substantive decisions regarding the processing of data.

The Data Controller may use a hosting provider for ensuring the IT background infrastructure and a courier service for the delivery of ordered products as Data Processors.

Specific Data Processors

A “Third Party” means any natural or legal person, public authority, agency, or other body other than the data subject, the Data Controller, the Data Processor, or persons who, under the direct authority of the Data Controller or Data Processor, are authorized to process personal data.

Third-party Data Controllers process personal data in their own name and in accordance with their own privacy policies.

Third-Party Data Controllers

1. Fact of data collection and scope of managed data: the name and publicly available profile picture of the Customer registered on Meta / X (formerly Twitter) / Pinterest / YouTube / Instagram and similar social networking platforms.

2. Scope of data subjects: all persons registered on Meta/X/Pinterest/YouTube/Instagram and similar social networking sites who “like” the Service Provider’s social media page or contact the Data Controller through a social networking platform.

3. Purpose of data collection: sharing or “liking” specific content elements, products, promotions of the website, or the website itself on social networking platforms.

4. Duration of data processing, deadline for deletion of data, identity of possible Data Controllers entitled to access the data, and information regarding the rights of data subjects: information regarding the source of the data, the processing of the data, the method of transfer, and the legal basis for the data processing can be found on the relevant social networking platform. Data processing takes place on social networking sites; therefore, the duration of data processing and the options for deleting or modifying data are governed by the rules of the respective social networking platform.

5. Legal basis for data processing: the voluntary consent of the Customer for the processing of personal data on social networking platforms.

1. If you have any questions or issues regarding the use of our data processing services, you may contact the Data Controller through the contact methods provided on the website (telephone, e-mail, social networking platforms, etc.).

2. The Data Controller shall delete all incoming e-mails, messages, telephone messages, or communications received through social networking platforms, etc., containing the Customer’s name, e-mail address, or other personal data provided, after 2 years from the commencement of the service.

3. Data processing activities not specifically listed in this Privacy Policy shall be governed by the information provided at the time of data collection.

4. The Service Provider is obliged to provide information, data, documents, and records to the competent authorities in response to exceptional requests or requests from other bodies authorized by law.

5. In such cases, the Service Provider shall provide personal data to the requesting party only to the extent and in the scope necessary to fulfill the purpose of the request, provided that the exact purpose and scope of the requested data have been specified.

1. Right of Access

You have the right to obtain confirmation from the Data Controller as to whether or not your personal data are being processed, and where such processing is taking place, you have the right to access your personal data and the information specified in the Regulation.

2. Right to Rectification

You have the right to obtain from the Data Controller without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the data processing, you also have the right to request the completion of incomplete personal data, including by means of providing a supplementary statement.

3. Right to Erasure

You have the right to request that the Data Controller erase personal data concerning you without undue delay, and the Data Controller shall be obliged to erase such personal data without undue delay under certain conditions.

4. Right to be Forgotten

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

5. Right to Restriction of Processing

You have the right to obtain from the Data Controller restriction of processing where one of the following applies:

• you contest the accuracy of the personal data, for a period enabling the Data Controller to verify the accuracy of the personal data;

• the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;

• the Data Controller no longer needs the personal data for the purposes of processing, but you require them for the establishment, exercise, or defense of legal claims;

• you have objected to the processing; in this case, the restriction shall apply for the period pending the verification whether the legitimate grounds of the Data Controller override your legitimate grounds.

6. Right to Data Portability

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

7. Right to Object

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

8. Right to Object to Direct Marketing

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

9. Automated Individual Decision-Making, 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:

• is necessary for entering into, or the performance of, a contract between you and the Data Controller;

• is authorized by European Union or Member State law applicable to the Data Controller, which also lays down suitable measures to safeguard your rights, freedoms, and legitimate interests;

• is based on your explicit consent.

The Data Controller shall inform you without undue delay, and in any event within one month of receipt of the request, of any measures taken in response to these requests.

Where necessary, this period may be extended by a further two months. The Data Controller shall inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.

If the Data Controller does not take action on your request, it shall inform you without delay, and at the latest within one month of receipt of the request, of the reasons for not taking action and of your right to lodge a complaint with a supervisory authority and seek a judicial remedy.

The Data Controller and the Data Processor shall implement appropriate technical and organizational measures, taking into account the state of the art, the costs of implementation, the nature, scope, context, and purposes of the data processing, as well as the varying likelihood and severity of risks to the rights and freedoms of natural persons, in order to ensure a level of data security appropriate to the risk, including, where appropriate:

1. the pseudonymization and encryption of personal data;

2. ensuring the ongoing confidentiality, integrity, availability, and resilience of processing systems and services used for processing personal data;

3. the ability to restore access to personal data and the availability of data in a timely manner in the event of a physical or technical incident;

4. a process for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of data processing.

5. Processed data must be stored in a manner that prevents unauthorized access. In the case of paper-based data carriers, this shall be ensured by establishing rules for physical storage, archiving, and handling; in the case of electronically processed data, by implementing a centralized access authorization system.

6. The method of data storage using IT systems shall be selected in such a way that deletion may be carried out after the deletion deadline expires or when otherwise required, subject to any different statutory deletion periods. Deletion must be irreversible.

7. Paper-based data carriers shall be destroyed using a document shredder or by an external organization specializing in document destruction. In the case of electronic data carriers, physical destruction must be carried out in accordance with the rules governing the disposal of electronic media, including the prior secure and irreversible deletion of the data where necessary.

8. The Data Controller shall implement the following specific data security measures:

Protection of Paper-Based Personal Data

To ensure the security of personal data processed on paper, the Service Provider applies the following measures (physical protection):

1. Documents shall be stored in a secure, lockable, and dry room.

2. The buildings and premises of the Service Provider are equipped with fire protection and property protection systems.

3. Personal data may only be accessed by authorized persons and shall not be accessible to third parties.

4. Employees of the Service Provider may leave the room where data processing takes place during the course of their work only after locking the entrusted data carriers or securing the room itself.

5. Where digitization of paper-based personal data takes place, the rules applicable to digitally stored documents shall apply.

IT Protection

1. Computers and mobile devices (and other data carriers) used for data processing are the property of the Service Provider.

2. The computer systems used by the Service Provider containing personal data are protected against viruses.

3. The Service Provider uses backups and archives to ensure the security of digitally stored data.

4. Access to the central server machine is granted only to authorized persons.

5. Access to data stored on computers is possible only through the use of a username and password.

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

The information provided to the data subject shall be clear and easy to understand and shall include the nature of the data breach, as well as the name and contact details of the Data Protection Officer or another contact person able to provide further information. The likely consequences of the personal data breach shall also be described, together with the measures taken or proposed to be taken by the Data Controller to address the breach, including, where appropriate, measures to mitigate its possible adverse effects.

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

• the Data Controller has implemented appropriate technical and organizational protection measures and those measures were applied to the data affected by the data breach, in particular measures such as encryption that render the personal data unintelligible to any person who is not authorized to access it;

• following the data breach, the Data Controller has taken subsequent measures ensuring that the high risk to the rights and freedoms of the data subject is no longer likely to materialize;

• informing the data subject would involve disproportionate effort. In such cases, a public communication or similar measure shall be used whereby the data subjects are informed in an equally effective manner.

If the Data Controller has not already communicated the data breach to the data subject, the supervisory authority may require it to do so after considering whether the breach is likely to result in a high risk.

NOTIFICATION OF A PERSONAL DATA BREACH TO THE AUTHORITY

The personal data breach shall be notified to the supervisory authority referred to in Article 55 without undue delay and, where feasible, not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.

Where the notification is not made within 72 hours, it shall be accompanied by reasons for the delay.

If the duration of mandatory data processing or the periodic review of its necessity is not determined by law, local government decree, or a binding act of the European Union, the Data Controller shall review, at least every three years from the commencement of the data processing, whether the personal data processed by the Data Controller or by a Data Processor acting on its behalf or under its instructions are still necessary for the purpose of the data processing.

The circumstances and results of such review shall be documented by the Data Controller and retained for a period of ten years following the review, and shall be made available upon request to the Hungarian National Authority for Data Protection and Freedom of Information (NAIH) (hereinafter referred to as the “Authority”)._)

A complaint regarding a possible violation of the law by the Data Controller may be submitted to the Hungarian National Authority for Data Protection and Freedom of Information (NAIH):

Hungarian National Authority for Data Protection and Freedom of Information
1055 Budapest, Falk Miksa utca 9-11., Hungary

Postal address:
1363 Budapest, Pf. 9., Hungary

Telephone:
+36-1-391-1400

Fax:
+36-1-391-1410

E-mail:
ugyfelszolgalat@naih.hu

The following legislation and recommendations were taken into account when preparing this Privacy Policy:

• 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 – GDPR)

• Act CXII of 2011 on Informational Self-Determination and Freedom of Information (hereinafter: “Infotv.”)

• Act CVIII of 2001 on Electronic Commerce Services and Certain Issues of Information Society Services (in particular Section 13/A)

• Act XLVII of 2008 on the Prohibition of Unfair Commercial Practices against Consumers

• Act XLVIII of 2008 on the Basic Requirements and Certain Restrictions of Commercial Advertising Activities (in particular Section 6)

• Act XC of 2005 on the Freedom of Electronic Information

• Act C of 2003 on Electronic Communications (in particular Section 155)

• Opinion No. 16/2011 concerning the EASA/IAB Recommendation on Best Practice in Online Behavioral Advertising

• Recommendation of the Hungarian National Authority for Data Protection and Freedom of Information on the data protection requirements of prior information notices