A cookie is a packet of information sent by a visited website, which is created on the visitor’s computer device through the browser and stored for a predetermined period of time. The cookie application provides the possibility to retrieve some of the visitor’s data and to track his/her internet usage in the browser. Cookies can be used to precisely determine the interests, internet usage habits and website visit history of the user concerned. Cookies alone cannot identify the user by name, they are only able to recognise the visitor’s computer device, but they can be used to create an accurate profile of the user and their internet usage habits.

Types of cookies used by the Company:

1. Temporary / session cookies (session / navigation cookies): their validity is limited to the user’s current session only, and they are automatically deleted from the visitor’s device when the session ends or the browser is closed. In no case do session cookies collect information that can be used to identify you. These cookies usually store information such as the login status.
2. Functional cookies: these improve the functionality of the website by remembering the user’s choices and browser settings for that page.
3. Performance cookies (preferences cookie): to provide a better user experience, to enhance the visitor experience, they collect information about the user’s behaviour, time spent on the website, clicks.
4. Statistical/marketing cookies: statistical or marketing cookies help us to understand visitor behaviour by collecting anonymous data from which reports can be generated and/or direct targeted advertising can be displayed on the website. These cookies are usually used to create a profile of the visitor (profiling cookie).

The source of the cookies used by the Company:

1. Own cookie: these cookies are created by the website that the user is visiting at the time, in this case the Company’s website.
2. Third-party cookie: when a user visits a page, another party activates the cookie through the website and can access the information stored in the cookie or collect data about the visitor.

Management and use of cookies

Accepting or authorising the use of cookies is not mandatory. The visitor of the website can disable or enable the use of cookies in his/her internet browser and delete cookies that have already been enabled before they expire. However, rejecting all cookies may limit the usability of some websites.

Users can find help on how to manage cookies in their browser’s Help or for the most commonly used browsers on Symantec’s website: https://support.norton.com/sp/hu/hu/home/current/solutions/v57840314_NortonM_Retail_1_hu_hu

In the case of Google Analytics, you can prevent Google from collecting and processing your data (including your IP address) about your use of the website through cookies by downloading and installing the browser plugin available at the following link:https://tools.google.com/dlpage/gaoptout?hl=hu

The websites, information and downloadable materials available through the links above are entirely independent from the Company’s website and the Company cannot provide any information or take any responsibility for their availability or the information contained therein.

Visitors to the Company’s website must accept cookies before they are used, with the following exceptions, i.e. it is not necessary to obtain consent from the

• cookies that store information recorded by the user (user-input cookies),
• authentication session cookies (authentication cookies),
• user centric security cookies,
• for multimedia player session cookies,
• load balancing session cookies,
• session cookies for user interface customisation (user interface customisation cookies).

When using these cookies, we only need to inform the data subjects.

All other uses of cookies, in particular cookies used to create profiles of users and to display advertising messages based on the user’s browsing habits, require the user’s prior consent, i.e. the data subject must declare that:

• has read the Company’s Privacy Policy and accepted its provisions,
• consent to the use of cookies and to the processing of data in connection therewith.

The boxes to accept cookies are not pre-checked by the Company, only the data subject can do so by his/her active activity.

Cookies requiring consent will not be installed on the user’s computer until the data subject has given his or her consent. As a result, users may not be able to access certain parts of the website or functions unless they opt in or opt out of cookies.

The Company will ensure that, in the case of cookies, the withdrawal of the data subject’s consent to its use is as simple as giving it.

Exceptions include browser manufacturers’ own cookies – e.g. Google Inc. in the case of Google Chrome browser, where the Company cannot delete cookies placed by the manufacturer’s scripts due to technical limitations built in by the manufacturer. In such cases, the deletion can only be done by the data subject in his or her browser.

For session cookies, the purpose of the processing is to ensure the proper functioning of the website. The duration of the data processing is limited to the current visit of the visitor, and the cookie is automatically deleted from the computer at the end of the session or when the browser is closed.

The legal basis for data processing is the Elkertv. 13/A. § (3), according to which the service provider may process personal data that are technically necessary for the provision of the service. The service provider must, other things being equal, choose and in any case operate the means used in the provision of the information society service in such a way that personal data are processed only to the extent strictly necessary for the provision of the service and for the fulfilment of the other purposes set out in the Elkertv, but only to the extent and for the duration necessary.

In the case of functional cookies, the purpose of the processing is to improve the functionality of the website by remembering the user’s choices and browser settings for that page, which may result in an increase in the operational efficiency of the website.

The legal basis for the processing is the consent of the data subject, and the duration of the processing is until the date of deletion of the cookie by the data subject.

In the case of performance and visitor experience cookies (preferences cookie), the purpose of data processing is to analyse the users of the website for the purpose of enabling visitor-oriented development of the website to enhance the user experience.

The legal basis for the processing is the consent of the data subject, and the duration of the processing is until the date of deletion of the cookie by the data subject.

Analytic / marketing cookies are used to analyse and understand visitor behaviour and to collect anonymous data for statistical purposes and/or to serve targeted advertising.

The legal basis for the processing is the consent of the data subject, and the duration of the processing is until the date of deletion of the cookie by the data subject.

The recipients of the data are: the Company’s officers, employees performing tasks related to the operation of the website, the IT service provider, and the issuer of the cookie.

Server log file, hosting visitor statistics

Regardless of the information available through cookies, the Company may know and process the following data in connection with the visitor’s use of its website:

• the visitor’s IP address and/or mobile network information,
• browser type, version number and default language,
• the type and version of the operating system,
• the type of device used,
• the pages visited, the date and time of the visit, the referring website from which the visitor came,
• the name and address of your internet service provider host,
• clicks on the page.

The IP address can be used to determine the current location of the website at the time of viewing, with varying levels of accuracy.

The collection of traffic data is partly made possible by the programming language used to develop websites. However, some hosting software automatically collects statistics independently of the website owner.

The statistical data collection and processing does not contain any personal identification data and does not allow the identification of our visitors by name. We do not combine this data with other data sources, we use the collected statistical information to analyse the number of visits and to improve our website.

The legal basis for data processing is GDPR 6. Article 4(1)(f). the legitimate interests of the controller or a third party.

The recipients of the data are: the Company’s senior management, its employees performing tasks related to the operation of the website, its IT service providers.