PRIVACY POLICY

ZEBRA PEN (UK) Limited Hungarian Branch Office

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TABLE OF CONTENTS

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Company name: A ZEBRA PEN (UK) Limited Hungarian Branch Office
Company’s abbreviated name: ZEBRA PEN
Registered office: H-1039 Budapest, Pünkösdfürdő utca 52.
Postal address: H-1039 Budapest, Pünkösdfürdő utca 52.
Company registration number: 01-17-001339
Registration authority: Metropolitan Court of Registration
Tax number: 28753773-2-41
Name of representative: Lázár Szilvia, branch director
E-mail: marketing@zebrapen-eu.hu
Phone: +36 1 630 9173
Website: https://zebrapeneu.com

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ZEBRA PEN sends newsletters to subscribers by using MailChimp’s newsletter sending interface operated by The Rocket Science Group LLC.

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ZEBRA PEN controls the personal data of the contact persons (name, contact info) of potential new contractual partners for the purpose of direct marketing activities.

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Legal basis for data controlling is the prior consent of the recipient, given by subscribing to the newsletter (Article 6 Section (1) Point a) of GDPR).

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Persons subscribing voluntarily to the newsletter of ZEBRA PEN.

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While sending the newsletter ZEBRA PEN controls the following personal data of the subscriber:

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Should the recipient of the newsletter unsubscribe from the newsletter, ZEBRA PEN shall consider this to be a withdrawal of the recipient’s consent and shall not send further newsletters to the recipient and as from the unsubscription is detected, the recipient shall be deleted from the recipient list.

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ZEBRA PEN controls the personal data (name, contact info) of the contact persons of potential new contractual partners for the purpose of direct marketing and stores them in its own CRM system for a specified period of time.

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Based on the expressed and voluntary consent of the concerned data subject, ZEBRA PEN contacts these data subjects with advertising materials and promotional offers (Article 6 Section (1) Point a) of GDPR).

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The persons filling out and sending the contact form located on the Website.

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During the completion of the contact form, ZEBRA PEN controls the following personal data of the persons filling out the contact form:

• full name
• email address
• phone number
• address
• company name

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The consent given during the submission of the contact form is sent by e-mail to the e-mail address order@zebrapen-eu.hu, to which the marketing staff member shall have access. If no agreement is reached between ZEBRA PEN and the company of the data subject on the basis of the requests, ZEBRA PEN shall store the data controlled in connection with the requests for 6 months, unless the data subject expressly requests further controlling of its data, after which ZEBRA PEN shall delete them immediately.

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The data subject is entitled to withdraw its consent to data controlling for marketing purposes at any time by sending a statement to marketing@zebrapen-eu.hu, in which case ZEBRA PEN shall delete the data subject’s personal data from its records.

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The Website uses cookies. The cookie is sent by the web server to the visitor’s browser and then is returned by the browser to the server.

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Cookies are encrypted data sets, paths that are stored by the browser of the data subject visiting the Website and shall only be interpreted together with the given server. The user’s data itself is stored by the server, not by the cookie. The next time the data subject visits the Website, its browser will read the cookie and display the information or item on the Website that originally set the cookie. Cookies are usually stored by visiting or leaving the Website. Cookies cannot be used to identify the data subject and do not affect the performance of the data subject’s device.

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For more information about cookie technology and how cookies work, visit e.g. www.allaboutcookies.org.

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The data subject is entitled to determine the conditions for storing and accessing cookies by appropriately setting its internet browser. Most browsers generally accept cookies by default. However, the data subject may completely disable cookies or set its browser to send an alert when sending a cookie. In order to prevent the reception of cookies or to apply settings, the data subject shall change the browser settings. For information on disabling or enabling cookies the data subject shall visit its browser’s “Help” menu. For popular browsers, information on setting cookies can be found at the following links:

• Internet Explorer: https://support.microsoft.com/hu-hu/help/17442/windows-internet-explorer-delete-manage-cookies;
• Mozilla Firefox: https://support.mozilla.org/hu/questions/new/desktop/cookies;
• Google Chrome: https://support.google.com/chrome/answer/95647?hl=hu;
• Opera: http://help.opera.com/opera/Windows/2256/en/controlPages.html#manageCookies
• Safari: https://support.apple.com/kb/PH5042

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By clicking on the “Accept” button, the data subject gives its expressed consent to the storage of cookies on its device (Article 6 Section (1) Point a) of GDPR).

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More information about the cookies used to visit the Website from a mobile device can be found on the following pages:

• Android: https://developer.android.com/reference/android/webkit/CookieManager.html
• Blackberry: https://docs.blackberry.com/en/smartphone_users/deliverables/3200 /Turn_off_cookies_in_the_browser_60_1072866_11.jsp
• Opera: https://www.opera.com/help/tutorials/security/privacy/
• SafariOS: https://support.apple.com/kb/PH5042

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Persons visiting the Website only when giving their consent.

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When using cookies, ZEBRA PEN controls the following personal data of the visitors:

• IP address
• location
• time and date, duration and frequency of visiting https://zebrapeneu.com/ website

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Depending on their type, these files shall be deleted at the end of the browsing session (temporary cookies) or after a longer period of time (permanent cookies).

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A data processor is a natural or legal person who processes personal data on behalf of ZEBRA PEN as data controller.

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ZEBRA PEN engages the following data processors for data processing:

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Name	Registerd office and further contact info	Description of the activity carried out	Scope of controlled data
BlazeArts Korlátolt Felelősségű Társaság	https://www.forpsi.org/hu/home registered office: 6090 Kunszentmiklós, Damjanich u. 36. 1/8 company registration number: 03-09-109150 tax number: 12539833-2-03 E-mail: https://webmail.forpsi.com/ Phone: (+36 1) 610 5506	The host of ZEBRA PEN own website. The information You provide is stored on a server operated by the hosting provider. The data can only be accessed by our employees and the employees operating the server, however, they shall all be responsible for the secure controlling of the data. The purpose of data controlling is to ensure the operation of the Website. The personal data provided by the data subject will be processed until the end of the operation of the Website or in accordance with the contractual agreement between the Website’s operator and the hosting provider. If necessary, the data subject may also request the deletion of its data by contacting the hosting provider. The legal basis for data controlling is the consent of the data subject and data data controlling based on law. The data center is located in Ktiš, at the headquarters of INTERNET CZ, a.s.	storage and backup of Website data (including contact form submissions)
Google (Google Analytics)	https://www.google.com/about/datacenters/	ZEBRA PEN measures the traffic of the Website by using Google Analytics. Data is transmitted during the use of the service. The data transmitted are not suitable for identifying the data subject. For more information about Google’s privacy principles, go to https://www.google.com/policies/privacy/ads/ .	cookie data
The Rocket Science Group LLC	https://mailchimp.com/ The Rocket Science Group, LLC 675 Ponce de Leon Ave NE Suite 5000 Atlanta, GA 30308 USA Products .	The Rocket Science Group LLC is the data processor engaged by ZEBRA PEN and ZEBRA PEN ensures the security of personal data and data controlling in accordance with the GDPR through the review of the data protection regulations of The Rocket Science Group LLC. .	data provided by the user, based on consent, for sending newsletters or for direct marketing
iWebMa Magyarország Korlátolt Felelősségű Társaság	registered office: 1061 Budapest, Király u. 26. company registration number: 14666641-2-41 tax number: 14666641-2-41 E-mail: webma@iwebma.com Phone: (+36 1) 786 48 45	web-developer company	website data

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ZEBRA PEN takes appropriate data security measures to protect the personal data provided by data subjects. Within this scope, its IT systems, which also contain personal data stored in electronic form, are protected by a multi-level password.

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ZEBRA PEN protects the security of personal data controlled in relation to the operation of Website with technical, organizational and physical measures, including secure servers and firewalls.

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Data subjects shall have the right to request from ZEBRA PEN access to and rectification or erasure of personal data concerning them or restriction of data controlling and to object to data controlling as well as the right to data portability.

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ZEBRA PEN specifies below the content of certain rights to be exercised by data subjects in accordance with data controlling and certain characteristics of exercising these rights.

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The data subjects shall have the right to obtain confirmation from ZEBRA PEN as data controller as to whether or not personal data concerning them are being controlled. In case their personal data are being controlled, the data subjects shall have the right to access the personal data and the following information:

• the purposes of the data controlling;
• the categories of personal data of the data subject;
• the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
• the envisaged period for which the personal data will be stored;
• the rights of data subject in relation to data controlling (in particular the right to rectification, erasure or restriction of data controlling and to object);
• the right to lodge a complaint with the supervisory authority;
• any available information as to the source of data;
• the existence of automated decision-making, including profiling and at least meaningful information about the logic involved, as well as the significance and the envisaged consequences of such data controlling for the data subjects.

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ZEBRA PEN as data controller shall provide a copy of the personal data undergoing data controlling. For any further copies requested by the data subjects, ZEBRA PEN may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided by ZEBRA PEN in electronic form. The right to access shall be exercised by using the contact details provided in Section 5.8.

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The data subjects shall have the right to request the rectification of inaccurate personal data concerning them and ZEBRA PEN shall comply with such request without undue delay. Taking into account the purposes of the data controlling, the data subjects shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

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The data subjects shall have the right to have ZEBRA PEN erase personal data concerning them without undue delay. ZEBRA PEN shall erase the personal data of data subjects without undue delay, if:

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ZEBRA PEN shall refuse to erase the personal data of data subjects, if the data controlling is necessary for compliance with a legal obligation which requires data controlling by European Union or Member State law to which ZEBRA PEN is subject or for the submission, assertion or defense of legal claims.

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The data subjects shall have the right to obtain from ZEBRA PEN restriction of controlling their personal data, if:

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Should data controlling be restricted, such personal data shall, with the exception of storage, only be controlled with the data subject’s consent or for the submission, assertion or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.

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The data subjects shall have the right to receive the personal data concerning them, which they have provided to ZEBRA PEN, in a structured, commonly used and machine-readable format and to transmit such data to another controller if the data controlling is based on consent or a contract and the data controlling is carried out by automated means.

In exercising the right to data portability, the data subjects shall have the right to have the personal data transmitted directly from one controller to another, if technically feasible.

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The data subjects shall additionally have the right to object at any time to controlling of personal data concerning them for direct marketing purposes, which includes profiling. In such cases the personal data shall no longer be controlled for such purposes.

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In case the data subject objects, ZEBRA PEN shall no longer control the personal data unless ZEBRA PEN demonstrates compelling legitimate basis for the data controlling which override the interests, rights and freedoms of the data subject or for the submission, assertion or defense of legal claims.

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The data subjects shall have the right to revoke their consent at any time. The consent of the data subjects shall be deemed as the legal basis for the data controlling in case of the data controlling purposes set forth in Section 2 of this Policy. The legal basis for the data controlling shall not affect the lawfulness of data controlling based on consent before its revocation, thus the prior data controlling of ZEBRA PEN based on consent is not rendered unlawful by the fact that the data subjects subsequently revoke their consent.

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The data subjects can notify ZEBRA PEN of their request to exercise any of their rights related to data controlling by the following contact details:

• personally, at the registered office of ZEBRA PEN: H-1039 Budapest, Pünkösdfürdő utca 52.
• in writing by mail: H-1039 Budapest, Pünkösdfürdő utca 52.
• electronically: order@zebrapen-eu.hu / marketing@zebrapen-eu.hu

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ZEBRA PEN shall provide the data subject with information on the evaluation of the request and the measures taken without undue delay, but within 1 (one) month of receipt of the request, at the latest. In case the data subject submits a large number of requests, or his/her request is particularly complex, ZEBRA PEN may extend the 1 (one) month period by 2 (two) additional months but shall inform the data subject on the justification and reasons of such extension within 1 (one) month of receipt of the request. The data subject is notified by ZEBRA PEN on its decision in writing or by electronic means, where the request was submitted by electronic means.

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In case ZEBRA PEN does not take measures on the request of the data subject, ZEBRA PEN shall inform the data subject without delay but within 1 (one) month of receipt of the request at the latest of the reasons for not taking measures and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.

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The above information and measure shall be provided by ZEBRA PEN free of charge.

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Should requests from a data subject be manifestly unfounded or excessive, in particular because of their repetitive character, ZEBRA PEN as data controller may either, considering the administrative costs of providing the information or notification or taking the measure requested:

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ZEBRA PEN is obliged to demonstrate the manifestly unfounded or excessive character of the request.

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The detailed provisions of the rights of data subjects related to data controlling are specified in Chapter III „Rights of data subject” of GDPR and in Sections 14-21 of Data Protection Act.

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Within the scope of alternatives to exercising rights, the data subjects may initiate two procedures, which are described by ZEBRA PEN below:

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The data subjects shall have the right to lodge a complaint with National Authority for Data Protection and Freedom of Information (hereinafter: NAIH) as supervisory authority, if the data subjects consider that the controlling of personal data concerning them infringes the provisions of GDPR.

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The contact details of NAIH:

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Registered office: H-1125 Budapest, Szilágyi Erzsébet fasor 22/c.
Postal address: 1530 Budapest, Pf. 5
Phone: +36 1 391 1400
Official electronic mail address: ugyfelszolgalat@naih.hu
The website of NAIH: https://naih.hu

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The data subjects shall additionally have the right to judicial remedy (i) against a legally binding decision of the supervisory authority concerning them, (ii) if the supervisory authority does not handle a complaint or (iii) does not inform the data subjects within 3 (three) months on the progress or outcome of the complaint lodged. The data subjects may, at their own discretion, bring the proceedings before the competent regional court where the data subjects have their residential address or place of stay.

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The personal data breach shall mean 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 controlled.

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In case of a personal data breach, ZEBRA PEN shall, without undue delay, and where feasible, not later than 72 hours after having become aware of it, notify the competent supervisory authority on the personal data breach, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of the data subjects. To ensure this, ZEBRA PEN shall take all necessary measures.

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ZEBRA PEN shall notify the data subjects on the personal data breach without undue delay if it is likely to result in a high risk. In such case ZEBRA PEN shall, in the notification addressed to the data subjects, describe in clear and plain language the nature of the personal data breach, the likely consequences of the personal data breach and the measures taken or proposed to be taken to remedy the personal data breach, including, if applicable, measures to mitigate its possible adverse effects.

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__ July 2021

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