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We would like to inform our customers that, with effect from 18 December 2019, the company name of our company changed from Parkour Technologies Kft. to Rollet Kft. These general terms and conditions reflect the change in the company name; no changes have been made to the contractual provisions.
Please read the contents of this privacy notice carefully.
By way of this privacy notice (hereinafter: the “Notice”), Rollet Kft. (formerly Parkour Technologies Kft., company registration number: Cg. 01-09-303490; tax number: 26130107-2-41; registered seat: 1051 Budapest, Vörösmarty tér 7-8. 4th floor) as data controller (hereinafter: the “Service Provider”) provides information on the processing of personal data by the Service Provider to every visitor (hereinafter: “Website Visitor”) of the Service Provider’s website available at https://www.rollet.hu (hereinafter: the “Website”), as well as to every private individual who wishes to use or uses the Service Provider’s parking service named “Rollet” (hereinafter: the “Service”) and the application enabling the use thereof, which can be run on a mobile phone or another suitable mobile device (hereinafter: the “Application”) (hereinafter: “User”), and to other private individuals (Website Visitors, Users and other private individuals together hereinafter: “Data Subjects”).
In order for the User to be able to use the Service, the User must become familiar with this Notice and must expressly consent to the processing, as described in this Notice, of the personal data described in this Notice. This can be done by ticking the checkbox relating to data processing during the installation of the Application. The full Notice is available during installation, prior to ticking the checkbox, via the hyperlink provided next to the checkbox. If the User does not consent to the data processing, use of the Service is not possible.
1. In connection with visiting the Website
On its Website, the Service Provider uses short texts, anonymous user identifiers, so-called cookies, in order to enhance the user experience and make use of the Website more convenient. Cookies store a unique computer identifier and profile information, placed on the Website Visitor’s computer or device. Cookies are not capable of identifying the person of the Website Visitor, but they are capable of identifying and recognising their computer or device.
By setting their browser appropriately, the Website Visitor may prohibit the placing of cookies on their computer or device. However, if the placing of cookies on the computer is prohibited, the user experience does not change.
The Service Provider may use the advertising services of third-party providers, in the course of which the third-party advertising provider may, by means of cookies, save the data of the Website Visitor, in particular the fact and time of the visit to the Website, the time spent on the Website, etc., so that the Website Visitor may receive targeted advertisements relating to the Service. The Website Visitor receives separate notification of this and must separately consent to receiving such advertisements.
2. In connection with installing the Application
Use of the Service is possible exclusively by downloading, installing and using the Application. During the installation of the Application, the Service Provider obtains from the online store enabling the download of the Application the download data (such as the time of the download of the Application and the name of the online store enabling the download of the Application), as well as the following personal data of the User: the type of software used on the User’s mobile device and the information as to whether the User is over 18 years of age. By installing the Application, the User consents to the processing of such data by the Service Provider.
If the User consents to this during the installation or use of the Application, the Application accesses the following applications on the User’s mobile device: camera, photos, location data. Granting access to the camera and to photos is not indispensable for using the Service; however, without granting access to location data the Service cannot be used.
3. In connection with registration for the Service
1. The scope of personal data required for registration.
The Service is available exclusively to Users registered in the Application. For the User’s registration, the Service Provider requests the following personal data from the User:
Data mandatory for registration:
for identifying the person of the User: the User’s surname, given name (gender);
for creating the User account and for keeping in contact with the Service Provider in the case of a private individual: the User’s e-mail address, telephone number, a password chosen by the User of at least 8 (eight) characters in length or – in the case of logging in using Google Connect or Facebook Connect – the personal e-mail address and password used for these; the password cannot be decrypted even by the Service Provider.
for identifying the vehicle the User wishes to register within the Application (hereinafter: the “Vehicle”) and for associating it with the User account: the licence plate number of the Vehicle;
for the purpose of sending invoices: the User’s surname, given name (gender), e-mail address.
Data that may be provided for registration at the User’s discretion:
the nickname given by the User to the Vehicle;
a photograph or video recording taken of the Vehicle from the front of the Vehicle with the driver-side door of the Vehicle in an open position;
for issuing an invoice to the User, if the User requests an invoice in addition to the electronic receipt automatically issued in connection with the use of the Service: the User’s residential address or postal address, billing address (optionally, if different from the residential address or postal address).
2. The User’s Facebook or Google account.
If the User decides to log in to the Application with their existing Facebook or Google account instead of providing a separate username and password, by providing this and by doing so they consent to the Service Provider obtaining certain data from Facebook or Google in accordance with the policies of Facebook and Google, and to the Service Provider being able to access the following personal data of the User:
the User’s username indicated on Facebook, gender, e-mail address, telephone number, profile picture, list of friends, or
the username and e-mail address used for the User’s Google account.
Beyond the above, the Service Provider does not obtain any other data from Facebook or Google.
3. Personal data required for the payment by the User of the fee and costs of the Service.
For registration for the Service, the personal data required for the payment by the User of the fee and costs of the Service (see below) are processed not by the Service Provider but by the operator of the service named Simple engaged by it, OTP Mobil Szolgáltató Korlátolt Felelősségű Társaság (registered seat: 1093 Budapest, Közraktár utca 30-32., company registration number: 01-09-174466; hereinafter: the “Payment Service Provider”). The personal data processed by the Payment Service Provider as data processor for the purposes of carrying out the payment transaction, authenticating the payment transaction and preventing possible fraud are the following: the bank card number provided by the User, its expiry date, the name of its holder, its CVC code, the name of its issuer (the bank issuing the bank card), the User’s name, telephone number, e-mail address, the amount of the transaction, the IP address of the device sending the transaction, the date and time of the transaction, the billing address. The sub-activity performed by the Payment Service Provider as data processor covers the recording, storage, transfer to authorisation partners and erasure of all such personal data.
The Payment Service Provider is entitled to engage sub-processors. For the authentication of payment transactions and the prevention of fraud, the Payment Service Provider engages the following sub-processors:
OTP Bank Nyrt. (1051 Budapest, Nádor u. 16., company reg. no. 01-10-041585)
Borgun hf. (Ármuli 30, 108 Reykjavik, Iceland, company reg. no. 440686-1259)
The Payment Service Provider is liable for the sub-processors engaged by it as if it had carried out the sub-processing activity itself. The Payment Service Provider is entitled to engage only such sub-processors as comply with the data protection legislation in force and with the provisions applicable to data processors under the general terms and conditions of the Payment Service Provider, with particular but not exclusive regard to the data security requirements.
The Service Provider does not automatically receive from the Payment Service Provider any of the personal data provided by the User to the Payment Service Provider; it receives merely a sequence of numbers generated by the Payment Service Provider on the basis of all such personal data. The above personal data provided by the User to the Payment Service Provider cannot be decrypted from the sequence of numbers generated on the basis of the bank card data, and the Service Provider is not able to become aware of them; however, upon the Service Provider’s request, the Payment Service Provider may disclose the bank card data to the Service Provider.
4. Recordings made of the Vehicle for the authentication of the Vehicle as potential personal data.
In accordance with the General Terms and Conditions relating to the use of the Service (hereinafter: the “GTC”), it is the User’s responsibility to ensure that no persons appear in the photograph or short video recording taken of the Vehicle, just as it is the User’s responsibility to hold the copyright in such recordings lawfully and to be able to lawfully provide a copy thereof to the Service Provider for the purpose of providing the Service.
In view of the fact that a User may register several Vehicles within the Application, by accepting this Notice the User declares that they have understood that, in accordance with the GTC, they are subject to an obligation to inform all users of the Vehicle registered in the Application about the scope of data processed by the Service Provider.
4. In connection with the provision of the Service
1. The scope of personal data.
The Service Provider processes the personal data indispensably necessary for the secure use of the Service via the Application, which, in addition to the personal data required for registration for the Service (see point 3.1 above), mean the User’s personal data related to parking, the latter being the following: the place and time of the Vehicle’s arrival at and departure from the parking space (Car Park), the fee and location of the parking, and the photographic or video recording taken of the Vehicle (and its driver and passengers) at the time of arrival and departure.
2. The camera surveillance system installed by the Service Provider in the Car Park.
The Service Provider operates an independent, uninterruptible camera system at the entry gates of the Car Park(s). One camera scans the licence plate number of every vehicle entering the Car Park, while another camera is activated when the camera scanning the licence plate numbers identifies a licence plate number registered by a User for the purpose of using the Service. The provisions of Act CXXXIII of 2005 on the Rules of Security Services Protecting Persons and Property and on the Activities of Private Investigators (hereinafter: the “Security Services Act”) govern their operation. The purpose of making the recordings is property protection: reducing the risk that the Service is used unlawfully to the detriment of the User by a person entering the parking space (Car Park) with a motor vehicle bearing the same licence plate number as the Vehicle but differing from the Vehicle, and thereby protecting the User’s property, since the detection of infringements, the apprehension of the perpetrator and the prevention and proof of such infringing acts cannot be achieved by other means; furthermore, the use of these technical devices is to an indispensably necessary extent and does not entail a disproportionate restriction of the right to informational self-determination. The Service Provider stores the recordings in a closed IT system separate from the Car Park. The Service Provider informs third parties in an appropriate manner about the fact of the camera surveillance and its field of view. The Service Provider erases the recordings without delay, but in any event within the deadline laid down in the legislation in force (see point III. 3. below).
3. Cameras of the Car Parks.
The car parks providing the parking spaces that may be used in connection with the Service (hereinafter: the “Car Park(s)”) may operate camera surveillance systems. The Service Provider is not liable for the operation of these cameras; the User may obtain information about them from the Car Park.
4. Data processing related to an authenticated Vehicle.
A User who has authenticated their Vehicle within the Application with a photograph or video recording enjoys the following benefits: * upon parking, they receive a welcome message from the Service Provider on their mobile device with the location of the given Car Park; and
already during the period of parking they may view and track within the Application the approximate location of the parking (parking area), the price list of the given Car Park, the duration of the parking (from the exact start of the parking to its end), the licence plate number of the Vehicle, and the total amount of the parking fee;
following the parking, they may view and track within the Application the exact location of their earlier parkings and the price lists of the Car Parks concerned applicable on the day of the parkings, the duration of their earlier parkings (from its exact start to its end), the parking fee paid during their earlier parkings, and the licence plate number of the Vehicle.
By comparison, a User who does not authenticate their Vehicle may, within the Application, during and after the period of parking, view only the date and current duration of the parking, the current parking fee, the licence plate number of the Vehicle and, at the end of the parking, the total amount of the parking, but not the approximate location of the parking (parking area) and its exact duration.
For the avoidance of doubt, the Service Provider processes the personal data listed above even if the User does not authenticate their Vehicle; the difference resulting from authentication is that a non-authenticated User may become aware of certain information only if and to the extent that they request information from the Service Provider in connection with the processing of their personal data, and only in respect of their own personal data.
5. In connection with complaint handling
The User may submit a complaint relating to the Service as described in the GTC. In connection with complaint handling, the Service Provider processes the personal data provided by the User in the course of the complaint submitted by them (in particular, but not exclusively, the time and manner of the submission of the complaint, the detailed description of the complaint, the circumstances of the use complained of, the documents submitted in connection with the complaint), and, to the extent necessary for handling the complaint, the personal data processed in the context of providing the Service to the User. The Service Provider informs Users separately about the rules of complaint handling.
6. In connection with the marketing activity intended to be carried out by the Service Provider
In order to promote the Service among Users, to advance the awareness and use of the Service, and to improve the quality of the Service, the Service Provider processes Users’ surname, given name (gender), e-mail address, residential address or postal address, telephone number and mobile telephone number.
The Service Provider may carry out data processing for marketing purposes only with the User’s separate express consent, and shall terminate the data processing serving this purpose without delay at the User’s express request.
To subscribe to receive the newsletter, the Website Visitor, as Data Subject, must provide their e-mail address and the name of the locality of their place of stay. Upon subscribing to the newsletter, the time of subscription and the IP address at the time of subscription may also be recorded.
By subscribing to receive the newsletter and direct marketing materials, the Data Subject consents to the Service Provider sending the Data Subject electronic messages containing advertising and providing information about current news, promotions, new functions, games, etc.
7. For other purposes
The Service Provider monitors the number of cars entering the Car Parks and processes this for business development purposes, and also prepares statistics and reports from other anonymised data in order to develop the Service.
1. To the Car Parks: In order to provide the Service in full and without disruption, the Service Provider necessarily cooperates closely with the Car Parks and transfers to them the licence plate number of the Vehicle, the time of the Vehicle’s arrival at and departure from the Car Park (i.e. the duration of the parking), the image and video recordings made of this (entry and exit), the location of the approximate place of the parking (parking area), the fee of the parking, and the pricing of passes per parking space. The Car Parks act as data processors of the Service Provider in respect of all such personal data.
In the event that the outstanding parking fee exceeds the deposit amount requested by the Service Provider upon registration in the Application, in addition to the above the Service Provider transfers to the Car Park, for the purpose of payment of the parking fee, the User’s surname, given name and telephone number. The Car Parks act as independent data controllers in respect of all such personal data, since in such cases the parking takes place on the basis of a contract concluded with the Car Park.
2. To the company operating the invoicing software: The Service Provider prepares and issues the invoice for the consideration of the Service with software operated by KBOSS.hu Kft. (registered seat: 1031 Budapest, Záhony utca 7.). This company may become aware of the content of the invoices (the User’s surname, given name (gender), residential address or postal address, billing address (if different from the residential address), as well as the duration of the User’s parking and the fee of the parking) for the purposes of operating, maintaining and troubleshooting the invoicing management software, to the minimum extent and for the minimum period necessary for performing all such tasks. In this respect, KBOSS.hu Kft. acts as a data processor engaged by the Service Provider.
3. To the police, the national defence and national security services: In cases prescribed by law or on the basis of a final court decision, the Service Provider may hand over all processed personal data to the law enforcement bodies specified in legislation (in particular, but not exclusively, the police, the national defence and national security services).
4. To the accounting, financial and legal advisors engaged by the Service Provider: In order to comply with its statutory obligations, to secure its claims, and to enforce its rights and legitimate interests, the Service Provider may transfer the personal data described in this Notice to the advisors engaged by the Service Provider (in particular, but not exclusively, accountants, financial and legal advisors).
1. The Service Provider retains the personal data related to visiting the Website, in order to enforce its rights and legitimate interests, for five (5) years from the time of the visit (or, if the limitation period for possible enforcement of claims is longer, until the end of such period).
2. The Service Provider retains the personal data related to the installation of the Application and to registration for the Service, in order to enforce its rights and legitimate interests, for five (5) years from the termination of the User’s registration (or, if the limitation period for possible enforcement of claims is longer, until the end of such period).
3. The Service Provider retains the personal data related to the provision of the Service and to keeping in contact, in order to enforce its rights and legitimate interests, for five (5) years from the time of the User’s parking (or, if the limitation period for possible enforcement of claims is longer, until the end of such period), with the exception of
the invoices issued by the Service Provider, which the Service Provider retains until the end of the period corresponding to the legislation in force at any given time (at the time of this Notice: for eight (8) years).
4. The Service Provider retains the personal data related to complaint handling, in order to enforce its own and the User’s (consumer’s) rights and legitimate interests, for five (5) years from the time of the complaint (or, if the limitation period for possible enforcement of claims is longer, until the end of such period).
5. The Service Provider retains the personal data for marketing purposes until the deletion of the User’s registration or until the withdrawal of consent.
The Service Provider stores the personal data at its registered seat (1051 Budapest, Vörösmarty tér 7-8. 4th floor).
The legal basis for the processing (collection, storage, transfer, etc.) by the Service Provider of the personal data listed in this Notice is the voluntary consent of the Data Subjects (Website Visitor, User, etc.), pursuant to Section 5(1)(a) of Act CXII of 2011 on the Right to Informational Self-Determination and on Freedom of Information (hereinafter: the “Information Act”) and Article 6(1)(a) of 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; hereinafter: the “GDPR”).
In the event of withdrawal of consent, the Service Provider processes the personal data listed in this Notice pursuant to Section 6(4) and Section 6(1)(b) of the Information Act and Article 6(1)(b) and (c) of the GDPR.
The Service Provider processes the personal data related to complaint handling pursuant to Act V of 2013 on the Civil Code and Section 17/A of Act CLV of 1997 on Consumer Protection.
1. It is of paramount importance to the Service Provider that the personal data processed by it be secure and that no event breaching data security occur which results in the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or unauthorised access to, personal data transmitted, stored or otherwise processed (personal data breach).
2. The Service Provider seeks to ensure, by means of appropriate contracts, that all personal data are accessed by persons (employees, contributors, whether on the side of the Service Provider or of its data processors) only to the extent and for the period necessary to involve them for the purpose to be achieved. The Service Provider increases and develops the data protection awareness of such persons through data protection training, in order thereby also to prevent the occurrence of personal data breaches and to facilitate the effective, swift and reassuring handling of any personal data breach that may occur.
3. Taking into account the state of the art and the costs of implementation, as well as the nature, scope, context and purposes of the processing, and the risk of varying likelihood and severity for the rights and freedoms of natural persons, the Service Provider implements appropriate technical and organisational measures in order to guarantee a level of data security appropriate to the level of risk, including inter alia, as appropriate, the pseudonymisation and encryption of personal data, and the ongoing confidentiality, integrity, availability and resilience of the systems and services used for processing personal data.
4. For the security of personal data, in the event of a physical or technical incident the Service Provider restores access to the personal data and the availability of the data in a timely manner and keeps the measures taken under continuous review.
5. The Service Provider ensures a process for regularly testing, assessing and evaluating the effectiveness of the technical and organisational measures taken to guarantee the security of the processing.
6. In the area of outsourced activities, the Service Provider intends to select its partners on the basis of a careful selection procedure, bearing in mind the extent to which they are able to guarantee the security of the personal data coming into their possession.
1. The right to transparent information and communication. The Service Provider takes appropriate measures to provide the Data Subject with all information and all communication relating to the processing of personal data in a concise, transparent, intelligible and easily accessible form, using clear and plain language. The Data Subject may access the version of this Notice of the Service Provider on the processing of personal data in force at any given time on the Service Provider’s website and within the Application.
2. Right of access. The Data Subject has the right to obtain confirmation from the Service Provider as to whether or not their personal data are being processed and, where such processing is taking place, has the right to obtain access to the scope of the personal data, the purpose of the processing, the recipients of the processing, the envisaged period of storage of the data, information on the source of the data, or other information specified by law.
3. The right to rectification and erasure. The Data Subject has the right to obtain from the Service Provider, at their request, without undue delay the rectification or completion of inaccurate personal data concerning them. The Service Provider expressly requests every Data Subject to initiate with the Service Provider the correction of inaccurate personal data in the event of any change in data, detection of incorrectly recorded data, or any provision of untrue data.
4. The right to restriction of processing. The Data Subject has the right to obtain from the Service Provider, at their request, restriction of processing where the data subject contests the accuracy of the personal data, the processing is unlawful and the data subject requests the restriction of the use of the data instead of their erasure, the controller no longer needs the personal data for the purposes of the processing but they are required by the Data Subject for the establishment, exercise or defence of legal claims, or the data subject has objected to the processing.
5. The right to data portability. The Data Subject has the right to receive the personal data concerning them, which they have provided to the Service Provider, in a structured, commonly used and machine-readable format, and has the right to transmit those data to another controller without hindrance from the Service Provider to which the personal data have been provided.
6. The right to object. The Data Subject has the right to object at any time, on grounds relating to their particular situation, to the processing of personal data concerning them where the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, or where the processing is necessary for the purposes of the legitimate interests pursued by the Service Provider or by a third party, including profiling based on those provisions. In this case, the Service Provider may no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or which relate to the establishment, exercise or defence of legal claims.
7. Enforcement of rights. The Data Subject may exercise the rights set out in this point VII by way of a request sent to the Service Provider’s e-mail address [email protected].
8. Data protection officer. The Service Provider designates a data protection officer, in view of the fact that the Service, as the Service Provider’s core activity, involves processing operations which, by virtue of their nature, scope and/or purposes, require regular and systematic monitoring of Data Subjects on a large scale. The data protection officer can be reached directly at the following e-mail address: [email protected].
If the Service Provider fails to comply with its obligation in respect of any of the data subject’s above requests, then, upon the data subject’s request, the Hungarian National Authority for Data Protection and Freedom of Information (hereinafter: the “NAIH”) will launch an investigation in the matter or conduct an official procedure.
Contact details of the NAIH:
Hungarian National Authority for Data Protection and Freedom of Information
Address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c.
Telephone: 061/391-1400
Fax: 061/391-1410
E-mail address: [email protected]
Website: https://www.naih.hu
Irrespective of the NAIH’s decision, the Data Subject may turn to the competent court in the event of an infringement of their rights.
1. For the registration for the Service and for the use of the Service, the User may provide only their own true data. The Service Provider bears no liability for any legal consequences arising from the User providing untrue data or data that is not their own.
2. The Service Provider is entitled to request verification of the data in accordance with the general terms and conditions of the contract concluded between the Service Provider and the User for the use of the Service.
3. The Service Provider is not liable for the data processing and data security measures of third-party providers; the privacy notices of those third-party providers shall govern in respect of these.
4. The Service Provider reserves the right to amend the Notice at its own discretion in the future, in particular in the event of a change in legislation, in order to ensure that the information contained in the Notice provides appropriate information regarding the collection and processing of the Data Subjects’ personal data.
5. In the event of an amendment of the Notice, the Service Provider shall send the fact of the amendment, a concise summary of the changes with an indication of the amended provisions, the date of entry into force of the amendment and the full text of the amended Notice to Users at the e-mail addresses provided during registration at least ten (10) days before the entry into force, and shall also publish them on the Website.
6. The provisions of the Notice may be supplemented by other information received by the Data Subject from the Service Provider.
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