Content

1. Purpose of the Privacy Policy

Thegoal of our Privacy Policy is to provide all necessary informationabout processing your, as Data Subjects’ personal data in aconcise, transparent, intelligible and easily accessible form, usingclear and plain language, and assist you in exercising your rightsunder Section 4.

Withinthe current Privacy Policy, “Members” are qualified as thepersons or the representatives of companies who order our servicesand register to our Member database. “Service Providers” arethird party providers who offer cleaning services and certain otherservices published on our website. Both of these parties are DataSubjects in the scope of the Privacy Policy.

Ourdatabase where we store the Data Subjects’ personal data is locatedin Budapest.

Weare committed to protecting your privacy and developing technologythat gives you the most powerful and safe online experience. ThisPrivacy Policy applies to Homeluxy website and governs datacollection and usage.

Thelegal base of our duty to communicate information is Article 12 ofRegulation 2016/679 of the European Parliament and Council(hereinafter referred to as: GDPR) and Section 16 of Act CXII of 2011on the right to self-determination concerning personal informationand the freedom of information (hereinafter referred to as:‘Hungarian Information Act’).


2. Data of the Data controller

Name

SLS HUNGARY Bt.

Website

https://www.homeluxy.com/

Registry number

01-06-789505

Registered seat

1065 Budapest, Révay utca 6. fszt. 7.

Tax number

25289617-2-42

E-mail

info@homeluxy.com

Telephone number

+352621465738



3. Data processing activities

3.1. Processing concerning connection andcommunication, application as a Service Provider

Itis possible to contact us through the connection form and thechat-box located on the website. You can also find us in our Facebookpage, where we use chat bot software to collect your personal data inaccordance with the privacy regulations of Facebook. After youprovide the necessary information to us via Messenger, your personaldata are automatically forwarded to our website’s database.

Ifyou contact us as a Service Provider, we may ask further informationabout you (such as spoken languages) and you may also get evaluationsfrom the Members; evaluations are necessary for us and the otherMembers to get feedbacks from your work. The details of suchprocessing are described hereunder.

3.1.1.Processed personal data andpurpose of processing

personal data

purpose of processing

name

identifying you

phone number

contacting you

e-mail address

contacting you

spoken languages

checking your competences


3.1.2.Legal basis of processing

Processing(contacting) is necessary for compliance with a legal obligation;with regard to section 6 paragraph 1 point f of GDPR, section 5article 1 point b of the Hungarian Information Act and section 13/A.§ paragraph 1 and 3 of Act CVIII of 2001 and the relevantregulations of Luxembourgish law.

Contactingwith you as a Service Provider is necessary for taking steps at yourrequest prior to entering into a contract between you and the Memberwho ordered for services you provide (section 6 paragraph 1 point bof GDPR).

3.1.3.Duration of the processing

Ifyou contact us as a Member, we store your personal data for otherpurposes defined in the following parts of the current PrivacyPolicy. If you don’t register to our website thus not become ourMember, your connection data are stored in our e-mail box which weregularly revise.

Ifyou contact us as a Service Provider, we store your personal data inour database no longer than it is necessary for the purposes of thecollection; once we contact you with a Member who is looking for aService Provider, we instantly erasure all your personal data fromthe database.

3.1.4.Mode of processing

Personaldata are collected automatically, in electronic form.

3.2. Processing concerning registration,ordering and providing our services

Youare free to register (by providing your data located in our website’s“Sign in” menu) and book any of our services shown in our website(booking Service Providers for cleaning, gardening, repair work, andcooking), thus becoming our Member. The details of such processingare described hereunder.

3.2.1.Processed personal data andpurpose of processing

personal data

purpose of processing

name

identification of you or your representative

phone number

contacting you or your representative and giving information about the services; connecting with the eligible Service Provider

e-mail address

contacting you or your representative and giving information about the services; connecting with the eligible Service Provider

address (city)

contacting you or your representative; connecting with the eligible Service Provider

password

performing technical measures

payment details (such as bank account number)

performing the payment

3.2.2.Legal basis of processing

Ifyou are a person or self-employed, processing is necessary for theperformance of the contract concluded between you and us, as well asfor taking steps at your request prior to entering into a contractbetween you and the Service Provider who provide the services youbooked through our website (section 6 paragraph 1 point b of GDPR).

Ifyou, as the representative of a Member provide your personal data forthe above purposes, the legal basis of processing your personal data– with regard to the relevant authorial practice – is thelegitimate interest of each party in the relationship (us, theMember, the Service Provider, legal basis: section 6 paragraph 1point f of GDPR). It is each party’s legitimate interest tomaintain an effective business communication and to finalize thebooking. In our view – since it is the part of your scope of duty –the processing of the mentioned personal data doesn’t restrictdisproportionately your privacy and freedom of self-determination.

3.2.3.Duration of the processing

Weprocess your personal data as long as your Member profile is notdeleted, but – with regard to section 6:28 of act V of 2013 on theCivil Code (Hungarian Civil Code) – no longer than five yearsfollowing the last activity you demean concerning our services (suchas booking, writing an e-mail to us).

3.2.4.Mode of processing

Personaldata are collected automatically, in electronic form.

3.2.5.Provision of processing

Sincewe cannot perform our duties (connecting you with the eligibleService Provider) without knowing any information about you, theprocessing is a requirement necessary to enter into a contract bothwith us and the Service Provider.

3.3. Processingconcerning invoicing

Followingthe performance of the bookings we – with regard to Act C of 2000on accounting (hereinafter referred to as: Hungarian Accounting Act)– make out a bill. The details of such processing are describedhereunder.

3.3.1.Processed personal data andpurpose of processing

personal data

purpose of processing

Member’s (person or self-employed) name

confirmation of the accounting concerning the booking

Member’s (person or self-employed) address / headquarters

confirmation of the accounting concerning the booking


3.3.2.Legal basis of processing

Processingis necessary for compliance with a legal obligation; with regard tosection 6 paragraph 1 point c of GDPR, section 5 article 1 point b ofthe Hungarian Information Act and section 166 paragraph 1 to 3 of theHungarian Accounting Act.

3.3.3.Duration of the processing

8years following the accounting.

3.3.4.Mode of processing

Personaldata are collected manually, in electronic form.

3.3.5.Provision of processing

Sincewe cannot perform our accounting obligations without knowing anyinformation about you, the processing is a statutory requirement.

3.4. Processing concerning newsletter

Inorder to provide relevant information to you, it is possible tosubscribe to our newsletter. You can subscribe during registration byclicking on the consent button, or you can get information from usthrough direct message programs such as Messenger on your priorconsent. The details of such processing are described hereunder.

3.4.1.Processed personal data andpurpose of processing

personal data

purpose of processing

name

to identify you and address you in the letter

e-mail address

sending the newsletter


3.4.2.Legal basis of processing

Yourconsent (article 6 point (1) a of GDPR).

3.4.3.Duration of processing

Weprocess your personal data until the withdrawal of your consent,which you can do anytime by clicking the “Unsubscribe” button inthe newsletter.  The withdrawal ofyour consent does not affect the lawfulness of the processing basedon consent before the withdrawal.

3.4.4.Mode of processing

Personaldata are collected both automatically and manually, in electronicform.

3.5. Processingconcerning customer service

Inorder to answer your questions or to monitor the circumstances yourequested a complaint for, we operate customer service on ourwebsite.

3.5.1.Processed personal data andpurpose of processing

personal data

purpose of processing

name

to identify you

e-mail address

to contact you and provide information

phone number

to contact you and provide information


3.5.2.Legal basis of processing

Weprocess the personal data we collect from you by legal obligations(section 6 article (1) point c) of GDPR, and section 17/A, article 5of Act CLV of 1997 on consumer protection, hereinafter referred toas: Hungarian Consumer Protection Act).

3.5.3.Duration of processing

Weprocess your personal data as long as the relevant consumerprotection acts determine it; in line with section 17/A, article 7 ofthe Hungarian Consumer Protection Act, we are obliged to keep therecords and its copy of your complaint five years following yourrequest.

3.5.4.Mode of processing

Personaldata are collected manually, in electronic and paper form.


4. What are you rights?

4.1.Right to access:

Youhavethe right to obtain confirmation as to whether or not personal dataconcerning you are being processed, and, where that is the case,access to the personal data and the information featured in point 3.

4.2.Right to rectification

Youhave the right to obtain from us without undue delay therectification of inaccurate personal data concerning you. Taking intoaccount the purposes of the processing, you have the right to haveincomplete personal data completed, including by means of providing asupplementary statement.

4.3.Right to erasure:

Youhave the right to obtain from us the erasure of personal dataconcerning you without undue delay and we shall have the obligationto erase personal data without undue delay if it is mandatoryaccording to Article 17 of GDPR.

4.4.Right to be forgotten:

Ifwe made the personal data public and are obliged to erase yourpersonal data, we inform controllers which are processing thepersonal data that you have requested the erasure by such controllersof any links to, or copy or replication of, those personal data

4.5.Right to restriction of processing:

Youhave the right to obtain from us restriction of processing if isobligatory according to Article 18 of GDPR.

4.6.Right to data portability:

Youhave the right to receive the personal data concerning you, in astructured, commonly used and machine-readable format and have theright to transmit those data to another controller without hindrancefrom us if is possible according to Article 20 of GDPR.

4.7.Right to complain:

Youhave the right to appeal to courts of Hungary and Luxemburg as wellas to make a complaint to the Hungarian (Address:1125 Budapest, Szilágyi Erzsébet fasor 22/c.;https://www.naih.hu/panaszuegyintezes-rendje.html)and the Luxembourgish(https://cnpd.public.lu/en.html#) supervisory authorities of dataprotection.


5. Measures and notification

5.1.Informing you

Wecommunicate any rectification or erasure of personal data orrestriction of processing carried out in accordance with Article 16,Article 17(1) and Article 18 of GDPR to each recipient to whom thepersonal data have been disclosed, unless this proves impossible orinvolves disproportionate effort. We also inform you about thoserecipients if you request it.

5.2.Mode and deadline of notification

Weprovide information on action taken on a request under Articles 15to 22 of GDPR to you without undue delay and in any event withinone month of receipt of the request. That period may be extended bytwo further months where necessary, taking into account thecomplexity and number of the requests. We inform you of any suchextension within one month of receipt of the request, together withthe reasons for the delay. Where you make the request by electronicform means, we provided the information by electronic means wherepossible, unless you request it otherwise.

Ifwe do not take action on your request, we inform you without delayand at the latest within one month of receipt of the request of thereasons for not taking action and on the possibility of lodging acomplaint with a supervisory authority and seeking a judicial remedy(see point 4.7.).

5.3.Monitoring

Ifwe have reasonable doubts concerning the identity of the naturalperson making the request, we may request the provision of additionalinformation necessary to confirm your identity.

5.4.Costs of measures and notifications

Weprovide you information and take the necessary measures free ofcharge.

Ifyour requests are manifestly unfounded or excessive, in particularbecause of their repetitive character, we may charge a reasonable feetaking into account the administrative costs of providing theinformation or communication or taking the action requested or werefuse to act on your request.


6. Possible recipients


6.1.Duringthe operation of our website and the

Ourcontracted partners, such as the website’s hosting provider, thesoftware’s provider, an IT developer company, a marketing companymay have access to the personal data you provide while using thewebsite and taking our services.

6.2.Social media

Ourwebsite has several social media profile so that if you „like” uson Facebook or „follow” us on Twitter, we may learn all thepersonal data which is public on your profile.

6.3.Accounting

The Hungarian national tax authority is entitled to learn all informationconcerning accounting.

Name:Nemzeti Adó- és Vámhivatal

Connection: https://www.nav.gov.hu/nav/kapcsolat


7. Cookies

7.1.Cookies in general

Acookie is a file containing an identifier (a string of letters andnumbers) that is sent by a web server to a web browser and is storedby the browser. The identifier is then sent back to the server eachtime the browser requests a page from the server.

Cookiesmay be either "persistent" cookies or "session"cookies: a persistent cookie will be stored by a web browser and willremain valid until its set expiry date, unless deleted by the userbefore the expiry date; a session cookie, on the other hand, willexpire at the end of the user session, when the web browser isclosed.

Cookiesdo not typically contain any information that personally identifies auser, but personal information that we store about you may be linkedto the information stored in and obtained from cookies.

Cookiescan be used by web servers to identify and track users as theynavigate different pages on a website and identify users returning toa website.

7.2.Our cookies

Thenames of the cookies that we use on our website, and the purposes forwhich they are used, are set out below:

Sessioncookies: We use session cookies to enable the website to keep trackof your movement from page to page and to store your selections sothat you do not get asked repeatedly for the same information. Thesecookies allow you to proceed through many pages of the site quicklyand easily without having to authenticate or reprocess each new areayou visit

Log-in cookies: We use persistent cookies (up to14 days) to remember you so as to simplify the log-in process if youreturn to the site

Googleanalytics cookies: Google sets persistent cookies (up to two years)to recognize and count the number of site visitors, as well asproviding other information about each visit to the site such asduration, route through the site and what sites the visitor camefrom. This information helps us to improve the way the site works,for example by making sure users find what they need easily. Thesecookies are provided by Google. Google requires us to tell you thefollowing: “This website uses Google Analytics, a web analyticsservice provided by Google, Inc. (“Google”).  GoogleAnalytics uses “cookies”, which are text files placed on yourcomputer, to help the website analyze how users use the site. Theinformation generated by the cookie about your use of the website(including your IP address) will be transmitted to and stored byGoogle on servers in the United States. Google will use thisinformation for the purpose of evaluating your use of the website,compiling reports on website activity for website operators andproviding other services relating to website activity and internetusage.  Google may also transfer this information to thirdparties where required to do so by law, or where such third partiesprocess the information on Google's behalf. Google will not associateyour IP address with any other data held by Google.  You mayrefuse the use of cookies by selecting the appropriate settings onyour browser. However please note that if you do this you may not beable to use the full functionality of this website.  By usingthis website, you consent to the processing of data about you byGoogle in the manner and for the purposes set out above.

7.3.Blocking cookies

Mostbrowsers allow you to refuse to accept cookies; for example:

  • in Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking "Tools", "Internet Options", "Privacy" and then "Advanced";

  • in Firefox (version 39) you can block all cookies by clicking "Tools", "Options", "Privacy", selecting "Use custom settings for history" from the drop-down menu, and unticking "Accept cookies from sites"; and

  • in Chrome (version 44), you can block all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Content settings", and then selecting "Block sites from setting any data" under the "Cookies" heading.

Blockingall cookies will have a negative impact upon the usability of manywebsites.

Ifyou block cookies, you will not be able to use all the features onour website.


8. Other provisions

8.1.Processing for different purpose

Ifwe intend to further process the personal data for a purpose otherthan that for which the personal data were collected, we provide theyou prior to that further processing with information on that otherpurpose and with any relevant further information.

8.2.Data protection

Wesecure your personal information from unauthorized access, use ordisclosure. We secure the personally identifiable information youprovide on computer servers in a controlled, secure environment,protected from unauthorized access, use or disclosure. When personalinformation (such as a credit card number) is transmitted to otherWeb sites, it is protected through the use of encryption, such as theSecure Socket Layer (SSL) or HTTPS protocol.

8.3.Record of processing

Tocomply with section 30 of GDPR, we maintain a record of processingactivities under our responsibility.

8.4.Data breaches

Databreach is a breach of security leading to the accidental or unlawfuldestruction, loss, alteration, unauthorized disclosure of, or accessto, personal data transmitted, stored or otherwise processed. In caseof data breach, we act according to section 33 and 34 of GDPR.

8.5.Changes to our Privacy Policy

Wewill occasionally update this Privacy Policy to reflect feedback. Weencourage you to periodically review this Policy to be informed ofhow we are protecting your information.


Effective: March of 2019

SLS HUNGARY Bt.

Controller