1. Purpose of the Privacy Notice

Editio Musica Budapest Zeneműkiadó Kft (1132 Budapest, Visegrádi utca 13, hereinafter referred to as the service provider and data controller), both as a data controller and as the operator of the www.emb.hu and www.kotta.info websites, acknowledges the contents of this legal notice as binding upon itself. It undertakes to ensure that all data processing related to its activities complies with the requirements set out in these rules, in applicable national legislation and in the legal acts of the European Union.

The data protection principles relating to the data processing activities of Editio Musica Budapest Zeneműkiadó Kft are continuously available at www.emb.hu/campaign/adatvedelem.

Editio Musica Budapest Zeneműkiadó Kft reserves the right to amend this notice at any time. Naturally, it will inform its audience of any changes in due time.

Should You have any questions concerning this notice, please write to us and our colleague will answer Your question.

Editio Musica Budapest Zeneműkiadó Kft is committed to protecting the personal data of its customers and partners and considers respect for its customers’ right to informational self-determination to be of paramount importance. Editio Musica Budapest Zeneműkiadó Kft treats personal data confidentially and takes all security, technical and organisational measures necessary to guarantee the security of the data.

Below, Editio Musica Budapest Zeneműkiadó Kft describes its data processing practices.

2. Details of the Data Controller

Should You wish to contact our Company, You may contact the data controller at adatvedelem­@­emb.hu and at 1132 Budapest, Visegrádi utca 13.

Editio Musica Budapest Zeneműkiadó Kft deletes all letters received at adatvedelem­@­emb.hu, together with the personal data they contain, no later than 5 years after the disclosure of the data.

2.1. Data Protection Officer

3. Scope of Personal Data Processed

3.1. Personal Data to Be Provided During Registration

3.1.1. Website registration:

- email

- password

- country

- title

- surname

- first name

- company name

- postal code

- town/city

- street, house number, floor

- telephone number

- fax number

3.1.2. Newsletter subscription:

-  email

-  name

3.2. Technical Data

For the processing of personal data, Editio Musica Budapest Zeneműkiadó Kft selects and operates the IT tools used in the provision of its services in such a way that the processed data:

- are accessible to authorised persons (availability);

- have ensured authenticity and authentication (authenticity of processing);

- have verifiable integrity (data integrity);

-  are protected against unauthorised access (data confidentiality).

Editio Musica Budapest Zeneműkiadó Kft protects data by appropriate measures against unauthorised access, alteration, transfer, disclosure, deletion or destruction, as well as accidental destruction.

Editio Musica Budapest Zeneműkiadó Kft ensures the protection of the security of data processing through technical, organisational and administrative measures that provide a level of protection appropriate to the risks arising in connection with data processing.

During data processing, Editio Musica Budapest Zeneműkiadó Kft preserves

• confidentiality: it protects information so that it can only be accessed by persons authorised to do so;
• integrity: it protects the accuracy and completeness of the information and the processing method;
• availability: it ensures that, when an authorised user needs it, they can actually access the requested information and that the related tools are available.

3.3. Cookies

3.3.1. Purpose of Cookies

-  they collect information about visitors and their devices;

- they remember visitors’ individual settings, which may be used, for example, when using online transactions, so that they do not need to be entered again;

- they facilitate the use of the website;

-  they provide a high-quality user experience.

In order to provide customised service, a small data package, known as a cookie, is placed on the user’s computer and read during later visits. If the browser returns a previously saved cookie, the service provider managing the cookie may link the user’s current visit with previous visits, but only in respect of its own content.

3.3.2. Strictly Necessary Session Cookies

The purpose of these cookies is to enable visitors to browse the website of Editio Musica Budapest Zeneműkiadó Kft fully and smoothly, use its functions and the services available there. The validity period of this type of cookie lasts until the end of the session (browsing); when the browser is closed, this type of cookie is automatically deleted from the computer or other device used for browsing.

3.3.3. Third-Party Cookies (Analytics)

Editio Musica Budapest Zeneműkiadó Kft uses the following third-party cookies on its website:

- Google Analytics. By using the Google Analytics statistical service, Editio Musica Budapest Zeneműkiadó Kft collects information about how visitors use the website. The data are used to improve the website and the user experience. These cookies also remain in the visitor’s browser on their computer or other device used for browsing until they expire or until the visitor deletes them. Google Analytics does not store or transfer personal data to Editio Musica Budapest Zeneműkiadó Kft.

- Facebook. By using the Facebook Like Box function, it provides an opportunity to like the “Kotta.info” Facebook page and to list friends who also like the page. Content published by Editio Musica Budapest Zeneműkiadó Kft on Facebook can only be viewed by users who like it. Editio Musica Budapest Zeneműkiadó Kft has no access to the data of cookies stored by the Facebook Like Box; Facebook, Inc. uses these data in accordance with its own data processing policy.

- AddThis. The AddThis page element function enables products to be shared on various social media channels on individual product pages. Based on the data of cookies stored by the AddThis page element, Editio Musica Budapest Zeneműkiadó Kft receives regular anonymous reports on social media activity. The AddThis page element is operated by Oracle Corporation; Editio Musica Budapest Zeneműkiadó Kft has no access to the data of cookies stored by it, and Oracle Corporation uses these data in accordance with its own data processing policy.

3.4. Data Related to Online Orders

For the processing of online orders, Editio Musica Budapest Zeneműkiadó Kft stores the following data:

- Data provided during registration (see section 3.1.1, Website registration)

- Contents of the Cart

- Text comments sent to Editio Musica Budapest Zeneműkiadó Kft

- In the event of online payment, data sent by the online payment service provider, such as

• transaction ID
• and notification email address.

- From among the personal data of online orders, Editio Musica Budapest Zeneműkiadó Kft transfers names, billing and delivery data and contact details from the website to its order management system, which it operates and where it uses them for logistics and accounting purposes.

- In the event of online bank card payment, with the user’s consent, Editio Musica Budapest Zeneműkiadó Kft may transfer personal data to one of its payment service partners, which, depending on the type of payment, may be

- PayPal Holdings, Inc.

- OTP Mobil Kft.

- Depending on the type of order, with the user’s consent, Editio Musica Budapest Zeneműkiadó Kft may transfer personal data to one of its partners handling delivery or collection, such as

- Magyar Posta Zrt,

- the collection point selected by the customer in the “Delivery and payment” settings.

3.5. Data Related to Online Administration

3.6. Data Related to the Newsletter

Editio Musica Budapest Zeneműkiadó Kft sends a newsletter about the Company’s products to customers who request it and give their consent. Customers may unsubscribe from the newsletter at any time during any process relating to the newsletter.

4. Intended Use and Retention Period of Processed Data

5. Purpose, Method and Legal Basis of Data Processing

5.1. General Data Processing Principles

The data processing activities of Editio Musica Budapest Zeneműkiadó Kft are based on voluntary consent or statutory authorisation. In cases of data processing based on voluntary consent, data subjects may withdraw their consent at any stage of data processing.

In certain cases, legislation makes the processing, storage and transfer of certain provided data mandatory, of which we will notify our customers separately.

We draw the attention of persons providing data to Editio Musica Budapest Zeneműkiadó Kft to the fact that if they provide personal data other than their own, it is the duty of the person providing the data to obtain the consent of the data subject.

Its data processing principles comply with the applicable legislation on data protection, in particular the following:

- Act CXII of 2011 on Informational Self-Determination and Freedom of Information (Infotv.);

- Regulation (EU) 2016/679 of the European Parliament and of the Council (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 V of 2013 on the Civil Code (Ptk.);

- Act C of 2000 on Accounting;

- Act LIII of 2017 on the Prevention and Combating of Money Laundering and Terrorist Financing;

- Act CCXXXVII of 2013 on Credit Institutions and Financial Enterprises.

6. Physical Locations of Data Storage

 Your personal data (that is, data that may be associated with Your person) may come into our possession in the following ways: on the one hand, technical data relating to the computer, browser program, Internet address and pages visited by You are automatically generated in our computer system in connection with maintaining the Internet connection; on the other hand, You may provide Your name, contact details or other data if You wish to contact us personally while using the website.

Data technically recorded during operation of the system: data of the data subject’s computer used to log in, which are generated during use and recorded by the system of Editio Musica Budapest Zeneműkiadó Kft as automatic results of technical processes. Data recorded automatically are logged automatically by the system upon entry and exit, without any separate declaration or action by the data subject. These data may not be linked with other personal user data, except in cases made mandatory by law. Only Editio Musica Budapest Zeneműkiadó Kft has access to the data.

7. Data Transfer, Data Processing and Persons Having Access to the Data

In the course of its operation, due to contractual or statutory obligations, the data controller is required to transfer certain data to other organisations or companies. The names of these companies, their roles in the process and the list of their employees having access to the data may be obtained by writing to the data protection officer.

8. Rights of Data Subjects and Available Remedies

The data subject may request information on the processing of their personal data, and may request rectification or, except in the case of mandatory data processing, erasure or withdrawal of their personal data, and may exercise their rights to data portability and objection in the manner indicated when the data are collected or using the above contact details of the data controller.

8.1. Right to Information

Editio Musica Budapest Zeneműkiadó Kft shall take appropriate measures to provide data subjects with all information referred to in Articles 13 and 14 of the GDPR regarding the processing of personal data, and all information under Articles 15–22 and 34, in a concise, transparent, intelligible and easily accessible form, using clear and plain language.

8.2. Right of Access of the Data Subject

The data subject shall have the right to obtain confirmation from the data controller as to whether or not personal data concerning them are being processed and, where that is the case, access to the personal data and the following information: the purposes of processing; the categories of personal data concerned; the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations; the envisaged period for which the personal data will be stored; the right to rectification, erasure or restriction of processing and the right to object; the right to lodge a complaint with a supervisory authority; information concerning the sources of the data; the existence of automated decision-making, including profiling, and meaningful information about the logic involved and the significance and envisaged consequences of such processing for the data subject. The data controller shall provide the information no later than one month after submission of the request.

8.3. Right to Rectification

The data subject may request the rectification of inaccurate personal data concerning them processed by Editio Musica Budapest Zeneműkiadó Kft and the completion of incomplete data.

8.4. Right to Erasure

The data subject shall have the right to obtain from Editio Musica Budapest Zeneműkiadó Kft, upon request, the erasure of personal data concerning them without undue delay where one of the following grounds applies:

- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

- the data subject withdraws consent on which the processing is based, and there is no other legal ground for the processing;

- the data subject objects to the processing and there are no overriding legitimate grounds for the processing;

- the personal data have been unlawfully processed;

- the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the data controller is subject;

- the personal data have been collected in relation to the offer of information society services.

Erasure of data may not be requested where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation which requires processing under Union or Member State law to which the data controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; for reasons of public interest in the area of public health, or for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes; or for the establishment, exercise or defence of legal claims.

8.5. Right to Restriction of Processing

At the request of the data subject, Editio Musica Budapest Zeneműkiadó Kft shall restrict processing where one of the following conditions applies:

- the data subject contests the accuracy of the personal data, for a period enabling the accuracy of the personal data to be verified;

- the processing is unlawful and the data subject opposes the erasure of the data and requests the restriction of their use instead;

- the data controller no longer needs the personal data for the purposes of processing, but the data subject requires them for the establishment, exercise or defence of legal claims; or         

- the data subject has objected to processing; in this case, the restriction shall apply for the period until it is established whether the legitimate grounds of the data controller override those of the data subject.

Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence 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 Union or of a Member State.

8.6. Right to Data Portability

The data subject shall have the right to receive the personal data concerning them, which they have provided to the data controller, in a structured, commonly used and machine-readable format, and to transmit those data to another data controller.

8.7. Right to Object

The data subject shall have the right to object at any time, on grounds relating to their particular situation, to processing of personal data concerning them which is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller, or which is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, including profiling based on those provisions. In the event of objection, the data controller 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 for the establishment, exercise or defence of legal claims.

8.8. Automated Decision-Making in Individual Cases, Including Profiling

The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.

8.9. Right to Withdraw Consent

The data subject shall have the right to withdraw their consent at any time.

8.10. Right to Legal Action

In the event of an infringement of their rights, the data subject may bring legal proceedings against the data controller. The court shall act in the matter as a matter of priority.

8.11. Data Protection Authority Procedure

Complaints may be lodged with the National Authority for Data Protection and Freedom of Information:

Name: National Authority for Data Protection and Freedom of Information

Registered office: 1125 Budapest, Szilágyi Erzsébet fasor 22/C.

Postal address: 1530 Budapest, Pf.: 5.

Telephone: 0613911400

Fax: 0613911410  

E-mail: ugyfelszolgalat­@­naih.hu

Website: http://www.naih.hu

9. Other Provisions

 Information on data processing activities not listed in this notice shall be provided when the data are collected.

We inform our customers that the court, public prosecutor, investigating authority, authority dealing with minor offences, administrative authority, the National Authority for Data Protection and Freedom of Information, the Hungarian National Bank, or other bodies authorised by law may contact the data controller in order to request information, disclosure or transfer of data, or the provision of documents.

Editio Musica Budapest Zeneműkiadó Kft shall disclose personal data to authorities only to the extent and in such scope as is indispensably necessary to fulfil the purpose of the request, provided that the authority has specified the precise purpose and scope of the data.