Gold standard for utility performance

Privacy policy

1. Introduction

Budapest Waterworks Plc. (registered office: 1138 Budapest, Váci út 182., company registration number: 01-10-042451; e-mail: vizvonal@vizmuvek.hu , hereinafter the Company or the Controller) pays particular attention to ensuring that its activities meet the statutory requirements from time to time in effect, including in particular Regulation (EU) 2016/679 of the European Parliament and of the Council 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) (the Regulation), and the requirements and practices of the public water utility service sector.

With this Privacy Policy (the “Policy”), and with the provisions of its related internal regulations the Controller wishes to ensure the transparency of its data processing activities, and at the same time inform its consumers, applicants, interested parties or other natural persons (the Data Subjects) of the opportunities arising from the right of informational self-determination they are entitled to.

The purpose of the Policy on the one hand is to determine the lawful criteria and framework of all data processing activities of the Controller concerning personal data, ensuring thereby the exercise of the Data Subject’s right of informational self-determination, and on the other hand to provide detailed information to the Data Subjects on the rights and remedies they are entitled to, and the measures taken in the interest of the security of their personal data.

Structure of the Policy:

1. Introduction
2. Definitions
3. Policy scope
4. Data processing principles
5. The purpose of data processing
6. The processing of personal data by major Data Subject types
7. The legal basis of processing, categories of the processed data, retention period
8. Data processings related to the website operated by the Company (registration, data processing without registration, use of cookies, data processing related to surveys and questionnaires, data processing of the Recruitment portal)
9. Other processings (recording of telephone conversations with customer service, data processing for marketing purposes, data processing for the purpose of market and public opinion research, extraordinary events and loss events, security services, protected users)
10. Data transfer, activities of data processors
11. Rights and remedies
12. Data security, the storage and retention of personal data
13. Major laws concerning the activities of the Company
14. Miscellaneous provisions

Should a Data Subject have any questions regarding an issue that is unclear in this Policy, he or she should refer directly to our data protection officer in accordance with Section 11 of this Policy.

2. Definitions:

3. Policy scope

The scope of this Policy comprises

  • all data processing by the Company as a public utility service provider including the data of the natural persons who have a customer relationship with the Company, or wish to enter into a customer relationship with the Company, or are related to persons having a customer relationship with the Company so that the processing of their personal data is necessary for the provision of the Company’s services;
  • the services and processing of the Company provided in relation to its website (the “Website”), not inclusive of the website related to Vízplusz cards ( www.vizpluszkartya.hu );
  • data processing by the Company serving the purposes of marketing, or market and public opinion research, or related to extraordinary events and loss events;
  • anti-theft data processing by the Company concerning Data Subjects (Section 9.5); processing concerning the data of persons having other contractual relationship with the Company.

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Unless provided otherwise, the scope of the Policy does not comprise the services and data processings related to the services of third parties that might advertise in the Website or are displayed there in other ways, to their other campaigns, or to the content published by them. Unless provided otherwise, the scope of the Policy does not comprise the services and data processing of websites and service providers which the links available in the Website point at.

4. Data processing principles

The Controller endeavors to ensure that the following principles for the processing of personal data prevail in full in the course of its processing activities:

Principle of lawfulness, fairness and transparency

In the course of the processing, the Controller—in accordance with the requirements of good faith and fairness—is required to act in cooperation with the user, and shall process personal data in a way that is transparent for the user..

Principle of purpose limitation

The Controller shall collect personal data only for specified, explicit and legitimate purposes, and shall process the user’s data in a way that is not incompatible with the purposes specified in the relevant Data Protection Guidelines. The Controller shall erase the personal data in all cases where the purpose of the processing has ceased, and no statutory obligation or legitimate interest exists for the further storage or processing of the data.

Principle of data minimization

The personal data provided by the Data Subject shall be relevant for the purpose of the processing, and the Controller shall make sure that the range of the personal data processed by it shall be limited to what is necessary. The Controller shall not process data that are unnecessary to achieve the aim of the processing. Besides, the Controller endeavors to minimize processing, in so far as this is allowed by the IT background and its interest related to the purpose of the processing.

Principle of accuracy

The Controller shall take every reasonable step to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay, whereby the Controller shall ensure that the data are kept up to date.

Storage limitation

In order to ensure that the period of storage of personal data shall not be longer than what is necessary, the Controller establishes erasure deadlines.

Integrity and confidentiality

The Controller protects personal data in particular against unauthorized access, change, transmission, making public, deletion, intentional or accidental destruction or damage, and furthermore against becoming inaccessible due to changes in the technology used.

Accountability—data protection by design and by default

Taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for rights and freedoms of natural persons posed by the processing, the Controller shall, both at the time of the determination of the means for processing and at the time of the processing itself, implement appropriate technical and organizational measures which are designed to implement data-protection principles and to integrate the necessary safeguards into the processing in order to meet the requirements of the Regulation and protect the rights of data subjects.

5. Purpose of data processing

The primary purpose for processing by the Controller in relation to the performance of its public duty is to fulfill the contract with the Consumer, including the creation and maintenance of such contracts, and to provide in sufficient quality any other services required by the Consumer. The Controller shall use personal data for specified purposes only. The data processing shall be in all its phases compliant with the purpose of processing. The data are collected and processed in a fair and lawful manner. The Controller endeavors to ensure that only such personal data are processed as are indispensible for the implementation of the purpose of processing, and are suitable to achieve such purpose. Personal data may be processed only to the extent and for a period necessary for the implementation of the purpose.

Data processing by the Company may serve the following purposes:

  • Conclusion of a contract with a Consumer.
  • Provision of services based on the contract with the Consumer, and for this purpose identification of the point of consumption, examination of the point of consumption, and rendering it suitable to provide the service.
  • Determination of eligibility for the service.
  • Processing of sensitive personal data justifying protected user status.
  • Metering services rendered to the consumer, ensuring the qualitative and quantitative requirements of the service.
  • Metering the object of the service, reading off consumption.
  • Determination of payment obligation, invoicing, management of receivables.
  • Identification of Consumers, Applicants, Interested Parties, and other Data Subjects.
  • Communication with Consumers, Applicants, Interested Parties, and other Data Subjects, management of their complaints, reports and claims, and keeping record of and investigating these.
  • Enforcement of claims arising from legal relationships.
  • Direct marketing, market and public opinion research.
  • Provision of services through the Website.
  • Development of Website.

6. The processing of personal data by major Data Subject types

The Data Subjects of the personal data processed in relation to the Controller’s activity may be typically the following natural persons:

  • Consumer (a natural person who enters into an agreement with the Controller for public utility services)
  • Registered user a natural person who registered in the Website)
  • Applicant (a natural person who contacts the Controller for the purpose of applying for the service; however, the service relationship is created at a later date, or is not created at all)
  • Authorized representative (a natural person acting on behalf of another natural person or on behalf of a legal person in accordance with Art. 6:11 of the Civil Code)
  • Other Data Subject (a natural person who visits the Website, and/or subscribes to the Controller’s newsletter, and/or is involved in a loss event, and/or wishes to enter the Controller’s premises)

7. The legal basis of processing, categories of processed data, retention period

The processings executed by the Controller usually have a mixed legal basis, i.e. they include authorizations for processing based at the same time on contract, on the law, on legitimate interest (according to a balance of interests or impact assessment), and consent.

The personal data concerning Data Subjects may get into the possession of the Controller in 3 ways. Primarily as a result of being made available by the Data Subject with a view to the creation and performance of the contract, secondly as a result of recording in the course of communication with the Data Subject (on the phone/through customer service), and thirdly as a result of transmission by the Controller to a commissioned processor in the interest of communication with the Data Subject.

The Controller shall retain the data held by it adjusted to the different data retention purposes and legal bases, for the period specified in the laws, and shall subsequently lock or erase the data, taking into account its own and/or the Data Subject’s interests. The maximum period of processing varies depending on the legal bases underlying the processing of the Data Subject’s data.

The table below summarizes the different data processed by the Controller in relation to the performance of its public duty, the related legal bases for the processing, and the relevant retention periods:

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  Processed data Legal basis MagyarázatExplanation Retention period

7.1.
Natural person Consumer’s identification data - Statutory obligation as legal basis (Art. 6 (1) c) of the Regulation) (Art. 61 of Water Utility Service Act) The Controller processes the following data of the Consumer: name, address, mother’s name, place and date of birth. In case the Consumer’s data change, and he/she fails to report this, the Controller shall in accordance with the governing laws request the Consumer’s data from the central personal data and address registry. 8 years from the year of issuance of the last accounting certificate related to the contract (Art. 169 of Act C of 2000 on Accounting)
7.2. Natural person Applicant’s identification data - Contract as legal basis (Art. 6 (1) b) of the Regulation) With a view to the connection of the Applicant into the water works network, by completing a “Statement of Principles and Application” the Applicant makes his or her name and address and the details concerning the planned real estate construction (e.g. site plan, land register extract, connection plan) available to the Controller 3 years from the receipt of the form.
7.3. Telephone numbers necessary for communication with the Data Subject - Consent as legal basis (Art. 6 (1) a) of the Regulation)
- Legitimate interest as legal basis (Art. 6 (1) f) of the Regulation)
Based on the Data Subject’s consent, the Controller processes his/her phone numbers necessary for communication. It is not mandatory for the Data Subject to provide any phone number. In the case of Consumer communities the Controller processes the data of the representative of the community (including in particular the board presidents of apartment houses). As needed, the Controller has the right to take over the phone number necessary for communication with the Data Subject from lawfully published registries. In the case of data necessary for communication—for the purpose of the enforcement of the Controller’s or the Data Subject’s legitimate interest, based on a balance of interests test executed by the Controller—the Controller may as well process such data differently from the original purpose of processing, for the purpose of the alignment of the date and time of on-site works, or the settlement of the Data Subject’s outstanding debt, or to prevent the accumulation of debts. Until the purpose of processing is completed / until the consent is withdrawn / as long as the contractual relationship exists
7.4. Data required to certify a change in consumers - Statutory obligation as legal basis (Art. 6 (1) c) of the Regulation) (Art. 61 of Water Utility Service Act) In the case of change in the identity of the Consumer, the Controller may process any and all data that are necessary for the change or to certify the change. The Controller processes the copy of the document certifying the change. The Data Subject has the right to erase from the copy any data that are not necessary to certify the change in the Consumer’s identity. 8 years from the year of issuance of the last accounting certificate related to the contract (Art. 169 of Act C of 2000 on Accounting)
7.5. Copies and data of documents - Contract as legal basis (Art. 6 (1) b) of the Regulation))
- Statutory obligation as legal basis (Art. 6 (1) c) of the Regulation) (Art. 61 of Water Utility Service Act)
The Controller shall make copies of certain documents certifying data with a view to ascertaining the correctness of the data. ID card type personal documents which the Controller does not copy are exceptions from this. 8 years from the year of issuance of the last accounting certificate related to the contract (Art. 169 of Act C of 2000 on Accounting)
7.6. Data on point of consumption and metering devices

- Statutory obligation as legal basis (Art. 6 (1) c) of the Regulation) (Art. 61 of Water Utility Service Act)
- Legitimate interest as legal basis

The Controller processes technical and technological data concerning the point of consumption and metering devices, including in particular the data included in the land register extract, site plan, and plans. Based on its legitimate interest, in the course of the reading off of metering devices the Controller takes photos of such devices, also recording the GPS coordinates of the metering device. 8 years from the year of issuance of the last accounting certificate related to the contract (Art. 169 of Act C of 2000 on Accounting)
7.7. Data of natural persons other than consumers - Contract as legal basis (Art. 6 (1) b) of the Regulation) Primarily this comprises the processing of the data of the owner of the point of consumption, or the data of an authorized representative. If the conclusion of the contract and the provision of the service is not possible without having the ultimate owner’s data, the owner’s personal data will be processed by the Controller. Until the purpose of processing is completed / until the data subject’s request for erasure / for 8 years from the year of issuance of the last accounting certificate related to the contract (Art. 169 of Act C of 2000 on Accounting)
7.8. Data concerning the Data Subject’s consumption, and the provision and utilization of the service - Statutory obligation as legal basis (Art. 6 (1) c) of the Regulation) (Art. 61 of Water Utility Service Act) The processing of these data is closely related to the performance of the contract. The Controller processes the data generated in the course of the performance of the contract, including in particular data concerning consumption, complaints, the deficiencies of the service, and unlawful activities. 8 years from the year of issuance of the last accounting certificate related to the contract (Art. 169 of Act C of 2000 on Accounting)
7.9. Data concerning fees and costs payable and paid by the Data Subject, data of receivables - Statutory obligation as legal basis (Art. 6 (1) c) of the Regulation) (Art. 61 of Water Utility Service Act) All data that are related to the Data Subject’s payment obligation, and from which the performance or non-performance of the Data Subject’s payment obligation can be ascertained. 8 years from the year of issuance of the last accounting certificate related to the contract (Art. 169 of Act C of 2000 on Accounting)
7.10. Az ügyfélszolgálattal történő kapcsolatfelvétel során keletkezett adatok Data generated in the course of communication with the customer service - Contract as legal basis (Art. 6 (1) b) of the Regulation)
- Statutory obligation as legal basis (Art. 6 (1) c) of the Regulation) (Art. 61 of Water Utility Service Act)
All data generated at the customer service during any communication between the Data Subjects and the customer service belong here. Data processing in this case is closely related to proceedings launched by the Data Subject, and furthermore to the performance of the contract and of statutory obligations. 8 years from the year of issuance of the last accounting certificate related to the contract (Art. 169 of Act C of 2000 on Accounting)
7.11. Telephone conversations with the customer service - Consent as legal basis (Art. 6 (1) a) of the Regulation)
- Statutory obligation as legal basis (Art. 6 (1) c) of the Regulation) (Art. 17/B of Consumer Protection Act)
The Controller records and processes in accordance with the provisions of the governing laws—primarily the Act on Consumer Protection—the audio recording of the conversation between the Data Subject and the customer service. The Data Subject is informed of the recording in each case before the start of the conversation. For 5 years following the making of the audio recording (Art. 17/B (3) of Consumer Protection Act)
7.12 Data pertaining to other services - Contract as legal basis (Art. 6 (1) b) of the Regulation) If the Data Subject uses other services from the Controller apart from public utility services, a new contractual relationship is created. In such case the data are processed on the basis of the contract. 8 years from the year of issuance of the last accounting certificate related to the contract (Art. 169 of Act C of 2000 on Accounting)
7.13 Documents certifying protected customer status - Statutory obligation as legal basis (Art. 6 (1) c) of the Regulation) (Art. 61/A of Water Utility Service Act) With a view to ensuring the benefits due to protected users, the Controller keeps a registry from which it can be ascertained beyond doubt to which range of benefits the data subject is entitled to. Entry into the registry must be initiated by the data subject, and the documents certifying eligibility to protected user status as per Government Decree 58/2013 (II.27.) should be attached to the request. The data deleted from the registry should be stored for 5 years counted from the deletion (Art. 61/A (8) of Act CCIX of 2011 on Water Utility Services)

8. Data processings of the website operated by Budapest Waterworks Plc.
( www.vizmuvek.hu ; www.ugyfelszolgalat.vizmuvek.hu )

Registration is not a precondition for visits to the Controller’s website, and upon visits to the Website the web server does not record user data. In its Website, the Controller ensures the confidential treatment of data between the Data Subject’s computer and the website, therefore it employs a secure internet communication protocol (HTTPS). The Controller, however, reserves the right to provide such services through the Website whose use is subject to registration (e.g. promotions, prize competitions, newsletters, entry to online customer service).

8.1. Registration

In the course of registration the Data Subject provides the data specified in the registration form (Data Subject’s name, e-mail address, phone number, device location identifier, current account number, business partner code, factory number). The Controller reserves the right to make the provision of certain data in the registration form a precondition for registration (e.g. e-mail address in order to confirm registration), and furthermore to change the content of the registration form, delete certain data fields or create new ones, especially if this is made necessary or reasonable by the user’s needs or statutory changes. The Controller informs the Data Subjects of changes in each case. The data provided in the course of registration are processed by the Controller, and they are not transmitted to any processor or controller. The data shall be accessible to such persons acting on behalf of the Controller—including in particular its agents and employees—for whom it is necessary to access the data to perform their activities, and who are aware of their obligations related to the processing of the data.

The primary purpose of the data provided in the course of registration is to provide the services that are subject to registration, and identify the Data Subject, and their secondary purpose is to ensure the services of the Website, develop the services, send newsletters and advertisements to the users, and market and public opinion research.

Categories of processed data: Data Subject’s name, e-mail address, phone number, device location identifier, factory number.

Legal basis for the processing: consent of the Data Subject in each case (Art. 6 (1) a) of the Regulation).

Duration of the processing: the Controller processes the data until the consent is withdrawn, or the registration cancelled.

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Processed data Legal basis  Explanation  Retention period
Registered user’s data  - Consent as legal basis (Art. 6 (1) a) of the Regulation) In the course of registration, the Data Subject provides the data specified in the registration form to the Controller.  Withdrawal of the consent / cancellation of the registration of the Data Subject

8.2. Data processings without registration

8.2.1. Communication through online form

The Data Subject has an opportunity to communicate with the Controller through the Website, order diverse services, and register for events, for which the Data Subject is required to complete an online communication form. The Controller’s employees will get in touch with the Data Subject in any of the communication channels provided by the Data Subject, as soon as reasonably practicable, depending on their capacities.

Purpose of processing: communication with the Data Subject, and identification of the Data Subject.

Categories of processed data: Data Subject’s name, e-mail address, telephone number.

Legal basis for the processing:consent of the Data Subject in each case (Art. 6 (1) a) of the Regulation).

Duration of the processing: the Controller processes the data until the consent is withdrawn, or in case some service is ordered for 8 years following the performance of the service, and for 6 months where no service is ordered.

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Processed data Legal basis Explanation Retention period
Data Subject’s name, e-mail address, telephone number - Consent as legal basis (Art. 6 (1) a) of the Regulation) The Data Subject provides the data specified in the online communication form to the Controller. Until the Data Subject’s consent is cancelled / for 8 years/6 months from the year of issuance of the last accounting certificate related to the contract

8.2.2. Recording of meter reading data through online platform

Using the data provided in the invoice, the Data Subject has an opportunity to record meter reading data through the Website without registration or login.

Purpose of processing: Identification of Data Subject, facilitation of the recording of meter reading data, invoicing.

Categories of processed data:: device location identifier, factory number, current meter reading data, Data Subject’s e-mail address.

Legal basis for the processing: consent of the Data Subject (Art. 6 (1) a) of the Regulation), then after administration starts in merit the legal basis for the processing shall be the Controller’s statutory obligation (Art. 6 (1) c) of the Regulation) (Art. 61 of Water Utility Service Act).

Duration of the processing: the Controller shall retain the data provided by the Data Subject for 8 years from the year of issuance of the last accounting certificate related to the contract.

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Processed data Legal basis Explanation Retention period
Data Subject’s device location identifier, factory number, current meter reading data - Statutory obligation as legal basis (Art. 6 (1) c) of the Regulation) (Art. 61 of Water Utility Service Act) The Data Subject provides to the Controller the data necessary for invoicing as specified in the online form. 8 years from the year of issuance of the last accounting certificate related to the contract (Art. 169 of Act C of 2000 on Accounting)
Data Subject’s e-mail address - Consent as legal basis (Art. 6 (1) a) of the Regulation) It serves to send a certificate to the Data Subject, and is not stored by the Controller. Erased immediately after the sending of the certificate.

8.3. Use of cookies

The Processor installs cookies on the Data Subject’s computer, and reads the same back in the interest of a customized service.
The Controller uses the following cookies:
- Session cookies: session cookies are automatically erased after the Data Subject’s visit. The purpose of these cookies is to ensure that the Website can operate more efficiently and securely, therefore they are indispensable for the appropriate operation of certain functions of the Website or certain applications.
- Persistent cookies: the Controller uses persistent cookies as well for a better user experience (e.g. optimized navigation). These cookies are stored for longer periods in the browser’s cookie file. The duration of storage depends on the settings used by the Data Subject in his/her internet browser.
- Security cookies.
- PHPSESSID: php session cookies, whereby the php identifies the user, are active until the browser window is closed.
- Cookies accepted: a cookie that remembers the acceptance of the cookie policy available in the footer, its term to expiry is 10 years,
- overlay_seen_once: a cookie storing the display of the document in overlay (so that it shall not be shown to the user any more), its term to expiry is 10 years.
- banner_rotation: in case banner block is used, a cookie storing the banner ID shown last, its term to expiry is 1 day.
- voting: a cookie to remember participation in the given voting, with a period to expiry of, 300 days .
- Google Adwords remarketing: a tracking code ensuring that the Controller can later solicit visitors to the website with remarketing advertisements in the website belonging to the Google Display network. The remarketing code uses cookies to label visitors. Users of the Website may block these cookies by visiting the Google advertisement settings dashboard, and following the instructions found there. After this, personalized offers will not be displayed for them from the Controller.
- Google Analytics: he analytics service of Google, in the scope of which the user interactions in the website are analyzed by means of the cookies stored in the user’s computer, whose term to expiry is 2 years. The analytical information collected by Google Analytics cookies are transported to and stored in Google’s servers. Such information is processed by Google on behalf of the operator of the Website in order to evaluate the website visitors’ habits, prepare reports on the frequency of usage of the Website, and perform further services related to use for the Controller. The IP address transmitted through the browser in the scope of the Google Analytics application is not linked by Google with other data.
Further information on the cookies used by Google is available in the following link: http://www.google.com/policies/technologies/ads/.
Google’s Privacy Policy is available in the following link: http://www.google.com/intl/hu/policies/privacy/ .

Categories of processed data: identifier, date and time, and the page previously visited.

The purpose of processing is to identify Data Subjects, distinguish them from one another, monitor them, prevent data losses, and ensure the efficiency of the Website.

Legal basis for the processingis the consent of the Data Subject in each case (Art. 6 (1) a) of the Regulation).

Cookies that have an exact period of validity are stored in the Data Subject’s computer until their erasure, but not later than the expiry of their period of validity.

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Processed data Legal basis Explanation Retention period

Identifier, date and time, previously visited page

- Consent as legal basis (Art. 6 (1) a) of the Regulation) The Processor installs different types of cookies on the Data Subject’s computer, and reads the same back in the interest of a customized service. Withdrawal of the Data Subject’s consent, i.e. erasure of the cookies by the Data Subject / expiry of the period of validity of the cookies

The „Help” function", available in the menu bar of most browsers provides information regarding how the data subject can

  • block cookies in his/her own browser,
  • accept new cookies,
  • give instructions to his/her browser to set new cookies, or disable other cookies.

8.4. 8.4 Data processing related to the surveys and questionnaires concerning the Controller

The Controller wishes to assess the Consumers’ (Data Subjects’) expectations on the Controller and their satisfaction with the service occasionally, in its discretion, or with a view to compliance with the law, by means of questionnaires and surveys uploaded to the website www.vizmuvek.hu then on the basis of the results to ensure and develop its services in accordance with the requirements.

The categories of the personal data processed, in the course of the surveys or in the questionnaires are determined by the Controller in its sole discretion, with respect for the purpose limitation principle.

Legal basis for the processing: consent of the Data Subject in each case (Art. 6 (1) a) of the Regulation).

Duration of the processing: he Controller processes the data provided by the Data Subject until the consent is withdrawn, unless the processing of the data is a statutory requirement.

The Controller has the right to use the personal data provided in connection with the surveys, or in the questionnaires for the purpose of research, or to ask the Data Subject to participate in a research.

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Processed data Legal basis Explanation Retention period
Not defined in advance, always determined by the topic of the given questionnaire or survey - Consent as legal basis (Art. 6 (1) a) of the Regulation) The Controller wishes to assess the Consumers’ (Data Subjects’) satisfaction in its discretion, or with a view to compliance with the law, by means of questionnaires and surveys uploaded to its website, then on the basis of the results to harmonize its services with the requirements.

Withdrawal of the Data Subject’s consent / retention period prescribed in the given law

8.5. Data processing of the Recruitment portal

The purpose for the data processing of the Recruitment portal is to search up potential employees for the Controller, keep record of jobseekers, provide customized service to them, prepare and store CV-s, and notify jobseekers. The Data Subject provides the data for the purpose of the establishment of an employment relationship with the Controller.

The Controller reserves the right to use all data provided in the Recruitment portal to take decision on the employment of the Data Subject, and the different options of employment, to examine the suitability of the Data Subject, and to contact the Data Subject.

The Controller shall not use the data provided in the Recruitment portal for the purpose of research or advertisement.
Categories of processed data: Data Subject’s name, date of birth, e-mail address, telephone number, mailing address, CV, photo, motivation letter, document certifying his/her level of education.

Legal basis for the processing: consent of the Data Subject in each case (Art. 6 (1) a) of the Regulation).

Duration of the processing: as a general rule, until the withdrawal of consent by the Data Subject. The data provided in the Recruitment portal are processed by the Controller for 12 months counted from the last login, and in the case of unconfirmed registration requests the duration of processing is 30 days.
The Data Subject has the right to delete his/her CV, and the Controller also provides an opportunity to erase the registration in the Recruitment portal.

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Processed data Legal basis Explanation Retention period
Data Subject’s name, e-mail address, telephone number, mailing address, CV, motivation letter, document certifying his/her level of education - Consent as legal basis (Art. 6 (1) a) of the Regulation) With a view to searching up potential employees for the Controller, keeping record of jobseekers, providing customized service to them, preparing and storing CV-s, and notifying jobseekers, the Controller has created a Recruitment portal. Until the withdrawal of the consent of the Data Subject / for 30 days / 12 months

9. Other data processings

9.1. Recording of telephone conversations with the customer service

With a view to the administration of affairs connected to the water utility service, the Controller maintains a telephone customer service, which also performs administrative tasks. The Controller records in each case the conversation between the Data Subject and the customer service. In the case of both incoming and outgoing calls, the Controller informs the Data Subject of the recording of the conversation, creating an opportunity for the Data Subject to decide whether he or she consents to the recording of his or her conversation with the customer service or not. If the Data Subject decides not to consent to the recording of the telephone conversation, the Controller shall request the call to be interrupted, and provides an opportunity for communication in e-mail, by mail, online, or through the personal customer service.

Purpose for the recording of the telephone conversation is:

  • to perform customer service tasks, and provide help in the administration of affairs,
  • complaint management,
  • to fulfill requests,
  • quality assurance,
  • in the case of a consumer legal dispute, to use the recording in question.

Legal basis for the processing: consent of the Data Subject (Art. 6 (1) a) of the Regulation), then after administration starts in merit the legal basis for the processing shall be the Controller’s statutory obligation for the processing as per the Consumer Protection Act (Art. 6 (1) c) of the Regulation) (Art. 17/B of Consumer Protection Act).

Duration of the processing: the Controller retains the audio recording for 5 (five) years from the date of the recording, and after this period deletes the same from its system.

Issuance of the audio recording: in accordance with Art. 17/B (3) of Act CLV of 1997 on Consumer Protection, the Controller records its telephone conversation with the Data Subject, and informs the Data Subject of the retention of the audio recording and of its obligation to issue the same upon request, and furthermore of the individual identifier at the beginning of the conversation. Both parties have the right to know the audio recording including the conversation with the Data Subject, therefore the Controller shall provide an opportunity to the Data Subject to listen to the copy requested by the Data Subject in the office of the Controller’s Central Customer Service free of charge within 30 days of becoming aware of the Data Subject’s demand, provided that the Data Subject has not filed the same request yet to the Controller in the given year in respect of the same call, as well as to make a copy of the audio recording once. If the Data Subject requests, the Controller shall make a copy of the audio recording available electronically. The Data Subject may exercise such rights either collectively, or each right individually.

The Controller shall hand over the copy written onto a CD or DVD disk to the Data Subject, along with the privacy policy, as well as a copy of the minutes drawn on the circumstances of the request for the recording.

The Data Subject may put forth his or her request for the issuance of the recording in any of the customer service channels of the Controller, with reference to the conversation identifier.
The Data Subject may request only such an audio recording to be issued which includes a conversation conducted beyond doubt by him or her with the customer services staff.

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Processed data Legal basis Explanation Retention period
Telephone conversations with the customer service

 
- Consent as legal basis (Art. 6 (1) a) of the Regulation)
- Statutory obligation as legal basis ((Art. 6 (1) c) of the Regulation) (Art. 17/B of Consumer Protection Act)
The Controller records and processes in accordance with the provisions of the governing laws—primarily the Act on Consumer Protection—the audio recording of the conversation between the Data Subject and the customer service. The Data Subject is informed of the recording in each case before the start of the conversation. For 5 years from the date of the audio recording (Art. 17/B (3) of Consumer Protection Act)

9.2. Processing for marketing purposes

If the Data Subject expressly consents in any communication platform to being contacted for marketing purposes, the Controller may use his or her personal data provided in the course of the application to forward to the Data Subject information materials, promotions and offers concerning the Controller’s services. If the Data consents to this, the Controller shall send advertisements to the Data Subject by the method of direct marketing, and use the Data Subject’s data provided for this purpose: The consent equally concerns communication via e-mail, on the phone, or by mail.

Categories of processed data: the Data Subject’s e-mail address, telephone number, mailing address, and his/her consent to direct marketing.

Legal basis for the processing: consent of the Data Subject in each case (Art. 6 (1) a) of the Regulation).

Duration of the processing: as a general rule, until the withdrawal of consent by the Data Subject.
In the case of newsletters, the Controller shall process the Data Subject’s data provided in the course of the newsletter subscription until the Data Subject unsubscribes using the link provided in the newsletter, or requests his/her deletion from the list of subscribers in e-mail or by mail. If the subscription is cancelled, the Controller will not send any further newsletters or offers to the Data Subject.

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Processed data Legal basis Explanation Retention period
Data Subject’s e-mail address, telephone number and mailing address - Consent as legal basis (Art. 6 (1) a) of the Regulation) If the consent of the Data Subject is granted, the Controller transmits information material, promotions and offers related to its water utility services to the Data Subject. Until the purpose of processing is completed / until the Data Subject’s consent is withdrawn

9.3. Processing for the purpose of market and public opinion research

If in any communication platform the Data Subject expressly consents to being contacted for the purpose of public opinion and market research, then by using the personal data provided by the Data Subject (name, e-mail address, telephone number, mailing address) the Controller may contact the Data Subject for the purpose of the creation of an anonymous research sample that includes no personal data. The data used for the aforementioned purposes shall be used by the Controller for statistical purposes in such a way as ensures that the Data Subject cannot be identified.
The supervisory authority of the Controller (Hungarian Energy and Public Utility Regulatory Authority) may in a resolution require that the Controller periodically commission an independent public opinion research agency to assess the consumers’ level of satisfaction, in which case the privacy policy of the Authority shall be governing instead of this Policy.

Categories of processed data: the Data Subject’s e-mail address, telephone number, mailing address, his/her consent to being contacted for the purpose of public opinion and market research, market research and contact list.

Legal basis for the processing: consent of the Data Subject in each case (Art. 6 (1) a) of the Regulation).

Duration of the processing:until he withdrawal of consent by the Data Subject.
The Data Subject may at any time, without restrictions and without any explanation withdraw his or her consent to the processing for such purposes of his or her personal data. If the Data Subject withdraws his or her consent to the processing of his or her personal data, the Controller shall not contact the Data Subject for the purpose of market and public opinion research going forward through the specified communication channels.

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Processed data Legal basis Explanation Retention period
Market research and contact list, for the purpose of the creation of a statistics list - Consent as legal basis (Art. 6 (1) a) of the Regulation) Art. 3 and Art. 17 of Act CXIX of 1995 on the Use of Name and Address Information Serving the Purposes of Research and Direct Marketing provide the legal opportunity for the Controller—subject to the consent of the Data Subject—to set up a market research and contact list for the purpose of public opinion and market research on the basis of the Data Subject’s anonymized personal data. Until the purpose of processing is completed / until the Data Subject’s consent is withdrawn

9.4. 9.4 Extraordinary events and loss events

In the course of the reimbursement process of the losses caused to the Controller as an aggrieved party (e.g. damages caused by third parties in operated, rented or own property, damages related to meters or fire hydrants) or those caused by the Controller as an injuring party (e.g. outage losses), the Controller necessarily processes personal data for the purpose of loss administration not only of the Data Subject who is in a contractual relationship with the controller, but also of third parties (e.g. injuring parties, witnesses, experts, acting official persons).

Categories of processed data the Data Subject’s name, his/her mother’s name, mailing address, bank account number, insurer’s name, policy number, acting official person’s name, badge number, telephone number, invoice, injuring party’s statement, loss minutes, loss file, expert’s opinion (where available).

Legal basis for the processing: consent of the Data Subject (Art. 6 (1) a) of the Regulation), or the legitimate interest of the Controller or third party (Art. 6 (1) f) of the Regulation).

Duration of the processing: 5 years in respect of the documents of loss administration, 8 years in respect of issued invoices and transaction certificates.

Data transfer:: he documents generated in the course of the loss administration are necessarily sent to competent insurance companies and insurance brokers, with a view to the evaluation of the damages claim.
If the complexity of the case justifies this, experts and official bodies may also be involved.

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Processed data Legal basis Explanation Retention period
Data Subject’s name, his/her mother’s name, mailing address, bank account number, insurer’s name, policy number, witness’ name and address, acting official person’s name, badge number, telephone number, invoice, injuring party’s statement, loss minutes, loss file, expert’s opinion (where available). - Consent as legal basis (Art. 6 (1) a) of the Regulation)
- Legitimate interest of the Controller or third party as a legal basis (Art. 6 (1) f) of the Regulation)
The Controller as an aggrieved party or injuring party necessarily processes personal data concerning third parties for the purposes of loss administration. - 5 years as per the general limitation period (Art. 6:22 of Act V of 2013 on the Civil Code)
- 8 years from the year of issuance of the accounting certificate (Art. 169 of Act C of 2000 on Accounting)

9.5. Property protection

9.5.1. Camera system

The Controller qualifies as a body performing public duties, and in accordance with its statutory obligation it operates an electronic surveillance and recording system in its premises, central office building and customer service area (the “camera system”) for the purposes of property protection, the protection of critical infrastructures, the prevention, detection and proving of infringements, catching offenders in the act, as well as the protection of human life and physical integrity. The camera system does not record voices. The Controller meets its obligation to provide information by displaying pictograms signifying the location of each camera.

Categories of processed data:: image of the Data Subjects shown in the footage.

Legal basis for the processing: it is necessary for the performance of the Controller’s public interest task (Art. 6 (1) e) of the Regulation).

Duration of the processing:

  • the retention period of camera footage directly not related to drinking water or wastewater services is 3 days,
  • the retention period of footage related to public water utility services, but not covering technological spaces or areas—including customer service areas and the footage of transport routes as well—is 30 days,
  • the retention period of footage covering the technological spaces and areas falling in the patrol route of the armed security guards is 60 days.

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Processed data Legal basis Explanation Retention period
Image of the Data Subjects shown in the footage - Performance of public interest task as a legal basis (Art. 6 (1) e) of the Regulation) For the purposes of property protection, the protection of critical infrastructures, the protection of human life and physical integrity, the prevention, detection and proving of infringements, and catching offenders in the act, the Controller processes the images of Data Subjects shown in the camera footages. 3 days/30 days/60days

9.5.2. Access control system

For the purpose of property protection, the Controller operates an access control system in its premises. Visitors other than those administering cases related to customer service may enter the Controller’s premises only with visitor cards issued by the reception desk. A visitor card authorizes its bearer to a one-time entry. Partners having a regular business relationship with the Controller will be granted partner cards—based on individual application—authorizing their bearer to regular entry.

Categories of processed data: the Data Subject’s name, address, identity document number, telephone number (in the case of a partner card).

Legal basis for the processing: it is necessary for the performance of the Controller’s public interest task (Art. 6 (1) e) of the Regulation). In the case of a partner card, the telephone number of the Data Subject is processed on the basis of consent (Art. 6 (1) a) of the Regulation).

Duration of the processing: After the visitor card is returned to the reception desk, it loses its validity, and the data will be erased from the access control system within 24 hours. Data belonging to partner cards will be erased from the access control system after 6 months from the date when the card is returned to the reception desk or is withdrawn.

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Processed data Legal basis Explanation Retention period
Data Subject’s name, address and identity document number - Performance of public interest task as a legal basis (Art. 6 (1) e) of the Regulation) The Controller processes the Data Subjects’ data for the purposes of property protection and the protection of critical infrastructures. 24 hours / 6 months
Data Subject’s phone number in the case of partner cards - Consent as legal basis (Art. 6 (1) a) of the Regulation) The Data Subject’s telephone number is processed by the Controller for communication purposes. Until the withdrawal of the consent of the Data Subject / for 6 months

9.5.3. Access permission to protective zones

The purpose for the issuance of an access permission is to ensure stay at certain specific parts of protective zones for the Data Subject. The access permission is valid only and exclusively together with the valid identity document provided on the application form. Access permission to the protective zones of the Controller may be requested by private individuals aged 14 or more who wish to stay in or pass through the zone for private or touristic purposes. The access permission shall be valid for the protective zones of Csepel Island, the Left Bank, and Szentendre island. The permission shall not be valid for the southern, closed area of Szentendre Island, and to the operation zones.

Categories of processed data: the Data Subject’s name, address, mailing address where the permission is to be sent, identity document number, signature.

Legal basis for the processing: it is necessary for the performance of the Controller’s statutory obligation (Art. 6 (1) c) of the Regulation).

Duration of the processing: The data are processed during the period of validity of the permission (1 year).
If the given permission expires, and is not renewed, the Controller shall after the lapse of 6 months from the expiry of the period of validity of the permission erase the data from its system. If the Data Subject requests the erasure of his or her data prior to the lapse of the 6-month period, the Controller shall without delay take measures towards the erasure of the data. In the case of erasure the permission will be withdrawn, and cannot be used any longer.

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Processed data Legal basis Explanation Retention period
Data generated in the course of the request for permission to enter the protective zone - Statutory obligation as legal basis (Art. 6 (1) c) of the Regulation) (Art. 9/B of the Armed Security Guard Service Act) The following data of the Data Subject are processed by the Controller: name, ID card number, permanent address, mailing address. 18 months from the receipt of the form.

9.6. Protected users (persons with disabilities, persons with special social needs)

With a view to ensuring the benefits due to protected users, the Controller keeps a registry from which it can be ascertained beyond doubt whether the Data Subject is entitled to the benefits due to persons with disabilities and/or those due to persons with special social needs. Entry into the registry must be initiated by the Data Subject, and the documents certifying eligibility to protected user status as per Government Decree 58/2013 (II.27.) should be attached to the request. Registered Data Subjects are required to certify by 31 March each year whether their protected status still holds or not, unless the specialist opinion attached by the Data Subject states that no significant change is expected in his or her condition. If the Data Subject is no longer eligible to the benefit, or fails to certify his or her eligibility from year to year, the personal data concerning the Data Subject will be deleted from the registry. The Controller shall within 8 days notify the Data Subject of erasure from the registry.

Categories of processed data: name of the Data Subject and/or person living in the same household, mother’s name, place and date of birth, residential address, certifying documents issued by the agency establishing treatment providing eligibility to protected status.

Legal basis for the processing: statutory obligation of the Controller (Art. 6 (1) c) of the Regulation).

Duration of the processing: for 5 years from deletion from the registry.

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Processed data Legal basis Explanation Retention period
Documents certifying protected customer status - Statutory obligation as legal basis (Art. 6 (1) c) of the Regulation) (Art. 61/A of Water Utility Service Act) With a view to ensuring the benefits due to protected users, the Controller keeps a registry from which it can be ascertained beyond doubt to which range of benefits the data subject is entitled to. Entry into the registry must be initiated by the data subject, and the documents certifying eligibility to protected user status (as per the relevant Government Decree) should be attached to the request. The data deleted from the registry should be stored for 5 years counted from the deletion (Art. 61/A (8) of Act CCIX of 2011 on Water Utility Services)

10. Data transfer, activities of data processors

10.1. Data transfer

Data transfer may only take place based on the Data Subject’s consent, or the performance of a contract, or an authorization provided in the law, or the legitimate interest of the Controller or a third party concerned in the data transfer.
The Controller shall inform the Data Subject of the fact of the data transfer already upon the conclusion of the agreement, or when capturing the data, or before the data transfer (where this is possible, necessary and reasonable), as well as the legal basis and purpose of the transfer, any restrictions that may be applied, and the rights of the Data Subject.

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The Controller regularly reports to the agencies specified in the relevant laws, at the frequency and with the content specified in the laws.
In the case of statutory reporting on a one-time basis (e.g. requests by the investigating authority, the prosecutor’s office, a court, the national security service, a notary, the tax authority), the Controller ascertains about the legal basis for the processing, and in the case of doubt requests the cooperation of an expert.
The lawfulness of the data request is in each case the responsibility of the proceeding entity authorized to request the data, and the Controller has limited possibilities and liability in this respect. The Controller excludes all liabilities related to any losses that the Data Subject might sustain on account of the performance of reporting to the authorities.
The Controller transmits personal data only in case the legal basis for the processing is beyond doubt, and the purpose of the transfer and the identity of the recipient is clearly defined. The data transfer is documented in each case so that its procedure and lawfulness shall be provable.
In addition to the aforesaid, personal data are transferred by the Controller only in case the Data Subject has expressly consented to this. In case the transfer is subject to the consent of the Data Subject, the Data Subject shall make his or her declarations in an awareness of the recipient and purpose of the transfer.
The Controller logs data transfers so that it can be ascertained to whom, on what legal basis and for what purpose the personal data are transferred. The data recorded in the electronic log can only be consulted and used in order to check the lawfulness of data processing, to enforce data security requirements, and furthermore to conduct criminal proceedings.

The above prohibitions and restrictions are governing in the event of the termination of the customer relationship as well.

The Controller reserves the right to transfer its outstanding receivables to third parties via assignment in accordance with the rules set out in the Civil Code. As a result of such assignment, the identity of the beneficiary changes, and at the same time the Controller transfers the data related to the assigned receivables to the new beneficiary.

The table below summarizes the recipients of the Controller’s regular data transfers, the related legal bases for the transfer, and the relevant data subjects:

Recipients of data transfers >>

10.2. Execution of technical tasks connected to processing

The Controller reserves the right to engage data processors in the course of its activities, based on standing or ad hoc assignments. Processors may be engaged for the performance of technical tasks related to processing on a permanent basis primarily with a view to the performance of the administrative tasks related to the customer relationship and the provision of services, as well as the maintenance of the IT system. A processor may only be engaged on the basis of a written contract. The rights and obligations of the processor related to the performance of technical tasks related to the processing of personal data are determined by the Controller within the framework of the relevant laws. The lawfulness of instructions concerning data processing operations is the responsibility of the Controller.

By having terms of contract providing safeguards and adequate organizational and technical measures in place, the Controller ensures that in the course of the processor’s activities the rights of the data subjects will not be injured, and that the processor shall have access to personal data only if this is absolutely necessary for the performance of its tasks.

Where this is possible, the Controller shall inform the Data Subjects already upon the recording of the data about the Processors engaged by the Controller, and the tasks performed or potentially performed by them. Upon request, the Controller shall in addition to those included in the relevant prospectus inform the Data Subjects of the identity of the processor and the details of its data processing activities, including in particular executed operations, and the instructions given to the processor.

The range of the processors engaged by the Controller changes continuously.

The Controller engages the following enterprises and persons as processors in the scope of long-term assignments concerning the performance of technical tasks related to processing:

List of of Data Processors >>

11. Rights and remedies

  Rights Explanation
1. Information and access to personal data The Data Subject has the right to know and check his or her personal data stored by the Controller and obtain information related to their processing, and furthermore has the right to gain access to his or her personal data (e.g. what is the purpose and legal basis for the processing, when will the data be erased).
If after obtaining information the Data Subject does not agree with the processing of the data by the Controller, or finds that the data are incorrect, he or she may request the personal data concerning him or her to be rectified, completed, erased, or their processing to be restricted, may object to the processing of such personal data, and may exercise further legal remedies.
2. Right to rectify or complete personal data The Data Subject has the right to have inaccurate data rectified by the Controller without undue delay (e.g. to report a name change, or provide a new phone number).
3. Right to restriction of processing The Data Subject shall have the right to obtain from the Controller restriction of processing where one of the following applies:
- the accuracy of the personal data is contested by the Data Subject; in such case the restriction shall concern a period enabling the Controller to verify the accuracy of the personal data,
- the processing is unlawful and the Data Subject opposes the erasure of the personal data and requests the restriction of their use instead,
- 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 defense of legal claims,
- the Data Subject has objected to the processing; in such case the restriction concerns the period until it is verified whether or not the legitimate grounds of the Controller override those of the Data Subject.
4. Right to erasure (right to be forgotten) The Data Subject shall have the right to obtain from the Controller the erasure of personal data concerning him or her 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 by the Controller,
- 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 on grounds relating to his or her particular situation, and there are no overriding legitimate grounds for the processing,
- the Data Subject objects to the processing of his or her personal data for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing,
- the personal data have been unlawfully processed,
- the personal data have been collected in relation to the offer of information society services directly to a child.

The Data Subject may not exercise his or her right to erasure or right to be forgotten to the extent that processing is necessary:
- for exercising the right of freedom of expression and information;
- for reasons of public interest in the area of public health;
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in so far as the exercise of the right to erasure is likely to render impossible or seriously impair such processing; or
- for the establishment, exercise or defense of legal claims.
5. Right to data portability The Data Subject has the right to receive his or her “own” personal data that have been provided by the Data Subject and are available in the Controller’s system, and to use such data going forward for his or her own purposes. This right shall be in each case restricted to the data provided by the Data Subject, and portability shall not apply to other data (e.g. statistics).
6. Right to object to the processing of personal data The Data Subject shall have the right to object at any time to the processing of personal data concerning him or her (e.g. profiling, direct marketing).

The Controller shall perform written requests submitted by e-mail or mail only. The Controller shall inform the Data Subject on any action taken without undue delay, within 25 days of the receipt of any request. If the Data Subject has submitted the request electronically, the Controller shall also provide the information electronically, unless the Data Subject requests otherwise.

If the Data Subject’s request is obviously ungrounded or exaggerated (especially having regard to the repeated nature of the request), the Controller may charge a reasonable fee for the fulfillment of the request, or may refuse to take action. The burden of proof shall be incumbent on the Controller. If the Controller has doubts about the identity of the natural person submitting the request, it may ask the person concerned to submit additional information necessary to confirm the applicant’s identity.

With his or her general questions related to data protection, the Data Subject may as well refer directly to the Controller’s data protection officer: Károly Gróftelephone number: 06 1 465 2400; fax number: 06 1 435 3998; e-mail: vizvonal@vizmuvek.hu ; mailing address: Budapest Waterworks Plc. 1397 Budapest, Pf. 512

In connection with the lawfulness of the processing of his or her personal data by the Controller, the Data Subject may initiate action to be taken by the Hungarian National Authority for Data Protection and Freedom of Information (NAIH) (registered office: 1125 Budapest, Szilágyi Erzsébet fasor 22/c, mailing address: 1534 Budapest, Pf.: 843, website: www.naih.hu , telephone: +36 (1) 391-1400 , fax: +36 (1) 391-1410 , central e-mail address: ugyfelszolgalat@naih.hu ) or may refer to the tribunal having jurisdiction over the area where the Data Subject resides (“right to judicial remedy”).

Within 5 years of the Data Subject’s death, the rights the deceased was entitled to (see above) can be exercised by a person empowered by the Data Subject in a letter of authorization or in a declaration drawn up and certified in due legal form or made at the Controller and set out in a private document with full probative force. If the Data Subject failed to make such a legal statement, then in its absence an immediate family member of the deceased as per the Civil Code shall also have the right to exercise the rights the deceased was entitled to within 5 years of the death of the Data Subject. The person exercising the Data Subject’s rights may certify the fact and date of the Data Subject’s death with a death certificate or a court decision, and his or her own identity—and capacity as an immediate family member—with a public instrument.

The Controller shall be obliged to reimburse the Data Subject for any losses caused to the Data Subject by the unlawful processing of the Data Subject’s data, the infringement of his or her personality rights, or the violation of the requirement of data security. In the event of the infringement of his or her personality rights, the Data Subject has the right to claim restitution as per the Civil Code. The Controller shall not be held liable for any losses arising from failure of the Data Subject to meet his or her obligation to report changes in respect of personal data, and such losses shall be borne only and exclusively by the Data Subject.

12. Data security, the storage and retention of personal data

The Controller shall make reasonable efforts with a view for the security of data, ensure that the data are protected at adequate level, and shall prevent any unauthorized access, change, transmission, making public, deletion, intentional or accidental destruction or damage.

For the processing of personal data, the Controller shall select and operate IT instruments guaranteeing that the processed data are accessible only for persons authorized to know them (availability), that the authenticity of the data is ensured (authenticity of processing), that the data are unaltered (data integrity), and are protected against unauthorized access (confidentiality).

All IT systems used by the Controller in the course of the processing and registration of personal data are accessible only and exclusively for the employees authorized to process data, whereby the inviolability of the data is ensured.

In the course of mass processing tasks in the Controller’s internal administrative system, the Controller also uses robotized, new, innovative processing technologies that are suitable to replace live human resources, and at the same time result in an at least partly automated processing. Profiling Data Subjects is no purpose of the robotized processings applied by the Controller.
On the basis of individual contracts, the Controller may in its supply area receive hot and cold water meter data read off in remote meter reading systems of apartment houses, and may transfer the measurement data read off in the Data Subject’s system as a result of automated processing for the purpose of invoicing to Díjbeszedő Holding Zrt., and hot water submeter data to Budapesti Távhőszolgáltató Zrt.
Prior to the use of robotized technologies, or the operation of a remote meter reading system, the Controller shall decide on the applicability of these depending on the result of executed data protection impact assessments.

The Controller shall also use adequate organizational measures to ensure the security of data.

Upon the occurrence of a personal data breach—except where the personal data breach does not result in a risk to the rights and freedoms of natural persons—the Controller shall communicate the personal data breach to the Data Subject and the supervisory authority without undue delay, but within 72 hours at the latest. For the purpose of supervising the measures taken in respect of the personal data breach, informing the supervisory authority, and informing the Data Subject, the Controller maintains a register including the range of personal data concerned in the incident, the range and number of data subjects concerned, the date and time and circumstances of the incident, its effect, and the measures taken for its elimination.

The Controller as a company performing a public duty falls within the scope of the regulation concerning the protection of archival material. In accordance with Act LXVI of 1995 on Public Records, Public Archives, and the Protection of Private Archives, the documents generated at the Controller qualify as public records whose retention is governed by the above mentioned law, the document management rules issued under such law, and an archiving plan.

In accordance with the relevant rules, the Controller shall keep record of the archival material even if otherwise the purpose for which the personal data included in the documents were processed no longer exists. In such case the legal basis for the processing shall be the legislation concerning archival material.
Upon request, the Controller shall inform the Data Subjects in detail of the regulation concerning the retention of archival material.

13. Major laws concerning the activities of the Company

  • Regulation (EU) 2016/679 of the European Parliament and of the Council 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)
  • Act XLV of 1991 on Metrology
  • Ac LVII of 1995 on Water Management
  • Act LIII of 1995 on the General Rules for the Protection of the Environment
  • Act LVII of 1996 on the Prohibition of Unfair Market Practices and the Restriction of Competition
  • Act XXXI of 1997 on Child Protection and Custody Administration
  • Act CLIV of 1997 on Health Care
  • Act CLV of 1997 on Consumer Protection
  • Act C of 2000 on Accounting
  • Act LXXXIX of 2003 on Environmental Load Fee
  • Act XLVII of 2008 on the Prohibition of Unfair Commercial Practices against Consumers
  • Act LXXVI of 2009 on the General Rules for Starting and Pursuing Service Activities
  • Act CXII of 2011 on Informational Self-Determination and Freedom of Information
  • Act CXC of 2011 on National Public Education
  • Act CCIX of 2011 on Water Utility Services
  • Act V of 2013 on the Civil Code of Hungary
  • Act CLXXXVIII of 2013 on the Standard Format of Utility Invoices
  • Act LIV of 2013 on the Implementation of Utility Cost Reduction
  • Act XXII of 2013 on the Hungarian Energy and Public Utility Regulatory Authority
  • Act IX of 2016 on Collection Flat Rate
  • Government Decree 72/1996 (V.22.) on the exercise of the rights of the water management authority
  • IKIM Decree 78/1997 (XII.30.) on the establishment of the fees payable for the use of metrology administrative services
  • Government Decree 19/2009 (I.30.) on the implementation of the provisions of Act XL of 2008 on Natural Gas Supply
  • Government Decree 123/1997 (VII.18.) on the protection of water bases, long-term water bases, and water facilities serving drinking water supply
  • Government Decree 58/2013 (II.27.) on the implementation of certain provisions of Act CCIX of 2011 on Water Utility Services
  • Government Decree 127/1991 (X.9.) on the enforcement of the Act on Metrology
  • Government Decree 201/2001 (X.25.) on quality standards for drinking water and on the control process
  • KVVM Decree 28/2004 (XII.25.) on the limits for the emission of water pollutants and certain rules for their application
  • Government Decree 220/2004 (VII.21.) on the rules for the protection of the quality of surface waters
  • Government Decree 253/1997 (XII.20.) on the national requirements of urban planning and building construction
  • Decree 21/2015 (VIII.05.) of the Municipal Council of Budakeszi Town on the public service concerning the collection of household wastewater not collected by public utility
  • Decree 10/2015 (V.28.) of the Municipal Council of Biatorbágy Town on the public service concerning the collection of household wastewater not collected by public utility
  • Decree 8/2015 (V.29.) of the Municipal Council of Tököl Town on the public service concerning the collection of household wastewater not collected by public utility
  • Decree 11/2016 (IX.6.) of the Municipal Council of Pócsmegyer Village on the public service concerning the collection of household wastewater not collected by public utility
  • Decree 15/2016 (VII.22.) of the Municipal Council of Szigetmonostor Village on the amendment of Decree 12/2016 (VII.04.) on the public service concerning the collection of household wastewater not collected by public utility
  • KVVM Decree 27/2005 (XII.6.) on the detailed rules for the control of used and wastewater emission

14. Miscellaneous provisions

The Controller reserves the right to unilaterally amend this Privacy Policy, subject to the prior notification of the Data Subjects through the Website. After the entry into force of the amendment, by accepting the notice disclosed in the Website the Data Subject consents to data processing as described in the amended Privacy Policy.

This Privacy Policy shall be valid from the date of 8, January, 2019.

Budapest Waterworks Plc.