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PRIVACY AND DATA MANAGEMENT NOTICE
1. Identity and contact details of the controller
MKeys Travel (Beko GmbH., Adresse: Am Moosfeld 13., 81829 Munich, HRB 198931) acts as data controller for the personal data of its current, former and prospective customers.
2.
- Act CXII of 2011 on the Right of Informational Self-Determination and Freedom of Information,
- on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and on the protection of individuals with regard to the processing of personal data, and on the free movement of such data, and on the
- Regulation (EU) 2016/679 repealing Regulation (EC) No 95/46/EC (General Data Protection Regulation)
3. Definitions
- controller: the natural or legal person, public authority, agency or any other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of the processing are determined by Union or Member State law, the controller or the specific criteria for the designation of the controller may also be determined by Union or Member State law;
- 'processing' means any operation or set of operations which is performed upon personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
- processor: a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller;
- GDPR: REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC;
- supervisory authority or BayLDA: Bayerisches Landesamt für Datenschutzaufsicht.
- personal data means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
- special categories of personal data: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade-union membership, genetic data and biometric data revealing the individual's identity, health data and personal data concerning the sex life or sexual orientation of natural persons;
- customer: persons who inquire about MKeys Travel products and services in person, on the website, by telephone or in any other way, or who enter into a travel contract with MKeys Travel.
- website: https://mkeystravel.com/
4.
MKeys Travel will take appropriate measures to ensure that personal data relating to customers is at all times
a) lawfully and fairly and on an appropriate legal basis (legality, fairness and transparency);
b) collect only for specified, explicit and legitimate purposes and not process them in a way incompatible with those purposes;
(c) (c) be adequate, relevant and limited to what is necessary for the purposes for which they are processed (data minimisation);
(d) accurate and, where necessary, kept up to date; where possible, inaccurate personal data should be erased or rectified without undue delay (accuracy);
(e) (e) store the personal data in a form which permits identification of customers for no longer than is necessary for the purposes for which the personal data are processed; personal data should be stored for longer periods only for statistical purposes, subject to the implementation of appropriate technical and organisational measures (limited storage);
(f) (f) be processed in such a way as to ensure adequate security of personal data, including protection against unauthorised or unlawful processing, accidental loss, destruction or damage (integrity and confidentiality), by implementing appropriate technical or organisational measures.
5. Data processed by MKeys Travel, purpose, legal basis and duration of processing
MKeys Travel processes the following personal data about its customers for the purposes of the processing listed below:
I. Interest in services and individual requests for quotations via the website, in person, by telephone or otherwise
a) Name: data necessary to identify the customer
(b) e-mail address (telephone number): data indispensable for contacting the customer at a later stage
(c) subject of enquiry (e.g. period, length, destination, accommodation, catering, number of participants, age, mode of travel, price preference, comment): data necessary to clarify the customer's enquiry and to provide a personalised response, based on the customer's own information.
The legal basis for the processing is the consent of the interested party. The processing lasts for the duration indicated by the interested party or until the consent is withdrawn.
II. Subscription to newsletters (on the subscribe page of our website, when requesting a quote, when placing an order or in person/by telephone orally/written/by e-mail), other DM activities
a) e-mail address, name: data necessary to identify the customer
(b) telephone number: data essential to contact the customer at a later stage
(c) subject of interest: data necessary to specify the subject of the newsletter/other eDM tool, based on the customer's own information
d) date of subscription: for technical verification purposes
The legal basis for the processing is the consent of the interested party. The processing lasts for the duration indicated by the interested party or until the consent is withdrawn. The unsubscribe link is always included at the bottom of our newsletters, the interested party can unsubscribe
III.
a) name, title; date of birth; gender: data necessary to identify the customer
(b) e-mail address, telephone number; address (in some cases passenger data): data indispensable for contacting the customer at a later stage
(c) subject of the contract (e.g. period, destination, accommodation classification, number and date of birth of children, meal requirements, relevant medical data): definition of the subject of the contract
The legal basis for the processing of the data is the performance of the contract and the resolution of any disputes that may arise in connection with it. Duration of the processing: performance of the contract plus five years (general time limit for civil claims)
IV. Sale of airline tickets and other travel tickets
(a) name, title; date of birth; no: data strictly necessary to identify the customer
(b) e-mail address, telephone number; address (in some cases passenger data): data indispensable for contacting the customer at a later stage
(c) subject of the contract (e.g. period, destination, accommodation classification, number and date of birth of children, meal requirements, relevant medical data): definition of the subject of the contract
V. Visit to the website
Time and duration of the visit to the website: during the visit to the website, the service provider records the data of the visitor in order to monitor the performance of the service, its functioning and to prevent abuse
The legal basis for the processing is the consent of the data subject and the Electronic Commerce Act (Elektronischer Geschäftsverkehr-Gesetz EGG), the duration of which is 6 months.
The pages managed by MKeys Travel use cookies. Cookies are data files in text format which are stored by the user's browser on his/her hard disk. However, cookies do not contain any personal data, such as name, address, e-mail address, etc. The cookie is used by the visitor of the site, for example to obtain the right to view information on a page. No special settings are required on the user's browser to allow cookies to be downloaded to their computer. By default, the user's browser will accept cookies and store them in a list (e.g. "Temporarily downloaded internet files"), as there is no risk involved. If you do not want MKeys Travel and its contracted service providers and partners to use cookies, you should deactivate the acceptance of cookies in your web browser. For more information on this, the user can refer to the help section of their browser. If the user accepts cookies, they will be stored on the user's computer for 30 or 60 days, depending on their type, unless the user deletes them earlier. However, please note that not using cookies may result in limited functionality of the websites operated by MKeys Travel. Our partner Google places and reads back a cookie on the user's computer in order to serve its advertisements differently from the individual user. On a subsequent visit, the cookie management service provider has the possibility to match the user's current visit with previous visits, but only with regard to content relevant to the page. The user can delete the cookie from his/her computer or disable its management in his/her browser. Cookies used by Google can also be disabled at http://www.google.hu/privacy_ads.html
6. Recipients and categories of recipients of personal data
MKeys Travel generally shares customer personal data with the following third parties on a data controller to data controller basis:
(a) MKeys Travel or entities providing services to customers (e.g., insurance company (Mapfre Asistencia S.A. Hungarian Branch, 1146 Budapest, Hermina út 17. ), IT service provider);
b) third parties involved in the performance of the travel contract (hotel, airline, etc.);
c) supervisory authorities and other regulatory authorities and bodies.
d) subcontractors providing accounting and other accounting services
e) its IT system providers
Clients may request personal information on the processing of personal data relating to them by MKeys Travel (purpose of processing, legal basis, scope of data, transfer of data, duration of processing) by contacting MKeys Travel at the following contact point: info@mkeystravel.reise
7. Information on the use of a data processor
MKeys Travel, as a travel agency, uses a variety of IT services. In the course of these services, personal data may be accessed by external data processors. In addition to these, MKeys Travel uses services necessary to fulfil its accounting, bookkeeping, banking and other legal obligations. In doing so, it also transfers personal data to the data processors it engages.
MKeys Travel expects all its data processors to comply fully with its legal obligations.
8. International data transfers to third countries
Customers' personal data may be transferred to data controllers and data processors in countries outside the European Economic Area if this is necessary for the performance of the travel contract or if the traveller has given his/her explicit and informed consent (Article 49 GDPR).
MKeys Travel informs the traveller prior to the conclusion of the travel contract that the data transferred will be adequately protected with regard to the recipient outside the European Union to whom the data of the traveller are transferred:
(a) by means of general data protection clauses adopted by the Commission in accordance with the examination procedure referred to in Article 93(2) GDPR;
(b) general data protection clauses adopted by the supervisory authority and approved by the Commission in accordance with the examination procedure referred to in Article 93(2) of the GDPR;
(c) an approved code of conduct in accordance with Article 40 of the GDPR, together with a binding and enforceable commitment by the third country controller or processor to apply appropriate safeguards, including with respect to the rights of data subjects; or
(d) an approved certification mechanism pursuant to Article 42 of the GDPR, together with a binding and enforceable commitment by the third country controller or processor to apply appropriate safeguards, including with respect to the rights of data subjects. In this context, MKeys Travel will seek to have the contractual data protection model clauses approved by the European Commission / (BayLDA) adopted by its third country partners.
9. Customer access rights
The customer has access to his personal data.
If the customer requests feedback from MKeys Travel on whether MKeys Travel is processing his/her personal data, MKeys Travel is obliged to provide information.
The customer's right to receive feedback on whether MKeys Travel is processing
(or not) of his/her personal data,
(a) covers personal data relating to him/her;
b) not to anonymous data;
c) not personal data that does not relate to you; and
(d) includes pseudonymised data that can be clearly linked to the customer.
MKeys Travel will provide access and a copy of personal data to the requesting client upon request. If the customer requests an additional/repeat copy of his/her personal data, MKeys Travel may charge a reasonable fee to cover the administrative costs incurred in connection with fulfilling the request, which fee will be borne by the customer.
10. Client's right to rectification
The client has the right to rectify his personal data. This right
a) not to anonymous data;
b) personal data concerning him/her;
c) not to personal data which do not relate to him or her; and
(d) include pseudonymised data which can be clearly linked to the customer.
MKeys Travel will correct or complete the personal data of the client upon request. MKeys Travel will inform the recipients of such personal data (if any) of the rectification of the customer's personal data. However, MKeys Travel will not inform recipients of the rectification of personal data if it would prove impossible or would require a disproportionate effort to inform the recipients.
11. Customer's right to erasure
Under certain conditions, the customer is entitled to have his/her personal data deleted.
MKeys Travel is obliged to delete the personal data of the customer without undue delay if
a) MKeys Travel processes such personal data, and
b) the customer requests the deletion of his personal data, and
c) the personal data is no longer necessary for the purposes for which MKeys Travel processes the personal data.
MKeys Travel shall delete the customer's personal data without undue delay if
a) MKeys Travel processes the personal data of the customer, and
(b) the customer requests the deletion of his personal data, and (f) the customer withdraws the consent on which the processing of his data is based, and
(c) there is no other legal basis for the continued processing of the customer's data.
MKeys Travel shall delete the Client's personal data without undue delay if
a) the processing is necessary for the legitimate interests of MKeys Travel or a third party, and
b) the customer objects to the processing of his personal data by MKeys Travel, and
(c) a legitimate ground for processing such personal data does not override the customer's objection.
MKeys Travel shall delete the customer's personal data without undue delay if
a) the customer requests the deletion of his personal data; and
b) the processing of such data by the Company is not unlawful, or
c) the erasure is mandatory under applicable law, or
the customer's data are collected in connection with information society services.
MKeys Travel will inform the recipients of such personal data (if any) of the deletion of the customer's personal data. However, MKeys Travel will not inform the recipients of the deletion of personal data if it would be impossible or would require a disproportionate effort to inform the recipients.
Deletion from our newsletter system is automated. Users can unsubscribe at any time by sending a reply email to the newsletter and writing "unsubscribe" in the subject line, indicating in their email that they wish to unsubscribe or by clicking on Unsubscribe from this newsletter at the bottom of the newsletter.
12. The customer's right to restrict processing
The customer may request the restriction of the processing of his/her personal data.
The customer's right to request the restriction of the processing of his/her personal data
a) not include anonymous data;
b) personal data concerning him or her;
(c) not to personal data not relating to him or her; and
(d) include pseudonymised data which can be clearly linked to the customer.
MKeys Travel will limit the processing of a customer's personal data for the period during which it verifies the accuracy of such data if the customer requests the limitation of the processing of his or her personal data and the customer disputes the accuracy of such data.
MKeys Travel will restrict the processing of the customer's personal data if the customer requests the restriction of the processing of data whose processing is unlawful and the customer objects to the deletion of such data.
MKeys Travel will restrict the processing of the customer's personal data if
a) the customer requests the restriction of the processing of his personal data, and
b) MKeys Travel no longer needs such data for the purposes of its processing, and
c) the customer requires the data for the establishment, exercise or defence of a legal claim.
MKeys Travel will restrict the processing of the customer's personal data if
a) the customer objects to the processing of his/her personal data which is necessary for the purposes of the legitimate interests of MKeys Travel, and
(b) the customer is awaiting confirmation that MKeys Travel has a legitimate ground for processing the customer's personal data which does not override the customer's objection.
MKeys Travel will inform the recipients of such personal data (if any) of the restriction on the processing of the customer's personal data. However, MKeys Travel will not inform recipients of such restriction if it would be impossible or would require a disproportionate effort to inform the recipients.
If MKeys Travel restricts the processing of a customer's personal data, it will
a) store such personal data,
b) process such personal data subject to the consent of the customer,
(c) process the personal data for the establishment, exercise or defence of legal claims or the defence of the rights of any person.
MKeys Travel may not use customer data for direct marketing purposes, including profiling or automated decision-making in individual cases.
13. Customer's right to data portability
A customer has the right to receive personal data concerning him/her that he/she has provided to a controller in a structured, commonly used, machine-readable format and the right to have such data transmitted to another controller without hindrance (where technically feasible) to the controller to whom the personal data has been provided, if the processing is based on consent or is necessary for the performance of a contract and the processing is automated.
The customer's right to data portability
a) does not extend to anonymous data;
(b) personal data relating to him or her;
(c) does not cover personal data not relating to him or her; and
(d) not include pseudonymised data which can be clearly linked to the customer.
14. Time limit for the administration of the client's request as data subject
MKeys Travel will respond to requests for the rights to which the customer is entitled under the above within the following time limits.
Subject of the data subject's request Deadline
Right to be informed when the data is collected (if provided by the data subject) or within one month (if not provided by the data subject)
Right of access within one month
Right to rectification one month
Right to erasure without undue delay
Right to restriction of processing without undue delay
Right to data portability one month
Right to object upon receipt of the objection
Right to automated decision-making and profiling not specified
15. Security of data processing
MKeys Travel's computer systems and other data storage locations are located at its headquarters and at its data processors referred to in point 7.
MKeys Travel selects and operates the IT tools used to process personal data in the course of providing the service in such a way that the data processed is accessible to those authorised to access it, its authenticity and authentication are ensured, its integrity is verifiable, and it is protected against unauthorised access.
MKeys Travel shall ensure the security of data processing by technical, organisational and organisational measures that provide a level of protection appropriate to the risks associated with the processing.
MKeys Travel will maintain confidentiality - protecting information so that it is accessible only to those who are authorised to access it, integrity - protecting the accuracy and completeness of the information and the method of processing, availability - ensuring that when an authorised user needs it, he or she has effective access to the information required and the means to do so.
The IT systems and networks of MKeys Travel and its partners are protected against computer-assisted fraud, espionage, sabotage, vandalism, fire and flooding, as well as computer viruses, computer intrusions and denial of service attacks.
The operator ensures security through server-level and application-level protection procedures.
Users are informed that electronic messages transmitted over the Internet, regardless of protocol (e-mail, web, ftp, etc.), are vulnerable to network threats that could lead to fraudulent activity, contract disputes, or the disclosure or modification of information. To protect against such threats, the provider will take all reasonable precautions. It shall monitor systems in order to record and provide evidence of any security incidents. System monitoring also allows the effectiveness of the security measures taken to be checked.
16. Right to lodge a complaint
If the customer believes that his/her rights have been violated, MKeys Travel recommends that the customer initiate a conciliation with the controller by contacting him/her directly. If such conciliation does not lead to any result, or if the data subject does not wish to engage in such activity, he or she may refer the matter to the courts or the (BayLDA. In the event of legal proceedings, the data subject may decide to bring the proceedings before the competent court in the place where he or she resides or is domiciled.
The contact details of the BayLDA are as follows:
Bayerisches Landesamt für Datenschutzaufsicht
Promenade 18
91522 Ansbach
Fax: +49 (0) 981 180093-800
Telephone: +49 (0) 981 180093-0
E-mail: poststelle@lda.bayern.de
17. Amendments to this information
MKeys Travel reserves the right to amend this information at any time. MKeys Travel will inform customers of such changes by letter or e-mail, as appropriate, and in each case in accordance with applicable law.
2020.03.10.