1. Responsible organization

Organization responsible for processing personal data:

Intersnack Magyarország Kft.
H-1117, Budapest
Alíz u. 1.

Tel.: +36-1-204-5945
Fax: +36-1-204-5965
E-mail: chio@chio.hu

Data protection officer:
Metterhausen Werner
Von zur Mühlen´sche GmbH
Alte Heerstr. 1
53121 Bonn

2. Personal data

We treat all data provided by users on our websites as personal data, by which we can infer the user's identity (for example, the user's name and e-mail address). We use this data to the extent and for the purposes specified below in accordance with the provisions of the legislation.

3. Collection, processing and use of data

3.1 Participation in promotions and competitions

In order to participate in certain promotions or contests available through the websites of Intersnack Magyarország Kft., the user must first register. When participating in promotions and competitions, you must provide your family name, first name, e-mail address and possibly other personal data. We process these data only to the extent necessary to fulfill our obligations regarding promotions and competitions. We will not use this data for any other purpose without the explicit consent of the user. Details regarding the procedure and configuration of the given promotions and contests, as well as the extent of data processing for these purposes, are contained in the conditions of participation of the individual promotions and contests (the legal basis is Section 6, Paragraph (1) point b) of the GDPR).

3.2 Newsletter

We only use the user's data for advertising purposes, if the user has given his express consent. On the websites of Intersnack Magyarország Kft., it is possible for users to subscribe to the company's newsletter on a voluntary basis, with a separate registration. The personal data provided when subscribing to the newsletter or to participate in contests and promotions will only be used for the above-mentioned advertising purposes if the user allows it in the relevant separate box when subscribing. The subscription to the newsletter is completed when the user clicks on the link received in our e-mail sent to the specified e-mail address after the subscription (the legal basis is Section 6, Paragraph (1) point a) of the GDPR).

The newsletter of Intersnack Magyarország Kft. provides regular information about our latest products (for example, new flavors), as well as promotions and competitions in which you can participate on the websites of Intersnack Magyarország Kft.

The data provided by users when subscribing to the newsletter (e-mail address, possibly name and address) are processed for the specified advertising purposes.

The following applies to data processing for advertising purposes:

Consent to the use of the data made available to us for use for the specified advertising purposes can be withdrawn at any time, either by e-mail (chio@chio.hu) or by letter (Intersnack Magyarország Kft, 1509 Budapest, Pf. 28.), without giving reasons. In each newsletter, we provide the possibility for the user to unsubscribe from further newsletters (via the specified unsubscribe link).

3.3 Disclosure of Information

In connection with the performance of the necessary activities (e.g. sending confirmation letters and newsletters, creating and deleting user accounts on the login interface) the above (in point 3.2) mentioned data processed in connection with the services will be transferred to our service provider (Magyar Telekom Nyrt., 1087 Budapest, Asztalos Sándor u. 13.). Additional information about the service provider can be found at www.telekom.hu. We will not disclose any other data collected in this context to third parties.

3.4 Contact form

There is a contact form on www.chio.hu and www.pombar.hu, with which users can send us their questions, suggestions, wishes and comments. In the form, you must enter the name and e-mail address, as well as the message intended for us. We store this data and forward it to our customer service, where they will respond to your inquiry. The data generated in connection with this will be deleted when they are no longer needed, but no later than after 365 days, unless the stored data is subject to different laws and obligations.

4. Data processing when using the pages of Intersnack Magyarország Kft. (user data)

In addition to the above, we also use user data to optimize our internet platform and to make the use of our websites as convenient as possible and the user experience more customized and secure.

4.1 Log files

If the user visits our website for informational purposes only, i.e. does not sign up for anything and does not provide us with any data, we only store the data automatically sent by the browser to the server of the content provider in the so-called log files and process them as necessary. When you visit our website, we collect the following data, which we need from a technical point of view to display the website and to ensure stability and security (legal basis is provided by Section 6, Paragraph (1) point f) of the GDPR):

• the IP address of the user's computer
• the exact date and time the server was queried
• the URL of the visited websites
• by definition, the URL of the website through which the user accessed the visited website
• the name of the requested file
• the page from which the file was retrieved
• the access status of the web server (file transferred, file not found, command not executed, etc.)
• browser type and version number
• the operating system of the terminal device used
• amount of data transferred

This data is collected exclusively in anonymized form, so no conclusions regarding the person can be drawn from the collected data. We do not combine these data with other data sources, on the basis of which anyone could be identified. The data is evaluated for statistical purposes at most and is automatically deleted after four weeks.

4.2 Use of cookies

We also use so-called 'cookies' on our websites (the legal basis is Section 6, Paragraph (1) point a) of the GDPR).

Cookies are small data files that the browser places on the user's computer while browsing our websites. Cookies can only contain data that we send to the user's computer and with the help of which we obtain specific data - personal data cannot be read in this way. Such data are mainly the type and version number of the user's browser, the URL clickstream (i.e. the web pages visited by the user and the order in which the web pages were visited), the date and time of the website visit, and the cookie number. If cookies are used, and if the user has accepted the use of cookies on our website, we do not have access to the user's personal data, but we can use cookies to identify the user's computer. Based on the cookies, we cannot draw any conclusions about the user's identity. Only anonymized data is generated. We only use so-called 'session cookies': these cookies do not remain on the user's computer. When the user leaves the website, temporary cookies are also deleted. With the help of the collected data, we can analyze the patterns and structure of the use of the website and optimize the website by developing content and personalizing and simplifying the use. We do not use persistent cookies - i.e. cookies that remain even after you leave the website. Further information on the use of cookies related to the functional analysis of the website can be found in section 4.3.

Most browsers (e.g. Firefox, Chrome, Internet Explorer, Safari, etc.) accept cookies by default. Accepting or blocking temporary and permanent cookies can be set independently in the browser settings. However, we specifically draw your attention to the fact that some options on our websites will not be available, and some websites may not be displayed correctly if cookies are not enabled.

4.3 Web analytics using Google Analytics

This website uses the analytics service Google Analytics from Google Inc. ('Google'). Google Analytics uses cookies stored on the user's computer, which can be used to analyze the use of the website. The information stored in cookies is transferred to a Google server in the USA and stored there. In the member states of the European Union and in other contracting states of the Agreement on the European Economic Area, the IP address is always truncated by Google before transmission. Google uses this information for us to evaluate the use of the website, to compile reports on the activity on the website and to provide individual services related to the website and internet use. Google does not combine the anonymized IP addresses transmitted by the user's browser in connection with the Google Analytics service with other data. Please note that on this website Google Analytics has added the code '_anonymizeIp()', which ensures that IP addresses are collected in an anonymized form (so-called IP masking). Based on this, identification can be completely excluded. Please note that in this case Google first collects the IP address and then shortens it. This takes place primarily in the EU, but partly in the USA. Additional information regarding data processing is contained in the company's data protection policy, which can be found under this Data Protection Policy. The user can prevent Google Analytics from collecting and processing their data. This can be done using your browser's cookie settings (see above) or by downloading and installing a plug-in made available by Google at the following link: http://tools.google.com/dlpage/gaoptout?hl=en. To prevent Google Analytics from collecting data, click on the following link to disable cookies so that we no longer collect data from you when you visit this website: Disable Google Analytics. Note that you will need to do this again if you delete this or all cookies in your browser settings. With the help of the Google Analytics service, we can analyze and regularly improve the usability of our website. Based on the obtained statistics, we can improve our internet platform and make it more interesting for users. For exceptional cases in which personal data is transferred in the USA, Google has joined the EU-US Privacy Shield (https://www.privacy-shield.gov/EU-US-Framework). The legal basis is section 6, paragraph (1) point f) of the GDPR. Third party provider to whom the data is transferred: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland; Information on Google's terms of service and privacy policy can be found at: https://www.google.com/analytics/terms/gb.html (Google Analytics Terms of Service), https://www.google.com/intl/de/analytics/learn/privacy.html (Privacy) and https://www.google.de/intl/de/policies/ (Google Privacy and Terms).

4.4 Use of the Facebook 'remarketing' service

This website uses Facebook's 'Custom Audiences from your Website' remarketing service. The purpose of this service is to show ads that match the interests of website visitors when they visit the Facebook social network (so-called Facebook ads). This allows us to show the user advertisements that may be of interest to him, thus making our website more interesting for him. For this purpose, our website uses the remarketing function of Facebook. If the user is logged in to Facebook when they visit our website in their browser, Facebook will be notified of this. On the basis of this information, when using the social site, Facebook displays our advertisements published on Facebook to the user. In this context, we do not collect any personal data - neither when the user visits our website, nor when Facebook displays our ads to the user on the user's page. We have no control over how much data Facebook collects and for what purpose. Information on how much data Facebook collects and for what purpose, as well as how it processes and uses this data, can be found at http://de-de.facebook.com/about/privacy/. The remarketing function 'Custom Audiences from your Website' can be disabled for the user's Facebook account at http://www.facebook.com/settings/?tab=ads. To do this, you need to log in to your Facebook account. The legal basis is Section 6, Paragraph (1), Point (1), Paragraph (f) of the GDPR.

4.5 Facebook conversion tracking

This website uses conversion tracking from Facebook*. This is usually accomplished with a conversion tracking pixel placed on our website. If the user is logged in to Facebook and the user is redirected to our website in connection with a given advertising measure, Facebook may use the tracking pixel to evaluate the effectiveness and attractiveness of the advertising measure and to transmit the results of this evaluation to us. The collected data is transferred to us anonymously. In other words, we don't know who Facebook referred to our site. If the user does not want Facebook to be informed that he has visited our website, he must first log out of Facebook.

Information on how much data Facebook collects and for what purpose, as well as how it processes and uses this data, can be found at http://de-de.facebook.com/about/privacy/. The user can disable Facebook conversion tracking for his account at the following link: http://www.facebook.com/settings/?tab=ads. To do this, you need to log in to your Facebook account. The legal basis is Section 6, Paragraph (1), Point (1), Paragraph (f) of the GDPR.

4.6 Use of social media plugins and our social media presence

For our presence on Facebook - our so-called Facebook page - Facebook provides information about how visitors use our Page (this is called 'Page Insights'). We and Facebook Ireland Limited (“Facebook”) jointly control the processing of Page Insights data – we have entered into an agreement regarding this (Section 26 of GDPR). The essence of this agreement, which also affects the user: Facebook takes primary responsibility for the processing of Page Insights data based on the GDPR (including, but not limited to: the exercise of data subject rights). At the end of this section, we indicate where you can obtain further information about data processing via Facebook.
In addition, we have no influence on the collected data or the data processing, nor do we know the extent of data collection, the purpose for which the data is processed, or how long it is stored. We also have no information on how the plug-in provider deletes the collected data.
The plug-in provider stores the data collected about the user as a usage profile and uses it for advertising, market research and/or customizing the website. Such an evaluation is carried out in particular for the purpose of presenting relevant advertisements (to users who are not logged in) and for the purpose of informing users of the social network about your activities on our website. You are entitled to object to the creation of these user profiles. To exercise this right, they must contact the respective plug-in provider.

Through our presence on social media platforms, user data generated there and through plugins, we provide more information about our products and offer you the opportunity to develop an active relationship with social networks and other users, which gives us the opportunity to develop our platform and more make it more interesting for you as a user. The legal basis for the use of user data generated through our presence on social media platforms and plug-ins is Section 6, Paragraph (1), Point (1), Paragraph (f) of the GDPR.
The data transfer takes place regardless of whether the user has an account with the plug-in provider and is logged in there. If the user is logged in, the data we collect is directly linked to the user's account with the plug-in provider. If the user presses the enabled button and, for example, links the page, the plugin provider also stores this information in the user's user account and shares it publicly with their contacts. We recommend that you regularly log out after using the social network, but especially before enabling the button, if you do not want it to be associated with the user's profile at the plugin provider.

You can find more information about the purpose and extent of data collection and data processing by the social media and plug-in provider in the privacy statements of these providers available at the following locations. The statements also contain information regarding the rights of users and data protection settings. The address of each plugin provider and their privacy policy URL:
 

• Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA; http://www.facebook.com/policy.php; additional information regarding data collection: http://www.facebook.com/help/186325668085084 és http://www.facebook.com/about/privacy/your-info-on-other#applications. Facebook has entered the EU-US data protection shield, https://www.privacyshield.gov/EU-US-Framework.
• Google Inc., 1600 Amphitheater Parkway, Mountainview, California 94043, USA; https://www.google.com/policies/privacy/partners/?hl=en. Google has entered the EU-US data protection shield, https://www.privacyshield.gov/EU-US-Framework.
  • Twitter, Inc., 1355 Market St, Suite 900, San Francisco, California 94103, USA; https://twitter.com/privacy. Twitter has entered the EU-US data protection shield, https://www.privacyshield.gov/EU-US-Framework.

5. User's rights

With regard to personal data, users have the following rights:

• Right of access (paragraph (1) and (2) in section 15 of GDPR)
• Right to rectification (paragraph (1) in section 15 of GDPR)
• Right to erasure (section 17 of GDPR)
• Right to restriction of processing (section 18 of GDPR)
• Right to object to processing (section 21 of GDPR)
• Right to data portability (section 20 of GDPR)

To exercise the above rights, you must contact the organization named in point 1.

Regarding the processing of your personal data by us, the user can file a data protection complaint at the supervisory authority.

6. Objection to the processing of user data and withdrawal of consent

The user can withdraw his consent to the processing of his personal data at any time without giving reasons, either by e-mail (chio@chio.hu) or by letter (Intersnack Magyarország Kft., 1509 Budapest, Pf. 1509.). The effect of the revocation is limited to the storage and use of personal data that we do not process on other legal grounds.

If the processing of the user's personal data is based on the balance of interests (section 6 paragraph (1) point (f) of the GDPR), the user can object to the processing. This is especially the case when the user's data is used for marketing purposes without his consent, or when the processing is not necessary for the fulfillment of the contract with the user, which was referred to in connection with the above-mentioned description of the individual functions.

It is possible to object to the processing of data for advertising purposes without justification. In all other cases, we ask the user to justify why we should not process his data in the way we do. In the event of a legitimate objection, we will immediately limit the further processing of the user's data. We examine the circumstances and either stop the data processing or modify the processing or reveal to the user the compelling interests that are worthy of protection and on the basis of which we continue the processing.