INTRODUCTION

The REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (hereinafter: Regulation) 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, requires that the Data Controller takes appropriate measures to ensure that any information regarding the processing of personal data is provided to the data subject in a concise, transparent, intelligible, and easily accessible form, using clear and plain language, and that the Data Controller facilitates the exercise of the data subject's rights. The preliminary information obligation of the data subject is also stipulated by Act CXII of 2011 on the Right of Informational Self-Determination and Freedom of Information.

I. NAME OF THE DATA CONTROLLER

The publisher of this information, also the Data Controller:

(hereinafter: the Company)

II. NAME OF THE DATA PROCESSORS

Data Processor: means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the data controller. (Regulation Article 4 (8))

The use of a data processor does not require the prior consent of the data subject, but they must be informed accordingly. Therefore, we provide the following information:

1. Our Company's IT Service Provider

Our Company uses a data processor for the maintenance and management of its website, who provides IT services (hosting services) and, as part of this, stores personal data provided on the website for the duration of our contract with them.

The name of this data processor is as follows:

2. Our Company's Accounting Service Provider

Our Company employs an external service provider for the fulfillment of its tax and accounting obligations through an accounting service agreement, who processes the personal data of natural persons in a contractual or payee relationship with our Company for the purpose of fulfilling our tax and accounting obligations.

The name of this data processor is as follows:

III. DATA PROCESSING RELATED TO THE CONTRACT

1. Management of Contract Partners' Data - Registration of Buyers and Suppliers

1. The Company processes the data of natural persons who have contracted with it as buyers or suppliers, including their name, birth name, date of birth, mother's name, address, tax identification number, tax number, business license number, phone number, email address, website, bank account number, customer number (client number, order number), online identifier (lists of buyers, suppliers, loyalty lists), for the purpose of concluding, performing, terminating a contract, and providing contractual discounts. This processing is lawful even if it is necessary for taking steps at the request of the data subject prior to entering into a contract.
2. Recipients of personal data: employees of the Company responsible for customer service tasks, data processors handling accounting and tax duties. Duration of data processing: 5 years after the termination of the contract.
3. The data subject must be informed before data processing begins that the processing is based on the performance of a contract; this information can be provided in the contract itself.
4. The data subject must be informed about the transfer of their personal data to a data processor.

2. Contact Information of Representatives of Legal Entity Clients, Buyers, and Suppliers

1. Scope of personal data processed: name, address, phone number, email address, online identifier of the natural person.
2. Purpose of data processing: performance of a contract concluded with the Company's legal entity partner, business communication, legal basis: the data subject's consent.
3. Recipients of personal data, or categories of recipients: employees of the Company performing customer service tasks.
4. Duration of personal data storage: 5 years after the termination of the business relationship or the status of the data subject as a representative.

3. Visitor Data Processing on the Company's Website

1. Cookies are small data files that the visited website places on the user's computer. The purpose of a cookie is to facilitate and make the use of the given information and communication, internet service more convenient.
2. The Company does not store user data or use cookies to enhance the user experience on its website (www.robbkontrolkft.hu, www.robbanasmegelozes.hu).
3. On the website, visitors can request a quote or ask questions, during which they must provide some personal data. Therefore, before sending an email in the request for quote or contact sections of the Company's website, the user is asked for consent to data processing, which they can provide after reading the data processing information displayed on the website. With this information, the Company ensures that visitors can understand which types of data are processed for which purposes before and during the use of the website's services related to the information society, including data not directly associated with the user.

IV. DATA PROCESSING BASED ON LEGAL OBLIGATIONS

1. Data Processing for the Purpose of Fulfilling Tax and Accounting Obligations

1. The Company processes the data of natural persons who enter into a business relationship with it as buyers or suppliers, based on legal obligation, for the purpose of fulfilling tax and accounting obligations as defined by law (accounting, taxation). The data processed are those defined in Act CXXVII of 2017 on Value Added Tax, §169, and §202, in particular: tax number, name, address, tax status, and under Act C of 2000 on Accounting, §167: name, address, designation of the person or entity ordering the economic transaction, signature of the person authorizing and verifying the execution of the transaction, and the signature of the recipient on stock movement and cash handling documents.
2. Duration of personal data storage: 8 years after the termination of the legal relationship.
3. Recipients of personal data: the Company's employees and data processors responsible for taxation, accounting, payroll, and social security duties.

2. Payer Data Processing

1. The Company processes the personal data of those with whom it has a payer relationship (employees, their family members, employees, other beneficiaries) based on legal obligation for the purpose of fulfilling tax and social security contribution obligations (establishing tax, advance tax, contributions, payroll, social security, and pension administration) as specified by tax laws. The scope of data processed is defined by Act CL of 2017 on the Rules of Taxation (Art.), §50, specifically highlighting: natural person's identifying information (including previous names and titles), gender, nationality, tax identification number, social security number (TAJ). If tax laws associate a legal consequence with it, the Company may process data regarding employees' health (Income Tax Act §40) and union membership (Income Tax Act §47(2) b./) for the purpose of fulfilling tax and social security contribution obligations (payroll, social security administration).
2. Duration of personal data storage: 8 years after the termination of the legal relationship.
3. Recipients of personal data: the Company's employees and data processors responsible for taxation, payroll, and social security (payer) duties.

3. Data Processing Regarding Documents of Permanent Value Under the Archives Act

1. The Company processes its documents deemed to be of permanent value under the Act LXVI of 1995 on Public Records, Public Archives, and the Protection of Private Archival Material (Archives Act) based on legal obligation, for the purpose of preserving the part of the Company’s archival materials of permanent value intact and usable for future generations. Duration of data storage: until the transfer to the public archive.
2. The Archives Act governs the recipients of personal data and other aspects of data processing.

V. SUMMARY INFORMATION ABOUT THE DATA SUBJECT'S RIGHTS

In this section, we summarize the rights of the data subject for the sake of clarity and transparency, with detailed information provided in the following chapter.

1. Right to prior information: the data subject has the right to be informed about facts and information related to data processing before it begins. (Regulation Articles 13-14)
2. Right of access: the data subject has the right to obtain confirmation from the Controller as to whether personal data concerning them is being processed, and if so, to access the personal data and the related information as specified in the Regulation. (Regulation Article 15)
3. Right to rectification: the data subject has the right to obtain from the Controller without undue delay the rectification of inaccurate personal data concerning them. Considering the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement. (Regulation Article 16)
4. Right to erasure ("right to be forgotten"): the data subject has the right to obtain from the Controller the erasure of personal data concerning them without undue delay, and the Controller has the obligation to erase personal data without undue delay if one of the reasons specified in the Regulation applies. (Regulation Article 17)
5. Right to restriction of processing: the data subject has the right to obtain from the Controller restriction of processing if the conditions specified in the Regulation are met. (Regulation Article 18)
6. Notification obligation regarding rectification or erasure of personal data or restriction of processing: the Controller shall communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. Upon the data subject’s request, the Controller shall inform them about those recipients. (Regulation Article 19)
7. Right to data portability: under the conditions laid down in the Regulation, the data subject has the right to receive the personal data concerning them, which they have provided to a Controller, in a structured, commonly used, and machine-readable format, and have the right to transmit those data to another Controller without hindrance from the Controller to whom the personal data have been provided. (Regulation Article 20)
8. Right to object: the data subject has the right to object, on grounds relating to their particular situation, at any time to the processing of personal data concerning them based on Article 6(1)(e) (processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller) or Article 6(1)(f) (processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party), including profiling based on those provisions. (Regulation Article 21)
9. Right to withdraw consent: the data subject has the right to withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
10. Right to lodge a complaint with a supervisory authority: every data subject has the right to lodge a complaint with a supervisory authority if they consider that the processing of personal data relating to them infringes the Regulation.

VI. DETAILED INFORMATION ON THE RIGHTS OF THE DATA SUBJECT

1. Right to preliminary information: the data subject is entitled to receive information regarding the facts and data related to data processing before the data processing begins.

1. Information to be provided if personal data is collected from the data subject:
   1. If personal data related to the data subject is collected from the data subject, the data controller shall provide the data subject with all of the following information at the time of data acquisition:
      1. the identity and contact details of the data controller and, if applicable, the data controller's representative;
      2. the contact details of the data protection officer, if applicable;
      3. the purpose of the planned processing of personal data and the legal basis for the processing;
      4. in the case of data processing based on Article 6(1)(f) of the Regulation (legitimate interest), the legitimate interests of the data controller or third party;
      5. if applicable, the recipients or categories of recipients of the personal data;
      6. if applicable, the fact that the data controller intends to transfer the personal data to a third country or international organization, and the existence or absence of a Commission adequacy decision, or in the case of data transfer under Article 46, Article 47, or the second subparagraph of Article 49(1) of the Regulation, the appropriate and suitable safeguards, as well as reference to the means of obtaining a copy of them or their availability.
   2. In addition to the information mentioned in point 1, the data controller shall provide the data subject with the following supplementary information at the time of data acquisition to ensure fair and transparent data processing:
      1. the duration of personal data storage, or if this is not possible, the criteria for determining this duration;
      2. the right of the data subject to request from the data controller access to, rectification, deletion, or restriction of the processing of personal data concerning them, and to object to the processing of such personal data, as well as the right to data portability;
      3. in the case of processing based on Article 6(1)(a) (consent of the data subject) or Article 9(2)(a) (consent of the data subject) of the Regulation, the right to withdraw consent at any time, which does not affect the lawfulness of the processing based on consent before its withdrawal;
      4. the right to lodge a complaint with a supervisory authority;
      5. whether the provision of personal data is required by law or contractual obligation or is a prerequisite for entering into a contract, as well as whether the data subject is obliged to provide personal data and the possible consequences of failing to provide such data;
      6. the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the Regulation, and, at least in these cases, meaningful information about the logic involved and the significance and expected consequences of such processing for the data subject.
   3. If the data controller intends to further process personal data for a purpose other than that for which it was collected, the data controller shall provide the data subject with information on this different purpose and all relevant supplementary information as referred to in paragraph 2 before the further processing.
   4. Points 1-3 do not apply if and to the extent that the data subject already has the information. (Article 13 of the Regulation)
2. Information to be provided if personal data is not obtained from the data subject:
   1. If personal data is not obtained from the data subject, the data controller shall provide the following information to the data subject:
      1. the identity and contact details of the data controller and, if applicable, the data controller's representative;
      2. the contact details of the data protection officer, if applicable;
      3. the purpose of the planned processing of personal data and the legal basis for the processing;
      4. the categories of personal data concerned;
      5. the recipients or categories of recipients of the personal data, if applicable;
      6. if applicable, the fact that the data controller intends to transfer the personal data to a third-country recipient or international organization, as well as the existence or absence of a Commission adequacy decision, or in the case of data transfer under Article 46, Article 47, or the second subparagraph of Article 49(1) of the Regulation, the appropriate and suitable safeguards, and reference to the means of obtaining a copy of them or their availability.
   2. In addition to the information mentioned in point 1, the data controller shall provide the data subject with the following supplementary information necessary for ensuring fair and transparent data processing for the data subject:
      1. the duration of personal data storage, or if this is not possible, the criteria for determining this duration;
      2. if the processing is based on Article 6(1)(f) of the Regulation (legitimate interest), the legitimate interests of the data controller or third party;
      3. the right of the data subject to request from the data controller access to, rectification, deletion, or restriction of the processing of personal data concerning them, and to object to the processing of personal data, as well as the right to data portability;
      4. in the case of processing based on Article 6(1)(a) (consent of the data subject) or Article 9(2)(a) (consent of the data subject) of the Regulation, the right to withdraw consent at any time, which does not affect the lawfulness of the processing based on consent before its withdrawal;
      5. the right to lodge a complaint with a supervisory authority;
      6. the source of the personal data and, if applicable, whether it originates from publicly accessible sources; and
      7. the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the Regulation, and, at least in these cases, meaningful information about the logic involved and the significance and expected consequences of such processing for the data subject.
   3. The data controller shall provide the information referred to in points 1 and 2 as follows:
      1. taking into account the specific circumstances of the processing of personal data, within a reasonable period after obtaining the personal data, but no later than one month;
      2. if the personal data is used for communication with the data subject, at least at the time of the first communication with the data subject; or
      3. if the data is expected to be disclosed to another recipient, at the latest at the time of the first disclosure of the personal data.
   4. If the data controller intends to further process personal data for a purpose other than that for which it was collected, the data controller shall provide the data subject with information on this different purpose and all relevant supplementary information as referred to in paragraph 2 before the further processing.
   5. Points 1-4 do not need to be applied if and to the extent that:
      1. the data subject already has the information;
      2. providing the information proves impossible or would involve a disproportionate effort, in particular for processing for purposes of public interest archiving, scientific or historical research purposes, or statistical purposes, in accordance with the conditions and safeguards referred to in Article 89(1) of the Regulation, or if the obligation referred to in this paragraph is likely to render impossible or seriously impair the achievement of the objectives of that processing. In such cases, the data controller shall take appropriate measures to protect the rights, freedoms, and legitimate interests of the data subject, including making the information publicly available;
      3. the acquisition or disclosure of the data is explicitly laid down in Union or Member State law applicable to the data controller that provides for appropriate measures to protect the data subject's legitimate interests; or
      4. if the personal data must remain confidential subject to an obligation of professional secrecy regulated by Union or Member State law, including a statutory obligation of secrecy.

2. Right of Access by the Data Subject

1. The data subject has the right to obtain confirmation from the Data Controller as to whether or not personal data concerning them is being processed, and, where that is the case, access to the personal data and the following information:
   1. the purposes of the processing;
   2. the categories of personal data concerned;
   3. the recipients or categories of recipients to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organizations;
   4. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
   5. the existence of the right to request from the Data Controller rectification or erasure of personal data concerning them, or restriction of processing of personal data, or to object to such processing;
   6. the right to lodge a complaint with a supervisory authority;
   7. where the personal data is not collected from the data subject, any available information as to its source;
   8. the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the Regulation, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
2. Where personal data is transferred to a third country or to an international organization, the data subject has the right to be informed of the appropriate safeguards relating to the transfer pursuant to Article 46 of the Regulation.
3. The Data Controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the Data Controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form. The right to obtain a copy shall not adversely affect the rights and freedoms of others. (Article 15 of the Regulation)

3. Right to Erasure (“Right to be Forgotten”)

1. The data subject has the right to obtain from the Data Controller the erasure of personal data concerning them without undue delay, and the Data Controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
   1. the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
   2. the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1) or point (a) of Article 9(2) of the Regulation, and where there is no other legal ground for the processing;
   3. the data subject objects to the processing pursuant to Article 21(1) of the Regulation and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
   4. the personal data has been unlawfully processed;
   5. the personal data must be erased for compliance with a legal obligation in Union or Member State law to which the Data Controller is subject;
   6. the personal data has been collected in relation to the offer of information society services referred to in Article 8(1) of the Regulation.
2. Where the Data Controller has made the personal data public and is obliged pursuant to the above point to erase the personal data, the Data Controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copies or replication of, those personal data.
3. Points A and B shall not apply to the extent that processing is necessary:
   1. for exercising the right of freedom of expression and information;
   2. for compliance with a legal obligation which requires processing by Union or Member State law to which the Data Controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;
   3. for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3) of the Regulation;
   4. for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) of the Regulation, in so far as the right referred to in point A is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
   5. for the establishment, exercise, or defense of legal claims. (Article 17 of the Regulation)

4. Right to Restriction of Processing

1. The data subject has the right to obtain from the Data Controller restriction of processing where one of the following applies:
1. the accuracy of the personal data is contested by the data subject, for a period enabling the Data Controller to verify the accuracy of the personal data;
2. the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of its use instead;
3. the Data 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; or
4. the data subject has objected to processing pursuant to Article 21(1) of the Regulation pending the verification whether the legitimate grounds of the Data Controller override those of the data subject.
2. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
3. The Data Controller shall inform the data subject who has obtained restriction of processing pursuant to paragraph 1 before the restriction is lifted. (Article 18 of the Regulation)

5. The Right to Data Portability

1. The data subject shall have the right to receive the personal data concerning them, which they have provided to a Controller, in a structured, commonly used, and machine-readable format and have the right to transmit those data to another Controller without hindrance from the Controller to which the personal data have been provided, where:
   1. the processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a) of the Regulation, or on a contract pursuant to Article 6(1)(b); and
   2. the processing is carried out by automated means.
2. In exercising their right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one Controller to another, where technically feasible.
3. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17 of the Regulation. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller.
4. The right referred to in point A shall not adversely affect the rights and freedoms of others. (Article 20 of the Regulation)

6. The Right to Object

1. The data subject shall have the right to object, on grounds relating to their particular situation, at any time to the processing of personal data concerning them which is based on point (e) (processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller) or (f) (processing necessary for the purposes of the legitimate interests pursued by the Controller or by a third party) of Article 6(1) of the Regulation, including profiling based on those provisions. The Controller shall no longer process the personal data unless the Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defense of legal claims.
2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to the processing of personal data concerning them for such marketing, which includes profiling to the extent that it is related to such direct marketing.
3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
4. The right referred to in points A and B shall be explicitly brought to the attention of the data subject at the latest at the time of the first communication with the data subject and shall be presented clearly and separately from any other information.
5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise their right to object by automated means using technical specifications.
6. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1) of the Regulation, the data subject shall have the right to object, on grounds relating to their particular situation, to processing of personal data concerning them, unless the processing is necessary for the performance of a task carried out for reasons of public interest. (Article 21 of the Regulation)

7. Automated Individual Decision-Making, Including Profiling

1. The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.
2. The provision referred to in point A shall not apply if the decision:
   1. is necessary for entering into, or performance of, a contract between the data subject and a Controller;
   2. is authorized by Union or Member State law to which the Controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests; or
   3. is based on the data subject's explicit consent.
3. In the cases referred to in points 1 and 3 of point B, the Controller shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the Controller, to express their point of view, and to contest the decision.
4. Decisions referred to in point B shall not be based on special categories of personal data referred to in Article 9(1) of the Regulation, unless point (a) or (g) of Article 9(2) applies and suitable measures to safeguard the data subject's rights and freedoms and legitimate interests are in place. (Article 22 of the Regulation)

8. Restrictions

1. Union or Member State law applicable to the Controller or Processor may restrict the scope of the rights and obligations provided for in Article 5 of the Regulation with legislative measures, as well as the provisions in line with the rights and obligations set out in Articles 12-22 and Article 34 of the Regulation, provided that the restriction respects the essence of fundamental rights and freedoms and constitutes a necessary and proportionate measure in a democratic society for the protection of:
   1. national security;
   2. defense;
   3. public security;
   4. the prevention, investigation, detection, or prosecution of criminal offenses or the execution of criminal penalties, including the protection against and prevention of threats to public security;
   5. other important objectives of general public interest of the Union or of a Member State, in particular an important economic or financial interest of the Union or of a Member State, including monetary, budgetary, and taxation matters, public health, and social security;
   6. the independence of the judiciary and judicial proceedings;
   7. the prevention, investigation, detection, and prosecution of breaches of ethics for regulated professions;
   8. monitoring, inspection, or regulatory functions connected, even occasionally, to the exercise of official authority in the cases referred to in points 1-5 and 7;
   9. the protection of the data subject or the rights and freedoms of others;
   10. the enforcement of civil law claims.
2. The legislative measures referred to in point A shall, where relevant, include specific provisions at least for:
   1. the purposes of the processing or categories of processing;
   2. the categories of personal data;
   3. the scope of the restrictions introduced;
   4. safeguards to prevent abuse or unlawful access or transfer;
   5. the specification of the Controller or the definition of the categories of Controllers;
   6. the storage periods and applicable safeguards, taking into account the nature, scope, and purposes of the processing or processing categories;
   7. the risks to the rights and freedoms of data subjects;
   8. the right of data subjects to be informed about the restriction, unless this may adversely affect the purpose of the restriction. (Article 23 of the Regulation)

9. Information to the data subject about the data breach

1. If the data breach is likely to result in a high risk to the rights and freedoms of natural persons, the Controller shall inform the data subject of the data breach without undue delay.
2. The information provided to the data subject referred to in point A shall clearly and plainly describe the nature of the data breach and must include at least the information and measures referred to in Article 33(3)(b), (c), and (d) of the Regulation.
3. The data subject does not need to be informed as set out in point A if any of the following conditions are met:
   1. the Controller has implemented appropriate technical and organizational protection measures, and those measures were applied to the personal data affected by the data breach, especially measures - such as encryption - that render the data unintelligible to any person not authorized to access it;
   2. the Controller has taken subsequent measures that ensure that the high risk to the rights and freedoms of the data subject referred to in point 1 is no longer likely to materialize;
   3. notifying the data subject would involve disproportionate effort. In such cases, the data subjects shall be informed by means of publicly issued information or by taking a similar measure that ensures effective information for the data subjects.
4. If the Controller has not yet informed the data subject of the data breach, the supervisory authority, having considered the likelihood of a high risk resulting from the data breach, may require the data subject to be informed or determine that one of the conditions referred to in point 3 is met. (Article 34 of the Regulation)

10. Right to lodge a complaint with a supervisory authority

1. Without prejudice to any other administrative or judicial remedy, every data subject has the right to lodge a complaint with a supervisory authority, particularly in the Member State of their habitual residence, place of work, or place of the alleged infringement if they consider that the processing of personal data relating to them infringes this Regulation.
2. The supervisory authority to which the complaint has been submitted shall inform the complainant of the progress and the outcome of the complaint, including the possibility of a judicial remedy pursuant to Article 78 of the Regulation. (Article 77 of the Regulation)

11. Right to an effective judicial remedy against a supervisory authority

1. Without prejudice to any other administrative or non-judicial remedy, every natural and legal person has the right to an effective judicial remedy against a legally binding decision of a supervisory authority concerning them.
2. Without prejudice to any other administrative or non-judicial remedy, every data subject has the right to an effective judicial remedy where the supervisory authority does not handle a complaint, or does not inform the data subject within three months of the progress or outcome of the complaint lodged pursuant to Article 77.
3. Proceedings against a supervisory authority shall be brought before the courts of the Member State where the supervisory authority is established.
4. If proceedings are brought against a decision of a supervisory authority following an opinion or decision issued by the Board under the consistency mechanism, the supervisory authority shall forward that opinion or decision to the court. (Article 78 of the Regulation)

12. Right to an effective judicial remedy against a controller or processor

1. Without prejudice to any available administrative or non-judicial remedy - including the right to lodge a complaint with a supervisory authority pursuant to Article 77 of the Regulation - every data subject has the right to an effective judicial remedy where they consider that their rights under this Regulation have been infringed as a result of processing of their personal data in non-compliance with this Regulation.
2. Proceedings against a controller or processor shall be brought before the courts of the Member State where the controller or processor has an establishment. Such proceedings may also be brought before the courts of the Member State where the data subject has their habitual residence, unless the controller or processor is a public authority of a Member State acting in the exercise of its public powers. (Article 79 of the Regulation)

VII. SUBMISSION OF THE DATA SUBJECT'S REQUEST, ACTIONS OF THE DATA CONTROLLER

1. Our Company, as the data controller, shall inform the data subject without undue delay, but in any event within one month of receipt of the request, about the actions taken in response to the request for exercising their rights.
2. If necessary, taking into account the complexity of the request and the number of requests, this deadline may be extended by a further two months. The Data Controller shall inform the data subject of any such extension, along with the reasons for the delay, within one month of receipt of the request.
3. If the data subject submitted the request electronically, the information shall be provided electronically whenever possible, unless the data subject requests otherwise.
4. If the Data Controller does not take action on the data subject’s request, it shall inform the data subject without delay, but at the latest within one month of receipt of the request, of the reasons for not taking action, as well as of the possibility for the data subject to lodge a complaint with a supervisory authority and seek judicial remedy.
5. Our Company, as the Data Controller, shall provide the information specified in Articles 13 and 14 of the Regulation and information about the data subject’s rights (Articles 15-22 and 34 of the Regulation) and actions free of charge. If the data subject's request is clearly unfounded or excessive, especially due to its repetitive nature, the Data Controller may, taking into account the administrative costs of providing the requested information or taking the requested action, refuse to act on the request. The burden of proving the clearly unfounded or excessive nature of the request lies with the Data Controller.
6. If our Company, as the Data Controller, has reasonable doubts concerning the identity of the natural person making the request, it may request the provision of additional information necessary to confirm the identity of the data subject.

Robbkontrol Ltd., 20th September, 2025