Privacy Policy

Yumraya Kft. (registered office: 1149 Budapest, Nagy Lajos király útja 176, mezzanine 4th door, Tax Number: 32746983-1-42) (hereinafter referred to as "Yumraya.com" or "We"), as the data controller, hereby informs you—our customers who purchase goods or use services through our web shop available at https://www.yumraya.com—about the processing of personal data and this Privacy Policy.

To help you navigate our Privacy Policy, we have provided an overview of the following sections, outlining the key points:

1. SCOPE, PURPOSE, AND LEGAL BASIS OF PERSONAL DATA PROCESSING

Purposes of Personal Data Processing:

• Responding to requests, questions, suggestions, and account deletion requests
• Processing orders
• Creating customer accounts
• Sending commercial communications
• Conducting satisfaction surveys
• Recording telephone calls
• Selling alcoholic products
• Conducting marketing analyses and compiling statistics

2. WHO HAS ACCESS TO YOUR PERSONAL DATA?

Access to Personal Data:

• General information about data access

3. DURATION OF PERSONAL DATA PROCESSING

Information Regarding Data Retention Periods:

• For contract fulfillment and compliance with legal obligations
• Based on legitimate interests
• Within the customer account
• For age verification purposes
• For sending commercial communications

4. INFORMATION REGARDING COOKIES

Details About Cookies and Social Media Links:

• Third-party tools
• Cookie settings
• Social media buttons
• Links to detailed cookie information

5. WHAT ARE YOUR RIGHTS REGARDING THE PROCESSING OF YOUR PERSONAL DATA?

Information About Your Rights Related to Personal Data:

• Right of Access: You have the right to request access to your personal data that we process.
• Right to Rectification: You can request corrections to any inaccurate or incomplete personal data.
• Right to Erasure: You have the right to request the deletion of your personal data under certain conditions.
• Right to Restrict Processing: You may request the restriction of processing your personal data in specific situations.
• Right to Object: You have the right to object to the processing of your personal data, particularly for direct marketing purposes.
• Right to Lodge a Complaint with a Supervisory Authority: If you believe that the processing of your personal data violates data protection laws, you have the right to file a complaint with the relevant supervisory authority.

 

6. SCOPE, PURPOSE, AND LEGAL BASIS OF PERSONAL DATA PROCESSING

In this section, we inform you about the personal data we process about you. For your convenience, the section is divided based on the purposes of data processing. Each processing purpose is accompanied by the legal basis that allows such processing, based on Article 6 of the General Data Protection Regulation (GDPR) (EU) 2016/679.

6.1. Responding to Requests, Questions, and Suggestions

When you contact us with a request, question, or suggestion, you may need to provide certain personal or business-related information. This information may include, but is not limited to:

• a) Last name, first name
• b) Address
• c) Business name
• d) Company headquarters
• e) Identification number and tax identification number
• f) Phone number
• g) Email address

The information you provide is used to contact you and provide the requested information. Providing personal data is necessary to respond to your requests, and failure to do so may result in us being unable to respond.

Legal Basis: The legal basis for this data processing is our legitimate interest in handling your requests, inquiries, or suggestions.

6.2. Data Processing Related to Orders

When you purchase goods from the Yumraya.com web shop, we require your personal data to conclude and fulfill the contract. This personal data includes:

• a) Last name, first name
• b) Shipping address
• c) Phone number
• d) Email address
• e) Information about the ordered goods
• f) Information regarding the chosen payment method
• g) Payment card details
• h) Communication with you, including any photos you may provide (e.g., in case of complaints)

Providing personal data for contract fulfillment is a contractual obligation. Failure to provide such data may result in the inability to conclude the contract.

When making a purchase on the Yumraya.com web shop, we save the data you provide (primarily your name, shipping address, phone number, and email address) to make future purchases more convenient, so you don’t have to enter them again. Additionally, purchased products are saved in your "Favorites" list, allowing you to quickly find these items during your next visit to Yumraya.com.

If you wish to access your order history, you can set up a password under your emails.

Legal Basis: The legal basis for processing this data is the performance of the contract with you, compliance with our legal obligations, and the protection of our legitimate interests—primarily documenting key aspects of our contractual relationship with you.

6.3. Creating a Customer Account

When you create a password-protected customer account on the Yumraya.com webshop or use an account created by us, we process the personal data you provide through your account. This includes your purchase history within the webshop. The data is processed to manage your customer account, compile a list of favorite products for future purchases, and personalize the website content to make your shopping experience more convenient and efficient (see section 1.9 Customizing Webshop Content).

Legal Basis: The legal basis for this data processing is the performance of the contract with you.

6.4. Sending Commercial Communications (Newsletters)

When you become our customer, we are entitled to use your name, surname, email address, and phone number to send you newsletters electronically (via email, SMS, and other electronic channels such as, but not limited to, push notifications, instant messages, Viber, WhatsApp, Facebook Messenger). This is to inform you about the goods and services we offer unless you opt out under the exceptions provided by Act XLVIII of 2008 on the Basic Requirements and Certain Restrictions of Commercial Advertising Activities.

With your consent, we may prepare promotional offers tailored to the categories of products you have previously purchased from us. In this case, we will send newsletters to your email address regarding our products, services, and those of our partners, considering your purchase history and preferences to better meet your needs.

You may withdraw your consent, refuse, or modify your subscription preferences at any time via your customer account settings or by sending an email to info.yumraya@gmail.com. You can also unsubscribe from newsletters by clicking the links provided in the emails.

We may also contact you with information about our offers, news, and discounts, or other commercial communications:

• a) By postal mail
• b) By phone

Please let us know if you do not wish to receive commercial communications from us via phone or postal mail.

Legal Basis: The legal basis for this data processing is your consent and our legitimate interest in promoting the sale of our goods and services to our customers.

6.5. Satisfaction Surveys

If you complete a satisfaction survey, market research questionnaire, or product feedback form, we process the data provided to improve the quality of our services. The completed satisfaction survey will be linked to your order details. Participation in these surveys is entirely voluntary.

Legal Basis: The legal basis for this data processing is your consent, as it results from your voluntary feedback.

6.6. Recording Phone Calls

When you communicate with us by phone, all calls are recorded for quality assurance purposes. The recordings are stored in our internal system and, if you are a registered customer, linked to your customer account. Call recordings primarily serve to document the fulfillment of contractual obligations, address your requests, and respond to your questions.

If you do not consent to the recording of calls, please refrain from calling us and instead contact us via email.

Legal Basis: The legal basis for this data processing is our legitimate interest, primarily the documentation of essential aspects of our contractual (or other) relationships.

6.7. Sale of Alcohol

When you purchase products containing alcohol, we are legally obligated to verify your age to ensure that alcohol is not sold to individuals under 18 years of age. Upon delivery of alcohol-containing purchases, the courier is required to request proof of age by checking the recipient's identification.

To confirm compliance with age verification for regulatory authorities, the courier will record the following in our internal system:

• Name and surname
• Date of birth
• The last four digits of the identification card number (we do not process the full ID number)

Legal Basis: The legal basis for this data processing is the fulfillment of our legal obligations.

6.8. Marketing Analysis and Statistics

With your consent, we process the personal data you provide on Yumraya.com, including your purchase history, for marketing analysis and statistical purposes. Providing consent is voluntary, and you are under no legal obligation to grant it. You may withdraw your consent at any time, and withdrawal will not affect the legality of data processing carried out before the withdrawal.

Legal Basis: The legal basis for this data processing is your consent.

6.9. Customizing the Content of the Yumraya.com Webshop

The Yumraya.com webshop uses your customer account number and purchase history to display personalized content. Personalized content simply means that your favorite products will appear at the top of each product category to make shopping easier.

The purpose of this data processing is to enable purchases with as few clicks as possible.

Please note that this personalized content feature is an integral part of the Yumraya.com webshop service, designed to ensure a seamless shopping experience. It is not intended for marketing activities, distributing advertisements, or encouraging the purchase of specific products.

Legal Basis: The legal basis for this data processing is the performance of the contract with you.

7. Processing of Personal Data to Customize Our and Our Partners' Advertisements to Your Preferences

If you consent to the use of your data (see specific usage details below) for tailoring our and our partners' advertisements to your interests, you enable us to display ads that we believe may interest you. This consent is referred to as "marketing consent."

If you provide us with marketing consent, we will target and evaluate the success of our campaigns based on the analysis of your behavior using pseudonymized data. With your consent, we may also use a unique identifier (user ID) to track your behavior across different websites, browsers, or devices.

Please note that providing marketing consent is entirely voluntary, and not giving your consent will not affect our business relationship in any way.

7.1. What Personal Data Do We Use in Connection with Marketing Consent?

The specific data used for more accurate ad targeting and customization depends on how the advertisement is targeted/personalized. In most cases, the following categories of personal data are used:

• Location Data: Primarily used to create geographic target groups.

• Purchase and Webshop Usage Data: Information about your past purchases, use of our webshop, favorite product categories, preferences for special offers, purchasing frequency, average order value, and whether you shop via our website. This data helps create interest and behavior-based target groups.

Additionally, to evaluate the success of campaigns, we process data on reactions to displayed ads (e.g., clicks, conversions in the webshop).

We use pseudonymized data for ad targeting and customization. Pseudonymization is the processing of personal data in such a way that the data can no longer be linked to a specific individual without additional information, which is stored separately with appropriate technical and organizational measures to prevent unlawful association with an individual.

7.2. How Do We Obtain Marketing Consent?

You can decide whether to give marketing consent through banners or pages on our webshop by selecting the active "Yes" or "No" fields. Once you make your decision, the banner will disappear. If you do not give your consent, we will offer you the opportunity to reconsider after 30 days from the rejection. From then on, it’s entirely up to you. If you change your mind at any time, you can modify your settings as described below.

7.3. Where Can You Modify Your Marketing Consent Settings?

You can manage (grant or withdraw) your marketing consent at any time in your profile center on Yumraya.com.

7.4. How Long Do We Use Personal Data Based on Marketing Consent?

If you give your marketing consent, we will process your personal data for the duration of the consent (i.e., until you withdraw it).

Please note that if you provide marketing consent, we will process the full range of data we hold about you from the start of our business relationship (see the categories above).

7.5. Who Has Access to Your Personal Data?

Your personal data is processed by us, as the data controller. The data controller is Yumraya.com, operated by Yumraya Kft. We only disclose personal data to authorized employees and collaborators, as well as individual contractual data processors or other data controllers, to the extent necessary for the specific purposes and based on appropriate legal grounds for data processing.

Such parties may include:

• a) External accounting firms;

• b) Contracted suppliers, couriers;

• c) External law firms;

• d) Third parties providing server, web, marketing, or IT services.

8. Duration of Personal Data Processing

We process your personal data as long as we provide services to you, fulfill a contract, or as required to meet archiving or other legal obligations (e.g., obligations under the Tax Administration Act, Accounting Act, or VAT Act).

After fulfilling the contract (payment of the purchase price and delivery of the goods), we will continue to process your personal data for the necessary period to protect our legitimate interests and claims, but no longer than 4 years.

Personal data processed based on your consent will be processed until the consent is withdrawn. To withdraw your consent, please send an email with your request to info.yumraya@gmail.com.

8.1. Customer Account

We process personal data related to your customer account, including the data contained therein, for the purpose of managing the customer account as long as the account is active.

We process this personal data for the purpose of sending offers related to our products until you delete your account or refuse to receive our offers. If you create a customer account but do not make a purchase, we will process the data for 5 months from the date of creation.

We retain purchase-related data in your customer account for 4 years and delete it thereafter, unless:

• you have made a purchase from us in the past 6 months; or

• you have logged into your customer account within the past 12 months; or

• you have consented to the processing of your personal data.

8.2. Age Verification

We retain personal data necessary for age verification when selling alcoholic beverages for 4 years from the date of your last purchase of alcoholic beverages.

8.3. Sending Newsletters and Other Commercial Communications

We process personal data for sending commercial communications (newsletters) based on legitimate interest during the duration of our contractual relationship and for up to 12 months after its termination, or until you refuse data processing.

We process personal data for sending commercial communications based on your consent for as long as your consent is provided. You may refuse the processing of your personal data for commercial communication purposes at any time. You can unsubscribe from newsletters by clicking the link in the newsletters or by sending an email to info.yumraya@gmail.com.

 

9. COOKIES AND SOCIAL MEDIA

Cookies are small text files containing brief data that can be stored on a user's device when visiting a website. We use cookies on the Yumraya.com e-shop for the following purposes:

• remembering logged-in users;

• adding items to the cart and placing orders;

• convenient web functionalities;

• anonymized evaluation of user web activity;

• customer chat;

• voluntary user feedback collection; and

• personalization of advertisements.

All personal data is processed lawfully and transparently; we only require data relevant and necessary for the purpose of data processing. Further information is available in the cookie management policy here.

9.1. Third-Party Cookies

We also use cookies in the Yumraya.com webshop to ensure you receive information aligned with your interests (including on third-party websites).

We use third-party cookies from:

• Google Analytics advertising features beyond basic analytics;

• Additional Hotjar services for website optimization;

• Adform for displaying relevant ads, improving campaign performance reports, or preventing the same ad from appearing multiple times;

• Facebook marketing services to display ads to website users when visiting Facebook or other sites using these tools.

9.2. Cookie Settings

You can manage cookies in your browser settings, allow or refuse them, or set preferences for specific cookies. Instructions for the most common browsers are available on their respective websites:

• Google Chrome

• Firefox

• Microsoft Internet Explorer

• Opera

• Microsoft Edge

9.3. Social Media Feedback Buttons

Social media buttons on the Yumraya.com webshop are primarily for potential interaction with social media, making the e-shop more engaging for you as a user. A connection with the respective social media platform is only established if you actively click on the button. In such cases, your web browser will initiate a connection with the social media servers.

 

10. YOUR RIGHTS REGARDING PERSONAL DATA PROCESSING

You have the following rights concerning the processing of your personal data:

• the right to access personal data;

• the right to rectification;

• the right to erasure ("right to be forgotten");

• the right to restrict processing;

• the right to object to processing; and

• the right to file a complaint regarding personal data processing.

Below, we describe your rights to give you a clearer understanding of their content. To exercise your rights, send an email to info.yumraya@gmail.com. You may also submit a complaint to the National Authority for Data Protection and Freedom of Information (https://naih.hu).

10.1. Right of Access

You may request confirmation from us at any time regarding whether we are processing your personal data, the purpose and extent of such processing, whether data is shared, how long we process it, the source of the data, and whether automated decision-making, including profiling, occurs.

You also have the right to receive a copy of your personal data, with the first copy provided free of charge. We may charge a reasonable administrative fee for additional copies.

10.2. Right to Rectification

You may request the correction or completion of your personal data at any time if it is inaccurate or incomplete.

10.3. Right to Erasure

We must delete your personal data if:

• it is no longer necessary for the purpose it was collected or processed;

• the processing is unlawful;

• you object to the processing, and there are no overriding legitimate grounds for processing; or

• we are legally obligated to do so.

10.4. Right to Restrict Processing

Until issues related to the processing of your personal data are resolved, we must restrict the processing so that it is only stored and used for legal claims, enforcement, or defense purposes.

10.5. Right to Object

You may object to the processing of your personal data for direct marketing or based on legitimate interest. If you object to direct marketing, we will no longer process your personal data for this purpose.

 

11. FINAL PROVISIONS

Information about the effectiveness and changes to the privacy policy, as well as the contact details of the data protection officer.

If you need clarification on any part of this notice, advice, or to discuss the further processing of your personal data, please contact us anytime at info.yumraya@gmail.com.

 

12. SCOPE OF THE PRIVACY NOTICE

This Privacy Policy is effective from February 12, 2025, and is continuously updated.

Last updated: February 12, 2025.