We hereby inform you that our Company, MrCoin Ltd. (96 Kensington High Street, London, W8 4SG, United Kingdom- www.mrcoin.eu) and its cooperating partner, Shinrai Kft. (phone: +36 16 555 333, address: 1025 Budapest, Vérhalom utca 40., Hungary (hereinafter collectively referred to as MrCoin.eu or MrCoin) operate their special Internet kiosk terminals (Bitcoin ATMs) in the customer service areas of DOBLO Wine Bar (H-1072 Budapest, Dob u. 20.) and Virpay Pénzforgalmi Szolgáltató Kft. (H-9200 Mosonmagyaróvár, Szent István király út 49.).
We hereby inform you that we conduct recorded camera video surveillance in those rooms, whereby, in respect of images taken of you, MrCoin together with Virpay Kft. with respect to the terminal located in Mosonmagyaróvár, qualify as joint (multiple) data controller.
By entering the premises, customers acknowledge and accept the fact of camera surveillance and expressly permit the taking of footage featuring. In compliance with our obligation as controller, we have placed a sign notifying customers of the existence and the operation of the surveillance system, which provides clear information to the persons using the services that the area has an electronic surveillance and recording system of cameras in operation.
The locations of the cameras and the target areas they monitor:
Budapest - DOBLO Wine Bar:
Camera 1 (above the terminal): records video of the terminal user interface and the customer from above
Camera 2 (opposite the terminal on the wall) : records video of the terminal user interface and the customer from the front
Mosonmagyaróvár - Virpay Kft. customer service office:
Camera 1 (above the entrance door on the right): street front – records video of customers entering the customer area
Camera 2 (above the entrance door on the left): street front – records video of customers entering the customer area
Camera 3 (on the corner of the building next to the entrance door): video of the street front area perpendicular to the entrance door – records video of customers entering the customer area
Camera 4.: record video of the terminal user interface and the customer from the back
The objective of our data processing is the protection of human life, bodily integrity and personal freedom, protection of business, payment, bank and security secrets, asset protection; and the detection of associated illegal actions (fraud, abuse, other criminal offences), catching perpetrators in the act, and the prevention and/or proof of illegal actions.
The legal basis for our data processing is MrCoin’s rightful interest in achieving the above objectives, and the legislative authorisation granted in Article 31, paragraph (1) of Act CXXXIII of 2005 on the regulations governing personal and asset protection and private investigation services (hereinafter the PPIA).
Range of data processed: video footage of persons entering and spending time in the customer service areas, and of their conduct in the customer service areas.
Period for which video footage is retained: the recorded footage (unless used in official or court proceedings or the person concerned requests that it be retained) shall be deleted in compliance with Article 31, paragraph 4 of the PPIA, after 60 days from the date of recording.
Persons authorised to view the recordings: in case of suspected illegal conduct or extraordinary events: the operative management of MrCoin; in case of complaints or protest, the internal data protection officer; and in case of queries from authorities or courts of law, the person acting on behalf of the organisation submitting the query, and in case of the terminal operated on the customer service premises of Virpay Pénzforgalmi Szolgáltató Kft. in Mosonmagyaróvár, the operative management of MrCoin through the banking security officer of Virpay Pénzforgalmi Szolgáltató Kft.
The recordings are protected by a password and high grade encryption in a protected, limited access separate IT system whose servers are also in a physically separated, locked room. The system of cameras monitoring the terminal at the DOBLO Wine Bar is operated by MrCoin itself, while the terminal in Mosonmagyaróvár is monitored by cameras operated and managed by Virpay Kft., our company is entitled to access those recordings under the tenancy and cooperation agreement in effect between the parties.
The recordings are only disclosed to third persons in response to queries from the authorities or courts of law.
You, as data subjects, are entitled to so-called rights of data subjects. In relation to that we hereby inform you as follows.
As a data controller, we do everything we can in order to ensure that your rights associated with the processing of your personal data, detailed below, are not infringed.
As a data controller, we shall provide an opportunity for you to submit requests associated with the exercise of your data subject rights by mail, by e-mail or by telephone.
As a data controller, we must comply with your request without any undue delays, and in any case no later than 30 days from the receipt of the request, and we shall provide you information about it in a concise, transparent, intelligible and easily accessible form. If we reject your request, we shall also reach a decision within the same deadline and inform you of the rejection of your request, of our reasons for that, and the legal remedy you are entitled to in relation to the matter.
By default, we shall comply with your request by email, but if you specifically request it and provide your mailing address or telephone number, we shall also perform requests by mail or by telephone. Telephone information can only be provided at your request if you establish your identity.
We shall not charge a fee or costs for complying with your request. However, if a second request is received for the same range of data within one year of a previous, already completed request, we reserve the right to charge costs proportional to the workload involved in compliance with the request.
Right to information and access to personal data:
At your request we shall provide the following information in a concise, transparent, intelligible and easily accessible form:
- Whether we are processing your personal data;
- Our name and contact information;
- Of the data processing, the names and contact information of our data processors;
- Your personal data that we process and their sources;
- The objective and the legal basis of processing your personal data;
- The period of data processing;
- The addressees or categories of addresses to whom or which we have communicated or will communicate your personal data, with particular regard for addresses in third countries and international organisations;
- The consequences of data processing;
- Your rights; and
- The circumstances and impacts of any data breach and the measures taken to remedy it.
Through our website, we shall provide information to you about any material changes in data processing relative to the content of the present document, and the circumstances and impacts of any data breach and the measures taken to remedy it.
Use the following contact information to request written information from MrCoin.eu about video footage containing images of you. Contact details: email address: [email protected], website URL: www.mrcoin.eu, telephone no.: +36 16 555 333, mailing address: 1025 Budapest, Vérhalom utca 40., Hungary.
Right to erasure:
At your request, we shall erase your personal data provided any of the following conditions apply:
- your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- the data subject withdraws consent;
- the data subject objects to the processing;
- the personal data have been unlawfully processed; and
- the personal data have to be erased for compliance with a legal obligation in EU or Hungarian law.
We shall inform all addressees to whom we have communicated personal data of the erasure, unless this proves impossible or would require a disproportionately large effort. At your request, we shall inform you of such addressees.
Right to restriction of processing:
At your request, we shall restrict processing where one of the following applies:
- the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
- the processing is unlawful, but you oppose the erasure of the personal data and request the restriction of their use instead;
- we no longer need the personal data for the purposes of the processing, but you require them for the purpose of establishment, exercise or defence of legal claims.
We shall inform all addressees to whom we have communicated personal data of the restriction, unless this proves impossible or would require a disproportionately large effort. At your request, we shall inform you of such addressees.
Right to legal remedy:
Legal remedies available to you: if you disagree with the decision of MrCoin.eu concerning your request for correction, restriction or erasure or your objection, or if MrCoin.eu fails to comply with the deadlines specified above, you may lodge a complaint with a court of law within 30 days of the communication of the decision, or the day on which the deadline expires. You may also lodge a complaint with a court of law if your rights are infringed, in particular if requests for information are denied.
You may initiate an investigation by lodging a complaint – referencing an infringement of rights associated with the processing of personal data or the rights associated with gaining access to data in the public interest or data that are public in the interest of the public, or a direct risk thereof – to the supervisory authority, namely the National Authority for Data Protection and Freedom of Information (hereinafter the NAIH), at 1125 Budapest, Szilágyi Erzsébet fasor 22/c., Hungary, mailing address: H-1530 Budapest, Pf.:5, email: [email protected]).
We undertake to cooperate with the court of law involved and the NAIH in all particulars and that we shall provide the data concerning the data processing to the court of law involved or to the NAIH.
We undertake to provide compensation for any damage you incur as a result of our unlawful processing of your personal data or our infringement of data protection requirements. If your privacy rights are infringed, you shall be entitled to damages. We shall be exempt from liability if the damage is caused by a factor outside the scope of data processing that could not have been averted, and if the damage or the infringement of privacy rights is the result of the wilful and grossly negligent conduct of the data subject.
We request and recommend that, prior to launching an official or court procedure, you should exercise your right to lodge an objection or a complaint with MrCoin.eu.
You can find our detailed Data Processing Regulations produced for our customers, which also covers our data processing associated with the use of the electronic surveillance system, on our company website (www.mrcoin.eu).
Budapest, 25 May 2018