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Privacy Policy and Cookies


- on the processing of personal data regarding newsletter subscriptions - 

Conscious Luxury Kft.. (the “Company” or “Controller”) is processing the personal data of individuals visiting the website  in connection with the provision of the functions and services of the sites and with the marketing activities of the Company on Perpetua Europa Websites.

The aim  of  this  privacy  notice  (the  “Privacy Notice”)  is  to provide  you,  as  the  subject  of  the  data  processing  with information  about  processing  of  your  personal  data  and  about  your  data  privacy  rights  in  connection  with  such processing activities in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (the “GDPR”) and according to Act CXII of 2011 on Informational Self-determination and Freedom of Information (the “Data Protection Act”).


1. Details of the Data Controller and the Data Protection Officer 

The controller of the personal data is Conscious Luxury Kft, with a registered address on 1097 Budapest, Hungary, Vágóhíd utca 3. C. ép. 2. Em, and registration number 01-09-396727 before the Budapest Court of Registration.

The email address of the contact person designated for managing and responding to inquiries and requests by data subjects is: 

You may contact the Controller directly via the above email address to exercise your data privacy rights. 


2. Scope of personal data processed and the purpose of data processing 

Contact information (e-mail address), to be able to send newsletters to the subscribers;
Name, gender to address the subscribers;
Month and day of birth to send birthday wishes;
Country, city, interest ("jewelry" or "engagement ring") and gender to segment the subscribers and send only relevant information. 


3. The legal basis for data processing 

The data will be processed in accordance with your voluntary, informed statement, which contains your express consent to the processing of your personal data provided during the subscription to the newsletter. The legal basis for data processing is Article 6 (1) (a) of GDPR. Consent is voluntary and you have the right to withdraw it at any time. Withdrawal of consent shall not affect the lawfulness of any previous processing of data with consent. You have the right to object to the processing of data for direct business purposes. 


4. Recipients of personal data

For the purpose of operating the website and managing the newsletter database, the Data Controller transfers personal data to the Data Processor (Conscious Luxury Kft.,


5. The duration of data processing

Until the withdrawal of the consent to the data processing. 


6. Your rights and remedies

You can request information about the processing of your personal data and access the data, as well as request the rectification or erasure of personal data, except for certain types of data processing, you can exercise your right to data portability and right to object in the manner indicated at the time of data collection or at the above contact details of the data controller.

Upon request, the information shall be provided in electronic form without delay and at the latest within one month. Your requests for the fullfilment of your rights are fulfilled by the Data Controller free of charge.

Right to information:
The Data Controller shall take appropriate measures to provide the data subjects with all information concerning the processing of personal data referred to in Articles 13 and 14 of the GDPR and Articles 15 to 22 and provide all the orientation referred to in Article 34 in a concise, transparent, comprehensible and easily accessible form, in a clear and comprehensible manner, but also in a precise way. 

Right of access:
You have the right to access your personal data (receive a copy) and to receive feedback from the Data Controller as to whether your personal data is being processed. If personal data is being processed, you have the right to access the personal data and the following information in the list.

• the purposes of processing;
• the categories of personal data concerned;
• the recipients or categories of recipients to whom or with whom the personal data have been or will be disclosed, including in particular recipients in third countries (outside the European Union) or international organizations;
• the planned duration of the storage of personal data;
• the right to rectify, erase or restrict data processing and to protest;
• the right to lodge a complaint with the supervisory authority;
• information on data sources; the existence of automated decision-making, including profiling, and meaningful information on the logic involved and the significance of such data management and the envisaged consequences for the data subject. 

Right to rectification:
In accordance with the law, you may request the rectification of inaccurate personal data concerning you processed by the Data Controller and the supplementation of incomplete data.

Right to erasure:

You have the right to have your personal data erased without undue delay at your request for any of the following reasons:
• the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• you withdraw the consent on which the data processing is based and there is no other legal basis for the data processing;
• you object data processing and there is no overriding legitimate reason for the data processing;

• unlawful processing of personal data can be established;
• the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject
• personal data have been collected in connection with the provision of information society services. 

Erasure of data may not be initiated if the data processing is necessary for the following purposes:
• to exercise the right to freedom of expression and information;
• for compliance with a legal obligation which requires processing by Union or Member State law to which the 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 controller;
• in the field of public health, or for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes
for the establishment, exercise or defence of legal claim 

Right to restrict data processing:
Upon request, data processing may be restricted under the conditions set out in Article 18 of the GDPR:
• 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 and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
• the Data Controller no longer needs the personal data for the purpose of data processing, but you request them for the establishment, exercise or defence of legal claims;
• You objected to the data processing; in that case, the restriction shall apply for as long as it is established whether the legitimate reasons of the controller take precedence over the legitimate reasons of the data subject.
Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defence 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. The data subject shall be informed by the Data Controller before the restriction of processing is lifted. 

Right to data portability:
He shall have the right to receive the personal data concerning him which he has made available to the controller in a structured, widely used machine-readable format and to transmit this data to another controller. The Data Controller can fullfil such a request of the data subject in MS Word or Excel format. The right to data portability is conditional on the data processing being automated and based on a consent or contract. 

Right to object:
If personal data are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning them for this purpose, including profiling, insofar as it relates to direct marketing. In the event of an objection to the processing of personal data for the purpose of direct marketing the data may not be processed for this purpose. You have the right to object if the processing is based on the legitimate interest of the controller, but in this case the consideration of the request will be considered, depending on which party's rights take precedence under Article 21 (1) GDPR. 

Right of withdrawal:
You have the right to withdraw your consent at any time. Withdrawal of consent shall not affect the lawfulness of the data processing based on consent before its withdrawal. 

Rules of procedure: 

The Data Controller shall, without undue delay, but in any case within one month from the receipt of the request, inform the data subject of the action taken on the request. If necessary, taking into account the complexity of the application and the number of applications, this time limit may be extended by a further two months. The Data Controller shall inform the data subject about the extension of the deadline, indicating the reasons for the delay, within one month from the receipt of the request. 

If you have submitted the application electronically, the information is provided electronically, unless the data subject requests otherwise.
If the Data Controller fails to take action on the data subject's request, it shall inform the data subject without delay, but no later than one month after receipt of the request, of the reasons for delay and of the data subject's complaint to the supervisory authority. 

The Data Controller shall inform all recipients to whom it has disclosed personal data about any rectification, erasure or restriction on the processing of personal data, unless proves impossible or requires a disproportionate effort. At your request, the Data Controller will inform these recipients. 

If you believe that your rights have been violated, you can file a complaint at the Data Controller (at the contact details according to point 1), where your request or complaint will be treated confidentially and you will not be disadvantaged as a result. In addition, you have the right to complain directly to the competent authority: 

Hungarian National Authority for Data Protection and Freedom of Information 

Mailing address: 1363 Budapest, Pf. 603. Address: 1055 Budapest, Falk Miksa utca 9-11. Phone: +36 (1) 391-1400

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