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Privacy Policy

Effective date: 25 January 2026

This Privacy Policy applies to the data processing activities of the
https://www.flinkproduct.com/
online store (hereinafter referred to as the “Website”).
The operator of the Website and the data controller is:

1. Data Controller Details

  • Company name: Cívis-Therm Ltd.
  • Registered office: 4030 Debrecen, Veker u. 3., Hungary
  • Contact person: Zoltán Konyári
  • Tax number: 12420106-2-09
  • Phone: +36/20-269-2370
  • Email: flinkproduct@gmail.com

2. Definitions

  • Personal data: any information relating to an identified or identifiable natural person.
  • Data subject: the natural person whose personal data is processed.
  • Processing: any operation performed on personal data (e.g. collection, storage, use, transmission).
  • Processor: a party that processes personal data on behalf of the data controller.

3. Principles of Data Processing

Personal data is processed in accordance with applicable legislation,
in particular Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR)
and relevant Hungarian laws.
Data is processed lawfully, fairly and transparently, only to the extent necessary,
and for no longer than required for the stated purposes.

4. Data Processing Activities

4.1. Orders and Contract Performance

Scope of processed data: name, email address, phone number, billing and shipping address, order details (products, quantity, payment method), invoice data, communication content.

Purpose of processing: order handling, confirmation, contract performance, invoicing, delivery, customer service.

Legal basis: GDPR Article 6(1)(b) (performance of a contract) and Article 6(1)(c) (legal obligation, e.g. accounting).

Retention period: until the limitation period of contractual claims, and for accounting documents typically 8 years as required by law.

4.2. Contact and Customer Service

Scope of processed data: name, email address, phone number, message content, order ID (if provided).

Purpose of processing: responding to inquiries, complaint handling, communication.

Legal basis: GDPR Article 6(1)(f) (legitimate interest – customer service operation) or Article 6(1)(b) if related to a contract.

Retention period: for a reasonable period after closing the inquiry, typically 1–3 years; complaints are retained as required by law.

4.3. User Account / Registration (if available)

Scope of processed data: name, email address, password (stored in encrypted/hashed form), order history, saved billing/shipping details.

Purpose of processing: providing a user account, faster checkout, order history management.

Legal basis: GDPR Article 6(1)(b) (contract) and Article 6(1)(a) (consent) for optional data.

Retention period: until account deletion; certain data may be retained longer due to legal obligations.

4.4. Newsletter (if available)

Scope of processed data: email address, name (if provided), subscription-related technical data (date, IP address).

Purpose of processing: sending marketing messages, promotions and news.

Legal basis: GDPR Article 6(1)(a) (consent).

Retention period: until unsubscription or withdrawal of consent.

Unsubscription: via the unsubscribe link in each newsletter or by contacting us directly.

4.5. Cookies and Logging

The Website uses cookies to ensure proper operation, improve user experience,
and for statistical and marketing purposes (if enabled).

  • Strictly necessary cookies: required for core website functions (e.g. cart, session management).
  • Statistical cookies: to analyze traffic and improve services.
  • Marketing cookies: to display personalized offers and advertisements.

Legal basis: legitimate interest (GDPR Article 6(1)(f)) for strictly necessary cookies,
and consent (GDPR Article 6(1)(a)) for all other cookies.

Cookies can be managed or disabled in the browser settings.
Please note that disabling certain cookies may affect website functionality.

5. Data Processors and Data Transfers

For operating the Website, we may use external service providers (data processors)
who process personal data solely on our instructions and to the extent necessary.

Typical categories of data processors:

  • hosting and IT service providers
  • payment service providers
  • courier and delivery services
  • invoicing and accounting service providers
  • analytics and marketing service providers (if used)

Data transfer to third countries: where applicable, such transfers are carried out only
with appropriate safeguards in accordance with the GDPR (e.g. adequacy decisions, standard contractual clauses).

6. Data Security

We implement appropriate technical and organizational measures to protect personal data,
including access control, password protection, encrypted communication (HTTPS),
logging and regular updates.
However, internet-based data transmission cannot be guaranteed to be completely secure.

7. Rights of Data Subjects

You have the following rights under the GDPR:

  • Right to information and access to personal data
  • Right to rectification of inaccurate data
  • Right to erasure (“right to be forgotten”)
  • Right to restriction of processing
  • Right to data portability
  • Right to object to processing based on legitimate interest
  • Right to withdraw consent at any time (where processing is based on consent)

Requests can be submitted using the contact details above.
We will respond without undue delay, and no later than within one month.

If you believe that your personal data has been processed unlawfully,
you have the right to lodge a complaint with a supervisory authority
or seek judicial remedy.

Supervisory authority: National Authority for Data Protection and Freedom of Information (NAIH)

Website: naih.hu

Address: 1055 Budapest, Falk Miksa utca 9-11., Hungary

9. Automated Decision-Making and Profiling

The Website does not typically use automated decision-making that would have legal
or similarly significant effects on you.
If profiling is used for marketing purposes, it is carried out only with proper information and consent.

10. Amendments to This Policy

We reserve the right to amend this Privacy Policy.
Amendments take effect upon publication on the Website.
Please review this policy periodically.

Contact

Legal notice: This document provides general information only.
Depending on the actual operation of the online store (payment providers, couriers,
newsletters, analytics, remarketing, invoicing systems, cookie banner settings, etc.),
further customization may be required.

When designing the product, our goal was to create a dog house with unique features that is able to provide a comfortable space for dogs using only renewable geothermal energy, in a self-sustaining and fully autonomous way. During the design process, key considerations included sustainability, simplicity, and creating a durable, long-lasting construction.