GENERAL TERMS AND CONDITIONS

1. Introductory provisions

1.1. PBT Hungary Kft. (hereinafter referred to as the Service Provider) sets out in these General Terms and Conditions (hereinafter referred to as the Terms and Conditions or GTC) the terms and conditions applicable to the sale of products and the use of related services provided through the Hungarian-language online stores available under the domains https://vivas.hu and https://shop.pbtfencing.hu, as well as through the international online store available under the domain https://pbtfencing.com. These Terms and Conditions also regulate the rights and obligations of the Service Provider and the person entering into or intending to enter into a contractual relationship with the Service Provider (hereinafter referred to as the Customer or Buyer).

1.2. Before placing an order in the Service Provider’s online store, the Customer shall confirm, by ticking the designated checkbox on the website, that they accept these Terms and Conditions, are aware of the ordering process, have reviewed these Terms and Conditions prior to placing the order, and accept their content. The Customer may not proceed with placing an order without opening the linked Terms and Conditions and becoming acquainted with the content of the documents.

1.3. The Service Provider and the Customer enter into a sales contract, which shall be governed by the laws of Hungary. The concluded contract shall qualify as a written contract; however, the Service Provider does not file or archive the contract, and the Service Provider is not bound by any code of conduct.

1.4. The Service Provider reserves the right to unilaterally amend the terms and conditions and rules applicable to purchases, in whole or in part, at any time, provided that such amendments shall not affect contracts already concluded or orders already placed retroactively. The Service Provider excludes liability, to the extent permitted by applicable law, for amendments to these Terms and Conditions. Amendments to these Terms and Conditions shall enter into force on the date specified therein following publication of the amended text on the website.

1.5. The details of the Service Provider:

Company name: PBT Hungary Kft.
Registered office: 1139 Budapest, Teve utca 9. Building D, Ground Floor, Door 6
Court of registration and company registration number: Company Registry Court of the Metropolitan Court of Budapest, 0109667141
Tax number: 12335990-2-41
MKEH registration number: C/003 550

Bank account details and group identification number:
Kereskedelmi és Hitelbank Zrt.

HUF account: HU67 10201006-50258040-00000000
EUR account: HU12 10201006-60192415-00000000

Customer contact address, telephone number, and e-mail addresses:

1139 Budapest, Teve utca 9. Building D, Ground Floor, Door 6

Telephone: +36-1-329-0683

pbtbolt@vivas.hu (for inquiries related to the Hungarian-language online store)

orders@pbtfencing.com (for inquiries related to the international online store)

Hosting service provider:

Company name: SiteFace Kft.
Registered office: 1034 Budapest, Szőlő utca 35. 2nd Floor, Door 10

1.6. These General Terms and Conditions shall enter into force on 23 July , 2026.

2. Ordering

2.1. Orders placed through our Hungarian online store may only be accepted for delivery addresses located within the territory of Hungary. Customers residing abroad may purchase products through our international online store, provided that there is no exclusive PBT representative operating in their country.

2.2. Registration is required for placing an online order. The registration must be activated before the first purchase. Activation can be completed by clicking on the link provided in the e-mail sent to the e-mail address provided during registration.

2.3. After logging in, select the desired products and any additional options or conditions relating to them. The selected products will be added to the virtual shopping cart.

2.4. At the end of the purchase process, please provide your billing and delivery address. As the next step, please select the payment method and proceed. After accepting the “General Terms and Conditions of Purchase”, you may finalize your order by clicking the “Confirm Order” button.

2.5. We will immediately confirm receipt of your order by e-mail.

2.6. During the ordering process, please always ensure that the appropriate sizes and quantities are selected.

2.7. The order cannot be paid immediately upon submission.

2.8. We will confirm receipt of your order without undue delay and will endeavour to confirm the fulfilment of your order (including payment conditions) by e-mail within 48 hours by adding the delivery costs to the total order value and informing customers qualifying as consumers of their statutory rights. If any questions arise in connection with the order, we will contact the Customer by telephone before issuing the confirmation. Orders placed on Fridays can be confirmed as capable of fulfilment at the earliest on the following Monday. If an official public holiday falls on the day following the order placement or on subsequent days, the confirmation will be provided within two working days following the end of the holiday period. In such cases, the Customer shall not be bound by their offer (i.e. by placing the order).

2.9. Orders placed through our Hungarian online store may only be delivered within Hungary via the DPD courier service and, upon request, via MPL (Hungarian Post). In the case of payment by bank card or bank transfer, the delivery fee is HUF 2,000 via DPD courier service and HUF 2,990 via MPL (Hungarian Post). In the case of cash-on-delivery payment, the delivery fee is HUF 2,700 via DPD and HUF 4,315 via MPL. Delivery is free for purchases exceeding HUF 40,000.

Unless otherwise requested by the consumer Customer, delivery of ordered products shall be carried out via the DPD courier service. Our additional delivery partner is MPL (Hungarian Post); therefore, consumer Customers may request delivery via MPL through our contact details, except where the specific product is excluded from MPL delivery (for example, due to the size of the product or pursuant to MPL’s General Terms and Conditions). Further information regarding MPL and parcel delivery is available at https://www.posta.hu.

Orders placed through our international online store may be delivered to destinations where the Service Provider does not have an exclusive brand distributor. International delivery fees are estimated individually after the order has been placed and are manually added to the order within a few days. Following this, the Customer may decide whether to proceed with the purchase or reject the order.

2.10. In the case of payment by bank card, payment may be completed immediately after receipt of the order confirmation. In the case of payment by bank transfer, we will send the Customer a pro forma invoice. Once payment has been received, we will begin preparing the order for dispatch. In the case of cash-on-delivery payment, we will issue and send the invoice together with the goods, including the total amount increased by the applicable delivery fee.

2.11. Following confirmation of the order, amendments can only be accepted if the package has not yet been closed for shipment. In the case of sizes not available from stock, changes may be requested until production has commenced.

2.12. The Service Provider shall not be liable in any form for errors, damages, or consequences arising from incorrectly or falsely provided information; all liability in this respect shall rest with the Customer (for example, incorrect delivery address, incorrect product quantity, or other incorrect product-related information).

2.13. PBT Fencing Shop reserves the right not to dispatch a package without prior telephone or e-mail consultation if any question arises in connection with the order.

3. Prices

3.1. The prices of products available for purchase through the website are displayed in Hungarian forints and include value added tax (VAT), but do not include delivery costs.

3.2. The prices of products available for purchase through the international website are displayed in euros. In the case of deliveries within the European Union, the prices include the VAT applicable in the country of delivery.

For countries outside the European Union, the prices do not include import duties or VAT payable upon importation. Such costs are determined in each case by the customs authorities of the relevant country and shall be paid locally by the Customer.

3.3. We reserve the right to modify the prices of products available for purchase through the website. Any modification shall enter into force simultaneously with its publication on the website. Such modifications shall not affect the purchase price of products already ordered.

3.4. If, despite exercising due care, an incorrect price is displayed in the online store, for example where the displayed price significantly differs from the commonly known, generally accepted, or estimated market price of the product, or where a price of “HUF 0” or “HUF 1” is displayed due to a system error, the Service Provider shall not be obliged to deliver the product at the incorrect price, where the error is clearly recognisable to anyone. In such cases, the Service Provider may offer delivery at the correct price, following which the Customer may decide whether to maintain their intention to purchase or withdraw from the purchase.

4. Delivery Terms

4.1. Our prices do not include delivery costs. Information regarding delivery costs is provided in the following sections.

4.2. Orders placed through our Hungarian online store may only be delivered within Hungary via the DPD courier service and, upon request, via MPL (Hungarian Post). In the case of payment by bank card or bank transfer, the delivery fee is HUF 2,000 via DPD courier service and HUF 2,990 via MPL (Hungarian Post). In the case of cash-on-delivery payment, the delivery fee is HUF 2,700 via DPD and HUF 4,315 via MPL. Delivery is free for purchases exceeding HUF 40,000 (forty thousand Hungarian forints).

Orders placed through our international online store may be delivered to destinations where the Service Provider does not have an exclusive brand distributor. International delivery fees are estimated individually after the order has been placed and are manually added to the order within a few days. Following this, the Customer may decide whether to proceed with the purchase or reject the order.

4.3. In the case of payment by bank card or bank transfer, we can only dispatch the order after payment has been received.

4.4. The dispatch date depends on the quantity ordered, any additional products included in the order, and the number of orders received prior to the relevant order.

4.5. We reserve the right to make partial deliveries where no other solution is available.

4.6. Delivery deadline: The processing period for orders (i.e. the deadline for assessing whether an order can be fulfilled) is generally 2 (two) working days. An order placed on the same day means an order received on working days no later than 10:00 a.m.; orders received after this time will only be processed on the following working day.

The contract between the parties shall be concluded when the Service Provider confirms to the Customer that the Customer’s order can be fulfilled and such confirmation is received by the Customer. Unless otherwise agreed by the parties, the Service Provider shall, following the conclusion of the contract, make the product available to the Customer (deliver the product) without undue delay, but no later than within thirty days.

The delivery period shall commence on the working day following the sending of the electronic confirmation e-mail to the Customer confirming receipt of payment for the order.

4.7. From the time the Service Provider hands over the package to the delivery company, the Service Provider shall not be liable for delivery taking place within the estimated timeframe specified in the confirmation e-mail. However, where necessary, the Service Provider shall use all reasonable efforts to ensure that the delivery company complies with the indicated delivery deadline.

4.8. Both Customers qualifying as consumers and Customers not qualifying as consumers (e.g. associations) are obliged to act in good faith and cooperate in the performance of the contract. Accordingly, they are required, without undue delay and in the presence of the courier, to verify whether the packaging of the delivered product is intact.

If significant damage is visible on the packaging, the Customer shall refuse acceptance of the package, request that the courier prepare an official damage report, and notify the Service Provider of the incident through any available contact channel.

If the Customer does not require the courier to prepare a damage report despite damaged packaging (crushed, dented, torn packaging), the Customer shall photograph the packaging on the day of receipt, open the package, and inspect the product (with regard to both quality and quantity conformity).

In such cases – i.e. where it is established that not only the packaging but also the product itself was damaged during delivery by the courier service – the Service Provider shall not accept any subsequent undocumented claims from non-consumer Customers regarding such damage under any circumstances (i.e. claims submitted without a damage report prepared by the courier or without photographic evidence taken by the Customer on the day of receipt).

The Customer shall also immediately notify the Service Provider if the courier company refuses to prepare a damage report. Business Customers shall provide such notification to the Service Provider in writing.

From 1 March 2026, the Service Provider also expects micro-enterprises, small enterprises, and medium-sized enterprises qualifying as consumers under Government Decree No. 151/2003 (IX.22.) on mandatory warranty applicable to certain durable consumer goods to comply with the above requirements.

4.9. The costs of re-delivery resulting from unsuccessful delivery due to the Customer’s fault shall in all cases be borne by the Customer.

4.10. The risk of damage shall pass to the Customer upon receipt of the Product. Accordingly, the Service Provider shall not be liable for defects or damage arising or occurring after receipt of the Product.

If the Customer fails to accept the Product for the second delivery attempt due to reasons attributable to the Customer, the package shall be returned to the Service Provider. The Service Provider shall thereafter cancel the issued invoice and refund the purchase price paid in advance to the Customer, less the costs incurred due to the unsuccessful delivery.

5. Payment

5.1. In the case of special sizes and individual requirements, an additional fee shall be charged, which will be automatically added to the purchase price. The Customer shall be informed of this additional charge in each case during the purchasing process and before placing the order.

5.2. Payment methods:

Payment by bank card: After entering the card details during payment and following confirmation by the bank, the amount due will be charged to the card. The virtual POS terminal operated by our bank accepts the following cards: Maestro bank cards issued by K&H Bank Zrt., as well as VISA Electron cards issued by any bank, embossed Visa cards, EC/MC cards, JCB cards, and internet payment cards.

Credit card security: When the Customer enters the section of the website where card details must be provided, the website redirects the Customer to a secure server. The URL displayed in the browser address bar will begin with https:// instead of the usual http://, indicating a secure internet connection. A padlock symbol will also appear in the browser window. These pages are guaranteed to be secure. There is no possibility for third parties to access the data entered during the payment process.

Cash on delivery: In this case, payment for the ordered products must be made to the delivery person upon receipt of the package. Please note that each delivery company may charge an additional fee for cash-on-delivery payment. The amount of this fee depends on the value of the ordered products.

5.3. Partial payments cannot be accepted.

6. Right of Withdrawal from the Purchase for Consumer Customers Who Are Natural Persons

6.1. A consumer Customer who is a natural person shall have the right to withdraw from a contract for the sale of goods without giving any reason:

in the case of a contract for the sale of one product, from the date on which the consumer or a third party designated by the consumer, other than the carrier, receives the product;

in the case of the sale of several products, where the products are delivered at different times, from the date on which the consumer or a third party designated by the consumer, other than the carrier, receives the last product;

in the case of a product consisting of several lots or pieces, from the date on which the consumer or a third party designated by the consumer, other than the carrier, receives the last lot or piece;

in the case of a contract for the regular supply of products over a specified period, from the date on which the consumer or a third party designated by the consumer, other than the carrier, receives the first product,

within fourteen (14) days.

The consumer may also exercise the right of withdrawal during the period between the date of conclusion of the contract and the date of receipt of the product.

6.2. Accordingly, if the Customer is a natural person consumer and changes their mind after placing the order, or does not accept the purchase price or delivery cost communicated in our confirmation of delivery, the Customer shall have the right to withdraw from the purchase.

In the case of payment by card, withdrawal may be exercised by notifying the Service Provider by sending a written notice to the Service Provider’s address or by calling +36-1-329-0683.

From 1 March 2026, a Customer qualifying as a micro-enterprise, small enterprise, or medium-sized enterprise and considered a consumer under Government Decree No. 151/2003 (IX.22.) on mandatory warranty applicable to certain durable consumer goods shall not be entitled to the right of withdrawal described in this Section 6, even though such Customer qualifies as a consumer for mandatory warranty purposes.

6.3. A natural person consumer Customer may withdraw from the purchase without giving any reason within fourteen (14) days following receipt of the goods. In such case, after the goods have been returned, the Service Provider shall refund the full amount paid by the Customer as consideration without undue delay, but no later than within fourteen (14) days from the date on which the Service Provider became aware of the withdrawal.

6.4. If the natural person consumer Customer wishes to exercise the right of withdrawal, the Customer shall provide the Service Provider with an unambiguous statement expressing the decision to withdraw, either by post or electronically (to pbtbolt@vivas.hu, or in the case of orders placed through the international online store, to orders@pbtfencing.com), using the contact details provided in the introductory provisions of these Terms and Conditions.

For this purpose, the Customer may also use the model withdrawal form entitled “Withdrawal Statement” available on the website and attached as Annex 1 to these Terms and Conditions.

In the latter case, the Service Provider shall immediately confirm receipt of the consumer’s withdrawal statement.

The Customer shall bear the burden of proving that the right of withdrawal was exercised in accordance with the conditions and within the applicable deadline.

A natural person consumer may also exercise the right of withdrawal personally at the Service Provider’s physical store in relation to an online purchase of a product that is also sold by the Service Provider in its store. In such case, the withdrawal statement may also be made orally and the product may be returned to the Service Provider at the store.

6.5. From 19 June 2026, the Customer may also exercise the right of withdrawal specified in these Terms and Conditions by using the online withdrawal function provided on the website.

The online withdrawal function is available on the website under [insert direct link or exact access path], under the title “Withdrawal from the Contract”. The online withdrawal function shall remain continuously available to the Customer in a clearly visible and easily accessible manner throughout the entire withdrawal period.

When submitting an online withdrawal statement, the Customer shall provide:

the Customer’s decision to withdraw from the contract;

the Customer’s name;

the information necessary to identify the contract or order concerned by the withdrawal, including in particular the order number; and

the electronic contact details to which the Customer wishes to receive confirmation of receipt of the withdrawal statement.

After providing the required information, the Customer may submit the online withdrawal statement to the Service Provider by using the function labelled “Confirm Withdrawal”.

The Service Provider shall, without undue delay, send an acknowledgement of receipt of the online withdrawal statement on a durable medium, primarily by e-mail to the electronic address provided by the Customer.

The acknowledgement of receipt shall contain the content of the withdrawal statement, as well as the date and exact time of submission.

The right of withdrawal shall be deemed exercised within the deadline if the Customer submits the online withdrawal statement before the expiry of the withdrawal period.

6.6. If the Customer has withdrawn from the contract, the Customer shall return the Product to the Service Provider without undue delay, but no later than within fourteen (14) days from the date of communicating the withdrawal.

The Product must be returned complete (including accessories, components, and full documentation), undamaged, clean, and, where possible, in its original packaging, or otherwise carefully packaged in a manner suitable for protecting the condition of the Product.

Where possible, we request that the Product be returned in its original box; however, in all cases the Customer shall use packaging suitable for preserving the condition of the Product. The Customer shall exercise due care when packaging the Product.

6.7. The return shall be considered completed within the deadline if the Customer sends the Product to the Service Provider before expiry of the applicable period.

The direct cost of returning the Product shall be borne by the Customer. The Service Provider shall neither arrange the return transport of the Product(s) nor bear the costs of such return.

The Service Provider shall not accept packages returned by cash on delivery.

6.8. If the Customer has properly withdrawn from the contract concluded with the Service Provider in accordance with these Terms and Conditions, the Service Provider shall refund the full amount paid by the Customer, including costs incurred in connection with performance of the contract, without undue delay, but no later than within fourteen (14) days from the date on which the Service Provider became aware of the withdrawal.

The refund shall be made using the same payment method used by the Customer for the original transaction. With the Customer’s express consent, the Service Provider may use another method of refund; however, the Customer shall not incur any additional fees as a result.

If the Customer expressly chooses a method of transport other than the least expensive standard delivery method offered by the Service Provider, the Service Provider shall not be obliged to reimburse the additional costs arising from such choice.

6.9. Pursuant to Government Decree No. 45/2014 (II.26.), the costs incurred in connection with returning the goods following withdrawal shall be borne by the Customer.

6.10. The return of the package (or the return of the product personally at the store in the case of an oral withdrawal statement made in person) may only be made to our store at the following address:

PBT Fencing Store
1139 Budapest, Teve u. 9/D.

6.11. PBT Hungary Kft. shall only be obliged to reimburse the full purchase price if the product is returned complete and without damage.

The Customer shall be liable for any reduction in the value of the Product resulting from use exceeding the handling necessary to establish the nature, characteristics, and functioning of the Product, and shall compensate the Service Provider for such reduction.

6.12. The Service Provider may withhold reimbursement until the Product has been returned by the Customer or until the Customer has provided unequivocal evidence that the Product has been returned.

6.13. The Customer shall not have the right of withdrawal in particular:

after the complete performance of a service (e.g. our painting service), if the Service Provider commenced performance with the Customer’s express prior consent and the Customer acknowledged that the right of withdrawal would be lost after complete performance of the service;

in respect of non-prefabricated products manufactured according to the consumer’s instructions or expressly requested by the consumer, or products clearly personalised for the consumer; this category may include, in particular, clothing or bags with personalised name inscriptions, custom-painted protective masks, and clothing manufactured according to individual measurements or specific individual requirements;

in respect of sealed products which, for reasons of health protection or hygiene, cannot be returned after opening following delivery;

in respect of products which, due to their nature, become inseparably mixed with other products after delivery.

7. Statutory Warranty for Lack of Conformity

7.1. In the event of defective performance by the Service Provider, the Customer may enforce statutory warranty claims against the Service Provider.

In contracts between a consumer and a business, the statutory warranty claim of a Customer qualifying as a consumer in relation to new (unused) products shall expire after two years from the date of performance. After the expiry of the two-year limitation period, the Customer may no longer enforce statutory warranty rights.

In contracts concluded with non-consumers, statutory warranty claims shall generally expire after one year from the date of performance.

The provisions of Act V of 2013 on the Civil Code (hereinafter: the Civil Code) applicable to consumers shall also apply to micro, small, and medium-sized enterprises acting outside the scope of their profession, independent occupation, or business activity.

7.2. In the case of used products, the Customer may only enforce warranty rights in relation to defects that exceed defects resulting from normal use and that arose independently of such normal wear and use.

For used products, the Service Provider provides a statutory warranty period of one (1) year to Customers qualifying as consumers, meaning that the Customer may enforce warranty claims within a limitation period of one year.

If a used product is defective (for example, due to an aesthetic defect) and the consumer Customer was informed of such defect at the time of purchase, the Service Provider shall have no liability in relation to that known defect.

7.3. The part of the repair period during which the Customer cannot use the product for its intended purpose shall not be included in the limitation period.

In respect of the part of the product affected by replacement or repair, the limitation period for the statutory warranty claim shall restart.

7.4. Information regarding statutory warranty rights:

Based on the statutory warranty claim, the Customer may, at their choice, request the following remedies in the order specified below:

repair or replacement, unless the selected remedy is impossible or would result in disproportionate additional costs for the Service Provider compared to another statutory warranty remedy; or

a proportionate reduction of the purchase price or termination of the contract if the Service Provider has not undertaken the repair or replacement, is unable to fulfil this obligation, or if the Customer’s interest in repair or replacement has ceased.

7.5. The Service Provider may refuse to bring the goods into conformity if repair or replacement is impossible or would result in disproportionate additional costs for the Service Provider, taking into account all circumstances, including in particular the value of the goods in a defect-free condition and the significance of the breach of contract.

The consumer may request a proportionate reduction of the consideration or terminate the sales contract in the cases specified in Government Decree No. 373/2021 (VI.30.) on the detailed rules applicable to contracts between consumers and businesses concerning the sale of goods, the supply of digital content, and the provision of digital services, in particular where:

the Service Provider has not carried out or has refused repair or replacement;

repeated defective performance has occurred;

the defect is of such seriousness that it justifies an immediate price reduction or termination of the contract; or

it is clear that the Service Provider will not bring the goods into conformity within a reasonable period of time or without causing significant inconvenience to the consumer.

For Customers not qualifying as consumers, the provisions of the Civil Code shall apply.

Termination of the contract due to an insignificant defect shall not be permitted.

If the consumer wishes to terminate the sales contract on the basis of defective performance, the Service Provider shall bear the burden of proving that the defect is insignificant.

7.6. The Customer may change from the selected statutory warranty remedy to another remedy. The Customer shall bear the costs caused by such change unless the change was justified by the conduct of the Service Provider or was otherwise reasonable.

7.7. The Customer shall notify the Service Provider of the defect without undue delay after discovering it. The Customer shall be liable for any damage resulting from delayed notification.

In the case of consumer contracts, a defect notified within two months from the date on which it was discovered shall be deemed to have been notified without delay.

In contracts between a natural person consumer and a business concerning the sale of goods, it shall be presumed, unless proven otherwise, that a defect discovered within one year from the date of performance already existed at the time of performance, unless this presumption is incompatible with the nature of the goods or the nature of the defect.

In the case of a micro, small, or medium-sized enterprise acting outside the scope of its profession, independent occupation, or business activity, the six-month presumption of defective performance under the Civil Code shall apply.

7.8. The Service Provider shall have no statutory warranty liability, product warranty liability, or guarantee obligation in respect of defects of which the Customer was aware at the time of conclusion of the contract, or defects arising after performance, in particular as a result of damage caused by the Customer, improper use, improper handling, or external influence.

8. Information on Product Warranty Liability Towards Consumer Customers

8.1. In the event of a defect in a product sold by the Service Provider to the Customer, the Customer may request the manufacturer to repair the defect of the product or, if repair cannot be carried out within an appropriate period of time without adversely affecting the interests of the consumer, to replace the product.

A product shall be considered defective if it does not comply with the quality requirements applicable at the time it was placed on the market by the manufacturer, or if it does not possess the characteristics described by the manufacturer.

For the purposes of product warranty liability, the manufacturer shall include both the producer of the product and the distributor of the product.

8.2. The Customer may enforce statutory warranty claims and product warranty claims simultaneously and in parallel in respect of the same defect.

However, if the Customer successfully enforces a product warranty claim, the Customer may thereafter enforce a statutory warranty claim in relation to the replaced product or the part of the product affected by the repair against the manufacturer.

In the case of enforcing a product warranty claim, the Customer shall bear the burden of proving the defect of the product.

The Customer may enforce a product warranty claim within two years from the date on which the product was placed on the market by the manufacturer. After the expiry of this period, the Customer shall lose this right.

8.3. The consumer Customer shall notify the manufacturer of the defect without undue delay after discovering the defect.

A defect notified within two months from the date on which it was discovered shall be deemed to have been notified without delay.

The consumer shall be liable for any damage resulting from delayed notification.

8.4. The manufacturer shall be exempt from product warranty liability if it proves that:

the product was not manufactured or distributed within the scope of its business activity or independent profession;

the defect could not have been recognised according to the state of scientific and technical knowledge at the time when the product was placed on the market; or

the defect in the product was caused by the application of mandatory legislation or a compulsory official requirement.

9. Statutory warranty (“guarantee”) applicable to consumers

9.1 Pursuant to Ministerial Decree No. 10/2024 (VI. 28.) IM on the determination of the scope of durable consumer goods subject to mandatory statutory warranty, the mandatory warranty applies to new durable consumer goods listed in Annex 1 of the Decree where the selling price of such goods reaches HUF 10,000.

Among the products marketed by the Service Provider, in particular fencing and sports equipment falling under point 23 of the Annex, as well as accessories and components of durable consumer goods subject to mandatory warranty under point 38 of the Annex, may fall within this category.

The performance of the mandatory statutory warranty obligation is the responsibility of the seller company contracting with the consumer.

The Service Provider shall be released from its mandatory warranty obligation if it proves that the cause of the defect arose after performance of the contract.

The mandatory statutory warranty does not affect the consumer’s statutory rights arising from statutory warranty for defects, product warranty or any other rights provided by law.

9.2. For consumer contracts concluded between 1 January 2021 and 7 May 2024, the duration of the mandatory statutory warranty depended on the selling price of the product and was one, two or three years as follows:

one year in the case of a selling price reaching HUF 10,000 but not exceeding HUF 100,000;

two years in the case of a selling price exceeding HUF 100,000 but not exceeding HUF 250,000;

three years in the case of a selling price exceeding HUF 250,000.

From 8 May 2024, the duration of the mandatory statutory warranty is:

two years in the case of a selling price reaching HUF 10,000 but not exceeding HUF 250,000;

three years in the case of a selling price exceeding HUF 250,000.

The warranty period is a forfeiture period.

The warranty period begins on the date on which the consumer receives the consumer product or, if installation is carried out by the Service Provider, its representative, or another authorised person responsible for installation, on the date of installation.

If the consumer has the consumer product installed more than six months after delivery, the starting date of the warranty period shall be the date of delivery of the consumer product.

If the consumer product is repaired, the warranty period shall be extended by the period during which the consumer was unable to use the product for its intended purpose due to the defect, starting from the date on which the product was handed over for repair.

9.3. For contracts concluded from 1 March 2026, the mandatory statutory warranty pursuant to Government Decree No. 151/2003 (IX. 22.) shall also apply to micro, small and medium-sized enterprise purchasers acting outside the scope of their profession, independent occupation or business activity.

For the purposes of this Decree, a micro, small or medium-sized enterprise shall be deemed to act outside the scope of its profession, independent occupation or business activity if it purchases the consumer product within the framework of retail activities as defined by the Act on Trade, regardless of whether the consumer product is accounted for within its economic activity.

When assessing the proper use, handling, storage and maintenance of a product, the Service Provider shall take into account the manufacturer’s instructions for use and handling supplied with the product, as well as any manufacturer requirements applicable to the product.

The conditions of any voluntary or commercial manufacturer’s warranty provided by the manufacturer are separate from the mandatory statutory warranty based on legislation and do not limit the consumer’s statutory warranty or guarantee rights.

9.4. The Service Provider is not obliged to issue and provide a warranty certificate to the consumer if the selling price of the consumer product subject to mandatory statutory warranty does not exceed HUF 100,000.

In such cases, rights arising from the warranty may be enforced by presenting the invoice or receipt confirming payment of the purchase price.

At the time of delivery of the consumer product, the Service Provider shall inform the consumer accordingly and shall provide the consumer with the statutory information regarding product identification, warranty rights and conciliation board proceedings in a form that ensures readability until the end of the warranty period.

9.5. For consumer products subject to mandatory statutory warranty with a selling price exceeding HUF 100,000, the Service Provider shall provide a warranty certificate.

Unless otherwise requested by the consumer, the warranty certificate may also be provided electronically.

Except for contracts concluded between absent parties (distance contracts), the Service Provider shall inform the consumer at the time of delivery of the consumer product about the possibility of requesting a different form of delivery.

The Service Provider shall provide the electronic warranty certificate no later than the day following the delivery or installation of the consumer product.

If the electronic warranty certificate is not sent directly but is made available through an access link enabling download, the Service Provider shall ensure that the certificate remains downloadable and that the access link remains available until the end of the warranty period.

An electronically issued invoice may only be accepted as a warranty certificate if its content also complies with the statutory requirements applicable to warranty certificates.

9.6. The consumer may enforce claims arising from the mandatory statutory warranty within the warranty period.

Otherwise, the rules applicable to the exercise of statutory warranty rights for defects shall apply accordingly to the enforcement of warranty claims, provided that, in the case of consumer products subject to mandatory statutory warranty, the specific provisions of Government Decree No. 151/2003 (IX. 22.) shall also apply.

The consumer may submit a warranty claim, at their choice, at the registered office, any premises or branch office of the Service Provider, or directly to the repair service indicated by the Service Provider on the warranty certificate.

Based on a warranty claim, the consumer may primarily request repair or replacement.

Where the conditions specified by the applicable legislation are met, the consumer may request a proportionate reduction of the purchase price or terminate the contract.

Termination of the contract due to an insignificant defect shall not be permitted.

9.7. During repair, only new parts may be installed in the consumer product.

The Service Provider shall endeavour to complete the repair or replacement within a maximum period of fifteen days.

If the repair or replacement takes longer than fifteen days, the Service Provider shall inform the consumer of the expected duration of the repair or replacement.

When fulfilling a request for repair, the Service Provider or — where the repair request is submitted directly to the repair service — the repair service shall record on the warranty certificate or attach thereto:

the date on which the repair claim was reported;

the date on which the consumer product was received for repair;

the cause of the defect;

the method of repair; and

the date on which the consumer product was returned to the consumer.

In the event of replacement, the Service Provider shall indicate the fact and date of replacement on the warranty certificate.

9.8. If, during the mandatory warranty period, the Service Provider establishes that the consumer product cannot be repaired due to a malfunction, the Service Provider shall replace the consumer product within eight days, unless otherwise instructed by the consumer.

If replacement of the consumer product is not possible, the Service Provider shall refund the purchase price indicated on the warranty certificate or, in the absence thereof, on the invoice or receipt presented by the consumer confirming payment of the purchase price, within eight days.

9.9. If, during the mandatory warranty period, the consumer product becomes defective again after three repairs, the Service Provider shall replace the consumer product within eight days, unless otherwise instructed by the consumer.

If replacement of the consumer product is not possible, the Service Provider shall refund the purchase price indicated on the warranty certificate or, in the absence thereof, on the invoice or receipt presented by the consumer confirming payment of the purchase price, within eight days.

9.10. If the repair of the consumer product has not been completed by the thirtieth day following notification of the warranty claim to the Service Provider, the Service Provider shall, unless otherwise instructed by the consumer, replace the consumer product within eight days following the unsuccessful expiry of the thirty-day repair period.

If replacement of the consumer product is not possible, the Service Provider shall refund the purchase price indicated on the warranty certificate or, in the absence thereof, on the invoice or receipt presented by the consumer confirming payment of the purchase price, within eight days following the unsuccessful expiry of the thirty-day repair period.

9.11. If the consumer submits a replacement claim due to a malfunction of the consumer product within three working days from the date of purchase or installation, the Service Provider may not rely on disproportionate additional costs and shall replace the consumer product within eight days, provided that the malfunction prevents normal intended use.

If replacement of the consumer product is not possible, the Service Provider shall immediately refund the purchase price indicated on the warranty certificate or, in the absence thereof, on the invoice or receipt presented by the consumer confirming payment of the purchase price.

9.12. The Service Provider shall be released from its warranty obligation if it proves that the cause of the defect arose after performance of the contract.

The warranty and statutory warranty rights do not cover defects or damage which demonstrably arose after the transfer of risk, in particular as a result of improper use, improper handling, incorrect storage, failure to perform maintenance, incorrect assembly, or external physical or chemical effects.

Normal wear and tear and deterioration resulting from proper intended use shall not in themselves constitute defective performance.

9.13. For the purposes of Clause 9.12, the Service Provider may particularly examine the following circumstances if there is a causal relationship between such circumstances and the reported defect:

improper, grossly negligent or non-intended use or handling;

overloading;

incorrect assembly;

cleaning with corrosive detergents or detergents with a composition different from that recommended in the instructions for use, or failure to comply with washing instructions;

normal wear and tear and deterioration resulting from proper intended use.

9.14. Special provisions:

The following phenomena shall not in themselves constitute defective performance if they result exclusively from normal wear and tear associated with proper intended use, improper use of the product, improper handling, unsuitable storage, failure to maintain the product, or external effects.

This does not affect the consumer’s statutory rights where the cause of the defect already existed at the time of performance, including in particular hidden material defects or manufacturing defects.

Breakage of a fencing blade shall not in itself constitute defective performance. In the event of a hidden material defect or manufacturing defect, the consumer may enforce their statutory rights.

Damage caused by a fencing blade to fencing clothing or fencing gloves as a result of external physical impact shall not in itself constitute defective performance of the clothing or gloves.

Oxidation resulting from improper storage of the blade, particularly in a humid environment, shall not in itself constitute defective performance.

Natural oxidation occurring during the use of lamé made from non-washable material shall not in itself constitute defective performance.

Oxidation of a non-FIE mask grille caused by use or improper storage shall not in itself constitute defective performance.

Wear of the sole or leather surface of fencing shoes resulting from normal intended use shall not in itself constitute defective performance.

Jamming of the fencing scoring reel cable or contamination of the contacts caused by use shall not in itself constitute defective performance.

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PRIVACY NOTICE

This Privacy Notice describes the processing of personal data in connection with the PBT Hungary Ltd. website and online store. Its purpose is to provide data subjects with clear and easy-to-understand information about the purposes and legal bases of the data processing, the categories of personal data processed, the retention periods, the recipients of the data, and the ways in which they can exercise their rights.

1. Details of the Data Controller

Name of the Data Controller	PBT Hungary Vívófelszereléseket Gyártó és Értékesítő Korlátolt Felelősségű Társaság
Registered office	1139 Budapest, Teve utca 9., Building D, Ground Floor, Door 6
Postal address	1139 Budapest, Teve utca 9., Building D, Ground Floor, Door 6
Representatives	Bence Kovács, Managing Director Orsolya Kovács, Managing Director
Company registration number	01-09-667141
Tax number	12335990-2-41
Website	https://vivas.hu https://shop.pbtfencing.hu https://pbtfencing.com
Customer service e-mail	pbt@vivas.hu
Data protection contact e-mail	pbt@vivas.hu
Data protection contact person	Ildikó Wimmi
Data Protection Officer	In the case of PBT, the appointment of a Data Protection Officer is not mandatory.

2. Purpose and Scope of this Privacy Notice

2.1. This Privacy Notice applies to the processing of personal data in connection with the use of the websites and webshops available at https://vivas.hu, https://shop.pbtfencing.hu, and https://pbtfencing.com, including data processing related to user registration, ordering, payment, delivery, customer communication, complaint handling, newsletters, cookies, web analytics, AI-powered webchat, as well as the customer loyalty discount programme and customer loyalty card.

2.2. This Privacy Notice applies, in particular, to visitors to the websites, registered users, customers, natural persons acting as contact persons, newsletter subscribers, visitors using the AI-powered webchat, and individuals submitting complaints, customer service enquiries, or other requests.

3. Applicable Legislation

3.1. The processing of personal data by PBT is governed in particular by the following legislation:

•  Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation – GDPR);

•  Act CXII of 2011 on the Right of Informational Self-Determination and Freedom of Information (Hungary) (Info Act);

•  Act CVIII of 2001 on Certain Issues of Electronic Commerce Services and Information Society Services (Hungary);

•  Act C of 2003 on Electronic Communications (Hungary);

•  Act XLVIII of 2008 on the Basic Requirements and Certain Restrictions of Commercial Advertising Activities (Hungary);

•  Act CLV of 1997 on Consumer Protection (Hungary);

•  Act V of 2013 on the Civil Code (Hungary);

•  Act C of 2000 on Accounting (Hungary);

•  Act CL of 2017 on the Rules of Taxation (Hungary).

4. Data Processing Principles

4.1. PBT processes personal data lawfully, fairly and in a transparent manner, for specified purposes, to the extent necessary, and for no longer than is necessary to achieve the purposes of the processing.

4.2. PBT requests that data subjects provide true, accurate and up-to-date personal data when submitting their information and, where possible, notify PBT of any changes to such data. Inaccurate, incomplete or outdated information may prevent or hinder the completion of registration, the processing of orders, invoicing, delivery, customer communication, or the provision of other requested services. In accordance with Article 5(1)(d) of the GDPR, PBT takes reasonable steps to ensure that the personal data it processes are accurate and, where necessary, kept up to date, and that inaccurate personal data are rectified or erased without undue delay.

4.3. PBT stores personal data in a form that permits the identification of data subjects only for as long as is necessary to achieve the purposes for which the data are processed. PBT implements appropriate technical and organisational measures to protect personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage.

5. Definitions

5.1. The terms used in this Privacy Notice shall primarily be interpreted in accordance with Article 4 of the GDPR. The most important terms are summarised below:

•  Personal data: any information relating to an identified or identifiable natural person.

•  Data subject: the natural person to whom the personal data relate.

•  Processing: any operation or set of operations performed on personal data, including, in particular, collection, recording, organisation, storage, alteration, retrieval, use, disclosure by transmission, erasure, or destruction.

•  Controller: the natural or legal person, public authority, agency or other body which determines the purposes and means of the processing of personal data.

•  Processor: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

•  Recipient: a natural or legal person, public authority, agency or another body to which the personal data are disclosed.

•  Consent: any freely given, specific, informed and unambiguous indication of the data subject's wishes.

•  Cookie: a small data file stored on the user's device, or a similar online identifier, which may be used to ensure the operation of the website, facilitate its use, measure its performance, or enable personalisation.

6. Processing Activities

6.1. Website Operation and Server Logging

Purpose and Data Subjects	To ensure the secure and reliable operation of the website and to detect errors and misuse. Data subjects: visitors and users of the website.
Categories of Personal Data Processed	Technical and log data, including in particular the IP address, the date and time of the visit, the requested page or URL, browser and device information, as well as error and security-related data.
Legal Basis	Article 6(1)(f) GDPR – the legitimate interest of PBT in ensuring the IT security and proper functioning of the website.
Retention Period	Server logs are retained for 14 days.
Recipients or Categories of Recipients	Server hosting and infrastructure provider: SiteFace Kft.
Provision of Data	The processing of technical data is inherent in the use of the website; without such processing, the website cannot operate properly.

6.2. Registration and User Account

Purpose and Data Subjects	Creation and maintenance of a user account, user login, and preparation of online orders. Data subjects: registered users.
Categories of Personal Data Processed	E-mail address, password/password hash, first name, last name, billing name, indication of purchase as a business, tax number, country/shipping country, telephone number and address (where provided during registration or the ordering process), account identifier, and date of registration.
Legal Basis	Article 6(1)(b) GDPR – processing necessary for the performance of a contract or in order to take steps at the request of the data subject prior to entering into a contract.
Retention Period	Until the user account is deleted. The user may delete their account at any time through the webshop. Upon deletion of the account, or when the purpose of processing related to maintaining the account no longer exists, the account data shall be erased. Deletion of the user account does not affect the retention of order, invoicing, complaint-handling or other data relating to legal claims where continued processing is required on a separate legal basis for the applicable retention period.
Recipients or Categories of Recipients	Server hosting and infrastructure provider: SiteFace Kft.; webshop developer: I-Soft.hu Kft. (registered office: 4 Fecske Street, 2nd Floor, Door 8, H-6723 Szeged, Hungary).
Whether the Provision of Personal Data is Mandatory	The provision of the data required for registration is necessary to create a user account and to place online orders.

6.3. Customer Loyalty Discount Programme and Loyalty Card

Purpose and Data Subjects
Categories of Personal Data Processed	Name, e-mail address, telephone number, residential address, loyalty programme identifier or loyalty card details, data relating to purchases and discounts, and any other information provided by the data subject that is necessary for the administration of the programme.
Legal Basis	Article 6(1)(b) GDPR – processing necessary for the performance of a contract or in order to take steps at the request of the data subject prior to entering into a contract in connection with the application for or use of the customer loyalty discount or loyalty card. Where processing is required to comply with accounting or tax obligations, the legal basis is Article 6(1)(c) GDPR. Processing for newsletters or direct marketing is governed by Section 6.11 of this Privacy Notice.
Retention Period	Until the termination of the customer loyalty membership and thereafter until the expiry of the applicable limitation period for related legal claims. Accounting records are retained for the period specified in Section 6.7. Personal data processed for newsletter purposes are retained until consent is withdrawn.
Recipients or Categories of Recipients	Developer and operator of the SAP application and, where necessary, the server hosting and infrastructure provider: SiteFace Kft
Whether the Provision of Personal Data is Mandatory	Participation in the customer loyalty programme is voluntary. However, without the required personal data, the customer loyalty discount or loyalty card cannot be provided.

6.4. Shopping Cart, Wishlist and Product Comparison

Purpose and Data Subjects	To facilitate the purchasing process by enabling the management of selected products in the shopping cart, wishlist or product comparison feature. Data subjects: visitors and registered users using these functions.
Categories of Personal Data Processed	Product identifiers, shopping cart contents, wishlist and product comparison data, user identifier, session identifier, and technical data required for the operation of these functions.
Legal Basis	Article 6(1)(b) GDPR for processing necessary to provide functions required for the preparation of an order. Where online identifiers stored on the user's device are not strictly necessary, the legal basis is the data subject's consent pursuant to Article 6(1)(a) GDPR.
Retention Period	For as long as necessary to provide the relevant functionality. The data shall be erased when the purpose of the processing no longer exists or when the data subject deletes the relevant content.
Recipients or Categories of Recipients	Server hosting and infrastructure provider: SiteFace Kft.; webshop developer: I-Soft.hu Kft.
Whether the Provision of Personal Data is Mandatory	Use of the shopping cart is necessary for the preparation of online orders. The wishlist and product comparison features are optional.

6.5. Order Placement, Fulfilment and Customised Products

Purpose and Data Subjects	To receive, confirm, fulfil and internally administer orders, maintain customer and business partner records, and, where requested by the customer, prepare customised inscriptions or product markings. Data subjects: customers, recipients, and natural persons acting as contact persons on behalf of a company or other organisation.
Categories of Personal Data Processed	Name, e-mail address, telephone number, billing name and address, shipping name and address, company name/tax number, ordered products, product size or other product selections, order identifier, payment and delivery method, date of the order, contents of the order notes, discounts/coupons, and order status. PBT also processes the personal data necessary for order fulfilment and internal administration as customer and business partner data within its SAP system. For customised inscriptions: product code, product name, size, handedness, requested name or inscription, country code, information relating to national logos or painting, and any other information provided in the order notes.
Legal Basis	Article 6(1)(b) GDPR – processing necessary for the performance of a contract. Following fulfilment of the contract, processing required for compliance with legal obligations is based on Article 6(1)(c) GDPR. Processing that is limited to what is necessary for the establishment, exercise or defence of legal claims is based on Article 6(1)(f) GDPR – PBT's legitimate interest in protecting its legal claims.
Retention Period	Order data are retained for as long as necessary to perform the contract and thereafter until the expiry of the applicable limitation period for contractual legal claims. The retention of accounting records is governed by Section 6.7 of this Privacy Notice. Customer and business partner data stored in the SAP system are retained for the period applicable to the underlying order, accounting or legal processing purpose.
Recipients or Categories of Recipients	Server hosting and infrastructure provider: SiteFace Kft.; webshop developer and IT support provider: I-Soft.hu Kft.; developer and operator of the SAP application and provider of the invoicing software: Contact Plus Consulting Kft. (registered office: 63 Álmos vezér útja, Ground Floor, Door 2, H-1141 Budapest, Hungary); accountant: Molnár & Partners Kft. (registered office: 35 Liszt Ferenc Street, 1st Floor, Door 1, H-9022 Győr, Hungary); card payment service provider: K&H Bank Zrt.; delivery service providers: DPD and MPL / Hungarian Post.
Whether the Provision of Personal Data is Mandatory	The provision of the personal data required to fulfil the order is a contractual requirement. Data relating to customised inscriptions are required only if the customer requests such a service.
Source of the Personal Data	Where the delivery recipient is different from the customer, the recipient's contact and delivery details are obtained from the customer.

6.6. Payment

Purpose and Data Subjects	To enable payment of the purchase price and delivery charges and to manage the payment status. Data subjects: customers and persons making payments.
Categories of Personal Data Processed	Order identifier, amount payable, currency, payment method, payment confirmation status, transaction identifier, payment identifier, the date and time of creation and modification of the transaction, bank response, and the amount payable on delivery (cash on delivery). PBT does not receive or store any payment card details; payment card information is entered directly on the bank's secure payment interface.
Legal Basis	Article 6(1)(b) GDPR – processing necessary for the performance of a contract. For accounting records, the legal basis is Article 6(1)(c) GDPR – processing necessary for compliance with a legal obligation.
Retention Period	For as long as necessary to complete and reconcile the transaction; accounting records are retained for at least eight (8) years; where necessary for the establishment, exercise or defence of legal claims, personal data are retained until the expiry of the applicable limitation period.
Recipients or Categories of Recipients	K&H Bank Zrt., as the payment card service provider; in the case of cash on delivery, the selected delivery service provider: DPD or MPL / Hungarian Post.
Whether the Provision of Personal Data is Mandatory	The provision of the personal data required for the selected payment method is a contractual requirement. Without such data, payment cannot be processed and the order cannot be fulfilled.

6.7. Invoicing, Accounting and Taxation

Purpose and Data Subjects	To issue invoices and comply with accounting and tax obligations. Data subjects: customers and natural persons acting as contact persons for customers purchasing on behalf of a company.
Categories of Personal Data Processed	Billing name, billing address, tax number, ordered products and/or services, price, payment method, order identifier, invoice identifier, e-mail address (where an electronic invoice is issued), and other accounting document data.
Legal Basis	Article 6(1)(c) GDPR – processing necessary for compliance with a legal obligation.
Retention Period	Accounting records are retained for at least eight (8) years. Other tax-related records are retained until the expiry of the statutory limitation period for the assessment of taxes.
Recipients or Categories of Recipients	Invoicing software provider: Contact Plus Consulting Kft.; accountant: Molnár & Partners Kft.; the Hungarian National Tax and Customs Administration (NAV), including the NAV Online Invoice System.
Whether the Provision of Personal Data is Mandatory	The provision of the personal data required for invoicing is a legal and contractual requirement. Without such data, the order cannot be fulfilled

6.8. Delivery and Shipping

Purpose and Data Subjects	Delivery of ordered products and handling of matters related to delivery. Data subjects: customers and recipients.
Categories of Personal Data processed	Recipient’s name, delivery address, telephone number, e-mail address, order ID, parcel tracking number, delivery method, cash-on-delivery amount, delivery status.
Legal Basis	Article 6(1)(b) of the GDPR: processing is necessary for the performance of a contract.
Retention Period	Until completion of the delivery. After that, only those data necessary for handling complaints or for the establishment, exercise, or defence of legal claims may continue to be processed until the relevant matter is closed, or, in the case of legal claims, until the end of the applicable limitation period, which is generally 5 years. The data processing carried out by courier service providers is governed by their own privacy notices.
Recipients or Categories of Recipients	Shipping service providers: DPD courier service; MPL / Hungarian Post.
Nature of Data Provision	Without the data required for delivery, the delivery cannot be completed.

6.9. Customer Communication, Contact Requests and Requests for Quotations

Purpose and Data Dubjects	Responding to inquiries, requests for quotations, and customer service questions. Data subjects: prospective customers, customers, and contact persons.
Categories of Personal Data Processed	Name, e-mail address, telephone number, postal address, company details, order ID, other personal data provided in the message/request, and the date and content of the communication.
Legal Basis	For inquiries related to the conclusion of a contract or the performance of a contract: Article 6(1)(b) of the GDPR: processing is necessary for the performance of a contract. For other inquiries: Article 6(1)(f) of the GDPR: the legitimate interest of PBT in responding to inquiries.
Retention Period	Until the matter has been closed. After this period, only those personal data necessary in connection with the contract or legal claims may be processed further until the end of the applicable limitation period, which is generally 5 years.
Recipients or Categories of Recipients	E-mail service provider: Microsoft 365 / Exchange-based e-mail services – Microsoft Ireland Operations Limited (registered office: 70 Sir John Rogerson’s Quay, Dublin D02 R296, Ireland).
Nature of Data Provision	Provision of data is voluntary; however, without the contact details required for responding, PBT is unable to provide a response.

6.10. Complaint Handling, Withdrawal, Warranty and Guarantee Claims

Purpose and Data Subjects	Investigation and handling of complaints, withdrawal requests, warranty and guarantee claims, and other customer claims. Data subjects: persons submitting complaints or claims.
Categories of Personal Data Processed	Name, postal address, e-mail address, telephone number, order ID, invoice ID, product details, content of the complaint, attached photographs/documents, records of proceedings, response, case-handling information, and any refund-related data.
Legal Basis	Article 6(1)(c) of the GDPR: processing is necessary for compliance with a legal obligation. For retention related to legal claims: Article 6(1)(f) of the GDPR: the legitimate interest of PBT in protecting its legal claims.
Retention Period	The minutes recorded of an oral complaint, the written complaint, and a copy of the substantive response provided to the complaint shall be retained by PBT for 3 years. The retention period for minutes recorded regarding a consumer’s warranty or guarantee claim is 3 years from the date of recording. Other documents related to withdrawal requests and other claims may be processed until the matter has been resolved or, in the case of legal claims, until the end of the applicable limitation period.
Recipients or Categories of Recipients	Where necessary: invoicing software provider: Contact Plus Consulting Kft.; accounting service provider: Molnár & Partners Kft.; shipping service providers: DPD courier service; MPL / Hungarian Post; legal representative, manufacturer, supplier, service provider, authority, or conciliation body.
Nature of Data Provision	Submission of a complaint is voluntary; however, without the data necessary for investigating the claim, the matter cannot be handled or can only be handled to a limited extent.

6.11. Newsletter and Direct Marketing

Purpose and Data Subjects	Sending newsletters and electronic marketing messages to individuals who have provided their consent. Data subjects: subscribers to the newsletter.
Categories of Personal Data processed	E-mail address; name; date and source of subscription, version of the consent statement, IP address; date of unsubscribing, telephone number, and postal address.
Legal Basis	Article 6(1)(a) of the GDPR: consent; prior, explicit, and express consent pursuant to Section 6(1) of the Hungarian Act on Business Advertising Activity (Grtv.). Where PBT retains separate, limited log data for the purpose of proving the granting or withdrawal of consent, the legal basis for such processing is Article 6(1)(f) of the GDPR: the legitimate interest of PBT in demonstrating compliance and protecting its legal claims.
Retention Period	Until unsubscribing or withdrawal of consent. After that, the data must be deleted without undue delay from the direct marketing database. PBT deletes the related newsletter subscription when the user account is deleted. The separate data necessary to prove the granting and withdrawal of consent may be retained until the expiry of the limitation period applicable to related legal claims.
Recipients or Categories of Recipients	E-mail service provider: Microsoft 365 / Exchange-based e-mail services – Microsoft Ireland Operations Limited.
Nature of Data Provision	Voluntary. Failure to subscribe does not affect registration or purchasing. Consent may be withdrawn at any time without undue delay.

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