Privacy policy

Smart Shopping Ltd.

Last version: 2018. October 29.

  1. General information
    1. Smart Shopping Ltd. has developed the Smartlyst application (hereinafter referred to as: “Application”) to make your everyday shopping easier. Smart Shopping Ltd. respects your rights to privacy, therefore we comply with our obligations to process your personal data as stipulated by the data protection laws in force. The purpose of this Privacy Policy is to outline how we deal with any Personal Data you provide us while visiting this website. Naturally, if you are not happy with this Privacy Policy you should not use our Application.
    2. This Privacy Policy is a translation of the original Hungarian version. Should there be a dispute among the parties, and a discrepancy in the Hungarian and English text, the Hungarian text shall prevail.
    3. The data controller and the client:
      1. Data controller (hereinafter referred to as: „Smart Shopping Ltd.”, „Data Controller” or „Service provider”): the company responsible for the maintenance of the Application:
        Name:Smart Shopping Ltd.
        Seat:2092 Budakeszi, Vásárhelyi Pál street 45.
        Registration number:13-09-182854
        Tax number:25746455-2-13
      2. For the purposes of this Privacy Policy, any reference to „you” is to a Client, who is a natural person (hereinafter: „User”).
  2. The Smartlyst application
    1. Smartlyst is an application that makes shopping easier for you. Smartlyst can be synchronized on multiple platforms such as smart phones, tablets, Ipads or desk tops. You can create different shopping lists through the Application, which can then be shared with others, or you can also co-edit it with those whom you shared the list with. From desk tops, you can reach our Application via Otherwise, please download the Application from your Appstore or GooglePlay. The Application can be used with your registration and without registration as well, but in order to use all the functions of the Application, it is recommended for you to register. You can register with an e-mail address or via a Facebook or Google+ account as well.
    2. You can add items to a shoppinglist by typing or orally through voice recording. You may edit the items according to category, quantity, price, and you may also add additional comments.
    3. You can also upload a photo of the list item, which you are obliged to obtain legally. By uploading and publishing the picture, you warrant that in no way infringe any third person’s right, or legitimate interest, in particular their copyright or personality rights. We maintain our right to delete those picture from out Application that we deem contestable for the aforementioned reasons, and to claim any and all damages in relation to this. Should you upload a picture authored by you, by agreeing to its publishing, you give us your explicit consent and license us to use your picture without limitations in time, or territory, and you explicitly renounce any claims to royalties. The pictures uploaded as such shall only be used in the Application, and we shall not be authorized to transfer or sublicense them to third persons for a consideration or for free.
    4. On the shopping lists you can also pin the items according to category, quantity, price, and you may also add additional comments. With this, you can look up the details of your previous purchases at any time.
    5. You can also pin the items that you purchase on a regular basis, thereby allowing the Application to automatically recommend these to you.
    6. The Application can also remind you when an item on your shopping list is running out, either in the form of push-notifications (without opening the application that is), or in a pop-up window when opening the Application – according to your choice. You can thereby add the item to your shopping list with a single click.
    7. You can add recipes as well as the ingredients of the recipes to your shopping list. You can also import recipes from and You can organize the recipes into various categories of your choice for more transparency. You can also share these recipes with other registered users.
    8. By registering on the Application you consent to receiving automatically generated system notifications on confirming your registration, your forgotton password, and deleting your account. The Application notifies you, according to your choice, either via email, in the form of a pop-up window or a push notification, of the following:
      1. New items added,
      2. Items running out soon,
      3. Sharing shopping lists,
      4. Sharing recipes,
      5. Sales from different shops,
      6. New functions and updates.
    9. You can manage the notifications under „Settings”.
  3. Our privacy policies
    1. The aim of data protection legislations is to ensure the protection of natural persons, whose data are recorded and stored on a computerized or other system. For this, legislations pose strict requirements of precision, assigned purpose, security and the data transfer. Our Privacy Policy is in compliance with the legislations in force, in particular Act CXII. of 2011 on Informational Self-Determination and Freedom of Information (hereinafter referred to as „Information Act”), and the General Data Protection Regulation EU 2016/679 (hereinafter referred to as „GDPR”).
    2. Our company, as data controller, shall, at all times, be obliged to comply with all requirements of data management incorporated in this Privacy Policy and legislation in force.
    3. By using the Application, you consent to the collection, use and storage of your personal information for the provision of our services through our Application and our related legitimate business purposes as explained in this Privacy Policy. We only collect, use or store information about you, if we reasonably believe it is justified, required and useful in order to conduct our business effectively and to provide you with information about products and services we believe will be of interest to you.
    4. We reserve the right to unilaterally modify our Privacy Policy, so please check back regularly for changes. In the case of any modification, our Company will notify the users by posting the changes of the Privacy Policy on the website eight (8) days prior to the enforcement of the changes. The date of any amendments shall be displayed under „Last Updated” at the top of the page. Your continued use of our Application after the amended Privacy Policy enters into force, shall constitute a consent to the amended Privacy Policy.
    5. Our company is committed to protect your and our other Users’ personal information, therefore we find it crucial to respect your right to informational self-determination. Our company takes all technical and organizational measures to safeguard the personal information of its users.
    6. Our company shall only use your personal information necessary to use our website according to your voluntary consent and only in accordance with the herein defined data processing purposes.
    7. Should our company wish to use the personal information provided to us for purposes other than the data collection purposes, we shall notify you of this and seek your explicit, prior consent, as well as give you the possibility to forbid it.
  4. Legal basis for data processing
    1. Your personal information may only be used if and when, and to the extent that you, as data subject, consent to it, or the data processing is mandatory by law, or municipality regulations. In case of our Application, the legal ground for our data processing is your voluntary consent.
    2. When registering on the Application and accpeting to the provisions of this Privacy Policy (by clicking the check-boksz), you explicitly consent to the processing of your personal information for the purposes and by the means defined in this Privacy Policy.
    3. By registering on the Application you consent to receiving automatically generated system notifications on confirming your registration, your forgotton password, and deleting your account.
    4. In accordance with your explicit consent, the Application may:
      1. send newsletters to your email address,
      2. send you direct marketing newsletters to your email address (e.g. on items on sale),
      3. place direct marketing advertisements on the Application’s platform,
      4. remind you on the Application of the items running out,
      5. send you direkt marketing push notifications,
      6. send you push notifications about items running out.
    5. As data controller, we may process your personal data (i) based on your voluntary consent for the purposes of fulfilling our legal obligations unless otherwise provided by law; or (ii) without your additional consent, and after you revoke your consent, to serve the legitimate interest of the data controller or a third person, if this legitimate interest is proportionate to the limitation of data protection.
    6. Considering that you use our Application based on your voluntary consent, you may, at any point in time, decide to stop using it and to delete your account. By deleting your account in the Application, you explicitly revoke your consent to our data controlling.
  5. Personal data controlled, Purposes and means of data control
    1. You may use our Application as a registered user but also without registering. Registration is not compulsory, but for the full appreciation of the services of the Application, it is recommended.
    2. We do not collect personal data about not registered visitors of our Application. Any personal information you may provide are exclusively stored on your device, to which our Company has no access to, neither via our Application, nor in any other way. We only collected aggregated data about our not registered Users, in order to know where our visitors come from and so we could improve the services provided through our Application. These are also used to improve our servives and user experience. We may also use these data for testing, troubleshooting and repairs.
    3. If you register with an email address, the following personal information shall be required upon registration:
      1. name;
      2. email address;
      3. password;
      4. location.
    4. If you forget your password, by providing your email address, the Application shall send you a new, temporary password. You are obliged to change this temporary password upon the first time you open the Application following the receipt of the temporary password. We shall bear no liability for any damages arising in relation to you not changing the temporary password.
    5. If you register with a Facebook account, our Application shall have access to the following personal information through your Facebook account:
      1. name;
      2. profile picture;
      3. email address;
      4. location.
    6. If you register with a Google account, our Application shall have access to the following personal information through your Google+ account:
      1. name;
      2. profile picture;
      3. email address;
      4. location.
    7. Through registering and using the services provided by our Application, our company collects your following personal information:
      1. the name, the items and the categories of the shopping list created by the User,
      2. based on the shopping list, the name, the category of the purchased item, and the details of previous purchases,
      3. consumer habits (that is, how often does the User add an item to a shopping list,
      4. the User’s geographical location,
      5. the exact date of the registration and the use and opening of our Applicaiton,
      6. profile picture, should you register via your Facebook or Google+ accounts.
    8. Please note that any audio recorded via voice recording qualifies as sensitive personal data, therefor right before the start of the audio recording the Application will automatically seek authorization for recording the audio. Our voice recording system contains speech recognition only, and thus we are unable to identify your voice. Voice recording is done as per your explicit and voluntary consent.
    9. Please note that we do not draw any conclusions based on your shopping lists, or any items on your lists – such as food allergy, health issues, etc. – and – apart from consumer habits – we make no decisions based on these, neither manually nor automatically.
    10. In order to make your experience more convenient, registered Users have the option to authorize the Applicaiton to save and store your data and be able to input your data only once and not everytime you sign in.
    11. Data processing purposes:
      1. to ensure the provision of the services through our Application and the management of the shoppinglists, and the items on it, as well as the recipes,
      2. to send automatic system notifications through our Application based on your consent,
      3. to identify the User, to administer the Users and to distinguish them from one another,
      4. to process your inquires,
      5. to settle any possible legal disputes, and to comply with any official control,
      6. to contact you, if we are convinced that our similar products or services may interest you, such as in the form of newsletters, or other direct marketing tools based on your separate consent. We may also engage third party service providers to process your personal data for example in order to send you marketing materials.
    12. Personal data provided by the User shall be used by the Service Provider until the User forbids such use of their data.
    13. Please note that by downloading the Application, AppStore and GooglePlay may collect personal data about you – such a show many people have downloaded the app, from which country and from what sources did the Users come from, etc. – and study their respective privacy policies. We may only access and use these data in aggregated form. We are not liable for such data control.
    14. We maintain our right to transfer our data - including your personal data – to third persons, in the event of a merger and acquisition, voluntary or forced liquidation and/or winding up process, and the transfer of all or almost all of our company’s assets, ont he condition that the third party agrees to comply with this privacy policy and that the third party only managed your data for the purposes we define. Should the transfer of your data take place in such a way, we shall notify you of this in due time, in case you would like to unsubscribe.
    15. We manage your personal data only for predefined puposes, to exercise a right or to fulfill an obligation. We comply with our privacy policy at each and every stage of the data management process. We only process personal data that is necessary and adequate to fulfill our data management purposes. We manage your personal data only to the extent and for the time period necessary for our data management purposes. Data processing of the Data controllers services are based on your voluntary consent, however in certain cases it is our legal duty to manage, store, transmit these personal data. Data controller does not use your personal data for any other purposes.
    16. Data controller does not check the personal data provided by the user. Only the person providing these data in fact shall be liable for the accuracy of the personal data. By providing us your email address, you shall be responsible for making sure that only you engage our services through your account. For this purposes, any responsibility concerning signing in with a registered email address, shall only be assumed by the person who registered that email address. In case the user does not provide its own personal data, the user shall be obliged to seek consent for those personal information.
  6. Data transfers, and data processors
    1. Only our employees, third service providers we engage and data processors are entitled to access your personal data,
    2. We only communicate statistics and aggregated data to our advertisers – for example how many discounted products were added to the Users’ shopping lists, how many times the advertiser’s banner appeared, how many Users clicked on the link to the advertiser’s website, etc. – but not personal data.
    3. Hosting services: :
      Name:Rackforest Informatikai Kereskedelmi Szolgáltató és Tanácsadó Korlátolt Felelősségű Társaság
      Seat:1132 Budapest, Victor Hugo utca 18-22. 3. em. 3008.
      Company registration no.:01-09-914549
      Tax no.:14671858-2-41
    4. We may only transmit personal data to third parties based on the User’s prior, well-informed and explicit consent. This does not apply to data transmission required by law or performed towards our data processors.
    5. Our company, as data controller, is entitled and obliged to transmit all personal data at its legal disposal to the competent authorities, as required by law. data controller is not liable for such data transmission or the consequences thereof.
  7. Cookies és web beacons
    1. If you wish to use our Application from a desktop, or if you would like to have more information about our Application, please visit our Website.
    2. As data controllers, for the pusposes offering your customized services, we use so-called cookies, which are small data packeges placed by our Webiste on our user’s device. The aim of the cookie is to ensure a higher quality of our service through improving our user experience. By visiting our Website, you may grant us your voluntary consent to store cookies on your device and for us to access it, according to our Cookie Policy. For more information please check our Cookie Policy here
    3. We use Google Analytics, Google Adwords and Facebook-tracking through our website and our Application. To know more about data management and data processing regarding these, please check the relevant privacy policies. Our company is in no way liable for these tools.
  8. Security measures
    1. Our company takes utmost care while managing and storing your personal data. Regarding information security, we apply the most efficient and modern tools and procedures, reasonably available to us.
    2. We design and perform our data management operations in a way to ensure the protection of the privacy of our data subjects.
    3. Both the data controller and the data processor within the scope of its assigned task shall ensure the security of the data, and shall performa any and all technical and organizational measures, and shall create such processes and policies, which are necessary by law.
    4. We collect, manage, and store your data in compliance with the necessary security policies and processes, in order to prevent any unauthorized access to them. We may only reveal your data to our own employees, contractors and representatives if necessary.
    5. Unfortunately the information flow on the internet is not completely safe. Electronic messages are volnurable to web threats, irrespective of the used protocol (email, web, ftp, etc.), which may lead to fraudulant activity, uncovering or modifying information. Although we do everything we can to protect your data, by monitoring our systems and recording the security derogations, we cannot guarantee the security of your data, so please only upload data at your own risk. When we receive your data, we subject them to strict security procedures in order to prevent unauthorized access. Nonetheless, the internet is known by the Users to be unsafe. We are not liable for any damagest hat may emerge from attacks we are unable to prevent notwithstanding the expected care from our company.
  9. The rights of Users as data subjects
    1. In case of any changes to your personal data or should you wish to request to delete your personal data from our records, please send your queiries to us in writing via your registered email address or by postal mail. The original data after the modification or the deletion of the data may be restored until one year of the performance of the request. When we receive your request to delete your personal data, you will be provided an identification code by email. You may reactivate your account by sending us an email with your request to reactivate the account and your personal identification code to the following email: Please note that we are unable to restore your personal data after the expiry of the one-year deadline.
    2. You may request information pertaining to your personal data. Only requests through the user’s registered email address will qulaify as authentic requests. At your request, we provide you with information about the personal data that we and on our behalf our data processors process, their sources; the purposes, the cause and the period of the data processing; the name, address, of the data processor and their relevant activities, and in case of data transmission, the cause and the addressee of the data transmission. Please send your request for information to the following email address:
    3. We shall provide you with the information requested upon your request as soon as possible but no later than 25 days from the query, in plain written language. This will be free of charge, unless you have already submitted a request pertaining to the same set of data in the current year. In such instances and others, we may charge a service fee.  We shall reimburse the service fee, in case it is established that we processed your data illegally or the request for information led to a data correction.
    4. We shall only deny your your request for information for reasons prescribed by law. In case we deny your request, we shall notify you in writing of the precise legal grounds. In case we deny your request, we shall notify you of the possible legal remedies available to you, and the legal possibility for you to turn to the National Data Protection and Freedom of Information Authority (hereinafter referred to as ’Authority’). We shall notify the Authority of the denied requests annually by the 31st of January of the following year at the latest.
    5. You may request for is to correct, to delete or to block your personal data, except mandatory data processing.
    6. If the personal data are not accurate, and the accurate personal data are at our disposal, we may correct the data provided.
    7. In case you contest the accuracy or the correctness of the personal data, but should it prove difficult to prove its incorrectness and inaccuracy, we shall mark it.
    8. In case we deny your request to correct, bloc kor to delete, we shall notify you within 25 days of the receipt of your request about the reasons and the legal grounds for doing so. We shall also notify you of the legal remedies available to you as wall as the option to turn to the competent Authority.
    9. You may object to our data processing of your personal data in the following cases:
      1. if the sole purpose of data processing or data transmission is for the data controller to perform its legal obligations or to serve the legitimate interest of the data controller, the data importer or any third person, except mandatory data processing;
      2. if the the personal data is used or transmitted for the purposes of direct marketing, public opinion survey or scientific research; and
      3. for any other reason prescribed by law. 
    10. We shall examine your objection within the shortest time possible but maximum within 15 days, and make a decision on its justification and notify you in writing. If the data controller verify the justification of your objection, we shall cease the data processing, including future data recording and transmission, and we shall block the data, and notify thereof any other persons involved with the personal data transmitted to them previously, and who are obliged to take measures pertaining to your right to object. If you do not agree with our decision, or in case we miss our deadline, you are entitled to seek legal remedy before a court within 30 days of the last day of our deadline.
    11. We may not delete your personal data, if their processing is mandatory by law.
    12. We shall be liable to compensate any damages caused by illegal data processing or by any security infringement. We shall also be liable to compensate you on behalf od our data processors. We shall be exempted from liability if we prove that the damage was caused by circumtances outside of the scope of the data processing. We shall not be obliged to recompensate the damages, if these were caused by the injured party intentionally or with negligence.
  10. Quiries and Remedies
    1. Please forward your questions and queries to us to the following email address:
    2. As a data subject, you may seek remedy against the Data controller before a judicial court. Tribunals have competence over the legal dispute. The legal proceedings may be initiated by the data subject before a competent tribunal based on the data subject’s permenant or temporary residence, according to the data subject’s choice.
    3. Formal complaints and requests for remedies may be submitted to the following Authority:
      Name: National Authority for Data Protection and Freedom of Information
      mailing address: 1530 Budapest, Pf.: 5. 
      seat: 1125 Budapest Szilágyi Erzsébet fasor 22/c 
      Phone no.: +36 (1) 391-1400 
      Fax: +36 (1) 391-1410