Privacy Policy

iCare Debrecen (hereinafter: the Data Controller) is committed to protecting the personal data of its website visitors and customers. This Privacy Policy is based on Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR) and on Hungarian Act CXII of 2011 on the Right of Informational Self-Determination and Freedom of Information (Infotv.).

1. Data Controller details

• Company name: AppTrade Kft. (trading as iCare Debrecen)
• Registered office / store: 4029 Debrecen, Csapó utca 54.
• Company registration number: 15-09-088096
• Tax number: 28984940-2-15
• Phone: +36 30 817 8178
• Email: info@icaredebrecen.hu
• Website: icaredebrecen.hu

2. Purposes of data processing

Our company provides specialist Apple repair services and iPhone buyback. In the course of this, we process our customers’ personal data for the following purposes:

• Creating and managing repair work orders
• Customer identification
• Communication (phone, email, SMS)
• Repair status updates
• Warranty administration
• Invoicing and accounting
• Handling buyback quotes and payments
• Fulfilling legal obligations
• Managing Apple IRP (Independent Repair Provider) processes — registering genuine Apple parts, GSX service administration
• Producing educational and marketing content (under clause 3.8 of the Terms & Conditions, with the customer’s consent)

3. Categories of data processed

3.1. Customer data

• First and last name
• Phone number
• Email address
• Billing name and address
• Tax number (for business customers)
• Shipping address (for buyback when using a courier)

3.2. Device data

• Device type and model
• IMEI / serial number
• Fault description and symptoms
• Repair history
• Diagnostic results
• List of parts used during the repair

3.3. Communication data

• Content of email correspondence
• Text and timestamps of SMS notifications
• Summaries of phone communication (recorded on the work order)

3.4. Security and operational data

• CCTV footage of the store premises (for property protection)
• Work orders and signatures
• Video and photo recordings of the repair process (for educational / marketing purposes, under clause 3.8 of the Terms & Conditions)

4. Legal basis and duration of processing

Purpose of processing	Legal basis (GDPR)	Retention period
Performance of the repair / buyback contract	Art. 6(1)(b) – performance of a contract	5 years after the contract ends (limitation period under the Hungarian Civil Code)
Retention of accounting records	Art. 6(1)(c) – legal obligation (Hungarian Accounting Act, Section 169)	8 years
Apple IRP / GSX administration	Art. 6(1)(b) and (c) – contract and legal obligation	Retention period of the repair documentation (5 years)
Responding to enquiries and quote requests	Art. 6(1)(f) – legitimate interest	1 year after the enquiry
CCTV footage (property protection)	Art. 6(1)(f) – legitimate interest	Maximum 30 days, or until any legal dispute is resolved
Video/photo recordings of repairs (education, marketing)	Art. 6(1)(a) – consent	Until consent is withdrawn, for the time the content is published
Newsletter (if you subscribed)	Art. 6(1)(a) – consent	Until consent is withdrawn

5. Data processors

We use the following data processors:

5.1. Service management system

• RepairDesk (RepairDesk Inc., United States and/or United Kingdom)
  Role: Storing customer and repair data, managing work orders, repair process communication, sending SMS/email notifications.
  Website: repairdesk.co

5.2. Apple IRP / GSX system

• Apple Distribution International Ltd. (Hollyhill Industrial Estate, Hollyhill, Cork, Ireland)
  Role: Registering genuine Apple parts, GSX service administration, officially recording repairs in Apple’s global service system.
  Website: apple.com/legal

5.3. Hosting and website services

• Rackhost Zrt. (6722 Szeged, Tisza Lajos körút 41., tax number: 25333572-2-06) – hosting, website hosting
• FormSubmit (formsubmit.co) – forwarding quote request forms
• Google Ireland Ltd. – the embedded Google Map on the Contact page

5.4. Other data processors

• Accounting firm – for fulfilling accounting obligations (name under confirmation; the specific partner is named in the accounting contract)
• Courier service – during buyback, if the device is sent by courier; the specific partner is named when the individual order is placed

6. International data transfers

Some data processors (in particular RepairDesk) may also process data in countries outside the European Union (e.g. the United States, the United Kingdom). Such transfers take place with appropriate safeguards:

• by applying the Standard Contractual Clauses (SCC) approved by the European Commission,
• or by other compliance mechanisms under Chapter V of the GDPR.

The Apple IRP / GSX system operates within the European Union (Ireland), so no international data transfer takes place for this processing.

7. Cookies

The website uses technically essential cookies required for its basic operation (e.g. storing your cookie consent status). The Contact page contains an embedded Google Map, which may set third-party cookies — but only once you actively use the map. We only place marketing or analytics cookies with your separate consent. You can block or delete cookies at any time in your browser settings.

8. Video and photo recordings

Under clause 3.8 of the Terms & Conditions, the Service Provider may record video or photos of the fault symptoms and the repair process of a device handed in for repair, for educational, professional and marketing purposes. In these recordings:

• The device’s unique identifiers (IMEI, serial number) are not shown, or are made unrecognisable.
• The customer’s personal data (screen content, photos, messages, accounts) may not appear.
• Only the fault symptoms, the parts and the repair operations are visible.

By signing the repair work order, the customer gives prior consent to these recordings. If you do not wish recordings to be made, you must state this in writing when handing in the device.

9. Customer obligations

Before handing in the device, the customer must:

• Back up the data stored on the device,
• Turn off Find My where necessary,
• Sign out of the Apple ID / iCloud account (mandatory for buyback),
• Handle any sensitive data stored on the device at their own responsibility.

The Service Provider accepts no liability for:

• Pre-existing data loss,
• Data loss resulting from hidden faults,
• Software damage,
• Issues caused by third-party applications.

10. Your rights as a data subject

Under the GDPR, you have the following rights:

• Right to be informed – access to the data we process about you
• Right to rectification – correction of inaccurate data
• Right to erasure (the “right to be forgotten”)
• Right to restriction of processing
• Right to data portability
• Right to object to processing based on legitimate interest
• Right to withdraw consent – withdrawal does not affect the lawfulness of prior processing. Consent can be withdrawn by email at info@icaredebrecen.hu.

Jogaidat az info@icaredebrecen.hu címen vagy postai úton (4029 Debrecen, Csapó utca 54.) gyakorolhatod. A megkeresésre legkésőbb 30 napon belül válaszolunk.

11. Legal remedies

If you believe your personal data is not being handled properly, you may lodge a complaint with:

• The Hungarian National Authority for Data Protection and Freedom of Information (NAIH)
  1055 Budapest, Falk Miksa utca 9-11.
  Postal address: 1363 Budapest, Pf. 9.
  Phone: +36 1 391 1400 · Email: ugyfelszolgalat@naih.hu · naih.hu
• You may also bring the matter before the regional court of your place of residence or stay.

12. Amendments and final provisions

The Data Controller reserves the right to amend this Privacy Policy unilaterally. The amended version takes effect upon publication on the website. The current version is always available on the website or in our store.

13. Version history

Every amendment to this Privacy Policy is published with a new version number and a new effective date.

This document is for information purposes. It is recommended to have it reviewed by a data protection expert or lawyer before going live.