Privacy Policy
How we handle your personal data under the GDPR.
Machine-translated version
The Hungarian text is the legally binding version of this document. The English version below is provided for convenience only and may contain inaccuracies introduced by automatic translation.
If anything is unclear, please contact us at [email protected] before booking.
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Last updated: September 24, 2026
FASTBACK Kft.
Privacy Policy
Introduction
FASTBACK Kft. (1164 BUDAPEST, 80, tax ID: 23334474-2-42, company registration number: 0109960652) (hereinafter: Service Provider, Data Controller) processes personal data in accordance with the provisions set forth in this notice.
REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL OF 27 APRIL 2016 ON THE PROTECTION OF NATURAL PERSONS WITH REGARD TO THE PROCESSING OF PERSONAL DATA AND ON THE FREE MOVEMENT OF SUCH DATA, AND REPEALING DIRECTIVE 95/46/EC (General Data Protection Regulation) REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016, we provide the following information.
This Privacy Policy governs the processing of personal data on the following websites and mobile applications: https://atlaszrent.hu, https://atlaszrent.com, https://atlaszkaland.hu, https://atlaszkaland.com
The privacy notice is available at the following URLs: https://atlaszrent.hu/hu/adatvedelem and https://atlaszrent.hu/en/privacy
Amendments to the policy take effect upon publication at the above addresses.
The Data Controller and Contact Information
Name: FASTBACK Kft.
Registered office: 1164 BUDAPEST, 80
Email: [email protected]
Phone: +36304382323, +36309144140
Definitions
- “Personal data”: any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person;
- “data processing”: any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction;
- “data controller”: a natural or legal person, public authority, agency, or any other body that, alone or jointly with others, determines the purposes and means of the processing of personal data; if the purposes and means of data processing are determined by Union or Member State law, Union or Member State law may also determine the controller or the specific criteria for designating the controller;
- “data processor”: a natural or legal person, public authority, agency, or any other body that processes personal data on behalf of the data controller;
- “recipient”: a natural or legal person, public authority, agency, or any other body to whom or which personal data is disclosed, whether or not that entity is a third party. Public authorities that have access to personal data in the context of a specific investigation in accordance with Union or Member State law are not considered recipients; the processing of such data by those public authorities must comply with the applicable data protection rules in accordance with the purposes of the processing;
- “consent of the data subject”: a voluntary, specific, and adequate information, by which the data subject, through a statement or a clear affirmative action, indicates his or her consent to the processing of personal data concerning him or her;
- “data breach”: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or unauthorized access to, personal data transmitted, stored, or otherwise processed.
- “profiling”: any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to evaluate work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movement;
- “third party”: a natural or legal person, public authority, agency, or any other body that is not the data subject, the data controller, the data processor, or persons authorized to process personal data under the direct authority of the data controller or data processor.
Principles Governing the Processing of Personal Data
Personal data:
- must be processed lawfully, fairly, and in a manner that is transparent to the data subject (“lawfulness, fairness, and transparency”);
- be collected only for specified, explicit, and legitimate purposes and not processed in a manner incompatible with those purposes; in accordance with Article 89(1), further processing for archiving in the public interest, scientific or historical research purposes, or statistical purposes shall not be considered incompatible with the original purpose (“purpose limitation”);
- the purposes of data processing must be appropriate and relevant to the purposes of the processing and must be limited to what is necessary (“data minimization”);
- they must be accurate and, where necessary, kept up to date; all reasonable measures must be taken to ensure that personal data that are inaccurate in relation to the purposes of the processing are erased or rectified without delay (“accuracy”);
- they must be stored in a form that permits identification of data subjects only for as long as is necessary to fulfill the purposes for which the personal data are processed; personal data may be stored for a longer period only if the processing is carried out in accordance with Article 89(1) for archiving purposes in the public interest, for scientific or historical research purposes, or for statistical purposes, in accordance with Article 89(1), while also taking into account the implementation of appropriate technical and organizational measures required by this Regulation to protect the rights and freedoms of data subjects (“limited storage”);
- processing must be carried out in such a manner that, through the application of appropriate technical or organizational measures, the security of the personal data is ensured, including protection against unauthorized or unlawful processing, accidental loss, destruction, or damage (“integrity and confidentiality”).
The data controller is responsible for compliance with the above and must be able to demonstrate such compliance (“accountability”).
The data controller declares that its data processing is carried out in accordance with the principles set forth in this section.
Car Rental Reservations
1. The fact of data collection, the scope of the data processed, and the purpose of data processing:
Personal data | Purpose of data processing | Legal basis |
Name, email address, phone number | Identification, communication | Article 6(1)(b) of the GDPR. |
Reservation-related data (vehicle type, pickup and drop-off dates and times, add-ons) | Performance of a contract | Article 6(1)(b) of the GDPR. |
Billing information | Issuance of a valid invoice | Article 6(1)(c) of the GDPR. (Legal obligation: Section 169(2) of Act C of 2000 on Accounting) |
Date of reservation | Performance of a technical operation. | Article 6(1)(b) of the GDPR. |
IP address at the time of booking | Performance of a technical operation. | Article 6(1)(b) of the GDPR. |
2. Data subjects: All data subjects who book an appointment on the website.
3. Duration of data processing and deadline for erasure: Data processing continues until an offer is made; or, if any of the conditions set forth in Article 17(1) of the GDPR apply, until the data subject requests erasure. The data controller shall notify the data subject electronically of the erasure of any personal data provided by the data subject, in accordance with Article 19 of the GDPR. If the data subject’s request for erasure also extends to the email address provided by them, the data controller will also erase the email address following the notification. This does not apply to accounting documents, as these must be retained for 8 years pursuant to Section 169(2) of Act C of 2000 on Accounting. The data subject’s contractual data may be deleted upon the expiration of the civil statute of limitations, based on the data subject’s request for deletion.
Accounting documents directly and indirectly supporting the accounting entries (including general ledger accounts, analytical records, and detailed records) must be retained in a legible form for at least 8 years, in a manner that allows them to be retrieved based on references in the accounting records.
4. Identities of potential data controllers authorized to access the data and recipients of personal data: Personal data may be processed by the data controller’s authorized employees.
5. Description of the data subjects’ rights regarding data processing:
- The data subject may request from the data controller access to their personal data, the rectification or erasure of such data, or the restriction of its processing, and
- the data subject has the right to data portability and to withdraw consent at any time.
6. The data subject may request access to, erasure of, or correction of their personal data, or restriction of its processing, as well as data portability, in the following ways:
- by mail at 1164 BUDAPEST, 80,
- by email at [email protected],
- by phone at +36304382323 or +36309144140.
7. Please be advised that
- data processing is necessary for making a reservation.
- You are required to provide your personal information so that we can record the car rental period.
- Failure to provide this information will result in our inability to provide the vehicle during the requested time period.
Data Processing Related to the Use of Services (Car Rental)
- The fact of data collection, the scope of the data processed, and the purpose of data processing:
Personal data | Purpose of data processing | Legal basis |
Last name and first name | Necessary for establishing contact, using the service, and issuing a valid invoice. | Article 6(1)(b) of the GDPR |
Email address, phone number | To maintain contact. | |
Other data included in the lease agreement | Performance of the service | |
Billing name and address | Issuing a valid invoice, as well as creating the contract, determining its content, amending it, monitoring its performance, invoicing the resulting fees, and enforcing related claims. | Article 6(1)(c) of the GDPR (Legal obligation: Section 169(2) of Act C of 2000 on Accounting) |
Neither the username nor the email address is required to contain personal data.
2. Scope of data subjects: All data subjects who use car rental services.
3. Duration of data processing and deadline for erasure: If any of the conditions set forth in Article 17(1) of the GDPR apply, data will be retained until the data subject requests erasure. The data controller shall notify the data subject electronically of the erasure of any personal data provided by the data subject, in accordance with Article 19 of the GDPR. If the data subject’s request for erasure also extends to the email address provided by them, the data controller shall erase the email address as well following the notification. This does not apply to accounting records, however, as these data must be retained for 8 years pursuant to Section 169(2) of Act C of 2000 on Accounting. The data subject’s contractual data may be deleted upon the expiration of the civil statute of limitations, based on the data subject’s request for deletion.
Accounting documents that directly or indirectly support the bookkeeping entries (including general ledger accounts, as well as analytical and detailed records) must be retained in a legible form for at least 8 years, in a manner that allows them to be retrieved based on references in the accounting records.
4. Identities of potential data controllers authorized to access the data and recipients of personal data: Personal data may be processed by the data controller’s sales and marketing staff, in accordance with the above principles.
5. Description of the data subjects’ rights regarding data processing:
- The data subject may request from the data controller access to their personal data, the rectification or erasure of such data, or the restriction of its processing, and
- the data subject has the right to data portability and to withdraw consent at any time.
6. The data subject may request access to, erasure of, or correction of personal data, or the restriction of its processing, as well as data portability, in the following ways:
- by mail to 1164 BUDAPEST, 80,
- by email at [email protected],
- by phone at +36304382323 or +36309144140.
7. Please be advised that
- data processing is necessary for the performance of the contract and for providing a quote.
- You are required to provide your personal data so that we can fulfill your order.
- Failure to provide this information will result in our inability to process your order.
Customer Relations
1. The fact of data collection, the scope of the data processed, and the purpose of data processing:
|
Personal Data |
Purpose of data processing |
Legal basis |
|
Name, email address, phone number. |
Communication, identification, performance of contracts, business purposes. |
Article 6(1)(b). |
2. Scope of data subjects: All data subjects who contact the data controller by phone, email, or in person, or who are in a contractual relationship with the data controller.
3. Duration of data processing and deadline for erasure: Letters containing inquiries are retained until the data subject requests erasure, but for no longer than 2 years.
4. Identities of potential data controllers authorized to access the data and recipients of personal data: Personal data may be processed by the data controller’s authorized employees, in accordance with the above principles.
5. Description of the data subjects’ rights regarding data processing:
- The data subject may request from the data controller access to, rectification of, erasure of, or restriction of the processing of personal data concerning him or her, and
- the data subject has the right to data portability and to withdraw consent at any time.
6. The data subject may request access to, erasure of, or correction of their personal data, as well as a restriction on the processing of such data or data portability, in the following ways:
- by mail at 1164 BUDAPEST, 80,
- by email at [email protected],
- by phone at +36304382323 or +36309144140.
7. Please be advised that
- data processing is necessary for the performance of the contract and for submitting an offer.
- You are required to provide your personal data so that we can fulfill the contract or process your other request.
- Failure to provide your personal data will result in our inability to fulfill the contract or process your request.
B2B Customer Relationship Data Processing
This section governs the processing of contact information for natural persons (data subjects) acting on behalf of the data controller’s business partners or other clients.
1. The fact of data collection, the scope of data processed, and the purpose of data processing:
Personal Data | Purpose of data processing | Legal basis |
Name, email address, phone number, and other contact information specified in the contract. | Maintaining contact, cooperation, entering into a contract, and fulfilling rights and obligations arising from the contract. | For legal entities: Article 6(1)(f) (legitimate interests of the data controller), In the case of sole proprietors: Article 6(1)(b). |
2. Source of the data:
- For legal entities: the data subject’s personal data is provided by the data controller’s business partner.
- In the case of sole proprietors and natural persons: directly from the data subject.
3. Scope of data subjects: All data subjects in a contractual relationship with the data controller, as well as natural persons acting on behalf of the data controller’s business partners.
4. Duration of data processing and deadline for erasure: Data processing continues until the termination of the legal relationship between the data controller and the business partner, or, in the case of claims, until the statute of limitations expires.
5. Identities of potential data controllers entitled to access the data, and recipients of personal data: Personal data may be processed by the data controller’s authorized employees, in accordance with the principles outlined above.
6. Description of the data subjects’ rights regarding data processing:
- The data subject may request from the data controller access to, rectification of, erasure of, or restriction of the processing of personal data concerning him or her, and
- the data subject has the right to data portability,
- Natural persons acting on behalf of legal entities may object to the processing of their personal data.
7. The data subject may request access to, erasure of, modification of, or restriction on the processing of personal data, as well as data portability, in the following ways:
- by mail at 1164 BUDAPEST, 80,
- by email at [email protected],
- by phone at +36304382323 or +36309144140.
8. Legal basis for data processing:
- For natural persons acting on behalf of legal entities: Article 6(1)(f) of the GDPR. Specification of the legitimate interest: cooperation, performance of a contract, business purposes.
- For sole proprietors and natural persons: Article 6(1)(b) of the GDPR.
- In the case of enforcing claims arising from a contract, 5 years pursuant to Section 6:21 of Act V of 2013 on the Civil Code.
Section 6:22 [Statute of Limitations]
(1) Unless otherwise provided by this Act, claims become time-barred after five years.
(2) The statute of limitations begins to run when the claim becomes due.
(3) Any agreement to modify the statute of limitations period must be in writing.
(4) Any agreement that excludes the statute of limitations is void.
9. Please be advised that
- data processing is based on the contract or the data controller’s legitimate interest.
- contact information is provided by the data controller’s business partner,
- failure to provide data
- in the case of legal entities, this may result in difficulties in the performance of the contract, the exercise of rights arising from the contract, the fulfillment of obligations, and cooperation between the contracting parties.
- In the case of natural persons, this results in our inability to enter into a contractual relationship.
- The data controller conducted a balancing test regarding the processing of personal data of natural persons acting on behalf of legal entities, as a result of which it was determined that the data subject’s interests or fundamental rights and freedoms, which would necessitate the protection of personal data, do not take precedence over the data controller’s legitimate interests.
Use of Cookies
1. The use of so-called “cookies used for password-protected sessions,” “cookies necessary for the shopping cart,” “security cookies,” “necessary cookies,” “functional cookies,” and “cookies responsible for managing website statistics” do not require prior consent from data subjects.
2. Fact of data processing, scope of processed data: Unique identification number, dates, times.
3. Scope of data subjects: All data subjects visiting the website.
4. Purpose of data processing: To identify users, track visitors, and ensure a personalized experience.
5. Duration of data processing and deadline for data deletion:
Cookie Type | Legal basis for data processing | Duration Duration |
Session cookies or other cookies essential for the website’s operation | No data processing occurs through the use of cookies. | The period lasting until the end of the relevant visitor session; thus, the cookie remains on the computer only until the browser is closed. |
Statistical and marketing cookies | Article 6(1)(a) of the GDPR | Data processing lasts for 1 day to 2 years, as specified in the cookie notice, or until the data subject withdraws their consent. |
Other cookies used on the site:
| Name / Identifier | Purpose | Category | Duration |
|---|---|---|---|
| cookie_consent | Stores your cookie settings. | Essential | 1 year |
| fastback_pickup, fastback_dropoff | Saves the selected pickup and drop-off dates across navigation, page refreshes, and new tabs so the calendar doesn't reset. | Basic | 30 days |
| fastback_booking_details, fastback_booking_details_consent (localStorage) | If checked, it saves your contact and billing information so that the next booking form is pre-filled. | Essential | Persistent (until you delete it) |
| legal.cookies.cookies.wizardStateName | Stores the state of the booking wizard form so that a page refresh or language change does not lose the booking in progress. | Essential | Session (up to 1 hour) |
| scrollToBooking, autoOpenPicker (sessionStorage) | Short-lived navigation flags that scroll to the booking section or automatically open the date picker after a redirect. | Basic | Session |
| fastback_recent_booking_v1 (localStorage) | Stores the ID of a recently created booking and your email address so we can notify you if the confirmation email cannot be delivered. Contains the email address. | Functional | 30 minutes |
| Error reporting | Sends error reports to our server to ensure the reliability of the website. | Basic | No storage (activated in case of an error) |
| Google Maps (address autocomplete + embedded map) | Powered the address autocomplete on the booking form and the embedded map on the contact page. It only loads if you accept third-party services. | Third Party | Determined by Google; see Google’s Privacy Policy. |
| Stripe | Processes online credit card payments. Loads only on the payment page and only after you accept the third-party services. | Third Party (Payment) | Determined by Stripe; see Stripe’s Privacy Policy. |
| __cf_bm, cf_clearance | Bot protection and security verification cookies set by Cloudflare, which sits in front of the website. | Essential (security) | 30 minutes / 30 days |
| _ga, _ga_<id> - Google Analytics 4 | traffic and usage measurement | Analytics | 2 years |
| _gcl_au - Google Ads | Conversion tracking and remarketing | Marketing | 90 days |
| _fbp, _fbc - Meta (Facebook) Pixel | Measuring Facebook/Instagram ads and remarketing | Marketing | 90 days |
6. Description of data subjects’ rights regarding data processing: Data subjects have the option to delete cookies in their browsers’ Tools/Settings menu, typically under the Privacy settings.
7. Most browsers used by our users allow you to configure which cookies should be saved and enable you to delete (specific) cookies. If you restrict the storage of cookies on specific websites or do not allow third-party cookies, this may, under certain circumstances, result in our website no longer being fully usable. Here you’ll find information on how to customize cookie settings in common browsers:
Google Chrome (https://support.google.com/chrome/answer/95647?hl=hu)
Microsoft Edge (https://support.microsoft.com/...)
Firefox (https://support.mozilla.org/hu/kb/sutik-engedelyezese-es-tiltasa-amit-weboldak-haszn)
Safari (https://support.apple.com/hu-hu/guide/safari/sfri11471/mac)
Use of Google Ads Conversion Tracking
- The data controller uses the online advertising program called “Google Ads” and, within that framework, utilizes Google’s conversion tracking service. Google conversion tracking is an analytics service provided by Google Ireland Limited (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”).
- When a User accesses a website via a Google ad, a cookie required for conversion tracking is placed on the User’s computer. These cookies have a limited validity period and do not contain any personal data, so the User cannot be identified through them.
- When the User browses certain pages of the website and the cookie has not yet expired, both Google and the data controller can see that the User clicked on the ad.
- Each Google Ads customer receives a different cookie, so these cookies cannot be tracked across the websites of Ads customers.
- The information—collected using conversion tracking cookies—is used to generate conversion statistics for Ads clients who have opted in to conversion tracking. This allows clients to see how many users clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not have access to any information that could be used to identify individual users.
- If you do not wish to participate in conversion tracking, you can opt out by disabling cookies in your browser. You will then no longer be included in conversion tracking statistics.
- Based on Google Consent Mode v2, Google also uses two new types of cookies: ad_user_data and ad_personalization, which are based on the user’s consent and pertain to the use and sharing of data. The ad_user_data cookie is used to grant consent for Google to use user data for advertising purposes. The ad_personalization cookie determines whether the data may be used to personalize ads (e.g., remarketing). The data controller ensures that the appropriate consents are obtained and revoked via its cookie banner or panel. Withdrawal of consent does not affect the lawfulness of data processing based on consent that occurred prior to the withdrawal.
- Further information and Google’s Privacy Policy are available at the following link: https://policies.google.com/privacy
Use of Google Analytics
- This website uses Google Analytics, a web analytics service provided by Google Ireland Limited (“Google”). Google Analytics uses so-called “cookies,” which are text files stored on your computer, to help analyze your use of the website you are visiting.
- The information generated by the cookies regarding your use of this website is typically transmitted to and stored on a Google server in the United States. By enabling IP anonymization on the website, Google truncates the User’s IP address beforehand within the member states of the European Union or in other states party to the Agreement on the European Economic Area.
- The full IP address is only transmitted to a Google server in the U.S. and shortened there in exceptional cases. On behalf of the operator of this website, Google will use this information to evaluate how the User has used the website, to compile reports for the website operator regarding website activity, and to provide other services related to website and Internet usage.
- Within the framework of Google Analytics, the IP address transmitted by the User’s browser is not associated with any other data held by Google. The User can prevent the storage of cookies by adjusting the settings in their browser; however, please note that in this case, not all features of this website may be fully available. You can also prevent Google from collecting and processing data related to your use of the website (including your IP address) via cookies by downloading and installing the browser plugin available at the following link. https://tools.google.com/dlpage/gaoptout?hl=hu
Meta Pixel
The Meta pixel is a piece of code that enables the website to generate reports on conversions, create target audiences, and provide the website owner with detailed analytics on how visitors use the site. Using the Meta remarketing pixel tracking code, you can display personalized offers and ads to website visitors on Facebook. The Meta remarketing list cannot be used to identify individuals. For more information about the Meta Pixel, visit: https://www.facebook.com/business/help/651294705016616
Facebook Remarketing
1. The fact of data collection, the scope of the data processed, and the purpose of data processing:
Personal Data |
Purpose of data processing |
Legal basis |
Email address |
Remarketing, display of targeted ads by Facebook. |
Consent of the data subject, Article 6(1)(a). Section 6(5) of Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Commercial Advertising. |
2. Scope of data subjects: All data subjects who consent to Facebook remarketing and the display of targeted advertisements.
3. Purpose of data processing: The targeted display of content containing advertisements to the data subject.
4. Duration of data processing and deadline for erasure of data: Data processing continues until consent is withdrawn.
5. Description of the data subjects’ rights regarding data processing:
- The data subject may request from the data controller access to, rectification of, erasure of, or restriction of the processing of personal data concerning them, and
- the data subject has the right to data portability and to withdraw consent at any time.
6. The data subject may request access to personal data, its erasure, rectification, or restriction of processing, data portability, or the right to object in the following ways:
- by mail at 1164 BUDAPEST, 80,
- by email at [email protected],
- by phone at +36304382323 or +36309144140.
7. Please be advised that
- the withdrawal of consent does not affect the lawfulness of data processing based on consent prior to the withdrawal.
Recipient’s name: Facebook Inc., Address: 1601 Willow Road, Menlo Park, CA 94025, United States
Data processors used
Hosting provider
1. Activity performed by the data processor: Hosting service
2. Name and contact information of the data processor:
Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany, +49 (0)9831 505-0
3. Fact of data processing and scope of data processed: All personal data provided by the data subject.
4. Data subjects: All data subjects who use the website/mobile app.
5. Purpose of data processing: To make the website/mobile app available and to ensure its proper operation.
6. Duration of data processing and deadline for erasure: Data processing continues until the termination of the agreement between the data controller and the hosting provider, or until the data subject submits a request for erasure to the hosting provider.
7. Legal basis for data processing: Article 6(1)(c) and (f), as well as Act CVIII of 2001 on Electronic Commerce Services and Section 13/A(3) of Act CVIII of 2001 on Certain Issues Related to Information Society Services. The legitimate interest is the proper operation of the website and protection against attacks and fraud.
Other data processors (if any)
Brevo — Sendinblue SAS 106 Boulevard Haussmann, 75008 Paris, France, [email protected] sending transactional emails (booking confirmations, reminders, administrative notifications) / Számlázz.hu KBOSS.hu Kft. 1031 Budapest, Záhony utca 7. (Graphisoft Park) [email protected] issuing electronic invoices (mandatory data reporting to the National Tax and Customs Administration) / Google Ireland Limited (Google Maps Platform) Gordon House, Barrow Street, Dublin 4, Ireland (address autocomplete in the booking form—opt-in, only if the user agrees) / Innorado Limited, 14 Glenburn Place, Papakura, 2110, New Zealand, [email protected] (system operation) / Stripe Payments Europe Ltd. - 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland - processing of card payments (reservation deposit and final balance). Data controller within the EEA; during certain support functions, data may be transferred to Stripe Inc. (USA) under the EU Standard Contractual Clauses (SCCs). / Cloudflare, Inc. - 101 Townsend St, San Francisco, CA 94107, USA — CDN, DDoS protection, security services. Data may be transferred to the U.S.; the legal basis for the data transfer is the Standard Contractual Clauses (SCCs) adopted by the European Commission. Cloudflare’s Privacy Policy: https://www.cloudflare.com/privacypolicy/
Social Media Platforms
The data controller is also present on social media platforms in order to showcase its services and maintain contact with interested parties and customers.
Scope of data processed: Data publicly available on the data subject’s social media profile, specifically:
– name (username)
– public profile picture
– interactions posted by the data subject or related to the data controller’s page (e.g., comments, messages).
Scope of data subjects: Natural persons who follow the data controller’s social media page, interact with it, or send messages through it.
Purpose of data processing:
– to present the data controller’s activities and services,
– marketing and communication on social media platforms,
– maintaining contact with interested parties and customers.
Legal basis for data processing: The data subject’s voluntary consent to the processing of their personal data on social media platforms.
Duration of data processing: Data processing continues for as long as the data subject’s interaction persists or until the content posted by the data subject is deleted. The data controller retains messages and communications for up to 2 years.
Additional data controllers: Social media platforms act as independent data controllers and process users’ data in accordance with their own privacy policies.
Facebook / Meta Joint Data Control
The data controller maintains a Facebook / Meta profile related to this activity. Data processing for statistical purposes carried out on the Facebook social media platform is a joint data processing activity between the data controller and Facebook Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, D2 Dublin, Ireland). Detailed information on the joint data processing agreement is provided in the Data Controllers’ Addendum for the Facebook Page Insights feature. The addendum is available
at the following link: https://www.facebook.com/legal/terms/page_controller_addendum
The Data Controller will communicate with you via private message on the social media platform only if you contact us there.
1. Categories of Data Subjects
- data subjects who have registered on the social media site and “liked” the Data Controller’s profile page,
- Data subjects who contact the Data Controller via private message on the social media platform.
2. Purpose of Data Processing
The purpose of data processing is to share and promote the Data Controller’s activities and services on the Facebook social media platform. The Data Controller may use the data provided by the data subject in a private message to respond to the message; otherwise, the Data Controller does not collect data through social media platforms nor does it extract data from them.
3. Legal Basis for Data Processing
Data processing is based on Article 6(1)(a) of the GDPR; the legal basis for data processing is the data subject’s consent to the processing of their personal data on the Facebook social media platform.
4. Scope of Processed Data
- the data subject’s registered name,
- the data subject’s public profile picture
- other public data provided or shared by the data subject on the social media platform
5. Source of the processed personal data: The source of the processed data is the data subject.
6. Withdrawal of Consent: You may withdraw your consent to data processing at any time and delete your posts and comments. Data processing takes place through social media sites operated by third parties
. If you withdraw your consent, the Data Controller will delete the conversation with you. Withdrawal of consent does not affect the lawfulness of data processing based on consent prior to the withdrawal.
You, as the data subject, may request access to your personal data, its erasure, rectification, or restriction of processing, as well as data portability, in the following ways:
- by mail at 1164 BUDAPEST, 80,
- by email at [email protected],
- by phone at +36304382323 or +36309144140.
7. Duration of data processing
- until the data subject withdraws their consent,
- or, if correspondence takes place, for 2 years.
8. Transfer of personal data, recipients, and categories of recipients: For the definition of “recipient,” see Article 4(9) of the GDPR. The Data Controller shall transfer the Data Subject’s personal data to state bodies and authorities—including, in particular, courts, the public prosecutor’s office, investigative authorities, administrative offense authorities, and the National Authority for Data Protection and Freedom of Information—only in exceptional cases and in accordance with legal obligations.
9. Possible Consequences of Failure to Provide Data
If data is not provided, the Data Subject will not be able to obtain information about the Data Controller’s activities and services via the Facebook social media platform or send messages to the Data Controller via Facebook Messenger.
10. Automated decision-making (including profiling): No automated decision-making, including profiling, takes place during data processing.
11. Joint Data Controller Agreement with Facebook Ireland Ltd.:
The Page Insights feature displays aggregated data that provides insight into how data subjects use the Facebook Page. Facebook Ireland Limited (“Facebook Ireland”) and the Data Controller are joint controllers with respect to the processing of analytics data. The Page Insights Addendum defines Facebook’s responsibilities and the Data Controller’s responsibilities regarding the processing of analytics data. Facebook Ireland assumes primary responsibility under the GDPR for the processing of analytics data and for complying with all relevant obligations set forth in the GDPR regarding the processing of analytics data. Facebook Ireland will also make an excerpt from the Page Insights Addendum available to all data subjects. The Data Controller ensures that it has an appropriate legal basis under the GDPR for processing analytics data, identifies the Page’s data controller, and complies with all other applicable legal obligations. Facebook Ireland is solely responsible for the processing of personal data in connection with the Page Insights feature, except for data falling within the scope of the Page Insights Addendum. The Page Insights Addendum does not grant the Data Controller the right to request personal data of Facebook users that Facebook Ireland processes in connection with Facebook, including Page Insights data. The Data Controller may not act on behalf of Facebook Ireland or provide responses when fulfilling data protection requests.
Customer Relations and Other Data Processing
- If any questions arise or the data subject encounters any issues while using the Data Controller’s services, they may contact the Data Controller via the methods listed on the website (phone, email, social media, etc.).
- The data controller processes the data provided in received emails, messages, phone calls, Meta, etc., along with the inquirer’s name, email address, and any other personal data voluntarily provided, no later than 2 years after the data was provided.
- We will provide information regarding data processing activities not listed in this notice at the time the data is collected.
- In the event of an exceptional request from a government authority or a request from other bodies authorized by law, the Service Provider is obligated to provide information, disclose data, transfer data, or make documents available.
- In such cases, the Service Provider shall disclose personal data to the requesting party—provided that the party has specified the exact purpose and scope of the data—only to the extent strictly necessary to fulfill the purpose of the request.
Rights of Data Subjects
1. Right of Access
You have the right to receive confirmation from the data controller as to whether your personal data is being processed, and if such processing is taking place, you have the right to access your personal data and the information listed in the Regulation.
2. Right to Rectification
You have the right to have the data controller rectify inaccurate personal data concerning you without undue delay upon your request. Taking into account the purposes of the data processing, you have the right to request that incomplete personal data be completed, including by means of a supplementary statement.
3. The Right to Erasure
You have the right to request that the data controller erase your personal data without undue delay, and the data controller is obligated to erase your personal data without undue delay under certain conditions.
4. The Right to Be Forgotten
If the data controller has made the personal data public and is required to erase it, it shall take all reasonable steps—taking into account available technology and the cost of implementation— — including technical measures — to inform other data controllers processing the data that you have requested the deletion of links to the personal data in question or of copies or replicas of such personal data.
5. Right to Restriction of Processing
You have the right to request that the data controller restrict data processing if any of the following conditions are met:
- You contest the accuracy of the personal data; in this case, the restriction applies for a period that allows the data controller to verify the accuracy of the personal data;
- the data processing is unlawful, and you oppose the erasure of the data and instead request that its use be restricted;
- the data controller no longer needs the personal data for the purposes of processing, but you require it to establish, exercise, or defend legal claims;
- You have objected to the processing; in this case, the restriction applies for as long as it remains to be determined whether the data controller’s legitimate grounds take precedence over your legitimate grounds.
6. The Right to Data Portability
You have the right to receive the personal data concerning you, which you have provided to a data controller, in a structured, commonly used, and machine-readable format, and you have the right to transmit those data to another data controller without hindrance from the data controller to whom you have provided the personal data (...)
7. The Right to Object
In cases where data processing is based on legitimate interests or on the exercise of official authority as legal grounds, you have the right to object at any time, on grounds relating to your particular situation, to the (...) processing of your personal data, including profiling based on the aforementioned provisions.
8. Objection in the Case of Direct Marketing
If personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for this purpose, including profiling, to the extent that it is related to direct marketing. If you object to the processing of your personal data for direct marketing purposes, your personal data may no longer be processed for that purpose.
9. Automated Decision-Making in Individual Cases, Including Profiling
You have the right not to be subject to a decision based solely on automated processing—including profiling—that produces legal effects concerning you or similarly significantly affects you.
The preceding paragraph does not apply if the decision:
- is necessary for the conclusion or performance of a contract between you and the data controller;
- is authorized by Union or Member State law to which the data controller is subject, which also provides for appropriate measures to safeguard your rights, freedoms, and legitimate interests; or
- is based on your explicit consent.
Time Limit for Action
The data controller shall inform you of the actions taken in response to the above requests without undue delay, but in any event within 1 month of receiving the request.
If necessary, this period may be extended by 2 months. The data controller will notify you of any extension of the deadline within 1 month of receiving the request, specifying the reasons for the delay.
If the data controller does not take any action in response to your request, it will inform you without delay, but no later than one month after receiving the request, of the reasons for not taking action, as well as of your right to file a complaint with a supervisory authority and to seek judicial remedy.
Security of Data Processing
The data controller and the data processor shall, taking into account the state of the art, the cost of implementation, and the nature, scope, context, and purposes of the data processing, as well as the risks of to ensure a level of data security appropriate to the risk, including, among other things, where applicable:
- the pseudonymization and encryption of personal data;
- ensuring the ongoing confidentiality, integrity, availability, and resilience of the systems and services used to process personal data;
- the ability, in the event of a physical or technical incident, to restore access to personal data and the availability of the data in a timely manner;
- a procedure for regularly testing, assessing, and evaluating the effectiveness of the technical and organizational measures implemented to ensure the security of data processing.
- Processed data must be stored in such a way that unauthorized persons cannot access it. For paper-based data carriers, this is achieved by establishing procedures for physical storage and archiving; for data processed in electronic form, this is achieved by using a centralized access control system.
- The method of storing data using IT systems must be chosen so that the data can be deleted—taking into account any differing deletion deadlines—upon the expiration of the data retention period or whenever necessary for other reasons. Deletion must be irreversible.
- Paper-based data carriers must be stripped of personal data using a document shredder or by engaging an external organization specializing in document destruction. In the case of electronic data storage media, physical destruction must be carried out in accordance with the rules governing the disposal of electronic data storage media, and, if necessary, the data must be securely and irreversibly deleted in advance.
- The data controller implements the following specific data security measures:
To ensure the security of personal data processed on paper, the Service Provider implements the following measures (physical protection):
- Store documents in a secure, lockable, dry room.
- If personal data processed on paper is digitized, the rules governing digitally stored documents must be applied.
- An employee of the Service Provider who processes data may only leave the room where data processing is taking place during the course of their work after securing the data storage media entrusted to them or locking the room.
- Personal data may only be accessed by authorized persons; third parties are not permitted to access it.
- The Service Provider’s building and premises are equipped with fire protection and property security systems.
IT Security
- The computers and mobile devices (and other data storage media) used in data processing are the property of the Service Provider.
- The computer system used by the Service Provider that contains personal data is equipped with virus protection.
- To ensure the security of digitally stored data, the Service Provider performs data backups and archiving.
- Access to the central server is restricted to authorized personnel only.
- Data stored on the computers can only be accessed with a username and password.
Notifying the Data Subject of a Data Breach
If a data breach is likely to result in a high risk to the rights and freedoms of natural persons, the data controller shall notify the data subject without undue delay.
The information provided to the data subject must clearly and in plain language describe the nature of the data breach and include the name and contact information of the data protection officer or other contact person who can provide further information; it must describe the likely consequences of the data breach; the measures taken or planned by the data controller to address the data breach must be described, including, where appropriate, measures aimed at mitigating any adverse consequences resulting from the data breach.
The data subject need not be informed if any of the following conditions are met:
- the data controller has implemented appropriate technical and organizational security measures, and these measures were applied to the data affected by the data breach, in particular measures—such as the use of encryption—that render the data unintelligible to any person who is not authorized to access the personal data;
- the data controller has taken further measures following the data breach to ensure that the high risk to the data subject’s rights and freedoms is unlikely to materialize in the future;
- notifying the data subjects would require a disproportionate effort. In such cases, the data subjects must be informed through publicly available information or through similar measures that ensure they are informed with comparable effectiveness.
If the data controller has not yet notified the data subject of the personal data breach, the supervisory authority, after assessing whether the personal data breach is likely to result in a high risk, may order that the data subject be notified.
Reporting a Data Breach to the Authority
The data controller shall report the data breach to the competent supervisory authority under Article 55 without undue delay and, where feasible, no later than 72 hours after becoming aware of the data breach, to the competent supervisory authority pursuant to Article 55, unless the data breach is unlikely to result in a risk to the rights and freedoms of natural persons. If the notification is not made within 72 hours, the reasons for the delay must be provided.
Periodic Review of Mandatory Data Processing
If the duration of mandatory data processing or the periodic review of its necessity is not specified by law, a local government ordinance, or a binding legal act of the European Union, the data controller shall review, at least every three years from the start of data processing, whether the processing of personal data carried out by the data controller or by a data processor acting on its behalf or pursuant to its instructions is necessary to achieve the purpose of the data processing.
The data controller shall document the circumstances and results of this review, retain this documentation for ten years following the completion of the review, and make it available to the National Authority for Data Protection and Freedom of Information (hereinafter: the Authority) upon request.
Right to File a Complaint
Complaints regarding any potential violations by the data controller may be filed with the National Authority for Data Protection and Freedom of Information:
National Authority
for Data Protection and Freedom of Information
9–11
Falk Miksa Street, 1055 Budapest
Mailing address: P.O.
Box 9, 1363 Budapest
Phone: +36 -1-391-1400
Fax: +36-1-391-1410
Email: [email protected]
Closing Remarks
In preparing this notice, we have taken into account the following laws and recommendations:
- On the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (GDPR) (April 27, 2016);
- Act CVIII of 2001—on certain issues related to electronic commerce services and information society services (primarily Section 13/A);
- Act XLVII of 2008—on the Prohibition of Unfair Commercial Practices against Consumers;
- Act XLVIII of 2008—on the Fundamental Conditions and Certain Restrictions of Commercial Advertising (in particular Section 6);
- Act C of 2003 on Electronic Communications (specifically Section 155a);
- Opinion No. 16/2011 on the EASA/IAB Recommendation on Best Practices for Behavioral Online Advertising;
- Recommendation of the National Authority for Data Protection and Freedom of Information on data protection requirements for prior notification.
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Date of last update: September 24, 2026