Privacy Policy

Ádám Felméry, sole trader (hereinafter: Service Provider or Data Controller) provides data subjects with the most important information regarding the processing of personal data through this Privacy Policy, including in particular the purposes, legal basis and duration of data processing, the rights of data subjects and the available remedies.

The Data Controller processes personal data in all cases in compliance with applicable legislation, in particular observing the principles of data protection and information security. Personal data means any information relating to an identified or identifiable natural person.

The purpose of this Privacy Policy is to present in a transparent manner what personal data the Service Provider processes, for what purposes and on what legal basis, and what rights data subjects have in relation to that processing.

This Privacy Policy applies to natural persons using the Service Provider's services and to anyone who contacts the Service Provider or provides their personal data to the Service Provider.

This Privacy Policy is freely accessible and available to anyone without restriction. Please read it carefully.

In processing personal data, the Service Provider takes particular account of the following legislation:

• 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 (hereinafter: GDPR);
• Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information (hereinafter: Infotv.);
• Act V of 2013 on the Civil Code (Ptk.), which governs, among other things, the rules on the limitation of civil law claims;
• Act C of 2000 on Accounting, which governs obligations relating to the retention of accounting documents.

The Data Controller

The data controller is the natural or legal person who determines the purposes and means of processing personal data and is responsible for that processing.

Data controller details:

Data Subjects

A data subject is any natural person whose personal data is processed by the Data Controller, in particular persons using the Service Provider's services, as well as those who contact the Service Provider or provide their personal data to the Service Provider.

Third Parties

A third party is any natural or legal person, authority, institution or other body which is not the data subject, the data controller or the data processor, and to whom or which personal data is disclosed.

The Data Controller transfers personal data to third parties only to fulfil a statutory obligation or based on the data subject's consent.

Main Data Processing Activities

1. Appointment Booking
2. Invoicing

1. Appointment Booking

During appointment booking, the personal data necessary for using the service is provided. The Data Controller processes the data provided by the data subject solely for the purposes of recording the appointment, sending a confirmation and any necessary communication related to the appointment.

Data processed:

During appointment booking, the data subject's name and email address are provided. Providing a phone number is optional; if provided, the Data Controller also processes the phone number.

Purpose of data processing:

Personal data is processed for the purposes of recording the appointment, sending confirmation, making modifications if necessary, and communicating in connection with the appointment.

Legal basis for data processing:

The legal basis for data processing is the taking of steps at the request of the data subject prior to entering into a contract for the use of the service [GDPR Article 6(1)(b)].

Duration of data processing:

The Data Controller processes personal data until the appointment takes place or until the appointment is cancelled or modified.

2. Invoicing

In connection with the use of the service, the data controller issues an invoice to fulfil its statutory obligations. The processing of certain personal data of the data subject is necessary for issuing the invoice and fulfilling accounting obligations.

Data processed:

For the purpose of issuing an invoice, the data subject's name, billing address and — where provided — email address are processed.

Purpose of data processing:

Personal data is processed for the purposes of issuing invoices, fulfilling accounting obligations and settling the consideration for the service.

Legal basis for data processing:

The legal basis for data processing is the fulfilment of a legal obligation applicable to the data controller [GDPR Article 6(1)(c)], having regard to the provisions of Act C of 2000 on Accounting.

Duration of data processing:

The Data Controller retains personal data related to invoicing for 8 years from the date of issue of the invoice, pursuant to the statutory obligation to retain accounting documents.

Data Processors

In processing personal data, the Data Controller may use data processors for the performance of certain technical and administrative tasks. The data processor acts on behalf of and according to the instructions of the Data Controller, and may only process personal data for the purposes and within the framework determined by the Data Controller.

The Data Controller uses the following data processors:

Online appointment booking system provider

The Data Controller uses the Minup appointment booking system to provide online appointment scheduling.

Processor name: Minup Informatikai Zrt.
Representative: Ádám Gyula Marjai
Registered address: 2071 Páty, Völgy sétány 8, door 2
Company registration number: 13-10-042751
Tax number: 32636774-2-13
EU VAT number: HU32636774
Data protection contact: Áron Dudás
Data protection email: adatkezeles@minup.io
General contact: hello@minup.io
Website: https://minup.io/hu/

Purpose of processing: Providing and operating the online appointment booking system.

Data processed: Personal data provided during appointment booking (name, email address, optionally phone number).

The data processor processes personal data on behalf of the Data Controller solely for the purpose of operating the booking system and managing appointments.

Invoicing service provider

The Data Controller uses the Billingo online invoicing system for issuing invoices and managing invoicing processes.

Processor name: Billingo Technologies Zrt.
Registered address: 1133 Budapest, Árbóc utca 6.
Website: https://www.billingo.hu/

Purpose of processing: Issuing invoices and performing administrative tasks related to invoicing.

Data processed: Billing data (name, billing address, email address where required).

The data processor processes personal data on behalf of the Data Controller solely for the purpose of operating the invoicing system and issuing invoices.

The Data Controller has a contractual relationship with each data processor that ensures data processors process personal data in accordance with applicable data protection legislation, in particular the GDPR.

Cookie Management on the Website

The Service Provider uses so-called cookies on the https://felmeryadam.hu/ website in order to ensure the proper functioning of the website, improve user experience, analyse website traffic and support marketing activities.

A cookie is a small data packet placed by the website on your device (computer, mobile phone or tablet) via your browser. Cookies allow the website to recognise your browser, store certain information and collect statistical data about the use of the website.

The cookies used when visiting the website are not suitable for directly identifying the data subject; however, they may collect information about visitors' browsing habits in order to improve the user experience and optimise the functioning of the website.

Types of cookies used

The following cookies are used on the website:

CookieYes
The website uses the CookieYes service to manage cookie consent. This cookie ensures that visitors receive appropriate information about the use of cookies and allows them to accept or reject different cookies. Cookies used by CookieYes record the visitor's cookie preferences so that the website can respect the user's choices on subsequent visits.

Google Analytics (GA4)
The website uses the Google Analytics (GA4) web analytics service, operated by Google LLC. Google Analytics collects anonymous statistical data about website usage via cookies, for example:

• the number of visitors,
• time spent on the website,
• pages visited,
• the approximate geographic location of visitors,
• the source from which visitors arrived at the website.

This information helps the Service Provider better understand visitor behaviour and improve the functioning of the website. The data collected by Google Analytics is not suitable for directly identifying the data subject.

Google Tag Manager (GTM)
The website uses Google Tag Manager, which enables the management and operation of various measurement and marketing codes. Google Tag Manager itself does not collect personal data; it assists in the operation of other services (such as Google Analytics or Google Ads).

Google Ads
The website uses Google Ads remarketing and conversion tracking cookies. These cookies enable:

• the Service Provider to measure the effectiveness of advertisements,
• relevant advertisements to be displayed to website visitors within Google's advertising network.

Through remarketing cookies, Google can display advertisements to users who have previously visited the website.

Purpose of data processing:

The purposes of using cookies include in particular:

• ensuring the proper functioning of the website,
• improving user experience,
• statistical analysis of website usage,
• supporting marketing and advertising activities.

Legal basis for data processing:

The use of non-essential cookies (statistical and marketing cookies) is based on the consent of the data subject [GDPR Article 6(1)(a)].

Consent can be given in the cookie management interface that appears on the first visit to the website, and can be withdrawn at any time.

Data processed:

In the course of using cookies, the following data may be processed in particular:

• IP address,
• browser type and version,
• operating system data,
• pages visited on the website,
• time and duration of the visit,
• approximate geographic location.

Duration of data processing:

The retention period of cookies may vary by cookie type. Cookies used for statistical and marketing purposes may be stored for up to 12 months, or until the data subject withdraws their consent.

Managing and Deleting Cookies:

You may modify or withdraw your cookie preferences at any time through the cookie management panel displayed on the website.

In addition, most browsers provide options to delete or disable cookies. For information on how to change cookie settings in various browsers, please visit the following links:

• Google Chrome: https://support.google.com/chrome/answer/95647
• Microsoft Edge: https://support.microsoft.com/en-us/help/17442
• Mozilla Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer

Third-Party Cookies:

Some cookies used on this website originate from third parties (e.g. Google services). These providers may process data in accordance with their own privacy policies.

Google's privacy policy is available at the following link: https://policies.google.com/privacy

Rights of Data Subjects

Data subjects have various rights in connection with the processing of their personal data under Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR).

You have the right to request information about the processing of your personal data, to request the rectification, erasure or restriction of processing of your personal data, and in certain cases to exercise your right to data portability, as well as to object to the processing of your personal data.

Requests related to data processing may be submitted to the Data Controller at the following contact details:

E-mail: felmerya93@gmail.com
Postal address: 1137 Budapest, Szent István Park 35

The Data Controller will examine the received request without undue delay, and at the latest within 30 days of receipt, and will provide a substantive response.

The Data Controller may, where necessary, request verification of the data subject's identity in order to ensure that personal data is accessible only to the authorised person.

Right of Access

You have the right to obtain confirmation from the Data Controller as to whether your personal data are being processed. Where such processing takes place, you have the right to:

• access your personal data being processed,
• receive information about the purpose, legal basis and duration of the processing,
• receive information about any data transfers,
• request a copy of your personal data held by the Data Controller.

The first copy of personal data shall be provided free of charge.

Right to Rectification

You have the right to request the Data Controller to rectify any inaccurate personal data relating to you, or to complete any incomplete data.

In your request for rectification, please specify the data to be corrected and — where applicable — the correct data.

Right to Erasure (“Right to Be Forgotten”)

You have the right to request the erasure of your personal data without undue delay, where any of the following grounds apply:

• the personal data are no longer necessary in relation to the purposes for which they were collected or processed;
• you withdraw your consent on which the processing is based;
• you object to the processing and there are no overriding legitimate grounds for the processing;
• the personal data have been processed unlawfully;
• the personal data must be erased in order to comply with a legal obligation.

The right to erasure does not apply where processing is necessary for compliance with a legal obligation, or for the establishment, exercise or defence of legal claims.

Right to Restriction of Processing

If you have questions or concerns about the accuracy, justification or lawfulness of the processing of your personal data by us, you may request the restriction of certain processing activities.

You may also request restriction where we no longer need your data, but you as the data subject require it for the establishment, exercise or defence of legal claims. You may also request restriction if you contest the legal basis for processing on grounds of legitimate interest.

During the period of restriction, no processing operations may be carried out; the data may only be stored.

Right to Data Portability

You have the right to receive the personal data you have provided to the Data Controller in a structured, commonly used and machine-readable format, and to request the transmission of such data to another data controller.

This right applies only to personal data that you have provided and whose processing is based on consent or on the performance of a contract.

Right to Withdraw Consent

Where the processing of personal data is based on your consent, you have the right to withdraw that consent at any time.

The withdrawal of consent shall not affect the lawfulness of processing carried out prior to the withdrawal.

Right to Object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data where processing is based on legitimate interest.

In the event of an objection, the Data Controller may no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject.

Legal Remedies

If you believe that the processing of your personal data infringes applicable data protection legislation, you have the right to lodge a complaint with the supervisory authority:

Hungarian National Authority for Data Protection and Freedom of Information (NAIH)
Address: 1055 Budapest, Falk Miksa utca 9–11.
Postal address: 1363 Budapest, Pf. 9.
Phone: +36 1 391 1400
E-mail: ugyfelszolgalat@naih.hu
Website: https://www.naih.hu

You also have the right to bring proceedings before a court. You may choose to initiate proceedings before the court with jurisdiction over your place of residence or habitual residence.