Cookie Policy
## Management of Internet Cookies (COOKIES)
Any external visitor can access the Contractor’s website and the information provided by the Contractor. During the visit to the website, the website’s hosting provider records visitor data to monitor the operation of the service, prevent abuse, and ensure proper functioning. The purpose of recording is to collect information on the use of the website and to prepare traffic and internet usage statistics and analyses. External service providers may place a so-called cookie on the user’s computer, enabling them to link the user’s current visit with previous ones. The user may reject the cookie request at any time in the pop-up window on the website.
> “A cookie is a small file that is placed on your computer when you visit a website. When you visit the site again, the cookie allows the site to recognize your browser. Cookies can also store user preferences and other information. On other platforms—where cookies are not available or usable—other technologies are used for purposes similar to cookies: such as the advertising ID on Android mobile devices. You can reset your browser settings to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies.” (Source: Google)
> “Cookies used by Google Analytics may operate on the website, which are subject to Google’s privacy policy.”
### 13.1.1. Strictly Necessary Cookies
These cookies are essential for the proper functioning of our website. Without accepting these cookies, we cannot guarantee the expected performance of our website or that you will have access to all the information you seek. These cookies do not collect personal data about you or data that can be used for marketing purposes.
* *Relevant links:* [GDPR Info](https://www.gdpr.info.hu/adatkezeles), [Google Analytics Support](https://support.google.com/analytics/answer/6004245?hl=hu)
**Performance Cookies (Strictly Necessary):** These collect information on whether our website is working properly, identify errors, help us improve the site, and indicate the most popular parts of the website.
**Functional Cookies:**
These cookies ensure a consistent appearance of our website tailored to your needs and remember the settings you have chosen (e.g., color, font size, layout).
**Targeting Cookies:**
Targeting cookies ensure that the advertisements appearing on our website are tailored to your interests. Our website primarily features advertisements related to the services we provide to facilitate access to more favorable offers for you.
**Third-Party Cookies:**
From time to time, cookies provided by a third party—such as a social media site—may appear on our website, allowing you to share or like content and sending information to the third party that they may later use to display advertisements to you on other websites.
### Scope and Legal Basis of Processed Data
Date, time, the IP address of the user’s computer, the IP address of the visited page, the IP address of the previously visited page, and data related to the user’s operating system.
**Legal Basis:** Voluntary consent of the data subjects based on Regulation (EU) 2016/679 (GDPR) and Section 5(a) of Act CXII of 2011 (Infotv.).
**Duration of Data Processing:** 2 years from viewing the website.
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### Marketing-related Data Processing
**Newsletter Processing:**
* **Processed Data:** Name, e-mail address.
* **Duration:** Until the withdrawal of the data subject’s consent.
* **Legal Basis:** Your voluntary consent provided during registration and subscription [Data processing according to Article 6(1)(a) of the GDPR].
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### Rights of the Data Subjects
During the period of data processing, you are entitled to the following rights under the GDPR:
* Right to withdraw consent
* Right of access to personal data and information
* Right to rectification
* Right to restriction of processing
* Right to erasure (Right to be forgotten)
* Right to object
* Right to data portability
**Exercise of Rights:** Exercising your rights requires identification and communication with the Data Controller. Therefore, personal data will be required for identification (based only on data the Controller already processes). Complaints will be answered within **30 days**.
**Detailed Rights:**
1. **Right of Access:** You are entitled to receive feedback on whether your data is being processed and receive information on the purposes, categories, recipients, and planned duration of storage.
2. **Right to Rectification:** You have the right to have inaccurate personal data corrected without delay.
3. **Right to Restriction:** You can request the restriction of processing if you contest accuracy, if the processing is unlawful but you oppose erasure, or if the data is needed for legal claims.
4. **Right to Erasure:** Data must be deleted if it is no longer necessary, consent is withdrawn, or processing is unlawful. This does not apply if processing is required by law (e.g., invoicing).
5. **Right to Object:** You may object to processing based on legitimate interests or for direct marketing (including profiling).
6. **Data Portability:** You can request to receive your data in a structured, commonly used format (xml, JSON, csv) and have it transmitted to another controller.
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### Data Security Measures
The Data Controller has implemented appropriate security measures to protect personal data against unauthorized access, alteration, transmission, disclosure, deletion, or destruction.
### Legal Remedies
If you believe the Data Controller has violated legal provisions, you may:
1. Initiate an investigation by the **National Authority for Data Protection and Freedom of Information (NAIH)** (1363 Budapest, Pf.: 9., ugyfelszolgalat@naih.hu).
2. File a **civil lawsuit** against the Data Controller in court.
### Amendments to the Privacy Policy
The Data Controller reserves the right to modify this policy in a way that does not affect the purpose and legal basis of the processing. By using the website after the modification takes effect, you accept the modified policy.