In effect since: 2018.06.25.
Last review: 2025.04.24.
Privacy Notice
on data processing in relation to the website
1. Data controller and contact details
Name: ABT Hungária Tanácsadó Kft. (hereinafter: „ABT”)
| Headquarters | E-mail address | Phone number | Data protection responsible |
| H-1037 Budapest, Montevideo u. 3/A. | adatvedelem@abt.hu | 06-1-4303400 |
Smohay Ferenc |
2. Data processors
| Name | Headquarters | Contact | Data processing activity |
| Newfold Digital, Inc. | 5335 Gate Pkwy, Jacksonville, FL 32256 USA | privacy@newfold.com | Providing hosting services for this website. |
| Collective Art Kft. | 1053 Budapest, Veres Pálné Street 13. | hello@collective.hu | Providing technical background for the website, performing development tasks. |
| MPC Hardver Kft. | H-3300 Eger, Petőfi S. u. 19. | laszlo.gillanyi@mpchardver.eu | Provides IT support for ABT. |
| Microsoft Ireland Operations Limited | One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland | (+1) 425-882-8080 | Providing e-mail system (Outlook). |
| Google Ireland Ltd. | Gordon House, Barrow Street, Dublin 4., Ireland | Privacy help center | Providing cookie services for ABT in order to ensure safe operation and statistical analysis of this website. |
| Hotjar Ltd. | Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian's STJ 3141, Malta | E-mail: support@hotjar.com | Providing cookie services for ABT in order to ensure statistical analysis of this website. |
3. Third parties
ABT does not transfer personal data to third parties other than the data processors.
4. Processing of personal data
4.1. Contacting and enquiries
Those who are interested in ABT’s data protection services can reach ABT via the given contacts or send a message through the website’s contact forms. On these platforms ABT requests the personal data (e.g. contact details), which are necessary for smooth communication and cooperation.
| You have the right to object, on grounds relating to your particular situation at any time to the processing of your personal data based on legitimate interest. |
| Purpose of data processing | Legal basis of data processing | Scope of personal data | Duration of data processing |
| Identify and assess the needs of those interested in data protection services and assessing their needs. |
legitimate interest of ABT: Promote potential orders and contacts for data protection services Article 6 (1) (f) GDPR |
· Contact persons’ identification and contact data: (e.g., name, e-mail address) · Other optional data (e.g. company name, telephone number) · Information regarding the enquiry: (e.g message content) |
The duration of data processing lasts until the enquiry in question is settled. |
| If an enquiry or request is received by the ABT via gdpr-tanacsadas.hu website or e-mail, the following data processors are involved in the process: | |||
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Newfold Digital Inc., Collective Art Kft., Microsoft Ireland Ltd, MPC Hardver Kft. |
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4.2. Social media presence
The website offers the possibility to click on the LinkedIn sign to redirect the visitor directly to the LinkedIn page, where the visitor can view and follow ABT's LinkedIn page. ABT shares some of the content of its website on this page, where users of the social networking site can provide feedback or comments on the content.
LinkedIn's data processing is governed by its own privacy policies, and ABT has no control over LinkedIn's data processing. More detailed information on LinkedIn's data processing can be found here: https://www.linkedin.com/legal/privacy-policy?trk=organization-guest_footer-privacy-policy
| You have the right to object to the processing of your personal data based on legitimate interests at any time on grounds relating to your particular situation. |
| Purpose of data processing | Legal basis of data processing | Scope of personal data | Duration of data processing |
| To publish and communicate widely information on the activities of the ABT and the professional articles of its employees. |
ABT’s legitimate interest: Promoting ABT's activities and services. paragraph (f) of subsection (1) Article 6 of GDPR |
· LinkedIn profile identification data (e.g. public name, photo) · Reactions to shared content, comments |
It is determined by the following criteria: · deletion of user’s reaction and comment · the existence of ABT's LinkedIn page |
4.3. Cookies
ABT uses cookies to operate this website. Cookies are variable files of letters and numbers that are stored on your computer or mobile device and are stored for a predetermined period of time. Cookies allow the website to remember your actions and personal preferences (such as your username, language, font size and other unique settings related to the website's display) for a certain period of time, so that you do not have to re-enter them each time you visit our website or navigate from one page to another. ABT can also use cookies to gain an insight into visitors' habits when using the website.
ABT uses cookies managed by Google Analytics to help measure website traffic and other web analytics data, but ABT has little control over Google's processing of data.
ABT also uses Hotjar to help understand user activity. Like Google, these cookies contribute to the measurement of website traffic and other web analytics data.
For more detailed information, please see the Cookie Notice.
| You have the right to object to the processing of your personal data based on legitimate interests at any time on grounds relating to your particular situation. |
| Purpose of data processing | Legal basis of data processing | Scope of personal data | Duration of data processing |
| Necessary cookies: to provide the technical support necessary for the smooth operation of the website. |
ABT’s legitimate interest: the smooth running of the website paragraph (f) of subsection (1) Article 6 of GDPR |
· Identification data (e.g. visitor's IP address, country of visit) · Information about the visitor's cookie preferences |
More detailed information can be found in section 5 of the Cookie Notice. |
| Preferences cookies (settings): to improve the user experience of the website. |
Consent of the data subject paragraph (a) of subsection (1) Article 6 of GDPR |
· Site-related settings (e.g. language) |
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| Statistics cookies (Google Analytics): analysing data on the website, monitoring the number of visits, improving the website. |
· Statistical identification data (separate ID) · Statistics related to your website visits (e.g. pages viewed, time spent, clicks, opens) |
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| The following data processors are involved in the process regarding cookies: | |||
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Google Ireland Ltd., Hotjar Ltd. |
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5. Data transfers outside the EU
ABT does not intend to transfer personal data to a third country or international organisation.
However, ABT uses service providers outside the European Union and in their cases, it cannot be excluded that personal data will be transferred outside the European Union. In the case of such transfers, ABT must provide one of the safeguards under Chapter V of the GDPR to ensure adequate protection of personal data. ABT applies the following safeguards to service providers outside the European Union:
- In the case of Newfold Digital, Inc. (HostGator.com, LLC) transfers are based on the relevant European Commission’s Standard Contractual Clauses for the Transfer of Personal Data to Third Countries (“standard contractual clauses”), unless the transfer’s specific location is to a country that has been determined by the European Commission, as applicable, to provide an adequate level of protection for individuals’ rights and freedoms for their personal information (“adequacy decision”).
For more information on Newfold’s data processing click here.
- Regarding Microsoft and Google such transfers are also based on one of the mechanisms under Article 45-46 of the GDPR, either on an adequacy decision or on standard contractual clauses.
For more information on Microsoft’s data processing click here.
For more information on Google’s data processing click here.
- In the case of Hotjar Ltd, standard contractual clauses ensure adequate security of personal data.
For more information on Hotjar’s data processing click here.
6. Your Rights as a Data Subject
6.1. Right to information and access
You have the right to receive information whether ABT processes your personal data and if they do, about the relevant circumstances of the processing.
Such relevant information may be:
- the type of data processed by ABT;
- the purpose, duration, and legal basis for data processing;
- the name and address of ABT as well as their activities related to data processing;
- the identity of third parties to whom personal data are transferred and the purpose of such disclosures.
You have the right to access, obtain or request a copy of your personal data. Exercising this right cannot adversely affect the rights and freedoms of others.
6.2. Right to rectification
You are entitled to request:
- correction of inaccurate data
- completion of incomplete data.
6.3. Right to erasure
You have the right to have ABT erase your personal data if one of the following conditions apply:
- the data are no longer necessary in relation to the purposes for which they were collected or otherwise processed by ABT
- you withdraw consent and there is no other legal ground for the processing
- you object to the processing and ABT has no overriding legitimate grounds for the processing
- the data have been unlawfully processed,
- the data must be erased for compliance with a legal obligation.
In exceptional cases, your data cannot be deleted even if one of the above conditions is met. For example, if it is necessary to retain for the establishment, exercise, or defence of legal claims.
6.4. Right to restriction of processing
If you dispute the accuracy of your personal data, you have the right to request ABT to restrict the processing of your data until verification.
If the data processing is unlawful or the storage period has expired, but you need them in order to enforce your legal rights, you may also request the restriction of processing instead of the erasure your data.
Restriction of processing means that ABT will only store your data. They will not change the data or perform any other processing activity.
ABT may use your restricted data IF you consent to the processing, or it is necessary for the establishment, exercise, or defence of legal claims OR to protect the rights of another person.
6.5. Right to data portability
You have the right to receive the personal data concerning you that you have provided to the data controller in a structured, commonly used, machine-readable format and the right to transmit such data to another data controller without hindrance from the data controller to whom you have provided the personal data, IF:
- the processing is based on your consent or on the performance of a contract (if you are a contracting party); and
- the processing is carried out by automated means.
When exercising your right to data portability, you have the right to request, where technically feasible, the direct transfer of personal data between controllers.
The right to data portability must be without prejudice to the provisions governing the right to erasure and must not adversely affect the rights and freedoms of others.
6.6. Right to withdraw consent
You are entitled to withdraw your consent at any time, without restriction and without giving any reason, free of charge. However, the withdrawal of your consent shall not affect the lawfulness of the processing carried out on the basis of your consent prior to its withdrawal.
6.7. Right to object
You have the right to object to the processing of your personal data at any time on grounds relating to your particular situation. Unless ABT demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the visitor or the processing is necessary for the establishment, exercise or defence of legal claims the personal data will no longer be processed.
If you object against the processing related to the newsletters, which is done for direct marketing purposes, the personal data shall no longer be processed for such purposes.
ABT may still process your personal data if:
- there is a compelling legitimate interest,
- it is necessary for the establishment, exercise, or defence of legal claims.
6.8. Fulfilling the data subjects’ requests
If you think that your personal data is not being processed in accordance with the applicable data protection requirements, you may request ABT to rectify it. ABT will respond to your request within a maximum of one month after it was received. If ABT is unable to comply with your request or more time is needed because of its complexity or, in the case of multiple requests, its volume, you will be informed within the one-month period. In such cases, the deadline may be extended, up to two months.
6.9. How to exercise your rights
You have the right to lodge a complaint with the competent data protection supervisory authority. In Hungary the authority is the Nemzeti Adatvédelmi és Információszabadság Hatóság (National Authority for Data Protection and Freedom of Information) or briefly ‘NAIH’. NAIH’s website: https://naih.hu/
| Postal address | E-mail / mailing address | Telephone number |
|
Falk Miksa street 9-11 1055 Budapest, Hungary |
1363 Budapest, Pf.: 9. |
+36 (30) 683-5969 +36 (30) 549-6838 |
If you believe that your rights have been violated, you also have the right to seek judicial remedy at a court of law, which falls within the jurisdiction of the Törvényszék (General Court). Upon the request, the action can be brought before the Court which is competent based on the domicile or the place of residence of the data subject (you). More information is available here: https://birosag.hu/en