PRIVACY
Privacy Notice
This Privacy Notice describes the processing of personal data carried out through the pappzsolt.eu website. Its purpose is to explain in clear terms what data we process, for what purposes and on what legal bases, how long we retain the data, who may have access to it, and what rights data subjects have.
Scope of this Privacy Notice
This Privacy Notice applies to the processing of personal data related to the operation of the pappzsolt.eu professional profile and informational website, including in particular contact made through the website, communication by e-mail and telephone, and data processing necessary for the technical operation of the website.
Any regulated professional or financial intermediation process that may commence following an initial enquiry is separate from the website. Any further processing of personal data within such a process is governed by the separate privacy information and legal requirements applicable to the relevant activity and legal relationship.
1. Data controller
Data controller: Zs22 Tanácsadó Kft. (abbreviated name: Zs22 Kft.)
Registered office: 2132 Göd, Jósika utca 5, Hungary
Company registration number: 13-09-211307
Tax number: 29154603-1-13
Data protection contact: contact@pappzsolt.eu
The data controller has not appointed a data protection officer.
2. Contact form
| Data subjects | Natural persons who initiate contact through the website. |
|---|---|
| Personal data processed | Name, e-mail address, optionally telephone number and city, selected topic, the content of the message, as well as technical data associated with sending the message to the extent necessary for the secure operation of the system. |
| Purpose | To receive and respond to enquiries and to maintain contact. If a separate professional or contractual process subsequently begins on the basis of the enquiry, the related processing of personal data takes place separately from the website and in accordance with the privacy information applicable to that process. |
| Legal basis | For general contact through the website, the legal basis is the legitimate interest under Article 6(1)(f) GDPR in receiving and properly handling enquiries and documenting communications. If the data subject expressly requests steps to be taken prior to entering into a contract, the legal basis for the relevant further processing may be Article 6(1)(b) GDPR. |
| Retention | As a general rule, personal data processed under this Privacy Notice in connection with a closed enquiry are retained for no longer than 6 months. If a separate professional, contractual or other legal relationship is established following the initial contact, any further processing of personal data required for that relationship takes place separately from the processing associated with contact through the website, in accordance with the legal basis, privacy information and retention rules applicable to that relationship. Where a legal claim arises, the necessary data may be retained for as long as required for the claim to be asserted or defended. |
| Required data | Name, e-mail address, topic and message are required in order to submit an enquiry through the website. Providing a telephone number and city is optional. |
In the free-text message field, please do not include special categories of personal data (for example, health data) or any third-party personal data that is not necessary for the enquiry.
3. E-mail and telephone communication
If contact is made by e-mail or telephone, the purpose and legal basis of the processing are, depending on the nature of the enquiry, the same as described above. During communication, we use only the personal data necessary to handle the enquiry. Telephone conversations are not recorded; however, a summary of the content necessary for handling the enquiry may be recorded in the data controller’s own system, separately from the website. Personal data recorded in this way are processed in accordance with the provisions of this Privacy Notice relating to enquiries and contact. The data are not used for marketing communications without a separate appropriate legal basis.
4. Server logs and IT security
When the website is served, the hosting provider may process technical log data – including in particular the IP address, the time of the request, the requested resource, technical information relating to the browser/device, and error information – for the purposes of providing the service, preventing misuse, troubleshooting and ensuring IT security. The legal basis for this processing may be the legitimate interest of the data controller under Article 6(1)(f) GDPR.
According to the information provided by Rackhost Zrt., access and error logs for shared hosting services are available for the preceding one-month period. The log files are accessible to the data controller via FTP in the hosting account’s /log directory.
5. Cookies, analytics and external tracking
The current website code does not use cookies for analytics, marketing or profiling purposes and does not contain Google Analytics, Meta Pixel or other similar tracking code. Therefore, a consent-based cookie banner is not required for the current version of the website. If non-essential cookies or tracking technologies are introduced in the future, the Privacy Notice and consent-management mechanism must be updated appropriately before such technologies are activated.
6. Data processors and recipients
Hosting and e-mail infrastructure
Rackhost Informatikai Zártkörűen Működő Részvénytársaság (Rackhost Zrt.)
Registered office: 6722 Szeged, Tisza Lajos körút 41, Hungary
Company registration number: 06-10-000489
Tax number: 25333572-2-06
Rackhost Zrt. is involved in providing the web hosting and related technical infrastructure. In respect of personal-data processing operations carried out on behalf of the data controller and on its documented instructions, Rackhost Zrt. acts as a data processor.
E-mail delivery
The contact form forwards the data provided through a secure SMTP connection to an e-mail account on the data controller’s own domain. Messages are processed for the purposes of receiving and responding to enquiries and maintaining contact.
Personal data are disclosed to other recipients only for a lawful purpose and on an appropriate legal basis. No transfer of personal data to a third country is currently planned as part of the website’s operation; this must be reviewed separately if a new external service is introduced.
7. Data security
The data controller applies technical and organisational measures appropriate to the risks associated with the processing of personal data. The website uses HTTPS, server-side form validation, spam protection, restriction of access rights to those necessary, and a secure SMTP connection to support data security. Personal data submitted through the form are not made public.
8. Rights of the data subject
Subject to the conditions laid down in the GDPR, the data subject may request:
- access to their personal data;
- rectification of inaccurate personal data;
- erasure of personal data;
- restriction of processing;
- data portability, where the applicable legal conditions are met;
- and may object to processing based on legitimate interests.
Where processing is based on legitimate interests, the data subject has the right to object at any time, on grounds relating to their particular situation, to the processing of their personal data. In such a case, the data controller will 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, or the processing is necessary for the establishment, exercise or defence of legal claims.
Requests concerning data-subject rights may be submitted to contact@pappzsolt.eu. The data controller will provide information on the action taken on a request without undue delay and in any event within one month of receipt of the request. Where necessary, taking into account the complexity and number of requests, this period may be extended by a further two months; the data subject will be informed of the extension and the reasons for the delay within one month of receipt of the request.
9. Complaint and legal remedies
If the data subject considers that the processing of their personal data infringes the GDPR or other applicable data-protection legislation, they may lodge a complaint with the competent supervisory authority or seek a judicial remedy.
Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH)
1055 Budapest, Falk Miksa utca 9-11, Hungary
Postal address: 1363 Budapest, Pf. 9, Hungary
Website: www.naih.hu
E-mail: ugyfelszolgalat@naih.hu
Before submitting a complaint, the data subject may also contact the data controller directly at contact@pappzsolt.eu in order to clarify or resolve the matter.
10. Automated decision-making and profiling
In connection with the operation of the website, no decision is made based solely on automated processing that produces legal effects concerning the data subject or similarly significantly affects them within the meaning of Article 22 GDPR. The website does not carry out profiling for marketing purposes.
11. Changes to this Privacy Notice
This Privacy Notice may be amended if the operation of the website, the service providers used, the purposes of data processing or the applicable legal environment change. The version currently in force will always be available on the pappzsolt.eu website.