Privacy Notice
Personal data protection is extremely important for us, therefore we inform you by way of this Privacy Notice about the personal data we process, as well as the purpose and legal basis of processing. The Privacy Notice also contains the rights you are entitled to.
- Details of the Data Controller
Data Controller: Lengyel Tünde Law Office (hereinafter: Data Controller)
Registered seat: 1025 Budapest, Kapy str. 51. 2/7.
Bar number: 5111 – Budapest Bar Association
Tax number: 18510827-2-41
Telephone: +36-20-439-8363
Email contact details: lengyel.tunde@ltlo.hu
- General legislative provisions serving as a legal basis for data processing
- 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 (GDPR)
- Act CXII of 2011 on Informational self-determination and freedom of information (Act on Privacy)
- Act V of 2013 on the Hungarian Civil Code (Civil Code)
- Act CXXVII of 2007 on Value Added Tax (Act on VAT)
- Act C of 2000 on Accounting (Act on Accounting)
- Act LXXVIII of 2017 on legal practice (Act on Legal Practice)
- Act LIII of 2017 on the prevention and combating of money laundering and terrorist financing (AML Act)
- Act CXLI of 1997 on the real estate register (Act on Real Estate)
- Act CXXX of 2016 on civil procedure (Act on Civil Procedure)
- Definitions
Personal data means 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, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Such typical personal data includes in particular: name, address, place and date of birth, mother’s name.
Data Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Data Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the Data Controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Data Processor means the natural or legal person, public authority, agency or other body which processes personal data on behalf of the Data Controller.
Recipient means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not.
- Principles
In the course of processing personal data, the following principles are taken into account by the Data Controller so that personal data is:
- processed lawfully, fairly and in a transparent manner in relation to the Data Subject (lawfulness, fairness and transparency)
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89 (1) of the GDPR, not be considered to be incompatible with the initial purposes (purpose limitation)
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (data minimisation)
- accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (accuracy)
- kept in a form which permits identification of Data Subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89 (1) of the GDPR subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (storage limitation)
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (integrity and confidentiality)
- the Data Controller shall be responsible for compliance with the foregoing, and must be able to demonstrate such compliance (accountability)
- Data processing activity
a.) contact (private individual)
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Purpose of data processing Contacting, keeping in touch Legal basis of data processing GDPR, Article 6 (1) a): consent Categories of Data Subjects Any natural person Scope of Personal Data Contact data under Section 33 (6) of the Act on Legal Practice: name, email address, telephone number Data retention period - For 1 year from the date of contacting, if no contract is concluded
- Under Section 53 (3) and (5) of the Act on Legal Practice, 5 years or 10 years, if no contract is concluded
Data transfer Data transfer is not performed on the basis of Articles 44-49 of the GDPR Recipients The Data Controller engages a Data processor: - hosting service provider: dima.hu Kft. (registered seat: 4032 Debrecen, Békessy Béla utca 9. C. ép. 3. em. 10., corporate registration number: 09-09-014017)
- mail system provider: Microsoft Hungary Kft. (registered seat: 1031 Budapest, Graphisoft Park 3., corporate registration number: 01-09-262313)
Source of personal data The source of personal data is the visitor Method and consequences of data provision Provision of data is voluntary. If you do not provide the required information, we cannot contact you
b.) contractual communication (corporate contact)
The Data Controller communicates with contracted Partners and maintains the business relationship through the contact person specified in the contract.
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Purpose of data processing Maintaining communication and realizing cooperation in order to achieve the objectives of the contract concluded between the Data Controller and the Partner Legal basis of data processing Article 6 (1) f) of the GDPR: legitimate interest Categories of Data Subjects Partner’s employee (individual entrepreneur, Kft. /limited liability company/, Bt. /limited partnership/, Zrt./private company limited by shares/), as appointed contact person Scope of Personal Data Name, position, telephone number, email address Data retention period End of the 5th year following the performance or termination of the contract Data transfer Data transfer is not performed on the basis of Articles 44-49 of the GDPR Recipients The Data Controller does not engage a Data Processor Source of personal data The source of personal data is the Partner’s contact person Method and consequences of data provision
Provision of data is necessary. If you do not provide the required information, we cannot cooperate with your company’s contact person
c.) identification of a person under legal obligation in the case of any engagement
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Purpose of data processing Identification of individuals Legal basis of data processing Article 6 (1) c) of the GDPR: compliance with legal obligation Section 32 of the Act on Legal Practice Categories of Data Subjects Any natural person Scope of Personal Data Personal data in the records specified in Section 33 of the Act on Legal Practice Data retention period 5 or 10 years based on Section 53 (3) and (5) of the Act on Legal Practice Data transfer Data transfer is not performed on the basis of Articles 44-49 of the GDPR Recipients The Data Controller does not engage a Data Processor In the course of official and legal proceedings, the recipients of the data transfer can be, considering the interests of the Client and subject to advance notification to the Client:
- court
- public notary
- executor
- government office
- local government
- mayor’s office
- police
- ministry
- financial organisation (bank, factoring firm, insurance company)
- liquidator
- utility service provider
- competent authority
- chamber
- attorney, law office
- National Tax and Customs Authority
- Hungarian Intellectual Property Office (HIPO), European Union Intellectual Property Office (EUIPO), World Intellectual Property Organization (WIPO)
Source of personal data The source of personal data is the client Method and consequences of data provision Provision of data is obligatory. If you do not provide the required information, we cannot fulfil the identification obligation prescribed by law
d.) due diligence of individuals under legal obligation in the case of any engagement
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Purpose of data processing Client due diligence Legal basis of data processing Article 6 (1) c) of the GDPR: compliance with legal obligation Section 6 of the AML Act: Client due diligence obligation
Section 15 of the AML Act: Simplified client due diligence
Section 16 of the AML Act: Enhanced client due diligence
Categories of Data Subjects Any natural person Scope of Personal Data Section 7-14/A of the AML Act Section 15 (1) of the AML Act
Section 16 (1) of the AML Act
Data retention period 8 years based on Section 56 (2) and Section 57 (2) of the Act on AML Data transfer Data transfer is not performed on the basis of Articles 44-49 of the GDPR Recipients The Data Controller does not engage a Data Processor In light of Section 74 (1) of the AML Act, data is transferred to the territorial chamber.
In the course of official and legal proceedings, the recipients of the data transfer can be, considering the interests of the Client and subject to advance notification to the Client:
- court
- public notary
- executor
- government office
- local government
- mayor’s office
- police
- ministry
- financial organisation (bank, factoring firm, insurance company)
- liquidator
- utility service provider
- competent authority
- chamber
- attorney, law office
- National Tax and Customs Authority
- Hungarian Intellectual Property Office (HIPO), European Union Intellectual Property Office (EUIPO), World Intellectual Property Organization (WIPO)
Source of personal data The source of personal data is the client Method and consequences of data provision Provision of data is obligatory. If you do not provide the required information, we cannot fulfil the client due diligence obligation prescribed by law
e.) invoicing
- Data processing through the website
Our Website uses cookies.
A cookie is a file that is placed on your computer when you visit a website. A cookie is a set of information sent from the server to the browser, then every time there is a request the browser sends it back to the server with data content specified by the server. This is designed to save the internet settings on the website you visited, so if you visit the site again from the same device, the page will remember the set parameters.
Cookies have several functions. Cookies are most often used for personalizing advertisements and services, and analysing website traffic.
In light of the current legislation in force, we can only store cookies on your device if this is strictly necessary, that is, if it is essential for the operation of the website; these are called “necessary cookies”. We need your consent to use any other types of cookies. You can view and set the cookies currently used on the website in a pop-up window when accessing the website.
Every modern browser allows changes to cookie settings. Most browsers automatically accept cookies by default, however, these changes can usually be modified, thus the browser can block automatic acceptance, and offer the choice of accepting cookies every time.
Please note that since the aim of the cookies is to enhance or enable our website usability and processes, if you block or delete cookies, you may not be able to use the full functionality of our website or the website will work differently in your browser than planned. Information is available here about the cookie settings of the most popular browsers:
- Google Chrome
- Firefox
- Microsoft Internet Explorer 11
- Microsoft Internet Explorer 10
- Microsoft Internet Explorer 9
- Microsoft Internet Explorer 8
- Microsoft Edge
- Safari
- Access to data
Personal data can be accessed by the competent staff of the Data Controller to the extent necessary for the performance of their duties.
- Data security measures
The Data Controller shall ensure adequate IT, technical and personnel measures to protect the processed personal data, including the protection of the personal data against unauthorized access or unauthorized modifications.
- Data Subject rights and their content relating to data processing
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Data processing-related
Data Subject rightsContent of Data Subject rights relating to data processing Right to be informed /GDPR, Article 13-14./
You have the right to be provided information about the fact and purpose of data processing at the time when personal data are obtained. The Data Controller provides you with additional information that are necessary to ensure fair and transparent data processing, taking into account the specific circumstances and context of the personal data processing. You must also be informed about the fact of profiling and its consequences. Right of access /GDPR, Article 15/
You are entitled to receive confirmation as to whether your personal data are being processed, and if such data processing is in progress, you will be entitled to be granted access concerning: - what personal data
- on what legal basis
- for what processing purposes
- for how long are processed by the Data Controller
- who to, when, and based on which legislation did the Data Controller provide access to your personal data or who were they transmitted to
- what source do personal data originate from (if it was not you that provided them to the Data Controller)
- whether you apply automated decision-making and its logic, including profiling as well.
Right to rectification /GDPR, Article 16/
You have the right to receive from the Data Controller upon request the rectification of inaccurate personal data concerning you or to have incomplete personal data completed. Therefore, you may ask the Data Controller to modify some of your personal data (for example, you can change your email address or other contact details at any time). Right to erasure (“right to be forgotten”) /GDPR, Article 17/
You have the right to obtain from the Data Controller the erasure of your personal data where one of the following grounds applies: - your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed
- you withdraw your consent on which the processing is based according to point (a) of Article 6 (1), or point (a) of Article 9 (2), and there is no other legal ground for the processing
- you object to data processing on the basis of Article 21 (1), and there is no overriding legitimate reason for the processing of data, or you object to data processing on the basis of Article 21 (2)
- your personal data have been unlawfully processed
- your personal data must be deleted in order to comply with a legal obligation imposed by EU or Member State law applicable to the Data Controller
- the collection of your personal data is performed in connection with offering information society services as referred in Article 8 (1).
Right to restriction /GDPR, Article 18/
You have the right to obtain from the Data Controller the restriction of your personal data where one of the following grounds applies: - The accuracy of your personal data is contested by you (in this case the restriction applies to the time period which allows the Data Controller to verify the accuracy of the personal data)
- the data processing is unlawful and you oppose to the erasure of the data and request the restriction of their use instead
- the Data Controller no longer needs the personal data for the purpose of data processing, but you require them to present, exercise or defend a legal claim
in light of Article 21 (1) you objected to data processing (in this case the restriction applies to the time period that is necessary to determine whether the Data Controller’s legitimate reasons override your legitimate reasons).
Right to data portability /GDPR, Article 20/
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 have the right to transmit those data to another Data Controller without hindrance from the Data Controller to which the personal data have been provided, where: - the processing is based on consent according to point (a) of Article 6 (1), or point (a) of Article 9 (2), or on a contract within the meaning of point b) of Article 6 (1), and
- the processing is carried out by automated means.
You also have the right – if this is technically feasible – to request that your personal data are directly transferred among Data Controllers.
Right to object /GDPR, Article 21/
You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on point (e) or (f) of Article 6 (1), including profiling based on the referred provisions. In this case the Data Controller shall not continue to process your personal data, except where the Data Controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. If your personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing purposes, which includes profiling to the extent that it is related to such direct marketing.
Right to withdraw consent /GDPR, Article 7 (3)/
You have the right to withdraw your consent at any time. Withdrawing your consent does not affect the lawfulness of the data processing performed based on consent before the withdrawal. You shall be informed of this before consent is granted. It shall be as easy to withdraw as to give consent.
- Legal remedies for Data Subjects relating to data processing, and their content
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Legal remedy Content of the remedy Right to lodge a complaint with a supervisory authority /GDPR, Article 77/
If your right to the protection of personal data is infringed, you may lodge a complaint to the following Authority: Hungarian National Authority for Data Protection and Freedom of Information
registered seat: 1055 Budapest, Falk Miksa utca 9-11.
address for correspondence: 1363 Budapest, Pf. 9.
telephone: +36 (1) 391-1400
email:ugyfelszolgalat@naih.hu
website: www.naih.huRight to effective judicial remedy against a Data Controller or Data Processor (initiation of court proceedings) /GDPR, Article 79/
You are entitled to go to court against the Data Controller or the Data Processor if you experience the unlawful processing of your personal data. The court will hear the case without delay. In this case you are free to decide whether to submit your request with the tribunal of your domicile or your residence. Contact details of the tribunals: https://birosag.hu/torvenyszekek
- Updates to the Privacy Notice
The Data Controller reserves the right to unilaterally modify this Privacy Notice. The modification of this Notice may be particularly executed if it is necessary due to changes in legislation, official data protection practices, business needs or other circumstances. At the request of the Data Subject the Data Controller sends a copy of the Privacy Notice in force to the Data Subject in the arranged format.