1. Data manager’s data:

Name: Ltd.

Seat: H-8272 Tagyon, Petőfi Sándor str. 7.

Tax nr.: 13412274-2-19

Company reg. nr. 19-09-515271

Customer service’s phone number: +36 1 422 1460

Customer service’s e-mail address:


  1. Scope of personal data to be managed by Ltd. for the purpose of data management: Ltd. (hereinafter: Service Provider) – in regard to the provisions of Act 112 of 2011 about the Rights of Informational Self-determination – manages the following personal data:

2.1. Personal data managed for contact keeping reasons:

  1. a)   Name of authorized representative of person availing the services of Service Provider;
  2. b)   name of person availing the services of Service Provider, name and post of contact keeper inquiring about the services of Service Provider;
  3. c)   availabilities suitable for contact keeping: e-mail address, phone number, mobile phone number.

2.2. Personal data managed for invoicing and collecting corresponding charges, monitoring the customer agreements:

  1. a)     caller and called phone numbers;
  2. b)     type, direction, starting time of call or other service, the length of talk or the size of forwarded data, unique identifier (IMEI) used when availing the service, in case of IP networks, the applied identifiers;
  3. c)      date of call or other service.

2.3. Data storage for law enforcement, national security and defense purposes:

  1. d)     in case of stationary phone service, internet access service, internet phone and mail services (or their combination), the phone number of subscriber’s or user’s end-device or subscriber’s access point, or other technical identifiers required for the user’s unique identification (as described in the Subscriber Agreement or otherwise matched to the subscriber or user by the electronic telecommunication Service Provider);
  2. e)     in case of stationary phone service, internet access service, internet phone and mail services (or their combination), the phone number of subscriber’s or user’s participating in the communication, their unique technical identifiers, user IDs, the type of availed electronic telecommunication Service, date of communication, its start and end date;
  3. f)     in case of stationary Phone Service, or call redirection/forwarding used for their combination, the intermediate subscriber or user phone numbers;
  4. g)    in case of internet electronic mail, internet phone service, or their combination, data according to point b) regarding the communication initiated to the required direction;
  5. h)   in case of internet access, internet electronic mail, internet phone Service, or their combination, the type of electronic telecommunication Service, and the date, starting and end time of availing service by the Subscriber or User, the applied IP address, user ID, phone number;
  6. i)      data required for tracking data (IP address, port number) of subscriber/user unique technical identifiers or any transformation performed by the electronic Service Provider during internet access, internet electronic mail, internet phone service, or their combination;

2.4. Audio recordings:

  1. a)     Audio recordings of reports (complaint or failure report) received at phone customer service department;
  2. b)     Audio recording of distance contract or order made via phone.


  1. Term and method of personal data management:

3.1. Term of data management:

  1. a)     Service Provider manages personal data until the forfeiture deadline following the cease of legal relationship. The forfeiture deadline in case of electronic telecommunication services – according to the 143. § (2) of Act 100 of 2003 about Electronic Telecommunication – is 1 year, in case of non-electronic telecommunication services: 5 years.
  2. b)     Audio recordings of reports received by the phone customer service, according to the Decree 2/2015 (III. 30). of NMHH about the Detailed Regulations of Subscription Agreements: 2 years from the reception of the report.
  3. c)      In case of every data regarding troubleshooting, the storage time is 1 year from the troubleshooting.
  4. d)     In case of law enforcement, defense data storage, subscriber’s data shall be stored according to 159/A. § (3) of Act 100 of 2003 about Electronic Telecommunication: 1 year following the cease or sign of Agreement; in case of unsuccessful calls: half year.
  5. e)     In case of data managed for contact keeping or sending out Service Provider’s offers, until the revocation of affected person’s consent.

3.2. Method of storage: miscellaneous (mechanical and/or paper-based storage).


  1. Title of personal data management:

Legal order, or the consent of affected person.


  1. Proper description of regulation ordering data management:

Act 100 of 2003 about Electronic Telecommunication.


  1. Service Provider’s internal data privacy desk officer:

Name: dr. Balázs Tóth-B.
Post: internal data privacy desk officer


Address: 1149 Budapest, Egressy rd. 27-29 B/3
Phone number: +36 1 422 1460


  1. Information about the security of personal data

Service Provider shall ensure the security of Service and personal data managed during providing Services, by technical and organizational measures. Security of data management is also included.

Service Provider informs the User about the risks threatening the network integrity and Service security, as well as the measures to be availed by the Customer for security purposes, nevertheless the technical and organizational measures taken by the Service Provider.

If due to an event threatening network integrity and service security, a new, yet unknown risk is experienced, Service Provider immediately informs the User at its Customer Service and on its webpage about the new security risk, the measures to be taken by the Customer in order to maintain security, and about their estimated costs.


  1. Data management information regarding personal data managed upon the consent of affected person

8.1. Direct solicitation

The purpose of data management is to make Service Provider able to contact the affected persons with its offers, or information regarding its Services using direct marketing.

8.2. Newsletter about blog posts

The purpose of data management is to make Service Provider able to send e-mail information about blog posts.

8.3. Information regarding the goals defined in points 8.1. and 8.2.:

Managed personal data:

  • name of affected person,
  • Name of employer or enterprise of affected person (company name),
  • e-mail address of affected person,
  • phone number, sector, position.

Data management is based on the consent of the affected person. Affected person provides the consent via the Service Provider’s webpage, or in written form.

Service Provider manages provided data until their revocation (by the affected person).

Affected person may revoke his/her consent to data management without assigning any reason via the following e-mail address ( or post (1149 Budapest, Egressy rd. 27-29 B/3) free of charge. Data manager erases the provided personal data at the time of revocation, and does not manage them anymore for any reasons.


  1. Rights of affected person regarding data management:

Affected person may claim the erasure, modification or information of his/her personal data at Service Provider’s customer service by phone (+36 1 422 1460), or via e-mail (

In case of violation of Privacy Policy, the affected person is entitled to seek remedy at the competent bodies: Nemzeti Adatvédelmi és Információszabadság Hatóság (National Data Privacy and Information Freedom Authority) – 1125 Budapest, Szilágyi Erzsébet fasor 22/c; phone nr.: +36 1 391 1400; fax: +36 1 391 1410; e-mail:; or – according to his/her choice – turn to the competent Court according to his/her residence.

In regard advertisements sent in electronic form, Nemzeti Média- és Hírközlési Hatóság (National Media and Telecommunication Authority) has competence, the detailed regulations are available in Act 112 of 2011 about the Rights of Informational Self-determination (‘Infotv’), and in Act 108 of 2001 about Certain Issues Regarding Informational Society.

With respect to issues of this Privacy Policy, the Hungarian Law, especially the provisions of ‘Infotv’ shall apply. According to the 6. § (5), the data manager is entitled to manage the received data without any provisions of Law, to perform its legal obligations (if this interest is in proportion to the restriction of rights to defend personal data), without any further consent, or even following the revocation.

The data management is reported to the Nemzeti Adatvédelmi és Információszabadság Hatósághoz (National Data Privacy and Informational Freedom Authority), which is registered at the following data management ID nr.: