WEBSITE PRIVACY POLICY

Clarity Consulting Kft. – hereinafter referred to as the Company - hereby complies
with its prior information obligation concerning the processing of personal data of data subjects prescribed by REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
by publishing this privacy policy, according to which every piece of information under the relevant articles of the Regulation must be provided to the data subjects in a concise, transparent, intelligible
and easily accessible form, using clear and plain language.

I. NAME OF THE DATA CONTROLLER

The Company informs the data subject that it constitutes a data controller
regarding the processing of their personal data.
COMPANY NAME: Clarity Consulting Kft.
REGISTERED OFFICE: 1145 Budapest, Erzsébet királyné útja 29/B
COMPANY REGISTRATION NUMBER: 900711-01-09
TAX NUMBER: 12735345-2-42
PHONE: 1/4223030
REPRESENTED BY: Gyula Csorba, Managing Director
E-MAIL: info@clarity.hu
WEBSITE: www.clarity.hu

Personal data may be accessed by employees of the Company who have access rights
associated with the relevant data processing purpose, as well as persons and organisations performing data processing activities for the Company on the basis of service contracts,
to the extent specified by the Company and to the extent necessary to perform their activities.

II. DEFINITIONS

1. “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;

2. “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;

3. “restriction of processing”: means the marking of stored personal data with the aim of limiting their processing in the future;

4. “profiling”: means any form of automated processing of personal data consisting of the use of personal data
   to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health,
   personal preferences, interests, reliability, behavior, location
   or movements;

5. “pseudonymization”: means the processing of personal data in such a manner that the personal data
   can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and
   is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable
   natural person;

6. “filing system”: means any structured set of personal data which are accessible according to specific criteria,
   whether centralized, decentralized or dispersed on a functional or geographical basis;

7. “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 controller or the specific criteria
   for its nomination may be provided for by Union or Member State law;

8. “processor”: means a natural or legal person, public authority, agency or other
   body which processes personal data on behalf of the controller;

9. “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. However,
   public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law
   shall not be regarded as recipients; the processing of those data by those
   public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;

10. “third party”: means a natural or legal person, public authority, agency or
    body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor,
    are authorized to process personal data;

11. “consent of the data subject”: means any freely given, specific, informed
    and unambiguous indication of the data subject's wishes by which he or she, by a statement or by
    a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

12. “personal data breach”: means a breach of security leading to the accidental or unlawful destruction, loss,
    alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed;

13. “undertaking”: means a natural or legal person engaged in an economic activity, irrespective
    of its legal form, including partnerships or associations regularly engaged in an economic activity.

    
    III. LEGAL BASIS OF DATA PROCESSING
    
    The Data Protection Officer (DPO) of the Company is Zsófia Dely, representing the DR. DELY ZSÓFIA Law Office,
    who performs the data protection duties defined in the Company's policies.
    Contact details:
    DR. DELY ZSÓFIA Law Office
    Dr. Zsófia Dely attorney-at-law
    address: 1055 Budapest, Szalay utca 4. VI. floor
    phone: Tel.: +36/1-332-1943

    Consent of the data subject
    
    (1) The lawfulness of the processing of personal data must be based on the consent of the data subject, or
    must have some other lawful basis established by law.
    (2) In case of data processing based on the data subject's consent, the data subject may give their consent
    to the processing of their personal data in the following form:
    a) in writing, in the form of a declaration giving consent to the processing of personal data,
    b) by electronic means, by clear affirmative action on the Company's website,
    by ticking a box, or if they perform technical settings to this effect while using information society services,
    as well as any other statement or action which clearly indicates in this context the data subject's consent to the planned processing of their personal
    data.
    (3) Silence, pre-ticked boxes or inactivity should therefore not constitute consent. (4)
    Consent covers all processing activities carried out for the same purpose or purposes.
    (5) If the processing has multiple purposes, consent should be given for all of them. If the data subject's consent is given following an electronic request,
    the request must be clear and concise, and it must not unnecessarily disrupt the use of the service
    for which the consent is requested.
    (6) The data subject shall have the right to withdraw his or her consent at any time. The withdrawal of consent
    shall not affect the lawfulness of processing based on consent before its withdrawal. Prior to giving consent, the data subject shall be informed thereof. It shall be as easy
    to withdraw as to give consent.

    Performance of a contract
    
    (1) Data processing is considered lawful if it is necessary for the performance of a contract to which the
    data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
    (2) Data subject consent to the processing of personal data that is not necessary for the performance of the contract
    cannot be a condition for entering into the contract.

    Compliance with a legal obligation to which the controller is subject, or protection of the vital interests of the data subject or of another natural
    person
    
    (1) The legal basis for processing in case of compliance with a legal obligation is determined by law, therefore the
    consent of the data subject to the processing of their personal data is not required.
    (2) The controller is obliged to inform the data subject about the purpose, legal basis, duration of the data processing,
    the identity of the controller, as well as their rights and the available remedies.
    (3) Under the legal basis of compliance with a legal obligation, the controller is entitled to process the data category
    which is necessary for compliance with a legal obligation to which it is subject, even after the data subject has withdrawn their consent.
    
    

    Performance of a task carried out in the public interest or in the exercise of official authority vested in the controller,
    or for the purposes of the legitimate interests pursued by the controller or by a third party.
    
    (1) The legitimate interests of a controller – including those of a controller to whom the
    personal data may be disclosed – or of a third party may provide a legal basis for processing, provided that the interests
    or the fundamental rights and freedoms of the data subject are not overriding, taking into consideration the reasonable expectations of the data subject based on their relationship with the controller. Such legitimate interest could exist, for example,
    where there is a relevant and appropriate relationship between the data subject and the controller, such as
    in situations where the data subject is a client or in the service of the controller.
    (2) In any case, the existence of a legitimate interest would need careful assessment including
    whether a data subject can reasonably expect at the time and in the context of the collection of the personal data that processing for that purpose may take place.
    (3) The interests and fundamental rights of the data subject could override the interest of the data controller if
    personal data are processed in circumstances where data subjects do not
    reasonably expect further processing.

    
    IV. RIGHTS OF THE DATA SUBJECT CONCERNING THE PROCESSING OF THEIR PERSONAL DATA

    The Company briefly provides the following information regarding the rights of the data subject:
    The data subject has the right:
    a) to be informed before the data processing starts,
    b) to obtain from the controller confirmation as to whether or not personal data concerning
    him or her are being processed, and, where that is the case, access to the personal
    data and the following information,
    c) to request rectification or erasure of their data, and to be notified by the controller of such action, d)
    to request restriction of processing, and to be notified by the controller of such action,
    e) to data portability,
    f) to object, if their personal data are processed for purposes of public interest or on the grounds of the legitimate interests
    of the controller,
    g) not to be subject to a decision based solely on automated processing, including profiling,
    h) to lodge a complaint with a supervisory authority. The data subject can exercise their right to lodge a complaint at the following
    contact details: National Authority for Data Protection and Freedom of Information, address: 1125
    Budapest, Szilágyi Erzsébet fasor 22/c., Phone: +36 (1) 391-1400; Fax: +36(1)391-1410., www: http://www.naih.hu e-mail: ugyfelszolgalat@naih.hu i) to an effective judicial remedy against a supervisory
    authority,
    j) to an effective judicial remedy against a controller or a processor,
    k) to be informed of a personal data breach.

    Detailed information on data subject rights
    
    Right to be informed
    
    (1) The data subject has the right to receive information related to the data processing prior to
    the commencement of any activity aiming to process their data.
    (2) Information to be provided where personal data are collected from the data subject:
    a. the identity and the contact details of the controller and, where applicable, of the controller's representative;
    b. the contact details of the data protection officer, where applicable;
    c. the purposes of the processing for which the personal data are intended as well as the legal basis for the processing;
    d. where the processing is based on point (f) of Article 6(1) of the Regulation, the legitimate interests pursued by the controller or
    by a third party;
    e. the recipients or categories of recipients of the personal data, if any;
    g. where applicable, the fact that the controller intends to transfer personal data to a third country or international organization
    and the existence or absence of an adequacy decision by the Commission, or in the case of transfers referred to in Article 46 or 47, or the second subparagraph of Article 49(1) of the Regulation, reference to the appropriate or suitable
    safeguards and the means by which to obtain a copy of them or where they have been made available.
    (3) In addition to the information referred to in paragraph (1), the controller shall, at the time
    when personal data are obtained, provide the data subject with the following further information necessary to ensure
    fair and transparent processing:
    a. the period for which the personal data will be stored, or if that is not possible, the criteria used to
    determine that period;
    b. the existence of the right to request from the controller access to and rectification or erasure of personal data
    or restriction of processing concerning the data subject or to object to processing as well as the right to data portability;
    c. where the processing is based on point (a) of Article 6(1) or point (a) of Article 9(2) of the Regulation,
    the existence of the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
    d. the right to lodge a complaint with a supervisory authority;
    e. whether the provision of personal data is a statutory or contractual requirement, or a requirement
    necessary to enter into a contract, as well as whether the data subject is obliged to provide the personal data and of the possible consequences of failure to provide such data;
    f. the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the Regulation
    and, at least in those cases, meaningful information about the logic involved, as well as the significance and
    the envisaged consequences of such processing for the data subject.
    (4) Where personal data have not been obtained from the data subject, the controller shall provide the data subject with
    the following information:
    a. the identity and the contact details of the controller and, where applicable, of the controller's representative;
    b. the contact details of the data protection officer, where applicable;
    c. the purposes of the processing for which the personal data are intended as well as the legal basis for the processing;
    d. the categories of personal data concerned;
    e. the recipients or categories of recipients of the personal data, if any;
    f. where applicable, that the controller intends to transfer personal data to a recipient in a third country or international organization
    and the existence or absence of an adequacy decision by the Commission, or in the case of transfers referred to in Article 46, Article 47 of the Regulation, or the second subparagraph of Article 49(1),
    reference to the appropriate or suitable safeguards and the means to obtain a copy of them or where they have been made available.
    (2) In addition to the information referred to in paragraph (1), the controller shall provide the data subject
    with the following further information necessary to ensure fair and transparent data processing in respect of the data subject:
    a. the period for which the personal data will be stored, or if that is not possible, the criteria used to
    determine that period;
    b. where the data processing is based on point (f) of Article 6(1) of the Regulation, the legitimate interests pursued by the controller
    or by a third party;
    c. the existence of the right to request from the controller access to and rectification or erasure of personal data or restriction
    of processing concerning the data subject and to object to processing of personal data as well as the right to data portability;
    d. where the processing is based on point (a) of Article 6(1) or point (a) of Article 9(2) of the Regulation,
    the existence of the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
    e. the right to lodge a complaint with a supervisory authority;
    f. from which source the personal data originate, and if applicable, whether it came from publicly
    accessible sources; and
    g. the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the Regulation
    and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences
    of such processing for the data subject.
    (3) Where the controller intends to further process the personal data for a purpose other than that for which they were
    obtained, the controller shall provide the data subject prior to that further processing with information on that other purpose
    and with any relevant further information as referred to in paragraph (2).
    (4) Paragraphs (1) to (3) shall not apply if and in so far as:
    a. the data subject already has the information;
    b. the provision of such information proves impossible or would involve a disproportionate
    effort, in particular for processing for archiving purposes in the public interest, scientific or historical research
    purposes or statistical purposes, subject to the conditions and safeguards referred to in Article 89(1), or in so far as
    the obligation referred to in paragraph (1) of this Article is likely to render impossible or seriously impair the achievement of the objectives
    of that processing. In such cases the controller shall take appropriate measures
    – including making the information publicly available – to protect the data subject's rights and freedoms and legitimate interests;
    c. obtaining or disclosure is expressly laid down by Union or Member State law to which the controller is subject and
    which provides appropriate measures to protect the data subject's legitimate interests; or
    d. where the personal data must remain confidential subject to an obligation of professional secrecy regulated by Union
    or Member State law, including a statutory obligation of secrecy.
    
    Right of access by the data subject
    
    (1) The data subject shall have the right to obtain from the controller confirmation as to whether or not
    personal data concerning him or her are being processed, and, where that is the case, access to the personal
    data and the following information:
    a. the purposes of the processing;
    b. the categories of personal data concerned;
    c. the recipients or categories of recipient to whom the personal data have been or will be disclosed,
    in particular recipients in third countries or international organizations;
    d. where possible, the envisaged period for which the personal data will be stored, or, if not possible,
    the criteria used to determine that period;
    e. the existence of the right to request from the controller rectification or erasure of personal data
    or restriction of processing of personal data concerning the data subject or to object to such processing;
    f. the right to lodge a complaint with a supervisory authority;
    g. where the personal data are not collected from the data subject, any available information as to their source;
    h. the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the Regulation
    and, at least in those cases, meaningful information about the logic involved, as well as the significance and
    the envisaged consequences of such processing for the data subject.
    (2) Where personal data are transferred to a third country or to an international organization,
    the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.
    (3) The controller shall provide a copy of the personal data undergoing processing to the data subject.
    For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative
    costs. Where the data subject makes the request by electronic means, the information shall be provided in a commonly used electronic form, unless otherwise requested by the data subject.
    
    Right of the data subject to rectification and erasure
    
    Right to rectification
    
    (1) The data subject shall have the right to obtain from the controller without undue delay the rectification of
    inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
    Right to erasure (“right to be forgotten”)
    (1) The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
    a. the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
    b. the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1) (consent to the processing of personal data) or point (a) of Article 9(2) of the Regulation (giving explicit consent), and where there is no other legal ground for the processing;
    c. the data subject objects to the processing pursuant to Article 21(1) (right to object) of the Regulation, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) (objection to processing of personal data for direct marketing purposes) of the Regulation;
    d. the personal data have been unlawfully processed;
    e. the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
    f. the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).
    (2) Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data,
    the controller, taking into account available technology and the cost of implementation, shall take reasonable steps – including technical measures – to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
    (3) Paragraphs (1) and (2) shall not apply to the extent that processing is necessary:
    a. for exercising the right of freedom of expression and information;
    b. for compliance with a legal obligation which requires processing by Union or Member State law to which the controller
    is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
    c. for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3) of the Regulation;
    d. for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) of the Regulation in so far as the right referred to in paragraph (1) is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
    e. for the establishment, exercise or defense of legal claims.
    
    Right to restriction of processing
    
    (1) The data subject shall have the right to obtain from the controller restriction of processing where one of the
    following applies:
    a. the accuracy of the personal data is contested by the data subject, for a period enabling the controller
    to verify the accuracy of the personal data;
    b. the processing is unlawful and the data subject opposes the erasure of the personal data and requests
    the restriction of their use instead;
    c. the controller no longer needs the personal data for the purposes of the processing, but they are required
    by the data subject for the establishment, exercise or defense of legal claims; or
    d. the data subject has objected to processing pursuant to Article 21(1) of the Regulation; in this case
    the restriction applies pending the verification whether the legitimate grounds of the controller override those of the data subject.
    (2) Where processing has been restricted under paragraph (1), such personal data shall, with the exception of storage,
    only be processed with the data subject's consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
    (3) A data subject who has obtained restriction of processing pursuant to paragraph (1) shall be informed
    by the controller before the restriction of processing is lifted.
    
    Notification obligation regarding rectification or erasure of personal data or restriction of
    processing
    
    (1) The controller shall communicate any rectification or erasure of personal data or restriction of processing
    carried out to each recipient to whom the personal data have been disclosed, unless this proves impossible
    or involves disproportionate effort.
    (2) The controller shall inform the data subject about those recipients if the data subject requests it.
    
    Right to data portability
    
    (1) The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided
    to a controller, in a structured, commonly used and machine-readable format and have the right to transmit
    those data to another controller without hindrance from the controller to which the personal data have been provided, where:
    a. the processing is based on consent pursuant to point (a) of Article 6(1) (data subject's consent to the processing of personal data) or point (a) of Article 9(2) (data subject's explicit consent to processing) of the Regulation, or on a contract pursuant to point (b) of Article 6(1); and
    b. the processing is carried out by automated means.
    (2) In exercising his or her right to data portability pursuant to paragraph (1), the data subject shall have the right
    to have the personal data transmitted directly from one controller to another, where technically feasible.
    (3) The exercise of the right referred to in paragraph (1) of this Article shall be without prejudice to Article 17 of the Regulation. That right
    shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
    (4) The right referred to in paragraph (1) shall not adversely affect the rights and freedoms of others.
    
    

    Right to object

    (1) The data subject shall have the right to object, on grounds relating to his or her particular situation,
    at any time to processing of personal data concerning him or her which is based on public interest or in the exercise of official authority,
    or necessary for the purposes of the legitimate interests pursued by the controller or by a third party (processing based on point (e) or (f) of Article 6(1) of the Regulation),
    including profiling based on those provisions. The controller shall no longer process the
    personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests,
    rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.
    (2) Where personal data are processed for direct marketing purposes, the data subject shall have the right
    to object at any time to processing of personal data concerning him or her for such marketing,
    which includes profiling to the extent that it is related to such direct marketing.
    (3) Where the data subject objects to processing for direct marketing purposes, the personal data
    shall no longer be processed for such purposes.
    (4) At the latest at the time of the first communication with the data subject, the right referred to in paragraphs (1) and (2)
    shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately
    from any other information.
    (5) In the context of the use of information society services, and notwithstanding Directive 2002/58/EC,
    the data subject may exercise his or her right to object by automated means using technical specifications.
    (6) Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant
    to Article 89(1) of the Regulation, the data subject, on grounds relating to his or her particular situation,
    shall have the right to object to processing of personal data concerning him or her,
    unless the processing is necessary for the performance of a task carried out for reasons of public interest.
    
    Right to exemption from automated decision-making
    
    (1) The data subject shall have the right not to be subject to a decision based solely on automated processing,
    including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
    Paragraph (1) shall not apply if the decision:
    a. is necessary for entering into, or performance of, a contract between the data subject and a data controller;
    b. is authorized by Union or Member State law to which the controller is subject and which also lays down
    suitable measures to safeguard the data subject's rights and freedoms and legitimate interests; or
    c. is based on the data subject's explicit consent.
    (3) In the cases referred to in points (a) and (c) of paragraph (2), the data controller shall implement suitable
    measures to safeguard the data subject's rights and freedoms and legitimate interests,
    at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.
    (4) Decisions referred to in paragraph (2) shall not be based on special categories of personal data referred to in Article 9(1)
    of the Regulation, unless point (a) or (g) of Article 9(2) applies and suitable measures to safeguard the data subject's rights and freedoms and legitimate interests are in place.
    
    Right of the data subject to lodge a complaint and to judicial remedy
    
    Right to lodge a complaint with a supervisory authority.
    
    (1) Without prejudice to Article 77 of the Regulation, every data subject shall have the right to lodge a complaint with a supervisory authority,
    if the data subject considers that the processing of personal data relating to him or her infringes this Regulation. (2)
    The data subject can exercise their right to lodge a complaint at the following contact details:
    National Authority for Data Protection and Freedom of Information address: 1125 Budapest, Szilágyi Erzsébet fasor
    22/c Phone: +36 (1) 391-1400; Fax: +36 (1) 391-1410 www: http://www.naih.hu
    e-mail: ugyfelszolgalat@naih.hu
    (3) The supervisory authority with which the complaint has been lodged shall inform the complainant on the
    progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Article 78 of the Regulation.
    
    Right to an effective judicial remedy against a supervisory authority
    
    (1) Without prejudice to any other administrative or non-judicial remedy, each natural or legal
    person shall have the right to an effective judicial remedy against a legally binding decision of a supervisory authority concerning them.
    (2) Without prejudice to any other administrative or non-judicial remedy, each data subject
    shall have the right to an effective judicial remedy where the supervisory authority which is competent does not handle
    a complaint or does not inform the data subject within three months on the progress or outcome of the complaint lodged pursuant to Article 77 of the Regulation.
    (3) Proceedings against a supervisory authority shall be brought before the courts of the Member State where
    the supervisory authority is established.
    (4) Where proceedings are brought against a decision of a supervisory authority which was preceded by an opinion
    or a decision of the Board in the consistency mechanism, the supervisory authority shall forward that opinion or decision to the court.
    Right to an effective judicial remedy against a controller or processor
    (1) Without prejudice to any available administrative or non-judicial remedy, including the right to lodge
    a complaint with a supervisory authority pursuant to Article 77, each data subject shall have the right to an effective judicial remedy if he or she considers that his or her rights under this Regulation have been infringed as a result of the processing of his or her personal data in non-compliance with this Regulation.
    (2) Proceedings against a controller or a processor shall be brought before the courts of the Member State where the controller
    or processor has an establishment. Alternatively, such proceedings may be brought before the courts of the Member State where
    the data subject has his or her habitual residence, unless the controller or processor is a public authority of a Member State acting in the exercise of its public powers.
    Restrictions
    (1) Union or Member State law to which the data controller or processor is subject may restrict by way of legislative
    measures the scope of the obligations and rights provided for in Articles 12 to 22 and Article 34, as well as Article 5 in so far as its provisions correspond to the rights and obligations provided for in Articles 12 to 22, when such a restriction respects the essence of the fundamental rights and freedoms and is a necessary and proportionate measure in a democratic society to safeguard:
    a. national security;
    b. defense;
    c. public security;
    d. the prevention, investigation, detection or prosecution of criminal offences or the execution of
    criminal penalties, including the safeguarding against and the prevention of threats to public security;
    e. other important objectives of general public interest of the Union or of a Member State, in particular
    an important economic or financial interest of the Union or of a Member State, including monetary, budgetary
    and taxation matters, public health and social security;
    f. the protection of judicial independence and judicial proceedings;
    g. the prevention, investigation, detection and prosecution of breaches of ethics for regulated professions;
    h. a monitoring, inspection or regulatory function connected, even occasionally, to the exercise of official
    authority in the cases referred to in points (a) to (e) and (g);
    i. the protection of the data subject or the rights and freedoms of others;
    j. the enforcement of civil law claims.
    (2) In particular, any legislative measure referred to in paragraph (1) shall contain specific provisions
    at least, where relevant, as to:
    a. the purposes of the processing or categories of processing,
    b. the categories of personal data,
    c. the scope of the restrictions introduced,
    d. the safeguards to prevent abuse or unauthorized access or transfer,
    e. the specification of the controller or categories of controllers,
    f. the storage periods and the applicable safeguards taking into account the nature, scope and purposes of the processing
    or categories of processing,
    g. the risks to the rights and freedoms of data subjects, and
    h. the right of data subjects to be informed about the restriction, unless that may be prejudicial to the purpose of the restriction.
    Information on a personal data breach
    (1) When the personal data breach is likely to result in a high risk to the rights and freedoms of natural
    persons, the controller shall communicate the personal data breach to the data subject without undue delay.
    (2) The communication to the data subject referred to in paragraph (1) shall describe in clear and plain language
    the nature of the personal data breach and contain at least:
    the name and contact details of the data protection officer or other contact point where more information can be obtained; the likely consequences of the personal data breach; the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.
    (3) The communication to the data subject referred to in paragraph (1) shall not be required if any of the following
    conditions are met:
    a. the controller has implemented appropriate technical and organizational protection measures, and those
    measures were applied to the personal data affected by the personal data breach, in particular those that
    render the personal data unintelligible to any person who is not authorized to access it, such as encryption;
    b. the controller has taken subsequent measures which ensure that the high risk to the rights and freedoms of
    data subjects referred to in paragraph (1) is no longer likely to materialize;
    c. it would involve disproportionate effort. In such a case, there shall instead be a public
    communication or similar measure whereby the data subjects are informed in an equally effective manner.
    (4) If the controller has not already communicated the personal data breach to the data subject, the supervisory
    authority, after having considered the likelihood of the personal data breach resulting in a high risk,
    may require it to do so or may decide that any of the conditions referred to in paragraph (3) are met.

    V. PROCEDURE APPLICABLE IN CASE OF DATA SUBJECT REQUESTS
    
    (1) The Company shall facilitate the exercise of data subject rights, and cannot refuse to comply with a request
    of the data subject for exercising their rights as recorded in this privacy policy, unless the controller demonstrates
    that it is not in a position to identify the data subject.
    (2) The Company shall provide information on action taken on a request to the data subject without undue delay
    and in any event within one month of receipt of the request. That period may be extended by two further months
    where necessary, taking into account the complexity and number of the requests. The controller shall inform the data subject
    of any such extension within one month of receipt of the request, together with the reasons for the delay.
    (3) If the data subject makes the request by electronic form, the information shall be provided by electronic means
    where possible, unless otherwise requested by the data subject.
    (4) If the Company does not take action on the request of the data subject, the controller shall inform the data subject
    without delay and at the latest within one month of receipt of the request of the reasons for not taking action
    and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.
    (5) The Company shall provide the following information and action to the data subject free of charge:
    feedback on the processing of personal data, access to the processed data, rectification, completion,
    erasure of data, restriction of processing, data portability, objection to processing, and communication of a personal data breach.
    (6) Where requests from a data subject are manifestly unfounded or excessive, in particular because of
    their repetitive character, the controller, taking into account the administrative costs of providing the information
    or communication or taking the action requested: may charge a fee of HUF 5,000, or refuse to act on the request.
    (7) The controller shall bear the burden of demonstrating the manifestly unfounded or excessive character of the request.
    (8) Without prejudice to Article 11 of the Regulation, where the controller has reasonable doubts concerning the identity
    of the natural person making the request under Articles 15 to 21 of the Regulation,
    the controller may request the provision of additional information necessary to confirm the identity of the data subject.

    VI. PROCEDURE APPLICABLE IN CASE OF A PERSONAL DATA BREACH
    
    (1) According to the Regulation, a personal data breach means a breach of security leading to the accidental or
    unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted,
    stored or otherwise processed.
    (2) A personal data breach includes the loss or theft of a device containing personal data (laptop, mobile phone),
    or if a code used to decrypt files encrypted by the data controller is lost or becomes inaccessible, infection by ransomware
    which makes the data processed by the data controller inaccessible until the ransom is paid,
    attacks on the IT system, mistakenly sent email containing personal data, disclosure of a mailing list, etc.
    (3) Upon detection of a personal data breach, the representative of the Company shall immediately conduct an investigation
    to identify the personal data breach and determine its potential consequences. Necessary measures must be taken
    to mitigate damages.
    (4) The controller shall notify the personal data breach to the supervisory authority competent without undue delay
    and, where feasible, not later than 72 hours after having become aware of it, unless the personal data breach
    is unlikely to result in a risk to the rights and freedoms of natural persons. Where the notification is not made within 72 hours,
    it shall be accompanied by reasons for the delay.
    (5) The processor shall notify the controller without undue delay after becoming aware of a personal data breach.
    (6) The notification referred to in paragraph (3) shall at least:
    a. describe the nature of the personal data breach including where possible, the categories and
    approximate number of data subjects concerned and the categories and approximate number of personal data records concerned;
    b. communicate the name and contact details of the data protection officer or other contact point where
    more information can be obtained;
    c. describe the likely consequences of the personal data breach;
    d. describe the measures taken or proposed to be taken by the controller to address the personal data breach,
    including, where appropriate, measures to mitigate its possible adverse effects.
    (7) Where, and in so far as, it is not possible to provide the information at the same time, the information
    may be provided in phases without undue further delay.
    (8) The controller shall document any personal data breaches, comprising the facts relating to the personal data breach,
    its effects and the remedial action taken. That documentation shall enable the supervisory authority to verify
    compliance with Article 33 of the Regulation.

    VII. DATA PROCESSING RELATED TO THE WEBSITE
    
    Information regarding the data of visitors to the Company's website
    (1) During visits to the Company's website, one or more cookies - small packets of information
    sent by the server to the browser, and then sent back by the browser to the server upon every request
    directed towards the server - are sent to the computer of the person visiting the website, which uniquely
    identifies their browser, provided that the person visiting the website has given their explicit (active)
    consent following clear and unambiguous information through their behavior to continue browsing the website.
    (2) Cookies operate solely to improve user experience and automate the login process. The cookies used
    on the website do not store information suitable for personal identification, and the Company does not conduct personal data processing in this scope.

    VIII. DATA PROCESSING ACTIVITIES RELATED TO THE PERFORMANCE OF A CONTRACT
    
    (1) The Company performs the processing of personal data of natural persons contracting with it – clients,
    customers, suppliers – in connection with the contractual relationship. The data subject must be informed about
    the processing of their personal data.
    (2) Scope of data subjects: all natural persons who establish a contractual relationship with the Company.
    (3) The legal basis for the processing is the performance of a contract; the purpose of the processing is maintaining contact,
    enforcing claims arising from the contract, and ensuring compliance with contractual obligations.
    (4) Recipients of the personal data: the manager of the Company, and the employees and processors of the Company
    carrying out customer service and accounting tasks based on their job descriptions.
    (5) Scope of processed personal data: name, address, registered office, phone number, email address, tax number,
    bank account number, sole proprietor license number, primary producer license number.
    (6) Duration of data processing: 5 years from the termination of the contract.
    
    IX. PROVISIONS ON DATA SECURITY
    
    (1) The Company may process personal data only in accordance with the activities recorded in this policy,
    consistent with the purpose of data processing.
    (2) The Company ensures the security of the data, and in this scope undertakes to take all technical
    and organizational measures that are absolutely necessary to enforce data protection and confidentiality laws
    and rules, and to establish the procedural rules necessary for the compliance with the laws specified above.
    (3) The Company protects the data by appropriate measures against unauthorized access, alteration, transmission,
    disclosure, erasure or destruction, as well as accidental destruction and damage, and inaccessibility
    resulting from changes in the technology used.
    (4) The technical and organizational measures to be implemented by the Company for data security are recorded
    in the Company's data protection policy.
    (5) When defining and applying measures to ensure data security, the Company takes into account the current state of technology,
    and in case of several possible data processing solutions, selects the solution providing a higher level of protection
    for personal data, unless this would cause disproportionate difficulty.

    X. RULES ON DATA PROCESSING
    
    General rules on data processing
    (1) The rights and obligations of the processor regarding the processing of personal data are defined by the controller
    within the framework of the law and specific laws on data processing.
    (2) The Company declares that the processor has no competence to make substantive decisions regarding the data processing
    during its activities; the processor may process the personal data it becomes aware of solely in accordance with the controller's instructions, cannot carry out data processing for its own purposes, and is obliged to store and preserve personal data in accordance with the controller's instructions.
    (3) The Company is responsible for the lawfulness of the instructions given to the processor regarding data processing operations.
    (4) The Company is obliged to provide information to data subjects about the identity of the processor and the location of the data processing.
    (5) The Company does not authorize the processor to employ a sub-processor.
    (6) The contract for data processing must be in writing. An organization interested in business activities
    utilizing the personal data to be processed cannot be commissioned with data processing.
    
    Dated: March 31, 2026