Adatvédelmi nyilatkozat – Zafír Project

Data protection statement

Effective from: From 1 January 2024 · Last updated: 1 June 2025.

1. Details of the data controller

This privacy statement applies to the Zafír Project website (zafirproject.hu) and relates to data processing activities carried out in the context of the services provided by the data controller.

Name of the data controller:Adrienn Kosik-Fehér, sole trader
Registered office:3064 Szurdokpüspöki, 4 József Attila Street.
Tax number:56507081-1-32

The data controller carries out its data processing activities in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR) and Act CXII of 2011 on the right to informational self-determination and freedom of information (Info Act).

2. Data processing principles

The data controller processes personal data in accordance with the following principles:

  • Legality, due process and transparency: We process personal data only lawfully and in a manner that is transparent to the data subject.
  • Purpose-specificity: We collect personal data only for specified, explicit and legitimate purposes.
  • Data efficiency: We process personal data only to the extent and to the scope necessary.
  • Accuracy: I ensure that the personal data we process is accurate and up to date.
  • Limited shelf life: We only store personal data for as long as is necessary.
  • Integrity and confidentiality: We protect personal data by taking appropriate technical and organisational measures.

3. Scope and purpose of the data processed

3.1 Contact form

We process the following data via the contact and enquiry forms available on the website:

  • Name (first name, surname)
  • Email address
  • Telephone number (optional)
  • The content of the message

The purpose of data processing: responding to enquiries from interested parties, drawing up quotations, and establishing business contacts.

3.2 Contractual relationship

When concluding a contract of engagement, we process the following data:

  • Name or company name
  • Registered office or residential address
  • Tax registration number (for businesses)
  • Email address, telephone number
  • Bank account number (for invoicing)

The purpose of data processing: performance of the contract, invoicing, compliance with legal obligations.

3.3 Website visits (cookies)

When you visit this website, technical data (IP address, browser type, time of visit) may be recorded automatically. For further details, see the Cookie Policy in the chapter.

3.4 Newsletter (if applicable)

When you subscribe to our newsletter, we process your email address and name solely for the purpose of sending you the newsletter, based on your consent. You can unsubscribe from the newsletter at any time.

4. The legal basis for data processing

  • Consent (Article 6(1)(a) of the GDPR): contact forms, when subscribing to the newsletter.
  • Performance of a contract (Article 6(1)(b) of the GDPR): in the case of data processing carried out under a data processing agreement.
  • Compliance with a legal obligation (Article 6(1)(c) of the GDPR): in relation to the fulfilment of accounting and tax obligations.
  • Legitimate interest (Article 6(1)(f) of the GDPR): maintaining business contacts, ensuring website security.

5. Data retention period

  • Contact messages: 1 year from the date the enquiry was closed, or until the data subject submits a request for erasure.
  • Contract details: 5 years from the date of termination of the contract (the general limitation period under the Civil Code).
  • Billing details: 8 years, in accordance with Act C of 2000 on Accounting.
  • Subscribe to the newsletter: until you unsubscribe or withdraw your consent.
  • Cookies: This varies depending on the type of cookie; please see the Cookie Policy for full details.

6. Data transfer, data processors

The data controller uses the following data processors:

Web hosting provider

We use a web hosting provider to operate the website, which stores the website’s data (including visitor logs). The data processor may act solely on the instructions of the data controller.

Email provider

We use the FormSubmit.co service to process the data submitted via the contact form. The data is processed to the extent necessary for the delivery of the email.

Google services

This website may use Google Analytics 4 and Google Search Console to analyse visitor data. Google’s privacy policy: policies.google.com/privacy

Invoicing software

For invoicing, we can use the Billingo or Számlázz.hu services. These data processors handle only the data necessary for invoicing.

Important: The data controller does not sell personal data to third parties, nor does it disclose such data for marketing purposes. Personal data may only be transferred outside the European Union with the data subject’s explicit consent or subject to appropriate safeguards.

7. The rights of the data subject

Data subjects may exercise the following rights in relation to the processing of their personal data:

Right of access

The data subject is entitled to receive confirmation as to whether their personal data are being processed and, if so, is entitled to access their personal data that are being processed.

Right of rectification

The data subject has the right to have inaccurate personal data concerning them rectified by the data controller without undue delay, upon request.

Right to erasure („the right to be forgotten")

The data subject has the right to have the data controller erase personal data relating to them without undue delay upon request, if there is no legal basis for the processing of such data.

The right to restrict data processing

The data subject is entitled, upon request, to have the data controller restrict the processing of their data in specific circumstances (e.g. where the accuracy of the data is disputed).

Right to data portability

The data subject has the right to receive the personal data concerning them, which they have provided, in a structured, commonly used and machine-readable format.

The right to protest

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 based on legitimate interests.

The right to withdraw consent

Where data processing is based on consent, the data subject has the right to withdraw their consent at any time. Such withdrawal does not affect the lawfulness of the data processing carried out prior to the withdrawal.

To exercise your rights, please contact me at info@zafirproject.hu by email. We will reply to your enquiry within 30 days.

9. Data security

In the course of its data processing activities, the data controller shall implement appropriate technical and organisational measures to ensure the security of personal data, in particular against unauthorised or unlawful processing, accidental loss, destruction or damage.

  • SSL/TLS encryption to protect communication between the website and its visitors
  • Regular backups
  • Restrictions on access rights
  • Regular security updates

In the event of a data breach, the data controller shall act in accordance with the provisions of the GDPR and, where necessary, notify the relevant supervisory authority and the data subjects.

10. Legal remedies, complaint handling

If the data subject considers that the processing of their personal data infringes the provisions of the GDPR, they may lodge a complaint with the supervisory authority:

Name of authority:National Authority for Data Protection and Freedom of Information (NAIH)
Title:1055 Budapest, 9–11 Falk Miksa Street.
Website:www.naih.hu

In the event of a breach of the data subject’s rights, they may also bring the matter before a court. The proceedings may be brought – at the data subject’s discretion – before the court with jurisdiction over the data subject’s place of residence or place of stay.

If you have any questions or complaints, please contact me directly at info@zafirproject.hu via email – we aim to reply to all enquiries within 30 days.

Amendment to the declaration

The data controller reserves the right to amend this privacy policy. We will inform visitors of any amendments on the website. The current version of the policy is always available on the website.