Privacy Policy (hereinafter “Policy”) applies to users (“users” or “you”) of the website operated by Éva Zsuzsanna Trembácz (headquarters: 5030 Istanbul Place, Dulles VA 20189, U.S.; website: evazsuzsa.hu, hereinafter “Data Controller” or “We”).

The Data Controller processes personal data of users only to the extent necessary to achieve the purposes of data processing, in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR), Act CXII of 2011 on the right of informational self-determination and freedom of information (Info Act), the Civil Code Act V of 2013, Act XLVIII of 2008 on the basic conditions and certain restrictions of economic advertising activity, Act CVIII of 2001 on certain issues of information society services, and this Policy.

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Why do we process your personal data?

We process information about you to maintain contact with you as a user or business partner, primarily to respond to inquiries and for communication purposes. Typically, we process data related to the services provided, your name, position, and contact details such as email addresses and phone numbers. We do not record or retain data considered “special categories of data.”

Additionally, with your explicit consent, we process opinions and personal data provided as references to promote our activities.

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What personal data do we process?

Personal data may be collected directly from the data subject or from publicly available sources (e.g., company registers). These data may include:

• Identification data (name)

• Contact data (email, phone number)

• Contractual data (contract subject, description of economic events, delivery and receipt details, billing name and address)

• Communication data (email contents and other communication records)

• Reference data (opinions and personal data given as references)

• Data related to contract performance.

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Legal basis for data processing

We rely on several legal bases for processing your personal data:

• Contract performance: If you are a private individual client, the legal basis is usually Article 6(1)(b) of the GDPR. Providing personal data is voluntary.

• Legitimate interest: We also process data based on our legitimate interest in maintaining ongoing communication and business relationship with you (Article 6(1)(f) GDPR).

• Consent: In some cases, we request your consent (Article 6(1)(a) GDPR), especially for direct marketing or public use of photos, opinions, or references.

• Legal obligation: Processing may be necessary to comply with tax, accounting, or regulatory obligations (Article 6(1)(c) and (e) GDPR).

By providing personal data, you warrant that you have obtained permission to provide contact persons’ data, informed them about this Policy, and keep their data up to date.

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Who has access to your personal data?

Within the Data Controller’s organization, only authorized persons with a “need-to-know” basis may access your personal data. Outside the Data Controller, personal data may be transferred to third parties only for the following reasons:

• Service providers: The Data Controller uses IT systems and services from third parties, such as Tárhely.Eu Szolgáltató Kft., WordPress.org, hu.wordpress.org, under appropriate data processing agreements.

• Accounting service provider: Éva Zsuzsanna Trembácz, 5030 Istanbul Place, Dulles VA, U.S.A.

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Data transfer abroad

Personal data are not transferred to third countries.

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Data retention period

Personal data are stored by the Data Controller and its hosting provider only as long as necessary for fulfilling obligations and for achieving the purposes for which the data were collected. Personal data will be deleted or anonymized once they are no longer needed. If a contract exists, data are retained for the statute of limitations period (5 years). Records of contracts, communications, and business correspondence are subject to retention requirements under accounting law (minimum 8 years). Access to personal data is restricted after these periods.

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Your rights as a data subject

You may withdraw your consent to data processing at any time; this does not affect the lawfulness of processing prior to withdrawal. You have the following rights:

• Right of access: You may request confirmation whether your personal data is being processed and access to such data, including purposes and recipients. This right may be limited by the interests of others.

• Right to rectification: You may request correction of inaccurate data or completion of incomplete data.

• Right to erasure (“right to be forgotten”): Under certain conditions, you may request deletion of your data.

• Right to restriction of processing: Under certain conditions, you may request limitation of data use; in such cases data may only be processed for limited purposes.

• Right to data portability: You may request to receive your personal data in a structured, commonly used, machine-readable format and transmit it to another controller.

• Right to object: You may object to data processing for reasons related to your particular situation; if upheld, processing must cease unless legally justified. Exercising this right is free of charge and does not apply if processing is necessary for contract performance or pre-contractual steps.

• Right to lodge a complaint: You may file a complaint with the National Authority for Data Protection and Freedom of Information (NAIH).

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Contact

We are happy to provide further information or respond to requests concerning your rights. Please direct such requests to your designated contact person or send an email with the subject “DATA PROTECTION REQUEST” to: evazsuzsa@gmail.com.