Privacy policy

The data controller and contact details

This notice covers the use of the drcsillag.hu website and contacting the data controller.

Data protection officer

Under Article 37 GDPR the data controller is not required to appoint a data protection officer and has not appointed one. Questions about data processing can be sent to the contact details above.

Definitions

1. “personal data”: 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. “special category data”: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic and biometric data, data concerning health, and data concerning a natural person’s sex life or sexual orientation (Article 9(1) GDPR);
3. “criminal offence data”: personal data relating to criminal convictions and offences or related security measures (Article 10 GDPR);
4. “processing”: any operation or set of operations 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;
5. “controller”: 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;
6. “processor”: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
7. “recipient”: a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not;
8. “consent of the data subject”: 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;
9. “personal data breach”: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Principles relating to the processing of personal data

Personal data shall be:

1. processed lawfully, fairly and in a transparent manner in relation to the data subject (“lawfulness, fairness and transparency”);
2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (“purpose limitation”);
3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (“data minimisation”);
4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate are erased or rectified without delay (“accuracy”);
5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes of the processing (“storage limitation”);
6. 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 is responsible for, and must be able to demonstrate, compliance with the above (“accountability”).

Processing activities

1. Contact form

The form on the Contact page of the website can be used to send a message to the data controller. Submitting the form does not create an engagement and does not involve any payment obligation.

1.) The data collected, the scope of the data and the purpose of processing:

2.) Data subjects: everyone who fills in the form, and any other persons named in the message.

3.) Retention period and deadline for erasure:

• Submitted data are stored in the website’s database, and the data controller receives an e-mail notification of them.
• If no engagement follows, the data controller erases the data from the website’s database and from the mailbox no later than 1 year after the enquiry is closed.
• If an engagement follows, the data become part of the case file and are kept for the retention periods set by Act LXXVIII of 2017 on the Activities of Attorneys (Üttv.) and Act LIII of 2017 on the Prevention and Combating of Money Laundering and Terrorist Financing (Pmt.).

4.) Recipients: the submitted data are seen only by the data controller. The data controller does not pass the data to third parties, does not use them for marketing, does not send newsletters, and uses the e-mail address only to reply to the enquiry. The data are stored by the hosting provider acting as processor.

5.) Legal basis:

1. for the name, e-mail address, phone number, type of matter and message: taking steps at the request of the data subject prior to entering into a contract, Article 6(1)(b) GDPR;
2. for any special category data in the message: processing necessary for the establishment, exercise or defence of legal claims, Article 9(2)(f) GDPR;
3. for criminal offence data: Article 10 GDPR, within the attorney’s activities under the Üttv., subject to the safeguards of attorney–client confidentiality;
4. for the technical data of the submission: the data controller’s legitimate interest in preventing abuse of the form, Article 6(1)(f) GDPR.

6.) Please note:

• providing the data is not a legal obligation, but if the data are not provided, the data controller cannot reply to the enquiry;
• the enquiry can also be sent by e-mail or by phone instead of the form.

2. Contact by phone and e-mail

1.) Data processed: the name, phone number and e-mail address provided by the data subject, and any information voluntarily given in the message or during the call. The data controller does not record phone calls.

2.) Data subjects: everyone who contacts the data controller using the contact details provided.

3.) Purpose: replying to the enquiry and arranging the consultation.

4.) Retention period: if no engagement follows, no later than 1 year after the enquiry is closed; if an engagement follows, the retention periods under the Üttv. and the Pmt.

5.) Legal basis: taking steps at the request of the data subject prior to entering into a contract, Article 6(1)(b) GDPR; for special category and criminal offence data, as set out in point 1.

3. If an engagement follows

If the enquiry leads to an engagement, the processing of the client’s data, including the customer due diligence and identification required by the Pmt., is governed by the engagement agreement and the separate information provided with it.

4. Website analytics (Google Analytics)

1.) Data processed: an online identifier (cookie), the pages viewed, the time of the visit, the device and browser type, and the approximate location. Google Analytics does not store the IP address.

2.) Purpose: producing aggregate statistics on the use of the website.

3.) Legal basis: the data subject’s consent, Article 6(1)(a) GDPR, and Section 155(4) of Act C of 2003 on Electronic Communications. Without consent, no measurement takes place.

4.) Retention period: the cookies remain in the browser for up to 2 years; Google keeps the statistical data for the retention period set in the account, for no longer than 14 months.

5.) Data transfer: the service is provided by Google Ireland Limited as processor. Data may also be transferred to the United States; Google LLC participates in the EU–US Data Privacy Framework, which is covered by an adequacy decision of the European Commission.

5. Google Maps

The map only loads if the data subject consents to external content (marketing category) in the cookie banner, or allows it with the button shown in place of the map. When it loads, Google LLC, as an independent controller, may receive data (such as the IP address) and may set cookies; see Google’s privacy policy. The “Open in Google Maps” link can be used instead of the map. Legal basis: the data subject’s consent, Article 6(1)(a) GDPR.

6. Fonts and technical logs

The website’s fonts are loaded from its own hosting; no data are sent to third parties for this. The hosting provider logs requests (IP address, time, requested address, browser) for operation and security. Legal basis: the data controller’s legitimate interest in operating the website securely, Article 6(1)(f) GDPR. The hosting provider keeps the logs for a short period under its own policy.

Processors used

Hosting provider and e-mail

• Activity: web hosting, operating the website’s database and the data controller’s mailbox
• Name: Sybell Informatika Kft.
• Address: 1138 Budapest, Tomori utca 34, 2nd floor, Hungary
• E-mail: info@sybell.hu
• Phone: +36 1 707 67 27
• Data processed: all personal data provided on the website and by e-mail, and the technical logs.
• Duration: for as long as the contract between the data controller and the hosting provider is in force, or until the data controller erases the data.

Website analytics

• Activity: aggregate measurement of website use, only with consent
• Name: Google Ireland Limited
• Address: Gordon House, Barrow Street, Dublin 4, Ireland
• Privacy policy of the service: policies.google.com/privacy

The data controller does not disclose the data to any other third party unless required to do so by law.

Cookies

The website uses cookies that are necessary for it to work and, only with the visitor’s consent, analytics cookies and cookies that load external content. The data controller does not use advertising or profiling cookies.

The cookie banner and consents are managed by the Complianz plugin. Strictly necessary cookies do not require consent under Section 155(4) of Act C of 2003 on Electronic Communications. Other cookies are only placed with consent (Article 6(1)(a) GDPR). Consent can be withdrawn at any time with the “Cookie settings” link at the bottom of the page; withdrawal does not affect the lawfulness of earlier processing. Cookies can be deleted and blocked in the browser settings, usually under Privacy.

Rights of the data subject

1. Right of access. You have the right to obtain confirmation from the data controller as to whether or not personal data concerning you are being processed and, where that is the case, access to the personal data and the information listed in the Regulation.
2. Right to rectification. You have the right to have inaccurate personal data concerning you rectified by the data controller without undue delay. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of a supplementary statement.
3. Right to erasure. You have the right to have personal data concerning you erased by the data controller without undue delay, and the data controller is obliged to erase them where certain conditions apply. Erasure may be limited by attorney–client confidentiality and statutory retention obligations.
4. Right to be forgotten. Where the data controller has made the personal data public and is obliged to erase them, the data controller, taking account of available technology and the cost of implementation, takes reasonable steps, including technical measures, to inform controllers processing the data that you have requested the erasure of any links to, or copies or replications of, those personal data.
5. Right to restriction of processing. You have the right to have the data controller restrict processing where one of the following applies:
   • you contest the accuracy of the personal data, for a period enabling the data controller to verify the accuracy of the personal data;
   • the processing is unlawful and you oppose the erasure of the data and request the restriction of their use instead;
   • the data controller no longer needs the personal data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims;
   • you have objected to processing, pending the verification whether the legitimate grounds of the data controller override yours.
6. Right to data portability. You have the right to receive the personal data concerning you, which you have provided to a controller, in a structured, commonly used and machine-readable format and to transmit those data to another controller without hindrance, where the processing is based on consent or on a contract and is carried out by automated means.
7. Right to object. You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions.
8. Objection to direct marketing. Where personal data are processed for direct marketing purposes, you have the right to object at any time to such processing. The data controller does not process personal data for direct marketing.
9. Right to withdraw consent. Where processing is based on your consent, you have the right to withdraw it at any time. Withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.
10. Automated individual decision-making, including profiling. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. The data controller does not use such automated decision-making: every enquiry is reviewed personally.

Deadline for action

The data controller informs you of the action taken on the above requests without undue delay and in any event within 1 month of receipt of the request.

Where necessary, this period may be extended by 2 months. The data controller informs you of any extension, together with the reasons for the delay, within 1 month of receipt of the request.

If the data controller does not take action on your request, it informs you without delay and at the latest within one month of receipt of the request of the reasons for not taking action, and of the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.

Security of processing

Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, the data controller and the processor implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including, as appropriate:

• access to the website and the form over an encrypted (HTTPS) connection;
• access to the submitted data by the data controller only;
• the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
• the ability to restore the availability of and access to personal data in a timely manner in the event of a physical or technical incident;
• a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.

As an attorney, the data controller is bound by professional secrecy with regard to all data and facts that come to her knowledge in the course of her practice.

Informing the data subject of a personal data breach

When a personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, the data controller communicates the personal data breach to the data subject without undue delay.

The communication to the data subject must describe in clear and plain language the nature of the personal data breach and give the name and contact details of the person from whom more information can be obtained; it must describe the likely consequences of the personal data breach and the measures taken or proposed by the data controller to address it, including, where appropriate, measures to mitigate its possible adverse effects.

The communication to the data subject is not required if any of the following conditions are met:

1. the data controller has implemented appropriate technical and organisational protection measures, and those measures were applied to the personal data affected by the breach, in particular those that render the personal data unintelligible to any person who is not authorised to access it, such as encryption;
2. the data controller has taken subsequent measures which ensure that the high risk to the rights and freedoms of data subjects is no longer likely to materialise;
3. it would involve disproportionate effort. In such a case, there must instead be a public communication or similar measure whereby the data subjects are informed in an equally effective manner.

If the data controller has not already communicated the personal data breach to the data subject, the supervisory authority, having considered the likelihood of the breach resulting in a high risk, may require it to do so.

Notifying the authority of a personal data breach

The data controller notifies the Hungarian National Authority for Data Protection and Freedom of Information of a personal data breach without undue delay and, where feasible, no later than 72 hours after becoming aware of it, unless the 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 must be accompanied by the reasons for the delay.

Complaints

If you feel that the data controller has infringed your right to the protection of your personal data, it is worth contacting the data controller first using the details above. Complaints about a possible infringement can be lodged with the Hungarian National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság):

• Hungarian National Authority for Data Protection and Freedom of Information
• 1055 Budapest, Falk Miksa utca 9–11, Hungary
• Postal address: 1363 Budapest, Pf. 9, Hungary
• Phone: +36 1 391 1400
• E-mail: ugyfelszolgalat@naih.hu
• Website: www.naih.hu

Data subjects may also go to court if their rights are infringed. Such proceedings fall within the jurisdiction of the regional court (törvényszék) and, at the data subject’s choice, may also be brought before the regional court of the data subject’s place of residence or stay.

Closing provisions

This notice was prepared with regard to the following legislation:

• 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 (General Data Protection Regulation, GDPR);
• Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information (Infotv.);
• Act LXXVIII of 2017 on the Activities of Attorneys (Üttv.);
• Act LIII of 2017 on the Prevention and Combating of Money Laundering and Terrorist Financing (Pmt.);
• Act CVIII of 2001 on Certain Issues of Electronic Commerce Services and Information Society Services;
• Act C of 2003 on Electronic Communications (in particular Section 155);
• the recommendation of the Hungarian National Authority for Data Protection and Freedom of Information on the data protection requirements of prior information.

The Hungarian version of this notice prevails.

Effective from 18 October 2026 until revoked.