Please read this notice carefully to understand how we process your personal data and what rights you have in relation to that processing. This English version is provided for information; in the event of any discrepancy, the Hungarian version prevails.
In the course of our business we pay particular attention to the protection of personal data, to compliance with mandatory legal requirements, and to secure and fair data processing. We recognise the principles and rules governing the protection and processing of your personal data, and we process data in accordance with them.
This notice explains the principles, process and safeguards of our data processing. We recognise the right of individuals to control their own personal data. Please note, however, that the right to the protection of personal data is not an absolute right; it must be considered in line with the principle of proportionality and balanced against other fundamental rights.
Pursuant to Article 13 of the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR"), we provide the following information:
I. Data controller
Details of the data controller:
Company name: FRONTX Kft.
Registered office: Jávorka Ádám utca 56, 1147 Budapest, Hungary
Website: https://frontx.hu
Contact: Sándor Fekete, data protection officer (internal contact)
Phone: +36 20 479 9760
Email: info@frontx.hu
Data Protection Officer: under Article 37 of the GDPR, the controller is not required to appoint a Data Protection Officer.
Data protection requests: if you have any request or question regarding data processing, you can send it by post or electronically to: 1053 Budapest, Szép utca 2., Hungary; email: info@frontx.hu. We will reply without undue delay, and in any case within 30 days, to the address you specify.
Data processing: data processing is carried out on behalf of the controller by the persons specified in the policy.
II. Applicable legislation
We always process personal data in compliance with applicable Hungarian and EU legislation and data protection principles, and we provide the safeguards required for secure processing. This privacy policy has been prepared in particular, but not exclusively, on the basis of the following legislation:
a) Regulation (EU) 2016/679 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 (the "Regulation")
b) The Fundamental Law of Hungary
c) Act V of 2013 on the Civil Code (Ptk.)
d) Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information (Infotv.)
e) Act CXIX of 1995 on the Use of Name and Address Data for Research and Direct Marketing Purposes
f) Act CVIII of 2001 on Certain Issues of Electronic Commerce Services and Information Society Services
g) Act XLVIII of 2008 on the Basic Requirements and Certain Restrictions of Commercial Advertising
h) Act XLVII of 2008 on the Prohibition of Unfair Business-to-Consumer Commercial Practices
i) Act CLV of 1997 on Consumer Protection (Fgytv.)
j) Act C of 2000 on Accounting (Számv. tv.)
III. Principles of data processing
In our data processing practice we observe the following principles:
a) lawfulness: compliance with applicable EU and Hungarian legislation at all times
b) fairness: fair procedures that respect the law and these principles
c) transparency: processing is transparent and accessible to data subjects
d) purpose limitation: data may be processed only for specified, explicit and legitimate purposes. This policy sets out the purpose of processing for the data handled by the controller, from collection through to erasure [Article 5(1)(b) of the Regulation]
e) data minimisation: in line with purpose limitation, processing is limited to data that is relevant and necessary [Article 5(1)(c) of the Regulation]
f) proportionality: the controller may restrict an individual's right to informational self-determination only in the interest of another right, and only to the extent necessary. Compliance with the principle of proportionality must be documented in each specific case to demonstrate the lawfulness of processing [Article 6(1)(f) of the Regulation]
g) accuracy: in the course of processing, and having regard to the principles of processing, inaccurate data must be rectified or erased [Article 5(1)(d) of the Regulation]
h) accountability: the controller is responsible for complying with, and ensuring compliance with, the law and this policy. The controller designs its processing operations so that compliance with data protection principles and rules can be demonstrated [Article 5(2) of the Regulation]
i) privacy by design: when designing its processing operations, the controller takes the principles of data security and data protection into account and seeks to implement them through elements built into the process [Article 26 of the Regulation]
IV. Purposes of processing
In line with the principle of purpose limitation, we process data for the following purposes:
a) we process the data of our service users to comply with legal obligations and to maintain the client relationship
b) processing the data of employees and job applicants
c) facilitating internal administration
d) statutory obligations (e.g. accounting obligations)
V. Legal bases for processing your personal data
We process your personal data on the following legal bases set out in the Regulation:
a) issuing invoices in accordance with accounting legislation: legal basis: Article 6(1)(c) GDPR
b) communication and contact: legal basis: Article 6(1)(f) GDPR
c) processing employee data: Article 6(1)(b) and (c) GDPR
d) processing data of contractual partners: legal basis: Article 6(1)(b) GDPR
e) marketing activities: legal basis: Article 6(1)(a) GDPR
The legitimate interest assessments referred to in point b) are available on request sent to info@frontx.hu.
VI. Your rights
In relation to your personal data, you have the following statutory rights:
a) right of access (to know whether processing takes place and to access the data)
b) rectification of data that is outdated or incorrect
c) erasure (only where processing is based on consent)
d) restriction of processing
e) objecting to the use of your personal data for direct marketing purposes
f) the transfer of your personal data to a third-party service provider, or objecting to such transfer
g) requesting a copy of any personal data processed by the controller
h) objecting to the use of your personal data
VII. Data processors
The controller transfers data to data processors and to other independent controllers. The recipients of such transfers are available on request sent to info@frontx.hu. The controller performs certain activities through its contractual partners; for this purpose, data processors also carry out processing operations on behalf of and on the instructions of the controller. In the data processing agreement, the controller obliges the processor to process data in accordance with the Regulation. The processor has no decision-making authority over the processing and may process the data it obtains only as instructed by the controller. The processor must notify the controller without delay of any personal data breach arising within its sphere. The controller always transfers data for a specific purpose and to a specific recipient. The controller does not act as a data processor.
VIII. Website visitor data
What is a cookie?
The controller uses cookies when you visit the website. A cookie is a package of letters and numbers that our website sends to your browser in order to save certain settings, make the website easier to use and help us collect relevant statistical information about our visitors. Cookies do not contain personal information and cannot be used to identify an individual user. Cookies often contain a unique identifier - a secret, randomly generated sequence of numbers - stored on your device. Some cookies expire when you close the website; others are stored on your computer for longer.
Legal background and legal basis for cookies:
The legal background to this processing is provided by Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information (Infotv.) and Act CVIII of 2001 on Certain Issues of Electronic Commerce Services and Information Society Services. The legal basis for processing is your consent, in accordance with Section 5(1)(a) of the Infotv.
Main characteristics of the cookies used on this website:
Google Analytics cookie: Google Analytics is Google's analytics tool that helps website and app owners better understand how visitors use their services. The service may use cookies to collect information and report website usage statistics without personally identifying individual visitors to Google. The main cookie used by Google Analytics is the "__ga" cookie. In addition to reporting website usage statistics, Google Analytics - together with some of the advertising cookies described above - may also be used to show more relevant ads in Google products (such as Google Search) and across the web.
If you do not accept the use of cookies, some features will not be available to you. For more information on deleting cookies, see the links below:
IX. Remedies
If you have any questions or comments, please contact us at:
Company name: FRONTX Kft.
Registered office: Jávorka Ádám utca 56, 1147 Budapest, Hungary
Website: https://frontx.hu
Contact: Sándor Fekete, data protection officer (internal contact)
Phone: +36 20 479 9760
Email: info@frontx.hu
You may also enforce your rights in court under the Hungarian Civil Code. At your choice, proceedings may be brought before the regional court for your place of residence or stay. You may also lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information:
Name: Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH)
Postal address: 1530 Budapest, Pf.: 5., Hungary
Address: Szilágyi Erzsébet fasor 22/c, 1125 Budapest, Hungary
Phone: +36 (1) 391-1400
Fax: +36 (1) 391-1410
Email: ugyfelszolgalat@naih.hu
URL: http://naih.hu
