Privacy Notice

Privacy Notice for Visitors and Users of the Spányi Partners Zrt. Website

Purpose of this Privacy Notice

This Privacy Notice governs the processing of personal data by Spányi Partners Zrt. (hereinafter: the “Controller”). This Privacy Notice shall remain valid until withdrawn. Any amendments shall take effect upon publication on the website accessible under the domain names spanyipartners.hu, spanyi.hu and spajak.hu (hereinafter: the “Website”). This Privacy Notice may be amended unilaterally at any time, with such amendments taking effect upon publication.

By accessing and using the Website or using the Controller’s services, visitors to the Website and users of the Controller’s services (hereinafter: the “User”) accept all the terms set out in this Privacy Notice (hereinafter: the “Notice”). Please therefore read this Notice carefully before using the Website or the services.

We collect and process only such data through our Website as are necessary and essential for the purposes specified in this Notice. Visiting the Website and using the services offered on it are voluntary; accordingly, Users also provide their data to the Controller voluntarily.

1. Details and Contact Information of the Controller

The controller of the personal data is Spányi Partners Zrt.

  • Registered office: 1123 Budapest, Győri út 16–18., 1st floor
  • Company registration number: 01-10-048398
  • Tax number: 25180549-2-43
  • EU VAT number: HU25180549
  • Email address: info@spanyipartners.hu
  • Telephone number: +36 30 500 0165
  • Website: www.spanyi.hu

2. Categories of Personal Data Processed

2.1. Contact Enquiries

Users may provide their details through the designated contact interface on the Website to contact the Controller and obtain information about the Controller’s services. The following personal data are requested when submitting a contact enquiry (fields marked with an asterisk are mandatory):

  • Name;
  • Company;
  • Email address*;
  • Message.

Only persons aged 18 or over may submit personal data.

2.3. Careers

The Controller maintains a separate Careers page on the Website to advertise current vacancies. Users may submit job applications through this interface. These data may be accessed by the Controller’s staff responsible for human resources and by the head of the department to which the application relates. The following personal data are requested when submitting an application (fields marked with an asterisk are mandatory):

  • Name;
  • Email address*;
  • CV upload.

2.4. Newsletter Subscription

Users may subscribe to a newsletter through the Website. The following personal data are requested when subscribing to the newsletter (fields marked with an asterisk are mandatory):

  • Email address*.

Users may unsubscribe from the newsletter at any time, without giving a reason, by using the unsubscribe link included in the newsletter (opt-out).

Only persons aged 18 or over may submit personal data.

3. Cookies

3.1. Purpose of Cookies

Cookies:

  • Collect information about visitors and their devices;
  • Remember visitors’ individual preferences;
  • Make the Website easier to use;
  • Provide a high-quality user experience.

To provide a personalised service, a small data file known as a cookie is placed on the User’s computer and retrieved during subsequent visits. If the browser returns a previously stored cookie, the service provider managing that cookie can associate the User’s current visit with previous visits, but only in relation to its own content.

3.2. Strictly Necessary Session Cookies

These cookies enable visitors to browse the Spányi Partners Zrt. Website fully and seamlessly, use its features and access the services available on it. These cookies remain valid until the browsing session ends. When the browser is closed, they are automatically deleted from the computer or other device used for browsing.

3.3. Third-Party Cookies (Analytics)

The Spányi Partners Zrt. Website also uses third-party cookies provided by Google Analytics. By using the Google Analytics statistical service, the Controller collects information about how visitors use the Website. This information is used to improve the Website and enhance the user experience. These cookies remain in the browser on the visitor’s computer or other browsing device until they expire or are deleted by the visitor.

4. Purposes and Duration of Processing

The purposes of processing are to establish and maintain contact with Users interested in the services provided by the Controller, to provide information to Users, and to handle comments concerning the Controller’s activities.

The Controller processes personal data for as long as the purpose of processing continues to apply. In the case of contact enquiries, this period begins when the Controller receives the enquiry and continues until the User requests the erasure of their data or withdraws their consent to the processing of their personal data.

Personal data shall be erased without delay when the purpose of processing ceases to apply or upon the User’s request.

5. Legal Basis for Processing Personal Data

When contacting the Controller, the User consents to the Controller processing the User’s personal data in accordance with this Notice. The processing of personal data is based on the User’s freely given consent, provided after reading this Notice (Article 6(1)(a) of the GDPR).

Personal data processing carried out in connection with the activities of Spányi Partners Zrt. is based on freely given consent or statutory authorisation. Where processing is based on consent, data subjects may withdraw their consent at any stage of the processing.

In certain cases, the processing, storage or transmission of certain categories of the data provided is required by law.

Persons providing data to Spányi Partners Zrt. are advised that, if they provide personal data relating to another person, they are responsible for obtaining that data subject’s consent.

Our data processing principles are consistent with the applicable data protection legislation, including, in particular:

  • Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information (Infotv.);
  • 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 V of 2013 on the Civil Code (Ptk.); Act C of 2000 on Accounting (Számv. tv.);
  • Act LIII of 2017 on the Prevention and Combating of Money Laundering and Terrorist Financing (Pmt.);
  • Act CCXXXVII of 2013 on Credit Institutions and Financial Enterprises (Hpt.).

6. Persons Authorised to Access Personal Data and Data Processing on Behalf of the Controller

The Controller and the processors engaged by it are authorised to access personal data in accordance with applicable legislation.

The following processor processes data on behalf of the Controller:

Spányi Partners Zrt.
Registered office: 1123 Budapest, Győri út 16–18.
Purpose of processing: Provision of IT and server services.

The Controller reserves the right to engage additional processors in the future. Users will be informed of this by an amendment to this Notice.

In the absence of an express statutory provision, the Controller shall disclose personally identifiable data to third parties only with the express consent of the User concerned.

7. Rights of the User

7.1. Right of Access

The data subject has the right to obtain confirmation from the Controller as to whether personal data concerning them are being processed. Where such processing takes place, the data subject has the right to access the personal data and the following information:

  • The purposes of the processing;
  • The categories of personal data concerned;
  • The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations, and the envisaged period for which the personal data will be stored;
  • The right to request rectification, erasure or restriction of processing, and the right to object to processing;
  • The right to lodge a complaint with a supervisory authority, and information concerning the sources of the data;
  • The existence of automated decision-making, including profiling, together with meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

The Controller shall provide this information no later than one month after the request is submitted.

7.2. Right to Rectification

The User may request, using the contact details specified in Section 1, that the Controller rectify inaccurate personal data or complete incomplete personal data, taking into account the purposes of the processing. The Controller shall carry out the rectification without undue delay.

7.3. Right to Erasure

The User may request that the Controller erase personal data concerning them without undue delay. The Controller shall be obliged to erase such personal data without undue delay where any of the following grounds applies:

  • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  • The User withdraws consent and there is no other legal basis for the processing;
  • The personal data have been unlawfully processed;
  • The personal data must be erased to comply with a legal obligation under Union or Member State law to which the Controller is subject;
  • The personal data were collected on the basis of consent in connection with the offer of information society services to children.

Erasure may not be requested where processing is necessary:

  • For exercising the right to freedom of expression and information;
  • For compliance with a legal obligation requiring processing under 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;
  • For reasons of public interest in the area of public health, or for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes;
  • For the establishment, exercise or defence of legal claims.

7.4. Restriction of Processing

The User has the right to request that the Controller restrict processing instead of rectifying or erasing the personal data where any of the following applies:

  • The User contests the accuracy of the personal data, in which case processing shall be restricted for a period enabling the Controller to verify their accuracy;
  • The processing is unlawful and the User opposes the erasure of the personal data and requests the restriction of their use instead;
  • The Controller no longer needs the personal data for the purposes of processing, but the User requires them for the establishment, exercise or defence of legal claims.

7.5. Action Taken by the Controller in Response to a User’s Request

The Controller shall inform the User of the action taken in response to a request for access, rectification, erasure, restriction of processing, objection to processing or data portability without undue delay and, in any event, within one month of receiving the request. Where necessary, taking into account the complexity and number of requests, this period may be extended by a further two months. The Controller shall inform the User of any such extension within one month of receiving the request, together with the reasons for the delay.

Where the User submits the request electronically, the information shall, where possible, be provided electronically, unless the data subject requests otherwise.

If the Controller does not take action on the User’s request, it shall inform the User without delay and, at the latest, within one month of receiving 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.

Information, communications and actions taken in response to the User’s request shall be provided free of charge. Where the User’s request is manifestly unfounded or excessive, in particular because of its repetitive nature, the Controller may charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested, or may refuse to act on the request. The Controller bears the burden of demonstrating that the request is manifestly unfounded or excessive.

8. Links

The Controller accepts no responsibility for the content or data protection and information security practices of external websites accessible through links on the Website. If the Controller becomes aware that a linked website or the provision of a link infringes the rights of third parties or violates applicable legislation, it shall remove the link from the Website without delay.

9. Data Security

The Controller undertakes to ensure the security of the data and to implement the technical and organisational measures and procedural rules necessary to protect the data collected, stored or otherwise processed and to prevent their destruction, unauthorised use or unauthorised alteration. The Controller also undertakes to require all third parties to whom it transmits or discloses data on the basis of Users’ consent to comply with data security requirements.

The Controller shall ensure that unauthorised persons cannot access, disclose, transmit, alter or erase the data processed. The data may be accessed only by the Controller, its employees and the processor engaged by it. The Controller shall not disclose the data to third parties who are not authorised to access them.

The Controller shall make every effort to prevent accidental damage to or destruction of the data. The Controller shall also require its employees involved in data processing activities to comply with the above obligations.

The User acknowledges and accepts that, when providing personal data through the Website, complete protection of those data over the Internet cannot be guaranteed, even though the Controller uses up-to-date security tools to prevent unauthorised access to or interception of the data. If unauthorised access to or acquisition of the data occurs despite our efforts, the Controller shall not be liable for such acquisition or unauthorised access, or for any damage suffered by the User as a result. Furthermore, the User may themselves disclose personal data to third parties who may use those data for unlawful purposes or in an unlawful manner.

10. Remedies

The Controller makes every effort to ensure that personal data are processed in accordance with the law. If, however, the User believes that the Controller has failed to do so, the User may contact the Controller at info@spanyipartners.hu.

If the User believes that their right to the protection of personal data has been infringed, they may seek a remedy, in accordance with the applicable legislation, before the competent bodies:

  • The Hungarian National Authority for Data Protection and Freedom of Information (address: 1125 Budapest, Szilágyi Erzsébet fasor 22/C.);
  • A court.

The court shall hear the case on an expedited basis. The Budapest-Capital Regional Court (Fővárosi Törvényszék) has territorial jurisdiction over the proceedings. However, at the claimant’s discretion, proceedings may also be brought before the regional court having jurisdiction over the claimant’s place of residence or place of stay.

11. Copyright Notice

The entire content of the Website is protected by copyright under Act LXXVI of 1999 on Copyright. Copying, transmitting or distributing all or any part of the Website’s content without prior written permission is prohibited. Publication or adaptation of the content available on the Website is permitted only with the operator’s prior written permission and with acknowledgement of the source.

Visitors may download, display on their screens and print the Website’s content, but may not otherwise reproduce it. Users may use the Website’s content, or any part thereof, solely for their own personal purposes. Copying for the purpose of distribution requires the Website operator’s written consent.

Unauthorised use may result in criminal and civil liability. The Website operator may claim damages or compensation for non-material harm.

12. Miscellaneous Provisions

This Notice shall be governed by Hungarian law, in particular Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information, and 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.

Budapest, 15 October 2025

Spányi Partners Zrt.
Controller