Policies

Privacy policy

1. The data controller

Data controller: AQUA-NIVÓ Víz- és Hőtechnikai Korlátolt Felelősségű Társaság (hereinafter: the "Company" or the "Controller")

Registered office and postal address: 9700 Szombathely, Szövő utca 100.

Represented by: Márton Horváth, Imre Horváth and József Pál, managing directors, each acting independently

Phone: +36 70 779 9622

Email (including for data protection matters): info@telepszagtalanitas.hu

Website: https://www.telepszagtalanitas.hu

This notice covers the processing of personal data carried out through the website https://www.telepszagtalanitas.hu (hereinafter: the "Website"), as well as the processing of data relating to the Company's clients and business partners. This notice is always available at https://www.telepszagtalanitas.hu/policies/adatkezeles. A "Privacy policy" link in the footer of every page leads here.

Pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR), the Controller provides concise, transparent and easily understandable information on the processing of personal data.

2. Applicable legislation

  • Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation, "GDPR")

  • Act CXII of 2011 on the right to informational self-determination and freedom of information ("Infotv.")

  • Act V of 2013 on the Civil Code ("Ptk.")

  • Act CVIII of 2001 on certain issues of electronic commerce services and information society services ("Ekertv."), regarding the use of cookies

  • Act C of 2000 on Accounting, regarding the retention of accounting documents

3. Individual processing activities

3.1. Quote requests and contact via the Website forms

Data subjects: persons who complete the contact / quote request form on the Website

Data processed: name, email address, phone number, company name, content of the message; in addition, on the odour management concept design form: location, odour source, description, and whether official proceedings are under way

Purpose: responding to the enquiry, preparing a quotation, maintaining contact

Legal basis: GDPR Article 6(1)(b), taking steps at the request of the data subject prior to entering into a contract; for data of a company's representative, GDPR Article 6(1)(f), legitimate interest (maintaining contact with the partner company)

Retention period: if no contract results from the enquiry: 2 years from the enquiry; if a contract is concluded: as set out in point 3.4

Processors: Framer B.V. (serving the form), Google Ireland Limited (submissions arrive by email in Gmail), monday.com Ltd. (client and project records), Zapier Inc. (automatic transfer of data between systems)

Providing the data is voluntary, but without it we cannot respond to the enquiry.

3.2. Newsletter

Data subjects: persons who subscribe to the newsletter on the Website

Data processed: name, email address

Purpose: sending newsletters about the Company's services, events and professional materials

Legal basis: your consent (GDPR Article 6(1)(a)), given by subscribing; consent may be withdrawn at any time using the unsubscribe link in the newsletters or by sending an email to info@telepszagtalanitas.hu

Retention period: until unsubscription

Processors: Framer B.V. (subscription), Google Ireland Limited (Gmail), GrandSoft Kft. (Cronmail newsletter system)

3.3. AI chat assistant (Molin)

The chat assistant available on the Website is provided by Molin AI Ltd. If you ask a question in the chat, the service processes the content of the message and any data you provide in it (e.g. name, email address, phone number) in order to generate a response, as a processor acting on our behalf.

Data processed: chat messages and the data provided in them; a technical identifier (molin_distinct_id)

Purpose: answering visitors' questions, establishing contact

Legal basis: GDPR Article 6(1)(b) (providing information on request, a pre-contractual step); for the identifier cookie, consent

Retention period: up to 2 years from the conversation

3.4. Fulfilment of orders, invoicing

Data processed: name and contact details of the customer/contact person, billing data

Purpose: performance of the contract, invoicing

Legal basis: GDPR Article 6(1)(b) (performance of a contract); for invoicing, GDPR Article 6(1)(c) (legal obligation, Accounting Act)

Retention period: contractual data: 5 years from termination of the contract; accounting documents: 8 years (Section 169 of the Accounting Act)

Processors: Billingo Technologies Zrt. (invoicing), 3 KÖNYV-MOLY Kft. (bookkeeping), MetaBox Fulfillment Kft. (warehousing, order picking and delivery), monday.com Ltd. (client and project records)

3.5. Business contacts

For business development purposes, we collect, from publicly available sources (for example LinkedIn professional profiles, company websites, and public attendee lists of professional events), the business contact details of employees of companies for whom our services may be relevant.

Data subjects: contact persons and employees of potential and existing partner companies

Data processed: name, job title, company name, business contact details (company email address, phone number), link to the public professional profile

Source of the data: publicly available sources (LinkedIn, company websites, public materials of professional events)

Purpose: establishing and maintaining business contact, presenting our services, inviting to professional events

Legal basis: GDPR Article 6(1)(f), the Company's legitimate interest in establishing and maintaining business relationships

Retention period: 2 years from the last contact, or immediate erasure in the event of an objection

Processors: Google Ireland Limited (Gmail, Drive), monday.com Ltd. (client records)

We inform the data subject about the processing and the source of the data at the time of first contact, and at the latest within one month of obtaining the data. The data subject may object to the processing at any time at info@telepszagtalanitas.hu or in their reply to our message; in that case we erase their data and will not contact them again.

3.6. Cookies and tracking codes

A cookie is a small data file that the Website stores in the visitor's browser. On the cookie banner shown on your first visit to the Website, you can choose which cookie categories to allow. Apart from strictly necessary cookies, all cookies and tracking codes are activated ONLY after you have given your consent. You can change or withdraw your consent at any time by clicking the cookie settings icon on the Website; withdrawal does not affect the lawfulness of processing carried out before it.

Legal basis: strictly necessary cookies: Section 13/A of the Ekertv. and GDPR Article 6(1)(f) (operation of the Website); all other cookies: your consent (GDPR Article 6(1)(a)).

  • cookieyes-consent – provider: CookieYes; category: strictly necessary; purpose: remembering cookie settings; expiry: 1 year

  • _ga, _ga_W0EF22DPGL – provider: Google (Google Analytics); category: analytics; purpose: measuring traffic, anonymous statistics; expiry: 400 days

  • __oppref – provider: OpenAI; category: advertising; purpose: identifier of a click on a ChatGPT ad; expiry: 30 days

  • __obref – provider: OpenAI; category: advertising; purpose: random browser identifier for the tracking code; expiry: 365 days

  • __oaiq_consent – provider: OpenAI; category: advertising; purpose: consent status of the tracking code; expiry: 30 days

  • molin_distinct_id (+ local storage) – provider: Molin; category: functional; purpose: operation of the chat assistant, remembering the conversation; expiry: 365 days

The Website also uses the cookieless traffic measurement of its hosting provider, Framer, which does not place any cookies in the visitor's browser.

Advertising measurement (OpenAI)

If you accept advertising cookies in the cookie settings, our Website uses OpenAI's advertising tracking code (OpenAI Pixel) to measure how many of the visitors who click on our ads shown in ChatGPT go on to submit a quote request. The tracking code runs only on the thank-you page displayed after a successful quote request, and transmits only that fact to OpenAI; the data entered in the form (name, email address, phone number, message) are not transmitted. The cookies used for this are: __oppref (identifier of the ad click, 30 days), __obref (random browser identifier, 365 days). The legal basis for this processing is your consent, which you may withdraw at any time in the cookie settings; upon withdrawal, the above cookies are deleted. OpenAI processes the data collected by the tracking code as an independent controller under its own advertising terms (see point 4).

Web analytics (Google Analytics)

If you accept analytics cookies, the Website uses Google Analytics to measure traffic (pages viewed, duration of visit, device and browser type, approximate geographical location). We use the data in aggregated form to improve the Website. Google Analytics retains the data for the period set in the account, up to a maximum of 14 months.

You can also manage cookie settings in your browser: Google Chrome: https://support.google.com/chrome/answer/95647?hl=hu · Mozilla Firefox: https://support.mozilla.org/hu/kb/sutik-engedelyezese-es-tiltasa-amit-weboldak-haszn · Microsoft Edge: https://support.microsoft.com/hu-hu/microsoft-edge · Safari: https://support.apple.com/hu-hu/guide/safari/sfri11471/mac

4. Processors and recipients

The Controller uses the following processors. The processors process the data solely on the Controller's instructions, under a data processing agreement.

  • Framer B.V. – registered office: Rozengracht 207B, 1016 LZ Amsterdam, the Netherlands; activity: website hosting, serving forms

  • Viacom Informatikai Kft. – registered office: 2360 Gyál, Deák Ferenc utca 17.; activity: IT operations, domain, technical support

  • monday.com Ltd. – registered office: 52 Begin Menachem Rd, Tel Aviv, Israel; activity: CRM and project management

  • FULLSPEKTRUM Marketing, Reklám és Kiállításszervező Kft. – registered office: 1026 Budapest, Gábor Áron utca 62/A. 1. em. 2.; activity: marketing and strategy consulting

  • Notion Labs Inc. – registered office: San Francisco, USA; activity: internal documentation

  • Google Ireland Limited – registered office: Gordon House, Barrow Street, Dublin 4, Ireland; activity: email (Gmail), document storage (Drive), web analytics (Google Analytics)

  • CookieYes Limited – registered office: 3 Warren Yard, Warren Park, Wolverton Mill, Milton Keynes, MK12 5NW, United Kingdom; activity: cookie consent management and logging

  • Molin AI Ltd – registered office: 124 City Road, London, EC1V 2NX, United Kingdom; activity: AI chat assistant on the Website (processing data provided in the chat)

  • GrandSoft Kft. (Cronmail) – registered office: 4400 Nyíregyháza, Csipke u. 14. 2/1; activity: newsletter sending

  • Anthropic Ireland, Limited – registered office: 27/29 Orwell Road, Rathgar, Dublin 6, Ireland; activity: artificial intelligence-based assistant for internal administration (e.g. processing incoming emails and quote requests)

  • Billingo Technologies Zrt. – registered office: 1133 Budapest, Árbóc utca 6. I. emelet; activity: online invoicing

  • 3 KÖNYV-MOLY Kft. – registered office: 9700 Szombathely, Kőszegi u. 2.; company registration number: 18-09-102801; tax number: 11317269-2-18; activity: bookkeeping

  • MetaBox Fulfillment Kft. – registered office: 9028 Győr, Külső Veszprémi út 32.; activity: warehousing, inventory and order management, delivery of orders

  • Zapier Inc. – registered office: San Francisco, California, USA; activity: automatic transfer of data between systems

Recipients acting as independent controllers

The following providers process the data they receive not on our instructions but in their own name, as independent controllers, in accordance with their own privacy policies.

  • OpenAI Ireland Ltd – registered office: 1st Floor, The Liffey Trust Centre, 117-126 Sheriff Street Upper, Dublin 1, D01 YC43, Ireland; with regard to the data of the advertising tracking code (OpenAI Pixel), only with your consent

  • Telegram Messenger Inc. – within the EEA, stores service data in data centres in the Netherlands; in connection with internal messaging (between staff and AI assistants), which may include client data

Data transfers outside the European Economic Area (EEA)

Some of our processors and recipients may also process data outside the EEA (United Kingdom, Israel, USA). Data transfers always take place subject to the safeguards set out in Chapter V of the GDPR: for the United Kingdom and Israel, on the basis of an adequacy decision of the European Commission; for the USA, on the basis of certification under the EU–US Data Privacy Framework or the standard contractual clauses (SCC) adopted by the European Commission.

5. Data security

The Controller protects personal data against unauthorised access, alteration, transfer, disclosure, erasure or destruction by appropriate technical and organisational measures (access control, password protection, encrypted connections, regular backups). Personal data can be accessed only by those employees who need it to perform their duties. The Controller keeps a record of personal data breaches and, where necessary, reports them within 72 hours to the Hungarian National Authority for Data Protection and Freedom of Information (NAIH), and, if the breach is likely to result in a high risk, informs the data subjects.

The Controller does not carry out automated decision-making or profiling.

6. Rights of the data subject

You may exercise the following rights using the contact details given in point 1:

  • Access (GDPR Article 15): you may request information on whether we process your data and, if so, what data, for what purpose and on what legal basis, for how long, to whom we have transferred it and where it originates from; you may request a copy of the data.

  • Rectification (Article 16): you may request the correction of inaccurate data and the completion of incomplete data.

  • Erasure (Article 17): you may request the erasure of your data if it is no longer needed, if you have withdrawn your consent and there is no other legal basis, if you have objected and there are no overriding legitimate grounds, or if the processing is unlawful. We do not erase data whose retention is required by law, or which is necessary for the establishment, exercise or defence of legal claims.

  • Restriction of processing (Article 18): you may request that we only store your data for a specified period, for example if you contest its accuracy or if you need it for a legal claim.

  • Data portability (Article 20): you may receive data processed by automated means on the basis of consent or a contract in a structured, commonly used, machine-readable format, or request that it be transmitted to another controller.

  • Objection (Article 21): you may object at any time, on grounds relating to your particular situation, to processing based on legitimate interest.

  • Withdrawal of consent (Article 7(3)): where processing is based on consent, you may withdraw your consent at any time (for cookies, in the cookie settings); this does not affect the lawfulness of processing carried out before withdrawal.

We will fulfil or, with reasons, reject your request within 1 month of its receipt at the latest; where justified, this deadline may be extended by a further 2 months, of which we will notify you within 1 month. Information and action are provided free of charge. Before fulfilling your request, we may ask to verify your identity.

7. Remedies

Please first contact us with your complaint using the contact details given in point 1. In the event of an infringement, you may lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH; address: 1055 Budapest, Falk Miksa utca 9–11.; postal address: 1363 Budapest, Pf. 9.; phone: +36 1 391 1400; email: ugyfelszolgalat@naih.hu; website: www.naih.hu), or you may apply to a court. At your choice, proceedings may also be brought before the regional court competent for your place of residence or place of stay.

8. Amendments to this notice

The Controller reserves the right to amend this notice; the amended version will be published on the Website.

Effective from 9 October 2026.