Data Processing

# PRIVACY AND DATA SECURITY STATEMENT

## DATA PROCESSING INFORMATION OF TAKLER KÚRIA Kft.

### Principles and practices regarding data protection and data processing

TAKLER KÚRIA Kft. – hereinafter referred to as the **Service Provider / Data Controller** – as the operator of the website **taklerkuria.hu** (“Website”), hereby publishes its principles regarding data protection and data processing, which it acknowledges as binding upon itself.

Before using the Website, please carefully read this Privacy Notice (“Notice”).

---

# DETAILS OF THE DATA CONTROLLER

The controller of the data is **TAKLER KÚRIA Kft.**, the operator of the Website (“Data Controller”).

**Registered office:**
H-7144 Decs, Decsi Szőlőhegy 1799. hrsz. PL 57.

**Operator:**
TAKLER KÚRIA KFT
H-7100 Szekszárd, Bem utca 13.

**Telephone/Fax:** +36 74 311 961
**Mobile:** +36 20/4292 430

**E-mail:** [kuria@takler.com](mailto:kuria@takler.com)
**Website:** [www.taklerkuria.com](http://www.taklerkuria.com) | [www.taklerkuria.hu](http://www.taklerkuria.hu)

**Tax number:** 23435685217
**Company registration number:** 17 09 008737

---

# PURPOSE OF THIS PRIVACY NOTICE

The Service Provider / Data Controller reserves the right to amend this Privacy Notice at any time. Naturally, users will be informed of any changes within an appropriate timeframe.

Should you have any questions regarding this notice, please contact us and our colleague will respond to your inquiry.

The Service Provider / Data Controller is committed to protecting the personal data of its customers and partners and considers it particularly important to respect and safeguard their right to informational self-determination.

The Service Provider / Data Controller processes personal data confidentially and takes all reasonable security, technical and organisational measures, as well as internal operational measures, necessary to ensure the security of such data.

The Service Provider / Data Controller deletes all e-mails received at **[kuria@takler.com](mailto:kuria@takler.com)**, together with any personal data contained therein, one year (12 calendar months) after the date of communication.

---

# PURPOSE OF THIS DOCUMENTATION

The purpose of this documentation is to ensure compliance with:

* the provisions of the Hungarian Act on Informational Self-Determination and Freedom of Information,
* the Regulation adopted by the European Union and the Council on the protection of personal data and the free movement of such data,
* Regulation (EU) 2016/679 (GDPR).

Furthermore, this document describes the technical and practical operational system ensuring compliance with the data protection and data processing requirements applied by the Service Provider / Data Controller, including measures preventing unauthorised access and disclosure, as well as the procedures for maintaining data protection records, with particular regard to their timing and scope.

---

# SCOPE OF THIS DOCUMENTATION

This documentation applies to the data processing activities related to the website operated by the Service Provider / Data Controller.

It also applies to:

* the processing of personal data that is essential and proportionate to the provision of services in current and future customer relationships with the Service Provider / Data Controller;
* all persons and contractual partners who participate in data processing based on an official assignment from the Service Provider / Data Controller and with the consent of the persons using the services, where their rights and legitimate interests are affected.

---

# BASIC LEGAL PROVISIONS

The relevant legal provisions include:

* The Fundamental Law of Hungary (25 April 2011);
* Act V of 2013 on the Civil Code (Civil Code);
* Act XLVI of 1993 on Statistics;
* Act CLV of 1997 on Consumer Protection;
* Act CLV of 2009 on the Protection of Classified Information;
* Act CXII of 2011 on Informational Self-Determination and Freedom of Information (Info Act);
* Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR);
* Directive (EU) 2016/680 of the European Parliament and of the Council.

The data processing activities of the website **taklerkuria.hu**, operated by the Service Provider / Data Controller, are also governed by the Hungarian legislation concerning the protection of personal data and the disclosure of information of public interest.

The text of the European General Data Protection Regulation is available in PDF and HTML formats at the following source link:

[https://www.adatvedelmirendelet.hu/a-rendelet-szovege/](https://www.adatvedelmirendelet.hu/a-rendelet-szovege/)

---

# DEFINITIONS OF INTERPRETATIVE TERMS IN PLAIN LANGUAGE

Source:
[http://naih.hu/mainw/?page_id=85](http://naih.hu/mainw/?page_id=85)

---

# I.) SCOPE OF PROCESSED PERSONAL DATA

## PROCESSING OF DATA PROVIDED BY USERS

The Data Controller reserves the right to involve additional data processors in the future. Visitors to the Website (“Users”) will be informed of such changes through amendments to this Privacy Notice.

Users may provide information and personal data about themselves on the Website through the following separate forms:

* “ACCOMMODATION – REQUEST FOR OFFER”
* “EVENTS – REQUEST FOR OFFER”
* “WINE TASTINGS – REQUEST FOR OFFER”

by completing the relevant contact fields.

Required information:

* Name
* E-mail address
* Telephone number

(* indicates mandatory fields.)

The use of the online messaging interface is subject to the User’s acceptance of this Privacy Notice.

Only persons who have reached the age of **18 years** are entitled to provide personal data on the Website.

We hereby draw the attention of data providers to the fact that if they provide personal data belonging to another person, it is the responsibility of the data provider to obtain and verify the consent of the relevant person (the data subject) in all cases.

When using any online messaging interface available on the Website, Users consent – by ticking the relevant checkbox and submitting the message – that the Data Controller may process their personal data **(only their own personal data may be provided)**, including:

* name;
* e-mail address;
* telephone number.

Providing a residential address is not mandatory.

The processing of personal data is based on the User’s voluntary consent, provided after being informed of this Privacy Notice. This information is directly available and can be reviewed before selecting the consent checkbox.

The Data Controller and the Data Processor(s) engaged by the Data Controller – as detailed below in the section concerning Data Processors – are entitled to access personal data in accordance with applicable legislation.

---

# PURPOSE AND DURATION OF DATA PROCESSING

The Data Controller uses the information provided through the Website for the provision of services available via the Website, in particular for the following purposes:

* maintaining contact and responding to messages initiated and submitted by the User.

The Data Controller processes personal data for as long as the purpose of processing exists, but no later than one year from the date on which the data was provided, unless the User requests the deletion of their data earlier.

---

# LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

By selecting the relevant checkbox when using the online messaging interface, Users consent to the processing of their personal data by the Data Controller.

The processing of personal data is based on the User’s voluntary consent, provided after having been informed of this Privacy Notice.

In certain cases, legislation may require the processing, storage or transfer of certain categories of provided data. The Data Controller shall inform the affected persons separately whenever such legal obligations apply.

Users may only provide their own personal data on the Website.

If a User provides personal data belonging to another person, the User is responsible for obtaining the consent of that person and forwarding the documented proof of such consent to us for supplementary documentation purposes.

---

# SCOPE OF PERSONAL DATA PROCESSED WHEN USING ACCOMMODATION SERVICES

## PERSONAL DATA REQUIRED WHEN COMPLETING THE ACCOMMODATION REGISTRATION FORM ON SITE AND FOR ISSUING INVOICES

Required information:

* Name;
* E-mail address;
* Identity card number;
* Billing information required for issuing an invoice.

(* indicates mandatory fields.)

We hereby draw the attention of data providers that if they provide personal data belonging to another person, it is the responsibility of the data provider to obtain verified consent from the relevant person (the data subject) in every case.

---

# DATA TRANSFER, DATA PROCESSING, AND PERSONS HAVING ACCESS TO DATA

## (WHO MAY ACCESS REGISTERED DATA?)

Personal data may be accessed by:

* the Data Controller;
* authorised employees of the Data Controller;
* Data Processors engaged by the Data Controller,

in accordance with applicable legislation.

The confidentiality clauses included in contracts concluded with our partners always cover all currently applicable requirements and details relating to the protection of personal data.

The following section describes the direct roles involved in transferring, processing or accessing data (internal employees), as well as the activities of contractual partners and companies providing related services.

---

# DATA PROCESSOR – 1

## Data processing activities performed by reception staff, the hotel manager, restaurant manager and sales manager employed by the Service Provider / Data Controller

During the performance of their duties, reception staff are authorised to handle electronic communications and the related data processing activities, provided that they strictly comply with and apply the internal security procedures and requirements specified in their employment contracts.

The data processing activities of reception staff also include recording personal data provided during accommodation check-in procedures by using the designated recording systems and access rights.

The duties of reception staff further include issuing invoices related to the services offered by the Service Provider / Data Controller, including the processing and recording of the data required for invoicing purposes within the invoicing system.

---

# DATA PROCESSOR – 2

## In case of postal invoice delivery

**Hotel management system provider and data storage service related to accommodation services:**
Previo.hu Kft.

**Name of Data Processor:**
Previo.hu Kft.

**Registered office:**
1119 Budapest, Petzvál József utca 4. A building.

**Telephone:**
+36-1-445-3737

**E-mail:**
mailto:info@previo.hu

**Data Processing Policy of the Data Processor:**
[https://www.previo.hu/wp-content/uploads/2026/03/Previo-ASZF.pdf](https://www.previo.hu/wp-content/uploads/2026/03/Previo-ASZF.pdf)

---

# DATA PROCESSOR – 3

## Accounting and bookkeeping-related data processing – Profi-Kontír

**Name of Data Processor:**
Profi-Kontír 2005 Kft.

**Registered office:**
7100 Szekszárd, Táncsics M. u. 3.

**Telephone:**
+36-74-510-318

**E-mail:**
mailto:konyveles@profikontir.hu

The Data Processor participates in the bookkeeping of accounting documents based on the terms of the written agreement concluded with the Data Controller and the confidentiality clause contained therein.

During this activity, the Data Processor processes the name and address of the data subject only to the extent necessary for accounting records, for the period specified under Section 169(2) of the Accounting Act, and subsequently deletes such data without delay.

---

# DATA PROCESSOR – 4

## Mandatory statistical data reporting: Hungarian Central Statistical Office (KSH) – upload in progress

No data suitable for identifying any specific individual is transferred in connection with this reporting obligation.

The mandatory reporting requirement does not extend to requesting such information.

# ACCESS AND SECURITY

## MANAGEMENT OF ELECTRONIC DATA FILES

The Service Provider / Data Controller, as well as employees working under contractual arrangements commissioned by the Data Controller, may access certain data necessary for providing services only with the level of authorisation and access rights determined by the head of the relevant organisational unit.

The specific technical settings and access control provisions required for this purpose – based on the instructions of the organisational unit manager – are recorded in writing.

Following this, access to data is only possible with valid, personal identification credentials and authorisation rights.

Access to network resources is granted only to persons with valid authorisation specified in their contracts, using individual usernames and passwords.

We take all reasonable measures – using the available IT tools and internal procedural systems – to ensure that unauthorised persons cannot access servers available through networks storing personal data.

---

# MANAGEMENT OF MANUAL DATA FILES

Documents and records belonging to archival-level data management are stored in dry, secure, lockable units or rooms.

Access to actively managed document files is granted exclusively to authorised employees based on contractual arrangements.

Documents relating to consumer relationships are stored in locked rooms and secure filing cabinets designated for this purpose.

Payroll and employment-related documents are stored in metal filing cabinets according to the applicable internal procedures.

---

# TECHNICAL DATA

The Service Provider / Data Controller selects and operates the IT equipment used for processing personal data during the provision of services in such a way that the processed data:

* is accessible only to authorised persons;
* is protected against unauthorised access, and all reasonable measures are taken to ensure such protection.

The data provided to us is always protected through appropriate measures against unauthorised access and disclosure.

---

# COOKIES

## Purpose and necessity of cookies

## Strictly necessary session cookies

The purpose of these cookies is to enable visitors to browse the **taklerkuria.hu** website smoothly and without interruption, use its functions, and access the information and services available on the Website.

The validity period of these cookies lasts until the end of the browsing session. When the browser is closed, this type of cookie is automatically deleted from the visitor’s computer or other device used for browsing.

---

## Third-party cookies (analytics)

The **taklerkuria.hu** website also uses cookies provided by Google Analytics as a third party.

By using Google Analytics for statistical purposes, the Website collects information about how visitors use the Website.

This information is used for the purpose of improving the Website and enhancing the user experience.

These cookies remain stored in the visitor’s browser on their computer or other browsing device until their expiry date or until the visitor deletes them.

---

# WEBSITE HOSTING PROVIDER DETAILS

**ICON MÉDIA Kft.**

Registered office:
6000 Kecskemét, Csóka u. 26.

Postal address:
6000 Kecskemét, Pásztor u. 17.

Hosting provider’s Privacy Notice:
[http://web-digital.hu/html/adatkezeles.html](http://web-digital.hu/html/adatkezeles.html)

Hosting provider’s General Terms and Conditions:
[http://web-digital.hu/html/aszf.html](http://web-digital.hu/html/aszf.html)

Cookie policy:
[http://web-digital.hu/html/cookie-sueti-szabalyzat.html](http://web-digital.hu/html/cookie-sueti-szabalyzat.html)

---

# DETAILS OF THE WEBSITE PROGRAMMER

**MEDIAPORTAL Kft.**

7100 Szekszárd, Székely Bertalan utca 8.

E-mail:
[info@szekszardportal.hu](mailto:info@szekszardportal.hu)

The website programmer’s current access is limited exclusively to future development tasks performed under a service agreement and only for the duration of the relevant assignment period.

Content uploading is carried out directly by the PR employee employed by the Service Provider / Data Controller, using their own individual access rights with administrator and/or operator privileges.

---

# USER RIGHTS REGARDING PROCESSED PERSONAL DATA

Upon the User’s request, the Data Controller shall provide information regarding the personal data processed by the Data Controller, including:

* the source of the data;
* the purpose of processing;
* the legal basis of processing;
* the duration of processing;
* the name and address of the Data Processor;
* the activities related to data processing;
* and, in the event of transfer of personal data, the legal basis and recipient of such transfer.

The information may be requested by e-mail at:

**[kuria@takler.com](mailto:kuria@takler.com)**

or by postal mail sent to:

**TAKLER KÚRIA ÉS PANZIÓ**
H-7144 Decs, Decsi Szőlőhegy 1799. hrsz. PL 57.

In both cases, the User must provide a mailing address.

The Data Controller shall respond in writing within no later than **30 (thirty) days** from receipt of the request.

---

The User has the right to request the modification or correction of their provided data by contacting:

**[kuria@takler.com](mailto:kuria@takler.com)**

or by postal mail:

**TAKLER KÚRIA ÉS PANZIÓ**
H-7144 Decs, Decsi Szőlőhegy 1799.

In both cases, the User must provide a mailing address.

The Data Controller shall promptly correct the relevant data in its records and shall inform the affected person in writing once the correction has been completed.

In addition to the above rights, the User may request the deletion or blocking – partially or completely – of their personal data at any time by contacting:

**[kuria@takler.com](mailto:kuria@takler.com)**

or by postal mail:

**TAKLER KÚRIA ÉS PANZIÓ**
H-7144 Decs, Decsi Szőlőhegy 1799.

The deletion or blocking request may be submitted free of charge and without justification, provided that the User specifies a mailing address.

Upon receipt of a deletion request, the Data Controller shall immediately terminate the processing activity and remove the User from its records.

# PRIVACY AND DATA SECURITY STATEMENT

## DATA PROCESSING INFORMATION OF TAKLER KÚRIA Kft.

### Principles and practices regarding data protection and data processing

TAKLER KÚRIA Kft. – hereinafter referred to as the Service Provider/Data Controller – as the operator of the website [taklerkuria.hu](https://www.taklerkuria.hu?utm_source=chatgpt.com) (“Website”), hereby publishes its privacy and data processing principles, which it acknowledges as binding upon itself.

Please read this Privacy Policy (“Policy”) carefully before using the Website.

---

# DETAILS OF THE DATA CONTROLLER

The controller of the data is TAKLER KÚRIA Kft., the operator of the Website (“Data Controller”).

**Registered office:**
H-7144 Decs, Decsi Szőlőhegy 1799. hrsz. PL 57.

**Operator:**
TAKLER KÚRIA Kft.
H-7100 Szekszárd, Bem utca 13.

**Telephone/Fax:**
+36 74 311 961 | Mobile: +36 20/4292 430

**E-mail:**
[kuria@takler.com](mailto:kuria@takler.com)

**Website:**
[www.taklerkuria.com](http://www.taklerkuria.com) | [www.taklerkuria.hu](http://www.taklerkuria.hu)

**Tax number:**
23435685217

**Company registration number:**
17 09 008737

---

# PURPOSE OF THIS PRIVACY POLICY

The Service Provider/Data Controller reserves the right to amend this Policy at any time. Naturally, visitors and users will be informed of any changes in due time.

Should you have any questions regarding this notice, please contact us and our colleague will respond to your inquiry.

The Service Provider/Data Controller is committed to protecting the personal data of its customers and partners and considers it of utmost importance to respect and safeguard the right of individuals to informational self-determination.

The Service Provider/Data Controller treats personal data confidentially and takes all reasonable security, technical and organisational measures, as well as internal operational measures, necessary to ensure the security of such data.

The Service Provider/Data Controller deletes all e-mails received at the address [kuria@takler.com](mailto:kuria@takler.com), including any personal data contained therein, after one year (12 calendar months) from the date of disclosure.

---

# PURPOSE OF THIS DOCUMENTATION

The purpose of this documentation is to ensure compliance with:

* the provisions of the Hungarian Act on Informational Self-Determination and Freedom of Information;
* the Regulation adopted by the European Union and the Council on the protection of personal data and the free movement of such data;
* Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR).

Furthermore, this document describes the technical and practical operational system ensuring compliance with data protection and data processing requirements established by the Service Provider/Data Controller.

Its purpose is to prevent unauthorised access and disclosure, while also describing the procedures for maintaining records related to data protection, with particular regard to their duration and scope.

---

# SCOPE OF THIS DOCUMENTATION

This Policy applies to the data processing activities connected with the website operated by the Service Provider/Data Controller.

It covers:

* the processing of personal data that is necessary for maintaining current and future customer relationships with the Service Provider/Data Controller, to the extent required for providing services;
* all persons and contractual partners who participate in data processing activities based on an official assignment from the Service Provider/Data Controller, with the consent of the persons using the services, where such processing affects their rights and legitimate interests.

---

# RELEVANT LEGAL PROVISIONS

The applicable legal framework includes:

* The Fundamental Law of Hungary (25 April 2011);
* Act V of 2013 on the Civil Code of Hungary (Civil Code);
* Act XLVI of 1993 on Statistics;
* Act CLV of 1997 on Consumer Protection;
* Act CLV of 2009 on the Protection of Classified Information;
* Act CXII of 2011 on Informational Self-Determination and Freedom of Information;
* Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR);
* Directive (EU) 2016/680 of the European Parliament and of the Council.

The processing of personal data carried out through the website taklerkuria.hu operated by the Service Provider/Data Controller is governed by the applicable Hungarian and European data protection legislation.

The text of the European General Data Protection Regulation is available in PDF and HTML format at the following source:
[https://www.adatvedelmirendelet.hu/a-rendelet-szovege/](https://www.adatvedelmirendelet.hu/a-rendelet-szovege/)

---

# DEFINITIONS OF INTERPRETATIVE TERMS IN PLAIN LANGUAGE

Source:
[http://naih.hu/mainw/?page_id=85](http://naih.hu/mainw/?page_id=85)

---

# I.) TYPES OF PERSONAL DATA PROCESSED

## PROCESSING OF DATA PROVIDED BY USERS

The Data Controller reserves the right to involve additional data processors in the future. Users of the Website (“Users”) will be informed of such changes through amendments to this Policy.

Users may provide personal information on the Website through the following separate forms:

* “ACCOMMODATION – REQUEST FOR OFFER”
* “EVENTS – REQUEST FOR OFFER”
* “WINE TASTINGS – REQUEST FOR OFFER”

by completing the relevant contact fields.

Required information:

* Name
* E-mail address
* Telephone number

(*Fields marked with an asterisk are mandatory.)

---

To use the online messaging function, the User must accept this Privacy Policy.

Only persons who have reached the age of 18 are entitled to provide personal data on the Website.

Users are reminded that if they provide personal data belonging to another person, they are responsible for obtaining the documented consent of the relevant person before providing such data.

By ticking the relevant consent box and submitting a message through any online contact form available on the Website, Users consent to the processing of their personal data by the Data Controller.

The Data Controller may process only the User’s own personal data:

* name;
* e-mail address;
* telephone number.

Providing a residential address is optional.

The processing of personal data is based on the User’s voluntary consent given after being informed of this Privacy Policy. This information is available and can be reviewed before submitting the consent declaration.

Personal data may be accessed by the Data Controller and its appointed Data Processors in accordance with applicable legislation.

# PURPOSE AND DURATION OF DATA PROCESSING

The Data Controller uses the data provided through the Website for the purpose of providing the services available through the Website, in particular for the following purposes:

* maintaining contact with the User;
* responding to messages and requests initiated or submitted by the User.

The Data Controller processes personal data for the duration necessary to fulfil the purpose of processing, but no later than one year from the date the data was provided, unless the User requests the deletion of their data earlier.

---

# LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

By ticking the relevant consent box when using the online messaging function, Users consent to the processing of their personal data by the Data Controller.

The processing of personal data is based on the User’s voluntary consent, provided after having received appropriate information regarding the processing activities described in this Policy.

In certain cases, the processing, storage or transfer of certain categories of data may be required by law. The Data Controller will inform the affected persons separately whenever such legal obligations apply.

Users may provide only their own personal data on the Website.

If a User provides personal data belonging to another person, the User is responsible for obtaining the consent of the relevant person and, where necessary, providing documented proof of such consent to the Data Controller for supplementary documentation purposes.

---

# SCOPE OF PERSONAL DATA PROCESSED DURING THE USE OF ACCOMMODATION SERVICES

## DATA PROVIDED ON SITE WHEN COMPLETING THE ACCOMMODATION REGISTRATION FORM AND REQUIRED FOR ISSUING INVOICES

The following data may be collected:

* Name;
* E-mail address;
* Identity card number;
* Billing information required for issuing an invoice.

(*Fields marked with an asterisk are mandatory.*)

Users are reminded that if they provide personal data belonging to another person, they are responsible for obtaining the documented consent of the relevant person in all cases.

---

# DATA TRANSFER, DATA PROCESSING AND PERSONS AUTHORISED TO ACCESS THE DATA

## (WHO MAY ACCESS THE REGISTERED DATA?)

Personal data may be accessed by:

* the Data Controller;
* authorised employees of the Data Controller;
* contracted Data Processors engaged by the Data Controller,

in accordance with applicable legislation.

The confidentiality clauses included in contracts concluded with our partners always cover all currently applicable requirements and obligations relating to the protection of personal data.

The following describes the roles and activities of internal employees and contractual partners who may be involved in data transfer, processing or access.

---

# DATA PROCESSOR – 1

## Activities of reception staff, hotel manager, restaurant manager and sales manager employed by the Service Provider/Data Controller

During the performance of their duties, reception staff are authorised to handle electronic communications and the related processing of personal data, in accordance with the strict requirements of the internal security procedures and the provisions of their employment contracts.

The data processing activities of reception staff also include recording personal data provided during accommodation check-in procedures, using the designated recording systems and access rights established for this purpose.

Reception staff are also responsible for issuing invoices related to the services provided by the Service Provider/Data Controller and for processing and recording the data necessary for invoicing within the invoicing system.

---

# DATA PROCESSOR – 2

## In case of sending postal invoices

**Accommodation service management system provider and data storage provider:**
Flexys Kft.

**Name of Data Processor:**
Previo.hu Kft.

**Registered office:**
1119 Budapest, Petzvál József utca 4. A building

**Telephone:**
+36-1-445-3737

**E-mail:**
[info@previo.hu](mailto:info@previo.hu)

**Data Processing Policy of the Data Processor:**
[https://www.previo.hu/wp-content/uploads/2026/03/Previo-ASZF.pdf](https://www.previo.hu/wp-content/uploads/2026/03/Previo-ASZF.pdf)

---

# DATA PROCESSOR – 3

## Accounting and bookkeeping-related data processing – Profi-Kontír

**Name of Data Processor:**
Profi-Kontír 2005 Kft.

**Registered office:**
7100 Szekszárd, Táncsics M. u. 3.

**Telephone:**
+36-74-510-318

**E-mail:**
[konyveles@profikontir.hu](mailto:konyveles@profikontir.hu)

The Data Processor participates in the bookkeeping of accounting documents based on the written agreement concluded with the Data Controller and the confidentiality clause included therein.

During this activity, the Data Processor processes the name and address of the affected persons only to the extent required for accounting records, for the period specified in Section 169 (2) of the Hungarian Accounting Act, after which the data is deleted without delay.

---

# DATA PROCESSOR – 4

## Mandatory statistical reporting

**Hungarian Central Statistical Office (KSH) – upload pending**

No data enabling the identification of a specific individual is transferred in connection with this obligation.

The mandatory reporting requirement does not include the submission of such personally identifiable information.

---

# ACCESS AND DATA PROTECTION

## MANAGEMENT OF ELECTRONIC DATA FILES

The unit manager determines the level and scope of access rights granted to the Service Provider/Data Controller and its contracted employees, specifying which data necessary for service provision may be accessed and by whom.

The relevant technical settings and access control provisions defined by the unit manager are documented in writing.

Following this process, data may only be accessed using valid, personal identification credentials and authorised access rights.

Access to network resources is granted only to persons with valid contractual authorisation, using individual usernames and passwords.

All reasonable measures are taken, using available IT systems and internal procedures, to prevent unauthorised persons from accessing servers and networks where personal data is stored.

# MANAGEMENT OF MANUAL DATA FILES

Documents and records belonging to the archive-level management category are stored in dry, secure and properly lockable storage areas or rooms.

Access to actively managed document files is restricted exclusively to authorised personnel responsible for handling such documents, based on contractual authorisations.

Documents related to consumer relationships are stored in locked rooms and secured filing cabinets according to the relevant internal procedures.

Payroll and employment-related documents are stored in metal cabinets designated for this purpose, in accordance with internal storage requirements.

---

# TECHNICAL DATA

The Service Provider/Data Controller selects and operates the IT tools used for processing personal data during service provision in such a way that the processed data:

* is accessible only to authorised persons or authorised personnel;
* is protected against unauthorised access, and the Data Controller takes all reasonable measures to ensure such protection.

The data provided to us is always protected through appropriate measures against unauthorised access and disclosure.

---

# COOKIES

## Purpose and function of cookies

### Strictly necessary session cookies

The purpose of these cookies is to enable visitors to browse the taklerkuria.hu website smoothly and without interruption, to use its functions and access the information and services available on the Website.

The validity period of these cookies lasts only until the end of the browsing session. When the browser is closed, this type of cookie is automatically deleted from the visitor’s computer or other device used for browsing.

---

## Cookies placed by third parties (analytics)

The taklerkuria.hu website also uses cookies provided by Google Analytics as a third-party service.

Through the statistical services of Google Analytics, the Website collects information about how visitors use the website.

The collected data is used for the purpose of improving the website, developing its functions and enhancing user experience.

These cookies remain stored in the visitor’s browser on their computer or other browsing device until they expire or until the visitor deletes them.

---

# WEBSITE HOSTING PROVIDER DETAILS

**ICON MÉDIA Kft.**

**Registered office:**
6000 Kecskemét, Csóka u. 26.

**Postal address:**
6000 Kecskemét, Pásztor u. 17.

**Hosting provider – Privacy Policy:**
[http://web-digital.hu/html/adatkezeles.html](http://web-digital.hu/html/adatkezeles.html)

**Hosting provider – General Terms and Conditions:**
[http://web-digital.hu/html/aszf.html](http://web-digital.hu/html/aszf.html)

**Cookie Policy:**
[http://web-digital.hu/html/cookie-sueti-szabalyzat.html](http://web-digital.hu/html/cookie-sueti-szabalyzat.html)

---

# WEBSITE PROGRAMMER DETAILS

**MEDIAPORTAL Kft.**

**Address:**
7100 Szekszárd, Székely Bertalan utca 8.

**E-mail:**
[info@szekszardportal.hu](mailto:info@szekszardportal.hu)

The website developer’s current access is limited exclusively to future development activities performed under a separate service agreement and only for the duration of the relevant assignment period.

Content uploading is carried out directly by the PR employee employed by the Service Provider/Data Controller, using an individual access authorisation with administrator/editor rights.

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# USERS’ RIGHTS REGARDING THEIR PROCESSED DATA

Upon request from the User, the Data Controller provides information regarding:

* the personal data processed by the Data Controller;
* the source of such data;
* the purpose and legal basis of processing;
* the duration of processing;
* the name and address of the Data Processor;
* the activities performed by the Data Processor in relation to data processing;
* in case personal data has been transferred, the legal basis and recipient of such transfer.

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Information may be requested:

**by e-mail:**
[kuria@takler.com](mailto:kuria@takler.com)

or

**by post:**
TAKLER KÚRIA ÉS PANZIÓ
H-7144 Decs, Decsi Szőlőhegy 1799. hrsz. PL 57.

In both cases, the User must provide a mailing address.

The Data Controller shall respond in writing within no later than 30 (thirty) days from receipt of the request.

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The User has the right to request the modification or correction of their provided data:

by e-mail:
[kuria@takler.com](mailto:kuria@takler.com)

or by post:

TAKLER KÚRIA ÉS PANZIÓ
H-7144 Decs, Decsi Szőlőhegy 1799. hrsz. PL 57.

In both cases, the User must provide a mailing address.

The Data Controller shall correct the relevant data in its records without delay and shall inform the affected person in writing once the correction has been completed.

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In addition to the above rights, the User may request the deletion or restriction (blocking) of their data, either partially or completely:

by e-mail:
[kuria@takler.com](mailto:kuria@takler.com)

or by post:

TAKLER KÚRIA ÉS PANZIÓ
H-7144 Decs, Decsi Szőlőhegy 1799.

The request may be submitted free of charge and without providing justification, provided that the User supplies a mailing address.

After receiving a deletion request, the Data Controller shall immediately terminate the processing activity and remove the User’s data from its records.

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Instead of deletion, the Data Controller shall restrict the processing of personal data if requested by the User or if, based on the available information, it can be assumed that deletion would adversely affect the legitimate interests of the User.

Restricted personal data may only be processed for as long as the purpose of processing remains valid and prevents deletion.

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If the Data Controller does not comply with the User’s request for correction, restriction or deletion, it shall provide written notification within 30 days of receiving the request, explaining the factual and legal reasons for rejecting the request.

If a request for correction, restriction or deletion is rejected, the Data Controller shall inform the User about the possibility of seeking judicial remedy and contacting the Hungarian National Authority for Data Protection and Freedom of Information.

# RIGHT TO OBJECT TO THE PROCESSING OF PERSONAL DATA

The User has the right to object to the processing of their personal data if:

* the processing or transfer of personal data is necessary exclusively for the fulfilment of a legal obligation applicable to the Data Controller, or for the enforcement of the legitimate interests of the Data Controller, the recipient of the data or a third party, unless the processing is mandatory by law;

* the personal data is used or transferred for the purposes of direct marketing, public opinion research or scientific research;

* or in other cases specified by law.

The Data Controller shall examine the objection within the shortest possible period after submission of the request, but no later than 15 days, decide whether the objection is justified, and inform the applicant in writing of its decision.

If the User does not agree with the decision of the Service Provider/Data Controller, or if the Data Controller fails to meet the above deadline, the User may seek judicial remedy within 30 days from the notification of the decision or from the final day of the applicable deadline.

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# II.) INFORMATION COLLECTED IN CONNECTION WITH THE USE OF THE WEBSITE

## DATA PROCESSED IN CONNECTION WITH WEBSITE USE

If the User does not explicitly provide any personal information or data on the Website, the Data Controller does not collect or process any personal data relating to the User in a way that would allow the User to be personally identified.

By visiting the Website, all Users consent to the use of cookies operated by external service providers for the purpose of recording the data and information described in this Section II of the Privacy Policy.

Such data includes information relating to the User’s computer used for accessing the Website, which is generated during website usage and recorded by cookies applied on the Website as an automatic result of technical processes.

Automatically recorded data is logged by the system when visiting or leaving the Website without requiring any separate declaration or action from the User.

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Such data is not combined with other personal information provided by the User; therefore, the User cannot be identified personally on the basis of this information.

Access to such data is available only to the external service providers managing the cookies and to the Data Controller.

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The Data Controller uses only cookies operated by external service providers (such as Google), in addition to cookies necessary for the basic technical operation of the Website.

Cookies are small text files sent by the Website to the hard drive of the User’s computer. They contain non-personal information relating to the User.

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# GOOGLE ANALYTICS

The Data Controller uses the services of Google Analytics in connection with the Website.

Cookies managed by Google Analytics assist in measuring visitor numbers and other web analytics information related to the Website.

Information collected through cookies is transferred to and stored on external servers operated by Google.

Google uses this information on behalf of the Data Controller primarily to monitor website traffic and prepare statistical analyses regarding activities performed on the Website in a manner that does not identify individual users.

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Google may transfer this information to third parties where required to do so by law.

Google may also transfer such data to third parties engaged by Google for data processing purposes.

Further information regarding the processing of data by Google Analytics is available from Google Analytics:

[http://www.google.com/analytics](http://www.google.com/analytics)

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# USE OF ADVERTISING AND MARKETING SERVICES

The Service Provider/Data Controller does not use paid advertising systems operated by external service providers (such as Google Ads, Facebook Pixel or similar services).

Users will therefore not receive advertisements based on remarketing activities when visiting other websites.

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Based on the content displayed on the taklerkuria.hu website, the Service Provider/Data Controller maintains its own Facebook profile.

The Service Provider/Data Controller declares that it does not use paid advertisements or marketing-related promotional activities on any social media platform.

Its social media feeds contain only organic content without advertising settings or paid promotion, including its own news information published on the Website and direct links leading to related Website content.

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The Service Provider/Data Controller reserves the right to change its current position regarding the use of paid advertisements in the future.

In such cases, Users will be informed by means of an amendment to this Privacy Policy.

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# DISABLING GOOGLE COOKIES

Google’s use of cookies may be disabled at any time through Google Advertising Settings.

Further information is available at:

[http://www.google.hu/policies/privacy/ads/](http://www.google.hu/policies/privacy/ads/)

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Users may also disable cookies from external service providers through the opt-out page of the Network Advertising Initiative:

[http://www.networkadvertising.org/choices/](http://www.networkadvertising.org/choices/)

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The data processing practices of the external service providers mentioned above are governed by the privacy policies established by those providers.

The Data Controller cannot assume responsibility for such external data processing activities.

# 2.) USE OF THIS INFORMATION

The data collected through the technologies described above cannot be used to identify the User, and the Service Provider/Data Controller does not combine such information with any other data that could potentially be used for personal identification.

The primary purpose of using such data is to enable the Data Controller to operate the Website properly, including in particular:

* monitoring website visitor activity;
* identifying and preventing possible misuse of the Website;
* blocking unauthorised activities.

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In addition to the above, the Service Provider/Data Controller may use this information to:

* analyse usage trends;
* improve and develop the functions of the Website;
* obtain comprehensive traffic statistics regarding the overall use of the Website;
* assess interest in website content and expand available information and services according to users’ needs.

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The Data Controller may use the information obtained in this way to create and analyse statistics related to Website usage.

The Data Controller may also transfer such non-identifiable statistical information (for example:

* number of visitors;
* most viewed topics;
* most popular content)

to third parties or publish such information in an aggregated form, always anonymously.

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# 3.) POSSIBILITY OF DISABLING COOKIES

If the User does not wish to allow the collection of the anonymous information described above during visits to the Website or in connection with Website usage, cookies may be partially or completely disabled in the settings of the internet browser.

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# 4.) COOKIES PLACED BY THIRD PARTIES

The Website currently does not contain information, particularly advertisements, originating from third-party advertisers or advertising service providers that are not affiliated with [www.taklerkuria.hu](http://www.taklerkuria.hu).

Accordingly, such third parties cannot place cookies or web beacons on the User’s computer, nor can they use similar technologies to collect information for the purpose of sending targeted advertising messages related to their own services.

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# III.) LINKS

The Service Provider/Data Controller shall not be responsible for the content, data protection practices or information security practices of external websites accessible through links provided on the Website.

Such links may be provided for the purpose of supplying additional information, expanding available content or as references.

If the Service Provider/Data Controller becomes aware that a linked website or link violates the rights of third parties or applicable legislation, the link will be removed from the Website without delay.

We welcome and appreciate any notifications regarding situations arising in this manner.

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# IV.) DATA SECURITY

The Data Controller undertakes to ensure the security of processed data and to implement all reasonable technical, organisational and procedural measures necessary to ensure that collected, stored and processed data remains protected.

The Data Controller also establishes procedures to prevent:

* destruction of data;
* unauthorised use of data;
* unauthorised modification of data.

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The Service Provider/Data Controller also undertakes to ensure that any third party to whom data is transferred or provided based on the consent of Users is informed of the applicable data security requirements.

Such obligations are incorporated into the relevant contractual agreements to ensure that these third parties fully comply with their data protection responsibilities.

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The Service Provider/Data Controller ensures that processed data cannot be accessed, disclosed, transferred, modified or deleted by unauthorised persons.

Processed data may only be accessed by:

* the Service Provider/Data Controller;
* authorised employees of the Data Controller;
* employees of Data Processors acting on behalf of the Data Controller who are authorised to access such information.

The Service Provider/Data Controller does not transfer personal data to third parties who are not authorised to access such data.

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The Service Provider/Data Controller takes all reasonable measures to prevent accidental damage or destruction of data.

These obligations are also imposed on employees participating in data processing activities and on Data Processors acting on behalf of the Data Controller, and are recorded in contractual agreements.

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The User acknowledges and accepts that, although the Data Controller applies modern security measures and takes all reasonable steps to prevent unauthorised access to or disclosure of personal data, complete protection of information transmitted through the Internet cannot be guaranteed.

In the event of unauthorised access or disclosure occurring despite the efforts of the Data Controller, the Service Provider/Data Controller shall not be liable for:

* the unauthorised acquisition of such data;
* unauthorised access to such data;
* any damage suffered by the User as a result of such incidents.

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The Service Provider/Data Controller declares that it does not collect special categories of personal data under any circumstances.

This includes data relating to:

* racial origin;
* membership of national or ethnic minorities;
* political opinions or political party affiliation;
* religious or philosophical beliefs;
* trade union membership;
* health status;
* addictions;
* sexual life;
* criminal records.

# V.) LEGAL REMEDIES AND ENFORCEMENT OPTIONS

The Data Controller makes every effort to ensure that the processing of personal data is carried out in accordance with applicable legislation.

If you believe that we have not complied with these requirements, please contact us:

**E-mail:**
[kuria@takler.hu](mailto:kuria@takler.hu)

or by post:

**TAKLER KÚRIA ÉS PANZIÓ**
H-7144 Decs, Decsi Szőlőhegy 1799. hrsz. PL 57.

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If you believe that your rights relating to the protection of personal data have been violated, you may seek legal remedies before the competent authorities in accordance with applicable legislation.

You may contact:

**Hungarian National Authority for Data Protection and Freedom of Information (NAIH)**

Address:
1125 Budapest, Szilágyi Erzsébet fasor 22/C.

You may also initiate legal proceedings before the competent court.

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Regarding electronic advertising communications, the competent authority is the **National Media and Infocommunications Authority (NMHH)**.

The detailed rules are contained in:

* Act CXII of 2011 on Informational Self-Determination and Freedom of Information;
* Act CVIII of 2001 on Electronic Commerce Services and Certain Issues Relating to Information Society Services.

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# VI.) OTHER PROVISIONS

This Privacy Policy is governed by Hungarian law, in particular by the provisions of Act CXII of 2011 on Informational Self-Determination and Freedom of Information.

The Service Provider/Data Controller reserves the right to amend this Privacy Statement unilaterally at any time, subject to prior notification of affected persons.

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**Date:**
18 May 2018