Published on 15th October 2023
1.1. We are committed to safeguarding the privacy of treasuresofhungary.com’s visitors and service users.
1.2. This policy applies where we are acting as a data controller with respect to the personal data of treasuresofhungary.com’s visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.4. In this policy, “we”, “us” and “our” refer to Eszter Tokai, the operator of this website. “You” or “your” means you as a participant in or as a user of the treasuresofhungary.com website. Our site means treasuresofhungary.com.
2.1. This document was created using a template from SEQ Legal.
3. Our details
3.1. This website is owned by
4. How we use your personal data
4.1. In this Section 4 we have set out:
a) the general categories of personal data that we may process;
b) the purposes for which we may process personal data; and
c) the legal bases of the processing.
4.2. We may process data about your use of our website (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services.
4.3. We may process information collected as part of the subscribing process you submit to us (“subscription data“). The subscription data may include your name, address and email address. The primary source of the subscription data is you.
4.4. We may process your user account data (“account data”). The account data may include your account identifier, name, addrss, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you, although some elements of the account data may be generated by our website.
4.5. We may process data enabling us to get in touch with you (“contact data“). The contact data may include your name, your contact details, information contained in communications between you and us and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website’s contact form. The source of the contact data is you. The contact data may be processed for the purposes of managing our relationships with customers, communicating with customers and keeping records of those communications.
4.6. We may process data collected when you comment on articles (“comment data“). The comment data may include your name and email address, information contained in communications between you and us and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website’s comment form. The source of the comment data is you. The comment data may be processed for the purposes of managing our relationships with customers, communicating with customers and keeping records of those communications. If you choose to leave a comment on treasuresofhungary.com, you should be aware that any personal information (including screen name or ID) you submit becomes public and can be read, collected and used by other users of the website. We are not responsible for the personal information you choose to submit.
4.7. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may include your name and your e-mail address, and may be processed for the purposes of sending you the relevant notifications and/or newsletters.
4.8. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.9. In addition to the specific purposes for which we may process your personal data set out in this Section 4, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
4.10. Please do not supply any other person’s personal data to us, unless we prompt you to do so.
5. Purposes of processing and legal bases
5.1. In this Section 5, we have set out the purposes for which we may process personal data and the legal bases of the processing.
5.2. Operations – We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
5.3. Relationships and communications – We may process contact and account data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.
5.4. Direct marketing (newsletter) – We may process notification data for the purposes of creating, targeting and sending direct marketing communications by email. The legal basis for this processing is your consent.
5.5. Research and analysis – We may process usage data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
5.6. Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
5.7. Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
5.8. Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
5.9. Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
6. Data storage and disclosure
6.1. Your personal data held in our website database will be stored on the servers of our web hosting provider.
Web hosting provider:
Name: Websupport Magyarország Kft.
Address: 1132 Budapest, Victor Hugo u. 18-22., Hungary
Tax ID No.: 25138205-2-41
Registry No.: 01-09-381419
6.4. In addition to the specific disclosures of personal data set out in this Section 6, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
6.5. We do not sell, rent or otherwise disclose your personal information to any third parties.
7. Retaining and deleting personal data
7.1. This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3. We will retain your personal data as follows:
a) contact data will be retained for a minimum period of 7 days following the date of the most recent contact between you and us, and for a maximum period of 30 days following that date.
b) account data will be retained for a period of 30 days following the date when your subscription expires.
c) subscription data will be retained for a period of 30 days following the date when your subscription expires.
d) notification data will be retained for a maximum period of 14 days following the date of cancelling your subscription from our newsletter.
e) usage data will be retained for 2 years following the date of collection.
f) comment data will be retained until deletion.
7.4. Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8. Your rights
8.1. In this Section 8, we have listed the rights that you have under data protection law.
8.2. Your principal rights under data protection law are:
a) the right to access – you can ask for copies of your personal data;
b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
c) the right to erasure – you can ask us to erase your personal data;
d) the right to restrict processing – you can ask us to restrict the processing of your personal data;
e) the right to object to processing – you can object to the processing of your personal data;
f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
8.3. You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
9.1. The following paragraphs explain what cookies are and how we use them, the types of cookies we use i.e, the information we collect using cookies and how that information is used, and how to control the cookie preferences.
9.2. You can at any time change or withdraw your consent from the Cookie Declaration on our website.
9.3. Your consent applies to the following domains: treasuresofhungary.com
9.4. Manage your consent
10. About cookies
10.1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
10.2. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
10.3. Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
11. Cookies that we use
11.1. As most of the online services, our website uses first-party and third-party cookies for several purposes. First-party cookies are mostly necessary for the website to function the right way, and they do not collect any of your personally identifiable data.
11.2. The third-party cookies used on our website are mainly for understanding how the website performs, how you interact with our website, keeping our services secure, and all in all providing you with a better and improved user experience and help speed up your future interactions with our website.
11.5. Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as You close your web browser.
11.6. We use both session and persistent cookies for the purposes set out below:
Essential: Some cookies are essential for you to be able to experience the full functionality of our site. They allow us to maintain user sessions and prevent any security threats. They do not collect or store any personal information. For example, these cookies allow you to log-in to your account and add products to your basket, and checkout securely.
Statistics: These cookies store information like the number of visitors to the website, the number of unique visitors, which pages of the website have been visited, the source of the visit, etc. These data help us understand and analyze how well the website performs and where it needs improvement.
Functional: These are the cookies that help certain non-essential functionalities on our website. These functionalities include embedding content like videos or sharing content of the website on social media platforms.
Preferences: These cookies help us store your settings and browsing preferences like language preferences so that you have a better and efficient experience on future visits to the website.
The below list details the cookies used in our website.
12. Information on the newsletter and consent
We are providing you with the following information to explain the content of our newsletter as well as the registration, dispatch and statistical evaluation processes and your right of objection. By our newsletter, you agree with the described processes and to the receipt of emails of Treasures of Hungary.
12.1. Content of our emails (newsletter)
We only send emails and other electronic notifications with advertising material (referred to hereinafter as the “newsletter”) with the consent of the recipients or legal permission. If specific content of the newsletter is altered during the registration process, this content is essential for the consent of the users. Our emails contain information about new posts published on Treasures of Hungary.
12.2. Double opt-in and recording process
Registration for our newsletter is completed as part of a double opt-in process. This means you will receive an email after registering in which you will be asked to confirm your registration. This confirmation is required so that nobody can register with email addresses that do not belong to them.
The newsletter registrations are recorded in order to be able to verify the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation and the IP address. The changes to your data that is held by MailerLite are also recorded.
12.3. Use of the email service provider “MailerLite”
The newsletter is dispatched by “MailerLite”, a newsletter distribution platform of MailerLite Limited, an Irish registered company at Ground Floor, 71 Lower Baggot Street, Dublin 2, D02 P593, Ireland.
The email addresses of our newsletter recipients and their further details described in this information are stored on the MailerLite servers in Ireland. MailerLite uses this information to send and evaluate the newsletters on our behalf. MailerLite can by its own admission also use this data to enhance or improve its own services, e.g. to technically enhance the dispatch procedure and display of the newsletter or for commercial purposes to be able to determine which countries the recipients are from. However, MailerLite will not use the data of our newsletter recipients to contact them itself or forward it to third parties.
12.4. Login details
You only need to provide your email address to register for the newsletter.
12.5. Statistical survey and analyses
Our emails contain a “web beacon”, i.e. a pixel-size file that is retrieved from the MailerLite server when opening emails. This initially involves technical information being retrieved such as information on the browser and your system as well as your IP address and the time of retrieval. This information is used to make technical improvements to services based on technical data or the target groups and their reading behaviour based on their retrieval locations (that can be determined with the IP address) or access times.
The statistical surveys also involve determining whether the newsletters are opened, when they are opened and which links are clicked on. This information may be assigned to individual newsletter recipients for technical reasons but it is neither our intention nor that of MailerLite to monitor individual users. The evaluations instead help us to recognise the reading habits of our users and to adapt our content to them or to send different content based on our users’ interests.
12.6. Online access and data management
There are instances where we lead newsletter recipients to the MailerLite web pages, e.g. our newsletters contain a link which newsletter recipients can use to access the newsletters online (e.g. if there are issues with displaying the newsletter in the email programme). Newsletter recipients may also correct data such as their email address retrospectively. The privacy statement of MailerLite can also only be accessed on its site.
Please, be aware that cookies are used on the MailerLite web pages for this purpose and personal data is therefore processed by MailerLite, its partners and the service providers it uses (e.g. Google Analytics). We have no influence on this data collection. You can find more information in the privacy statement of MailerLite. We would also like to refer you to the possibilities of opting out of data collection for promotional purposes on the websites http://www.aboutads.info/choices/ and http://www.youronlinechoices.com/ (for the European region).
You may opt-out of receiving our newsletter at any time, i.e. withdraw your consent. This means you also no longer consent to the distribution of this newsletter via MailerLite and the statistical analyses. It is not possible to cancel the distribution via MailerLite or the statistical evaluation separately.
You can find a link to unsubscribe to the newsletter at the end of each email. After opting-out we don’t use your personal datas for promotional purposes anymore, you will no longer get newsletter.
12.8. General Data Protection Regulation legal bases
According to the guidelines of the General Data Protection Regulation (GDPR) valid from 25 May 2018, we hereby inform you that you have consented to your email addresses being sent based on Art. 6 Para. 1 lit. a, 7 of the General Data Protection Regulation (GDPR) and § 7 Para. 2(3) or Para. 3 of the Unfair Competition Act (UC). The email service provider MailerLite is used, the statistical surveys and analyses are performed and the registration procedure is recorded based on our legitimate interests pursuant to Art. 6 Para. 1 lit. f of the General Data Protection Regulation (GDPR). Our interests focus on the use of a user-friendly and secure newsletter system that serves our business interests and meets user expectations.
We also wish to point out that you can object to the future processing of your personal data at all times in accordance with the legal regulations. Specifically, the objection can be made against processing for direct marketing purposes.
13. Managing cookies
13.1. Should you decide to change your preferences later through your browsing session, you can click on the “Manage your consent” link given above in section 9.4. This will display the consent notice again enabling you to change your preferences or withdraw your consent entirely.
13.2. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
13.3. Blocking all cookies will have a negative impact upon the usability of many websites.
13.4. If you block cookies, you will not be able to use all the features on our website.
14.1. We may update this policy from time to time by publishing a new version on our website.
14.2. You should check this page occasionally to ensure you are happy with any changes to this policy.
15.1. In case of a possible infringement you can file a complaint against the data controller with the National Authority for Data Protection and Freedom of Information.
National Authority for Data Protection and Freedom of Information
Address: 1125 Budapest, Szilágyi Erzsébet fasor 22/C., Hungary
Mailing address: 1530 Budapest, Postafiók: 5., Hungary
Telephone: +36 -1-391-1400