Privacy Notice

The controller is IT-Wan Kft. (brand: IT-Wan Agency). Registered office: [székhely / registered office]; registration no.: [cégjegyzékszám / registration no.]; tax no.: [adószám / tax no.]. For privacy matters contact [e-mail] (contact person: [adatvédelmi kapcsolattartó / privacy contact]).

We are the controller for the processing described below. Where we process the data of our clients’ own customers on their behalf (e.g. in a CRM, booking or AI Voice system), we generally act as a processor, and that client’s privacy notice applies.

Diagnostic quiz. We process the answers you give in the quiz (e.g. about your business, your current website and client acquisition situation, and your goals) and your contact data (name, e-mail address, phone number) so that we can assess your needs and give you a tailored recommendation and, later, a quote. Legal basis: taking steps at your request before entering into a contract (GDPR Art. 6(1)(b)); for follow-up contact beyond the quote, your voluntary enquiry and our legitimate interest (Art. 6(1)(f)).

Enquiries, quote requests and client communication. We process the data in your enquiry and our correspondence (name, contact details, message content) to answer you, prepare a quote and stay in touch. Legal basis: pre-contractual steps (Art. 6(1)(b)) and our legitimate interest in answering business enquiries (Art. 6(1)(f)).

Contract formation and performance. If you order our services, we process the data needed to conclude and perform the contract (name, company name, billing address, tax number, contact details, access needed for delivery). Legal basis: performance of a contract (Art. 6(1)(b)).

Invoicing and accounting obligations. We process billing data as required by accounting and tax law. Legal basis: legal obligation (Art. 6(1)(c)), in particular the Hungarian Accounting Act (Act C of 2000) and VAT Act (Act CXXVII of 2007).

Newsletters and direct marketing. We send marketing e-mails or SMS only if you have given your explicit prior consent. Legal basis: consent (Art. 6(1)(a)), which you can withdraw at any time without giving a reason.

Website use, cookies, language setting. We process technical data needed for the site to work and to remember your choices (e.g. language, cookie decision), and — with your consent — measurement data, as described in the Cookie Notice. Legal basis: legitimate interest for strictly necessary cookies (Art. 6(1)(f)); consent for measurement and other non-essential cookies (Art. 6(1)(a)).

AI Voice assistant. If you speak to the AI Voice assistant by phone, the AI Voice Terms govern the handling of call data (call recording and transcript are based on consent).

Legal claims. We process the necessary data when handling complaints and disputes and when establishing, exercising or defending legal claims. Legal basis: legitimate interest (Art. 6(1)(f)) and, for complaint handling, a legal obligation (Art. 6(1)(c)).

Providing data is voluntary, but without the data needed for a quote or contract (name, contact details) we cannot handle your enquiry or provide the service.

• Quiz answers and quote requests that did not lead to a contract: up to 12 months from the end of the quote process or last contact, or until you ask for deletion.
• Contract-related data: 5 years from the end of the contract (the general limitation period under the Hungarian Civil Code).
• Accounting documents and invoices: at least 8 years under accounting law.
• Processing based on consent (e.g. newsletter): until you withdraw consent.
• Complaints and the records made of them: for the period required by law.
• Language setting and cookie decision: up to 12 months (details in the Cookie Notice).

When the retention period ends we delete or anonymise the data, unless the law requires further retention or it is needed for a legal claim.

Personal data may be accessed by IT-Wan Kft. staff as needed for their tasks. We use trusted processors to provide our services and have agreements with them in line with data protection rules. The main categories of processors are:

• the platform and hosting provider that runs and hosts the website: [tárhelyszolgáltató / hosting provider];
• providers of CRM, booking, e-mail and SMS systems;
• telephony providers and providers involved in delivering the AI Voice service (speech recognition, artificial intelligence, call transcripts);
• accountants and invoicing and bookkeeping providers;
• legal, tax and other professional advisers.

On request we provide the exact list of processors at [e-mail]. Beyond that, we pass personal data to third parties only where required by law or at the request of an authority or court.

If a processor transfers data outside the European Economic Area (e.g. to the United States), we allow this only with safeguards that meet Chapter V of the GDPR, such as an adequacy decision or standard contractual clauses (SCCs).

We do not carry out solely automated decision-making that has legal effects on you or similarly significantly affects you. The diagnostic quiz result is informational and is not a decision.

We apply appropriate technical and organisational measures to protect personal data (e.g. encrypted connections, access restrictions, permission management). In a personal data breach we act as the law requires and, where necessary, notify the NAIH and the individuals affected.

Our services are aimed at businesses, so we do not knowingly collect data from persons under 16.

Under the GDPR you have the following rights:

• right of access: to know whether we process your personal data and to receive a copy;
• right to rectification: to have inaccurate data corrected and incomplete data completed;
• right to erasure (“right to be forgotten”): to have your data deleted where the legal conditions are met;
• right to restriction of processing: in the cases set out in law;
• right to data portability: to receive data you provided that we process by automated means on the basis of consent or contract, in a structured, machine-readable format;
• right to object: to processing based on legitimate interest, on grounds relating to your situation, and at any time and without reason to direct marketing;
• right to withdraw consent: withdrawal does not affect the lawfulness of processing before withdrawal.

We answer your request without undue delay and within one month of receiving it; for particularly complex or numerous requests this can be extended by two further months, and we will tell you the reason for the delay. You can submit a request at [e-mail] or by post ([székhely / registered office]). We may ask for further information to identify you. Information and action are free of charge unless the request is manifestly unfounded or excessive.

If you believe our processing of your personal data breaches the law, please contact us first so we can resolve the problem together. You also have the right to lodge a complaint with the supervisory authority and to go to court:

• Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH) — address: 1055 Budapest, Falk Miksa utca 9–11.; postal address: 1363 Budapest, Pf. 9.; e-mail: ugyfelszolgalat@naih.hu; phone: +36 1 391 1400; web: https://www.naih.hu;
• court action: for a breach relating to the processing of your data you may, at your choice, bring proceedings before the regional court (törvényszék) competent for your place of residence or stay (Infotv. Section 23; GDPR Art. 79).

For privacy questions and requests, contact us at [e-mail].

We may update this notice if our services, our processing or the law change. The current version is always available on this page, and the date of the latest update is shown at the top. Where we have your contact details, we will also notify you separately of material changes.