shub.hu
+36 20 964 8143
Magyar

Privacy notice

This document is not final yet. The fields marked [TBD] will be filled with the real details of the business. Before launch the final text must also be reviewed by a legal professional — the structure below covers the statutory mandatory elements, but it does not replace legal review.

This notice is provided under Article 13 of the General Data Protection Regulation ((EU) 2016/679, GDPR) and Hungarian Act CXII of 2011 on the Right of Informational Self-Determination and Freedom of Information (Infotv.). The mandatory operator disclosures are in a separate document: legal notice.

1. The controller

Controller
[TBD: company name / name of the sole trader]
Registered office
[TBD: registered office]
Email
info@shub.hu
Data protection officer
Not appointed — none of the cases requiring one under Article 37 GDPR applies.

2. What data we process, for what purpose, and on what legal basis

2.1 Contact and consultation request form

Data processed
Name, email address, and — if you provide it — phone number, plus the subject of your enquiry and the text of your message.
Purpose
Answering your enquiry, arranging a consultation, preparing the service.
Legal basis
Article 6(1)(b) GDPR — steps taken at your request prior to entering into a contract.
Provision
Voluntary. Without a name, an email address and a message we cannot reply; the other fields are optional.
Retention
[TBD: retention period — e.g. "1 year from the enquiry; where a contract is concluded, the statutory record retention period"]

2.2 Server logs

Data processed
For technical reasons the hosting provider's web server logs requests: IP address, timestamp, the path requested, and the identifier sent by the browser.
Purpose
Operating the service, troubleshooting, and protection against abuse and denial-of-service attacks.
Legal basis
Article 6(1)(f) GDPR — legitimate interest, namely the secure and reliable operation of the website.
Retention
[TBD: the hosting provider's log retention period]

2.3 Protecting the form against abuse

To filter out automated submissions (spam) the form uses a hidden trap field and a timestamp, and limits the number of submissions per IP address for a short period. This requires storing the sender's IP address temporarily. Legal basis: Article 6(1)(f) GDPR, the legitimate interest of operating the service free of abuse.

3. Cookies and tracking

This site uses no analytics or marketing cookies, runs no tracking code, loads no third-party embedded content, and uses neither Google Analytics nor any other web statistics service. There is therefore no consent banner.

One technical setting is stored in your browser's local storage: the dark or light theme you chose. That value stays on your device, never reaches us, and cannot be used to identify you.

Fonts are served from our own server rather than from an external font provider, so viewing the site does not disclose your IP address to a third party for that reason.

The WhatsApp and Viber buttons on this site are outgoing links, not embeds: no content, script or tracking pixel from those providers loads when the page is opened, so simply viewing the site sends them no data. If you click one, you leave this site and the conversation continues in your own app, under that provider's own data processing (Meta for WhatsApp, Rakuten for Viber) — which this notice does not cover. The same applies to the click-to-call link.

4. Who has access to the data

We do not sell your data and do not pass it to third parties for marketing purposes. We use the following processors to operate the service:

Hosting provider
[TBD: name and registered office of the hosting provider, and the place of storage]
Email service
[TBD: the email provider delivering the form notifications, if different from the hosting provider]

5. Transfers outside the European Economic Area

[TBD: if every processor stores data within the EEA, state that there is no transfer to a third country; if there is, name the Article 46 GDPR safeguard]

6. Your rights

Under the GDPR you may request:

  • Access — confirmation of whether we process data about you and, if so, what (Article 15).
  • Rectification — correction of inaccurate data and completion of incomplete data (Article 16).
  • Erasure — deletion of your data where there is no longer a legal basis for processing (Article 17).
  • Restriction — restriction of processing in the cases set out in law (Article 18).
  • Objection — objection to processing based on legitimate interest (Article 21).
  • Portability — release of the data you provided in a structured, machine-readable format (Article 20).

You can send these requests to the email address above. Under Article 12 GDPR we respond within one month at the latest.

7. Automated decision-making

We use no automated decision-making within the meaning of Article 22 GDPR, and we do no profiling.

8. Remedies

If you believe the processing is unlawful, you may lodge a complaint with the supervisory authority:

Authority
Hungarian National Authority for Data Protection and Freedom of Information (NAIH)
Address
Falk Miksa utca 9–11, 1055 Budapest, Hungary
Postal address
1363 Budapest, Pf. 9, Hungary
Website
naih.hu

Independently of any authority proceedings you may also go to court. Proceedings may — at your choice — be brought before the court competent for your place of residence.

9. Changes to this notice

We update this notice when the scope or manner of processing changes. The version in force is always available on this page.