Privacy Policy

1. The purpose of the Data Handling Notice

Avico 13 Alfa Kft. (1118 Budapest, Rétköz utca 5 1st em., Hereafter as Service Provider) as a data controller agrees to the content of this legal notice. Commits you to ensure that all data management related to your business complies with the requirements of this Code and the applicable national legislation and the legal acts of the European Union.
Data Protection Guidelines for Data Provider Data Services are permanently available at
The Service Provider reserves the right to change this information at any time. Of course, you will notify your audience in due time of any changes.
If you have any questions about this announcement, please write to us and our colleague will answer your question.
In order to protect the personal information of our dedicated customers and partners, the Service Provider considers it important to respect the client's right to information self-determination. The Service Provider shall treat the personal data in a confidential manner and shall take all security, technical and organizational measures that guarantee the security of the data.
The Service Provider describes its data management practices below.

2. Data Manager Data

If you are looking for our company, you can contact the data administrator at (hereinafter referred to as the "Website") and at +36 1 231 0500,
The Service Provider deletes all e-mails it has received with the Website, including personal data, after a maximum of 1 year from the date of disclosure.
Name: Avico 13 Alfa Kft.
Address: 1118 Budapest, Rétköz utca 5. 1. em.,
Company registration number: 01-09-320461
VAT number: 26256115-2-43
Phone: +36 1 231 0500

3. The scope of the personal data handled

3.1. Technical details

The Service Provider selects and manages the IT tools used to handle personal data in the provision of the service so that the data treated:

  • (available) to those entitled to it;
  • credibility and authentication (credibility of data management);
  • its integrity can be verified (data integrity);
  • unauthorized access (confidentiality of data).

The Service Provider protects the data with appropriate measures against unauthorized access, alteration, transmission, disclosure, deletion or destruction and against accidental destruction.
The Service Provider provides technical, organizational and organizational measures to safeguard the security of data management, providing a level of protection that meets the risks associated with data management.
The Service Provider retains the data handling

  • the secrecy: it protects the information so that it can only access the person who is entitled to it;
  • integrity: it protects the accuracy and completeness of the information and processing method;
  • Availability: Ensure that when the eligible user needs it, you really have access to the information you need and have the tools available to you.

3.2. Cookies

3.2.1. The task of cookies

  • collecting information about visitors and their assets;
  • note the custom settings for visitors that may be used (e.g. when using online transactions, so you do not have to type them again;
  • facilitate the use of the website;
  • quality user experience.

For a tailor-made service, the user's computer has a small data packet, place a cookie and read it later. If your browser returns a previously saved cookie, the cookie operator can link the user's current visit with the past, but only for their own content.

3.2.2. Essentially, session cookies are required

These cookies are designed to allow visitors to browse the Website in full and smooth, use its features and the services available there. The duration of this type of cookie expires until the session (browsing) ends, and by closing the browser, this type of cookies is automatically deleted from the computer or other device used for browsing.

3.2.3. Third party cookies (analytics)

The Website applies Google Analytics as a third-party cookie. Using Google Analytics for statistical purposes, the Website collects information about how visitors use the site. The data is used to improve the site's development and user experience. These cookies will remain on your browser or other browser on your computer or on your browser, or until your visitor cancels them.

4. The intended use and retention time of the data processed

Data management name: Messages sent from mail-based interfaces (Contact menu item on the Web site)
Use: Provide a contact opportunity for the correspondent
Legal basis: Access to property and business services
Shelf life: 1 year

5. The purpose, method and legal basis of data management

5.1. General Data Management Policies

The data management of the Service Provider's activity is based on a voluntary consent or legal authorization.
In some cases, the management, storage, and transmission of a particular set of data is mandatory by law, which is specifically notified to our customers.
We call on the Service Provider to inform the information providers that, if they do not provide their personal data, the data supplier is obliged to obtain the consent of the person concerned.
The data management principles are in line with existing data protection legislation, in particular:

  • 2011 CXII. Act on Information Self-Destruction and Freedom of Information (Infotv.);
  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Regulation (EC) No 95/46 / (General Data Protection Regulation, GDPR);
  • Act V of 2013 - Civil Code (Civil Code);
  • Act C of 2000 on Accounting (Accounting);
  • LIII. Law on the Prevention and Control of Money Laundering and Terrorist Financing (Pmt.);
  • 2013 CCXXXVII. Act on Credit Institutions and Financial Enterprises (Hpt.).

6. Physical storage locations

Your personal information (that is, the data that may be associated with you) can be treated in the following way: on the one hand, technical data on your computer, browser, web address, visited pages, on the other hand, you may also provide your name, contact details or other information if you intend to contact us personally using this site.
Technically captured data during the operation of the system: data of the computer of the person concerned that are generated during the voting and which the Website system records as an automatic result of the technical processes. Data that is automatically recorded will be logged automatically when entering or exiting, without the particular statement or action of the person concerned. This data can not be linked to other personal user data except in cases that are legally binding. This data is accessible only to the Website.

7. Data transmission, data retrieval, the circle of people familiar with the data

The persons who are sent by the Service Provider to the e-mail address can access and reply to the letters sent from the letter surface (Contact menu items on the Website). These individuals are the following: Avi Ben Yakar, Rónai Ákos, Kosik Éva.

8. Rights and Potentials Affected

You may request the information concerned to handle your personal data and may request the rectification of your personal data or, with the exception of mandatory data, cancellation, revocation, discretion and right of protest as indicated in the record and the above mentioned contact details of the data controller.

8.1. Right to information

The Service Provider shall take appropriate measures to ensure that all information relating to the processing of personal data, referred to in Articles 13 and 14 of the GDPR, and Article 34, in a concise, transparent, comprehensible and easily accessible manner, in a clear and unambiguous manner.

8.2. Right to access

The data subject is entitled to receive feedback from the data controller as to whether his or her personal data is being processed and, if such data is being processed, has access to personal data and the following information: the purpose of data management; the categories of personal data concerned; the categories of recipients or recipients with whom or which personal data will be communicated or disclosed, including in particular third-country addressees or international organizations; the intended duration of the storage of personal data; the restriction of rectification, deletion or data handling and the right of protest; the right to file a complaint addressed to the supervisory authority; data sources; the fact of automated decision making, including profiling, as well as the logic used and the understandable information on the significance of such data management and the likely consequences for the data subject. The data controller shall provide the information within a maximum of one month from the submission of the application.

8.3. Correction right

The person concerned may request rectification of inaccurate personal data handled by the Service Provider and of incomplete personal data.

8.4. Right to rescind

In the event of any of the following reasons, the data subject shall be entitled to cancel the personal data relating to him upon request by the Provider without undue delay:

  • personal data is no longer needed for the purpose for which they have been collected or otherwise handled;
  • the party concerned withdraws the consent of the data controller and does not have any other legal basis for data processing;
  • the person concerned objects to data manipulation and has no prior legitimate reason for data handling;
  • the personal data was unlawfully handled;
  • the personal data should be deleted for the legal obligation provided for by the law applicable to the data controller in the Union or the Member States;
  • the collection of personal data was made with the provision of information society services.

Deletion of data can not be initiated if data management is required: to exercise the right to freedom of opinion and the right of access; the fulfillment of an obligation under EU or Member State law applicable to the data controller for the processing of personal data, or for the performance of a task carried out in the exercise of public authority exercised in the public interest or on the data controller; for the purpose of archiving, scientific and historical research or for statistical purposes in the public health field, in the public interest; or for the submission, validation or protection of legal claims.

8.5. Right to Restrict Data Management

Upon request by the Service Provider, the Service Provider restricts the processing of data if one of the following conditions is met:

  • the person concerned disputes the accuracy of the personal data; in this case, the restriction concerns the period of time that allows the accuracy of personal data to be verified;
  • data handling is illegal and the data subject is opposed to the deletion of the data and instead asks to limit their use;
  • the data controller no longer needs personal data for data processing purposes but the data subject requires them to submit, enforce, or protect legal claims; or
  • the person concerned objected to data handling; in this case, the restriction applies to the duration of determining whether the data controller's legitimate reasons prevail over the legitimate grounds of the party concerned.

If data processing is restricted, personal data may be handled only with the consent of the person concerned or the submission, enforcement or enforcement of legal claims or the protection of the rights of a natural or legal person, or in the public interest of the Union or of a Member State .

8.6. Right to data storage

The data subject shall have the right to receive the personal data that he or she has accessed to the data controller in a fragmented, widely used machine-readable format and transmit such data to another data controller.

8.7. The right to protest

The person concerned is entitled to object at any time to the processing of data necessary for the execution of a task performed in the public interest or in the exercise of a public authority exercised on the data controller for the purposes of his or her own personal situation or for the treatment of the legitimate interests of the data controller or a third party, including profiling based on those provisions too. In the event of a protest, the data controller may not process personal data unless it is justified by compelling reasons of lawfulness that prevail over the interests, rights and freedoms of the person concerned, or which relate to the submission, enforcement or defense of legal claims.

8.8. Automated decision-making in individual cases, including profiling

The data subject shall be entitled to exclude the scope of a decision based solely on automated data management, including profiling, which would have a bearing on him or would have a significant effect on him.

8.9. Right of withdrawal

The person concerned has the right to withdraw his consent at any time.

8.10. Right to Court

In case of breach of his or her rights, the data subject may turn to the court. The court proceeds out of court.

8.11. Privacy Policy Procedures

Complaint with the National Data Protection and Information Authority can be used:
Name: Nemzeti Adatvédelmi és Információszabadság Hatóság
Address: 1125 Budapest, Szilágyi Erzsébet fasor 22/C.
Mailing address: 1530 Budapest, Pf.: 5.
Phone: 0613911400
Fax: 0613911410

9. Other provisions

Data management not listed in this information is provided when data is included.
We inform our clients that information, dissemination, transfer of documents or other documents from other bodies, based on the authority of the court, the prosecutor, the investigating authority, the offense authority, the administrative authority, the National Data Protection and Information Authority, the National Bank of Hungary, to access the data controller.
The Service Provider shall issue to the public authorities, if the authority indicates the exact purpose and scope of the data, only to the extent and to the extent that it is indispensable for the purpose of the request.

Budapest, 2018.05.24.