Privacy Policy
Information about our data processing activities when using PWS Solutions services
1. Data Controller Information and Contact Details
Data Controller Details
Name: Felczán Katalin e.v. (Sole Proprietor)
Tax Number: 91239978-1-24
Registration Number: 60710279
Registered Office: 5600 Békéscsaba, Pátkai Ervin utca 2, 4/12, Hungary
Contact Information
2. Data Protection Officer
The Data Controller qualifies as a small and medium-sized enterprise, and its activities do not fall within the scope defined in Article 37(1) of the GDPR, therefore the appointment of a data protection officer is not mandatory. For data protection matters, please contact the Data Controller directly.
3. Legal Basis for Data Processing
Consent (GDPR Article 6(1)(a))
The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
Contract Performance (GDPR Article 6(1)(b))
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Legitimate Interest (GDPR Article 6(1)(f))
Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject.
4. Categories of Personal Data Processed
Identification Data
- • First and last name
- • Email address
- • Phone number
- • Postal address
- • IP address
- • Company name (if applicable)
Communication Data
- • Message content
- • Communication preferences
- • Service-related requirements
- • Project specifications
- • Billing information
Technical Data
- • Browser type and version
- • Operating system
- • Referring website (referrer)
- • Pages visited
- • Date and time of visit
- • Data from cookies and similar technologies
5. Purposes and Legal Bases of Data Processing
Quote Request Handling
Purpose: Receiving customer inquiries, processing requests, preparing quotes
Legal Basis: Consent and contract preparation
Service Provision
Purpose: Delivering web development, hosting, and graphic design services
Legal Basis: Contract performance
Customer Relationship Management
Purpose: Ongoing communication, customer service, support provision
Legal Basis: Legitimate interest and consent
Billing and Accounting
Purpose: Fulfilling obligations under accounting law
Legal Basis: Legal obligation
Marketing Activities
Purpose: Sending newsletters, promoting services
Legal Basis: Consent
6. Data Retention Period
| Purpose of Processing | Retention Period |
|---|---|
| Quote request handling | 2 years after last contact |
| Contractual relationship | 5 years after contract expiration |
| Accounting documents | 8 years (as per accounting law) |
| Marketing data processing | Until consent withdrawal |
| Website usage data | 2 years |
7. Data Transfer and Processors
General Principles
The Data Controller does not transfer personal data of data subjects to third parties, except in cases specified in this policy or when required by law.
Data Processors
Hosting Provider
Website and data storage, backup creation
Email Service Provider
Electronic mail communication handling
Accountant
Billing and bookkeeping tasks
Analytics Providers
Website traffic analysis (Google Analytics)
8. Data Subject Rights
Right to Information
You have the right to request information about the processing of your data.
Right of Access
You have the right to access your data and request a copy of it.
Right to Rectification
You have the right to request correction or completion of inaccurate data.
Right to Erasure
Under certain conditions, you have the right to have your data deleted.
Right to Restriction
You have the right to request restriction of processing in certain cases.
Right to Data Portability
You have the right to receive your data in a structured, commonly used format.
Right to Object
You have the right to object to data processing under certain legal bases.
Withdrawal of Consent
You can withdraw your consent at any time for future processing.
How to Exercise Your Rights
You can exercise your rights through the following contact details:
- • Email: info@pws.hu
- • Phone: +36 70/319-40-21
- • Postal address: 5600 Békéscsaba, Pátkai Ervin utca 2, 4/12, Hungary
Response deadline: 1 month from receipt of the request
9. Legal Remedies
Complaint to Supervisory Authority
If you believe that the processing of your personal data violates GDPR provisions, you may file a complaint with the supervisory authority:
National Authority for Data Protection and Freedom of Information (NAIH)
Address: 1055 Budapest, Falk Miksa utca 9-11., Hungary
Postal address: 1363 Budapest, Pf. 9., Hungary
Phone: +36 1 391-1400
Email: ugyfelszolgalat@naih.hu
Website: https://naih.hu
Court Proceedings
Independently of or following a complaint to the supervisory authority, if you have suffered damage, you may seek compensation or damages in court.
10. Cookie Management
Our website uses cookies to improve user experience and optimize website functionality.
Essential Cookies
Essential for basic website functionality. These are always active.
Functional Cookies
Language selection, remembering preferences. Can be disabled.
Analytics Cookies
Website usage analysis (Google Analytics). Can be disabled.
Cookie Settings Management
You can manage and delete cookies in your browser. Disabling cookies may cause some website functions to not work properly.
For detailed information: Cookie Policy
11. Data Security
Technical Measures
- SSL encryption (HTTPS)
- Regular security backups
- Access control
- Antivirus protection and firewall
- Database encryption
- Regular security updates
Organizational Measures
- Data protection policies
- Staff training
- Access rights management
- Incident response procedures
- Confidentiality agreements
- Documented procedures
Data Breach Management
In case of a data protection incident, we act in accordance with GDPR Articles 33 and 34: we notify the supervisory authority within 72 hours and, if necessary, inform the data subjects as well.
12. Profiling and Automated Decision-making
The Data Controller does not engage in automated decision-making, including profiling, which would have legal effects or similarly significantly affect the data subject.
Exceptions
Should we engage in such activities in the future, we would provide separate information to data subjects about the logic involved, as well as the significance and envisaged consequences of such data processing.
13. International Data Transfers
General Principle
The Data Controller strives to process personal data of data subjects exclusively within the European Union.
Possible Exceptions
For certain services (e.g., Google Analytics, cloud services), data transfer to third countries may occur.
In such cases, we ensure appropriate safeguards:
- • Based on adequacy decisions
- • Appropriate safeguards (e.g., standard contractual clauses)
- • Exceptional situations (explicit consent of the data subject)
14. Data Subject Obligations
Data Accuracy
You are obliged to provide accurate and current data and inform us immediately of any changes to your data.
Information Obligation
You must notify the Data Controller if any changes occur in your data.
Lawful Use
Services must be used lawfully, without violating the rights of others.
Protection of Confidential Data
You must keep your access credentials (passwords) confidential.
15. Related Legislation
European Union Legislation
- GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data
- ePrivacy Directive: Directive 2002/58/EC concerning the processing of personal data and the protection of privacy in the electronic communications sector
Hungarian Legislation
- Infotv.: Act CXII of 2011 on Informational Self-Determination and Freedom of Information
- Accounting Act: Act C of 2000 on Accounting
- Civil Code: Act V of 2013 on the Civil Code
- Electronic Commerce Services Act: Act CVIII of 2001
16. Website-specific Data Processing
Contact Forms
Data processed: name, email address, phone number, message content
Purpose: receiving inquiries, preparing quotes
Legal basis: consent and contract preparation
Newsletter Subscription
Data processed: email address, name (optional)
Purpose: sending marketing content
Legal basis: consent (with double opt-in procedure)
Website Traffic Measurement
Data processed: IP address, browser data, visited pages
Purpose: optimizing website performance
Legal basis: legitimate interest (anonymous statistics)
Customer Relationship Management
Data processed: complete customer profile, project data, communication history
Purpose: service provision, customer support
Legal basis: contract performance, legitimate interest
17. Processing of Special Categories of Data
General Rule
The Data Controller does not generally process special categories of data under GDPR Article 9 (racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, data concerning sexual life or sexual orientation).
Exceptional Cases
Should the processing of special categories of data become necessary (e.g., accessibility requirements), we will request separate explicit consent and apply enhanced protective measures.
18. Special Situations
Business-purpose Data Processing
Due to the nature of our services (web development, graphic design, hosting), we primarily process data of businesses, companies, and sole proprietors within business relationships.
Project-based Cooperation
Data processing is typically related to specific projects, for a defined period, for the purpose of providing specific services.
B2B Relationships
The majority of our clients are businesses, so data processing is primarily limited to business contact data (corporate email, corporate phone, contact person's name).
19. Records of Processing Activities
The Data Controller maintains records of processing activities in accordance with GDPR Article 30, which includes:
- Name and contact details of the controller
- Purposes of processing
- Description of categories of data subjects
- Description of categories of personal data
- Categories of recipients
- Erasure time limits
- General description of technical and organizational security measures
20. Final Provisions
Entry into Force
This Privacy Policy enters into force on January 1, 2025.
Right to Modification
The Data Controller reserves the right to unilaterally modify this policy. We will inform data subjects of modifications through our website.
Language Versions
This policy is available in Hungarian, English, and German. In case of discrepancies, the Hungarian version shall prevail.
Contact
For data protection matters, please contact us at the following:
Email: info@pws.hu
Phone: +36 70/319-40-21