Privacy notice
Introduction
In this Privacy Notice, Majchrics Csaba sole proprietor (registered office: Hungary, 2724 Újlengyel, Petőfi Sándor utca 48., registration number: 62219815, tax number: 91996129-1-33, email: [email protected]), acting as the “Data Controller,” sets out for its current, former, and prospective clients and partners, as well as visitors to its website (hereinafter referred to as the “Users” or “Data Subjects”), the essential information relating to the management, processing, and recording of their personal data, the organizational and technical measures implemented to protect such data, and the rights of users in this regard, together with the means available for enforcing those rights.
The Data Controller considers the protection of personal data and the confidential treatment thereof to be of paramount importance, and in the course of its activities pays particular attention to the protection of personal data, compliance with mandatory legal provisions, and the secure and fair processing of personal data.
This Privacy Notice governs the processing of personal data in relation to the following website:
The Data Controller undertakes to comply unilaterally with the provisions of this Privacy Notice and requests that the Data Subjects also accept the terms set out herein. The Data Controller reserves the right to amend this Privacy Notice at any time, in which case the amended version shall be published publicly.
In the course of providing its services, the Data Controller shall select and operate the IT tools used for the processing of personal data in such a way as to ensure that the data processed:
• is accessible to those duly authorized to access it (availability);
• its authenticity and verification are ensured (authenticity of data processing);
• its integrity can be demonstrated (data integrity);
• is protected against unauthorized access (confidentiality of data).
The Data Controller does not engage any data processor in connection with the processing of personal data.
I. PURPOSE, SCOPE, AND LEGAL BASIS OF THIS PRIVACY NOTICE
1.1. The purpose of this Privacy Notice is to define the scope of personal data processed, the manner of such processing, and to ensure the enforcement of the constitutional principles of data protection and data processing, as well as the requirements of data security, in connection with the COACHING services (acquisition of new knowledge, performance enhancement, and facilitation of personal development) provided by Majchrics Csaba sole proprietor (registered office: Hungary, 2724 Újlengyel, Petőfi Sándor utca 48., registration number: 62219815, tax number: 91996129-1-33, email: [email protected]; hereinafter referred to as the “Data Controller”), in order to ensure that the privacy of natural person users is respected during the processing and handling of the personal data of the Data Subjects.
The purpose of the data processing is to enable the Data Controller to contact the Data Subjects for the provision of the COACHING SERVICES, to notify the participating Data Subjects in connection with their participation in the COACHING SERVICES, and to contact them subsequently for marketing purposes.
1.2. This Privacy Notice sets out the principles governing the processing of personal data voluntarily provided by Users on the Website and in the course of the performance of the services for the purpose of using such services.
1.3. Legal background of this Privacy Notice:
• Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Regulation 95/46/EC (General Data Protection Regulation).
• Act CXII of 2011 on Informational Self-Determination and Freedom of Information.
• Act LIII of 2017 on the Prevention and Combating of Money Laundering and Terrorist Financing.
• Act V of 2013 on the Civil Code.
• Act XLVIII of 2008 on the Basic Requirements and Certain Restrictions of Commercial Advertising Activities.
• Act C of 2003 on Electronic Communications.
• Act CVIII of 2001 on Certain Issues of Electronic Commerce Services and Information Society Services.
1.4. Scope of this Privacy Notice:
Temporal scope: This Privacy Notice shall enter into force on 1 January 2026 and shall remain in force until further notice or until revoked.
Personal scope: This Privacy Notice shall apply to the Data Controller, as well as to those persons whose data are processed under the data processing activities covered by this Notice, and to those persons whose rights or legitimate interests are affected by such data processing.
Material scope: This document shall apply to all data processing activities conducted by the Data Controller that involve personal data.
1.5. Personal data may be processed only for a specific purpose, for the exercise of a right, or for the performance of an obligation. At every stage of the processing, the data processing must comply with its intended purpose, and the collection and processing of data must be fair and lawful.
Only such personal data may be processed as is indispensable for the achievement of the purpose of the data processing and suitable for attaining that purpose. Personal data may be processed only to the extent and for the duration necessary to achieve the purpose concerned.
II. DEFINITIONS
2.1 "Data Processing": any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
2.2 "Data Controller": the person who, alone or jointly with others, determines the purposes and means of the processing of personal data.
2.3 "Personal Data": any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, number, location data, online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
2.4 "Data Breach": a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.
2.5 "Website" or "Site": the website operated by the Data Controller at www.capillarygrooves.com.
2.6 "Service(s)": the services provided by the Data Controller, accessible through the Website.
2.7 "User": the natural person who registers for the Services and contacts the Data Controller, providing their personal data in this context.
2.8 "Privacy Notice": this Privacy Notice of the Data Controller.
2.9 "Consent": a freely given and unambiguous expression of the data subject's wishes, based on adequate information, by which they give their unmistakable agreement to the processing of their personal data — either in full or limited to specific operations.
2.10 "Objection": a declaration by the data subject in which they contest the processing of their personal data and request the cessation of data processing or the deletion of the data being processed.
III. PRINCIPLES OF DATA PROCESSING
3.1. Personal data may be processed if the data subject consents thereto, or if such processing is ordered by law or — on the basis of authorization granted by law and within the scope defined therein — by a local government decree. Processing must be carried out lawfully, fairly, and in a transparent manner with respect to the data subject.
3.2. Personal data may only be collected and processed for specified, explicit, and legitimate purposes, and must not be processed in a manner incompatible with those purposes. Data processing must comply with these purposes at every stage. Only personal data that is indispensable for the fulfilment of the data processing purpose, suitable for achieving that purpose, and processed only to the extent and for the duration necessary for that purpose, may be processed.
3.3. Personal data may be transferred, and different data processing operations may be linked, if the data subject has consented thereto or if permitted by law, and provided that the conditions for data processing are met with respect to each item of personal data.
3.4. Data processing must be adequate, relevant, and limited to what is necessary in relation to the purposes for which it is carried out. Personal data must be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate with respect to the purposes of processing is erased or rectified without delay.
3.4. Data must be stored in a form that permits identification of data subjects only for as long as is necessary for the purposes of the data processing; personal data may be stored for longer periods only if the processing is carried out for archiving purposes in the public interest, for scientific and historical research purposes, or for statistical purposes in accordance with Article 89(1), subject to the implementation of appropriate technical and organizational measures required by this Regulation in order to safeguard the rights and freedoms of data subjects.
3.5. Processing must be carried out in such a manner as to ensure appropriate security of personal data through the application of appropriate technical or organizational measures, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage.
3.6. Personal data may be transferred from the country — regardless of the data carrier or the means of transfer — to a data controller or data processor located in a third country, if the data subject has expressly consented thereto or if permitted by law, and provided that an adequate level of protection for the transferred personal data is ensured during its processing or handling in the third country.
3.7. In the case of mandatory data processing, the purpose and conditions of processing, the scope and accessibility of the data to be processed, the duration of processing, and the identity of the data controller shall be determined by the law or local government decree ordering such processing.
3.8. Law may, in the public interest and with explicit specification of the categories of data concerned, order the disclosure of personal data. In all other cases, the consent of the data subject — and in the case of special categories of data, written consent — is required for disclosure. In case of doubt, it shall be presumed that the data subject has not given their consent.
3.9. The data subject's consent shall be deemed to have been given with respect to data disclosed by them in the course of their public activities or data provided by them for the purpose of publication.
3.10. In proceedings initiated at the request of the data subject, consent to the processing of the data necessary for such proceedings shall be presumed. The data subject must be expressly informed of this fact.
3.11. During data processing, the accuracy, completeness, and — where necessary with regard to the purpose of the processing — up-to-date nature of the data must be ensured.
IV. PURPOSE AND LEGAL BASIS OF DATA PROCESSING
4.1. Personal data may only be processed for a specified purpose, in order to exercise a right or fulfil an obligation. Data processing must comply with its purpose at every stage, and the collection and handling of data must be fair and lawful. Only personal data that is indispensable for the fulfilment of the data processing purpose and is suitable for achieving that purpose may be processed. Personal data may only be processed to the extent and for the duration necessary for the fulfilment of that purpose.
4.2. Legal basis for data processing:
4.2.1. Data processing is carried out on the basis of the voluntary, informed consent of visitors to the Website referred to above, which consent includes the users' express agreement that the personal data provided during use of the site or in the course of placing an advertisement may be used. The legal basis for data processing is the voluntary consent of the data subject pursuant to Section 5(1)(a) of the Information Act. With respect to the individual data processing operations, the user provides consent to the Data Controller by registering on the website, by voluntarily providing the requested data, and by signing a consent declaration during a personal consultation, and by doing so the user simultaneously accepts the data processing principles applied by the Service Provider. In certain cases, data processing may rest on a legal basis other than consent, or on Article 6 of the Regulation or other statutory provisions.
4.3. Purpose of data processing:
The Data Controller stores and processes the data provided by the User, pursuant to the Information Act and the Electronic Commerce Act, solely for the purpose of enabling the use of the services provided by the Data Controller as detailed on the websites, ensuring the provision of those services, and for marketing activities. Data processing is carried out exclusively in the manner prescribed by law, only to the extent and for the duration necessary for the fulfilment of the purpose, and solely with the personal data that is indispensable for and suitable for achieving the above purposes.
Purposes:
maintaining contact with the user
fulfilment of services
preparation of statistics and analyses
direct business acquisition and marketing outreach (prize draws, newsletters)
online content provision
protection of Users' rights
enforcement of the Data Controller's legitimate interests
handling and managing individual user enquiries
The Data Controller does not use personal data for purposes other than those listed above.
V. CATEGORIES OF PERSONAL DATA PROCESSED
5.1 When a User visits the Website, the Data Controller's system automatically records the User's IP address.
5.2 Based on the User's decision, the Data Controller may process the following data in connection with contact initiated through the Website and for the fulfilment of services:
name
home address
phone number
email address
identity card number
5.3. Additional categories of data processed by the Data Controller:
5.3.1. In order to provide a personalized experience, the Data Controller may place a small data package (a so-called "cookie") on the User's computer. The purpose of cookies is to ensure the highest possible quality operation of the given page, to provide personalized services, and to enhance the user experience. The User is able to delete cookies from their own computer or may configure their browser to block the use of cookies. By disabling the use of cookies, the User acknowledges that without cookies the full functionality of the given page cannot be guaranteed.
In the course of providing personalized services through the use of cookies, the Data Controller processes the following personal data: demographic data (based on the data referenced above) as well as information on interests, habits, and preferences (based on browsing history).
Data technically recorded during the operation of the systems: data generated by the User's login computer during the use of the Service, which is recorded by the Data Controller's system as an automatic result of technical processes. Automatically recorded data is logged by the system automatically upon login and logout, without any separate declaration or action on the part of the User.
VI. DURATION OF DATA PROCESSING
6.1 Automatically recorded IP addresses are stored by the Data Controller for a maximum of 30 days following their recording.
6.2 The User's personal data are processed for the duration of the service provision, for the purpose of organizing the data subject's participation and ensuring the proper delivery of the service, and — with regard to data processing for marketing purposes — until the withdrawal of the data subject's consent. The Data Controller does not transfer the data subject's data to third parties; such data remains exclusively under the management of the Data Controller.
6.3 In the event of unlawful or deceptive use of personal data, or in the event of a criminal offence or an attack against the system committed by the User, the Data Controller is entitled to delete the User's personal data without delay; however — in the event of a suspicion of a criminal offence or civil liability — the Data Controller is entitled to retain the personal data for the duration of the proceedings to be conducted.
6.4 If a court or authority issues a final and binding order for the deletion of personal data, the Data Controller shall carry out the deletion accordingly.
VII. USER RIGHTS AND HOW TO EXERCISE THEM
7.1 The User may request that the Data Controller inform them as to whether it is processing the User's personal data, and if so, to provide access to the personal data being processed, with particular regard to the following:
the purposes of the data processing
the categories of personal data concerned
the recipients or categories of recipients to whom the personal data have been or will be disclosed
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
the User's right to request from the Data Controller the rectification, erasure, or restriction of processing of personal data concerning them, and to object to the processing of such personal data
the right to lodge a complaint with a supervisory authority
where the data has not been collected from the data subject, all available information as to its source
the existence of any automated decision-making, including profiling, and at least in those cases, meaningful information about the logic involved and the significance and envisaged consequences of such processing for the data subject
7.2 The User may at any time request information regarding the processing of their personal data in writing, by sending a registered or registered letter with acknowledgement of receipt to the Data Controller's address, or by email to [email protected].
7.3 A request for information sent by post shall be considered authentic by the Data Controller if the User can be clearly identified on the basis of the submitted request. A request for information sent by email shall be considered authentic by the Data Controller only if it is sent by the User from their registered email address.
7.4 The User may request the rectification or modification of their personal data processed by the Data Controller.
7.5 Taking into account the purpose of the data processing, the User may request the completion of incomplete personal data.
7.6 The User may request the erasure of their personal data processed by the Data Controller. Erasure may be refused:
for the purpose of exercising the right to freedom of expression and the right to information; or
if the processing of personal data is authorized by law; or
to the extent necessary for the establishment, exercise, or defense of legal claims.
7.7 The Data Controller shall in all cases inform the User of any refusal of an erasure request, stating the reasons for the refusal. Once a request for the erasure of personal data has been fulfilled, the previously deleted data can no longer be restored.
7.8 The User may request that the Data Controller restrict the processing of their personal data if:
the User contests the accuracy of the personal data, in which case the restriction applies for the period enabling the Data Controller to verify the accuracy of the personal data;
the processing is unlawful and the User opposes erasure and requests restriction of use instead;
the Data Controller no longer needs the personal data for processing purposes, but the User requires them for the establishment, exercise, or defense of legal claims; or
the User has objected to the processing, in which case the restriction applies for the period until it is established whether the Data Controller's legitimate grounds override those of the User.
7.9 The User may request — where applicable — that the Data Controller transmit the personal data provided by the User and processed by the Data Controller by automated means, in a structured, commonly used, machine-readable format, and/or transfer such data to another data controller.
7.10 The User may object to the processing of their personal data:
if the processing is necessary solely for compliance with a legal obligation to which the Data Controller is subject, or for the purposes of the legitimate interests pursued by the Data Controller or a third party;
if the purpose of the processing is direct marketing, public opinion research, or scientific research; or
if the processing is carried out for the performance of a task in the public interest.
The Data Controller shall examine the lawfulness of the User's objection, and if the objection is found to be well-founded, shall cease the data processing and block the personal data concerned, and shall notify all parties to whom the personal data subject to the objection had previously been transferred, of the objection and of the measures taken on that basis.
7.11 If a data breach is likely to result in a high risk to the rights and freedoms of Users, the Data Controller shall notify the User of the data breach without undue delay. Notification to the User is not required if any of the following conditions are met:
the Data Controller has implemented appropriate technical and organizational protection measures and those measures were applied to the data affected by the data breach, in particular measures — such as encryption — that render the data unintelligible to any person who is not authorized to access it;
the Data Controller has taken subsequent measures that ensure that the high risk to the rights and freedoms of the data subjects is no longer likely to materialize;
the notification would involve a disproportionate effort, in which case the Data Controller shall inform the data subjects through publicly available notices or take similar measures ensuring equally effective notification.
7.12 Newsletters sent by the Data Controller may be unsubscribed from by sending an email to the Data Controller. Upon unsubscribing, the Data Controller shall delete the User's personal data from the newsletter database.
VIII. AMENDMENTS TO THE PRIVACY NOTICE
8.1. The Data Controller reserves the right to amend this Privacy Notice at any time by unilateral decision.
8.2. Applicable laws and procedural practices change from time to time. If the Data Controller decides to update this Privacy Notice, the amendments will be published on the Website. In the event of a material change to the manner in which the Data Controller processes the User's personal data, the Data Controller shall send prior notice to the User, and, where required by law, shall seek the User's consent before implementing such changes. The Data Controller strongly recommends that the User read this Privacy Notice and remain continuously informed about the practices followed by the Data Controller.
IX. LEGAL REMEDIES
9.1. For any questions or comments relating to data processing, the Data Controller can be contacted at [email protected].
9.2. The User may lodge a complaint regarding data processing directly with the National Authority for Data Protection and Freedom of Information (address: 1055 Budapest, Falk Miksa u. 9-11.; telephone: +36-1-391-1400; email: [email protected]; website: www.naih.hu).
9.3. In the event of an infringement of their rights, the User may have recourse to the courts. Jurisdiction over such cases lies with the regional court. The proceedings may — at the choice of the data subject — also be brought before the regional court having jurisdiction over the data subject's place of domicile or habitual residence. Upon request, the Data Controller shall inform the User of the available legal remedies and the means of pursuing them.
Budapest, 1 January 2026.
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