Privacy policy

Controller

The controller of personal data processed through this website is PRIVÁT UT Kft., 1138 Budapest, Váci út 161, 3/16, Hungary, contactable at office@privatut.com.

[Data protection officer: appointed / not appointed — to be confirmed. If appointed, name and contact details are published here.]

What we process and why

We process only what you send us. There is no account, no profiling and no automated decision-making on this site.

• Enquiry data: company name, contact person, business email, telephone, destination country, product or service, quantity, packaging, delivery terms, target period and any comments or attachment you provide.
• Correspondence: the messages exchanged with you about an enquiry and any resulting contract.
• Technical data strictly necessary to serve the site securely.
• Analytics data, only if you consent to it (see the cookie policy).

Legal bases

• Steps taken at your request prior to entering into a contract, and performance of a contract — Article 6(1)(b) GDPR. This covers handling your enquiry, preparing an offer and performing a shipment.
• Legitimate interests — Article 6(1)(f) GDPR. This covers keeping records of business correspondence, preventing abuse of our forms, and the counterparty and sanctions screening we are commercially and legally expected to perform.
• Legal obligation — Article 6(1)(c) GDPR. This covers retention required by accounting, customs and export control rules.
• Consent — Article 6(1)(a) GDPR. This covers optional analytics cookies only, and can be withdrawn at any time.

Recipients

Data is shared only where it is necessary to answer your enquiry or perform a contract.

• [Customer relationship management provider — name, role and location, to be confirmed]
• [Transactional email provider — name, role and location, to be confirmed]
• [Hosting provider — name, role and location, to be confirmed]
• Carriers, terminals, surveyors, customs agents and insurers appointed for a shipment, where the contact details are needed to perform it.
• Authorities, where disclosure is required by law.

International transfers

Where a shipment is destined outside the European Economic Area, contact details necessary to perform it may be transferred to the appointed agents in that country. Such transfers are made under Article 49(1)(b) GDPR where they are necessary for the performance of a contract with you, or under standard contractual clauses where a processor is involved.

[Confirm with counsel whether any processor is established outside the EEA, and attach the corresponding transfer mechanism.]

Retention

• Enquiries that do not result in a contract: [retention period — to be confirmed, commonly 12 to 24 months].
• Contract and shipment records: for the period required by Hungarian accounting and customs law [confirm the applicable period with counsel].
• Counterparty screening records: for the period required to evidence compliance with sanctions and export control obligations [confirm].
• Analytics data: [retention period — to be set once an analytics provider is chosen].

Your rights

You may request access to your personal data, its rectification or erasure, restriction of processing, portability, and you may object to processing based on our legitimate interests. Where processing rests on consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal. Requests are made to office@privatut.com.

You also have the right to lodge a complaint with a supervisory authority. In Hungary this is the Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH), or the authority of your habitual residence or place of work.

Status of this document

This document is a draft prepared for legal review. It has not been adopted and must be checked and approved by qualified counsel before the site goes live.