Privacy and data management information
Privacy and data management information
Effective: from 1 February 2026
"We treat our partners' data the way we expect others to treat our data."
Table of contents:
1. Principles governing the processing of personal data.
2. Basic terms used in our Privacy Notice.
3. The Data Controllers.
4. Newsletter registration.
5. Cookie information and Google Analytics.
6. Reservations (appointments) and food ordering through the contact details on the Website.
7. Card application and Card (gift card, voucher) registration.
8. Conclusion of a contract for catering services.
9. Scope of data processed in the course of WASABI career advertising.
10. Data processors.
11. Security of data processing.
12. Your rights.
13. Remedies.
14. Scope of the Privacy Notice, applicable law.
This notice will be reviewed and maintained in the light of changes in legislation and changes to our data
depends on.
Introduction
The purpose of this Privacy Policy (hereinafter referred to as „Privacy Policy”) is to enable WSB Zrt. as a franchise and licensee to
owner, transferor and owner and operator of the websites identified below, and the Data Controllers as franchisors and
the economic operators identified among the licensees, all data processed in the course of their activities and services
on its data management practices to provide data subjects with all information relevant to the processing of personal data,
in particular, the organisational and technical measures taken to protect the data and the rights of the users/interested parties
information on their rights and means of enforcing their rights.
This notice applies to the companies listed as Data Controllers and to natural persons,
to whom its processing activities apply. The data processing activities covered by this notice are natural
personal data of individuals. The scope of this notice does not cover the processing of personal data that is legally
persons, and in particular to undertakings which are constituted as legal persons, including
the name and form of the legal person and contact details of the legal person. Legal person means an association, a
a company, a cooperative, an association and a foundation.
Please note that your rights will be respected in all cases, and the provisions of this Privacy Notice will be complied with.
we accept that we are bound by them and will comply with their requests within the time limits set by law. Data Controllers
undertake to comply in their activities with the provisions of this Privacy Notice and the
On the basis of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter GDPR) and the relevant
in accordance with the law, as set out in this notice:
- during personal contact;
- when sending newsletters;
- a www.wasabi.hu, a www.wasabi-hirlevel.hu, a www.wasabi-etlap.hu, a www.whatsrunning.hu, a
www.yamatorestaurant.hu, a www.margarets.hu, www.kistarcsainosztalgia.hu, www.nosztalgia.hu,
Available under the domain names www.happyetterem.hu, www.doblo.hu, www.seoulhouse.hu, www.washwax.hu
in the operation of the websites (hereinafter referred to as the "Website");
- WASABI Club card, Yamato card, What's Running card, Doblo card, Margaret's card,
Personal and online registration for the Nostalgia Card and Happy Card (hereinafter: Card)
during;
- WASABI career during job advertisement
the data processed.
2
1. Principles governing the processing of personal data.
1.1 Principle of lawfulness: data controllers process your personal data lawfully. In order to ensure that
the processing of personal data to be lawful, it must be based on your consent or some other lawful basis,
have a basis established by law, including the ability to comply with legal obligations to which the Data Controller is subject
the need to comply, the performance of any contract entered into by the data subject, or the need to comply with any request made by the data subject to
the steps to be taken before signing a contract.
1.2. Fair and transparent processing: data controllers shall ensure that you, as the data subject, are informed of the following.
the fact and purposes of the processing. Data controllers shall provide the data subject with all necessary information,
taking into account the specific circumstances and context in which the personal data are processed. You are entitled to confirmation and
be informed about the processing of your personal data.
1.3 Purpose limitation principle: personal data are collected only for specified, explicit and legitimate purposes. The
Data controllers shall not, in a manner incompatible with the purposes set out in the Data Protection Notice, collect or use data
are treated. Additional processing for statistical purposes is not considered incompatible with the original purpose.
1.4. Data minimisation principle: Data Controllers shall ensure that personal data are processed in accordance with the following principles
must be adequate, relevant and limited to what is necessary for the purposes for which it is processed.
1.5. Accuracy principle: personal data must be accurate and, where necessary, kept up to date, and the Data Controller must ensure that all
take reasonable steps to ensure that personal data which are inaccurate for the purposes of the processing are not
be deleted or corrected without delay.
1.6. Limited Retention Principle: personal data is stored in a form which permits identification of data subjects only
allow the processing of personal data for the time necessary to achieve its purposes.
1.7. Integrity and Confidentiality: data controllers shall carry out data processing in such a way that all appropriate technical
and/or organisational measures to ensure that personal data are adequately protected, that the data are
unauthorised or unlawful treatment, accidental loss, destruction or damage to your personal data
be ensured.
1.8 Accountability principle: the Data Controller is responsible for the processing of personal data recorded in this Privacy Notice
the principles governing the processing of your personal data and the compliance of the processing with this Privacy Notice
justification.
2. Basic terms used in our Privacy Notice.
2.1 Users: readers, visitors, users of our Website, any natural or legal person or other entity,
who visits the Website at least once, views the Website, uses the Website or otherwise (by telephone,
in person, via an electronic mail system, etc.) to apply for a Card, register for a newsletter or request an offer.
2.2. Data Subject: a natural person User identified or identifiable from the personal data processed by the Data Controller,
or an employee of a sole trader or company who has entered into a contract with the Data Controllers and who has been appointed to contact us.
2.3. Personal Data: any information relating to an identified or identifiable natural person on the basis of which the
can be identified, directly or indirectly, on the basis of one or more factors, and the data can be used to
a conclusion about the data subject.
2.4. Processing: any processing of personal data or data files, regardless of the process used, by any
an operation or set of operations, in particular the collection, recording, recording, organisation and storage of data,
alter, use, retrieve, transmit, disclose, coordinate or combine,
blocking, erasure and destruction of data and to prevent their further use.
2.5. direct marketing (DM) newsletter: a postal letter sent by the data controller to data subjects at specified intervals or
sent by electronic mail about the products and services it sells or provides,
information and advertising material about possible promotions, etc., to which the Data Subject has given his or her prior consent in the newsletter.
by subscribing to the newsletter.
2.6. Data subject's consent: a voluntary, specific and unequivocal expression of the data subject's wishes, which is an appropriate
is based on information and by which you give your clear and unambiguous declaration, consent and agreement,
personal data relating to him or her to be processed.
2.7:
„checkbox”), you declare that you agree to the terms and conditions of this Privacy and Data
have read, understood and accept the terms and conditions.
2.8. Data subject's objection: a statement by the data subject objecting to the processing of his or her personal data and that the processing
or the deletion of the processed data or copies of the data.
2.9.
as a consequence, their restoration is not possible in the future.
2.10. Transfer of data: making data available to a specified third party.
2.11. Data restriction: the assignment of an identification mark to data for the purpose of their further processing, either permanently or for a limited period of time
to restrict.
2.12. Processing of data: the performance of technical tasks related to data processing operations, irrespective of the
the method and means used to carry it out and the place of application, provided that the technical task is carried out by
are carried out on data.
3
2.13. Data Processor: a natural or legal person or unincorporated body who, or
which, on the basis of a contract with the controller, including a contract concluded by virtue of a legal provision, is
processes the data.
2.14. Third party: any natural or legal person or unincorporated entity that is or
which is not the same as the Data Subject, the Controller or the Processor.
2.15. Specific data: racial or ethnic origin, political opinions, religious or philosophical beliefs or
personal data revealing trade union membership, and genetic data and personal data for the purpose of uniquely identifying natural persons
biometric data, health data and the sexual life or sexual orientation of natural persons
personal data concerning.
2.16. Other Data: any data that does not fall under the categories of Personal Data and Special Data.
2.17. Data Breach: a breach of security that compromises the security of Personal Data transmitted, stored or otherwise processed by us.
the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or access to data
result in unauthorised access.
2.18. cookies („cookies"): short data files placed by the website visited by the User on the User's computer.
on your computer.
2.19. IP address: the unique identification number (Internet Protocol address) of computers and other devices connected to the Internet.
3. The Data Controllers:
Name: WSB Hospitality and Services Private Limited Company
Head office: 2000 Szentendre, Rab Ráby tér 6.
Company registration number: 13-10-041901
Tax number: 26640424-2-13.
Electronic contact: wsbzrt@wasabi.hu
Represented by: dr. Bródi Béla Árpád CEO
Name: ABChikuma Ltd.
Registered office: 1095 Budapest, Mester utca 28. B. lph. I. floor 5.
Company registration number: 01-09-708614
Tax number: 12892666-2-43
Electronic contact: rendeles@wasabi.hu
Acting on behalf of: Szandra Kisgyőri, Managing Director
Name: Nagano Trade Ltd.
Head office: 1037 Budapest, Szépvölgyi út 15.
Company registration number: 01-09-337983
Tax number: 26664189-2-41
Electronic contact: wasabi@wasabi.hu
Represented by: Sándor György Eötvös, Managing Director
Name: Kuzama Trade Kft.
Head office: 1065 Budapest, Podmaniczky utca 21.
Company registration number: 01-09-333041
Tax number: 26576750-2-42
Electronic contact: wasabi2@wasabi.hu
Represented by: Károly Rudolf Debreczeni, Managing Director
Name: „ZEBRA ÜZLETHÁZ” Ltd.
Head office: 4025 Debrecen, Piac utca 18.
Company registration number: 09-09-035176
Tax number: 12730917-2-09
Electronic contact: wasabidebrecen@wasabi.hu
Represented by: István Tripó, Managing Director
Name: tokomu Trade Kft.
Head office: 1124 Budapest, Németvölgyi út 91.
Company registration number: 01-09-333581
Tax number: 26586182-2-43
Electronic contact: wasabimom@wasabi.hu
Represented by: Anna Beáta Bándy, Managing Director
Name: Minimal Design Ltd.
Head office: 1051 Budapest, Hercegprímás u. 4.
Company registration number: 01-09-997434
Tax number: 14114429-2-41
Electronic contact: whatsrunning@wasabi.hu
Represented by: László Attila Takó, Managing Director
Name: Seoul House Korean Restaurant Ltd.
Head office: 1011 Budapest, Fő utca 8.
Company registration number: 01-09-068728
4
Tax number: 10444614-2-41
Electronic contact: seouletterem@gmail.com
Represented by: Erzsébet Eötvös Gyöngyi, Managing Director
Name: for sale 2002 Ltd.
Head office: 1053 Budapest, Vámház körút 2.
Company registration number: 01-09-704842
Tax number: 12816840-2-41
Electronic contact: forsale.etterem@gmail.com
Represented by: Erzsébet Kelemen-Honvéd, Managing Director
Name: Alfred the Rabbit Ltd.
Head office: 2045 Törökbálint, Pistályi út 6.
Company registration number: 13-09-217695
Tax number: 27113215-2-13
Electronic contact: doblo@doblo.hu
Represented by: István Sallai Managing Director
Name: FORRÓKŐ Bt.
Registered office: 2143 Kistarcsa, Szabadság út 46.
Company registration number: 13-06-021821
Tax number: 24569600-2-13
Electronic contact: kistarcsainosztalgia@gmail.com
Represented by Katalin Gergely, Managing Director
Name: SUPER KAPPA 2007 Ltd.
Head office: 1027 Budapest, Margit körút 2.
Company registration number: 01-09-922199
Tax number: 14114450-2-41
Electronic contact: margarets@wasabi.hu
Represented by: Sándor Kötő managing director
Hereinafter collectively referred to as the Data Controllers.
Given that the purpose of certain processing activities set out in this Notice and the
the method of processing is determined jointly by the Data Controllers, WSB Zrt. and the other listed Data Controllers are subject to the European
Parliament and of the Council (EU) on the protection of natural persons with regard to the processing of personal data and
Regulation 2016/679 on the free movement of such data and repealing Regulation (EC) No 95/46/EC
(27 April 2016) (hereinafter referred to as "GDPR"), Chapter IV, Section 1, Article 26, they are considered to be joint controllers.
Data Protection Officer:
Szandra Kisgyőri
+36 30 825 6376
Our activities:
We are a Hungarian company duly registered and operating. WSB Zrt., as the legal owner of franchise and
licensor and the other Data Controllers as franchisees and licensees of our services.
Nationally, WSB Zrt. operates the Websites listed above and the associated webshop, as well as the additional
Data controllers operate Restaurants and home delivery, car service. All under the GDPR
They are considered as data controllers, in particular because they collect personal data (e.g. name, address, IP address, e-mail address,
type and type of vehicle), measure the use of the Website and log the views for security reasons. A
When visiting the website, the internet server of the Data Controllers automatically registers the IP address of the users and
the type of operating system of your computer and the time of your visit to the Website. Online marketing activity
you will be sent a newsletter. If you contact us by e-mail or via the Website in connection with a service, we will contact you
contact you, in particular to book a table (appointment) through the Website or the online shop for food delivery
or, if you request an offer or enter into a contract or register a Card, to provide the service in question.
process your personal data to the extent and for the duration strictly necessary.
4. Newsletter registration
Subscribing to the newsletter on the Website requires registration, during which you provide your e-mail address,
to which we will only send an advertising mailing if you have previously requested,
has explicitly contributed to. Subject to the provisions of this notice, the data subject shall, after having been duly informed.
then specifically consents to the processing of personal data by the Data Controllers for the purposes of sending promotional newsletters.
The Data Controllers will not send unsolicited commercial communications.
In practice, consent means that you, as a user visiting the Website, have the right to give your consent
checkbox, tick it, and you will receive a newsletter after registration. Data controllers are subject to the law
keep a database of subscribers and a blacklist of unsubscribers to the newsletter in order to fulfil their obligations.
4.1. Scope of stakeholders:
5
Users who visit the Website and register for the newsletter.
4.2. Purpose of the processing:
- sending e-mail newsletters to subscribers containing economic advertising,
- accurate management of orders or reservations,
- information on current information and promotions,
- storage in a database.
4.3. Legal basis for processing:
- voluntary, prior and informed consent of the data subject,
- the Data Controllers of the personal data of the persons giving their consent
are required to keep records. (Grt. § 6 (5).)
4.4. Scope and purpose of the data processed:
your name
send a birthday greeting and reminder of your date of birth
your e-mail address for newsletter distribution, general contact
the date of subscription to perform a technical operation.
performing a technical operation on the IP address at the time of subscription.
4.5. Source of data: directly from the data subject, i.e. you.
4.6 Duration of the processing:
- until the user's consent is withdrawn, i.e. until unsubscription,
- but no more than 24 months from the date of the user's last newsletter.
4.7. Unsubscribe from the Newsletter:
You can unsubscribe from the newsletter free of charge, without any restriction or justification. In this case, all - the
personal data necessary to send you promotional messages - will be deleted from our records and no further promotional offers will be sent to you.
let's find it.
Your consent may be withdrawn at any time, without restriction and without giving any reason, without prejudice to
the lawfulness of the processing prior to withdrawal:
- using the link at the end of this newsletter,
- by post: by letter sent to the head office of the operators,
- by sending an e-mail to info@wasabi.hu.
4.8. 6(5) of the Grt. on the personal data of persons giving their consent
we keep records. The data recorded in this register - which relates to the recipient of the advertising, i.e. you - is only used for the
in accordance with the terms of your consent until it is withdrawn.
4.9 The Data Controllers will not transfer your data to a third party, they will only store it in their own database. Your
data may only be accessed by a member of the Data Controllers' marketing or sales staff or by a person appointed by the Data Controllers
accessed by the data processor.
5. Cookie information and Google Analytics
The operator of our website currently uses cookies for the operation of the website.
Our website uses Google Analytics, a web analytics service provided by Google. The Google Analytics service
is based on internal cookies, so it uses cookies to compile reports for Data Controllers, provide information on the website
experienced users, i.e. your interactions (e.g. where you clicked and how much time you spent on certain subpages).
Because of the way it works, the operators and owners of the Website can learn the IP address of their users through Google Analytics
when using the service. However, Google Analytics only collects the IP addresses of website users in order to.
to protect the security of the service, and to give site owners an idea of how their visitors around the world
where they come from (also known as „IP geographic location”). Learn more about the Google cookie
are available at the following link: https://www.google.com/policies/technologies/cookies Detailed information on the
Google's privacy policy is available at the following link: https://policies.google.com/privacy?hl=hu
5.1 The purpose of using Google Analytics is to provide information to Data Controllers, in particular on.
for:
- how many visitors have visited our Website and how much time they have spent on our Website,
- whether the visitor is a returning visitor or a new visitor, and to track the visitor's journey through the Website and where they have gone
entered.
5.2 You can prevent Google Analytics cookies from being stored by changing your browser settings, but this is not possible
It may limit the proper functioning of the website. The user may also prevent Google from tracking
collect and process data about the user's use of the website through cookies, which can be accessed via the following link
to install the browser module: https://tools.google.com/dlpage/gaoptout?hl=hu
5.3 Google Analytics supports three JavaScript libraries (tags) for measuring the use of the Website: gtag.js,
analytics.js and ga.js. gtag.js and analytics.js set the following cookies:
cookie type cookie function duration
- ga - used to distinguish users, 2 years,
- gid - used to distinguish users ,24 hours,
- gat - used to control the polling rate, 1 minute,
6
AMP_TOKEN contains a token that is used to identify the customer from the AMP customer identification service.
can be downloaded from 30 minutes to 1 year,
- gac - contains information related to campaign for the user, 90 days,
ga.js sets the following cookies:
type of cookie, purpose of processing, duration of processing,
- path - used to distinguish between users and sessions. It provides information about whether the user
whether they have visited the website before, which can be used to determine who is a new visitor to the website. The cookie is updated
each time data is sent to Google Analytics, 2 years from the date of setting/updating,
- utmt - used to control the polling rate, 10 minutes,
- utmb - used to define new sessions/visits 30 minutes after setup/update,
- utmc - worked in conjunction with the _utmb cookie to determine if the user is in a new session/visit
until you close the browser,
- utmz - keeps track of where the visitor came from 6 months from the date of setting/updating,
- utmv - is used to store visitor-level, individually variable data. This cookie is created when a developer uses the
uses the setCustomVar method with visitor-level, individually variable data. 2 years from set/update.
6. Reservations (appointments) and food ordering through the contact details on the Website.
The telephone number and e-mail address on the Websites, through which you can contact the Data Controllers.
to get in touch.
Reservation (reservation): you can make a reservation over the phone, in which case our colleagues will contact you with the name of the reservation, the
your exact date and telephone number will be requested when you make a reservation (reservation) via the Website.
your booking, we will need your e-mail address to which we will send a confirmation message, the name, date and
phone number.
Ordering food: in the webshop, you add the products you want to order to your shopping cart and enter your e-mail address,
whereupon the data subject will receive a confirmation message from the Data Controller with details of his/her order. The order
we need your name, delivery address and a telephone number where we can contact you.
If by ticking the checkbox you declare that you agree to be bound by this Privacy Notice in relation to
you have read and accepted the processing and storage of your data by the Data Controller concerned, you register
to our webshop, which also includes your consent to receive our newsletter. To unsubscribe from the newsletter
see section 2.7. for options.
6.1. Data subjects: persons placing the order, persons making the reservation.
6.2 Purpose of the processing: to inform you, to fulfil your reservation or food order request.
6.3. Legal basis for processing:
- voluntary, prior and informed consent,
- data controllers must keep a record of the personal data of the persons who have given their consent. 6. §
(paragraph 5).)
6.4. Scope and purpose of the data processed:
your name identification
your e-mail address. enter information
your mobile phone number information, quick contact
the type and type of your vehicle the service charge is set
delivery address order fulfillment
6.5 Source of the data: directly from the data subject, i.e. you.
6.6 Duration of the processing:
- until the user's consent is withdrawn.
6.7 The Data Controllers will not transfer your data to a third party, it will be stored only in their own database. Your
data can only be accessed by an employee of the Data Controllers who is involved in marketing or sales activities.
If you contact us by phone to make a reservation, your details will be kept on paper until the time of the reservation,
then the paper is destroyed.
7. Card application and Card (gift card, voucher) registration
For details of the services, please visit the Website. In our restaurants or after registering online
we will create a so-called „user account” for you. If you register in person, we will create a card for you, which will then
your data will be included in our system from the date.
7.1 If you use the Card, you will receive discounts and credits for your purchases under the Basic Services. A
You can find out how to use your card, discounts and credits only on the Website and in our restaurants.
7.2 In addition to the basic services, we provide additional services, which are:
Advertising includes our own products, goods, promotions or services.
If you have any questions about the Card, you can contact our staff in our restaurants, or you can also contact us on our website
Our restaurants.
7.3 During the prize draw, we usually draw gift vouchers, shopping or discount coupons. A
prize draws will be published on our websites or Facebook account.
7
7.4. Your data will be used solely for the purposes of organising and conducting the promotions, delivering the prize, reporting the prize to the
for sending notifications, contacting and handling complaints, fraud detection and legal claims
we use. To do this, we process the following personal data.
7.5. Market research
Market research allows us to make decisions about our business model based on empirical evidence.
let's do it. To this end, we address pre-defined areas and criteria, such as demographic
development, consumer habits or media use. To do this, we record personal data that our customers
we anonymise it in advance to protect your privacy, so that the processing cannot be traced back to you.
Personal data evaluation allows us to automatically check your interests. A
by evaluating your personal data and understanding your habits, for example, to create more personalised
services, offers and promotions we can provide.
7.6. Within the framework of the use of the Card, the registration and the related Basic Services are subject to the following
provides personal data to our Company:
Surname and first name
date of birth
e-mail address
Name day (voluntary data)
After registration, a card number will be created, to which your personal data will be assigned, allowing you to
makes it possible to clearly identify you.
7.7 If you have given your consent to receive information and advertising about our products in accordance with point 1,
about our services, competitions, customer surveys and promotions.
This data processing is based on Article 6(1)(a) of the General Data Protection Regulation (GDPR) and is not based on personalised advertising.
to welcome.
8. Conclusion of a contract for catering services
If, in response to your request for a quotation or other enquiry, a Contract of Agency is entered into between us for catering
provide a service and you are a self-employed person or an employee of a company that contracts with us
designated person, your personal data will be recorded in the contract.
7.1.The data subjects are: individual entrepreneurs and businesses who have concluded a contract of agency with the Data Controller concerned
staff designated to liaise with.
7.2 Purpose of the processing: performance of the contract.
7.3. Legal basis for processing:
- performance of a contract to which the person concerned or his or her employer is a party or the conclusion of the contract
to take steps at the request of the data subject before,
- to comply with the legal obligations applicable to Data Controllers, such as those required by Act C of 2000 on Accounting.
Commitment.
7.4. Scope and purpose of the data processed:
your name identification
enter your mailing address information
enter your e-mail address information
enter your mobile phone number information
7.5. Source of data: directly from the data subject, i.e. you
7.6 Duration of data processing: if the Contract of Agency between us terminates on the date of the last
after the expiry of the retention period (8 years) for the account (as provided for in Act C of 2000), the data will be deleted.
After the date of termination of the Contract of Agency, the Data Controller concerned shall only store the data, and shall not process the data
does not operate on them.
9. Scope of data processed in the course of WASABI career advertising
9.1. On the registration interface of the Website, the User has the possibility to enter his/her data in order to
Website services (hereinafter referred to as "Registration"). During the Registration process, you will provide the following personal information.
data required (data marked with * are mandatory):
full name*;
e-mail address*;
password*;
phone number*
newsletter subscription
In the Google website link on the WASABI Careers Facebook page, sent to allas@wasabi.hu
by letter or in person at the Data Controller, the User may provide his/her data in order to,
to apply for the job advertised. When registering, you must provide the following personal information (marked with *)
marked data are mandatory):
full name*;
residence*;
date of birth*;
8
phone number * .
upload your CV.
9.2 When creating a new CV, the following information may be provided:
personal data:
o photo;
o address;
o Year of birth;
o citizenship;
o no;
o telephone number.
studies:
o type of qualification, name, name of institution, date of graduation;
o IT knowledge, certification;
o language skills: language, level, date of acquisition;
o type of licence, date obtained;
o other knowledge.
work experience:
o the name of the employing company;
o job title;
o work address;
o length of employment;
o job description.
9.3. In the User profile, the User has the possibility to select the job he/she is looking for, by clicking on the job, e-mail
message, you can enter your details and those of the job you are looking for (type of job, location, other aspects),
save job advertisements, modify the data you have provided, except for the optional data
delete data, subscribe or unsubscribe to newsletters.
9.4. The data subject also has the possibility to request, by personal appearance in the restaurants of the Data Controller or by the Data Controller
during a personal interview with your adviser (hereinafter referred to as the interview), using the paper form provided.
or a digital form (hereafter referred to as the "Data Sheet") with your details, CV and the job description
in order to be contacted by the Data Controller with a suitable job offer. Fill in the Data Sheet,
or during the interview, only the data of the Data Subject that is necessary for the job search will be collected.
On the basis of the data provided on the Data Sheet or during the interview, the Data Controller will also create the Data Subject's User
your profile, which may include the data provided under „User profile” with your voluntary consent
based on.
9.5 During a telephone conversation with the Data Controller, the Data Subject also has the possibility to provide data relating to.
in order to be contacted by the Data Controller in the future in connection with job opportunities, to inform you of job offers
at the e-mail address provided by you.
name (first name, surname)*;
city where you live;
phone number;
e-mail address;
type of education (primary school, secondary school, etc.)
what type/category of work do you want? (finance, manual work, etc.).
9.6. Applying for a job
The Data Controller shall process the personal data (CV,
identification data, contact details, data relating to education, employment, interests) processes the data
during and for the purpose of processing an application for a job offer.
In accordance with Section 10 of Act I of 2012 on the Labour Code (hereinafter referred to as "Labour Code"), the Data Controller shall process the following data.
The data of the employee concerned which are necessary for the establishment, performance and
are relevant for the elimination of:
employee identification data:
o name (name at birth);
o place and date of birth;
o mother's name;
o citizenship;
o place of residence, domicile;
o social security number, tax identification number; identity card number
o marital status;
9
o number, place and date of birth of children; tax identification number
o bank account number;
o photo.
data on studies, qualifications:
o data on educational attainment;
o data on qualifications and professional qualifications;
o language skills.
employment-related data:
o the start of employment, the position held, the working hours, the work performed
location;
o the date, manner and conditions of termination of employment.
The Data Controller only collects specific data on the basis of the Data Subject's written consent which is necessary for the performance of the job in question.
are needed to fill. Only persons over the age of 16 are entitled to provide data.
9.7. Purpose of data processing
The Data Controller uses the data for the following purposes in connection with the services it provides:
When registering on the Website: the purpose of the processing is to provide the services of the Website,
Create a user profile.
The purpose of data processing when creating a User Profile (or filling in the Data Sheet and the Interview) is
o managing, modifying, deleting data stored in the User profile, CVs;
o use of the data for the purpose of applying for a job advertisement, setting up job searches, job offers
and contacting the User, sending notifications according to his/her qualifications and abilities
job vacancies and opportunities that meet your needs;
o The purpose of processing the data provided when creating a CV is to enable the User to
to be contacted by the Data Controller with a suitable job offer, and the User
your qualifications, skills and abilities that are relevant to the position to be filled
to identify the needs of;
o monitor and facilitate the professional development of the Data Subject.
The purpose of collecting data when contacting us by telephone is to send information about the Data Subject's qualifications and
job vacancies that match your interests to the email address you provide when you contact us.
In the case of job applications, the purpose of the processing is
o contacting the Data Subject in relation to the job offer indicated;
o providing your details and CV to the employer advertising the job vacancy
on the basis of the data subject's consent;
o the selection procedure in relation to a job advertisement published by the Data Controller
conducting;
o facilitating the creation and maintenance of an employment relationship;
o with your specific consent, to create a User profile of you, your Data Subject
your qualifications, skills and needs relevant to the job to be filled
disclose to the data subject his or her interests, skills, abilities and needs;
finding the right job offer;
9.8 The Data Controller shall also use the personal data provided by the User for statistical purposes, solely in such a way that,
to anonymise the personal data so that it can no longer be used to identify you, in any way
cannot be linked to a natural person.
9.9. Duration of data processing
The Data Controller shall process personal data for the purposes for which the data are processed, such as registration on the Website, the
In the case of a User Profile, in connection with the collection of data during a telephone enquiry and in connection with the
until the User requests the deletion of his/her data or withdraws his/her personal data.
and to receive Newsletters.
The personal data shall be deleted at the same time as the purpose of the processing ceases to exist or at the request of the User without
are deleted without delay, except for data which the Data Controller is legally obliged to disclose to the
for the period specified in the legislation imposing the mandatory processing, so that the Data Controller is obliged to
personal data processed in the course of the establishment, performance and termination of the employment relationship arising from the employment relationship
until the statute of limitation for claims arising from employment law, i.e. from the date of termination of the employment relationship under Section 286 (1) of the Labour Code.
for 3 years or, where longer periods are required by law, for the duration of the retention period.
In the case of an application for a job advertisement, the Data Controller shall keep the personal data for the duration of the purpose of the processing, i.e.
in the case of a job offer, until the time of the administration of the job offer, to the Data Subject in response to his or her enquiry or
in the case of the placement of a job offer corresponding to your choice, for the duration of the purpose of the processing and for as long as the
The data subject does not request the erasure of data or withdraw consent.
10. Data processors.
10.1 The Data Controllers use a data processor to perform the following data processing activities:
10
- Website operation, maintenance:
Name: Challenger-Solution-it Ltd.
Headquarters: 3000 Hatvan, Madách utca 10/A.
Tax number: 32670554-2-10
Representative: Dr. Gábor Bánkuti, Managing Director
Elérhetősége: info@challengerit.hu
- Hosting services providing IT back-up:
Name: dotRoll Ltd.
Head office: 1148 Bp, Fogarasi út 3-5.
Representative: Gábor Busai
Contact: + 36 1 432 3232
Name: Challenger-Solution-it Ltd.
Headquarters: 3000 Hatvan, Madách utca 10/A.
Tax number: 32670554-2-10
Representative: Dr. Gábor Bánkuti, Managing Director
Elérhetősége: info@challengerit.hu
- Web analytics, email and document management, calendar, phone contacts, spreadsheet synchronisation, targeted advertising
display:
Name: Google LLC
Location: 1 Hacker Way, Menlo Park, California 94025
Representative: N/A
Contact details: N/A
Website: https://www.google.com/
- Targeted advertising display:
Name: Facebook Inc.
Location: 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
Contact: +1 650-543-4800
Website: https://www.facebook.com/
- Card registration:
Netlient Information Technology Services Limited Liability Company
Registered office: 2600 Vác, Háló köz 3.
E-mail address: info@ugyfelkartya.hu
Representative: managing director András Szilágyi
- Meeting tax and accounting obligations:
Name: Öt Agent Ltd.
Head office: 1037 Budapest, Szépvölgyi út 23.
Representative: Kristóf Palotai
Contact: + 36 30 634 9424
e-mail address: penzugy@wasabi.hu
. Send newsletter, e-mail contact and online reservations:
-MailerLite UAB
Address: 46 Paupio g., Vilnius, LT-11341, Lithuania
-The Rocket Science Group LLC (Mailchimp)
Location: 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA
- Online reservation (Tablein)
Name: UAB Internet Marketing Solutions
Address: 62 K. Donelaičio g., Kaunas, Lithuania
Company code: 301840551
Website: https://www.tablein.com/
10.2 If the processing is carried out by another party on behalf of the Data Controller, the Data Controller shall only use such processors,
who provide adequate safeguards to ensure compliance with the legal requirements for data processing and to protect the data subjects
implement appropriate technical and organisational measures to ensure the protection of their rights.
10.3 In the event of a transfer to a third country, the transfer must be subject to appropriate safeguards, in particular the European
The general terms and conditions of contract adopted by the Commission shall apply.
10.4. The Data Controllers reserve the right to use an additional processor after informing the data subjects in advance.
which may be done by amending this Privacy Notice accordingly and posting it on the Website
is.
11. Security of data processing.
11.1 As the Data Controller, we will take all technical and organisational measures to ensure an adequate level of data security.
we can guarantee to you, in particular against unauthorised access to or alteration of your personal data,
11
transmission, disclosure, deletion or destruction, accidental destruction or damage, and the
against inaccessibility due to changes in the technology used.
11.2 Together with our data processors, we will take steps to ensure that you are able to.
persons acting on our behalf who have access to your data may process your data only in accordance with the instructions of the Data Controllers.
data, unless they are required to do otherwise by law.
We use appropriate firewall and password-protected data networks, but please note that
Internet data transmission cannot be perfectly secure or error-free. Passwords, identifiers or other special
access methods, unless the damage is caused by unlawful processing of the data subject's data by the Data Controllers or
were caused by a breach of data security requirements.
11.3 To protect paper records, we will take the necessary measures, in particular to protect the physical
safety and fire protection.
The data carriers we use or hold that contain personal data, regardless of the type of data
how it is recorded, securely stored and protected against unauthorised access, alteration or disclosure,
disclosure, deletion or destruction, and against accidental destruction or damage.
12. Your rights.
You have the right to request from the Data Controller access to and rectification of your personal data,
erasure or restriction of the processing of personal data and to object to the processing of such personal data, and the data subject has the right to
to data portability and to withdraw consent at any time.
12.1. Right to information
We provide you with this Privacy Notice to provide you with prior and adequate information about our data processing.
about our activities before giving your voluntary consent.
12.2. Data subject's right of access
You have the right to receive feedback on whether the Data Controllers are processing your personal data.
At your request, we will provide information on:
- the data we process, the categories of personal data concerned and their source,
- the purposes and legal basis of the processing,
- the duration of the processing, the storage period of personal data,
- your right to ask us to correct, delete or obtain the deletion of personal data relating to you
restriction of the processing of personal data and may object to the processing of such personal data by lodging a complaint with the supervisory authority
the right to submit,
- the data processed by the data processors used, their source, the purposes and legal basis of the processing and the
the duration of data processing,
- the name and address of the data processor and his or her activities in relation to the processing,
- the circumstances of any data breaches, their effects and the measures taken to deal with them,
- the legal basis and the recipient of the transfer.
We will respond to your request within a maximum of 1 month, in accordance with the relevant provisions of the GDPR. If your
we refuse to provide the information, we will give you the reasons for our refusal in writing within 1 month and we will inform you
which supervisory authority you can lodge a complaint with, and your right to a judicial remedy. If your
your request is clearly unfounded or excessive, we may refuse to provide the information or charge an administrative fee
for providing the information.
12.3. The data subject's right to rectification:
You may request the Data Controller to correct inaccurate data and to complete incomplete data. On
Data controllers will take action without undue delay after receiving your request.
12.4. The data subject's right to erasure ("right to be forgotten"):
You have the right to obtain, at your request and without undue delay, the erasure of your personal data held by the Data Controllers.
data.
12.5. The data subject's right to restriction of processing:
You have the right to obtain, at your request, the restriction of processing by the Data Controller, in particular in the following cases:
- if you dispute the accuracy of your data, for as long as it takes us to verify it,
- the processing is unlawful and you request restriction of use of the data instead of erasure,
- we no longer need the personal data for the purposes of processing, but you require them for legal claims,
enforce or protect,
- if you object to the processing, for the period until it is established that the Controller.
whether the legitimate interests of the data subject prevail over the legitimate interests of the data subject.
12.6. Data subject's right to data portability:
You may request that the personal data you provide us with is structured, widely used, machine-readable
to you and/or transferred to another controller.
12.7. Right to object
You may object to the processing of your personal data (i) if the processing of your personal data is solely necessary to comply with a legal obligation to which we are subject
necessary for the performance of our obligations or the pursuit of our legitimate interests; (ii) where the purpose of the processing is direct marketing,
public opinion polling or scientific research; or (iii) where the processing is necessary for the performance of a task carried out in the public interest
sort.
12
We will examine the legitimacy of the objection within 15 days and, if we find that the objection is justified, we will stop the processing.
terminate and block the personal data processed, and of the objection and the action taken in response to it
we will notify all those to whom the personal data to which the objection relates have previously been disclosed. If the
disagrees with a decision we have made, you may appeal against it to the courts within 30 days of the date of notification.
12.8. Objection by the data subject in the event of direct marketing
If your personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for
the processing of personal data relating to them for such purposes, including profiling, where it is necessary for the direct
is linked to business acquisition. If you object to the processing of your personal data for direct marketing purposes,
the personal data may no longer be processed for that purpose.
12.9 Automated decision-making in individual cases, including profiling, you have the right not to be subject to the
the scope of a decision based solely on automated processing, including profiling, which is specific to you
would have legal effects or similarly significantly affect you.
The preceding paragraph shall not apply in the case where the decision:
- necessary for the conclusion or performance of a contract between us;
- is permitted by EU or Member State law applicable to the controller which protects your rights and freedoms and
also lays down appropriate measures to protect your freedoms and legitimate interests; or
- is based on your explicit consent.
Please make any request to exercise your rights under this Privacy Notice to the following address.
contact details:
- by post: by registered letter with acknowledgement of receipt sent to the registered office of the Data Controllers,
- electronically: by sending an e-mail to wsbzrt@wasabi.hu.
13. Remedies.
13.1 Please contact the Data Controllers in the first instance with any complaint and we will be happy to assist you in
at the following contact details:
- by post: by letter sent to the Data Controllers' headquarters,
- electronically: by sending an e-mail to wsbzrt@wasabi.hu.
13.2 Right to apply to the courts:
You can take the Data Controllers to court if your rights are infringed. The court will rule on the case out of turn. The lawsuit
is a matter for the courts. You can choose to bring the case in the court of your domicile or residence.
can also be brought before a court.
13.3 Data protection authority procedure:
In the event of a violation of your rights, you have the right to lodge a complaint with the National Authority for Data Protection and Freedom of Information at the following address
contact details below:
Name: National Authority for Data Protection and Freedom of Information
Head office: 1125 Budapest, Szilágyi Erzsébet fasor 22/C.
Address for correspondence: 1530 Budapest, Pf.: 5.
Phone: +36 1/391-1400
Fax: +36 1/391-1410
E-mail: ugyfelszolgalat@naih.hu
Website: http://www.naih.hu
14. Scope of the Privacy Notice, applicable law
14.1 The scope of this Privacy Notice covers the processing of your data on the Website and the processing of data when you use the
You contact or ask questions to any of the Data Controllers through the Website or otherwise, including by.
Services available on a website or through a website operated by the Data Controllers
the processing necessary to use the services.
The effective date of this Privacy Notice is 1 October 2025.
apply to all concerned from the date of entry into force.
14.2. The Data Controllers reserve the right to amend the Privacy Policy and the use of the Website
from time to time, unilaterally and without prior notice. Data Controllers shall ensure that.
the current Privacy Notice is permanently available on the Website.
14.3. By accepting this Privacy Notice, each data subject acknowledges that his or her personal data
shall be governed by the provisions of the Privacy Notice in force on the date of processing.
14.4 In providing their services and processing personal data, the Data Controllers shall in particular comply with the following legislation
is considered to be authoritative:
- General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016
- Act V of 2013 - on the Civil Code (Civil Code)
- Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information (Infotv.)
- Act XLVIII of 2008 on the Basic Conditions and Certain Restrictions of Economic Advertising (Act XLVIII of 2008)
- Act CVIII of 2001 on electronic commerce services and information society services
on certain issues of services (Elkertv.).
13
-------- O --------
