This Privacy Policy contains information on the data processing practices carried out by Trinspire Informatikai Szolgáltató és Tanácsadó Kft. (registered office: 1138 Budapest, Madarász Viktor u. 47-49., hereinafter referred to as “Masterfield”), acting as the data controller, and provides information on the rights of data subjects in relation to such processing activities.

Masterfield is committed to protecting the personal data of its partners and website visitors and considers the protection of its clients’ right to informational self-determination and privacy to be of paramount importance.

This Privacy Policy applies to all data processing activities carried out through the Masterfield website (http://masterfieldqa.hu) as well as to all non-online data processing activities conducted by Masterfield.

Masterfield reserves the right to amend this Privacy Policy at any time and will notify data subjects of any changes through its websites.

DEFINITIONS

A jelen Adatkezelési Szabályzatban használt fogalmak az alábbiak:

  1. data subject: any identified or identifiable natural person who can be identified, directly or indirectly, on the basis of personal data;
  2. personal data: any information relating to a data subject, in particular the data subject’s name, identification number, or one or more factors specific to their physical, physiological, mental, economic, cultural, or social identity, as well as any conclusion drawn from such information concerning the data subject;
  3. special categories of personal data:
  • personal data revealing racial or ethnic origin, political opinions or political affiliation, religious or other philosophical beliefs, trade union membership, or an individual’s sex life;
  • personal data concerning health status, pathological addictions, as well as criminal personal data;
  1. consent: any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which the data subject signifies agreement to the processing of personal data relating to them, either in its entirety or with respect to specific processing operations;
  2. objection: a statement by the data subject objecting to the processing of their personal data and requesting the termination of such processing and/or the deletion of the processed data;
  3. data controller: the natural or legal person, or organisation without legal personality, which alone or jointly with others determines the purposes of the processing of personal data, makes and implements decisions regarding the processing (including the means used), or has such processing carried out by a data processor on its behalf;
  4. processing: any operation or set of operations performed on personal data, regardless of the procedure used, including in particular collection, recording, organisation, storage, alteration, use, retrieval, transmission, disclosure, alignment or combination, restriction, erasure, and destruction, as well as the prevention of further use of the data; the taking of photographs, audio or video recordings; and the recording of physical characteristics suitable for identification of a person (e.g. fingerprints, palm prints, DNA samples, iris scans);
  5. data transfer: making data accessible to a specified third party;
  6. disclosure: making data accessible to anyone;
  7. erasure: rendering data permanently unrecognisable in such a way that its restoration is no longer possible;
  8. data marking: assigning an identifying label to data for the purpose of distinguishing it;
  9. restriction of processing (data blocking): assigning an identifying label to data for the purpose of restricting its further processing permanently or for a specified period;
  10. data destruction: the complete physical destruction of the data carrier containing the data;
  11. data processing (processor activities): the performance of technical tasks related to data processing operations, irrespective of the method, tools, or location used for carrying out such operations, provided that the technical task is performed on the data;
  12. data processor: a natural or legal person, or organisation without legal personality, that processes data on the basis of a contract, including a contract concluded pursuant to legal requirements;
  13. third country: any state that is not a member of the European Economic Area (EEA);
  14. Info Act (Infotv.): Act CXII of 2011 on the Right of Informational Self-Determination and Freedom of Information.

DATA CONTROLLER INFORMATION AND CONTACT DETAILS

Name: Trinspire Informatikai Szolgáltató és Tanácsadó Kft.

Registered Office: Building 1, 5th Floor, Madarász Office Park, 47–49 Madarász Viktor Street, Budapest 1138, Hungary

Email: info@masterfield.hu

Telephone: +36 1 288 0177

Data Protection Registration Number: NAIH-145990/2018

Data Protection Officer: Dániel Pehártz

Contact Details: pehartz.daniel@masterfield.hu

NEWSLETTER MODULE OPERATED BY

Name: SalesAutopilot Kft.

Registered Office: 1016 Budapest, Zsolt utca 6/A, 5th Floor, Door 1, Hungary

Postal Address: SalesAutopilot Kft., P.O. Box 515, 1538 Budapest, Hungary.

PRINCIPLES OF DATA PROCESSING AND DATA SECURITY

Personal data may only be processed for specified purposes, for the exercise of rights and the fulfilment of legal obligations. The purpose of data processing, as well as the collection and processing of personal data, must be fair and lawful. Only personal data that is essential for achieving the purpose of the processing and suitable for accomplishing that purpose may be processed. Personal data may only be processed to the extent and for the duration necessary to achieve the intended purpose. During processing, the accuracy, completeness, and, where necessary for the purpose of the processing, the currency of the data must be ensured, as well as the ability to identify the data subject only for as long as necessary to achieve the purpose of the processing. The data subject is responsible for the truthfulness, authenticity, and accuracy of the data provided.

Masterfield designs and carries out its data processing activities in a manner that ensures the protection of the privacy of data subjects throughout the processing operations. Masterfield, and where a data processor is engaged, the data processor within the scope of its activities, shall ensure the security of personal data and shall implement the technical and organisational measures and establish procedural rules necessary to comply with the Info Act and other applicable data protection and confidentiality regulations.

Masterfield implements appropriate measures to protect personal data, in particular against unauthorised access, alteration, transmission, disclosure, deletion or destruction, as well as against accidental destruction, damage, and loss of accessibility resulting from changes in the technology used.

Where Masterfield engages another organisation (a data processor) to carry out data processing activities, it shall inform the data subject of the fact of such engagement and the identity of the data processor before obtaining consent for the relevant processing activity. The data processor may perform only technical tasks related to data processing operations and is not authorised to make substantive decisions regarding the processing. The data processor may process personal data solely in accordance with Masterfield’s instructions, may not process such data for its own purposes, and shall store and retain personal data exclusively in accordance with Masterfield’s instructions.

During data processing and data handling activities, personal data may only be accessed by Masterfield, and where a data processor is engaged, by the data processor, as well as by those employees of Masterfield and the data processor who participate in achieving the data processing purposes specified in this Privacy Policy. Such individuals are bound by confidentiality obligations under their employment contracts and applicable legal requirements and may not disclose, use, make accessible to third parties, or otherwise publish any personal data that comes to their knowledge.

LEGAL BASIS AND PURPOSE OF DATA PROCESSING

Personal data may be processed either on the basis of the data subject’s consent or, where prescribed by law or a local government decree, on the basis of a legal obligation (mandatory data processing).

Prior to commencing any data processing activity, Masterfield shall inform the data subject whether the processing is based on consent or is mandatory under applicable law. Before the processing begins, Masterfield shall provide information regarding the categories of personal data processed, the purpose and legal basis of the processing, the persons authorised to perform data processing and data handling activities, and the duration of the processing. Information regarding the rights of the data subject and the available legal remedies is set out in this Privacy Policy.

Masterfield processes personal data for the following purposes:

  • identification of the data subject, differentiation from other data subjects, and maintaining contact with the data subject;
  • preparation of statistics and analyses;
  • complaint handling;
  • marketing activities;
  • fulfilment of other record-keeping obligations;
  • compliance with data processing and data disclosure obligations prescribed by law.

Where Masterfield does not process the data subject’s personal data on the basis of a legal obligation, such processing shall always be carried out on the basis of the data subject’s consent pursuant to Section 5 (1) of the Info Act. Submission of an application for a training course shall constitute the data subject’s consent to the processing of the data provided on the application form.

STORAGE OF WEBSITE VISITOR DATA

During visits to Masterfield’s websites, Masterfield is entitled to record visitors’ IP addresses, the date and time of the visit, and the addresses of the pages viewed for technical purposes and for the preparation of statistics relating to user behaviour. By using the website, visitors consent to the collection of such anonymised data.

USE OF COOKIES

European Union legislation requires organisations that place cookies on visitors’ devices through their websites to provide clear and comprehensive information about the use of cookies and to obtain visitors’ consent where required.

HOW CONSENT IS OBTAINED ON THIS WEBSITE

The legal framework governing consent for the use of cookies and other similar technologies used to track user activity (such as tracking pixels and website scripts, hereinafter collectively referred to as “Cookies”) is still evolving within the European Union. Although obtaining prior consent (“opt-in” method) is generally considered the most legally robust approach, it may negatively affect the user experience and the legitimate collection of website analytics data. Nevertheless, it remains the most widely accepted method of obtaining consent.

USE OF COOKIES

The cookies placed by this website are used solely for statistical purposes and to display relevant offers to users. These cookies store only the fact and time of a visit to the website and do not collect any other information.

The cookies transmitted in this way are used as follows: third-party service providers, including Google, use these cookies to recognise whether a user has previously visited the advertiser’s website and, based on this information, display advertisements to the user on the websites of the partners of such third-party providers, including Google.

Users may disable Google’s use of cookies through Google’s Ads Settings page.

Users may also opt out of cookies used by other third-party service providers at: http://www.networkadvertising.org/choices/.

Statistical information obtained through cookies is used to improve the operation of the website and to support developments aimed at enhancing the user experience. This website contains links and references to other websites. Please note that Masterfield has no control over the cookies and tracking technologies used by third-party websites, and this Privacy Policy does not apply to such websites.

If you have any questions, comments, or concerns regarding this Cookie Policy or the data collection practices of this website, please contact us at: info@masterfield.hu.

RIGHTS OF DATA SUBJECTS AND THEIR ENFORCEMENT

A data subject may request that Masterfield:

  • provide information regarding the processing of their personal data;
  • rectify their personal data; and
  • erase or restrict the processing of their personal data, except where processing is mandatory under applicable law.

Downloadable request forms:

  • Request for information regarding the processing of personal data
  • Request for rectification of personal data
  • Request for erasure of personal data

REQUESTING INFORMATION REGARDING THE PROCESSING OF PERSONAL DATA

The data subject may request information from Masterfield concerning the personal data processed about them, the source of such data, the purpose, legal basis, and duration of the processing, as well as, where personal data has been transferred, the legal basis and recipients of the transfer.

Masterfield shall provide the requested information in writing as soon as possible, but no later than 30 days from receipt of the request. The provision of information is free of charge if the requesting data subject has not submitted a request relating to the same category of data during the same calendar year. In all other cases, the data subject shall pay an administrative fee of HUF 2,000 per request.

RECTIFICATION OF PERSONAL DATA

Masterfield shall rectify personal data if the data is inaccurate and the correct personal data is available to Masterfield.

ERASURE OF PERSONAL DATA

Personal data shall be erased if:

  • the processing is unlawful;
  • the data subject so requests (except where processing is mandatory by law);
  • the data is incomplete or inaccurate and the deficiency or inaccuracy cannot be lawfully remedied, provided that erasure is not excluded by law;
  • the purpose of the processing has ceased to exist, or the statutory retention period has expired;
  • erasure has been ordered by a court or by the Hungarian National Authority for Data Protection and Freedom of Information (NAIH).

RESTRICTION OF PERSONAL DATA

Instead of erasure, Masterfield shall restrict the processing of personal data if:

  • the data subject so requests; or
  • based on the information available, it may reasonably be assumed that erasure would prejudice the legitimate interests of the data subject.

Personal data subject to such restriction may only be processed for as long as the purpose preventing its erasure continues to exist.

MARKING OF PERSONAL DATA

Personal data may be marked where the data subject disputes the accuracy or correctness of the personal data processed by Masterfield, but the inaccuracy or incorrectness of the disputed data cannot be definitively established.

Masterfield shall notify the data subject, as well as all parties to whom the data was previously disclosed for processing purposes, of any rectification, restriction, marking, or erasure. Notification may be omitted where, in view of the purpose of the processing, such omission does not prejudice the legitimate interests of the data subject.

If Masterfield rejects a request for rectification, restriction, or erasure, it shall provide the factual and legal grounds for the rejection in writing within 30 days of receipt of the request.

OBJECTION TO THE PROCESSING OF PERSONAL DATA

The data subject may object to the processing of their personal data where:

  • the processing is necessary solely for compliance with a legal obligation applicable to the data controller or for the purposes of the legitimate interests pursued by the data controller (except where processing is mandatory by law);
  • the personal data is used for direct marketing, public opinion surveys, or scientific research purposes; or
  • in any other cases provided by law.

Masterfield shall examine the objection and make a decision regarding its validity as soon as possible, but no later than 15 days from receipt of the request, and shall inform the applicant of its decision in writing. If Masterfield determines that the objection is justified, it shall terminate the processing, restrict the data, and notify all recipients to whom the affected personal data was previously disclosed and who are required to take measures to enforce the right of objection.

Masterfield shall be liable for any damage caused by the unlawful processing of personal data or by failure to comply with data security requirements. The data subject may also claim compensation for non-material damage if Masterfield infringes the data subject’s personality rights through unlawful processing or by violating data security requirements.

Masterfield shall be exempt from liability for damages and from the obligation to pay compensation for non-material damage if it proves that the damage or infringement of personality rights was caused by an unavoidable event outside the scope of the processing activity. No compensation shall be payable to the extent that the damage or infringement resulted from the intentional or grossly negligent conduct of the injured party.

LEGAL REMEDIES

The data subject may initiate legal proceedings against Masterfield if their rights relating to the processing of personal data have been violated. The data subject may also bring an action before the courts within 30 days from the communication of the decision, or from the last day of the applicable deadline, if they disagree with Masterfield’s decision regarding an objection to data processing.

The courts shall hear such cases with priority. Jurisdiction lies with the competent regional court (Törvényszék). At the data subject’s choice, proceedings may also be initiated before the regional court having jurisdiction over their place of residence or habitual residence.

Where a data subject believes that their rights relating to the processing of personal data have been infringed, they may lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH):

Registered Office: 1055 Budapest, Falk Miksa utca 9–11, Hungary

Postal Address: H-1363 Budapest, P.O. Box 9, Hungary

Telephone: +36 1 391 1400

Fax: +36 1 391 1410

Email: ugyfelszolgalat@naih.hu

FINAL PROVISIONS

In matters not regulated by this Privacy Policy, the provisions of Hungarian law shall apply, with the exception of the rules of private international law.

Budapest, 29 May 2026

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