Privacy policy

1. PURPOSE OF THE PRIVACY POLICY

Lelkes Mónika Rita, sole proprietor (registered address: 1188 Budapest, Rákóczi u. 59/1, Hungary) hereinafter referred to as the “Data Controller”, acknowledges the contents of this legal notice as binding.

The Data Controller undertakes that all data processing activities related to its operations comply with this Policy, applicable national legislation, and the legal acts of the European Union.

This Privacy Policy applies to all traditional offline and online activities of the business, as well as to the following domains and their subdomains:

• www.marrymehungary.hu; www.marrymehungary.com
• www.marrymebudapest.hu; www.marrymebudapest.com
• www.proposalbudapesthungary.hu; www.proposalbudapesthungary.com

The Data Controller’s data protection principles are continuously available on the privacy policy subpages of the above websites.

The Data Controller reserves the right to amend this Policy without prior notice. Data subjects will be informed of any changes.

If you have any questions regarding this notice, please contact us and we will respond. Contact details are available in the section titled “Data Controller Details.”

The Data Controller is committed to protecting the personal data of its clients and partners and places special importance on respecting their right to informational self-determination. Personal data is treated confidentially, and all necessary technical, security, and organizational measures are taken to ensure data protection.

Below, the Data Controller presents its data processing practices.

2. DATA CONTROLLER DETAILS

If you wish to contact the business, you may reach the Data Controller using the following email addresses and phone numbers:

Name: Lelkes Mónika Rita (Sole Proprietor)
Registered office: H-1188 Budapest, Rákóczi u. 59/1, Hungary
Tax number: 67640421-1-43
EU VAT number: HU67640421
Registration number: 50536230
Phone: +36 30 535 5608; +36 20 213 4628 (WhatsApp)
Email: info@marrymehungary.hu; marrymehun2024@gmail.com; monika.lelkes@gmail.com
Contact person: Lelkes Mónika Rita

2.1 DATA PROTECTION OFFICER

The Data Controller has not appointed a Data Protection Officer, as this is not required by applicable law.

3. GENERAL DATA PROCESSING PRINCIPLES, PURPOSE, LEGAL BASIS, AND RETENTION PERIOD

The Data Controller’s data processing activities are based on voluntary consent and statutory authorization. In the case of data processing based on voluntary consent, data subjects may withdraw their consent at any stage of the processing.

In certain cases, the processing, storage, and transfer of specific categories of data are required by law. Clients will be informed separately in such cases.

Data providers are hereby informed that if they provide personal data relating to third parties, they are responsible for obtaining the consent of the data subject concerned.

The Data Controller’s data processing principles comply with applicable data protection legislation, in particular:

• Act CXII of 2011 on Informational Self-Determination and Freedom of Information (Infotv.)
• Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR)
• Act V of 2013 on the Civil Code
• Act C of 2000 on Accounting
• Act LIII of 2017 on the Prevention of Money Laundering and Terrorist Financing
• Act CCXXXVII of 2013 on Credit Institutions and Financial Enterprises

The Data Controller has prepared data maps, on the basis of which the scope of processed data, their purpose, legal basis, and retention period have been determined.

3.1 DATA RELATED TO QUOTATION REQUESTS / CONTRACT PREPARATION

Services may be ordered through the website. During the ordering process, the following personal data may be requested:

• Name (mandatory)
• Email address (mandatory)
• Phone number (optional, for call-back purposes)
• Event details (location, date, preferences)

In the case of certain services (e.g. personalized or custom-labeled products), additional personal data may be provided.

Purpose of data processing: The data are used for the fulfillment of the order.

Legal basis: Contractual agreement.

Retention period: Up to 2–3 years from the date of the quotation request; in the event of a contract, 8 years from the termination of the contract, in accordance with legal obligations.

3.2 DATA RELATED TO EVENT MANAGEMENT / SERVICE PERFORMANCE

The following personal data may be processed in connection with event organization and service provision:

• Name (mandatory)
• Email address (mandatory)
• Phone number (optional, for call-back purposes)
• Event details (location, date, preferences)

In the case of certain services (e.g. personalized or custom-labeled products), additional personal data may be provided.

Purpose of data processing: The data are used for the fulfillment of the order and the performance of the service.

Legal basis: Contractual agreement.

Retention period: Up to 2–3 years from the date of the quotation request; in the event of a contract, 8 years from the termination of the contract, in accordance with legal obligations.

3.3 DATA RELATED TO OFFLINE OR ONLINE ORDERS

Services may be ordered through the website or offline channels. During the ordering process, the following personal data may be requested:

• Name (mandatory)
• Email address (mandatory)
• Phone number (optional, for call-back purposes)

In the case of certain services (e.g. personalized or custom-labeled products), additional personal data may be provided.

Purpose of data processing: The data are used for the fulfillment of the order.

Legal basis: Contractual agreement.

Retention period: Up to 2–3 years from the date of the quotation request; in the event of a contract, 8 years from the termination of the contract, in accordance with legal obligations.

3.4 DATA RELATED TO OFFLINE OR ONLINE CUSTOMER SERVICE

The following personal data may be collected during communication and customer service:

• Name (mandatory)
• Email address (mandatory)
• Phone number (optional, for call-back purposes)

Purpose of data processing: The data are used for communication and for the fulfillment of orders.

Legal basis: Performance of a contract and legal obligation.

Retention period: For the duration of the business relationship or until a deletion request is submitted.

3.5 DATA RELATED TO TELEPHONE CUSTOMER SERVICE

The following personal data may be collected during telephone communication:

• Name (mandatory)
• Phone number (optional, for call-back purposes)

Purpose of data processing: The data are used for communication and for the fulfillment of orders.

Legal basis: Performance of a contract and legal obligation.

Retention period: For the duration of the business relationship or until a deletion request is submitted.

3.6 CUSTOMER CONTACT AND BILLING DATA

The following personal data and contact details of company executives and contact persons of clients may be stored:

• Name
• Company name (if available)
• Tax number (if available)
• Registered office or home address
• Business site or delivery address
• Email address
• Phone number

Purpose of data processing: The data are used for communication and maintaining contact.

Legal basis: Legitimate interest.

Retention period: For the duration of the business relationship or until a deletion request is submitted.

3.7 DATA RELATED TO INVOICING

The data controller concludes a contract with clients regarding the ordered services, during which the following data are stored:

• Name
• Email address
• Address

Purpose of data processing: Invoicing.

Legal basis: Legal obligation.

Retention period: 8 years in accordance with accounting regulations.

3.8 DATA RELATED TO MARKETING / REMARKETING

• Cookie identifiers
• Behavioral data
• Advertising identifiers

Remarketing is carried out only with consent.

According to the GDPR, in the case of direct marketing, the user may object at any time, and in such cases, marketing data processing must be terminated.

Legal basis: voluntary consent.

3.9 WARRANTY CLAIMS / AFTER-SALES SERVICE

If you initiate a warranty claim, the processing of personal data and the provision of such data are necessary for handling the claim.

Collected data:

• Name
• Email address
• Phone number
• Complaint details

Purpose of data processing: handling warranty claims.
Legal basis: performance of a contract and legal obligation.
Retention period: 5 years, in accordance with consumer protection legislation.

3.10 HANDLING OF CONSUMER PROTECTION COMPLAINTS

If you submit a consumer protection complaint, the processing of personal data and the provision of such data are necessary for handling the complaint.

Collected data:

• Name
• Email address
• Phone number
• Complaint details

Purpose of data processing: handling consumer protection complaints.
Legal basis: performance of a contract and legal obligation.
Retention period: in accordance with consumer protection law, current year + 5 years.

4. PURPOSE AND LEGAL BASIS OF DATA PROCESSING

Note: For AI marketing analysis, the legal basis of data processing is the consent of the data subject when analyzing for marketing purposes, whereas for analysis of anonymized or aggregated data, the legal basis is the legitimate interest of the data controller.

5. PHYSICAL STORAGE LOCATIONS OF DATA

Your personal data (i.e., data that can be linked to you personally) may be processed in the following ways:

• Automatically collected technical data: In connection with maintaining an internet connection, technical data related to the computer, browser, IP address, and visited pages you use are automatically generated in our computer system.
• Data provided by you: You may also provide your name, contact details, or other information if you wish to establish personal contact with us while using the website.

The technical data recorded during the operation of the system includes the data of the user’s computer automatically captured by the systems on the domains and subdomains listed in point 1 as a result of technical processes.

Automatically recorded data is logged by the system at login and logout without any separate statement or action from the data subject.

Except in cases required by law, this data cannot be linked to other personal user data. Access to this data is restricted exclusively to the domains and subdomains listed in point 1.

6. DATA TRANSFER, DATA PROCESSING, AND PERSONS WITH ACCESS TO DATA

As part of its business activities, the Data Controller uses the following data processors:

6.1. WEB HOSTING SERVICE

• Name: ProfiTárhely Kft.
• Address: H-9024 Győr, Déry T. utca 11. 2nd floor, 4., Hungary
• Phone: +36 20 254 0866
• Email: ugyfelszolgalat@profitarhely.hu
• Invoice Owner Name: ELIN.hu Kft.

6.2. INVOICING SYSTEM PROVIDER

• Name: Billzone Korlátolt Felelősségű Társaság
• Address: H-3580 Tiszaújváros, Margit sétány 23., Hungary
• Registration Number / Official ID: 05-09-037916
• VAT Registration Number: 32590500-2-05
• EU VAT Number: HU32590500

6.3. ACCOUNTING

• Name: Hum Attiláné e.v.
• Address: H-2510 Dorog, Bécsi út 54., Hungary
• Tax Number: 58512081-1-31
• Sole Proprietor Registry Number: 4692644

7. DATA TRANSFER TO THIRD COUNTRIES

During the use of the website – especially through the use of Meta Pixel, Google Ads, or Google Analytics – personal data may be transferred to third countries outside the European Union (e.g., the United States of America).

The legal basis for such data transfers is:

• the European Commission’s adequacy decision (EU–US Data Privacy Framework), or
• the standard contractual clauses (SCC) adopted by the European Commission, and
• supplementary technical and organizational measures.

8. RIGHTS OF THE DATA SUBJECT AND ENFORCEMENT OPTIONS

The data subject may request information about the processing of their personal data, and may request the correction, deletion, or withdrawal of their personal data – except in cases of mandatory data processing. They may also exercise their rights to data portability and objection in the manner indicated at the time of data collection, or via the contact details of the data controller provided above.

8.1. RIGHT TO INFORMATION

The data controller shall take appropriate measures to ensure that data subjects are provided with all information regarding the processing of personal data as required by Articles 13 and 14 of the GDPR, and with the information referred to in Articles 15–22 and 34 of the GDPR, in a concise, transparent, intelligible, and easily accessible form, clearly and in plain language.

8.2. RIGHT OF ACCESS BY THE DATA SUBJECT

The data subject has the right to obtain from the data controller confirmation as to whether personal data concerning them is being processed. If such processing is taking place, the data subject has the right to access their personal data and the following information:

• the purposes of the data processing;
• the categories of personal data concerned;
• the recipients or categories of recipients to whom the personal data has been or will be disclosed, including recipients in third countries or international organizations;
• the planned period for which the personal data will be stored;
• the right to rectification, erasure, or restriction of processing, and the right to object;
• the right to lodge a complaint with a supervisory authority;
• information on the data sources;
• the existence of automated decision-making, including profiling, and meaningful information about the logic involved and the significance and envisaged consequences of such processing for the data subject.

The data controller shall provide the requested information within one month of receiving the request.

8.3. RIGHT TO RECTIFICATION

The data subject has the right to request the correction of inaccurate personal data concerning them and to request the completion of incomplete data processed by the Data Controller.

8.4. RIGHT TO ERASURE (“RIGHT TO BE FORGOTTEN”)

The data subject has the right to request that the Data Controller erase their personal data without undue delay if any of the following grounds apply:

• the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
• the data subject withdraws the consent on which the processing is based, and there is no other legal basis for the processing;
• the data subject objects to the processing and there are no overriding legitimate grounds for the processing;
• the personal data have been unlawfully processed;
• the personal data must be erased to comply with a legal obligation under EU or Member State law to which the Data Controller is subject;
• the personal data were collected in relation to the offer of information society services to a child.

However, the right to erasure shall not apply if the processing is necessary:

• for exercising the right of freedom of expression and information;
• for compliance with a legal obligation to which the Data Controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority;
• for reasons of public health, archival purposes in the public interest, scientific or historical research, or statistical purposes;
• for the establishment, exercise, or defense of legal claims.

8.5. RIGHT TO RESTRICTION OF PROCESSING

The data subject has the right to request the restriction of processing if any of the following applies:

• the data subject contests the accuracy of the personal data; in this case, the restriction applies for the period enabling the verification of the accuracy of the personal data;
• the processing is unlawful and the data subject opposes the erasure of the data, requesting instead the restriction of their use;
• the Data Controller no longer needs the personal data for the purposes of processing, but the data subject requires them for the establishment, exercise, or defense of legal claims;
• the data subject has objected to the processing; in this case, the restriction applies until it is determined whether the legitimate grounds of the Data Controller override those of the data subject.

When processing is restricted, personal data may be processed only with the consent of the data subject, for the establishment, exercise, or defense of legal claims, to protect the rights of another natural or legal person, or for important reasons of the Union or a Member State, except for storage.

8.6. RIGHT TO DATA PORTABILITY

The data subject has the right to receive their personal data provided to the Data Controller in a structured, commonly used, and machine-readable format and to transmit those data to another Data Controller.

8.7. RIGHT TO OBJECT

The data subject has the right to object at any time, for reasons relating to their particular situation, to the processing of their personal data for tasks carried out in the public interest or in the exercise of official authority, or for processing necessary for the legitimate interests of the Data Controller or a third party, including profiling based on those provisions.
In the event of an objection, the Data Controller shall no longer process the personal data unless compelling legitimate grounds exist which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defense of legal claims.

8.8. AUTOMATED DECISION-MAKING, INCLUDING PROFILING

The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.

8.9. RIGHT TO WITHDRAW CONSENT

The data subject has the right to withdraw their consent at any time.

8.10. RIGHT TO JUDICIAL REMEDY

In case of violation of their rights, the data subject may turn to the courts against the Data Controller. The court shall act without delay.
Complaints regarding data protection may also be filed with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH):

National Authority for Data Protection and Freedom of Information (NAIH)
Address: H-1055 Budapest, Falk Miksa utca 9–11., Hungary
Mailing address: H-1363 Budapest, Pf.: 9., Hungary
Email: ugyfelszolgalat@naih.hu
Phone: +36 1 391 1400
Web: www.naih.hu

9. AUTOMATED DECISION-MAKING, AI, AND PROFILING

The Data Controller may apply:

• AI marketing optimization
• Automated quotation system
• Chatbot communication
• Marketing profiling

Under the EU GDPR:

• In certain cases, the data subject has the right to request human intervention;
• The data subject must be informed about the automated logic used;
• The data subject has the right to object to profiling.

If an automated decision significantly affects the data subject, additional safeguards are required.
The automated quotation system does not result in solely automated decisions with legal effects; all quotations are finalized with human review.

10. MARKETING AND NEWSLETTER

The Data Controller sends marketing messages only:

• With prior consent, and
• With an option to unsubscribe.

Under GDPR, the data subject has an absolute right to object to marketing-related data processing.

11. SYSTEMS USED AND DATA PROCESSORS

Marry Me Hungary may use the following systems:

• Meta Pixel (Facebook, Instagram)
• TikTok Pixel
• Google Ads
• CRM system
• Chatbot service provider
• AI marketing tools
• Newsletter service provider

During the operation of the above systems, the Data Controller applies the respective service providers’ data processing terms and ensures GDPR compliance through data processing agreements.

12. DATA RETENTION PERIODS

13. CATEGORIES OF PERSONAL DATA PROCESSED

13.1. TECHNICAL DATA

The Data Controller selects and operates IT tools used in providing the service so that the processed data:

• Is accessible only to authorized persons (availability);
• Its authenticity and validation are ensured (data authenticity);
• Its immutability can be verified (data integrity);
• Is protected against unauthorized access (data confidentiality).

The Data Controller protects data with appropriate measures against unauthorized access, alteration, transmission, disclosure, deletion or destruction, as well as accidental loss.

The Data Controller applies technical, organizational, and administrative measures to ensure a level of protection appropriate to the risks associated with data processing.

During data processing, the Data Controller maintains:

• Confidentiality: only authorized persons can access the information;
• Integrity: the accuracy and completeness of the information and processing methods are ensured;
• Availability: authorized users can access the information when needed, and the necessary tools are available to facilitate access

14. COOKIES

14.1. PURPOSE IF COOKIES

A cookie is a small data file that is placed on the user’s device (computer, mobile phone, tablet) when visiting the website. Its purpose is to ensure the proper functioning of the website, enhance the user experience, support statistical analysis, and assist marketing and remarketing activities.

Cookies collect information about visitors and their devices; they remember individual user settings, which may be used, for example, when using online transactions, so users do not have to re-enter information. Cookies facilitate website use, provide a high-quality user experience, and contribute to the collection of certain visitor statistics.

To enable personalized service, a small data package, called a cookie, is placed on the user’s computer, phone, or tablet, and is read back during subsequent visits. When the browser sends back a previously stored cookie, the cookie-managing service can associate the current visit with previous visits, but only regarding its own content.

Some cookies do not contain personally identifiable information, while others include a secret, randomly generated number stored on the user’s device to ensure user identification.

14.2. LEGAL BASIS FOR USING COOKIES

• Necessary cookies: legitimate interest
• Statistical, marketing, and remarketing cookies: the user’s prior, voluntary consent

Marketing cookies are activated only if the user explicitly consents to them via the cookie banner.

14.3. TECHNICALLY NECESSARY (FUNCTIONAL) COOKIES

These cookies are essential for the proper functioning of the website and cannot be disabled.

Purpose examples:

• Ensuring the basic functions of the website
• Proper functioning of forms
• Security functions

Legal basis: legitimate interest

These cookies ensure that visitors can browse the marrymehungary.hu website fully and smoothly, use its functions, and access the services provided.

Duration: These cookies are valid for the duration of the session (until the browser is closed). Once the browser is closed, this type of cookie is automatically deleted from the computer or other device used for browsing.

14.4. STATISTICAL (ANALYTICAL) COOKIES

These cookies collect anonymous statistical data about the use of the website.

Used systems:

• Google Analytics (Google Tags)
• Google Search Console (cookies used only if technically necessary)
• Google SEO tools
• AI-based search engine optimization (AI SEO) systems

Collected data may include:

• Number of visits
• Pages viewed
• Browser type
• Device type

Legal basis: consent

The marrymehungary.hu website and its subdomains use Google Analytics third-party cookies. By using Google Analytics for statistical purposes, marrymehungary.hu and its subdomains collect information about how visitors use the websites. The data is used to improve the website and enhance the user experience.

These cookies remain on the visitor’s computer or device and in their browser until their expiration, or until the visitor deletes them.

14.5. MARKETING AND REMARKETING COOKIES

These cookies allow the Data Controller to display targeted advertisements to users across various platforms.

Used systems and platforms:

• Meta Pixel (Facebook, Instagram)
• TikTok Pixel
• Google Ads
• Google remarketing systems
• Meta advertising systems
• TikTok advertising systems
• AI-based marketing and remarketing tools

Purpose:

• Display personalized advertisements
• Measure the effectiveness of campaigns
• Create remarketing lists

Marketing and remarketing cookies are used only with the prior, voluntary consent of the data subject. Their purpose is to improve the user experience and display personalized advertisements. Data processing is carried out by external providers (Meta, Google, TikTok). Consent can be withdrawn at any time in the website’s cookie settings.

14.6. SOCIAL MEDIA COOKIES

The website may contain social media integrations that place cookies.

Affected platforms:

• Facebook
• Instagram
• TikTok

These cookies allow content sharing and measuring social media campaign performance.

Legal basis: consent

14.7. THIRD-PATRY COOKIES

Cookies placed by third parties (e.g., Google, Meta, TikTok) may also appear on the website.

The management of these cookies is governed by the respective provider’s privacy policy.

14.8. MANAGING AND WITHDRAWING COOKIES

Users can:

• Modify or withdraw their consent at any time via the cookie banner,
• Delete cookies in their browser settings.

Withdrawing consent does not affect the lawfulness of data processing prior to withdrawal.

The legal basis for strictly necessary cookies is the Data Controller’s legitimate interest. The legal basis for statistical and marketing cookies is the prior consent of the data subject.

If the user does not accept the use of cookies, certain website features listed in sections 14.4  may not be available, or some functions may not work correctly.

For more information about deleting cookies in common browsers, please refer to the HELP section of your browser software.

14.9. RELATIONSHIP BETWEEN COOKIE POLICY AND PRIVACY POLICY

The detailed rules for data processing related to the use of cookies are contained in the Privacy Policy, which is available on the website.

14.10. MODIFICATION OF THE COOKIE POLICY

The Data Controller reserves the right to modify the Cookie Policy. Changes take effect upon publication on the website.

14.11. COOKIE BANNER TEXT (POPUP)

The website uses cookies for functionality, statistics, and marketing purposes.

Marketing and remarketing cookies are only applied based on the user’s prior, explicit consent.

Buttons:

• Accept
• Settings
• Reject

In the “Settings” menu, users can manage the use of statistical and marketing cookies in detail.

15. REQUEST FORM CHECKBOX TEXT

15.1. GDPR Checkbox (Mandatory)
“I have read and accept the Privacy Policy.”

15.2. Marketing Checkbox (Optional)
“I consent to marketing and remarketing communications.”

15.3. Chatbot + AI Special Addendum
The website may use chatbot and AI-based marketing automation.
AI systems may generate recommendations based on behavioral data.

16. OTHER PROVISIONS

For any data processing not listed in this Privacy Policy, information will be provided at the time of data collection.

Clients are informed that courts, prosecutors, investigative authorities, law enforcement agencies, administrative authorities, the National Authority for Data Protection and Freedom of Information (NAIH), the Hungarian National Bank, or other bodies authorized by law may request information, disclosure, or access to documents from the Data Controller. The Data Controller will provide personal data to authorities only to the extent necessary and only for the purpose specified in the request.

This Privacy Policy has been prepared in accordance with applicable laws.