Privacy Policy and Legal Notice

1. Data Controller Information

Data Controller: Sugallat Ltd.

Registered office: 2461 Tárnok, Ősz u. 12.

Company registration number: 13-09-105169

Tax number: 13582920-2-13

Phone: +36-23-333-853

Email: benko@sugallat.hu

Website: sugallat.hu

2. Purpose and Legal Basis of Data Processing

Sugallat Ltd. processes your personal data for the following purposes:

2.1 Contact Form

Purpose: Contact, preparation of quotations, customer service

Legal basis: Your voluntary consent (Article 6(1)(a) of the GDPR)

Data processed: name, email address, phone number, company name, message content

2.2 Website Usage

Purpose: Website operation, statistics, marketing

Legal basis: Your consent (cookie banner)

Tools: Google Analytics, Facebook Pixel (currently inactive)

3. Duration of Data Processing

3.1 Contact Data

Data provided through the contact form is stored for 2 years from the date of contact. This enables us to retrieve previous communications and provide continuous customer service.

3.2 Website Usage Data

Website usage data is not stored by us. It is collected and stored by Google Analytics (Google LLC) and Facebook Pixel (Meta Platforms Inc.) in accordance with their respective privacy policies:

• Google Analytics: 26 months (as per Google's privacy policy)
• Facebook Pixel (currently inactive): 180 days (as per Meta's privacy policy)

4. Data Recipients and Data Sharing

Your personal data is NOT stored or shared with third parties, except in cases necessary for the purpose of contact:

4.1 Contact Data

Data provided through the contact form is stored and used solely for the purpose of communication and correspondence. This data:

• Is NOT transferred to third parties for marketing or other purposes
• Is NOT sold or NOT rented out
• Is used for internal purposes only (quotation preparation, project work, customer service)

4.2 Exceptions (Mandatory Data Transfer)

Your personal data will only be transferred in the following cases:

• Legal obligation: upon request from authorities or by court order
• Technical service providers: Google (Analytics), Facebook (Pixel, currently inactive) - pseudonymised web analytics and marketing data

4.3 Website Usage Data

Data collected by Google Analytics and (where active) Facebook Pixel constitutes pseudonymised personal data within the meaning of the EU General Data Protection Regulation (GDPR). This may include: client identifiers (client ID), IP address (anonymised), device characteristics, browsing behaviour, and (where Google Signals is enabled) demographic and interest data of users signed in to their Google account.

5. Your Rights

Under the GDPR, you have the following rights:

5.1 Right of Access

You have the right to request information on whether we process your personal data, and if so, what data is processed.

5.2 Right to Rectification

You may request the rectification or completion of inaccurate personal data.

5.3 Right to Erasure ("Right to Be Forgotten")

In certain cases, you may request the deletion of your personal data.

5.4 Right to Restriction of Processing

In certain cases, you may request the restriction of the processing of your data.

5.5 Right to Data Portability

You may request to receive your personal data in a structured, commonly used format.

5.6 Right to Object

You may object to the processing of your personal data.

5.7 Withdrawal of Consent

You may withdraw your consent to data processing at any time. The withdrawal does not affect the lawfulness of data processing carried out on the basis of consent prior to its withdrawal.

6. Legal Enforcement

For questions or requests regarding data protection, please contact us:

Email: benko@sugallat.hu

Phone: +36-23-333-853

Postal address: 2461 Tárnok, Ősz u. 12.

Response deadline: 30 days

If you believe that your data protection rights have been violated, you may file a complaint with the National Authority for Data Protection and Freedom of Information (NAIH):

NAIH: 1055 Budapest, Falk Miksa utca 9-11.

Phone: +36-1-391-1400

Email: ugyfelszolgalat@naih.hu

Website: www.naih.hu

7. Data Security

We implement appropriate technical and organisational measures to protect your personal data:

• SSL encryption between the website and the server
• Regular backups
• Access restriction (only authorised personnel may access data)
• Regular software updates

8. Use of Cookies

Our website uses cookies to ensure a better user experience and for marketing purposes:

8.1 Necessary Cookies

Cookies essential for the basic operation of the website (e.g. cookie consent settings).

8.2 Analytical Cookies

Google Analytics: Analysis of website usage, visitor statistics

Data Controller: Google LLC

More information: Google Privacy Policy

8.3 Marketing Cookies

Note: Facebook Pixel is currently not active on this website. The provisions below will apply upon activation of this service.

Facebook Pixel: Ad delivery, visitor behaviour tracking

Data Controller: Meta Platforms Inc.

More information: Facebook Privacy Policy

8.4 Google Signals

Our website may use the Google Signals feature of Google Analytics 4, provided you have given your consent via the cookie settings. Google Signals enables:

• Cross-device tracking of users signed in to their Google accounts
• Collection of demographic and interest data (age, gender, interest categories) in aggregated form
• Use of data for ads personalisation

Legal basis: Your consent (Article 6(1)(a) of the GDPR), which you may grant or withdraw via the cookie settings.

Data processor: Google LLC (Google Ireland Limited within the EEA), in accordance with the data processing terms.

Opt-out: You may disable Google ads personalisation at any time in your Google ad settings.

This feature complies with the Google Advertising Features Policy.

8.5 User-Provided Data (Enhanced Conversions)

When you submit our contact form, the email address you provide is encoded using a one-way SHA-256 cryptographic hash, and the hashed value is transmitted to Google Analytics 4 for conversion measurement purposes (generate_lead event). Google uses the hashed data for more accurate measurement of advertising conversions.

Important: Your original email address is never sent to Google. Only the irreversible hash value is transmitted.

Legal basis: Your consent (Article 6(1)(a) of the GDPR), granted by accepting the GDPR checkbox on the form and via the cookie settings.

Data processor: Google LLC (Google Ireland Limited within the EEA)

Retention period: In accordance with Google's data retention policy (up to 26 months)

9. Amendments

We reserve the right to amend this privacy policy. Any amendments will be communicated on our website.

Last modified: 13 April 2026

Effective date: 13 April 2026

10. Contact

If you have any questions regarding data processing, please do not hesitate to contact us:

Legal Notice

1. Nature of website content

The service descriptions, presentations of consulting activities, price ranges and process diagrams on the Sugallat Ltd. (hereinafter: Sugallat) website are for information purposes only. The scope, content, extent and terms of the described services may differ depending on the individual circumstances of each engagement.

2. Contractual relationship

The legal relationship between Sugallat and the client is established solely on the basis of a signed individual engagement contract. The actual scope of services, fees, performance deadlines and liability terms are set out in the engagement contract. Website content does not constitute an offer within the meaning of Section 6:64 of the Hungarian Civil Code (Ptk.), but an invitation to make an offer.

3. Scope of content liability

Sugallat makes every reasonable effort to ensure the accuracy and currency of the professional information on this website. However, due to changes in the legislative environment and authority practice, some information may become outdated. Public procurement legislation, authority guidance and Arbitration Board decisions should always be verified against the official source (jogtar.hu, kozbeszerzes.hu, dontobizottsag.kozbeszerzes.hu).

Information on this website does not constitute individual legal advice. Evaluation of a specific procedural or legal situation requires expert consultation within an individual engagement.

4. External links

Sugallat accepts no responsibility for the content of external websites accessible from this site (jogtar.hu, kozbeszerzes.hu, dontobizottsag.kozbeszerzes.hu, ekr.gov.hu, integritashatosag.hu and other official or professional sources). Their currency and accuracy are ensured by the respective publishers.

5. Data processing

Detailed information on the data processing practice of the website is set out in the Privacy Policy section above.

6. Right to modify

Sugallat reserves the right to modify this legal notice, the content of the website, and the service descriptions without prior notice. Modifications take effect upon publication on the website.

7. Governing law and jurisdiction

This legal notice and the use of the website are governed by Hungarian law. Hungarian courts have exclusive jurisdiction over any disputes arising from the engagement contract.

8. Contact

Questions: benko@sugallat.hu or +36-20-424-5411.

Last modified: 25 August 2026.