Privacy Notice

1. The Data Controller and contact details
This notice applies to the processing of personal data in connection with the https://everguest.com website operated by MGMT
Group Korlátolt Felelősségű Társaság
(registered office: 1126 Budapest, Dolgos utca 2. 4. ép. fszt. 1.; company registration no.:
01-09-299789).

The data controller is an entity that determines the purposes and means of the use of personal data in its possession. The data
controller is also responsible for the lawfulness of its own processing.

Name of the data controller: MGMT Group Korlátolt Felelősségű Társaság (“Data Controller”)
You can contact the Data Controller in the following ways:
Email address: legal@everguest.com

Online form to contact us: https://everguest.com/contact-us/

Below you will find information about all of our data processing activities in relation to our website and online activities.

All of our data processing is carried out in accordance with the relevant legislation, including in particular the General Data
Protection Regulation of the European Union (“GDPR“), Act CXII of 2011 on the Right of Informational Self-Determination and
Freedom of Information and other sectoral legislation.

2. Data processing in relation to the https://everguest.com/contact-us/ website

3. Cookies
What are cookies and what are they used for?

A cookie is a small text file that the website you are visiting stores on the device you use to browse the internet. Your device stores the cookie for a certain period of time. Some cookies are deleted as soon as you close your browser (these are called “session cookies”), others are stored for a longer period of time and are used by the website to “remember” certain parameters, such as the language of the website you have chosen. When you visit the website again, these “remembered” settings are automatically loaded.

Websites use cookies for several purposes. Some cookies are necessary to ensure the proper technical functioning of the website and to make all of its content available to you, so they are strictly necessary. Other cookies provide a more convenient use of the website or an additional functionality or, based on your activity on the website (e.g. the content you view, the menus you open), help us tailor the website to the needs and browsing habits of the users.

Cookies are not a security risk on your device and do not cause any operational disruption.

Given that some cookies may, in the course of their operation, record information that constitutes personal data (such as geo-location data derived from the IP address of the device you use for browsing, the type of device you use, your activity on the website), their use is only possible if it complies with the applicable data protection legislation.

Cookies can be categorised according to several criteria. One is whether they are used by us on the website (so-called “first party cookies”) or by a third party organisation (so-called “third party cookies”). Another possible categorisation is based on the categories mentioned above, e.g. essential, optional or marketing cookies.

The cookies used on the https://everguest.com website fall into the following categories:

Essential technical cookies. They are absolutely necessary for the technical functioning of the website (e.g. for the correct display of graphic content, navigation), so it is not possible for you to turn them off. These cookies are automatically installed on your computer or other device when you visit our website in order to ensure the undisrupted use of our website. Their purpose is to guarantee the security of the website, to ensure that its content is displayed without errors and to balance the traffic on the website. Without their use, the proper technical functioning of the website cannot be guaranteed. The data collected through the use of these cookies (in particular the geo-location data derived from the IP address of your computer or other device) are processed on the basis of our legitimate interest in providing the secure and undisrupted operation of our website, for a period of time depending on the type of the cookie. When you close your browser, some of these cookies are automatically deleted from your device’s cache, others remain there for a limited period of time.

Functional and convenience cookies. They are used to enhance your website experience by remembering certain preferences regarding the functioning of the website and displaying it accordingly when you visit the website again. These cookies are processed only if you’ve provided your consent to it, which you can withdraw at any time via the cookie settings interface.

Statistical cookies. These cookies are used to measure the number of visits to the website and the activity of users on the website for statistical purposes, in order to allow us to continuously improve the website. They are important to us and our third-party partners because they allow us to learn about certain statistical characteristics of our visitors (e.g. city, type of device, browser, operating system used, the content on our website you have visited and the duration of it). We use this data to generate general statistics about the traffic on our website and use them to improve it. These cookies are processed only if you’ve provided your consent to it, which you can withdraw at any time via the cookie settings interface.

Marketing cookies. Our website also uses marketing cookies to allow us and our third-party partners to serve you ads and customized marketing contents that are relevant to your interests, in addition to the main content. These cookies try to “guess” which content and menu items are most relevant to the user based on their activity on the website. These cookies are processed only if you’ve provided your consent to it, which you can withdraw at any time via the cookie settings interface.

Please note that you can manage cookies in your browser settings and delete all cookies stored on your device at any time. However, if you (also) delete cookies that are essential for the proper functioning of the website, some of the website’s functions may not or may not properly work.

Cookies used on the https://everguest.com website

On the website we only use cookies by Google Analytics, Google Ads, Meta and Hotjar.
Out of the cookies developed by Google, the Data Controller uses only the Google Analytics and Google Ads cookies. Google does not log or store the IP address of your device. Google only determines the “partial” location of your device based on its IP address, so it uses the IP address to determine the city, country, region, continent from which you have visited the website. The IP address is then deleted without being logged. More information on how Google uses and stores IP addresses within the European Union:
https://support.google.com/analytics/answer/12017362?hl=en

We use Google Ads cookies on the website only if you have consented to it.
For more information about how Google uses cookies, please visit https://policies.google.com/privacy?hl=hu. For information about how Google uses the data collected from the websites (including the Controller’s website) and applications using its services, please visit https://policies.google.com/technologies/partner-sites?hl=hu.

For more information about how the data collected by Hotjar cookies on the website is used, please visit:
https://www.hotjar.com/legal/policies/privacy/
For more information on how Meta uses cookies, please visit: https://hu-hu.facebook.com/privacy/policies/cookies/?entry_point=cookie_policy_redirect&entry=0

5. Recipients of personal data
By recipients we refer to all entities to which we – in certain cases – transfer personal data processed by us for the reasons set out below, or which may have access to such personal data. Some of the recipients are independent data controllers and are therefore responsible for the processing of the personal data transferred to them. Others act as our data processors, which means that they carry out certain operations on the personal data transferred on our instructions and within the framework of an agreement with us.

Below you will find information about these recipients.

In the context of transferring personal data to the above recipients, we will only transfer the personal data to a third country outside the European Union if a safeguard mechanism required by the GDPR is in place to protect the personal data transferred. For example, in case of our domain service provider, Domain.com LLC, the transfer is based on a model agreement approved by the European Commission (for more information, see here: https://newfold.com/privacy-center/addendum-eu-gdpr).
 
We provide more information on the applied guarantees on your request. We will not transfer your personal data to any person other than the above recipients unless such transfer is required by law.
 

6. Rights of data subjects and how to exercise them
According to the provisions of the GDPR, you have the following rights in relation to the data processing. You may exercise these rights at any time by contacting us at the contact details indicated in point 1 above.

We will consider your request without delay and, if necessary, take the appropriate measures. We will then provide you with a detailed response within max. 1 month as of receiving your request, explaining the taken measures or, if no measure has been taken, the reasons. If it is necessary due to the complexity of the request and the number of requests, the above deadline may be prolonged with two months. In such a case, the prolongation will be communicated within one month as of the receipt of the request, explaining the reasons for the delay.

Please make your request briefly, clearly and in your own words. All requests will be dealt with individually.

A) Right to access
At any time, you have the right to request information about whether and how we process your personal data, including the purposes of the processing, the recipients to whom your data have been disclosed or the source from which the data were obtained, the retention period, your rights in relation to the processing and, in the case of transfers to third countries or international organisations, information about the safeguards relating to the transfer. In exercising your right of access, you also have the right to request a copy of the personal data being processed by us. Where your right of access adversely affects the rights and freedoms of others, in particular the trade secrets or intellectual property rights of others, we are entitled to refuse to fulfil your request to the extent necessary and proportionate. In the event that you request more than one copy of the above information, we will charge you a reasonable fee proportionate to the administrative costs of producing the additional copies.

B) Right to rectification
We will correct the personal data we store about you at any time at your request (e.g. in the event of a change of data). If we have previously disclosed the personal data affected by the rectification to another person (such as a recipient as data processor), we will inform such persons of the rectification without undue delay after the rectification, provided that this is not impossible or does not require a disproportionate effort. Upon your request, we will inform you of these recipients.

C) Right to erasure (‘right to be forgotten’)
If you request the erasure of any or all of your personal data, we will erase it without undue delay if:
● we no longer need the personal data for the purposes for which it was processed;
● the data processing was based on your consent, but you have withdrawn your consent and there is no other legal basis for the data processing;
● the data processing is based on our legitimate interests, but you have objected to the data processing and there are no primary legitimate grounds for us to continue the processing (the burden of proof in this context is on us);
● we have unlawfully processed the personal data despite our best efforts; or
● the erasure of personal data is necessary to comply with a legal obligation.

If we have disclosed the personal data affected by the erasure to another person (such as a recipient as data processor), we will inform such persons of the fact of erasure without undue delay after the erasure, provided that this is not impossible or does not require a disproportionate effort. Upon your request, we will inform you of these recipients.

Please note that we may not be obliged to erase your personal data, in particular if the processing is necessary for the establishment, exercise or defence of legal claims.

D) Right to restriction of processing
You can also request the restriction of the processing of your personal data in the following cases. Restriction means that we will not perform any operation on the data concerned, except for storage, and we will not use the personal data:
● if you contest the accuracy of the personal data we process about you – in this case, the restriction applies for the period of time that allows us to verify the accuracy of the personal data;
● the data processing is unlawful, but you do not want the personal data concerned to be erased and instead you want the processing to be restricted;
● the purpose for which we carried out the processing no longer exists, but you require such data for the establishment, exercise, or defense of legal claims; or
● you have objected to the processing – in this case, the restriction will remain in place until it is determined whether there are any compelling legitimate grounds that overrides your objection, in other words, until it is decided whether the processing may continue despite the objection or not.

If the personal data affected by this right have been disclosed to another person (i.e. a recipient, such as a data processor), we will inform such persons of the fact of the restriction without undue delay after the restriction, provided that this is not impossible or doe not require a disproportionate effort. Upon your request, we will inform you of these recipients.

E) Right to object
If the legal basis for processing is our legitimate interest, you have the right to object to the processing. In this case, we have the burden of proof and we are not obliged to uphold your objection if:
● the data processing is justified by a compelling legitimate grounds which prevail your right to object, or
● the data processing relates to the establishment, exercise or defence of legal claims.
Otherwise, in the event of your objection, the data processing will be stopped immediately.

F) Right to data portability

You have the right to request that the personal data that you have provided to us on the basis of your consent be provided to you in a structured, machine-readable format (e.g. as an email attachment) or, where technically feasible, transferred directly to another data controller designated by you at your request. Where the exercise of your right to data portability would adversely affect the rights and freedoms of others, we are entitled to refuse to comply with your request to the extent necessary and justified.

G) Right to complain, right to remedy
We will do our best to ensure that we never give you cause for complaint. However, if you consider that our processing of your personal data violates the provisions of the applicable data protection legislation, in particular the General Data Protection Regulation, you have the right to lodge a complaint with the National Authority for Data Protection and Freedom of Information (“NAIH”). Contact details of the NAIH:

Website: http://naih.hu/
Address: 1055 Budapest, Falk Miksa utca 9-11.
Postal address: 1363 Budapest, Pf.: 9.
Phone: +36-1-391-1400
Fax: +36-1-391-1410
E-mail: ugyfelszolgalat@naih.hu

 
You also have the right to make a complaint to other supervisory authorities, in particular those established in the EU Member State where you have your habitual residence, place of work or where the alleged infringement took place.
 
Regardless of your right to complain, you can also initiate legal proceedings before a court. In our case, the competent court is the Metropolitan Court of Budapest (in Hungarian: Fővárosi Törvényszék), but you can also bring an action before the court of your place of residence. For more information about the courts, please visit http://birosag.hu/torvenyszekek. You can also bring the case before the competent court in the Member State where you have your habitual residence if you have your habitual residence in another EU country.
 

You also have the right to appeal against a legally binding decision of the NAIH that applies to you. You also have the right to a judicial remedy if the NAIH does not deal with your complaint or does not inform you within three months of the procedural developments or outcome of your complaint.

 

Effective: 14 February 2024.