Effective Date: 2025.10.16.
This Privacy Policy ("Policy") governs the manner in which HighCircl Kft. ("Company," "we," "us," or "our") collects, uses, maintains, and discloses information collected from users ("you" or "your") of the Company's website and related services (collectively, "Services"). This Policy is in compliance with the General Data Protection Regulation ("GDPR") and applicable Hungarian laws.
This Policy applies to:
By using the Services, you consent to the collection, processing, and use of your information as described in this Policy. If you do not agree, please do not use our Services.
Types of Personal Data Collected
We collect and process the following categories of Personal Data:
We do not collect any special categories of Personal Data, such as health or biometric data, as defined under GDPR Article 9.
Web Browser and IP Address Information
When you use our Services, certain details are automatically sent to us by your web browser. This information may include your IP address, the name and version of your browser and operating system, the date and time of your visit, the pages you view, and the identity of your internet service provider. You can adjust your browser settings to learn more about what information is shared or to modify your preferences.
Understanding IP Addresses
An IP address is a unique identifier assigned to your device when you access the internet. It serves as a "location" for delivering online content to your device. If your internet connection assigns dynamic IP addresses (e.g., through dial-up), your IP address may change with each session. For static IP addresses, your assigned address typically remains the same.
We may associate your IP address with personal data to improve our Services, such as tailoring content to your location. Additionally, this information helps us gather valuable demographic insights about our users. In cases of suspected fraudulent or malicious activity or potential threats to our systems, we may share server logs containing IP addresses with authorized investigative bodies to trace and address such issues.
Methods of Data Collection
We collect Personal Data from you when you voluntarily provide it through:
Additionally, we may collect information automatically through the use of cookies or similar tracking technologies, including, but not limited to, IP addresses, browser types, and analytics data, for the purpose of improving the user experience.
Purpose of Data Collection
We collect and process personal data to provide the best experience for our users. Specifically, we use the data for the following purposes:
If we need to process your data for purposes not listed above, we will obtain your explicit consent or provide notice as required by law.
Legal Basis for Processing
The legal basis for processing your Personal Data is your consent. By accessing and using our website, submitting your details through forms, or subscribing to our newsletters, you expressly consent to the collection, processing, and storage of your Personal Data in accordance with this Policy. You may withdraw your consent at any time by contacting us at info@highcircl.com.
Data Sharing with Third Parties
We may share your Personal Data with third-party service providers to facilitate our marketing and data storage efforts.
We do not share Personal Data with any third parties beyond those necessary for the provision of our Services, unless required by law.
Data Retention Policy
We retain your Personal Data for a period of 12 months following account closure or termination of your relationship with us. This retention period allows for continuity of services, marketing efforts, and necessary follow-up, unless you request deletion of your data earlier. After this period, your data will be securely deleted, unless further retention is required by law. This policy applies to all categories of Personal Data collected and processed under this Policy.
User Rights
Under GDPR, you have the following rights regarding your Personal Data:
To exercise any of these rights, please contact us at info@highcircl.com. We will respond to your request within the timeframe required by applicable law.
Data Security Measures
We are committed to ensuring the security of your Personal Data. Personal Data is stored using HubSpot, and access to this data is restricted through multi-factor authentication (MFA). We employ appropriate technical and organizational measures to safeguard your data against unauthorized access, loss, or destruction.
In the event of a data breach, we have protocols in place to notify the affected individuals and relevant authorities, in accordance with GDPR Article 33.
International Data Transfers
We do not transfer Personal Data outside of the European Economic Area (EEA). As such, no additional safeguards, such as Standard Contractual Clauses or other mechanisms, are required.
Children’s Data
Our website and Services are not intended for individuals under the age of 18. We do not knowingly collect or process Personal Data from children under 18. If we become aware that we have collected Personal Data from a child without parental consent, we will take immediate steps to delete that information.
Supervisory Authority Information
Should you wish to raise a concern about our data protection practices, you have the right to lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information ("NAIH").
Updates to the Privacy Policy
We reserve the right to update this Privacy Policy at any time. Any changes will be communicated to you via email or by posting a prominent notice on our website. Your continued use of the Services following the posting of changes constitutes your acceptance of such changes.
Cookie Policy
Cookies are small text files that are placed on your device by websites that you visit. They are widely used to make websites work more efficiently, as well as to provide information to the owners of the site.
Types of Cookies We Use
We use the following types of cookies on our website:
How You Can Manage Cookies
Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer. Please note that disabling cookies may limit your ability to use certain features of our website.
Third-Party Cookies
We may use third-party services, such as analytics providers (e.g., Google Analytics), which may set cookies on your device to collect information about how you use our site.
For more information about how these third parties use cookies, please refer to their privacy policies.
Contact Information
If you have any questions or concerns about this Privacy Policy, or if you wish to exercise any of your rights regarding your Personal Data, please contact us at info@highcircl.com
By using our website, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your Personal Data as described herein.