This Privacy Policy (the “Policy”) explains how Bódis Boglárka EV (registered seat: 2131 Göd, Alagút utca 4, Hungary ; registration number: 41184480 ; tax number: HU66937049-2-13; hereinafter: ELYSIAN, “Company”, “we”, or “us”) collects, stores, uses, and discloses personal information from their users (“you”, “user”) in connection with the website located at (the “Website”) operated by the Company, further by using our services (hereinafter: “Service” or “Services”) including registering an account on the Website (hereinafter: “Registration”), shopping on our Website (hereinafter: “Online Shopping”), signing up to our newsletter service (hereinafter: “Newsletter”). Furthermore, this Policy declares the rights and obligations regarding the processing of personal data and other essential provisions. This Policy forms an integral part of the Company’s the terms of use (hereinafter: “Terms of Use”), which is available here.

The processing and collecting of personal data by ELYSIAN shall be in harmony with the directly applicable data protection laws in effect:

In case of personal data processing, the Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter: “GDPR”), the Hungarian Act CXII of 2011 on the Right to Informational Self-determination and Freedom of Information (hereafter: “Freedom of Information Act”), the Hungarian Act XLVIII of 2008 on the Essential Conditions and Certain Limitations of Business Advertising Activity (hereinafter: “Business Advertising Act”), the Hungarian Act CVIII of 2001 on the ecommerce services and information society services (“Ecommerce Act”), furthermore the recommendations and the data protection practice of the Hungarian National Authority for Data Protection and Freedom of Information (hereinafter: “NAIH”) and the recommendations of the Article 29 Data Protection Working Party (hereinafter: “WP29”) and of the European Data Protection Board (hereinafter: “EDPB”) shall apply.

The Company is the data controller of any data which constitutes personal data and which is uploaded when using our Services: at Registration, while Online Shopping, when subscribing for the Newsletter or when Applying For Job.

The Company bound in honor to protect personal data; therefore, the Company will keep confidential the personal data received and take all necessary steps to secure data processing.

Please read and make sure you understand this Policy. If you do not agree with this Policy or our practices, you may not use our Website or our Services.


The following definitions are determined according to the GDPR:

‘personal data’: shall mean any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

‘consent’: shall mean any freely given, specific, informed and unambiguous indication of the will of the Data Subject by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

data controller’: shall mean the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

‘data processor’: shall mean a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

‘third party’: shall mean a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data;

‘personal data breach’: shall mean a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed;

‘recipient’: shall mean a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with European Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;

‘supervisory authority’: shall mean one or more independent public authorities provided by each Member State which is responsible for monitoring the application of the GDPR in order to protect the fundamental rights and freedoms of natural persons in relation to processing and to facilitate the free flow of personal data within the European Union;

‘supervisory authority concerned’: shall mean a supervisory authority which is concerned by the processing of personal data because: (a) the controller or processor is established on the territory of the Member State of that supervisory authority; (b) data subjects residing in the Member State of that supervisory authority are substantially affected or likely to be substantially affected by the processing; or (c) a complaint has been lodged with that supervisory authority.


The information we gather from users enables ELYSIAN to personalize and improve the Services, to allow the users to set up accounts on the Website and to fulfill Online Shopping, further, to conduct hiring process. We collect the following types of information from our users:

2.1 Information you provide to Us:


We collect the following personal data uploaded during the registration on the Website:

Full name, E-mail address, Phone number, Country, Date of birth, Password

Please note that the e-mail address provided does not require the inclusion of personal data, such as your name. You are free to choose an e-mail address that contains information about your identity.

After the registration you can optionally add the following personal data to your User Account:

Shipping address (name, company, address, phone number),

Billing address (name, company, address, phone number).


When you are shopping on our Website, we collect the following personal data:

Full name, Mailing address, E-mail address, Phone number, Credit card details (card number, card expiry date, issuing bank, CVC number), PayPal account name, Billing address, Order number, Return Goods Authorization (RGA) number.


We collect the following personal data when you sign up to our Newsletter on our Website:

E-mail address, Name, Country, Date of birth.


We receive and store certain types of information whenever you interact with our Website or Services. ELYSIAN automatically receives and records information on our server logs from your browser including your IP address, unique device identifier, browser characteristics, domain and other system settings, search queries, device characteristics, operating system type, language preferences, referring URLs, actions taken on our Website, page requested, content consumed (e.g., viewed, uploaded, and shared), dates and times of Website visits, and other information associated with other files stored on your device.


The Company processes anonymous data in order to improve the Website, to bring it to perfection. During this procedure ELYSIAN can incorporate “cookies”, which collect the visitor’s first level domain name, the date and the exact time of access. The “cookie” alone can’t be used to reveal the identity of the visitor. The “cookie” is a file, which is sent to the browser of the visitor and stored on the hard drive of visitor. Cookies don’t damage the computer of the visitor. The browser can be set to indicate when a cookie is received, so the visitor can decide to accept the so-called cookie or not. The Company does not use cookies to collect or manage any information that would allow the identification of the user. For further information, please read our Cookie Policy attached as Annex 1 to the present Policy.


We may use your information, including your personal information – based on diverse purposes as well as the legal basis of the processing – as follows:


Full name

E-mail address

Mailing address

Phone number

Financial data: credit card details, PayPal account name,

Order number

Return Goods Authorization (RGA) number

The above obligatory or optional personal data you provide is used for purposes such as fulfilling the obligations defined in the Terms of Use and providing the Service, responding to your questions, requests relating to the Service, customizing the visualized content, communicating with you about sales offers relating to special Services and new features, and responding to problems relating to our Services.


Full name

E-mail address

Mailing address

Date and place of birth

Phone number

Previous work experience

Any personal data included in the CV you sent to us

When initiating an employment relationship, the applicant sends his or her curriculum vitae and cover letter to ELYSIAN. In such case the legal base of processing the application of the personal data is the consent of the applicant, which is given with the application to the advertised position. In case the applicant is rejected, his or her personal data must be deleted in observance of the required retention period. If the applicant is expressly agreed to remain on file for future selection process, then his or her personal data can be processed for this purpose. You can always withdraw your consent.


Full name

Email address

Date of birth

Phone number

You shall always have the right to withdraw your consent given for marketing purposes at any time, without affecting the lawfulness of processing based on your consent, or on any other legal basis, before your withdrawal.



This means that in some cases the data processing is stipulated by the applicable laws and we have an obligation to process and keep this data for the required time. This includes employment data, billing data, data which is necessary to assist law enforcement etc.


IP address

Browser information

Contact information

Content consumed on the Website

Unique device identifier

Browser characteristics

Domain and other system settings

Search queries

Device characteristics

Operating system type

Language preferences

Referring urls

Actions taken on our Website

Page requested

Content consumed (e.g., viewed, uploaded, and shared)

Dates and times of Website visits

Other information associated with other files stored on your device

Where it is feasible we anonymize personal data or use non-identifiable statistical data. We do not collect personal data in advance and store it for potential future purposes unless required or permitted by the applicable laws.

For collecting anonymously the above-mentioned data and making statistics and analysis we may use the following software and programs:

Name   Registered seat Country

Google Analytics and Google AdWords (Google LLC.)      1600 Amphitheatre Parkway Mountain View, CA 94043  United States of America

Facebook pixel (Facebook Inc.)  1601 Willow Road Menlo Park, CA 94025           United States of America

4.6. Data integrity and purpose limitation: ELYSIAN will only collect and retain personal data which is relevant to the purposes for which the data is collected, and we will not use it in a way that is incompatible with such purposes unless such use has been subsequently authorized by you. We will take reasonable steps to ensure that personal data is reliable for its intended use, accurate, complete and current. We may occasionally contact you to determine that your data is still accurate and current. To secure your personal information processed we save your personal information to backup archives in every 24 hours. The data stored in our backup archives will be deleted in every half a year.


We will retain your personal data for so long as it is needed to fulfill the purposes outlined in this Policy or until you withdraw your consent, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements, further for the establishment, exercise or defense of legal claims). When we have no longer or no legal basis to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.


Information about our users is an integral part of our business, and we may share such information with our affiliated entities. Except as expressly described below, we neither rent nor sell your information to other people or nonaffiliated companies unless we have your permission.

6.1 ELYSIAN shall not ensure access for a third party to personal data provided by you without your preliminary consent, except the cases, when data transfer is necessary for the performance of the contract or for enforcing of ELYSIAN’s legitimate interest or prescribed by law.

6.2 ELYSIAN may share certain personal information with third party vendors in the EU or in third countries, who supply software applications, web hosting and other technologies or services for the Website and our Services (hereinafter: “Data Processor”). The Company will only provide these third parties with access to information that is reasonably necessary to perform their work or comply with the law. Those third parties will never use such information for any other purpose except to provide services in connection with the Website and our Services. During the service of data process, the Data Processor shall abide under the present Policy, relevant legislations in force, furthermore the provisions of the existing contracts between him and ELYSIAN.

We use the data process service of the following Data Processors:

Name   Registered seat Country Activity ( dataprocessing service)

Rendszerinformatika Zrt.           1134 Budapest, Váci út 19., Hungary      Server service

Google LLC        1600 Amphitheatre Pkwy, Mountain View,California 94043        USA      Cloud services

Dimnet Bt.        1044 Budapest, Gyertyaláng u. 4. II.em. I/5.,Hungary      Web hosting services

Hungarian Venture Capital Services Accounting & Consulting Kft.            9027 Győr, Hűtőházi út 2.          Hungary           Accounting services

DPD Hungária Kft.         1134 Budapest, Váci út 33.,       Order fulfilment services

Barion Payment Zrt.      1117 Budapest, Infopark sétány 1. I. épület 5. emelet 5. Hungary,           Payment services

OTP eBIZ           1138 Budapest, Szekszárdi u. 16-18., Hungary    Billing services

6.3 The Rocket Science Group, LLC and Google LLC comply with the EU-US and the EU-Swiss Privacy Shield Frameworks, therefore transfer of your personal data to the aforementioned service providers was deemed safe until July 16, 2020. Please note that according to the judgement no. C-311/18 of the Court of Justice of the European Union, these companies no longer considered to provide appropriate safeguards for the personal data of European citizens. For more information, you can read the judgement here.

6.4 We only transfer personal data collected from individuals located within the EU only with the consent of the individuals to a third-party having a registered seat outside the EU / in the USA acting as a data processor without the appropriate safeguards set out in the GDPR, or when it is necessary for the performance of the contract. ELYSIAN will make every effort to ensure that the personal data transferred is safe and secure and that the personal data is processed in a manner consistent with the GDPR.


We take commercially reasonable measures to protect all collected information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Please understand that you can help keep your information secure by choosing and protecting your password appropriately, not sharing your password and preventing others from using your computer. Please understand that no security system is perfect and, as such, we cannot guarantee the security of the Website, or that your information won’t be intercepted while being transmitted to us. If we learn of a security systems breach, then we may either post a notice, or attempt to notify you by email and will take reasonable steps to remedy the breach.


Our Website is not directed to children under 16 and we do not knowingly collect personal information from children under 16. If we learn that we have collected personal information of a child under 16 we will take steps to delete such information from our files as soon as possible. If you are aware of anyone under 16 using the Website, please contact us at

  1. Your privacy rights


If you have an account registered on the Website, you can log in to view and update your account information. You have the right to obtain confirmation of whether or not we are processing personal data relating to you, have communicated to you such data so that you could verify its accuracy and the lawfulness of the processing and have the data corrected, amended or deleted where it is inaccurate or processed in violation of the GDPR.

We encourage you to contact us at with your questions or concerns, or to request edits to your personal information, or to have it removed from our database. Requests to access, change or remove your personal data will be handled within 30 days.


If you are from the territory of the EU, you may have the right to exercise additional rights available to you under applicable laws, including:

Right of Erasure: In certain circumstances, you may have a broader right to erasure of personal information that we hold about you – for example, if it is no longer necessary in relation to the purposes for which it was originally collected. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.

Right to Object to Processing: You may have the right to request ELYSIAN to stop processing your personal information and/or to stop sending you marketing communications.

Right to Restrict Processing: You may have the right to request that we restrict processing of your personal information in certain circumstances (for example, where you believe that the personal information, we hold about you is inaccurate or unlawfully held).

Right to Data Portability: In certain circumstances, you may have the right to be provided with your personal information in a structured, machine readable and commonly used format and to request that we transfer the personal information to another data controller without hindrance.

If you would like to exercise such rights, please contact us at We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.

For any complaints that we can’t resolve directly, please contact Bódis Boglárka EV (registered seat: 2131 Göd, Alagút utca 4, Hungary ; registration number: 41184480 ; tax number: HU66937049-2-13).

If you don’t agree with our decision, you have the right to an effective judicial remedy or to lodge a complaint to the NAIH (registered seat: H-1125 Budapest, Szilágyi Erzsébet fasor 22/C., Website:

You also have the right to complain to the EU Data Protection Authority about our collection and use of your personal data. For more information, please contact your local EU Data Protection Authority.


If you are a Brazilian individual, you have the following rights in addition to the rights described in section 9.1 of this Policy:

Right of erasure: If you would exercise this right, we will respond to you immediately, or if that is not possible, we will send a reply to you to indicate the reasons of fact or law that prevents the immediate adoption of the measure. If we are not the data processors of the data you requested the erasure of – whenever possible – we will indicate who the processing agent is.

Right to be informed: You have the right to obtain information about what types of processing do we carry out on your personal information.

Right of access: If you request the providing of your personal data processed by us, we will grant you access to such data in 15 days of your request, if the data requested is more than the simplified request version.

Nondiscrimination: We do not process your data for unlawful or abusive discriminatory purposes. In certain circumstances, you have the right to request a review of our data processing and the supervisory authority (the Brazilian National Authority for Protection of Data (hereinafter: “ANPD”)) may carry out an audit to verify discriminatory aspects.

Data portability: Your data might be transferred to another service or product supplier in accordance with the regulations of the ANPD and as subjects to commercial and industrial secrets.

AERON appointed Weiszbart Law Firm (address: 1052 Budapest, Kristóf tér 3. III. emelet, Hungary, e-mail address: as data protection officer (hereinafter “DPO”) in accordance with item II of Article 23 of the LGPD.

f you would like to exercise the rights included in the present section of the Policy, please contact our DPO or AERON at We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.

You also have the right to complain to the ANPD about our collection and use of your personal data. For more information, please contact the ANPD.


We will modify this Policy if our privacy practices change. We will notify you of such changes by posting the modified version on our Website and indicating the date it was last modified, and, if the changes are significant, we will provide a more prominent notice (including by email in certain instances). The date this Policy was last modified is at the top of this page. Please periodically review this Policy so that you are familiar with the current Policy and aware of any changes.


If you are a user in California, the Company’s Privacy Notice for California Consumers attached as Annex 2 to this Policy applies to you. We will not share any personal data with third-parties for their direct marketing purposes to the extent prohibited by California Consumer Privacy Act of 2018 (CCPA). If our practices change, we will do so in accordance with applicable laws and will notify you in advance.


If you have any questions concerning this Policy or the Services, please contact us at You can also contact us at our contact office at H-1054 Budapest, Hold utca 27., Hungary.

Annex 1

Cookie Policy of Aeron


The present cookie policy (hereinafter: “Cookie Policy”) describes how ÁERON uses cookies and similar technologies to provide, customize, assess, enhance, promote, and protect our services. The Cookie Policy forms an integral part of the Privacy Policy of ÁERON. Please note that terms not described in this Cookie Policy have the similar meaning as defined in the Terms of Service and Privacy Policy of ÁERON. If you have any questions do not hesitate to contact us at


Cookie is a file, which is sent to the device of the user when the user visits the Website. ÁERON can access the cookie again when the user visits the Website on a further occasion, in order to facilitate navigation on the internet or transactions, or to access information about user behavior. It is sent to your browser and stored on your device’s hard drive. When you visit our Website, we may collect information from you automatically through cookies.


Strictly Necessary Cookies. These cookies are essential for the Website’s operation; therefore the operation and availability of the Website and the Services cannot be provided without them. They help verify your account and remember the choices you make at line with Article 5(3) of the ePrivacy Directive (Privacy and Electronic Communications Directive 2002/58/EC on Privacy and Electronic Communications), consent is not required for technical storage or access of the following cookies:cookies used for the sole purpose of carrying out the transmission of a communicationcookies that are strictly necessary in order for the provider of an information society service explicitly required by the user to provide the Services.

cookies used for the sole purpose of carrying out the transmission of a communication

cookies that are strictly necessary in order for the provider of an information society service explicitly required by the user to provide the Services.

Research, Performance, and Analytics Cookies. These cookies help us providing a better user experience by analyzing how users interact with For instance, they help us identify which pages are used most frequently, which newsletters are most engaging, and what type of ÁERON features are the most popular. This assists us in refining ÁERON according to our users’ interests.

Advertising Cookies. These cookies help us to inform you and provide you with customized advertisement based on your past use of the Website and / or the Services. These cookies are monitoring your usage data and by using cookies, information, which information does not consider as personal data, is transferred to the partners that manage the remarketing and behavioral targeting activity.


4.1 Strictly Necessary Cookies

Service provider name  Cookie name     Description       Expiry        _skala__preferred_country_code          country code preference           Persistent        _skala__order_token    Current cart/ order       Persistent        _skala__webp_support Should we use next gen image format    Persistent        _skala__cookie_accepted          Accepted the cookie consent popup      Persistent        _skala__jwt_token        Login token       Persistent          JSESSIONID       Preserves users states across page requests.      4 days       rc::a     This cookie is used to distinguish between humans and bots. This is beneficial for the Website, in order to make valid reports on the use of their w eb site.    Persistent       rc::a     This cookie is used to distinguish between humans and bots.      Session

4.2 Research, Performance and Analytics Cookies

Service provider name  Cookie name     Description       Expiry        _ga; _gid; _gat. These are third-party cookies by Google Analytics. Learn more at  _ga: 2 years; _gid: 1 day; _gat: 1 day.        _hjAbsoluteSessionInProgress   This cookie is used to count how many times the Website has been visited by different visitors – this is done by assigning the visitor an ID, so the visitor does not get registered twice.   1 day        _hjid     Sets a unique ID for the session. This allows the Website to obtain data on visitor behaviour for statistical purposes.        Session        _hjTLDTest       Detects the SEO-ranking for the Website. This service is part of HotJar’s statistics and analytics service.   Session    collect  Used to send data to Google Analytics about the visitor’s device and behaviour. Tracks the visitor across deices and marketing channels.          Session        hjViewportId     Sets a unique ID for the session. This allows the Website to obtain data on visitor behaviour for statistical purposes.            Session       vuid      Collects data on the User’s visits to the Website, such as which pages have been read.    2 years        _hjAbsoluteSessionInProgress   This cookie is used to detect the first pageview session of a user. This is a True/False flag set by the cookie.            Persistent        _hjIncludedInPageviewSample  This cookie is set to let Hotjar know whether that visitor is included in the sample which is used to generate Funnels. This is a session cookie which is destroyed when the user leaves the site.          1 day        _hjIncludedInSessionSample      This cookie is set to let Hotjar know whether that visitor is included in the sample which is used to generate Funnels. This is a session cookie which is destroyed when the user leaves the site.          1 day        _uetvid This is a cookie utilized by Microsoft Bing Ads. It allows us to engage with a user that has previously visited the Website. 16 days        _uetvid_exp                  Persistent

4.3 Advertising Cookies


Service provider name  Cookie name     Description       Expiry        _fbp     Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.    3 months        _gcl_au Used by Google AdSense for experimenting with advertisement efficiency across websites using their services.    3 months        _uetsid Collects data on visitor behaviour from multiple websites, in order to present more relevant advertisement. This cookie also allows the Website to limit the number of times that they are shown in the advertisement. 1 day        _uetsid_exp      Contains the expiry-date for the cookie with corresponding name.          Persistent       asd/ga-audiences          A pixel used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor’s online behaviour across the websites.    Session        ATN      Targets ads based on behavioural profiling and geographical location.   fr          Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.    3 months  A pixel, which sets a unique ID for the visitor, that allows third party advertisers to target the visitor with relevant advertisement. This pairing service is provided by third party advertisement hubs, which facilitates real-time bidding advertisers. Session          MUID   Used widely by Microsoft as a unique user ID. The cookie enables user tracking by synchronizing the ID across many Microsoft domains.            1 year   tr         Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.    Session


5.1 Strictly Necessary Cookies

We use the information we collect to:

verify the user’s account during the session;

remember the choices made on the Website;

avoid fraudulent access to the user account;

remember what is in your shopping bag;

process card payments.

5.2 Research, Performance, and Analytics Cookies

We use the information we collect to:

remember your information so that you will not have to re-enter it during your visit or the next time you visit the Website;

monitor aggregate usage metrics such as total number of visitors and pages viewed;

help AERON to improve its Services.

5.3 Advertising Cookies

We use the information we collect to:

provide custom, personalized advertisements, content, and information;

monitor the effectiveness of our marketing campaigns;

inform users about current promotions.


By entering our Website, users can actively check their desired preferences on the pop-up window about the cookies we use in the future. This consent must be renewed every 12 months. The cookies are grouped into four intelligible categories, that the user may check or uncheck. Strictly Necessary Cookies cannot be unchecked, because they are whitelisted and are necessary for our Website to function properly.


You can set their browser to not accept cookies, but this may limit your ability to use our Services. For example, you may not be able to log into your account. Please visit the following links to find out how you to change your cookie and advertisement settings:






The Website uses different third-party applications and services to enhance users’ experience. This includes social media platforms such as Facebook. As a result, cookies may be determined by such third parties and used by them to track your online activity. Please note, that ÁERON has no direct control over information collected by these cookies. To get more information on the cookies used by such third party through the embedded content, we recommend you to review the privacy policy and terms of use of this third party.

Annex 2

Privacy notice for California residents

This Privacy Notice for California Residents (this “Notice”) supplements the information contained in the Privacy Policy of Gold Lumen Kft. (the “Company”) and applies solely to all visitors, users, and others who reside in the State of California (“User” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals. Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some its requirements.


We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

Publicly available information from government records.

Deidentified or aggregated consumer information.

Information excluded from the CCPA’s scope, like:

health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We have collected the following categories of information from users in the past twelve (12) months and we also expect to collect them in the future:

Category           Examples          Collected

  1. Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. YES
  2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. YES
  3. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). YES
  4. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.           YES

  1. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
  2. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES
  3. Geolocation data. Physical location or movements. NO
  4. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
  5. Professional or employment-related information. Current or past job history or performance evaluations. NO
  6. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
  7. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you. For example, when you create an account to access or utilize our Services.

Indirectly from you. For example, behavior data collected when you use or utilize our Services.

Directly and indirectly from activity on our Website. For example, from submissions through our website portal or website usage details collected automatically.

From third-parties that interact with us in connection with the Services we perform.


We may use or disclose the personal information we collect for one or more of the following purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.

To provide, support, personalize, and develop our Services.

To create, maintain, customize, and secure your Account with us.

To process your requests, purchases, transactions, and payments and prevent transactional fraud.

To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

To personalize our service experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Services, third-party sites, and via email or text message (with your consent, where required by law).

To help maintain the safety, security, and integrity of our Services, the related databases and other technology assets, and business.

For testing, research, analysis, and product development, including to develop and improve our Services.

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

As described to you when collecting your personal information or as otherwise set forth in the CCPA.

To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.


We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

We share your personal information with the following categories of third parties:

Service providers, including without limitation Google Analytics (for usage analytics) and any third-party payment processors and fulfilment service providers.


In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A

Category B

Category C

We expect to disclose your personal information for a business purpose to the following categories of third parties:

Service providers, including without limitation Google Analytics (for usage analytics) and any third-party payment processors.


In the preceding twelve (12) months, the Company had not sold any personal information.


The CCPA provides California residents with specific rights to request information about the Company’s collection, use and disclosure of your personal information over the prior twelve (12) months, and ask that we provide you with the following information:

6.1 Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request, we will disclose to you:

– The categories of personal information we collected about you.

– The categories of sources from which we collect personal information.

– Purpose for collecting, using or selling personal information.

– The categories of third parties with whom we share that personal information.

– The specific pieces of personal information we collected about you (known as “data portability request”).

If applicable, categories of personal information sold about you and the categories of third parties to which the personal information was sold.

We do not provide these access and data portability rights for B2B personal information.

6.2 Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

Debug products to identify and repair errors that impair existing intended functionality.

Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

Comply with a legal obligation.

Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We do not provide these deletion rights for B2B personal information.

6.3 Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at:

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:

-First Name, Last Name, Email used to register with the Company, and Phone Number

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response timing and format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.


We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.

Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

Provide you a different level or quality of goods or services

Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.


We do not sell the personal information of Users, including of those we actually know are less than 16 years of age. Since we do not sell your personal information, you do not have to go through steps to opt-out or opt into the sale of your information.


We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website and update the notice’s effective date. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.


If you have any questions regarding this Notice or information we hold about you, you may contact us at or at 1054 Budapest, Hold utca 27., Hungary. In order for us to take the appropriate action, please describe in reasonable detail the nature of your request or inquiry.