Privacy & Cookie Policy

1. Introduction

This Privacy & Cookie Policy explains how personal data is processed when you visit abonett.eu (the “Website”) or contact us through its contact forms.

The Website provides information about Abonett and enables visitors to submit enquiries. It does not offer user registration or user accounts.

We process personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and applicable Hungarian data protection and electronic communications legislation.

2. Data Controller

The controller responsible for processing your personal data is:

Abonett Élelmiszergyártó és Kereskedelmi Kft.
Address: 2740 Abony, Füzesér dűlő 16., Hungary
Email: export@abonett.hu
Telephone: +36 53 560 020

In this Policy, “Abonett”, “we”, “us” and “our” refer to this company.

You may contact us using these details with questions about this Policy or to exercise your data protection rights.

3. Personal Data We Process

3.1. Contact forms and correspondence

Depending on the contact form and the information you provide, we may process:

• Full name;
• Work email address;
• Company name;
• Market segment;
• Telephone number;
• Country;
• Information contained in your enquiry and subsequent correspondence.

Required fields are identified on the relevant form. Providing optional information is voluntary. If you do not provide the information necessary to understand and respond to your enquiry, we may be unable to handle it.

Please do not submit sensitive personal information or unnecessary personal data about other individuals.

3.2. Technical information

Operating and securing the Website may involve processing:

• IP addresses;
• Request dates and times;
• Requested pages and technical response information;
• Browser and device information;
• Error and security logs.

Optional cookies and tracking technologies may collect additional information as described in Section 7.

4. Purposes and Legal Bases

4.1. Responding to enquiries

We use contact-form information to respond to your questions, provide requested information, and conduct business correspondence directly related to your enquiry.

For enquiries submitted on behalf of a company and general enquiries, processing is based on our legitimate interest in responding to incoming communications and handling business enquiries under Article 6(1)(f) GDPR.

Where you personally request steps before entering into a contract with us, processing necessary for those steps is based on Article 6(1)(b) GDPR.

Submitting a contact form does not subscribe you to marketing communications. We do not use contact-form data to send unsolicited marketing messages, add you to marketing mailing lists or create advertising audiences.

4.2. Technical operation and security

We process necessary technical information to operate the Website and email services, investigate faults, prevent misuse, protect systems, and create and restore security backups.

The legal basis is our legitimate interest in maintaining secure and reliable systems and protecting personal data under Article 6(1)(f) GDPR.

4.3. Optional analytics and advertising

Processing through optional analytics and advertising technologies is based on your consent under Article 6(1)(a) GDPR and applicable rules on storing or accessing information on your device.

Cookie consent is separate from submitting a contact form.

4.4. Legal obligations and claims

Where necessary, we may process information to comply with a specific legal obligation under Article 6(1)(c) GDPR.

We may also process information necessary to establish, exercise or defend legal claims based on our legitimate interests under Article 6(1)(f) GDPR.

5. Hosting, Email and Technical Data Processor

Our hosting, email and technical service provider is:

Spark of Madness Kft.
Address: 5630 Békés, Bocskai utca 28., Hungary
Email: info@webmentor.hu
Telephone: +36 70 739 7750

Spark of Madness Kft. acts as a data processor on behalf of Abonett and in accordance with Abonett’s documented instructions.

Its technical activities include:

• Website hosting and storage;
• Email hosting and technical email delivery;
• Technical maintenance and troubleshooting;
• Security support;
• Creating, retaining and restoring security backups.

Where necessary to perform these activities, authorised personnel may access personal data, including when investigating errors or restoring information from backups.

Spark of Madness Kft. does not determine independent business or marketing purposes for contact-form data. Its processing on behalf of Abonett is subject to the requirements of Article 28 GDPR.

The servers used to provide the Website’s hosting and email services are located in Hungary.

6. Access to and Disclosure of Personal Data

Access to personal data is limited to authorised Abonett personnel and service providers who need it for the purposes described in this Policy.

Spark of Madness Kft. may access personal data to the extent necessary to provide its hosting, email, maintenance, security and backup services.

Where legally required or necessary for legal proceedings, relevant information may be disclosed to competent authorities, courts or professional advisers.

Third-party analytics and advertising providers may receive information through the tracking technologies described in Section 7. This processing is separate from handling contact-form information.

7. Cookies and Tracking Technologies

7.1. What are cookies?

Cookies are small files stored on your device when you visit a website. Tags, pixels and similar technologies may also collect information about your browser and interactions with a website.

Some technologies are necessary for Website functionality. Others are used for analytics or advertising and require your consent.

7.2. Strictly necessary technologies

Strictly necessary technologies support essential functions, such as security, form operation and remembering your cookie choices, where implemented.

Consent is not required where storing or accessing information on your device is strictly necessary to provide a service you explicitly request. Any associated processing of personal data must also have an appropriate GDPR legal basis.

7.3. Analytics and advertising technologies

The following describes the purposes of Google, Meta/Facebook, LinkedIn and TikTok technologies where they are enabled on the Website.

Platform	Purpose
Google	Understanding Website usage and, where advertising tools are enabled, measuring advertising performance and supporting remarketing.
Meta / Facebook	Measuring advertising results and, where enabled, creating advertising audiences and supporting remarketing on Meta services.
LinkedIn	Measuring campaign performance, understanding professional audiences and, where enabled, supporting remarketing.
TikTok	Measuring advertising performance and, where enabled, creating advertising audiences and supporting remarketing.

Depending on the service and configuration, these technologies may process online identifiers, IP addresses, browser and device information, page URLs, referral information, visit timestamps and interaction events.

Providers may associate this information with other information they hold, including information connected with your account on their platform, in accordance with their applicable terms and privacy policies.

Further information is available here:

• Google: Information from partner websites
• Meta Privacy Policy
• LinkedIn Cookie Policy
• TikTok: About TikTok Pixel

7.4. Google Consent Mode v2 — Basic mode

The Website uses a cookie banner and preference settings integrated with Google Consent Mode v2 in Basic mode.

Google tracking tags remain blocked until you give the relevant consent. Before consent, no information is transmitted to Google through these tags, including consent-status signals or cookieless measurement pings. If you decline consent, the relevant Google tags remain blocked.

When you consent, the relevant tags are activated in accordance with your choices concerning analytics storage, advertising storage, advertising user data and advertising personalisation.

Consent for Google technologies does not automatically authorise tracking by Meta/Facebook, LinkedIn or TikTok. Any such technologies used on the Website require appropriate, separately configured consent controls.

7.5. Managing and withdrawing consent

Optional cookies and tracking technologies requiring consent must not be activated before you give the relevant consent.

You can accept or reject optional technologies and manage the available preferences through the Website’s cookie settings. Refusing optional tracking does not prevent you from submitting an enquiry.

You can change or withdraw your consent at any time. Withdrawal stops future consent-based tracking for the purposes you disable. It does not affect the lawfulness of processing carried out before withdrawal.

You can also delete or block cookies through your browser. Deleting cookies does not automatically delete information previously received by providers. Blocking strictly necessary cookies may affect Website functionality.

7.6. Cookie inventory and retention

Cookie expiry and the retention period for information already collected by a service are not necessarily the same.

8. Retention Periods

8.1. Contact-form data stored on the Website

Information submitted through contact forms is retained in the Website’s active records only until Abonett contacts the person in response to the enquiry. Following that contact, the submitted information is deleted from those active records.

Deletion from the Website’s active records does not automatically delete copies already delivered to an email mailbox or retained in security backups.

8.2. Email correspondence

Email copies of enquiries and subsequent correspondence are retained separately from the Website’s active form records.

8.3. Technical logs

Technical logs are retained for six months, after which they are deleted or overwritten.

8.4. Security backups

Security backups are retained for six months within the backup rotation cycle.

Information deleted from active systems may therefore remain in restricted-access backups until the relevant backup expires. Backups are used for security and recovery purposes.

Where a backup is restored, applicable deletion requirements must be reapplied.

8.5. Information required for legal purposes

Where a specific legal obligation or legal claim requires longer retention, only the information necessary for that purpose is retained for the applicable period.

9. International Data Transfers

The servers used for the Website’s hosting and email services are located in Hungary.

Third-party analytics and advertising services may nevertheless involve processing personal data outside the European Economic Area (“EEA”).

Where personal data is transferred outside the EEA, an appropriate transfer mechanism under Chapter V GDPR is required. Depending on the recipient and destination, this may include an applicable European Commission adequacy decision or Standard Contractual Clauses, together with additional safeguards where necessary.

You may contact export@abonett.hu for information about relevant safeguards and how to obtain a copy.

10. Data Security

We apply technical and organisational measures appropriate to the nature of the personal data and the risks of processing.

These include restricting access to authorised persons, maintaining technical systems and performing security backups. Access for troubleshooting and recovery is limited to what is necessary for the relevant task.

No method of transmission or storage is completely secure. Personal data breaches are assessed and handled in accordance with applicable legal requirements.

11. Your Data Protection Rights

Subject to the conditions of the GDPR, you may:

• Request access to your personal data and obtain a copy;
• Request correction of inaccurate or incomplete data;
• Request deletion of your personal data;
• Request restriction of processing;
• Request data portability where processing is automated and based on consent or a contract;
• Withdraw consent at any time where processing is based on consent.

You may object, on grounds relating to your particular situation, to processing based on legitimate interests. We will stop that processing unless we demonstrate compelling legitimate grounds overriding your interests, rights and freedoms, or the processing is necessary for legal claims.

You may object at any time to processing for direct marketing, including related profiling. Where you exercise this right, that processing must stop.

To exercise your rights, contact export@abonett.hu.

Where necessary, we may request proportionate additional information to verify your identity.

We normally respond within one month of receiving your request. Where permitted by the GDPR, this may be extended by up to two further months because of the complexity or number of requests. We will inform you within the initial month and explain the reasons.

Requests are normally free of charge. Where a request is manifestly unfounded or excessive, we may charge a reasonable fee or refuse to act, subject to the conditions of the GDPR.

12. Complaints and Judicial Remedies

You may lodge a complaint with a supervisory authority, particularly in the EU Member State of your habitual residence, place of work or the alleged infringement. You do not have to contact us first.

The Hungarian supervisory authority is:

Hungarian National Authority for Data Protection and Freedom of Information (NAIH)
Address: 1055 Budapest, Falk Miksa utca 9–11., Hungary
Postal address: 1363 Budapest, Pf. 9., Hungary
Email: ugyfelszolgalat@naih.hu
Telephone: +36 1 391 1400
Website: https://www.naih.hu

You may also seek a judicial remedy.

13. Automated Decision-Making

We do not use contact-form information to make decisions based solely on automated processing that produce legal effects or similarly significantly affect you.

Optional advertising technologies may involve profiling based on browsing activity for advertising audience purposes, as described in Section 7.

14. Changes to this Policy

We may update this Policy to reflect changes in Website operation, processing activities or legal requirements.

The current version will be published on this page with its effective date. Where a change requires additional notice or new consent, we will provide it as required.