Privacy Policy Summary

Effective: 10 March 2025

This is a user-friendly summary – not a substitute – of the legally compliant full privacy notice that follows on the next pages.

Who are we?
Name: Automation Gap Management KFT
Address: 4060 Balmazújváros, Vásártér utca 22
Owners: Tímea Pénzes-Lezák, Zita Kálmán-Koczka
Email: hello@agm.hu
Phone: +36 30 599 9121

What do we do?

We respect your rights and respond to your requests within the legally prescribed timeframes. We handle your data as we expect ours to be handled – with care.
Your data is protected, transmitted through encrypted channels, never sold, and only used for the purposes you agreed to.
We operate a website, monitor its usage, log access for security reasons, run targeted online marketing campaigns, and process the data you provide.
Upon request and after identification, we will provide or delete your data.

Our Services
Website
We log website visits for security (IP address, visited pages). With Google Analytics, we analyze how you use our site to create more relevant content (via cookies). Facebook and Google AdWords cookies may be placed in your browser; you may see targeted ads on these platforms.

Newsletter
You can subscribe to our newsletter by providing your name and email address. We will inform you via email about our new services, promotions, and useful insights.

Unsubscription and Data Retention
Every email we send includes an unsubscribe link, so you can opt out at any time.
Your data is retained for 365 days after your last interaction.

Payments
Due to legal requirements, certain personal data and data appearing on issued invoices are stored in accordance with applicable legislation for a minimum of 10 years and up to 15 years from the date of the last invoice.

Detailed Privacy Notice

Data Controller: Automation Gap Management Kft
Address: 4060 Balmazújváros, Vásártér utca 22
Owners: Tímea Pénzes-Lezák, Zita Kálmán-Koczka
Email: hello@agm.hu
Phone: +36 30 599 9121
Website: agm.hu
Company Registration No.: 09-09-036641
Tax No.: 32726480-2-09

Consent for the Processing of Personal Data
By visiting or interacting with the company’s digital platforms (website, Facebook ads, AdWords campaigns), I voluntarily and expressly give my consent to the processing of the personal data I provide.

By submitting my data, I declare that I am over 18 years old and legally competent. I represent a legal entity or an organization without legal personality, and I am duly authorized to act on its behalf and to give consent to the data processing and data handling described in this notice.

I declare that I will not provide any sensitive personal data, either during registration or at any later time, in any form.

Special Categories of Personal Data

Personal data includes, among others: racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic or biometric data used for identification purposes; health data; and data concerning a person’s sexual life or sexual orientation.

I declare that I will not provide any identification numbers suitable for uniquely identifying a person – examples include, but are not limited to: passport number, personal ID number, ID card number, address card number, or driver’s license number.

By giving my consent, I acknowledge that AGM.HU may send me marketing-related emails, informational materials, event invitations, or contact me by phone in relation to its business activities.

I understand that I may withdraw my consent to the processing of my personal data at any time by following the methods specified in this Privacy Notice, for example, by sending a request to hello@agm.hu.

Legal Basis: Legitimate Business Interest

If you provide your data through a form and indicate your interest or application, this is considered the preparation of a contract. In this case, the legal basis for processing your personal data under the GDPR becomes legitimate business interest.
This change in legal basis does not affect your rights or how we handle your personal data. It only means that, unless you request to stop the process, we will continue to process your data for the purpose of preparing the contract.

Legal Basis: Contractual Obligation in Case of Payment

If you pay for one of our services, the payment is made according to the conditions specified in our Terms and Conditions. In this case, the legal basis for the processing of your personal data under the GDPR becomes contractual obligation.
This change in legal basis does not affect your rights or how we handle your personal data. However, it means that even if you withdraw your consent, we will continue processing your data for the duration of the contract, solely for the purpose of fulfilling that contract.

As soon as the contract is fulfilled or terminated, the legal basis for data processing changes again, and your personal data will subsequently be processed based on legal obligation.

Following contract termination or fulfilment, based on legal obligation
Regarding the data appearing on the invoice, we are legally required to continue processing your personal data.

Your rights
You have the following rights. According to the GDPR, we must respond to your request within a maximum of 1 month. We will do our best to respond much sooner.

Right to information
You may request information about the personal data we process about you. You may request access to this data.

You can request information at any time by sending a registered letter with return receipt to our postal address, or by sending an email to our official email address. A request sent by post is considered valid if we can clearly identify you based on the content of the request.

An information request sent by email is considered valid only if it is sent from your registered email address. However, this does not exclude us from verifying your identity by other means for security reasons before providing the information.

Your request for information may include the data we process, its source, the purpose of processing, legal basis, duration, the names and addresses of any data processors, the activities related to data processing, and, in the case of data transfer, who received or receives your data and for what purpose.

Right of Access
If you request information about whether your Personal Data is being processed, and the answer is yes, you are entitled to access the purpose of processing, categories of data, recipients, storage duration, data subject rights, legal remedies, data sources, automated decision-making, and international data transfers.

Right to Rectification
You may request the correction or modification of your Personal Data at any time by sending a registered letter with return receipt to our postal address or by sending an email to our official email address. Taking into account the purpose of the processing, you may also request the completion of incomplete Personal Data.

Right to Erasure (“Right to be Forgotten”)
You may request the deletion of your Personal Data processed by us. Deletion may be refused if (i) it is necessary for exercising the right to freedom of expression and information, or (ii) if the data is processed in the public interest (as required by law), or (iii) due to legitimate private interest (for the establishment, exercise, or defence of legal claims).

We will always inform you if your request for deletion is denied, including the reason for the refusal. Once your Personal Data is deleted, the previous (deleted) data cannot be restored.

Newsletters can be unsubscribed from via the unsubscribe link included in each newsletter.

Right to Restriction of Processing
You may request the restriction of processing of your Personal Data if you contest the accuracy of the processed data. In such cases, the restriction applies for the period necessary for verifying the accuracy of the Personal Data.

We will mark the Personal Data we process if you dispute its correctness or accuracy, but the inaccuracy or incorrectness of the disputed Personal Data cannot be clearly established.

You may also request the restriction of processing your Personal Data if the Data Processing is unlawful but you oppose the deletion of the Personal Data and instead request the restriction of its use.

You may also exercise this right if the purpose of the Data Processing has already been fulfilled, but you require the continued processing of your data for the establishment, exercise, or defence of legal claims.

If you object to the processing, we will restrict the processing of your Personal Data for the period necessary to determine whether the controller’s legitimate grounds override those of the data subject.

Right to data portability
You may request that the Personal Data you have provided to us and which we process in an automated way be handed over to you in a structured, commonly used, machine-readable format (XML/XLS/CSV), and/or be transmitted to another data controller.

Right to object
You may object to the processing of your Personal Data if (i) the processing is necessary solely to fulfil our legal obligations or enforce our legitimate interests; (ii) the purpose of the processing is direct marketing, opinion polling, or scientific research; or (iii) the data is processed for the performance of a task carried out in the public interest.

We will assess the lawfulness of your objection, and if we find it justified, we will terminate the Data Processing and block the Personal Data processed. We will also inform you of your objection and any measures taken based on it.

We will notify all recipients to whom the Personal Data affected by the objection was previously disclosed.

Purpose of data processing
Protection of your rights.
Identification and communication with you.
Personalization of marketing messages sent to you. Providing targeted, relevant messages based on your area of interest.
Fulfilment of services undertaken in the General Terms and Conditions, ensuring service quality and safety conditions.
Compliance with our legal obligations.
Enforcement of our legitimate business interests.

Processed data
We process the data you have provided:
Name
Email
Phone number
Billing address, site address

We log data for security purposes:
Viewed page/function
Exact time
IP address
Browser cookie

We build a profile for marketing purposes:
What problem are you seeking a solution for?
What services are you interested in?

The profile is built based on the data you have provided. Our goal is to ensure that the messages we send are truly interesting and relevant to you. We also don’t like receiving generic messages that are not meant for us.

Web analytics performed on the website
Please note that to measure traffic on the “AGM.HU” website, monitor visitor behavior, create statistics, and track the performance of advertisements, we use the following programs: Google Analytics, Google Remarketing, AdWords Conversion Tracking, and Facebook Remarketing.

These programs place so-called cookies in your browser, which store unique user identifiers. By visiting the website, you allow the use of Google Analytics, Google Remarketing, AdWords Conversion Tracking, and Facebook Remarketing programs. You also consent to your behavior being monitored and tracked, and to the use of all services provided by these programs.

In addition, you can disable the future data collection and storage of cookies at any time, as described below. Please note that the settings and usage of Google Analytics, Google Remarketing, AdWords Conversion Tracking, and Facebook Remarketing fully comply with data protection authority requirements.

According to Google, Google Analytics primarily uses first-party cookies to report on visitor interactions on your website. These cookies only record non-personally identifiable information. Browsers do not share cookies between different domains. Further information about cookies can be found in Google’s Ads and Privacy FAQ.

Google Analytics
We primarily use Google Analytics for statistical purposes, including measuring the effectiveness of our campaigns. Through this program, we learn how many visitors have accessed the website and how much time they spent on it. The program recognizes the visitor’s IP address, which enables it to determine whether the visitor is a returning user or not.

Whether the visitor is a new user, and it also tracks the path the visitor takes on the website and where they entered.

Google AdWords Conversion Tracking
The purpose of Google AdWords Conversion Tracking is to allow the business to measure the effectiveness of AdWords ads. It uses cookies placed on the user’s computer, which remain active for 30 days.

Disabling cookies
If you want to manage or disable cookie settings, you can do so in your browser. This option is usually found in the browser’s toolbar under cookies/tracking functions. In general, you can configure what tracking functions you allow or block under Tools > Settings > Privacy.

If you do not want Google Analytics to report your visits, you can install the Google Analytics opt-out browser add-on. This add-on instructs the Google Analytics JavaScript not to send visit data to Google. If you have the add-on installed, you will also not participate in content experiments.

To disable Google Analytics for web activity, visit the Google Analytics opt-out page and install the browser add-on. For more information on installing or removing the add-on, please refer to your browser’s help section.

Principles of Data Processing
The Data Controller processes Personal Data in accordance with the principles of good faith, fairness, transparency, and applicable legislation, as well as the provisions of this Privacy Notice.
Personal Data that is essential for using the Services is processed by the Data Controller based on the User’s consent, and strictly for the purposes intended.

The Data Controller processes Personal Data only for the purposes specified in this Privacy Notice or in the applicable legislation. The scope of the processed Personal Data is proportionate to the purpose of the processing and shall not exceed it (data minimization).
We do not process Personal Data of individuals under the age of 18.
The Data Controller shall not transfer the Personal Data it processes to third parties other than the Data Processors specified in this Notice and, in certain cases referred to herein, to External Service Providers. An exception to this rule is the use of data in aggregated statistical form, which does not contain any other information capable of identifying the data subject, and therefore does not constitute data processing or data transfer.
In certain cases – such as an official court or police request, legal proceedings, suspected or actual infringement of copyright, property or other rights, a threat to the Data Controller’s interests, or to the provision of the Services – the Data Controller may make the Personal Data of the affected User available to third parties.
The Data Controller’s system may collect information about user activity, which cannot be linked to other data provided by the User during registration, nor to data generated when using other websites or services.
The Data Controller shall notify the data subject and all recipients to whom the Personal Data was previously disclosed of any correction, restriction, or deletion of the processed data. Such notification may be omitted if it does not infringe the legitimate interests of the data subject, in view of the purpose of the Data Processing.
The Data Controller ensures the security of Personal Data by implementing technical and organizational measures and establishing procedures to protect the collected, stored, and processed data, and to prevent accidental loss, unlawful destruction, unauthorized access, use, alteration, or disclosure. The Data Controller requires the same from all third parties to whom it transfers Personal Data.
In view of the relevant provisions of the GDPR, the Data Controller is not required to appoint a data protection officer.

The Data Controller is responsible for compliance with the principles.

Confidential data processing
We treat recorded data confidentially and take all necessary steps to ensure data security. Data is used in a way that is essential for the proper functioning of the Website. This includes, among other things, sending emails and SMS messages to you and to the contact details you provided, in which case the message is sent through the respective service provider.

We will never sell or lend your personal data to third parties for marketing purposes. However, we may disclose your personal data and other relevant information if required by subpoena, court order, or in the course of legal proceedings.

Access to personal data by employees
Our employees are granted access to personal data only to the extent necessary for their work. All access is logged, and access to data export functions is strictly limited.

Data transfer
We are entitled and obligated to transfer any available and properly stored Personal Data to the competent authorities if required by law or binding authority decision. The Data Controller cannot be held liable for such data transfers or any resulting consequences.

If the operation or utilization of our service is partially or fully handed over to a third party, we may transfer the Personal Data we process, in whole or in part, to this third party without requesting your separate consent, but only after proper prior notification. This transfer must not result in you being placed in a less favorable position than under the data processing rules set forth in the currently effective version of this Privacy Notice. In such a case, you will be given the opportunity, prior to the data transfer, to object to the data transfer before it takes place. In case of objection, your data cannot be transferred as specified in this section.

The Data Controller maintains a data transfer log for the purpose of verifying the lawfulness of data transfers and informing the data subject. This log includes the date of the data transfer, the legal basis and recipient of the transfer, the scope of the transferred personal data, and other details as required by applicable law.

Updating the Privacy Notice, following legal changes
The Data Controller regularly reviews and updates this Notice in accordance with changes in the legal environment and regulatory expectations. Users can always find the current version of the Privacy Notice under the “Privacy Policy” section of the website.

Further questions/answers
For any questions regarding data processing and/or data handling, you may contact us at any time via email at: hello@agm.hu

If you have a complaint about data processing, you may contact the Hungarian National Authority for Data Protection and Freedom of Information:

National Authority for Data Protection and Freedom of Information
Address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c
Phone: +36 (1) 391-1400, Fax: +36 (1) 391-1410
Website: http://www.naih.hu
Email: ugyfelszolgalat@naih.hu

If your rights have been violated, you may turn to the courts. Legal proceedings fall within the jurisdiction of the competent tribunal. You may choose to initiate proceedings at the court having jurisdiction over your place of residence or habitual residence may also be initiated before the court having jurisdiction over the place of the Data Controller’s registered office.
Upon your request, we will provide information about the available legal remedies and enforcement options.

Balmazújváros, 10 March 2025