Privacy Notice

1. The Data Controller

Data Controller

Márton Horváth

Business Name

DigiXRAY Labs Web Development & Web Design

Brand Name and Website

Digital Trail – https://digiosveny.hu/

Headquarters and mailing address

Wallstraße 37, 55122 Mainz, Germany

Email

hello@digiosveny.hu

Phone

+36 70 802 4667

Data protection inquiries, requests from data subjects, objections, or withdrawals of consent may be submitted using the contact information provided above. The data controller has not appointed a separate data protection officer.

2. Source of Data and Principles of Data Processing

Data is primarily provided by the data subject when contacting us, requesting a quote, during a website audit, a project needs assessment, via email, phone, AI chat, a customer service ticket, or in the course of fulfilling a contract. Technical data may be automatically generated by the browser, the web hosting service, the security system, and—with appropriate consent—by analytics or advertising services.

If the data does not come directly from the data subject—for example, from an organizational contact person, a file provided by the Client, a public business source, or a technical service provider— the data controller shall use only the data necessary for the specific matter and shall provide the information required under Article 14 of the GDPR within the applicable time limit, unless a lawful exemption applies.

The data controller processes personal data in a manner that is limited to the purpose, to the extent necessary, accurately, securely, and for a period appropriate to the purpose. It is not necessary to submit special categories of personal data, passwords, credit card information, copies of documents, or other unnecessarily sensitive information; such data must not be provided in the free-text fields of forms or in the AI chat.

3. Legal Bases Applied

In the case of data processing based on consent, consent may be withdrawn at any time with future effect. Withdrawal does not affect the lawfulness of prior data processing.

4. Web Hosting, Storage, and Security Logs

Hosting, infrastructure, and security service providers contracted to support the website’s operation may be used. When the website is accessed, the following information may be collected: IP address, access time, requested URL, referring page, browser and device characteristics, response code, and security events.

As part of automated abuse and spam protection, technical browser, device, and network data may be transmitted to the relevant security provider.

5. Contact, Audit, and Needs Assessment Forms

In the context of web forms and direct inquiries, the following data may be processed: name, email address, phone number, website address, message, project objective, service request, time of submission, source page, and technical metadata related to the submission.

Objective: identification, responding to inquiries, preparing proposals or audits, assessing needs, and documenting the inquiry and subsequent project.

Legal Basis: Article 6(1)(b) of the GDPR, if the inquiry is a step prior to entering into a contract; otherwise, Article 6(1)(f), legitimate interest in handling inquiries. Optional marketing may only take place with separate consent.

6. Communication via Email, Phone, and Social Media

When contacting us via email or phone, we may process the sender’s or caller’s name, email address, phone number, the content and date/time of the message or conversation, delivery and error information, as well as any replies and related attachments.

Objective: responding to inquiries, submitting quotes, fulfilling contracts, handling complaints, providing customer service, and maintaining verifiable records of business communications.

Legal Basis: Article 6(1)(b), (c), or (f) of the GDPR, depending on the nature of the matter. In the technical delivery of the email, the hosting, email account, or SMTP service provider may act as a data processor.

When you open a link to Facebook, Messenger, or WhatsApp, the relevant third-party service provider may process technical and account data at its own discretion. Digiösvény does not forward the data provided on the form to these service providers before the third-party service opens.

7. Client and Project Management

Inquiries can be recorded in the customer and project management system. The system allows you to manage contact information, basic case or project data, communication history, consent status, case status, and internal administrative notes necessary for fulfillment.

Objective: Consistent handling of inquiries and projects, client communication, order fulfillment, quality assurance, and business administration.

Legal Basis: Article 6(1)(b), (c), or (f) of the GDPR, depending on the specific data and purpose. Data may be used for marketing purposes only if there is an appropriate legal basis.

8. Customer Service Case Management

The customer service interface allows you to manage the name, email address, case ID, subject, message, category, priority, status, attachments, replies, timestamp, and the required technical log.

Objective: Receiving, investigating, responding to, escalating, and documenting the resolution of support, complaint, billing, data protection, or security issues.

Legal Basis: Article 6(1)(b), (c), or (f) of the GDPR, depending on the nature of the matter. Customer service data may not be used for sales or advertising purposes without a separate legal basis.

Do not send unnecessary passwords, complete credit card information, sensitive personal data, or other disproportionately sensitive information in attachments.

9. AI Assistant and AI-Powered Processing

The website and service processes may use AI-powered features to provide the responses, summaries, pre-screening, or task support requested by the user.

This process allows for the handling of the message, the conversation context, the session’s technical identifier, voluntarily provided contact or project information, as well as summary or categorization data necessary for processing the request.

• The direct communication interface indicates when the user is communicating with an AI system.
• AI responses may be incorrect; human review is required for contractual, legal, financial, data protection, or safety-critical decisions.
• Do not enter passwords, health information, identification documents, payment information, or other particularly sensitive information into the AI chat.
• When using an external AI service provider, the content necessary for operation may be transferred to the service provider in accordance with the applicable data processing and data transfer terms.

Legal Basis: for functions requested by the user, Article 6(1)(b) of the GDPR; for customer service and process security, Article 6(1)(f); for optional features or analytics, Article 6(1)(a), as well as Section 25 of the TDDDG, as applicable.

AI-based recommendations do not constitute independent, final business decisions.

10. Consent Management

The consent management system manages the selection of non-essential technologies. Within this framework, it can manage the consent ID, category, status, date, and time, as well as the technical data necessary to verify the decision.

Objective: Conducting, recording, and verifiably documenting the election.

Legal Basis: The processing of consent pursuant to Section 25 of the TDDDG, as well as Article 6(1)(c) and (f) of the GDPR, for the purposes of complying with a legal obligation and demonstrating consent.

11. Statistics, Behavioral Analysis, and Marketing

Statistical, usability, advertising, and conversion tracking services—provided they are actually configured and active—may only be used after the appropriate consent category has been enabled.

The detailed technology categories and durations are listed in the In the Cookie Policy and can be found on the consent management interface. Unnecessary measurement codes must be technically blocked until the appropriate consent is granted.

12. Browser Notifications and Language Preferences

Browser Notification

Browser notifications may only be sent after obtaining specific permission from the browser and—where necessary—the appropriate consent. The subscription ID, the device’s technical data, and the notification interaction may be processed. Legal basis: Article 6(1)(a) of the GDPR. Permission may be revoked at any time in the browser or operating system settings.

Language preference

A local identifier or cookie may be used to store the language selection. The purpose is to ensure that the language selected by the user is applied. The legal basis for this, depending on the requested function, is Article 6(1)(b) or (f) of the GDPR, as well as the necessity exception under Section 25(2) of the TDDDG.

13. Recipients, Data Processors, and Third Countries

As necessary, the following groups of recipients may have access to personal data:

• hosting, infrastructure, and security service providers;
• e-mail, communications, maintenance, backup, and technical service providers;
• service providers that handle consent, send notifications, and provide the feature that is actually activated;
• statistical, marketing, or AI service providers, but only if the appropriate function and legal basis exist;
• an accountant, legal representative, insurance company, government agency, or court, if justified by a legal obligation or the enforcement of a claim.

As a general rule, the core data of the content management, form, customer, and customer service systems operating on the website can be managed in a hosting environment under the service provider’s control; certain additional features may utilize a separate service provider.

Transfers outside the European Economic Area may only take place with appropriate safeguards in accordance with Chapter V of the GDPR.

14. Retention Periods

Upon expiration of the retention period, the data must be deleted or irreversibly anonymized, unless there is a further lawful basis for retention.

15. Rights of the Data Subject

Under the terms of the GDPR, you may request:

• information and access to processed data;
• correcting inaccurate data and supplementing missing data;
• erasure or restriction of data processing;
• data portability in the case of automated data processing based on consent or a contract;
• objection to data processing based on Article 6(1)(f) of the GDPR;
• withdrawal of consent for the future;
• a request for human intervention if, under applicable law, an automated decision would affect the individual.

The request is the hello@digiosveny.hu may be sent to the address provided. The data controller may request additional information, to the extent necessary, to verify the identity of the individual and the validity of the request.

Right to File a Complaint

A complaint may be filed, in particular, with the authority with jurisdiction over the data controller’s registered office:

Authority

The Data Protection and Freedom of Information Commissioner of the Land of Rhineland-Palatinate

Visiting Address

Hintere Bleiche 34, 55116 Mainz, Germany

Mailing Address

P.O. Box 30 40, 55020 Mainz, Germany

Phone

+49 (0) 6131 8920-0

Email

poststelle(at)datenschutz.rlp.de

Website

https://www.datenschutz.rlp.de/

The data subject may also contact another EU supervisory authority based on their usual place of residence, place of work, or the location of the alleged infringement.

16. Profiling and Automated Decision-Making

Statistical or marketing systems based on consent may create pseudonymized interest or campaign profiles. Systems that support administrative processes may categorize inquiries to ensure they are handled appropriately.

Digiösvény does not use any fully automated decision-making processes that would have legal effects on the data subject or similarly significantly affect them. Offers, contracts, complaints, data protection requests, payment issues, and significant customer decisions are all subject to human review.

16/A. Webinars: Registration, Participation, and Recordings

Digiösvény offers online professional presentations, 15-minute “Just in Time” access, a waiting room, and on-demand viewing through the WebinarPress-based webinar system. Registration and participation take place on the central webinar page at digiosveny.hu; the hello.digiosveny.hu interface may be part of the related customer journey. This process is not the same as booking an appointment through Amelia.

Data Processed: the name, email address, and message or question provided by the registrant; details regarding the selected event, registration and access status, date and time, and the delivery of confirmation and reminder notifications; session and security data required for participation, the waiting room, and on-demand viewing (e.g., IP address, device/browser characteristics, access log).

Purpose and Legal Basis: registering for the requested webinar, granting access, providing participation information, sending reminders, handling questions, and making the webinar available for replay: Article 6(1)(b) of the GDPR; technical protection and prevention of misuse: Article 6(1)(f) of the GDPR. The transactional emails required for the event are not the same as marketing newsletters; the latter require a separate legal basis and, if consent is given, such consent may be withdrawn.

Recording and External Video Services: A recording of the presentation may be available for viewing. A participant’s image, voice, name, or public comments will not automatically become part of the published recording; if such a recording is made, you will be notified separately in advance. When using a YouTube video, personal or technical data may be transmitted to Google’s service; external embedded players, cookies, and analytics features that are not strictly necessary operate in accordance with applicable consent requirements, and in the event of a transfer outside the EEA, safeguards in accordance with Chapter V of the GDPR are required.

Retention and Rights: We process registration and participation data for the purpose of organizing the event, until the related administrative procedures are completed, or until a legal obligation or a justifiable legal claim exists. The retention of technical logs, which is necessary for a short period of time, is for security purposes. Data subjects may exercise their rights and contact us as described in the relevant sections of this notice.

Webinar Supplement: WEB-LEGAL-2026-10-16-v1 • Effective: October 16, 2026 • Previous provisions remain in effect.

17. Amendments to the Prospectus and Related Documents

This privacy policy may be amended if there are changes to the service, the technology used, the list of data processors, or legal requirements. The current version is available on this page, with the date of any material changes indicated.