Privacy Policy
1. Purpose and Scope of the Privacy Policy:
The purpose of this Privacy Policy is to inform data subjects – Clients – in a transparent manner and in compliance with applicable laws, particularly Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR) and Act CXII of 2011 on Informational Self-Determination and Freedom of Information (Info Act), regarding the processing of their personal data.
The scope of this notice applies to the data processing carried out during the use of the services of Zsuzsanna Regina Szabó, sole proprietor. Processing of personal data is necessary for booking appointments for services available on the www.coffeeandclarity.hu website, for issuing invoices as consideration for the services, for fulfilling obligations arising from this legal relationship, and for enforcing legitimate claims.
2. Definitions:
Data Controller: Zsuzsanna Regina Szabó, sole proprietor, who independently or jointly with others determines the purposes and means of the processing of personal data.
Data Processing: technical tasks performed on personal data in connection with data processing operations, regardless of the method, means, or location of application.
Data Processor: a legal entity that processes personal data on behalf of and for the Data Controller.
User (Client): natural persons browsing the website who are data subjects in the data processing.
Data Subject’s Consent: a voluntary, specific, informed, and unambiguous indication of the data subject's wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.
Professional Confidentiality: The Data Controller handles secrets, life stories, and personal information shared during consultations under strict professional confidentiality.
Professional Notes: The Data Controller may make notes about discussions solely in an anonymous manner (in a form unsuitable for identification, using initials or codes) for the purpose of her own professional development and supervision. Legally, these notes do not constitute personal data as connecting them to the Client is impossible for any third party.
Special Categories of Data (Sensitive Data): The Data Controller does not collect or maintain in digital databases any special categories of personal data under Article 9 of the GDPR (health status, sexual life, religious beliefs, etc.). If the Client shares such information during discussions, it is considered solely as oral communication and is subject to strict professional confidentiality. The Data Controller uses so-called cookies to collect technical data necessary for the proper functioning of the website and relating to website visitors.
Cookie: an anonymous visitor identifier that the Data Controller places on and reads back from the device used by data subjects viewing the website during browsing. A cookie is a unique series of data used to save settings applied on the website, track from where and how a user visited the website, and observe what operations were performed there. This data series alone is in no way capable of identifying the user and contains no personal data; its function is solely to facilitate browsing. The User may decide whether to permit the use of cookies.
3. Data Controller:
Name: Zsuzsanna Regina Szabó, sole proprietor
Registered Seat: 1139 Budapest, Fiastyúk utca 26/G, Hungary
Phone Number: +36 30 447 6016
Registration Number: 62545280
E-mail Address: hello@coffeeandclarity.hu
Website: www.coffeeandclarity.hu
4. Legal Basis, Purposes, and Duration of Data Processing
4.1. Contact and Communication
Purpose of Data Processing: Communication with interested Users, scheduling appointments.
Scope of Data Processed: Name, e-mail address, phone number, message text.
Legal Basis for Data Processing: The data subject's voluntary consent (GDPR Article 6(1)(a)).
Duration of Data Processing: Until the conclusion of the contact, but at most until the withdrawal of consent or a request for erasure.
4.2. Performance of Engagement Contract (Service Provision)
Purpose of Data Processing: Organization and records of mental hygiene supportive conversations, fulfillment of contractual obligations.
Scope of Data Processed: Client's name, contact details, agreed appointment dates.
Legal Basis for Data Processing: Performance of a contract to which the Client is a party (GDPR Article 6(1)(b)).
Duration of Data Processing: Until the lapse of civil law claims arising from the engagement contract (5 years from the termination of the contract according to the Civil Code).
4.3. Invoicing and Fulfillment of Legal Obligations
Purpose of Data Processing: Fulfillment of statutory invoice issuance and billing obligations.
Scope of Data Processed: Client's billing name, billing address, tax identification number (if applicable), amount paid.
Legal Basis for Data Processing: Compliance with a legal obligation (GDPR Article 6(1)(c); Accounting Act and VAT Act).
Duration of Data Processing: Pursuant to Section 169 of the Accounting Act, 5 years from the issuance of the invoice.
5. Data Transfer
The Data Controller does not transfer data to third parties. The Data Controller transfers data exclusively to authorities, in the case of a legal obligation.
6. Data Processors
All personal data processed by the Data Controller is obtained directly from the data subjects. Accordingly, the Data Controller stores in databases and uses for specified purposes only those personal data provided by the data subjects themselves. The Data Controller does not collect personal data from any other sources, nor does she obtain personal data via data transfers from third parties.
Personal data may be accessed to a limited extent by businesses providing services to the Data Controller who qualify as data processors.
Within the scope of contract performance, your personal data is also processed for the purpose of delivering information regarding the use of the provided service to Users, including sending reminder e-mails. These informational e-mails do not constitute newsletters, marketing, or promotional communications, and sending them does not require separate consent from data subjects. For technical operation and fulfillment of legal obligations, the Data Controller engages the following data processors:
Hosting Provider: Squarespace Inc., 225 Varick Street, 12th Floor, New York City, 10014, USA
Invoicing System: Számlázz.hu (KBOSS.hu Kft.), 1031 Budapest, Záhony utca 7/D, Hungary (invoice generation).
Accountant: Lorien Kft., 1157 Budapest, Nyírpalota út 77, Hungary.
7. Data Security
Within the scope of data processing and data handling activities, the Data Controller ensures the security of data and implements technical and organizational measures to enforce legal obligations as well as other data protection and secrecy rules. Through appropriate measures, she protects processed data, in particular against unauthorized access, alteration, transfer, disclosure, deletion, or destruction, as well as against accidental destruction, damage, or rendering inaccessible due to changes in technology used.
8. Rights of Users Related to Data Processing
During the period of data processing, the Client is entitled at any time to exercise the following rights by issuing a statement sent to hello@coffeeandclarity.hu:
Right to Information and Access: You may request information on whether the Data Controller processes your personal data and, if so, gain access to it.
By reading this Privacy Policy, the User may obtain information about data processing at any time. At the User's request, oral information may also be given, provided that the User's identity has been verified by other means. The User may request information during or after their involvement in data processing.
The User has the right to access the data processed about them. Upon such a request, the Data Controller shall inform them whether data processing regarding the User's personal data is in progress, as well as about all relevant circumstances regarding the specific data processing.
Right to Erasure: The User may request the deletion of your data (except for invoicing data required by law). The User is entitled to request the Data Controller to erase personal data concerning them without undue delay, and the Data Controller is obliged to erase personal data concerning the User without undue delay.
Right to Rectification: The User may request the correction or completion of inaccurate data.
Right to Restriction of Processing: The User may request the restriction of processing if they contest the accuracy of the data or the lawfulness of the data processing. Upon request by the User, the Data Controller shall restrict data processing.
Right to Data Portability: The User may request the release of provided data in a machine-readable format and request that this data be transmitted to another controller without hindrance from the controller to which the personal data was provided.
Right to Object: The User has the right to object at any time, on grounds relating to their particular situation, to the processing of their personal data based on legitimate interests.
9. Amendments to the Privacy Notice
The Data Controller reserves the right to unilaterally amend this Privacy Notice at any time.
10. Legal Remedies
If the Client considers that the processing of their personal data violates applicable legal provisions:
Please contact the Data Controller first at hello@coffeeandclarity.hu so that the complaint can be resolved promptly and amicably.
You may lodge a complaint with the National Authority for Data Protection and Freedom of Information (NAIH):
Address: 1055 Budapest, Falk Miksa utca 9-11., Hungary (Mailing address: 1363 Budapest, Pf. 9.)
E-mail: ugyfelszolgalat@naih.hu
Data subjects may also enforce their rights before a court of law.
July 8, 2026