PRIVACY NOTICE

www.partosnoblet.com

Date of publication: 31 October 2025

1. Preamble

 The objective of this privacy policy (the “Policy”) is to establish the principles and policy of the data protection and processing carried out by Partos & Noblet Ügyvédi Iroda (registered seat: 1051 Budapest, Vörösmarty tér 7/8.; tax number: 18189443-2-41; „the “Law Firm”, “we” or “us”), the owner of the website www.partosnoblet.com  (the “Website”). The Law Firm expresses its commitment to be bound by this Policy. This Policy sets out the principles of the processing of the personal data provided by the users of the Website and provides information for the data subjects on the processing of their personal data.

When establishing the provisions of the Policy, we have paid particular attention to the provisions of Regulation 2016/679 of the European Parliament and of the Council (the “GDPR”), Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information (the “Data Protection Act”), Act V of 2013 on the Civil Code (the “Civil Code”) and  Act CVIII of 2001 on Electronic Commerce and on Information Society Services (the “E-Commerce Act”).

2. The data controller

The Law Firm processes your personal data and, as a data controller, is liable for their lawful processing. You can contact us using the contact details provided below:

Name of the Law Firm: Partos & Noblet Ügyvédi Iroda
Postal address: 1051 Budapest, Vörösmarty tér 7/8.
E-mail address: office@hoganlovells.co.hu
Website: www. partosnoblet.com

3. Brief introduction of our data processing activities

• Cookies

In order to provide customized services, the Law Firm places a small data packet (known as a „cookie”) on the user’s computer. The purpose of using cookies is to ensure the highest possible level of operation for a website, to provide customized services and to improve user experience. The user is able to delete the cookie from their computer and may prohibit the use of cookies by adjusting the settings of their browser, furthermore, you can allow or disable the use of cookies in the pop-up window appearing on the Website. By blocking the cookies the user acknowledges that the operation of the website is incomplete without cookies.

• Contact

We provide the users with the opportunity to contact us and submit inquiries under the “Contact” section of the Website using the contact details (office@hoganlovells.co.hu email address) indicated therein. This function enables general communication and allows the Law Firm to respond to any questions that may arise. In the course of such communication, certain personal data of the data subject will become known to the data controller, should the data subject choose to initiate contact. The messages sent and delivered to the office@hoganlovells.co.hu email address shall be answered by a member of the Law Firm or its staff either from the same email address or by another email address used by the Law Firm, or where the data subject has voluntarily provided a telephone number for this purpose, by phone.

4. The legal basis of the processing

In the case of personal data collected from the data subject in connection with the operation of the Website as indicated is this notice, the lawfulness of processing the personal data is based on your consent as a data subject, in accordance with Article 6 (1) a) of the GDPR. The processing is based on freely given consent in each case. You are entitled to withdraw your consent anytime by indicating such intent in an email addressed to office@hoganlovells.co.hu email address.

Consent to the processing of personal data for the purpose of establishing contact is deemed to be granted by the data subject upon sending an email to the electronic contact address indicated on the Website, while in the case of cookies the consent is given by visiting the Website and by using its contents. By deleting the cookies from your computer and by adjusting the settings of your browser to block cookies you can withdraw such implied consent.

5. The scope of personal data, purposes and legal basis of data processing

Personal data	Purpose of data processing	Legal basis of data processing
Name, email address, any personal data voluntarily provided in the message by the data subject	Responding to data subject inquiries and contacting the data subject upon their request.	Consent of the data subject in accordance with Article 6(1)(a) of the GDPR.
IP address	Placement and storage of cookies	Consent of the data subject in accordance with Article 6(1)(a) of the GDPR.

6. Term of the processing

• Contact, message sending

Our Law Firm processes your personal data related to such communication until the withdrawal of your consent or until the receipt of your request for data deletion, whichever occurs first. In any case, your personal data will be deleted no later than 30 days following the conclusion of the exchange of correspondence.

• Cookies

Session cookies are deleted automatically by closing the browser. In the case of other type of cookies we process your personal data until the goal intended by the usage of the certain type of cookies is achieved.

7. Data processors

• IT operations related to the Website

The Law Firm, as the owner of the Website, has engaged Pro Business Kft (registered office: 1132 Budapest, Váci út 6. IV. floor, door 5/a; e-mail: office@probusiness.hu; website: www.prolawyer.hu) to perform IT-related tasks in connection with the Website, including its development and IT-related updates. Accordingly, Pro Business Kft qualifies as a data processor and has access to your personal data.

• Web hosting service provider related to the Website

The web hosting services related to the Website are provided to the Law Firm by Webenlét Kft (registered office: 1130 Budapest, Hajdu köz 7. A. building, ground floor, door 4; e-mail: info@webenlet.hu; website: www.webenlet.hu). Accordingly, Webenlét Kft qualifies as a data processor and has access to your personal data.

8. Automated decision making and profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s work performance, economic situation, health, personal preferences, interests, reliability, behaviour, location, or movements. The Law Firm does not engage in profiling activities and does not operate any automated decision-making systems.

9. Your rights and your right to remedies

• Your right as a data subject in connection with the processing of your personal data

• • Right to information and access to personal data

You are entitled to obtain from the Law Firm confirmation as to whether personal data concerning you are being processed, and, where that is the case, to access to the personal data and the following information:

• the purposes of processing;
• the categories of personal data concerned;
• the recipients or categories of recipient to whom the personal data have been or will be disclosed (in particular the data processors);
• the envisaged period for which the personal data will be restored;
• your rights in relation to the processing of your personal data;
• where the personal data was not collected from you, any available information as to their source;
• information regarding automated decision-making.

Under the applicable legislation we will provide the information on the processing of your personal data free of charge. We will respond to your request in writing within a month. However, if such request is manifestly unfounded or excessive, in particular because of its repetitive character, the Law Firm may either, taking into account the administrative costs of providing the information or communication or taking the action requested:

• charge a reasonable fee; or
• refuse to act on the request.

If, after paying the fee, it turns out that the processing was unlawful, or upon your request, we are obliged to correct your data, we will reimburse you the fees already charged.

If, despite our best efforts to protect your personal data, someone unlawfully gains access to, changes, transmits, publishes, erases, destroys or causes unintended erasure or injury to your personal data or otherwise processes them unlawfully, we, upon your request, will inform you about the conditions of such incident, including the date, the possible effects and our measures to prevent or to mitigate the consequences.

• • Right to rectification

If the data we process are not correct, we will rectify them upon your request without undue delay. You are also entitled have incomplete personal data completed, including by means of providing a supplementary statement.

• • Right to erasure

The Law Firm will erase your personal data without delay, if:

• the personal data are no longer necessary in relation to the purpose of sending the newsletter;
• the personal data have been unlawfully processed;
• the personal data have to be erased for compliance with a legal obligation concerning the Law Firm;
• the person exercising parental authority over a children under 16 has not consented to the processing;
• the Law Firm has made the personal data public.

You are also entitled to request the erasure of your personal data by withdrawing the consent you previously gave to us. However, in such case we may refuse to further provide you certain services and/or certain services will not be available to you hereinafter.

Instead of erasing, we will block your personal data if you so request or if it can be assumed that erasure would have an impact on your legitimate interests. We do not process blocked data for the above purposes. We only process blocked data for the purpose that excluded the possibility of erasure.

• • Right to restriction of processing

Data processing may be restricted if:

• you contest the accuracy of the personal data, for a period enabling the Law Firm to verify the accuracy of the personal data;
• the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
• the Law Firm no longer needs your personal data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims;
• you have objected to processing, pending the verification whether the legitimate grounds of the Law Firm override yours.

For the duration of the evaluation of your objection, but not more than for 5 days, the Law Firm will suspend the processing, assess the merits of your objection and make a decision, about which the Law Firm will inform you without delay.

If the objection is justified, the Law Firm will restrict your data, i.e. only restoring as a means of processing if

• you consent to the processing;
• your data is necessary for enforcing your legal claims;
• processing becomes necessary in order to the defend the rights of a natural or a legal person; or
• processing is ordered by law in the public interest.

If you requested your personal data to be restricted, the Law Firm will notify you prior to the lifting of the restriction.

• • Right to data portability

You have the right to receive the personal data concerning you, which you have provided to the Law Firm, in a structured, commonly used and machine-readable format (e.g. .doc or .pdf) and have the right to transmit those data to another controller without hindrance from the Law Firm.

• • What happens and what can you do if we reject your request?

If the Law Firm rejects your request for the correction, restriction of erasure of your personal data, within 1 month of receiving your request we will inform you in writing why we could not comply with your request and we will inform you about your possibilities of judicial remedy and that you may submit a notice to the Nemzeti Adatvédelmi és Információszabadság Hatóság (the National Authority for Data Protection and Freedom of Information). If you agree, we will send our reply via e-mail.

• • What are your rights if you think the data processing is unlawful?

If you have some concerns regarding the lawfulness of the data processing, you have the right to object to it. Your objection should include a request for us to stop processing your data and to erase them.

If you object to the processing of your data, the Law Firm will examine the reasons of your objection within one month and will make a decision, regarding which the Law Firm notifies you in writing.

If we find your objection to be valid, we stop every data processing operation, block the data concerned and inform about the objection and the following measures taken everyone to whom we transmitted the personal data concerned by the objection. These recipients should also take the necessary actions for your objection to prevail. If you disagree with our decision or if the Law Firm fails to comply with the abovementioned one-month deadline, you may turn to the courts.

• • What are the legal remedies available to you?

If you find that during the processing of your data our Law Firm breaches the provisions of the GDPR, it is your right as a data subject to lodge a complaint before a supervisory authority (i.e. before any public authority set up by any of the EU member states in accordance with section 51 of the GDPR), in particular in the member state of your habitual residence, place of work or place of the alleged infringement. In Hungary, the supervisory authority set up in accordance with section 51 of the GDPR is the Nemzeti Adatvédelmi és Információszabadság Hatóság (Hungarian National Authority for Data Protection and Freedom of Information; “NAIH” or “the Authority”). Accordingly, in the sections below we inform you about complaint procedure of NAIH. However, please note that given the reasons mentioned above, you nevertheless have the right to lodge a complaint before any supervisory authority set up by one of the EU member states, not just before the Authority.

• • Notification to the Hungarian National Authority for Data Protection and Freedom of Information

Compliance with data protection legislation is supervised by the Hungarian National Authority for Data Protection and Freedom of Information. If you find that our data processing does not comply with the applicable law, or there is an imminent danger of non-compliance, you can lodge a complaint before the Authority through the following contacts:

Name of the authority: Nemzeti Adatvédelmi és Információszabadság Hatóság
Address: H- 1055 Budapest, Falk Miksa utca 9-11.
Postal address: H-1363 Budapest, Pf.:9.
E-mail address: ugyfelszolgalat@naih.hu
Phone number: +36 1 391 1400
Fax number: +36 1 391 1410

For further information regarding data protection go to the website of the Authority: http://naih.hu/

Please note that in the case of a personal data breach (i.e. a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed), the Law Firm shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the Authority. If the personal data breach is likely to result in a high risk to the rights and freedoms of data subjects, the Law Firm shall communicate the personal data breach to you as a data subject without undue delay.

• • Judicial proceedings for pursuing claims

If you find that your right to privacy has been infringed by us, or our decision regarding your objection was incorrect or we did not reply to your objection, you have the right to turn to the courts. You may also decide to initiate the proceeding before the tribunal of your domicile or habitual residence.

Furthermore, in accordance with conditions laid down by law, if our unlawful data processing or breach of security requirements caused damages to you, you may enforce your claim for compensation against the Law Firm before courts. In addition, if we violated your rights relating to personality, you shall be entitled to restitution, which is also enforceable before courts.

In this respect, we are responsible for our data processors.