The purpose of this privacy policy is to present what personal data we process during the use of the Studio Paolo website, for what purpose, on what legal basis, for how long, and what rights the data subjects have.
Personal data is processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council, i.e., the General Data Protection Regulation (GDPR).
Data Controller Information
Data Controller's name: Balázs Bóka sole proprietor
Registration number: 53017835
Tax number: 69323407-1-37
EU VAT number: HU69323407
E-mail: balazs@studiopaolo.hu
Website: https://www.studiopaolo.hu
The data controller, under the Studio Paolo brand name, is engaged in designing and developing Framer websites, as well as providing related creative and digital services.
Principles of Data Processing
During data processing, we strive to process only personal data that is necessary to achieve the given purpose. We process data lawfully, fairly, and in a transparent manner. During data processing, we take the following principles into particular consideration:
purpose limitation,
data minimization,
accuracy,
storage limitation,
integrity and confidentiality,
accountability.
Data Processing via Contact Form
It is possible to fill out a contact form on the website. The purpose of the form is to allow interested parties to contact us, request a quote, or briefly introduce their planned project.
Processed personal data:
last name,
first name,
e-mail address,
link to the provided website, if the data subject provides one,
content of the project or quote request,
selected budget / cost frame category,
time of message submission,
additional data provided voluntarily later during communication.
The purpose of data processing:
ensuring contact,
answering quote requests,
preliminary assessment of project needs,
conducting business communication,
preparation for subsequent contracting.
The legal basis of data processing:
The legal basis for data processing is primarily Article 6 (1) (b) of the GDPR, meaning processing is necessary in order to take steps prior to entering into a contract, provided the data subject requests a quote or expresses interest in a service.
If the inquiry constitutes general business interest or communication, the legal basis for data processing is Article 6 (1) (f) of the GDPR, meaning the legitimate interest of the data controller in managing and answering incoming messages.
Data retention period:
Data related to the quote request or contact will be retained for a maximum of 12 months from the last communication, unless a contractual relationship is established between the data subject and the data controller.
In the event a contractual relationship is established, data will be retained for the period necessary for the performance of the contract, as well as for the fulfillment of accounting, taxation, and legal obligations.
E-mail Communication
If the data subject contacts us via e-mail, we process the personal data provided in the e-mail for the purpose of handling and answering the inquiry.
Processed personal data:
name,
e-mail address,
content of the message,
additional data provided voluntarily by the data subject.
The purpose of data processing:
maintaining contact,
answering inquiries and quote requests,
business communication,
preparation or fulfillment of a contract.
The legal basis of data processing:
Article 6 (1) (b) of the GDPR, if the data processing is related to steps prior to entering into a contract or the performance of a contract. In other cases, based on Article 6 (1) (f) of the GDPR, the legitimate interest of the data controller in managing and answering incoming messages.
Data retention period:
E-mail inquiries are retained for a maximum of 12 months from the last communication, unless the communication becomes part of contractual or accounting documentation.
Framer Website and Hosting Service
The website was created on the Framer platform and operates through Framer's infrastructure. Framer may act as a data processor in connection with the operation, display, form management, and technical servicing of the website.
Service provider: Framer B.V. and its associated service providers Nature of service: website builder platform, hosting, technical infrastructure, form management According to Framer's data processing agreement, Framer may act as a data processor or sub-processor during the service used by the client, and processes personal data according to the client's instructions.
Framer may use hosting and infrastructure providers, among others, as subcontractors. For example, Amazon Web Services is included on Framer's public list of sub-processors as hosting infrastructure.
Website Analytics
We use Framer's built-in analytics solution on the website. The purpose of Framer Analytics is to provide basic, aggregated statistical information about website traffic and performance.
According to Framer's information, Framer Analytics does not use cookies and does not create persistent visitor identifiers. Based on this, the use of Framer's built-in analytics alone does not require a cookie consent banner.
We currently do not use the following on the website:
Google Analytics,
Google Tag Manager,
Meta Pixel,
LinkedIn Insight Tag,
Hotjar,
Microsoft Clarity,
remarketing or advertising tracking codes.
If we introduce a third-party analytics, marketing, or remarketing tool in the future, we will update this policy and apply a cookie consent solution if necessary.
Use of Cookies
We currently do not use our own or third-party cookies on the website that serve the purpose of marketing, remarketing, behavioral advertising, or detailed visitor tracking.
The technical elements necessary for the operation of the website are provided by Framer. If Framer or the browser processes data essential for the operation of the website for technical reasons, their sole purpose is to ensure the secure and proper functioning of the website.
Since there are currently no strictly unnecessary cookies requiring consent or third-party marketing tracking on the website, we do not consider the use of a separate cookie banner necessary at this time.
Data Transmission, Data Processors
We do not sell personal data to third parties, nor do we transfer it for marketing purposes.
The following service providers may access the data as data processors, to the extent necessary for the operation of the service:
Framer
Website builder, hosting, and technical infrastructure service provider.
E-mail service provider
For the purpose of e-mail communication and receiving form submissions.
Accountant or tax service provider
Only in the event that a contractual or billing relationship is established with the data subject.
Data processors may not make independent decisions regarding the purpose of data processing; they may process data solely in accordance with the instructions of the data controller.
International Data Transfers
Framer and certain of its sub-processors may also use service providers outside the European Economic Area. In such cases, data transfer takes place with guarantees permitted by the GDPR, such as an adequacy decision, standard contractual clauses, or another lawful data transfer mechanism.
Automated Decision-Making and Profiling
We do not perform automated decision-making based on personal data submitted through the website, nor do we create profiles that would produce legal effects concerning the data subject or similarly significantly affect them.
Newsletter and Direct Marketing
There is currently no newsletter subscription operating on the website, and we do not use the data provided in the contact form to send newsletters or mass marketing communication.
If we introduce a newsletter or direct marketing communication in the future, we will provide separate information and, if necessary, secure separate consent for it.
Rights of the Data Subjects
The data subject is entitled to the following rights in connection with the processing of their personal data:
Right of access
The data subject may request information as to whether we process their personal data, and if so, what data, for what purpose, on what legal basis, and for how long.
Right to rectification
The data subject may request the rectification or completion of inaccurate or incomplete personal data.
Right to erasure
The data subject may request the erasure of their personal data if the purpose of data processing has ceased, the data processing is unlawful, or other statutory conditions exist.
Right to restriction of processing
The data subject may request the restriction of data processing, for example, if they contest the accuracy of the data or object to the data processing.
Right to object
The data subject may object to data processing based on legitimate interest.
Right to data portability
If the data processing is based on consent or a contract, and is carried out by automated means, the data subject may request to receive the data they have provided in a structured, commonly used, machine-readable format.
Right to lodge a complaint
The data subject has the right to lodge a complaint with the National Authority for Data Protection and Freedom of Information (NAIH). NAIH also publishes a separate guide on exercising data subject rights.
Legal Remedies
If the data subject believes that the processing of their personal data violates the provisions of the GDPR or other data protection legislation, they may primarily contact the data controller at the following contact details:
E-mail: balazs@studiopaolo.hu
The data subject may also lodge a complaint with the National Authority for Data Protection and Freedom of Information.
National Authority for Data Protection and Freedom of Information
Headquarters: 1055 Budapest, Falk Miksa utca 9-11.
Mailing address: 1363 Budapest, Pf. 9.
Phone: +36 (1) 391-1400
E-mail: ugyfelszolgalat@naih.hu
Website: https://www.naih.hu
Based on the contact details published on NAIH's official contact page, the authority also provides the possibility for electronic case initiation.
Data Security
The data controller implements appropriate technical and organizational measures to ensure that personal data is protected against unauthorized access, alteration, transmission, disclosure, erasure, or destruction.
The technical operation of the website is provided by the Framer platform. According to Framer's information, they apply security measures in line with industry standards to protect personal data.
Modification of the Policy
The data controller reserves the right to modify this privacy policy, especially if the operation of the website, the scope of service providers used, the purposes of data processing, or the relevant legislation change.
The privacy policy currently in effect is available on the website.