First published: 1 August 2024 · Current version effective: 3 October 2026

This policy is based on Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation, hereinafter: GDPR) and Hungarian Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information (Infotv.).

1. Controller

Tumzel Service Korlátolt Felelősségű Társaság (a Hungarian limited liability company; hereinafter: Tumzel Service Kft.)

• Registered office: 6300 Kalocsa, Eperföld utca 9., Hungary
• Company registration number: 03-09-134475
• Tax number: 28988140-2-03
• Represented by: Gábor Kovács, Managing Director
• Email (including data protection matters): info@tumzel.hu

Kelsia NodeMind is a product of Tumzel Service Kft.; the website is operated by Tumzel Service Kft.

2. Contacting us and arranging a consultation

When you fill in the form on the Contact page or send an email to info@tumzel.hu, we process the following data:

• name, company name and email address — mandatory on the form; without them we cannot reply;
• phone number and message — optional;
• the language of the form and the address of the page from which you sent it — recorded automatically by the form processing system;
• in the case of email, the data contained in your message.

Purpose: to reply to your enquiry, to arrange and hold the consultation and — if both parties wish — to prepare a proposal for cooperation.

Legal basis:

• if you contact us on behalf of a company: Article 6(1)(f) GDPR (legitimate interests). Our legitimate interest is to reply to the contact persons of companies that approach us and to prepare a business relationship. The processing relates to the contact you initiated and covers only the data required for it;
• if you contact us as a sole trader or in your own name: Article 6(1)(b) GDPR (steps taken at your request prior to entering into a contract).

By ticking the checkbox on the form, you confirm that you have read this policy. The processing is not based on consent.

Retention period: if no cooperation results from your enquiry, we delete the data one year after the last contact. If cooperation results, we keep the data for the duration of the business relationship and, where the law requires longer retention (for example for accounting records), for the period specified there.

How your data is handled: the data entered in the form is received by the website's hosting provider and forwarded by email to info@tumzel.hu; once the form has been sent successfully, you receive an automatic confirmation email. We then record enquiries in an internal register stored on a password-protected computer of Tumzel Service Kft. Access to the data is limited to those employees of Tumzel Service Kft. who need it to respond to your enquiry.

We do not use the data for newsletters or any other marketing purposes, and we do not disclose it to third parties — except to the processor named in section 6, or where required by law.

3. Bot protection on the Contact page (Google reCAPTCHA)

The form on the Contact page is protected against automated (bot-generated) messages by the Google reCAPTCHA service. For this purpose, when you open the Contact page and during the check, your browser connects to Google's servers and transmits technical data — such as your IP address, browser and device information, and data about your interactions with the page; Google may also set cookies. reCAPTCHA is loaded only on the Contact page.

Legal basis: Article 6(1)(f) GDPR — our legitimate interest in protecting the form against unsolicited automated messages and misuse.

Provider: Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). Google processes the data in accordance with its own privacy policy: policies.google.com/privacy

4. Fonts (Google Fonts)

The website's fonts are loaded from the servers of the Google Fonts service. Technically, this requires your browser to connect to Google's servers, in the course of which Google receives your IP address and technical information about your browser. According to Google, Google Fonts does not set cookies and does not use the data for profiling.

Legal basis: Article 6(1)(f) GDPR — our legitimate interest in a consistent, legible presentation of the website.

Provider: Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). More information: developers.google.com/fonts/faq/privacy

5. Transfers outside the European Union

When Google reCAPTCHA and Google Fonts are used, data may also reach the servers of Google LLC (United States). Google LLC is certified under the EU–U.S. Data Privacy Framework; under the European Commission's adequacy decision of 10 July 2023, such companies ensure an adequate level of protection. In all other processing, we do not transfer personal data outside the European Economic Area.

6. Hosting, form processing and email (processor)

The website hosting, the processing of the Contact form and the info@tumzel.hu mailbox are provided by the domdom.hu service as a processor under a contract with Tumzel Service Kft. (for its details, see the Legal Notice). When the website is accessed, the server records technical log data (IP address, time, address of the page accessed, browser information), which, according to the provider, it retains for 30 days.

Legal basis: Article 6(1)(f) GDPR — our legitimate interest in the secure and uninterrupted operation of the website.

The provider's privacy policy (in Hungarian): domdom.hu/adatvedelmi-tajekoztato

7. Cookies

The website's own cookies are necessary for it to function; we do not use analytics, advertising or social media cookies. Cookies that are strictly necessary for the website to function do not require consent (Section 155 of Hungarian Act C of 2003 on Electronic Communications).

You can delete or block cookies at any time in your browser settings; in that case, some functions of the website (such as sending the form) may not work.

8. Data security

We receive data over an encrypted connection (HTTPS), restrict access to the persons who need it to perform their tasks, and store the internal register on a password-protected device.

9. Your rights

While your data is being processed, you may at any time request:

• information about and access to your data (Article 15 GDPR);
• rectification of your data (Article 16);
• erasure of your data (Article 17);
• restriction of processing (Article 18);
• where the processing is based on Article 6(1)(b) GDPR: receipt of the data you provided in a structured, machine-readable format, or its transmission to another controller (data portability, Article 20).

Right to object: where the processing is based on legitimate interests (Article 6(1)(f) GDPR), you may object to it at any time on grounds relating to your particular situation (Article 21). We will then stop the processing, unless there are compelling legitimate grounds that override your interests, rights and freedoms, or the processing is necessary for the establishment, exercise or defence of legal claims.

You can send your request to info@tumzel.hu or by post to our registered office. We will respond without undue delay and in any event within one month; where justified, this period may be extended by a further two months, in which case we will inform you within the original period. Requests are handled free of charge.

We do not carry out automated decision-making or profiling.

10. Remedies

If you consider that the processing of your personal data infringes the law, you may lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság, NAIH):

• Registered office: 1055 Budapest, Falk Miksa utca 9–11., Hungary
• Postal address: 1363 Budapest, Pf. 9., Hungary
• Phone: +36 1 391 1400
• Email: ugyfelszolgalat@naih.hu
• Website: naih.hu

You may also lodge a complaint with the supervisory authority of the EU Member State in which you habitually reside or work. If your rights are infringed, you may also take legal action; at your choice, proceedings may also be brought before the court of your place of residence or habitual stay.

Before lodging a complaint, we ask that you contact us at info@tumzel.hu, so that we have the opportunity to resolve the matter directly.

11. Changes to this policy

We may amend this policy if our processing or the applicable law changes. The current version is always available on this page; the effective date is shown at the top of the page.