This privacy policy is based on Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (GDPR), and Act CXII of 2011 on the right to informational self-determination and freedom of information. The policy applies to the personal data processing carried out in connection with the portal of Management SK Limited Liability Company (hereinafter: Management SK Kft.) available at https://ifly.hu/, as well as related subpages and websites within the scope of Management SK Kft.’s interests (hereinafter collectively: portals), and to the processing of personal data that comes into the possession of the Data Controller during personal meetings, telephone or e-mail communication.
Management SK Kft. is the data controller for all data processing activities related to the personal data processing mentioned above. Management SK Kft. is committed to the protection of personal data; in this spirit, this information summarizes information on the method of data collection and processing, and the exercise of data subject rights related to data processing. The information will be revised from time to time, and Management SK Kft. will publish the fact of the modification on the https://ifly.hu/ portal, indicating the modified provisions.
DATA PROCESSOR
- name of the data controller: Management SK Korlátolt Felelősségű Társaság
- data controller registration (company registration number): 04-09-017556
- registered office and postal address of the data controller: 5540 Szarvas, Béke ltp 3/E. 2. emelet 7.
- person authorized to represent the data controller: Somogyi Kinga ügyvezető
- data controller’s email address: info@ifly.hu
- data controller’s phone number: +36 70 333 2103
PRINCIPLES OF DATA PROCESSING
Management SK Kft. processes all data that qualify as personal data in accordance with the principles of lawfulness, fair procedure, transparency and data economy. The processing of data is purpose-bound, Management SK Kft. will continue data processing only if one of the legal grounds specified in this information exists, for the duration of the validity of the legal ground.
Management SK Kft. does not use the data for profiling, does not transfer them to third parties – neither domestically nor abroad, except in the case of an official or court request including the indication of the legal basis, or in the case of possible legal enforcement, and only uses the data processors specified in this information during data processing.
Management SK Kft. protects the data with appropriate, risk-proportionate technical and organizational measures, handles any data protection incidents that may arise in accordance with the provisions of the GDPR, and provides information about them to the affected parties – in the manner and with data content prescribed by law.
SCOPE OF DATA PROCESSING, SCOPE OF DATA PROCESSED
Viewing the information shared on the portals does not require the provision of personal data, this is only necessary in the case of contacting Management SK Kft. or using the services.
However, when downloading and viewing the portals – in accordance with the provisions of this information – we monitor the activities of visitors, during which we also collect personal data.
In the framework of services subject to registration or initiating contact – if you give your prior consent to data processing – the following data may or is required to be provided:
- surname and first name of the data subject(s);
- electronic mailbox address (e-mail);
- optionally telephone number;
The data subject is free to decide whether to provide the above data, however, in the event of failure to provide consent to data processing or at least partial provision of the data, some of the services may not be available, or registration or contact may fail.
In addition to the above, Management SK Kft. collects information about the IP addresses used to access the portals (an IP address is a unique network identifier that ensures the communication of computers over the Internet), operating systems, browsers, and the time and duration of viewing as part of visitor monitoring. The collected information is considered personal data if it allows the indirect or direct identification of the natural person concerned.
In order to improve the user experience, the portals use so-called cookies, information identifiers that are installed in the users’ browsers and stored – for a specified validity period. The use of cookies makes it possible to track users’ website usage habits, recognize returning users, and link browsing histories for a given website. Cookies are not suitable for identifying users by themselves, they only allow the recognition of the user’s browser. Cookies are used exclusively by portals and only when the user downloads or views the portals. Management SK Kft. does not use cookies to identify users who are only visitors to the websites. Users can set the rules governing the use of cookies in their browsers, or they can also disable the use of cookies (more information on setting cookies can be found in the user documentation of the browsers).
Management SK Ltd. does not process sensitive personal data.
LEGAL BASIS AND PURPOSE OF DATA PROCESSING
Data processing in connection with portals, meetings and telephone or e-mail communication is always based on the consent of the data subject and the legitimate interest of Management SK Kft. The legal basis for data processing is thus
- Article 6 (1) (a) of the GDPR, the consent of the data subject;
- Article 6 (1) (b) of the GDPR, for the performance of a contract or for taking steps at the request of the data subject prior to that, and
- Article 6 (1) (f) of the GDPR, for the purposes of the legitimate interests of Management SK Kft.
Purpose of data processing
- contacting potential partners and clients of Management SK Kft., maintaining the relationship, handling comments and inquiries;
- fulfilling or facilitating the conclusion of a contract
- sharing information;
- ensuring the legal and secure operation and integrity protection of the portals;
ensuring the enforcement of rights related to shared intellectual products and trademarks subject to copyright - enforcing legal claims.
DURATION OF DATA PROCESSING
Management SK Kft. provides the data
- until the data subject withdraws their consent;
- until the contract is concluded,
- in the case of the relevant purposes, until the legitimate interest in relation to them exists; or
- until notification of a change in the data subject’s data, or in the case of a request for deletion, until its execution.
RIGHTS OF THE DATA SUBJECT
The data subject has the right, in accordance with Chapter III of the GDPR, to
- receive information about the circumstances and characteristics of data processing (identity and contact details of the data controller; legal basis and purpose of data processing; duration of data processing; rights, in particular the right to withdraw consent; possibility of filing a complaint);
- request information from the data controller in connection with data processing;
- request access to personal data concerning him/her;
- exercise the option of data portability;
- request correction, deletion (oblivion) or restriction of processing of data concerning him/her; and
- object to the processing of his/her personal data.
In the event of unjustified multiple or repeated exercise of the right of access and data portability, the data controller may charge an administrative fee. The prerequisite for exercising the right of access and data portability may be the provision by the data subject of a suitable, secure data medium for storing the data. The data controller ensures access and data portability in the format and with technological parameters used during data processing.
DATA SECURITY
The portals, the IT system and network of Management SK Kft. serving them are protected against computer-aided fraud, espionage, sabotage, vandalism, fire and flood, as well as computer viruses, computer intrusions and attacks leading to denial of service. Management SK Kft. ensures security, the prevention of unauthorized access, alteration, transmission, disclosure, deletion or destruction, accidental destruction and damage to data by means of appropriate and risk-proportionate technical and organizational measures, server and application-level protection procedures. All employees and contractual partners of Management SK Kft. who have access to the data concerned have undertaken to protect the confidentiality, integrity and availability of personal data.
REMEDIES
The Data Controller will do everything possible to ensure that the processing of personal data is carried out in accordance with the law. If you feel that we have not complied with this, please write to us at the email address info(at)ifly.hu or at the postal address Management SK Korlátolt Felełősségű Társaság 5540 Szarvas, Béke ltp 3/E. 2. emelet 7.
In the event of a violation of law arising in connection with data processing, the data subject may contact the court competent for the registered office of Management SK Kft. or for his/her place of residence or residence. In order to check and facilitate the enforcement of your rights, you can also contact the National Data Protection and Freedom of Information Authority (seat: 1125 Budapest, Szilágyi Erzsébet Fasor 22/c.; telephone number: +36 (1) 391-1400; fax number: +36 (1) 391-1410; e-mail address: ugyfelszolgalat@naih.hu). You can find out about the steps for enforcing rights through the Authority on the www.naih.hu portal.
The data controller can exercise the enforcement of the rights of the data subject through the contact details published in this information.
DATA TRANSFER STATEMENT
I acknowledge that the following personal data stored by the data controller Management SK Kft. (5540 Szarvas, Béke ltp 3/E. 2. emelet 7.) in the https://ifly.hu user database will be transferred to Cooltix Kft., as the data processor. The scope of the data transmitted by the data controller is as follows: Name, billing information, telephone number and email address. The nature and purpose of the data processing activity carried out by the data processor can be viewed in the Cooltix Data Processing Information, at the following link: https://support.cooltix.com/hu/articles/6912348-adatkezelesi-szabalyzat
DATA PROCESSORS
Management SK Kft. uses the following data processors and services in the processing of data in connection with the portals:
Management SK Kft. uses the Google Analytics service of Google LLC. (1600 Amphitheatre Parkway Mountain View, CA 94043 USA; www.google.com/contact) to analyze the operation of the portals. Google Analytics is based on the use of cookies, and the information generated by the cookies is transmitted to Google’s own servers, where it is stored and processed. The IP address anonymization service is active on the portals, so within the member states of the European Union or the contracting states of the European Economic Area, Google makes the IP address of the users unidentifiable before transmission. By downloading and installing the plug-in module available at the link http://tools.google.com/dlpage/gaoptout, the user can prevent Google Analytics from collecting and processing the data generated by cookies in connection with the use of the portals.
Management SK Kft. uses Google LLC. (1600 Amphitheatre Parkway Mountain View, CA 94043 USA; www.google.com/contact) Google AdWords to support its advertising campaigns. Google AdWords ensures the tracking of Google advertising campaigns and the measurement of their effectiveness. Google AdWords also uses cookies for its operation, the prohibition of which is governed by the general notes on the prohibition of cookies.
Management SK Kft. uses the services of Attila Bacsó ev. (1124 Budapest, Jagelló út 40/b.) during its data backup activities.
Management SK Kft. does not use data processors during the data processing carried out in connection with the contact; in the event of the performance of the contract, the data processors are determined as specified in the contract.
The data processing guidelines of the data processors used are available at the data processors’ contact details specified above.
Valid: May 4, 2026