PRIVACY POLICY
Effective date: July 6, 2026
1. Data Controller Information
Data Controller:
Sövegjártóné Sándor Katalin Mária
Sole Proprietor
Brand name:
Kleo VVin Marketing Studio
Registered office:
8900 Zalaegerszeg, Lőrinc Barát utca 1.
Hungary
Registration number:
62279297
Tax number:
92036084-1-40
Website:
kleovvin.com
E-mail:
hello@kleovvin.com
2. Purpose of this Privacy Policy
This Privacy Policy explains what personal data Kleo VVin Marketing Studio collects, the purposes for which it is processed, the legal basis for processing, how long the data is retained, and the rights of data subjects.
The Data Controller processes personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR) and the applicable laws of Hungary.
3. Principles of Data Processing
The Data Controller processes personal data in accordance with the following principles:
- lawfully, fairly and transparently;
- solely for specified and legitimate purposes;
- only to the extent necessary for those purposes;
- ensuring the accuracy of the data;
- retaining personal data only for as long as necessary;
- protecting personal data through appropriate technical and organizational security measures.
4. Categories of Personal Data Processed
For the purpose of providing its services, the Data Controller may process the following personal data:
- full name;
- e-mail address;
- telephone number;
- business name;
- billing information;
- website address;
- Google Business Profile link;
- social media profile links;
- any other information voluntarily provided by the Customer;
- information provided during communication.
The Data Controller processes only the personal data necessary for providing the requested services.
5. Purpose of Data Processing
Personal data may be processed for the following purposes:
- communication with customers and responding to enquiries;
- preparing quotations;
- concluding and performing contracts;
- issuing invoices;
- customer identification;
- providing the ordered services;
- customer support;
- complying with legal obligations;
- processing orders submitted through the website;
- marketing communication where the data subject has given consent;
- sending automated confirmation e-mails;
- operating newsletters and marketing automation;
- preparing AI-assisted marketing analyses, reports and recommendations;
- preparing statistical analyses;
- improving the website and the services.
6. Legal Basis for Data Processing
The Data Controller processes personal data on the following legal bases:
- the data subject's consent;
- the performance of a contract;
- compliance with legal obligations;
- the legitimate interests of the Data Controller where permitted by law.
Personal data is processed in all cases in accordance with the GDPR and the applicable laws of Hungary.
7. Data Retention Period
The Data Controller retains personal data only for as long as necessary to achieve the purposes of processing or for the period required by applicable law.
Where processing is based on the data subject's consent, personal data will be retained until the consent is withdrawn or until the purpose of processing no longer exists.
Accounting records containing personal data are retained for the period required by the applicable accounting and tax legislation.
8. Data Transfers and Data Processors
The Data Controller transfers personal data only to the extent necessary for providing the services, performing the contract, and complying with legal obligations.
The Data Controller may use the following data processors:
- Google LLC (Google Sites, Google Forms, Google Drive, Google Workspace, Gmail, Google Analytics 4, Google Tag Manager)
- Microsoft Corporation (Microsoft Clarity)
- Meta Platforms Ireland Limited (Meta Pixel, Facebook and Instagram marketing and advertising services)
- OpenAI, LLC (AI-assisted marketing analyses, reports and content generation)
- SimplePay Zrt. (online card payment processing)
- MailerLite (newsletter distribution and marketing automation)
- Számlázz.hu (electronic invoicing)
- Hosting and domain service providers
- Other data processors necessary for the secure and lawful provision of the services.
The Data Controller engages only data processors that comply with the GDPR and the applicable Hungarian data protection laws.
The Customer acknowledges that certain elements of the services may operate through automated processes, including automated e-mail delivery, newsletter distribution, marketing automation, and AI-assisted analyses and reports.
9. Rights of the Data Subject
The data subject has the right to:
- request information about the processing of their personal data;
- access their personal data;
- request the correction of inaccurate personal data;
- request the deletion of personal data where permitted by law;
- request the restriction of data processing;
- receive their personal data in a structured, commonly used and machine-readable format (data portability);
- object to the processing of their personal data in cases provided by law.
Where data processing is based on consent, the data subject may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
The Data Controller will examine and respond to requests without undue delay and no later than within the time limits specified by the GDPR.
10. Data Security
The Data Controller implements appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, destruction, accidental loss, or any other unlawful processing.
Personal data is accessible only to those persons and data processors who require access for the performance of the services.
11. Legal Remedies
If a data subject believes that the processing of their personal data violates applicable data protection legislation, they may lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH) or bring the matter before the competent court.
The Data Controller will make every reasonable effort to resolve any complaint directly and amicably before legal proceedings become necessary.
12. Cookies
The Website uses cookies and similar technologies to ensure the proper operation of the Website, improve user experience, analyze visitor statistics, and support marketing activities.
Detailed information about the cookies used, their purposes, retention periods, and users' rights is available in the separate Cookie Policy published on the Website.
Where required by law, non-essential cookies are used only with the user's prior consent.
13. Changes to this Privacy Policy
The Data Controller reserves the right to amend this Privacy Policy, particularly in the event of changes in legislation, technical developments, or modifications to the services provided.
The amended Privacy Policy becomes effective upon its publication on the Website and applies to data processing carried out thereafter.
14. Governing Law and Contact Information
This Privacy Policy shall be governed by the laws of Hungary and the applicable legislation of the European Union, including the General Data Protection Regulation (GDPR).
For any questions regarding data processing, data subjects may contact the Data Controller at:
E-mail:
hello@kleovvin.com
Website:
kleovvin.com
15. Data Retention and Deletion
The Data Controller retains personal data only for the period necessary to achieve the purposes of data processing or for the period required by applicable law.
Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized, unless further retention is required by law or for the establishment, exercise, or defense of legal claims.
16. Final Provisions
This Privacy Policy enters into force on July 6, 2026, and remains valid until amended or withdrawn.
The Data Controller reserves the right to amend this Privacy Policy at any time. Any amendments shall become effective upon publication on the *kleovvin.com* website.
The most recent version of this Privacy Policy is always available on the Website.