TITEM Ipari és Kereskedelmi Korlátolt Felelősségű Társaság (registered office: 4028 Debrecen, Kassai út 141, Hungary) (hereinafter: TITEM Ltd.) as data controller is committed to protecting the personal data of its clients.
TITEM Ltd. pays particular attention to ensuring that the collection, processing, use, storage, and potential transfer of personal data are carried out in compliance with the applicable GDPR regulation—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—as well as other relevant national and international laws and recommendations.
The purpose of this policy is to ensure that our clients and partners understand how we use their personal data.
This Privacy Policy forms an integral part of any contract concluded between TITEM Ltd. and its clients or other natural persons.
By signing a contract with TITEM Ltd. that includes a reference to this policy, or by accepting the privacy policy via the pop-up window on the website www.titem.hu, users acknowledge that they have read and understood its contents.
1. Data Controller Information
Data Controller: TITEM KFT., as data controller
Registered office: 4028 Debrecen, Kassai út 141, Hungary
Mailing address: 4028 Debrecen, Kassai út 141, Hungary
Email: info@titem.hu
Phone: +36 70 366 5502
Website: www.titem.hu
Data Protection Officer:
Name: Ulziibadrakh Enkhbaatar
Address: 4028 Debrecen, Kassai út 141, Hungary
Email: info@titem.hu
Phone: +36 70 366 5502
2. Definitions
Data Subject
Any identified or identifiable natural person.
Personal Data
Any information relating to an identified or identifiable individual.
Consent
Freely given, specific, informed, and unambiguous indication of the data subject’s wishes.
Objection
Statement by the data subject opposing the processing of their data.
Data Controller
Entity determining the purposes and means of processing personal data.
Data Processing
Any operation performed on personal data (e.g., collection, storage, use, transmission).
Data Transfer
Making data accessible to a third party.
Erasure
Making data permanently irrecoverable.
Data Processor
Entity processing data on behalf of the data controller.
Third Party
Any person/entity other than the data subject, controller, or processor.
EEA State
EU Member States and other states within the European Economic Area.
Third Country
Any state outside the EEA.
Data Breach
Unlawful processing, loss, alteration, or unauthorized access to personal data.
3. Scope of Processed Data
TITEM Ltd. processes personal data obtained in connection with its services and contractual relationships.
Types of data processed include:
- Name and birth name
- Address
- Place and date of birth
- Mother’s name
- Shipping address
- Identification document details
- Photograph
- Copies of identification documents
- Tax number
- Bank account details
- Email address
- Phone number
- Employment and citizenship data
4. Data Subjects
Clients, authorized representatives, beneficiaries, and individuals whose data is provided by the client with proper authorization.
5. Purpose of Data Processing
Performance of services and contracts
Compliance with legal obligations (e.g., invoicing)
Anti-money laundering identification and verification (as required by law)
6. Legal Basis for Processing
Contract performance (GDPR Article 6(1)(b))
Legitimate interest (GDPR Article 6(1)(f))
Legal obligation (GDPR Article 6(1)(c))
Consent (GDPR Article 6(1)(a)) for cookies and other non-essential processing
7. Data Retention Period
General data: 5 years after contract termination
AML compliance: 8 years
Accounting documents: 8 years
8. Automated Decision-Making
TITEM Ltd. does not carry out automated decision-making or profiling.
9. Cookie Policy
Our website may place small data files (cookies) on your device to enhance user experience and improve functionality.
Cookies store technical data such as navigation patterns and user interactions.
Users may disable cookies via browser settings; however, this may affect website functionality.
10. Data Transfers
Personal data may be shared with:
- Accountants
- Shipping providers
- Payment processors
- Financial institutions
- Contractual partners
No data is shared beyond what is necessary without prior consent.
11. Data Processors
Website operator:
LinuxWeb Ltd.
12. Data Security
We implement appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, or loss.
Data processors are also required to comply with these standards.
RIGHTS OF DATA SUBJECTS
13. Right of Access
You may request confirmation and access to your personal data.
14. Right to Rectification
You may request correction of inaccurate data.
15. Right to Object
You may object to processing based on legitimate interests.
16. Right to Erasure
You may request deletion under certain conditions.
17. Right to Restriction
You may request limitation of data processing.
18. Right to Data Portability
You may request your data in a structured, machine-readable format.
19. Legal Remedies
Complaints can be submitted to:
Hungarian National Authority for Data Protection and Freedom of Information (NAIH)
Website: http://naih.hu
Address: 1055 Budapest, Falk Miksa utca 9–11
Phone: +36-1-391-1400
Email: ugyfelszolgalat@naih.hu
You may also initiate legal proceedings before a competent court.
20. Representation
You may authorize a non-profit organization to act on your behalf in data protection matters.
21. Final Provisions
TITEM Ltd. reserves the right to amend this policy without affecting its core purpose or legal basis.
If data is processed for new purposes, users will be informed in advance.
Processing based on consent requires prior approval.
This policy is effective as of August 5, 2025.
