Privacy and Client Information Notice – Euro-Sales Insurance Broker Ltd.

1. Data Controller

Name: EURO-SALES Insurance Broker Ltd.
Registered Seat: 1133 Budapest, Kárpát utca 9. 4/7, Hungary
Company Registration Number: 01-09-289023
Tax Number: 11818681-2-41
Head Office: 4032 Debrecen, Thomas Mann u. 31. 3/15, Hungary
Website: http://www.eurosales.hu
Email: eurosales@eurosales.hu
Phone: +36-1-794-7071
Managing Director: Attila Kósa

2. Introduction

Euro-Sales Insurance Broker Ltd. (hereinafter referred to as the “Company” or “Data Controller”) attaches particular importance to the protection of personal data and ensures their security. The Company fully complies with the applicable data protection laws, in particular the General Data Protection Regulation (EU) 2016/679 (“GDPR”). This Privacy and Client Information Notice is available on our website. The Company reserves the right to amend this Notice at any time, and will duly inform Data Subjects of any changes.

3. Definitions

For the purposes of this Notice, the following terms shall have the meanings set out below:
- Data Subject: any identified or identifiable natural person whose personal data are processed.
- Personal Data: any information relating to an identified or identifiable natural person.
- Special Categories of Data: data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, health data, or data concerning a natural person’s sex life or sexual orientation.
- Processing: any operation performed on personal data, such as collection, storage, alteration, transmission, erasure.
- Data Controller: the person or entity which determines the purposes and means of the processing of personal data.
- Processor: a person or entity that processes personal data on behalf of the Data Controller.
- Consent: freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which they agree to the processing of their personal data.

4. Principles of Data Processing

The Company processes personal data in accordance with the following principles:
- Lawfulness, fairness and transparency
- Purpose limitation
- Data minimisation
- Accuracy
- Storage limitation
- Integrity and confidentiality
- Accountability
- Privacy by design and by default

5. Purpose and Legal Basis of Processing

Personal data may be processed for the following purposes and on the following legal bases:
a) Contractual relationships: Insurance brokerage contracts, policy administration, premium quotations, contract termination, and claims handling. Legal basis: GDPR Art. 6(1)(b).
b) Marketing: Sending newsletters, updates on services, events, and offers. Legal basis: consent of the Data Subject (GDPR Art. 6(1)(a)).
c) Website and cookies: To ensure proper functioning of the website and improve user experience. Legal basis: legitimate interests (GDPR Art. 6(1)(f)).
d) Client database: For registration and access to services. Legal basis: consent or contract (GDPR Art. 6(1)(a), (b)).
e) Operational communication: Responding to requests for information. Legal basis: legitimate interests (GDPR Art. 6(1)(f)).
f) Job applicants: Processing of CVs and application materials for recruitment. Legal basis: consent or pre-contractual steps (GDPR Art. 6(1)(a), (b)).
g) Customer service: Telephone conversations with the customer service department may be recorded with the consent of the Data Subject. Retention period: 5 years.
h) Complaints: Handling client complaints. Legal basis: legal obligation (Act CLV of 1997 on Consumer Protection). Retention period: 5 years.

6. Data Subject Rights

Under the GDPR, Data Subjects have the following rights:
- Right of access
- Right to rectification
- Right to erasure (‘right to be forgotten’)
- Right to restriction of processing
- Right to data portability
- Right to object
- Rights related to automated decision-making and profiling
- Right to lodge a complaint with a supervisory authority
- Right to an effective judicial remedy

7. Data Transfers and Retention

Personal data may be transferred to insurance companies, IT providers, accountants and other partners, only to the extent necessary for the provision of services. Data will not be transferred outside the European Economic Area without adequate safeguards. Personal data are retained for the duration of the contractual relationship, and thereafter for 5 years, unless otherwise required by law.

8. Data Security

The Company applies appropriate technical and organisational measures to ensure the security of personal data and to protect them against unauthorised or unlawful processing, accidental loss, destruction or damage.

9. Contact Information

If you have any questions regarding this Notice or wish to exercise your data protection rights, please contact us at:
Email: eurosales@eurosales.hu
Phone: +36-1-794-7071
Postal address: 1133 Budapest, Kárpát utca 9. 4/7, Hungary
Supervisory Authority: National Authority for Data Protection and Freedom of Information (www.naih.hu)
 
Client Information Notice

Euro-Sales Insurance Broker Ltd. hereby informs its clients of the following:

1. Our company operates as an independent insurance intermediary, acting on behalf of and in the interests of our clients.

2. We are registered under number 10153633 in the register of the Central Bank of Hungary (MNB) as an insurance broker. Our activity is supervised by the Central Bank of Hungary (MNB). Contact: 1013 Budapest, Krisztina krt. 39., website: http://www.mnb.hu.

3. Our services include:
- Risk assessment and analysis,
- Preparation of insurance offers,
- Mediation of insurance contracts,
- Assistance with claims handling,
- Continuous client representation during the lifetime of the insurance contract.

4. Our remuneration is generally in the form of a commission paid by the insurance company, the amount of which does not increase the insurance premium payable by the client.

5. In the event of any complaints regarding our activities, clients may contact our Company directly at eurosales@eurosales.hu, or lodge a complaint with the Central Bank of Hungary (MNB).

6. Clients also have the right to initiate civil proceedings before a court in case of disputes relating to insurance contracts.
This Client Information Notice is provided in accordance with the applicable provisions of Hungarian insurance intermediary regulation.