Privacy Policy
This policy explains how Nabucodonosor Solutions Kft. handles personal data, which rights you have under the EU General Data Protection Regulation (GDPR) and how to exercise them.
Who we are
Nabucodonosor Solutions Korlátolt Felelősségű Társaság (Nabucodonosor Solutions Kft.)
Registered seat: 1155 Budapest, Rákos út 98. 9. em. 58. ajtó, Hungary
Company registration number: 01-09-422182 (Company Court of the Budapest-Capital Regional Court)
Tax number: 32401345-1-42 · D-U-N-S: 301253460
Email: [email protected]
Nabucodonosor Solutions Kft. (“we”, “us”) is the data controller for the processing described in this policy. We have not appointed a data protection officer, as the law does not require one for our activities; please send any data protection question to [email protected].
Scope of this policy
This policy covers our websites — haephaistoss.com, orionn.eu and the QuizUp Revived website — and describes, in general terms, the processing that takes place in our applications Orionn Cloud and QuizUp Revived.
Each product also has its own privacy notice and terms of use, shown inside the app and on the product’s website. Those documents describe the processing specific to that product in more detail. Where a product notice is more specific than this policy, the product notice applies to that product.
What data we process and why
| Activity | Data | Purpose | Legal basis | Retention |
|---|---|---|---|---|
| Visiting our websites | IP address, date and time, requested page, browser and device information, referring page | Delivering the website, security, preventing abuse, troubleshooting | Legitimate interest — GDPR Art. 6(1)(f) | Up to 90 days; longer only while needed to investigate a specific security incident |
| Writing to us by email | Name, email address, message content and anything you choose to include | Answering your enquiry; keeping a record of business correspondence | Steps prior to a contract — Art. 6(1)(b); legitimate interest — Art. 6(1)(f) | As long as needed to handle the enquiry, then up to 5 years (general limitation period under the Hungarian Civil Code) |
| Using our apps | Account data (e.g. name, email address), content you store, and data needed for the features you choose | Providing the service you signed up for | Contract — Art. 6(1)(b); consent for optional features — Art. 6(1)(a) | As set out in the product’s own privacy notice; generally until your account is deleted |
| Invoicing paid services | Billing name, address, tax number, invoice data | Meeting accounting and tax obligations | Legal obligation — Art. 6(1)(c) | 8 years, as required by the Hungarian Accounting Act (Act C of 2000) |
We do not sell personal data, and we do not use personal data for automated decision-making that produces legal or similarly significant effects on you.
Who receives personal data
- Hosting. Our websites and services run on servers that we operate ourselves, located in Hungary.
- Cloudflare, Inc. provides network delivery, DNS and security protection for our websites and services, and processes connection data on our behalf as a processor.
- Email service providers that we use to send and receive messages, acting as our processors.
- Apple and Google. When you download our apps from the App Store or Google Play, these companies process your data as independent controllers under their own privacy policies.
- Authorities and courts, where we are legally required to disclose data.
The processors used by a particular app are listed in that app’s privacy notice. We bind every processor by a contract that meets Article 28 GDPR.
Transfers outside the EEA
Some providers (for example Cloudflare) may process data outside the European Economic Area. In such cases we rely on an adequacy decision of the European Commission — including the EU–US Data Privacy Framework for certified companies — or on the European Commission’s standard contractual clauses.
How we protect data
We use encryption in transit (TLS) for every connection and encrypted storage on our servers, restrict access to the people who need it, protect administrative access with single sign-on, and keep encrypted backups. No system is perfectly secure; if a personal data breach is likely to put your rights at high risk, we will inform you without undue delay, as required by Article 34 GDPR.
Your rights
Under the GDPR you have the right to:
- access your personal data and receive a copy (Art. 15);
- have inaccurate data corrected (Art. 16);
- have your data erased (Art. 17);
- restrict processing (Art. 18);
- receive your data in a portable format (Art. 20);
- object to processing based on legitimate interest (Art. 21);
- withdraw your consent at any time, without affecting earlier processing (Art. 7(3)).
To exercise these rights, write to [email protected]. We may ask you to confirm your identity. We respond within one month; for complex requests this may be extended by two further months, in which case we will tell you why. Many rights can also be exercised directly in our apps (for example, deleting your account).
Complaints and remedies
If you believe that our processing of your personal data breaches the law, please contact us first — we will try to resolve the issue. You also have the right to lodge a complaint with the supervisory authority:
Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH) — Hungarian National Authority for Data Protection and Freedom of Information
Address: 1055 Budapest, Falk Miksa utca 9–11. · Postal address: 1363 Budapest, Pf. 9.
Phone: +36 1 391 1400 · Email: [email protected] · Web: naih.hu
You may also bring proceedings before a court. In Hungary, the regional court (törvényszék) has jurisdiction, and you may choose the court of your place of residence or stay. If you live in another EU member state, you may also contact the supervisory authority there.
Children
Our websites and services are not directed at children under 16. Where a product allows younger users, its own privacy notice sets out the conditions, including parental consent where required. If you believe that a child has given us personal data without the necessary consent, please contact us and we will delete it.
Changes to this policy
We may update this policy when our services or legal requirements change. The effective date at the top of the page always shows the current version. We will announce material changes in the affected product before they take effect.
Contact
Questions about this policy or about your personal data: [email protected], or by post to Nabucodonosor Solutions Kft., 1155 Budapest, Rákos út 98. 9. em. 58. ajtó, Hungary.