1. Name of data controller

Name of data controller: Headwaymakers Kft. (“Company”)

Company registration number of the data controller: 01 09 335087

Headquarters of the data controller: 1039 Budapest, Toldi utca 6

Data controller’s representative: Janka Sára Rábóczki


  1. Data management implemented by the Company and other data controllers


The purpose of data management is to collect personal data related to the data controller’s customer’s market research in order to share the research results and to send a notification about the possibility to subscribe to the customer’s newsletter.


data management registration number: 2021-01

the purpose of data management: sharing research results, communicating the possibility of subscribing to a newsletter

scope of data processed: name, email address, telephone number of the data subject

legal basis of data management: Infotv. The consent of the data subject pursuant to Section 5 (1) a)

data retention period: one month from the recording of the data or until deleted at the request of the data subject

data storage method: electronic

The data management complies with the general data protection regulation


  1. General Rules of Data Management


The use of personal data managed by the Company for private purposes is prohibited. Data management must at all times comply with the purpose limitation principle set out in point 2 above. Data management is based on this statement of consent. The rules of data management are governed by this prospectus.


  1. Enforcing the rights of data subjects


The data subject may request information about the handling of his or her personal data, as well as request the correction or deletion of his or her personal data at


The Company shall respond to the request related to the processing of the personal data of the data subject in writing no later than within 25 days from its submission, or within 15 days in case of exercising the right to protest.


The Company deletes personal data if (i) its processing is unlawful, (ii) the data subject requests it, (iii) the processed data is incomplete or incorrect, provided that the deletion is not precluded by law, the purpose of data processing has ceased or the data is stored or the cancellation has been ordered by a court or the National Data Protection and Freedom of Information Authority.


The Company has 25 days to delete, block and correct personal data. The Company notifies the data subject of the measures taken, as well as all those to whom the data was previously transmitted for data management purposes.

The Company treats all information provided as a trade secret and will not share or publish it with third parties without specific permission.


Appeals against data processing can be lodged with the National Data Protection and Freedom of Information Authority (address: 1024 Budapest, Szilágyi Erzsébet fasor 22 / C., Website:



  1. Data processor


During the processing of personal data, the Company uses the following data processor exclusively for the performance of technical tasks:


data processor name: Typefrom SL.

purpose of data processing: hosting service


The Data Processor shall process the data in accordance with the instructions of the Company, may not make a substantive decision concerning the data processing, may process personal data only in accordance with the provisions of the Company,