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Privacy notice

Finders Consulting Kft.

Effective from: 21 May 2026

1. INTRODUCTION AND PURPOSE OF THE NOTICE

Finders Consulting Kft. (hereinafter referred to as the "Controller" or "Finders") is committed to protecting the personal data it processes and to respecting the privacy of natural persons. The purpose of this Privacy Notice (hereinafter referred to as the "Notice") is to provide data subjects with clear, intelligible and transparent information about the circumstances of the processing of their personal data prior to such processing.

In preparing this Notice, the Controller ensures compliance with the following statutory and relevant regulatory provisions:

Regulation (EU) 2016/679 of the European Parliament and of the Council (the "GDPR");

Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information (the "Privacy Act");

Act V of 2013 on the Civil Code (the "Civil Code");

Act I of 2012 on the Labour Code (the "Labour Code");

Act C of 2000 on Accounting (the "Accounting Act");

Act CVIII of 2001 on Certain Issues of Electronic Commerce Services and Information Society Services (the "E-Commerce Act");

Act XLVIII of 2008 on the Basic Requirements of and Certain Restrictions on Commercial Advertising Activity (the "Advertising Act");

Regulation (EU) 2024/1689 of the European Parliament and of the Council on Artificial Intelligence (the "EU AI Act"), with particular regard to its provisions concerning high-risk AI systems and applications falling within the scope of employment and worker management.

2. CONTROLLER'S DETAILS

Company nameFinders Consulting Kft.
Registered seat2100 Gödöllő, Kard utca 17. 2., Hungary
Office / correspondence address1146 Budapest, Zichy Géza u. 5., Hungary
Company registration number13 09 207228
Registering authorityCourt of Registry of Pest County
Tax number28744517-2-13
Legal representativeMátyás Bíró, Managing Director
E-mailinfo@findersconsulting.com
Telephone+36 20 420 3557
Websitewww.findersconsulting.com

Data Protection Officer (DPO): Pursuant to Article 37 of the GDPR, the Controller's activities do not require the designation of a Data Protection Officer, given that the Controller is not a public authority, its core activities do not require regular and systematic monitoring of data subjects on a large scale, and it does not process special categories of personal data within the meaning of Article 9 on a large scale. The Controller has, however, designated a contact person for data protection matters, who can be reached at info@findersconsulting.com.

3. DEFINITIONS

The terms used in this Notice shall bear the meaning ascribed to them under Article 4 of the GDPR. The most relevant definitions are as follows:

Personal data: any information relating to an identified or identifiable natural person.

Data subject: the natural person whose personal data is processed by the Controller.

Processing: any operation performed on personal data (collection, recording, storage, use, transmission, erasure, etc.).

Controller: the entity that determines the purposes and means of the processing of personal data.

Processor: the entity that processes personal data on behalf of the Controller (e.g. hosting provider, ATS system operator).

Consent: any freely given, specific, informed and unambiguous indication of the data subject's wishes.

Profiling: any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person.

4. INDIVIDUAL PROCESSING ACTIVITIES

The Controller processes personal data in relation to three principal categories of data subjects. This section presents the processing activities grouped according to these categories.

4.1. PROCESSING OF WEBSITE VISITORS' DATA

4.1.1. Contact via the website

Purpose of processingResponding to enquiries received via the website, communication with the enquiring person, exploring potential business cooperation opportunities.
Categories of data processedName, e-mail address, telephone number (optional), company name (optional), other information voluntarily provided in the message.
Legal basis of processingArticle 6(1)(f) GDPR — the Controller's legitimate interest in responding to enquiries addressed to it and in developing business relationships. A balancing test has been performed.
Duration of processing2 years from the date of the last substantive contact, unless the data subject requests erasure before this period or a business relationship is established, in which case processing shall continue pursuant to section 4.3.
Data transfersData is transferred to the processors listed in section 7 (hosting, e-mail services). No data is transferred to third countries.

4.1.2. Newsletter and marketing communications

Purpose of processingSending newsletters, professional content (articles, webinar invitations, market insights) based on the data subject's voluntary subscription.
Categories of data processedName, e-mail address, optionally: name of organisation, position held.
Legal basis of processingArticle 6(1)(a) GDPR — the data subject's voluntary consent, which is also consistent with Section 6(1) of the Advertising Act. Consent shall be given by ticking a separate, dedicated checkbox (no pre-ticked box).
Duration of processingUntil withdrawal of consent. Withdrawal may be initiated via the unsubscribe link at the bottom of each newsletter, or at info@findersconsulting.com.
Rights of the data subjectThe withdrawal of consent shall not affect the lawfulness of processing carried out prior to such withdrawal.

4.1.3. Cookies

The website uses cookies for its operation. Detailed information on the use of cookies is provided in the separate Cookie Notice, available on the website.

4.2. PROCESSING OF APPLICANTS' AND CANDIDATES' DATA

In the course of its executive search and talent solution services, the Controller processes the personal data of applicants and candidates (jointly referred to as "Candidates"). Candidate data may originate from three sources: (a) direct application for a specific position; (b) general expression of interest / unsolicited application; (c) proactive approach initiated by the Controller (direct search).

4.2.1. Application for a specific position

Purpose of processingEvaluation of the Candidate's application, assessment of the Candidate in relation to the advertised position or the position represented by the Controller, communication with the Candidate during the selection process.
Categories of data processedName, date of birth, contact details (e-mail, telephone, address), data contained in the CV (work experience, qualifications, skills, language skills), motivation letter, salary expectations, interview notes, references (solely with the Candidate's consent).
Legal basis of processingArticle 6(1)(b) GDPR — steps taken prior to entering into a contract at the request of the Candidate. For stored Candidate profiles, Article 6(1)(a) GDPR — consent of the data subject.
Duration of processing6 months following the closure of the selection process (unless the Candidate has consented to longer retention — see section 4.2.4).
Data transfersWith the Candidate's express prior notification, the Controller forwards the Candidate's data to the client (prospective employer). The Candidate shall in all cases be informed of such transfer before it takes place.

4.2.2. Unsolicited application / general interest

Purpose of processingRegistration of the Candidate in the Controller's candidate database, contacting the Candidate in the event of future relevant positions.
Categories of data processedData as specified in section 4.2.1.
Legal basis of processingArticle 6(1)(a) GDPR — consent of the data subject.
Duration of processingUntil the withdrawal of consent, but no longer than 3 years, after which the Controller shall seek confirmation from the Candidate as to the continuation of processing.

4.2.3. Direct search initiated by the Controller

In the course of its executive search activities, the Controller may identify potential candidates from publicly available professional sources (in particular LinkedIn, participant lists of professional conferences, publicly communicated professional appearances) for the purpose of fulfilling a specific engagement.

Purpose of processingIdentification and approach of potential candidates for the purpose of fulfilling a specific engagement represented by the Controller.
Categories of data processedProfessional data available from public sources (name, current position, work experience, public contact details).
Legal basis of processingArticle 6(1)(f) GDPR — the legitimate interest of the Controller and its client in fulfilling the engagement. The balancing test has concluded that the processing of exclusively publicly available professional data, for explicitly professional purposes, with storage limited to the first point of contact, does not disproportionately restrict the privacy of the data subject.
Information to the data subjectAt the time of first contact — within the one-month period set forth in Article 14(3) GDPR — the data subject shall receive comprehensive information by way of reference to this Notice.
Duration of processingShould the data subject fail to respond, or decline the approach, the data shall be erased within 6 months of the last contact. Should the data subject express an intention to cooperate, processing shall continue pursuant to section 4.2.2.

4.2.4. Long-term candidate database

Purpose of processingFollowing the closure of the selection process, retention of the Candidate's data in the long-term candidate database based on the Candidate's voluntary consent, for the purpose of future relevant opportunities.
Legal basis of processingArticle 6(1)(a) GDPR — express, voluntary consent.
Duration of processing3 years from the granting of consent, after which the Controller shall seek confirmation; in the absence of confirmation, the data shall be erased.

4.2.5. Automated decision-making and profiling

In relation to Candidates, the Controller does not employ solely automated decision-making. Every decision producing legal effects concerning a Candidate, or similarly significantly affecting them (e.g. the recommendation to the client), is preceded by a human expert decision.

Where the Controller uses AI-based supporting tools to assist in the preparation of Candidate evaluations (e.g. CV structuring, preliminary skills-based fit screening), the output of such tools shall serve solely as input to the human expert decision. The Controller selects such tools in compliance with the requirements imposed by the EU AI Act on the field of employment and worker management, and ensures their transparent, auditable operation. The Candidate may request the human review of any output generated by such supporting tools and may submit a written objection thereto.

4.3. PROCESSING OF DATA OF REPRESENTATIVES AND EMPLOYEES OF COOPERATING PARTNERS AND CLIENTS

Purpose of processingThe processing of personal data of the employees, as well as the representatives, of the cooperating partner or client, in order to enable the Controller to deliver the business and organisational development engagement, as well as the executive search / talent solution engagement; communication, preparation, performance, documentation and invoicing of the engagement, and post-engagement follow-up.
Categories of data subjectsThe management, HR leadership, project owners, contact persons of the client / partner company, as well as all employees who come into contact with the Controller in the course of fulfilling the engagement.
Categories of data processedName, position, organisational unit, business contact details (corporate e-mail, telephone), content of written communication during the engagement, meeting notes, other professional information required for the performance of the engagement.
Legal basis of processingArticle 6(1)(b) GDPR — performance of the service agreement, where the data subject is a party to the agreement. For other representatives and employees, Article 6(1)(f) GDPR — the legitimate interest of the Controller and the client in the performance of the agreement.
Duration of processing5 years following the termination of the service agreement (general limitation period under Section 6:22 of the Civil Code), and for data falling within the scope of accounting records, 8 years pursuant to Section 169(2) of the Accounting Act.
Data transfersData is transferred to the processors listed in section 7.

4.4. RETENTION OF ACCOUNTING RECORDS

Purpose of processingCompliance with the document retention obligation laid down in the Accounting Act.
Categories of data processedData appearing on invoices: name, address, tax number (in the case of sole traders).
Legal basis of processingArticle 6(1)(c) GDPR — compliance with a legal obligation (Section 169 of the Accounting Act).
Duration of processing8 years.

5. PRINCIPLES OF PROCESSING

The Controller processes personal data:

lawfully, fairly and in a transparent manner;

collected solely for specified, explicit and legitimate purposes;

to the extent and for the duration necessary to achieve such purposes (data minimisation);

kept accurate and up to date;

protected against unauthorised or unlawful processing, accidental loss or destruction by appropriate technical and organisational measures.

6. RIGHTS OF THE DATA SUBJECT

Pursuant to Chapter III of the GDPR, the data subject is entitled to the following rights:

6.1. Right to information (Articles 13–14 GDPR) — the data subject shall be informed of the circumstances of processing at the time of the data collection.

6.2. Right of access (Article 15 GDPR) — the data subject may request a copy of the data provided, as well as information on the purpose, legal basis and duration of the processing.

6.3. Right to rectification (Article 16 GDPR) — correction of inaccurate data.

6.4. Right to erasure / "right to be forgotten" (Article 17 GDPR) — erasure of the data in specified cases.

6.5. Right to restriction of processing (Article 18 GDPR).

6.6. Right to data portability (Article 20 GDPR) — receiving and transmitting the data in a structured, machine-readable format.

6.7. Right to object (Article 21 GDPR) — in particular in cases of processing based on legitimate interest.

6.8. Right to withdraw consent (Article 7(3) GDPR) — withdrawal shall not affect the lawfulness of processing carried out prior thereto.

6.9. Rights relating to automated decision-making and profiling (Article 22 GDPR) — see section 4.2.5.

The exercise of these rights may be initiated at info@findersconsulting.com, or by sending a postal letter to the Controller's registered seat. The Controller shall respond to such request within one month of its receipt, which period may be extended by a further two months in the case of complex or numerous requests; in such case the Controller shall inform the data subject of the extension and its reasons within one month.

7. PROCESSORS AND RECIPIENTS

In the course of its activities, the Controller engages the following processors:

ProcessorActivity / Location of processing
dotroll.huWebsite hosting — EU
Google LLCE-mail service (Google Workspace) — EU / USA (under adequacy decision)
dotroll.huApplicant Tracking System (proprietary system) — EU
OREO-TAX Kft.Accounting and payroll services — Hungary

The complete and up-to-date list of processors shall be made available to data subjects upon request.

Recipients may further include: client companies (with respect to Candidate data), authorities (where required by law), and the Controller's contracted legal representative.

8. INTERNATIONAL DATA TRANSFERS

The Controller does not transfer personal data to third countries (outside the European Economic Area) on a systematic basis. Where the infrastructure of certain processors (e.g. Google Workspace) partly involves the United States, such data transfer is based on an adequacy decision of the European Commission (EU-U.S. Data Privacy Framework) or, in its absence, on the EU Standard Contractual Clauses (SCC).

9. DATA SECURITY

In order to ensure the security of personal data, the Controller applies the following technical and organisational measures:

password-protected systems with multi-level access control;

encrypted data transmission (HTTPS) for the website and communication channels;

regular data backups;

data protection and data security training for staff;

data processing agreements concluded with processors in compliance with Article 28 GDPR;

a register of and procedures for handling personal data breaches.

In the event of a personal data breach, the Controller shall — where the breach is likely to result in a high risk to the rights and freedoms of data subjects — notify the data subjects without undue delay, and shall report the breach to the Hungarian National Authority for Data Protection and Freedom of Information within 72 hours of becoming aware of it.

10. REMEDIES

Where the data subject considers that the processing of their personal data does not comply with statutory requirements, the following remedies are available:

10.1. Direct contact with the Controller at info@findersconsulting.com.

10.2. Lodging a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH):

Address: 1055 Budapest, Falk Miksa utca 9-11., Hungary

Postal address: 1363 Budapest, Pf. 9., Hungary

Telephone: +36 (1) 391-1400

E-mail: ugyfelszolgalat@naih.hu

Website: www.naih.hu

10.3. Judicial remedy — the data subject may bring an action before the regional court of the place of their habitual residence or of their stay.

11. AMENDMENT OF THE NOTICE

The Controller reserves the right to amend this Notice unilaterally, in particular in the event of legislative changes or changes in its processing activities. The amended Notice shall enter into force upon publication on the website. In the event of material changes, the Controller shall give prior notification to data subjects through the channels of the ongoing relationship.

Effective from: 21 May 2026

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Zichy Géza u. 5.
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