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Privacy Notice

Privacy Policy

Privacy Notice of Emily AI Limited Liability Company

Emily AI Limited Liability Company

Registered seat: 6000 Kecskemét, Gázló street 23.

Company registration number: [to be completed]

Tax number: [to be completed]

Website: www.emilycampus.com

E-mail: info@emilycampus.com

Telephone: +36 20 310 0233

Represented by: Balázs Kenyeres, Managing Director – hereinafter: Data Controller / Emily AI Kft.

The purpose of this Privacy Notice is for Emily AI Limited Liability Company to set out the data protection and data processing principles applied by the Data Controller, and to ensure that all data subjects receive clear and detailed information regarding the manner, purpose, legal basis and conditions of the processing of personal data provided through the Emily AI Website.

Privacy Notice

For Emily AI Ltd., the protection of the privacy of interested parties and the responsible, secure handling of personal data is of paramount importance. Our company is committed to ensuring that our data-processing practices are transparent and fully compliant with all applicable legal requirements.

If this notice does not answer all of your questions, please contact us at info@emilycampus.com, and our colleagues will be happy to assist you.

Emily AI Ltd. (registered office: 6000 Kecskemét, Gázló utca 23.) – hereinafter: Emily AI Ltd. / Service Provider / Data Controller – as data controller within the meaning of Section 3(9) of Act CXII of 2011 (Info Act), accepts the provisions of this Privacy Notice as binding upon itself.

We design our data-processing activities in such a way that they comply with the relevant legislation and reflect best practices for protecting users' data.

Definitions

Data Subject: any natural person who can be identified, directly or indirectly, on the basis of personal data.

Personal Data: any information relating to an identified or identifiable natural person, and any conclusion that can be drawn from such data which allows the person to be identified.

Special Category Data: sensitive data within the meaning of Article 9 of the GDPR, in particular data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health data, sex life or sexual orientation, or biometric data.

Data Controller: a natural or legal person who determines the purposes and means of the processing of personal data – in this document, Emily AI Ltd.

Data Processor: a natural or legal person who processes personal data on behalf of the Data Controller.

Processing of Personal Data: any operation or set of operations performed on personal data, such as collection, recording, organisation, storage, alteration, retrieval, consultation, use, transmission, disclosure, alignment, restriction, erasure or destruction.

Consent: a freely given, specific, informed and unambiguous indication of the Data Subject's wishes by which they signify agreement to the processing of personal data.

Personal Data Breach: a security incident that results in the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data.

Confidentiality

In the course of processing personal data relating to natural persons, in addition to complying with the applicable data protection rules, Emily AI Ltd. and the persons acting on its behalf are also subject to a duty of confidentiality.

A confidentiality obligation – with no time limitation – applies to the representative of the Data Controller, its executive officers, all its employees, and all other persons who gain access to information relating to Data Subjects.

The duty of confidentiality does not apply in relation to authorities acting within their statutory powers, including: the National Authority for Data Protection and Freedom of Information (NAIH), courts, investigating authorities, tax and customs authorities, and other bodies authorised by law.

Purpose of Data Processing

The purpose of this Policy is to define, in accordance with Regulation (EU) 2016/679 (GDPR) and Act CXII of 2011, the internal rules and procedures of Emily AI Ltd. relating to the processing of personal data.

Our Company records for each processing activity: the purpose of the processing, the duration of the processing, the recipients of the data, any restrictions on the rights of Data Subjects, as well as other conditions and limitations of the processing.

Scope of Data Processing

This Policy covers all personal data processed by Emily AI Ltd. relating to natural persons, including sole traders, primary agricultural producers and representatives of sole proprietorships.

This Policy does not apply to legal persons or to data relating to legal persons that do not qualify as personal data.

This Policy applies to all data-processing activities carried out by Emily AI Ltd. as Data Controller.

Legal Bases of Individual Data-Processing Activities

1. Processing on the Basis of a Legal Obligation

Certain data-processing activities are based on statutory requirements and do not depend on the Data Subject's consent.

Before starting any such processing, Emily AI Ltd. informs the Data Subject about the mandatory nature, purpose, legal basis, duration of the processing, and who may have access to the data.

2. Processing for the Performance of a Contract

The purpose of the data processing is the performance of a specific contract or cooperation.

The processing of personal data is necessary to establish and maintain the legal relationship in question.

3. Processing on the Basis of the Legitimate Interest

Emily AI Ltd. may process data on the basis of its legitimate interests where processing is necessary for secure operation, efficient service delivery, or protection of business interests.

Any processing based on legitimate interest is supported by a documented balancing test.

4. Processing Based on the Data Subject's Consent

Where the legal basis is voluntary consent, consent is obtained via a data-collection form or electronic form.

Consent is deemed given if the Data Subject indicates agreement by ticking a checkbox or by any other clear affirmative act.

The withdrawal of consent must be as easy as giving consent.

Data Controller Details

Name: Emily AI Korlátolt Felelősségű Társaság (Emily AI Ltd.)

Registered office: 6000 Kecskemét, Gázló utca 23.

E-mail: info@emilycampus.com

Telephone: +36 20 310 0233

Website: www.emilycampus.com

Represented by: Balázs Kenyeres, Managing Director

Emily AI Ltd. is not obliged to appoint a Data Protection Officer under Article 37 of the GDPR. However, a dedicated contact point is available for data protection matters: info@emilycampus.com

Data Security and Personal Data Breach Management

Technical Security Measures

  • HTTPS encryption
  • Server-side firewalls
  • DDoS protection
  • Brute-force and bot protection
  • Regular backups
  • Access logging and protection of log files
  • Automated error-reporting and monitoring systems
  • Use of EU-based data centers and AWS infrastructure
  • System recovery capabilities

Organisational and Administrative Measures

  • Role-based access control
  • Confidentiality obligations for employees and partners
  • Data Processing Agreements (DPA) with all processors
  • Internal IT and data protection protocols
  • Documented data security and incident response procedures
  • Regular internal audits and access reviews
  • Automated internal logging

Method of Storing Personal Data

Personal data are stored in Emily AI Ltd.'s own IT systems and on servers operated by its data processor partners.

All servers and data centers operate within the EU or in a GDPR-compliant environment.

Systems provide protection against computer fraud, espionage, sabotage, vandalism, fire, flood, viruses, unauthorized intrusions, and denial-of-service attacks.

Personal Data Breach Management

In the event of a breach, Emily AI Ltd. shall immediately investigate and take necessary action.

Notify the NAIH within 72 hours if required.

Inform affected Data Subjects if the incident poses a high risk.

Maintain a comprehensive incident register.

Data Processors

MailerSend, Inc.

228 Park Ave S, PMB 54955, New York, NY 10003-1502, USA

Sending transactional and marketing emails, newsletters

info@mailersend.com

Brevo (Sendinblue SAS)

106 boulevard Haussmann, 75008 Paris, France

Newsletter delivery, campaign management, marketing automation

VRNG Consulting Kft.

1013 Budapest, Attila út 2. B. lház. félemelet 5. ajtó

Accounting and financial documents

M. Nagy Ügyvédi Iroda

1013 Budapest, Attila út 2. B. Lph. Fm. 5.

Legal advice, contract drafting, representation

iroda@drnagy.net

Rackhost Zrt.

6722 Szeged, Tisza Lajos körút 41.

Web hosting services

info@rackhost.hu

monday.com Ltd.

6 Yitzhak Sadeh Street, 6777506 Tel Aviv, Israel

CRM system for customer relationships

Billingo Technologies Zrt.

1133 Budapest, Árbóc utca 6. I. emelet

Electronic invoicing

hello@billingo.hu

Data Transfers

Emily AI Ltd. transfers personal data to third parties only if required by law or if the Data Subject has provided explicit consent.

Transfers to authorities occur only when required by law.

Billing-related data are stored for at least 8 years, as required by legislation.

ProviderCountryLegal Basis
MailerSendUSAStandard Contractual Clauses (SCC)
BrevoFrance (EU)Stored within the EU
monday.comIsraelIsrael recognised as providing adequate protection by the EU
AWSEU regionEEA territory

Collection of Personal Data on the Website

1. Data of Website Visitors

Ensuring the operation of the website, monitoring performance, preventing misuse.

  • IP address
  • Date and time of visit
  • URL of the page visited
  • URL of the referring page
  • Type of browser
  • GPS-based location

2 years from the date of visiting the website

2. Requesting a Call-back

  • Name, email address, phone number
  • Name of institution, position
  • Message, fact of consent
  • Visited page and technical data

2 years

3. Newsletter Subscription

Sending newsletters, information and offers. Unsubscribing is possible at any time.

  • Name, email address, phone number
  • Name of institution, position
  • Message, fact of consent

Until withdrawal of consent

4. Client Communication

  • Name, email address, phone number
  • Name of institution, position
  • Message, fact of consent

5 years from closure of the enquiry

Operation and Analysis of the Website

When visiting www.emilycampus.com, the system places cookies on the user's device for identifying visitors, analysing visits, and enhancing security.

For detailed information about cookies, please refer to our Cookie Policy.

Essential cookies: Support basic functions (navigation, secure operation). Legal basis: legitimate interest.

Statistical cookies: Collect anonymous data about website use. Tools: Google Analytics, Yandex Analytics, Hotjar.

Marketing cookies: Support targeted advertising and social media functions. Tools: Google Remarketing, Google Ads, Facebook Remarketing.

Analytics and Marketing Tools

  • Google Analytics: Collects statistical information about visitors, duration, navigation path.
  • Google Remarketing: Combines Analytics data with DoubleClick cookies for ad optimization.
  • Google Ads Conversion Tracking: Measures ad effectiveness with short-lived cookies.
  • Facebook Remarketing: Uses Facebook pixel to build remarketing lists.
  • Yandex Analytics: Statistical information on visitors and navigation.
  • Hotjar: Detailed analysis of user behaviour (heatmaps, scroll patterns).

Disabling Cookies

Cookie settings can be modified in browser settings under Tools → Settings → Privacy / Security → Cookies.

Users can install the Google Analytics opt-out browser add-on to prevent tracking.

Disabling cookies may affect website functionality.

Rights of the Data Subject and Remedies

Right of Access

You have the right to receive confirmation on whether Emily AI Ltd. processes your personal data.

You are entitled to access your personal data and receive information on which data are processed, on what legal basis, for what purpose, from which source, and for how long.

Emily AI Ltd. will provide a copy of the personal data processed. Additional copies may incur a reasonable administrative fee.

Right to Rectification

You may request the correction or completion of inaccurate, incomplete, or outdated personal data.

Emily AI Ltd. will notify any recipients of the rectification, unless doing so is impossible or requires disproportionate effort.

Right to Erasure (Right to be Forgotten)

You may request deletion of your personal data if: the data are no longer needed, you withdraw consent, you object to processing, the processing is unlawful, or deletion is required by law.

Emily AI Ltd. will erase data when the processing purpose no longer exists or the statutory retention period has expired.

Restriction of Processing (Blocking)

Instead of deletion, personal data may be restricted if you request it or deletion would harm your legitimate interests.

During restriction, data may only be stored, processed with explicit consent, or used to establish, exercise or defend legal claims.

Right to Data Portability

You are entitled to receive personal data you provided in a structured, commonly used, machine-readable format.

This right applies only if processing is based on consent or contract and the processing is automated.

Right to Object

You may object to the processing of your personal data if processing is based on legal obligation, legitimate interest, or third-party interest.

Emily AI Ltd. will review the objection within 15 days. If well-founded, processing will cease and data will be blocked.

Right to Lodge a Complaint

You may contact Emily AI Ltd. at info@emilycampus.com

You may also file a complaint with the National Authority for Data Protection and Freedom of Information (NAIH).

Judicial Remedy

If you believe your personal data have been unlawfully processed, you may take the case to court.

The court acts in an expedited procedure. Emily AI Ltd. must prove the lawfulness of its data processing.

Emily AI Ltd. must compensate damage caused by unlawful data processing unless the damage was caused by an unavoidable external event.

Contact

E-mail: info@emilycampus.com

National Authority for Data Protection and Freedom of Information (NAIH)

1125 Budapest, Szilágyi Erzsébet fasor 22/C.

Phone: +36-1-391-1400

E-mail: ugyfelszolgalat@naih.hu

Web: https://www.naih.hu/

Final Provisions

Emily AI Ltd. reserves the right to modify this Privacy Notice especially if legislation changes, a new data processing activity is introduced, or a new processor is engaged.

The amendment enters into force on the day of publication on www.emilycampus.com.

If this Privacy Policy does not answer your question, contact us at info@emilycampus.com

Effective date of this Notice: 11 November 2025