### Privacy Policy

1. **Purpose of the Privacy Policy**
The Hullár Holding Kft. (hereinafter referred to as: service provider, data controller) as a data controller, acknowledges the content of this legal notice as binding. It commits to ensuring that all data processing activities comply with the expectations defined in this policy, applicable national laws, and the legal acts of the European Union.
The data protection principles related to Hullár Holding Kft.'s data processing activities are continuously accessible at https://ebeerbus.com.
Hullár Holding Kft. reserves the right to modify this notice at any time. Any changes will be communicated to the public in a timely manner.
If you have any questions regarding this notice, please write to us, and our colleague will respond.
Hullár Holding Kft. is committed to protecting the personal data of its clients and partners and considers the respect for its clients' informational self-determination rights paramount. Personal data is handled confidentially, and all necessary security, technical, and organizational measures are taken to ensure data security.
Below, we describe our data processing practices.

2. **Data of the Data Controller**
If you wish to contact our company, you can do so at the following contact details:
- Name: Hullár Holding Kft.
- Registered Office: 2310 Szigetszentmiklós, Komp Street 4, Building A, Ground Floor 4
- Company Registration Number: 01-09-208122
- Registering Court: Company Registry Court of the Metropolitan Court
- Tax Number: 25318218-2-13
- Phone Number: +36 70 457-8104
- Email: moc.subreebe%40olleh

Hullár Holding Kft. will delete all emails received, including personal data, after a maximum of 3 years.

3. **Scope of Personal Data Processed**

3.1 **Personal Data Provided During Registration**
Hullár Holding Kft. does not require registration from users.

3.2 **Technical Data**
Hullár Holding Kft. selects and operates the IT tools used for personal data processing in a way that ensures the processed data is accessible to authorized individuals (availability); its authenticity and authentication are ensured (data processing authenticity); its integrity is verifiable (data integrity); and it is protected against unauthorized access (data confidentiality).
Hullár Holding Kft. takes appropriate measures to protect data against unauthorized access, alteration, transmission, disclosure, deletion or destruction, and accidental destruction. It ensures the security of data processing with technical, organizational, and organizational measures that provide a level of protection appropriate to the risks associated with data processing.

3.3 **Cookies**

3.3.1 **Function of Cookies**
Cookies collect information about visitors and their devices; remember visitors' custom settings; facilitate the use of the website; and provide a quality user experience.

3.3.2 **Essential, Session Cookies**
The purpose of these cookies is to allow visitors to browse the Hullár Holding Kft. website smoothly, use its functions, and access the services available there. These types of cookies are automatically deleted when the browser is closed.

3.3.3 **Third-Party Cookies (Analytics)**
Hullár Holding Kft. uses Google Analytics cookies on its website. Google Analytics collects information about visitors' website usage for statistical purposes, which is used to develop the website and improve the user experience.

3.4 **Data Related to Online Orders**
During online administration, the customer's name, email address, phone number, and booking time are recorded.

3.5 **Data Related to Online Administration**
During online administration, the customer's name and email address are recorded.

4. **Intended Use and Retention Period of Processed Data**

| Data Processing Name | Use | Retention Period |
|----------------------|--------------------------|------------------|
| Full Name | Identity Verification | 36 months |
| Email Address | Contact | 36 months |
| Phone Number | Contact | 36 months |
| IP Address | Fraud Prevention | 36 months |
| Booking Time | Booking Identification | 36 months |

5. **Purpose, Method, and Legal Basis of Data Processing**

5.1 **General Data Processing Principles**
Hullár Holding Kft.'s data processing is based on voluntary consent or statutory authorization. In the case of data processing based on voluntary consent, data subjects can withdraw their consent at any time.
In certain cases, the processing of provided data is made mandatory by law, of which we notify our customers separately.
Data providers are obliged to obtain the consent of the data subject if they do not provide their own personal data.
The data processing principles are in line with the applicable data protection legislation, particularly the following:
- Act CXII of 2011 on the Right of Informational Self-Determination and Freedom of Information (Info Act)
- Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR)
- Act V of 2013 on the Civil Code (Civil Code)
- Act C of 2000 on Accounting (Accounting Act)
- Act LIII of 2017 on the Prevention and Combating of Money Laundering and Terrorist Financing (AML/CFT Act)
- Act CCXXXVII of 2013 on Credit Institutions and Financial Enterprises (Credit Institutions Act)

6. **Physical Storage Locations of Data**
Your personal data (i.e., data that can be associated with you) may be processed by us in the following ways: firstly, technical data related to the connection established with your computer, browser program, internet address, and the visited pages are automatically recorded in our computer system during the maintenance of the internet connection; secondly, you may provide your name, contact information, or other data if you wish to establish a personal connection with us during the use of the website. The technically recorded data during the system's operation are: the data of the logging-in computer generated during the voting process and recorded automatically by the Hullár Holding Kft system as an automatic result of technical processes. The automatically recorded data is logged by the system at the time of entry and exit without any separate declaration or action by the data subject. These data cannot be linked with other personal user data, except in cases mandated by law. Only Hullár Holding Kft has access to the data.

7. **Rights and Legal Remedies of Data Subjects**
Data subjects can request information about the processing of their personal data, request the correction, deletion, and withdrawal of their personal data – except for mandatory data processing – and exercise their data portability and objection rights in the manner indicated at the time of data collection, and through the data controller’s above contact details.

7.1 **Right to Information**
Hullár Holding Kft takes appropriate measures to provide data subjects with all information regarding the processing of personal data referred to in Articles 13 and 14 of the GDPR and any information under Articles 15 to 22 and 34 in a concise, transparent, intelligible, and easily accessible form, in clear and plain language.

7.2 **Right of Access**
The data subject has the right to obtain confirmation from the data controller as to whether or not personal data concerning them is being processed, and if so, the right to access the personal data and the following information: the purposes of the processing; the categories of personal data concerned; the recipients or categories of recipients to whom the personal data have been or will be disclosed, particularly recipients in third countries or international organizations; the envisaged period for which the personal data will be stored; the existence of the right to request rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; the right to lodge a complaint with a supervisory authority; any available information as to the source of the personal data; the existence of automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject. The data controller provides the requested information within a maximum of one month from the submission of the request.

7.3 **Right to Rectification**
The data subject can request Hullár Holding Kft to rectify inaccurate personal data concerning them and to complete incomplete data.

7.4 **Right to Erasure**
The data subject has the right to obtain from Hullár Holding Kft the erasure of personal data concerning them without undue delay if one of the following grounds applies:
- The personal data is no longer necessary for the purposes for which they were collected or otherwise processed;
- The data subject withdraws consent on which the processing is based and there is no other legal ground for the processing;
- The data subject objects to the processing and there are no overriding legitimate grounds for the processing;
- The personal data has been unlawfully processed;
- The personal data must be erased to comply with a legal obligation in Union or Member State law to which the data controller is subject;
- The personal data has been collected in relation to the offer of information society services.

Erasure of data cannot be initiated if processing is necessary for the following purposes: exercising the right of freedom of expression and information; compliance with a legal obligation requiring processing by Union or Member State law to which the data controller is subject; performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; public health purposes or archiving purposes in the public interest, scientific or historical research purposes or statistical purposes based on public interest; or for the establishment, exercise, or defense of legal claims.

7.5 **Right to Restriction of Processing**
The data subject has the right to obtain from Hullár Holding Kft restriction of processing if one of the following applies:
- The accuracy of the personal data is contested by the data subject, for a period enabling the data controller to verify the accuracy of the personal data;
- The processing is unlawful, and the data subject opposes the erasure of the

personal data and requests the restriction of their use instead;
- The data controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise, or defense of legal claims;
- The data subject has objected to processing, pending the verification whether the legitimate grounds of the data controller override those of the data subject.

Where processing has been restricted under the grounds outlined above, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State.

7.6 **Right to Data Portability**
The data subject has the right to receive the personal data concerning them, which they have provided to a data controller, in a structured, commonly used, and machine-readable format, and have the right to transmit those data to another data controller without hindrance from the data controller to which the personal data has been provided, if the processing is based on consent or on a contract and the processing is carried out by automated means.

7.7 **Right to Object**
The data subject has the right to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them, including profiling based on these provisions. Hullár Holding Kft shall no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defense of legal claims.

7.8 **Right to Withdraw Consent**
The data subject has the right to withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

7.9 **Right to Lodge a Complaint**
The data subject has the right to lodge a complaint with a supervisory authority if they consider that the processing of personal data relating to them infringes the GDPR.

8. **Data Security**
Hullár Holding Kft ensures the security of data by implementing appropriate technical and organizational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

9. **Contact Information**
For further information, or if you wish to exercise your rights as a data subject, please contact us at .moc.subreebe%40olleh

10. **Effective Date**
This Privacy Policy is effective from January 1, 2022.

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This Privacy Policy is subject to change. Please check back periodically for updates.

If you have any questions or concerns regarding our privacy practices, please contact us at .moc.subreebe%40olleh

* The service provider reserves the right to charge the damaging party the actual and verified amount of the damages over the flat rate of the compensation.**Accidentally spilled drinks does not apply, although we ask passengers to notify the bus crew about these cases.

Refunds: In case of an inadequate or cancelled service passengers are entitled to a full or partial (proportionate) refund of the fare. The claim for refund may be declared while presenting the ticket at the customer service or in e-mail at .moc.tsepadubsubreeb%40ofni The service provider reserves the right to cancel the service in case the number of passengers is under 5 (five) persons. In this case passengers who already bought fares may choose a full refund of the fare or changing the ticket for another time. In case a passenger is unable to use the service from reasons under their own control fares will not be refunded.
Force majeure: In case a passenger cannot use the service due to unforeseeable and uncontrollable reasons beyond their control (force majeure) they have to inform the service provider without delay, in which case the fare already paid will be fully reusable within one year. The passenger has to pay compensation for damages caused by the unreasonable delay of this informing.In case of legal or public authority measures (e.g. in order to prevent an epidemic or as a direct consequence of one) introduced after the time of the order put extra load on one of the parties (e.g. travel restrictions, quarantine), the parties will use the force majeure provisions.
Forgoing services: In case a passenger forgoes the service at least 5 days (120 hours) before the start the fares they paid will be fully reusable within one year. In case of forgoing the service within 5 days fares will not be refunded and neither can start time be modified.
Accidents and damaged baggage: Passengers are responsible to fully comply with traffic safety regulations. The bus moves during the sightseeing therefore passengers are required to hold the handrails on the bus. The service provider does not assume responsibility for cases when the passenger suffers an accident due to their own or to other, third parties’ fault. The service provider limits responsibility for the breach of contract at the amount of the fare except for responsibility for intentional breach of contract or for causing damages resulting in loss of life, or harm to physical integrity or health.
Consuming alcohol, food and beverages, smoking and pets on board: It is forbidden to smoke or use narcotics on the bus. It is forbidden to consume food or beverages on the bus except for those provided as part of the service. It is allowed to consume bottled soft drinks. It is forbidden to bring any kind of pets on the bus.
Settlement of complaints:In case of any problems, complaints or requests please contact our colleagues at .moc.subreebe%40olleh The contract between the parties is otherwise governed by Hungarian law and only Hungarian courts have jurisdiction.