Privacy policy

General information and mandatory disclosures
What is personal data?
Personal data in this sense is any information relating to personal or material circumstances
that relates to an identified or identifiable individual. This includes, for example, your name,
date of birth, e-mail address, postal address, or telephone number as well as online
identifiers such as your IP address. In contrast, information of a general nature that cannot
be used to determine your identity is not personal data. This includes, for example, the
number of users of a website.
Person responsible
The person responsible for processing pursuant to the UK`s Data Protection Act (“DPA”) and
the General Data Protection Regulation (“GDPR”) is:
Andras VAGANY
Correspondence address
Flat 11 Eldridge House 104-108, Hounslow Road, Feltham, England, TW14 0BY

Scope of the processing of personal data
As a matter of principle, we only collect and use personal data from you insofar as this is
necessary to provide a functional website and our content and services. This also includes
disclosure by transmission to third parties and, where applicable, to so-called third countries
outside the United Kingdom (“UK”) and the European Union („EU”) and the European
Economic Area („EEA”). Where we transfer data outside the UK, EU, EEA, I have described
it below.
Further, and in regard to the transfer of data into the USA, there is no adequacy decision of
the EU Commission for transfers to the USA. However, where we use third party providers in
the USA, we have made sure that an adequate level of data protection is guaranteed and
that the relevant agreements are entered into.
Relevant legal basis
In accordance with the GDPR, the following legal basis, apply to the processing of your
personal data:
 the legal basis for obtaining consent is Art. 6(1)(a) and Art. 7 GDPR,
 the legal basis for processing in order to fulfil our services and carry out contractual
measures and respond to enquiries is Art. 6(1)(b) GDPR,
 the legal basis for processing in order to fulfil our legal obligations is Art. 6(1)(c)
GDPR, and
 the legal basis for processing in order to protect our legitimate interests is Art. 6(1)(f)
GDPR.
Your rights

You have the following rights with regard to personal data concerning you, which you can
assert against us:
 Right of access (Art. 15 GDPR),
 Right to rectification (Art. 16 GDPR) or erasure (Art. 17 GDPR),
 Right to restriction of processing (Art. 18 GDPR),
 Right to object to processing (Art. 21 GDPR).
 Right to withdraw your consent (Art. 7(3) GDPR),
 Right to receive the data in a structured, common, machine-readable format („data
portability”) as well as the right to have the data transferred to another controller if the
conditions of Art. 20 (1) lit. a, b GDPR apply (Art. 20 GDPR).
You can assert your rights and withdraw your consents given by notifying me using the
contact details provided.
You also have the right to complain to a data protection supervisory authority about the
processing of your personal data carried out by me (Art. 77 GDPR). The Information
Commissioner`s Office (ICO) is the relevant authority in the UK. The ICO is located at
Wycliffe House, Water Ln, Wilmslow SK9 5AF, UK (www.ico.org.uk). I would, however,
appreciate the chance to deal with your concerns before you approach any supervisory
authority.
Automatic collection of general data and information
1. Hosting
The hosting services used for the purpose of operating our website is Namesco. In doing so
Namesco, processes all data and communication data of my customers, interested parties
and visitors of our website and services that is provided through the website. We use
Mxhost, on the basis of my legitimate interests (Art. 6 (1) f) GDPR) in an efficient and secure
provision of the website and services in conjunction with the provision of contractual services
and the conclusion of the contract for my services.
2. Content Management System (CMS)
We also use the Content Management System (CMS) of WordPress a service provided
by  Automattic Inc (USA) , to publish and maintain the created and edited content and texts on
my website. This means that all content and texts submitted to us by users for publication is
transferred to WordPress. In addition to texts, this also includes, for example your data in our
forms. The legal basis for this processing is our legitimate interest (Art. 6 (1) f) GDPR).
3. Logfiles
Each time you visit our website, a number of general data and information is transmitted –
even if you use my website for purely informational purposes. Namesco LTD collects the
general data and information that your browser transmits to my website`s server. This data
and information collected are technically necessary for the display my website to you and
that serve the stability, security and danger or threat prevention in the event of attacks on my
website, such as:
 IP address
 date and time of an access to the website

 type and version of browser used
 operating system used and its interface
 the website from which an accessing system arrives at my website (so-called
referrer)
 sub-websites that are accessed via an accessing system on my website,
 Internet service provider of the accessing system.
This data is deleted after the storage is no longer necessary for error analysis or danger or
threat prevention. The legal basis for this data processing is my legitimate interest (Art. 6 (1)
f) GDPR). When analysing these general data and information, I do not draw any
conclusions about you as a data subject.
4. Use of cookies
A cookie is a small simple file that is stored by your browser on the hard drive of your
computer or device and sent when you visit a website. The information stored in cookies is
then returned (depending on the cookie) to our servers (or to the servers of the relevant third
parties) on a subsequent visit. Doing so, Cookies transmit small amounts of data about your
device to the relevant web server and enables a website to recognise your computer,
smartphone, or other device. For further information on the cookies used on my website
please refer to my Cookie Policy. The legal basis for this data processing is my legitimate
interest (Art. 6 (1) f) GDPR).
5. Google Fonts
I integrate the fonts of the provider Google Inc, whereby the user’s data is used solely for the
purpose of displaying the fonts in the user’s browser. The integration is based on my
legitimate interest (Art. 6 (1) f) GDPR) in a technically secure, maintenance-free and efficient
use of fonts, their uniform display and taking into account possible licensing restrictions for
their integration.
6. WPForms
We use the standard version of the WP Forms plugin to process enquiries. According to the
developer’s privacy policy, this is done by WP Forms in the standard version: No data theft,
no storage of your form entries on the software provider’s website, No sending of data to
external servers, No use of cookies.
The use of our contact form is done with the consent of the user to store personal data is
your consent and my legitimate interest (Art. 6 (1) f) GDPR).
7. Google Tag Manager
We use Google Tag Manager, a web analytics service provided by Google, Inc. This service
allows website tags to be managed via an interface. The Google Tag Manager only
implements tags. No cookies are set, and no Personal information is collected. The Google
Tag Manager triggers other tags that may collect data. The Google Tag Manager does not
access this data.  If a deactivation has been made at domain or cookie level, it remains in
place for all tracking tags, insofar as these are implemented with the Google Tag Manager.
More information on the Google Tag Manager can be found at the following
link: http://www.google.com/tagmanager/use-policy.html. The legal basis for this data
processing is my legitimate interest (Art. 6 (1) f) GDPR).

8. Cookie Consent manager
We have integrated the consent management „GDPR Cookie Consent” from  Mozilor
Limited  trading as WebToffee to request consent for data processing or the use of cookies.
The purpose of integrating „GDPR Cookie Consent” is to allow the users of our website to
decide on the use of Cookies and, in the course of further use of our website, to offer them
the opportunity to change settings they have already made. In the course of using „GDPR
Cookie Consent”, personal data as well as information of the end devices used, such as the
IP address, are processed. The legal basis for the processing is your consent (Art. 6 (1) a)
GDPR) in conjunction with my legitimate interest(Art. 6 (1) f) GDPR) and my legal
obligation (Art. 6 (1) c) GDPR).
9. Google AdSense
We use Google AdSense, a web advertising service provided by Google Inc. Google
AdSense uses so-called „DoubleClick DART Cookies” („Cookies”). In addition, Google
AdSense also uses so-called „web beacons” (small invisible graphics) to collect information,
through the use of which simple actions such as user traffic on our website can be recorded,
collected and evaluated. For further information please refer to my Cookie Policy. The legal
basis for the processing of your data is my legitimate interest (Art. 6 (1) f) GDPR) in the
targeted use of advertising.
10. Google reCAPTCHA
We also use Google`s reCAPTCHA from Google Inc. to check whether data input is made
by a human being or by an automated program. For this purpose, reCAPTCHA analyses the
behaviour of the website visitor on the basis of various characteristics. This analysis begins
automatically as soon as the website visitor enters the website. The legal basis for the data
processing is our legitimate interest in operating a secure and spam free website.
Collection of personal data and information when provided
1. Contact options via the website
Contacting us is made possible by e-mail, contact form or social media (Facebook, Youtube,
TikTok). If you contact us, your transmitted personal data will be automatically stored for the
purpose of processing the request or contacting you. Data processing for the purpose of
contacting us is carried out on the basis of your voluntarily given consent (Art. 6 (1) a)
GDPR) or, in the case of a (pre-)contractual relationship with us, the initiation of a
contractual service (Art. 6 (1) b) GDPR). We delete the data accruing in this context after the
storage is no longer necessary for the processing of your request or restrict the processing if
there are legal retention obligations.
2. Purchase based processing
We collect, store, and process your data for the entire processing of your purchase, (Art. 6
(1) b) GDPR).  Your personal data will only be passed on to third parties or otherwise
transferred if this is necessary for the purpose of contract processing or billing or if you have
given your prior consent. In the context of order processing, for example, the service
providers we use (such as carriers, logistic companies) payment service providers receive
the necessary data for order and order processing. The data passed on in this way may only
be used by our service providers to fulfil their task within the framework of a contract
processing agreement in accordance with the DPA and GDPR. Any other use of the
information is not permitted and does not take place with any of the service providers
entrusted by me.

3. Membership Administration and contact management
We process data within the scope of administrative tasks as well as organisation of the
membership, our business, financial accounting (Art. 6 (1) f) GDPR), and compliance with
legal obligations, such as archiving (Art. 6 (1) c) GDPR). In doing so, we process the same
data that we process in the context of providing our contractual services to members. The
purpose and our interest in the processing thus lies in the administration, financial
accounting, archiving of data, i.e., tasks that serve the maintenance of my business
activities, performance of our tasks and provision of our services. In this context, we disclose
or transmit data to the tax authorities, consultants such as tax advisors or auditors as well as
other fee offices and payment service providers.
Disclosure of data to third parties, Security and Storage
1. Disclosure of data to third parties
I will only share your personal data with third parties if:
 you have given your express consent to do so (Art. 6 (1) a) GDPR),
 the disclosure is necessary for the assertion, exercise or defence of legal claims and
there is no reason to assume that you have an overriding interest worthy of
protection in the non-disclosure of your data (Art. 6 (1) f) GDPR),
 in the event that there is a legal obligation for disclosure (Art. 6 (1) c) GDPR), as well
as
 this is legally permissible and necessary for the processing of contractual
relationships with you (Art. 6 (1) b) GDPR).
2. General technical organisational measures (Security)
I have taken a variety of security measures to protect personal data to an appropriate extent
and adequately. All information held by me is protected by physical, technical, and
procedural measures that limit access to the information to specifically authorised persons
and in accordance with the GDPR and this Privacy Policy.
In addition, where we use third parties to carry out processing only those who need the
information to perform a specific job are granted access to personal data. If this is the case
these companies act on our behalf by way of commissioned processing and may therefore
use the data provided exclusively in accordance with our instructions. In this case, we are
legally responsible for appropriate data protection measures at the companies we
commission. We therefore agree on specific data security measures with these companies
and monitor them regularly.
If we use service providers in third countries, we take additional measures to ensure an
adequate level of data protection for the transfer of personal data and thus ensure that the
transfer is generally permissible and that the special requirements for a transfer to a third
country are met (e.g., by concluding standard contracts and additional guarantees,
supplementary technical and organisational measures such as encryption or anonymisation).
Finally, we may need to disclose your data to authorities or government agencies if we are
legally obliged to do so, for example, due to official or court orders, or because this is
necessary for the prosecution of criminal offenses or for the exercise and enforcement of our
rights and claims.

3. Duration of storage
We store your personal data for as long as necessary to achieve the respective storage
purpose. Afterwards, your data will be deleted, unless I am obliged to store it for a longer
period of time (Art. 6 (1) c) GDPR) due to tax, commercial or other legal storage or
documentation obligations, or you have agreed to a storage beyond this period (Art. 6 (1) a)
GDPR).
Miscellaneous and closing
1. Links to others
Our website contains so-called hyperlinks to websites of other providers. When you activate
these hyperlinks, you will be redirected from my website directly to the website of the other
provider. You will recognise this by the change of URL, among other things. I cannot accept
any responsibility for the confidential handling of your data on these third-party websites, as I
have no influence on whether these companies comply with data protection regulations.
Please inform yourself about the handling of your personal data by these companies directly
on these websites.
2. Social Media
We are present on Instagram, Facebook, TikTok, YouTube to communicate with our
followers, interested parties and users registered there and to be able to inform them about
our offers there. We would like to point out that you use these platforms and their functions
on your own responsibility. This applies in particular to the use of the interactive functions
(e.g., commenting, sharing, rating). The processing of users’ personal data is based on my
legitimate interests in providing users with effective information and communicating with
users (Art. 6 (1) f) GDPR).
3. Accuracy and updating your information
It is important that the data we hold about you is accurate and current, therefore please keep
us informed of any changes to your personal data. If you believe that the information, we
hold about you is inaccurate or that we am no longer entitled to use it and want to request its
rectification, deletion, or object to its processing, please do so by contacting us.
For your protection and the protection of all of users, we may ask you to provide proof of
identity before I can answer your requests. Also please keep in mind, that we may reject
requests for certain reasons, including if the request is unlawful or if it may infringe on trade
secrets or intellectual property or the privacy of another user. Lastly, we may not be able to
accommodate certain requests to object to the processing of personal data, notably where
such requests would not allow us to provide my service to you anymore.
4. Withdrawing your consent
You may withdraw your consent and request us to stop using and/or disclosing your
Personal Data for any or all of the Purposes by submitting your request to us in writing.
Should you withdraw your consent to the collection, use or disclosure of your Personal Data,
it may impact our ability to proceed with your transactions, agreements, or interactions with
us. Prior to you exercising your choice to withdraw your consent, we will inform you of the
consequences of the withdrawal of your consent. Please note that your withdrawal of
consent will not prevent us from exercising our legal rights (including any remedies) or
undertaking any steps as we may be entitled to at law.
5. Data Breaches/Notification

Databases or data sets that include personal data may be breached inadvertently or through
wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected
individuals whose personal data may have been compromised, and the notice will be
accompanied by a description of action being taken to reconcile any damage as a result of
the data breach. Notices will be provided as expeditiously as possible after which the breach
was discovered.
6. Personal data and children
Our services are aimed at people aged 18 and over. We will not knowingly collect, use, or
disclose personal data from minors under the age of 18 without first obtaining consent from a
legal guardian through direct offline contact.
Changes
We reserve the right to adapt this privacy policy with effect for the future, in particular in the
event of further development of the website, the use of new technologies or changes to the
legal basis or the relevant case law.
Questions or Comments
If you have any questions or comments about our Privacy Policy or wish to exercise your
rights under applicable laws, please contact us. This Privacy Policy was last updated on 1 st
of January 2025.