Privacy Notice
LEATEX Kft.
PRIVACY NOTICE
concerning the processing of personal data in connection with the leatex.eu website and the operations of LEATEX Kft.
1. Data controller
Company name: LEATEX Ruházati Kiskereskedelmi Korlátolt Felelősségű Társaság (short name: LEATEX Kft.)
Registered seat: 3390 Füzesabony, Hunyadi út 4., Hungary
Site: 3390 Füzesabony, Kerecsendi út 6., Hungary
Company registration number: 10-09-024204 (Regional Court of Eger, acting as Court of Registration)
Tax number: 12372625-2-10
E-mail: contact@leatex.eu
(hereinafter: the “Controller” or the “Company“)
The Company processes personal data obtained through the use of the website and through its business activities carried out at its site, in accordance with this notice.
The Company has not appointed a Data Protection Officer, as the nature, scope and purposes of its data processing activities do not make such appointment mandatory under Article 37 of the General Data Protection Regulation (GDPR). The Company is not subject to any separate registration obligation with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH), since NAIH has not maintained such a prior registration system since the GDPR entered into force.
2. Purpose and scope of this notice
The purpose of this notice is to provide data subjects who are natural persons (“Data Subject”) with appropriate information about the processing of their personal data by the Company, including the purpose, legal basis and duration of the processing, as well as their rights and available remedies in connection with the processing.
This notice is based on, among others, the following legislation:
- Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation, “GDPR”);
- Act CXII of 2011 on the Right of Informational Self-Determination and Freedom of Information (Hungary) (“Info Act”);
- Act V of 2013 on the Civil Code (Hungary) (“Civil Code”);
- Act CXXXIII of 2005 on Security Services and the Activities of Private Investigators (Hungary) (“Security Services Act”) – with respect to camera surveillance.
This notice applies to the processing of personal data carried out in connection with the use of the leatex.eu website, and in connection with the business activities the Company carries out at its site in Füzesabony, Hungary.
3. Processing carried out through the website
The leatex.eu website does not currently offer account registration, online order placement, newsletter subscription, or job applications. Through the website, visitors may provide their contact details in the following two ways:
- by completing the quote request form, primarily used by prospective new wholesale partners to make inquiries;
- by using the callback request feature.
The personal data processed, the purpose, legal basis and retention period applicable to each of the above are summarised in the table below:
| Personal data processed | Purpose of processing | Legal basis for processing | Retention period |
|---|---|---|---|
| Quote request form: name, company name, e-mail address, phone number, country, message text | Responding to wholesale quote requests submitted through the website; establishing contact; preparing offers | Consent of the data subject (GDPR Art. 6(1)(a)); taking steps at the request of the data subject prior to entering into a contract (GDPR Art. 6(1)(b)) | 1 year from submission, or until conclusion of a contract / until the business relationship ends, whichever is applicable |
| Callback request: name, phone number, optional message | Calling the inquirer back; establishing contact | Consent of the data subject (GDPR Art. 6(1)(a)) | 1 year from submission, or until the callback has taken place / until the business relationship ends |
Providing the requested data is voluntary in all cases. If the requested data is not provided, the Company will not be able to process the quote request or the callback request.
If an inquiry actually results in a business relationship or a contract, any further processing connected with that relationship (e.g. entering into the contract, invoicing, performance) will be governed by the specific rules and retention periods set out in the applicable contractual, accounting and tax legislation (e.g. Act C of 2000 on Accounting), about which the Company will inform the Data Subject when the contract is concluded.
4. Use of cookies
The website only uses cookies that are strictly necessary for its technical operation, for purposes such as ensuring the website is displayed correctly and securely and that its forms function properly. The website does not use statistical or analytics cookies (e.g. Google Analytics) or marketing cookies, and does not enable tracking by any third party.
The legal basis for the use of strictly necessary cookies is the Company’s legitimate interest (GDPR Art. 6(1)(f)) in operating the website securely and as intended; under Act C of 2003 on Electronic Communications (Hungary), no separate consent is required for the placement of such cookies.
5. Processing carried out at the site (facility and shop)
The shop operated at the Company’s site (3390 Füzesabony, Kerecsendi út 6.) is used primarily by retailers making purchases. Any related processing that is mandated by law (e.g. issuing an invoice where requested by the customer, or the statutory obligation to issue a cash-register receipt) is carried out on paper, in accordance with the retention periods set out in the applicable accounting and tax legislation (in particular Act C of 2000 on Accounting), which is typically 8 years. The Company processes this data solely for the purpose of complying with its legal obligations, on the basis of GDPR Art. 6(1)(c) (compliance with a legal obligation).
6. Camera surveillance at the site
The Company operates a camera (CCTV) system at its Füzesabony site for the purposes of protecting property, protecting human life and physical safety, and preventing and providing evidence of unlawful acts (in particular theft and damage to property).
The legal basis for this processing is the Company’s legitimate interest (GDPR Art. 6(1)(f)), having regard also to the provisions of Act CXXXIII of 2005 on Security Services and the Activities of Private Investigators (Hungary) (“Security Services Act”).
Areas subject to camera surveillance are marked with clearly visible warning signage (pictogram and/or notice) at the entrance. Recordings are retained by the Company only for as long as necessary to achieve the purpose set out in the Security Services Act and, absent any unlawful act, for no longer than the period specified by that Act, after which the recordings are deleted – unless the data is required as evidence in ongoing court or authority proceedings, or is otherwise necessary to substantiate a legitimate interest of the Company.
The detailed rules governing camera surveillance (exact camera placement, retention period, persons entitled to access the recordings, and the procedure for releasing recordings) are set out in the Company’s internal CCTV Operating Policy.
7. Data processors and data transfers
The website is hosted and operated on the Company’s own server; the Company does not currently use any external hosting provider or other data processor in connection with operating the website.
The Company does not transfer the personal data in its possession to any third party, except where required by law, and no personal data is currently transferred to any third country (i.e. outside the European Economic Area).
Should the Company engage an external service provider in the future (e.g. a hosting provider, accountant, or IT service provider), it will enter into a data processing agreement with that provider pursuant to Article 28 of the GDPR, and will update this notice accordingly.
8. Data security measures
The Company applies appropriate technical and organisational measures to ensure the security of the personal data it processes, and protects such data against unauthorised access, alteration, transmission, disclosure, erasure or destruction, as well as against accidental loss or damage and against becoming inaccessible as a result of changes in the technology used.
Personal data processed on paper is stored by the Company in a closed location that is not accessible to unauthorised persons; personal data processed electronically is accessible only to authorised staff members.
9. Rights of data subjects
Under the GDPR, the Data Subject has the following rights in connection with the processing of their personal data:
- Right to information and access (Art. 15): the Data Subject has the right to obtain confirmation as to whether their personal data is being processed and, if so, to access the data being processed and related information.
- Right to rectification (Art. 16): the Data Subject may request the rectification of inaccurate data or the completion of incomplete data.
- Right to erasure (“right to be forgotten”) (Art. 17): in certain cases, the Data Subject may request the erasure of their data.
- Right to restriction of processing (Art. 18): in certain cases, the Data Subject may request that the processing of their data be restricted.
- Right to object (Art. 21): where processing is based on legitimate interest, the Data Subject may object to the processing of their data.
- Right to data portability (Art. 20): where processing is based on consent or on a contract and is carried out by automated means, the Data Subject may request that their data be provided in a structured, commonly used, machine-readable format.
- Right to withdraw consent: where processing is based on consent, the Data Subject may withdraw that consent at any time, free of charge and without any restriction or need to state a reason; withdrawal does not affect the lawfulness of processing carried out prior to the withdrawal.
The Data Subject may exercise the above rights by contacting the Company at the details given in Section 1 (primarily by e-mail at contact@leatex.eu). The Company will comply with the request without undue delay, and in any event within one month of receiving it, or will inform the Data Subject of the reasons for refusing the request.
10. Remedies
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
Phone: +36 (1) 391-1400; E-mail: ugyfelszolgalat@naih.hu; Website: www.naih.hu
Judicial remedy
The Data Subject is entitled to bring proceedings against the Controller before a court if their rights have been infringed. Such proceedings fall within the jurisdiction of the regional courts (törvényszék); at the Data Subject’s choice, proceedings may be brought before the regional court having jurisdiction over the Data Subject’s place of residence or habitual residence.
11. Amendments to this notice
The Company reserves the right to unilaterally amend this notice in line with applicable legislation. The version of this notice in force at any given time is available on the Company’s website.
12. Effective date
This notice is effective as of [month] [day], 2026.
This English version is a translation of the Hungarian-language original privacy notice (“Adatkezelési Tájékoztató”). In the event of any discrepancy between the two versions, the Hungarian version shall prevail.