The purpose of this Privacy Notice is to provide you with accurate and comprehensive information regarding the use of your personal data with respect the online platform operated by BRTH Limited Company.
This Privacy Notice was prepared in view of the relevant laws and regulations, most notably:
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, and repealing Directive 95/46/EC (General Data Protection Regulation, “GDPR”);
The Hungarian Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information;
The Hungarian Act CVIII of 2001 on Electronic Commerce and on Information Society Services;
The Hungarian Act C of 2003 on Electronic Communications.
Definitions
This list of definitions is aimed at helping you to better understand this Notice.
Notice: this Privacy Notice.
Personal data: any information relating to an identified or identifiable natural person such as a name, or contact data, based on which the given natural person can be directly or indirectly (that is, combined with other information) identified.
Data subject: you, as a natural person (regardless of whether you are acting on behalf of a company or as a sole entrepreneur) with respect to whom the Data Controller processes Personal data.
Data Controller or “we”: the entity determining the purposes and means of the Data processing. The controller of your Personal data is BRTH Limited Company (company registry number: 08-09-036879; registered seat: 210. ajto, II. emelet, 10/A, Szent Istvan ut, HU-9021, Gyor, Hungary).
Data processing: any action performed on Personal data by the Data Controller, such as collection, storage, transmission, modification or erasure.
Data Processor: an entity which processes Personal data on our behalf, as per our instructions (see the list of Data Processors in Section 6.1).
Recipient: any third person (thus neither us nor you) to which we transfer Personal data or otherwise has access to the Personal data.
Platform: the online platform (https://anyfeedback.co/) operated by the Data Controller.
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, in particular to analyse or predict aspects concerning that natural person's preferences, interests. We conduct profiling when we send you personalized direct marketing content based on your activity carried out on the Platform.
The Platform and the Data Controller
The Data Controller is the operator of the Platform.
Registered seat and postal address: 210. ajto, II. emelet, 10/A, Szent Istvan ut, HU-9021, Gyor, Hungary
Company registration number: 08-09-036879
E-mail: support@anyfeedback.co
The Platform is an online surface which connects clients with mentors across a wide range of fields to provide feedback for the clients.
Operating the Platform necessarily entails the processing of Personal data. You can find the detailed description of such data processing in Section 4.
What are the principles of our Data processing?
When processing your Personal data, we adhere to the following principles:
we process your Personal data lawfully, fairly and in a transparent manner. This means that you will always be provided with all the relevant information that relates to how and why your Personal data is processed and what privacy-related rights you may exercise during the course of the Data processing.
The Data processing will always have a valid, real and lawful purpose. We will never process your Personal data for non-disclosed or not sufficiently specific purposes.
We do not collect or store any data that is not necessary for the purposes described in Section 4.
We do not store your data indefinitely and the applicable data retention periods are communicated to you in a transparent manner. Once the given retention period is over, your data will be permanently erased.
We do our best to ensure that your Personal data is kept accurate and up to date. For this purpose, we kindly ask you to inform us of any change in your Personal data that we process so that we can update the Personal data accordingly.
We always take appropriate steps to ensure the safety of your Personal data and minimize the risk of unauthorized access, disclosure or any other event or data breach. To achieve this, we use up-to-date and risk-based IT systems, as well as reliable contractual partners with a solid market reputation.
We know that first and foremost, you are the one who has the right to decide what happens to your Personal data. We examine and address any queries, requests or complaints you have in relation to the processing of your Personal data and within the statutory deadline. If we deem it necessary in light of your complaint or request, we will take the appropriate steps without any delay.
How do we process your Personal data?
In this Section we describe how your Personal data is processed by us. This helps you understand what Personal data we process, why, on what legal grounds and for how long.
Personal data processed during platform registration
What Personal data do we process?
If you are a client:
the full name, e-mail address, status (private individual, sole entrepreneur or behalf of a business entity) of the client registering the account;
profile picture;
billing details;
logging data (e.g. date of registration);
if you registered behalf of a business entity, in addition to the above information: name, tax number and registered office of the business entity
If you are a mentor:
all above mentioned information (as all mentor registrations require the registration as a client first);
services and service descriptions in which you provide feedback;
indicative minimum project price;
Stripe account details and bank account number;
if you registered on behalf of a business entity, in addition to the above information: name, tax number and registered office of the business entity. In such a case, your name and email address will be handled as contact information of the contact person of the business entity.
Why do we process your Personal data?
Enabling registration to the Platform.
Creating client and mentor account for you.
Ensuring password reset for your account if necessary.
On what legal grounds do we process your Personal data?
If you are a private person or a sole entrepreneur: the fulfillment of the contract resulting from the acceptance of the Client and / or Mentor General Terms and Conditions ("Client and / or Mentor GTC")
If you registered on behalf of a business entity: legitimate interest in fulfilling the provisions of the Client and / or Mentor GTC accepted during registration.
How long do we retain your Personal data?
Until the deletion of the created client or mentor account.
Until you, as Data subject, object to the Data processing and our assessment finds no compelling cause that overrides your objection.
Personal data processing during Platform usage
What Personal data do we process?
If you are a client:
Personal data related to the jobs created by you;
Personal data related to the feedback received by you;
the Personal data content of certain documents, pictures, videos, etc. uploaded by you to the Platform in connection with the fulfillment of the contract;
the review you give about the mentor;
your credit balance;
logged data relating to the your activity on the Platform.
If you are a mentor:
Personal data related to the Quote you give to a client;
Personal data related to the feedbacks given by you to a Client;
the review about you given by the client;
Why do we process your Personal data?
Fulfillment of the contract created by accepting the Client and / or Mentor GTC, maintaining contact during the fulfillment of the contract.
On what legal grounds do we process your Personal data?
If you are a private person or a sole entrepreneur: the fulfillment of the contract resulting from the acceptance of the Client and / or Mentor GTC.
If you are registered on behalf of a business entity: legitimate interest in fulfilling of the contract resulting from the acceptance of the Client and / or Mentor GTC.
How long do we retain your Personal data?
Until the expiry of the civil law statutory limitation period (5 years), which is calculated from the deletion of the created client account.
Data processed during billing and payment
What Personal data do we process?
If you are a client:
full name;
e-mail address;
registered office;
tax number;
payable amount;
credit balance;
if you are registered on behalf of a business entity: business entity’s full name, e-mail address, registered office and tax number.
If you are a mentor:
full name;
e-mail address;
registered office;
tax number;
the amount to be paid to you;
Personal data contained by the invoice issued by you;
your Stripe details and bank account information;
payment details (date and amount of payments to you).
Why do we process your Personal data?
Fulfilling the accounting obligations relating to the transactions and issuing and sending invoices to the recipient.
On what legal grounds do we process your Personal data?
The legal obligation to issue and retain accounting documents under Article 165 (1) of Act C of 2000 on Accounting.
How long do we retain your Personal data?
Until the end of the retention period pursuant to Article 169 of Act C of 2000 on Accounting (8 years).
Complaints and exercising data subject rights
What Personal data do we process?
Contact data (name, email address or phone number) and any Personal data that you or any other person having only access right provide to us in the exercise of your Data subject rights (e.g. to describe your complaint in detail).
Please provide us with Personal data only to the extent necessary to process your request or complaint. Please do not provide us with data that falls within special categories of Personal data (e.g. racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data or data concerning health, sexual orientation or gender identity). If you consider it absolutely necessary to share special data, please include in your request/complaint your explicit consent to the processing of such special data (or, where the special data does not relate to you, the explicit consent of the Data subject concerned) so that we can lawfully process such Personal data.
Why do we process your Personal data?
We process Personal data for the purposes of ensuring the Data subject's rights as described in Section 8 and for the purpose of fully investigating complaints.
On what legal grounds do we process your Personal data?
We process the Personal data on the basis of our legitimate interest in fulfilling our obligation to ensure that you are able to exercise your Data subject rights under the GDPR.
How long do we store your Personal data?
We will process your Personal data:
until the expiry of the civil law statutory limitation period (5 years), which starts as of the termination of the investigation of the complain; or
until you, as Data subject object to the Data processing, and our assessment finds no compelling cause that overrides your objection.
Enforcement of legal claims
What Personal data do we process?
All personal data indicated above, based on the case-by-case consideration of Data Controller, in justified cases.
Why do we process your Personal data?
To enforce the Data Controller's legal claims, to defend its legal position and, in this context, to substantiate its claims in the event of a dispute or official proceedings.
On what legal grounds do we process your Personal data?
The Data Controller's legitimate interest in pursuing legal claims, defending its legal position and its legitimate interest in being able to substantiate its claims in a possible dispute or administrative procedure.
How long do we retain your Personal data?
5 years from the end of the contract period or from the date of the reply to the complaint (civil limitation period).
If the court or official procedure actually takes place, until the final conclusion of the procedure (including any litigious, non-litigious, authority and enforcement procedures).
Marketing
What Personal data do we process?
Your contact email address.
If you specifically consented to personalized direct marketing data processing, we’ll also process your activity carried out on the Platform.
Why do we process your Personal data?
The purpose of the data processing is to send you direct marketing materials including newsletters, information and offers regarding our services. If you specifically consented thereto, the content of such materials will be partially based on your activity carried out on the Platform.
On what legal grounds do we process your Personal data?
Your explicit, voluntary and unambiguous consent, which you can provide with or without including marketing content personalization.
How long do we store your Personal data?
Until the withdrawal of your consent.
How do we store your Personal data?
Personal data is stored in a cloud infrastructure provided by a third-party service provider, Bubble Group, Inc. (registered seat: 1811 Silverside Road, Wilmington, New Castle County, Delaware 19801).
If any system components operated by our service providers are located outside the European Economic Area (EEA), the transfer of Personal data outside the EEA will be subject to appropriate additional safeguards required by applicable law and we will only use Data Processors that provide such safeguards.
Parties Involved in the Data Processing, Recipients:
Data Processors
Sendgrid (operated by Twilio Ireland Limited, registered seat: 70 Sir John Rogerson’s Quay, Dublin 2, D02 R296, Ireland): provides our mailing system;
Intercom (operated by R&D Unlimited Company, registered seat: 124 St Stephen's Green, Dublin 2, DC02 C628, Ireland): provides the customer support system integrated into the platform. performs frontline support for the users;
Google Ireland Limited (registered seat: Gordon House, Barrow Street, Dublin 4, D04 E5W5, Ireland): to track your journey on the Platform.
Meta Platforms Ireland Limited (registered seat: Merrion road, Dublin, D04 X2K5, Dublin, Ireland): to track your journey on the Platform.
TikTok Technology Limited (registered seat: 10 Earlsfort Terrace, Dublin, D02 T380, Ireland) to measure traffic on the Platform.
Stripe Payments Europe Limited (registered seat: 1 Grand Canal Street Lower. Grand Canal Dock. Dublin. D02 H210. Ireland): provides our payment system.
Mux, Inc. (registered seat: 50 Beale Street, Floor 9San Francisco, CA 94105): provides storage space for videos uploaded to the Platform.
Florian Körner (Dicebear) (registered seat: Karlsruher Str. 12, 23568 Lübeck, Germany) generates avatars for clients and mentors.
Billingo Technologies Zrt. (registered seat: 1133 Budapest, Árbóc utca 6.): provides our billing system.
Data Controllers
in the case of exercising legal claims or defending against legal claims, we might need to transfer your Personal data to our legal advisors. Our legal advisors are bound by professional confidentiality obligations derived from laws regulating the activity of attorneys at law;
if a court procedure is initiated in relation to the contractual arrangements our Partner and us, your Personal data might be disclosed to the court and other participants of such procedure;
upon the request of authorities or courts, we are obliged to provide the information requested, which may contain your Personal data. We cannot be held responsible for such data transfers and their consequences. You will be notified if such a transfer takes place, to the extent permitted by the applicable laws.
Other recipients
For clients and any other visitor of the Platform, the following Personal data about mentors will be made available: name, profile picture, cover photo, username, mentor category, list of services. If a job is established between the parties, the feedback given by the mentor will be shared with the respective client.
For mentors, the following Personal data about clients will be made available: name, profile picture, number of days since registration. If a job is established between the parties, the materials uploaded by the client as a project will become accessible to the mentor.
Profiling, automated decision-making
If you specifically consented to the receipt of personalized direct marketing content, we’ll use the logged data of your activity carried out on the Platform when creating such content, in order to make it more relevant to you. In this sense, the analysis of your personal preferences, otherwise called profiling, takes place.
The results of such analysis will not be used for any purposes other than the one described in the previous paragraph. We also inform you that in the course of our data processing, no decision-making takes place that has an impact on you, is automated and is without human oversight.
What are your rights with respect to the Data processing?
You, as Data subject have various rights with regards to the processing of your Personal data. These are set forth in the GDPR and you can exercise them at any time by contacting us via the contact details set out in Section 2.
We will handle your request regarding the exercise of your rights under the GDPR only if we can clearly identify you based on your request. We will accept your request only if it is made in writing or submitted via e-mail from the e-mail address provided by you or by your organization to us. If you contact us in a different way and do not voluntarily identify yourself, we will not be able to send the information requested by you as we’ll not know the e-mail address or postal address where such information should be sent to. This measure is aimed at the protection of your Personal data.
We kindly ask you to describe your request in a concise, clear manner in your own words. Once your request is received, we will examine it and take the necessary steps. We will respond to each request without any delay, but no later than 1 month as of the receipt of the request. The exercising of your rights if free of charge.
Right to access
Right to access means that you are entitled to request information about our processing of your Personal data. You may request us at any time to inform you whether we process your Personal data and if yes
what data we process about you,
what is the purpose of our Data processing,
to which recipients we disclose your Personal data,
how long we retain your Personal data,
what rights you have in relation to the Data processing, and
whether we transfer your Personal data to any country or entity outside the European Economic Area (the European Economic Area means the countries of the European Union plus Iceland, Liechtenstein and Norway) and if we do, what additional guarantees we put in place to ensure the safety of your Personal data.
Additionally, you can request us to provide you with a copy of your Personal data processed by us. These copies will always be provided to you in the form of a pdf file, an email or in another form depending on the circumstances. We can only deny providing such a copy to you if this would have a negative impact on the rights and freedoms or violate the intellectual property or business secrets of others.
Right to rectification
If you have a reason to believe that any of the Personal data we process about you is no longer correct you can request us at any time to correct or update the data in question and we kindly ask you to do so, so that our records always contain your up-to-date data. If feasible, we will also inform any Recipients of the change in your data so they can update their registries accordingly. Upon request, we will provide you a list of the Recipients to whom we communicated the change.
If you are registered as a contact person of an organization, we kindly ask you to let us know if you are no longer associated with the organization. If possible, please also provide us with the new contact data we can use.
Right to erasure (“right to be forgotten”)
As a Data subject, you have the right “to be forgotten”. This means that we will, without undue delay erase any or all of your Personal data, if at least one of the following criteria is met:
we no longer need the data for any of the purposes specified in Section 4 above;
we were processing your data on the basis of your explicit consent and you withdraw such consent;
we were processing your data based on our legitimate interest and you object to such processing, provided that based on our assessment, there are no legitimate grounds that override your objection;
despite our best efforts, for some reason the data is has been processed unlawfully;
we must erase the data in compliance with a mandatory provision in the laws either of the European Union or Hungary;
If feasible, we will also inform any Recipients of the erasure of your Personal data. Upon request, we will provide you a list of the Recipients to whom we communicated the fact of erasure.
Please note that we are not required to delete your data if the Data processing is necessary for the establishment, exercise or defence of our legal claims, or we are required by EU or Hungarian law to store it.
Right to restriction of Data processing
As a Data subject, you may request restriction of Data processing if at least one of the following criteria is met:
you contest the accuracy of the data – in this case, the restriction extends to the period while the Data Controller checks the accuracy of the data;
despite our best efforts the Data processing was unlawful, however, instead of erasing your data, you request that its processing be restricted;
we no longer need your Personal data for any of the purposes specified above, but the data is needed for the establishment, exercise or defence of our legal claims;
you objected to the processing; in this case, the restriction remains in effect until we have assessed whether there are any legitimate grounds that override your objection.
When Data processing is restricted, we are permitted to store the Personal data, but we are not allowed to use it in any other way. Please note that the restriction of Data processing does not apply, if the Data processing is necessary for the establishment, exercise or defence of our legal claims or for the protection of the rights of another person.
If you registered on behalf of a business organization, please consider that your Personal data is always processed as part of a business organisation profile registered on the Platform. Therefore, if you request the restriction of the processing of your Personal data, this might result in our inability to maintain contact with the organization on behalf of which your data was provided and we might not be able to fulfil our contractual obligations to your organisation.
We explicitly exclude any and all liability for the event when communication with your business organization or performing our obligations becomes impossible because you requested the restriction of the processing of your Personal data.
Right to object
If the legal basis for the processing of your Personal data is our legitimate interest or that of a third party, you may object to the processing at any time. Upon objection, we will erase your Personal data, except if
our Data processing is justified by legitimate and compelling causes that override your objection, or
the Data processing is required for the establishment, enforcement or defence of our legal claims.
If you registered on behalf of a business organization, please consider that your Personal data is always processed as part of a business organisation profile registered on the Platform. Therefore, if you object to the processing of your Personal data, this might result in our inability to maintain contact with the organization on behalf of which your data was provided and we might not be able to fulfil our contractual obligations to your organisation.
We explicitly exclude any and all liability for the event when communication with your business organization or performing our obligations becomes impossible because you objected to the processing of your Personal data.
Right to data portability
If the legal ground for data processing is a contract concluded between you and us, or your explicit consent, you may request that we provide you with your Personal data in a commonly used, machine-readable format (e.g. a pdf file or email) or that your Personal data be transferred directly to another data controller of your choice.
Right to lodge a complaint, right to an effective judicial remedy
We hope that you will never have a reason to lodge any complaint against the processing of your Personal data by us.
Nevertheless, we inform you of your rights to effective legal remedy as follows.
If you believe that your Personal data is processed unlawfully, you may file a complaint with the competent data protection supervisory authority. In Hungary, this is the National Authority for Data Protection and Freedom of Information (in Hungarian: “Nemzeti Adatvédelmi és Információszabadság Hatóság”, “NAIH”).
Website: http://naih.hu/
Address: H-1055 Budapest, Falk Miksa utca 9-11., Hungary
Postal address: 1363 Budapest, Pf.:9.
Telephone: +36-1-391-1400
Fax: +36-1-391-1410
Email: ugyfelszolgalat@naih.hu
If you live or work in a European Union Member State other than Hungary) you can also file a complaint with the competent authority of the country of your residence or workplace.
You may also bring proceedings before a court if
you believe your Personal data is processed unlawfully (you can go directly to court, there is no need for a preceding procedure by NAIH);
NAIH made a binding decision that you wish to contest;
NAIH fails to address your complaint or does respond to it within three months of receiving it (in the latter two cases, the proceedings must be brought against NAIH).
You can bring the proceedings at the regional court competent based on your domicile or habitual place of residence (depending on your choice). More detailed information on Hungarian courts is available here: https://birosag.hu/en
Last modified on 6 March 2025