PRIVACY POLICY

In effect: 12.03.2026.

INTRODUCTION Eredeti Megoldások Kft. (registered office: 1192 Budapest, Baross u 54/4, hereinafter: the Company), as a data controller, is committed to data protection and therefore undertakes to comply with the relevant legal provisions and the legal obligations defined by the European Union.

The Company reserves the right to amend this policy at any time.

Based on the above, the Company publishes the following Privacy Policy in accordance with Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information (hereinafter: „Info Act”) and 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 (hereinafter: „GDPR”). Fulfilling our obligation set out in Articles 12 and 13 of the GDPR, we hereby inform you about the processing of your personal data on the www.icfmentoring.com website/webshop. It is very important to us to comply with the currently valid data protection regulations and laws, so below we discuss and present in detail the data protection measures and data collection processes of www.icfmentoring.com (hereinafter: Website) and Eredeti Megoldások Kft.

Contact details: Full legal name: Eredeti Megoldások Kft. E-mail address: info@icfmentoring.com Postal address: 1192 Budapest, Baross u 54/4 Phone number: +36309220433 Tax number: 25533851-2-43 Company registration number: 01 09 280716

SCOPE OF PROCESSED DATA Personal data is information that clearly allows the precise identification of an individual. On the www.icfmentoring.com website, we process the following personal data, with the exact indication of the legal basis:

PERSONAL DATA Any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

COMMUNICATION DATA This includes any message you send us through the website, via email, social media message, or any other form of communication. We process and retain this data to fulfill orders and to provide a basis for decision-making in the event of potential legal claims. Our legal basis for processing this data is the user’s verifiable interest in our activities, which is manifested in the messages addressed to us.

CUSTOMER DATA This includes all data related to the purchase of products and services, such as the customer’s name, shipping and billing address, email address, phone number, and details of the purchased product. We process this data to successfully fulfill orders and to maintain legally compliant records of purchases. The legal basis for storing the data is the performance of the contract created by the order between the customer and Eredeti Megoldások Kft.

USER DATA This includes data generated during the use of the website, which allows the technical operation of the site, maintains the security of the site, stores backups of user activities, and ensures you always have access to the most relevant content. The legal basis for processing the data is the user’s clear interest in our activities, for which the storage of this data is necessary to ensure the technical operation of the site.

TECHNICAL DATA This includes data generated during the use of the site, such as IP address, login information, browser data, duration of visits to specific pages, page views and navigation paths, the number and time of site visits, time zones, and device information used to view the site. The source of the data is our analytical software. We process this data to analyze user habits on the site, maintain the secure operation of our site, and understand the effectiveness of our specific marketing decisions. The legal basis for processing the data is the user’s clear interest in our activities, which allows us to process this data in accordance with security expectations and use it to grow our business for more effective operation.

MARKETING DATA This includes the visitor’s preferences regarding the type of marketing content they wish to receive from us. We process this data to enable participation in prize draws and to send advertising related to our products/services in which the user has expressed interest. The legal basis for processing the data is the user’s clear interest in our activities, which allows us to process this data in accordance with security expectations and use it to grow our business for more effective operation.

FACEBOOK The collected data may occasionally be used for purposes such as providing targeted, relevant advertisements on the Facebook™ platform or on various dynamic advertising interfaces, and to measure the effectiveness of the advertisements. The legal basis for processing the data is the user’s clear interest in our activities, which allows us to process this data in accordance with security expectations and use it to grow our business for more effective operation. During our activities, we DO NOT collect sensitive data such as ethnicity, religious beliefs, sexual life and orientation, political opinions, trade union membership, health background, or genetic/biometric information.

CONSENT Any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

DATA CONTROLLER The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

DATA PROCESSING Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

DATA PROCESSOR A natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

PERSONAL DATA BREACH A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Personal data must be processed lawfully, fairly and in a transparent manner in relation to the data subject.

HOW DO WE COLLECT DATA? We may collect personal data in ways where the user directly provides it to us (for example, by placing an order or sending a message). Furthermore, certain data is collected automatically during the use of the site, for example, through „cookies” and similar technologies. These only become active after the user has given their consent. For more information, please see our Cookie Policy. We receive certain data from external partners, such as analytical providers like Google (non-EU partner), advertising networks like Facebook™ (non-EU partner), and payment providers like PayPal (non-EU partner) and Barion.

OUR PRACTICAL STEPS REGARDING DATA PROTECTION Protecting user data and complying with current regulations is extremely important to Eredeti Megoldások Kft. Therefore, we treat data protection as a top priority on the icfmentoring.com website and have made significant efforts to securely collect the information gathered by the site. To protect the data provided on forms and generated on the site, we use SSL certification across the entire website (Let’s Encrypt Authority X3 certification). To protect the site against attacks, we use security software (iThemes Security Pro) and protect stored data against viral attacks. In this privacy policy, we provide users with forms to request information about the processing of their personal data, or to modify or delete their personal data. Occasionally, it is necessary for our business activities to provide data to our service partners (e.g., hosting provider, courier company, logistics company, newsletter software). In such cases, we always choose partners that comply with the requirements of the GDPR.

MARKETING COMMUNICATION Conducting marketing communication is essential in the Company’s activities. The legal basis for related data processing is showing interest in our services or the explicit consent of the users. Based on the Privacy and Electronic Communications Regulations (PECR) of the European Union, we send marketing messages to our users if they have purchased from us or explicitly consented to receiving marketing messages. We always make it possible to suspend consent and unsubscribe from messages in a clearly visible manner. A link to unsubscribe is available at the bottom of every single email, or removal from the database can be requested at the info@icfmentoring.com email address. Even in the event of unsubscribing from marketing communication, we may still send messages, but only regarding the fulfillment of orders.

NOTE REGARDING PERSONAL DATA Occasionally, it is necessary to share certain personal data with some of our partners to maintain normal business operations:

• IT service providers, and service providers performing troubleshooting and maintenance on computer systems
• Expert partners, such as lawyers, accountants, bankers, insurers
• Government agencies that request reports on our activities
• Payment providers who securely handle credit card data
• Courier services that fulfill incoming orders to the specified delivery address International data transfers. To maintain business operations, we sometimes need to share user data with service partners outside the European Economic Area (EEA). Countries outside the EEA often do not provide the same level of data protection, so European laws prohibit the export of data in the absence of the fulfillment of appropriate conditions. Whenever personal data is transferred outside the EEA, in addition to the steps discussed in point 4, we take the following measures to ensure the secure processing of the data:
• We only transfer data to countries that the European Commission considers adequate in terms of data security.
• We only use US-based services that are part of the EU-US Privacy Shield data security initiative. If the above conditions are not met, we ask for the explicit consent of the users to execute the data transfer. Consent can be withdrawn at any time. Links to external sites. This site occasionally contains links to external sites, or code snippets embedded in the site that ensure the operation of external services. Clicking these links or using the embedded solutions may allow external partners to collect data about users. Although we do everything possible to properly vet our partners, we have no control over their privacy policies, and we are not responsible for their data management principles.

DURATION OF DATA PROCESSING We only store user data as long as our legal/accounting/data reporting obligations make it mandatory, or as long as it is necessary for the operation of the service. When deciding on the duration of storage, we consider the amount, nature, and sensitivity of the data, and the potential impact of its leakage in the event of a personal data breach. For tax reasons, we are required to retain customers’ billing and purchase data for at least 8 years to fulfill our legal obligations. Under certain circumstances, we may use the data in anonymized form for statistical purposes, in which case we store the data indefinitely without notification.

RIGHTS OF THE VISITOR As a citizen of the European Union, the law called the General Data Protection Regulation (GDPR) guarantees the following rights to the users of the site:

a, Access to personal data Users of the site have the right to request a copy of the personal data stored by icfmentoring.com The request will generally be fulfilled free of charge within 14 days of the inquiry. In case of repeated, abusive, or unjustified data requests, Eredeti Megoldások Kft. may charge a moderate fee for providing the data, and additional time may be required to provide the data. Furthermore, Eredeti Megoldások Kft. requests proof of identity before releasing the data to prevent abusive use. To request personal data, please send an email to info@icfmentoring.com.

b, Modification of personal data If personal data has changed or was entered incorrectly, users have the right to request the modification of the data. To modify personal data, please contact us at the info@icfmentoring.com e-mail address.

c, Request for deletion of personal data Users have the right to request the deletion of all their personal data. We will fulfill the request free of charge within 14 days following the request. After the deletion of personal data, the user account will no longer be accessible, and thus any purchased materials will also become inaccessible, as the personal data associated with the user account is absolutely necessary to access the service. Eredeti Megoldások Kft. requests proof of identity before deleting personal data to prevent abusive use. To delete personal data, please use the contact form above.

d, Request for restriction of personal data processing Users have the right to request the restriction of providing their data to third parties (service partners). During the submission of the request, the specific service partners to be restricted can also be named. It is important to note that cooperation with certain service providers is essential for the operation of the site (e.g., Barion, as a payment provider), so if they are restricted, the site’s services will become inaccessible to the user. Eredeti Megoldások Kft. requests proof of identity before restricting the transfer of personal data to prevent abusive use. To restrict the transfer of personal data, please send a message to the info@icfmentoring.com e-mail address.

ANONYMIZED DATA AND „COOKIES” On the icfmentoring.com website, in email messages and advertisements, we use „cookies” and similar technologies, such as tracking codes, remarketing tags, and pixels, which become active after the user’s consent. These technologies help us better understand user behavior and interests, thereby assisting us in providing higher quality and more effective operations. Our goal is to make the use of icfmentoring.com as user-friendly and personalized as possible. If the user wishes to prohibit the recording of non-personal data by these technologies, it can be done in the following ways:

• disabling their loading using the cookie warnings appearing on the website
• disabling „cookies” in the browser. In Hungary, the official body dealing with data protection is the National Authority for Data Protection and Freedom of Information (NAIH). Users can find out more about their data protection rights on the NAIH website.

LEGAL REMEDIES If you believe that the Data Controller has violated any statutory provision relating to data processing, or has failed to fulfill any of your requests, you may initiate the official investigation procedure of the National Authority for Data Protection and Freedom of Information in order to terminate the presumed unlawful data processing. Mailing address: 1530 Budapest, Pf.: 5. Address: 1125 Budapest, Szilágyi Erzsébet fasor 22/C. Phone: 0613911400 Fax: 0613911410 E-mail: ugyfelszolgalat@naih.hu Website: https://www.naih.hu

MODIFICATION OF THE PRIVACY POLICY The Data Controller reserves the right to modify this privacy policy. By using the website following the entry into force of the modification, you accept the modified privacy policy.