GDPR Statement

1. Data controller

Vivolytix is currently operated by an individual (a natural person), not an incorporated company. That individual is the data controller responsible for your personal data under the GDPR and Hungarian Act CXII of 2011:

• Name: Osváth Botond Márk
• Address: 2030 Érd, Keselyű utca 32, Hungary
• Email: info@vivolytix.com

A separate, fuller Privacy Policy describes exactly what we collect and why; this statement focuses on your GDPR rights and how we honour them.

2. Lawful basis for processing

We process personal data only where Article 6(1) GDPR allows it:

• Consent - Art. 6(1)(a) - for sending email updates to people who subscribed.
• Legitimate interests - Art. 6(1)(f) - for answering enquiries and keeping the site secure.
• Pre-contractual steps - Art. 6(1)(b) - where you contact us about joining the pilot programme.

We do not carry out automated decision-making or profiling that produces legal or similarly significant effects (Art. 22 GDPR).

3. Your rights under the GDPR

As a data subject you have the right to:

• Access (Art. 15) - a copy of the data we hold about you;
• Rectification (Art. 16) - correction of inaccurate or incomplete data;
• Erasure (Art. 17) - deletion of your data where the conditions are met;
• Restriction (Art. 18) - to limit how we use your data;
• Data portability (Art. 20) - to receive your data in a structured, machine-readable format;
• Object (Art. 21) - to processing based on legitimate interests, including any direct marketing;
• Withdraw consent (Art. 7(3)) - at any time, without affecting processing already done.

4. Exercising your rights

Email info@vivolytix.com and tell us which right you want to exercise. We may ask a question or two to confirm your identity. We act without undue delay and within one month (Art. 12(3)), and we do not charge for this unless a request is manifestly unfounded or excessive. To stop receiving emails, you can also use the unsubscribe link in any message.

5. International data transfers

We keep personal data within the EEA wherever we can. Our email processor (Mailjet, a Sinch company) operates in the EU. Should any transfer outside the EEA be necessary, we rely on an European Commission adequacy decision or appropriate safeguards such as Standard Contractual Clauses (Art. 46 GDPR).

6. Data retention

• Subscriber email addresses: until you unsubscribe or request deletion.
• Contact enquiries: up to 24 months after our last contact, unless needed for a legal claim.
• Security/server logs: typically up to 90 days.

We apply the storage-limitation principle (Art. 5(1)(e)): we keep data only as long as necessary for the purpose it was collected.

7. Complaints & supervisory authority

If you believe we have handled your data unlawfully, please contact us first so we can put it right. You also have the right (Art. 77 GDPR) to lodge a complaint with the Hungarian supervisory authority:

• Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH)
• 1055 Budapest, Falk Miksa utca 9-11, Hungary (post: 1363 Budapest, Pf. 9)
• Phone: +36 1 391 1400 · Web: naih.hu · Email: ugyfelszolgalat@naih.hu

8. Contact

For any GDPR or data-protection request, email info@vivolytix.com.