I. About this Policy

This Policy sets out the essential details relating to your personal data relationship with Turbine Ltd. The Policy applies to all personal data you provide to us and also to all personal data which we collect on you. Turbine Ltd. (registered seat: 1136 Budapest, Pannónia utca 32., company registration number: 01-09-177316, herinafter referred to as Turbine) acts as a data controller. This means Turbine decides how your personal data is processed and for what purposes.

The aim of this Policy is to:

  1. Ensure that you understand what personal data we collect concerning you, the reasons we collect and use it, and who we share it with;
  2. Explain the way we use the personal data that you share with us
  3. Explain your rights and choices in relation to the personal data we collect and process about you and how we will protect your privacy.

We hope this helps you understand our privacy commitments to you, if you do not agree with the content of this Policy, then please remember it is your choice whether you want us to collect or process your personal data.

II. Your personal data – What is it?

Personal data relates to a living individual who can clearly be identified from that data, in particular your name, address, phone number, e-mail address. Identification can be made by the information alone or in conjunction with any other information otherwise in the data controller’s possession or likely to come into such possession.

III. Your rights and your preferences

You may be aware that a new European Union law, called the General Data Protection Regulation or "GDPR" gives certain rights to individuals in relation to their personal data. Accordingly, the rights afforded to individuals are:

  • • Right of Access - the right to be informed of and request access to the personal data we process about you;
  • • Right to Rectification - the right to request that we amend or update your personal data where it is inaccurate or incomplete;
  • • Right to Erasure - the right to request that we delete your personal data;
  • • Right to Restrict - the right to request that we temporarily or permanently stop processing all or some of your personal data;
  • • Right to Object -
    • ○ the right, at any time, to object to us processing your personal data on grounds relating to your particular situation;
    • ○ the right to object to your personal data being processed for direct marketing purposes;
  • • Right to Data Portability - the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and
  • • Right not to be subject to Automated Decision-making - the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

If we send you electronic marketing messages (newsletters) based on your consent, you may, at any time, respectively withdraw such consent or declare your objection at no cost. The electronic marketing messages you receive from Turbine (those sent via email) also will include an opt-out mechanism within the message itself (an unsubscribe link in the emails we send to you).

If you have any questions about your privacy, your rights, or how to exercise them, please contact us. If you are unhappy with the way we are using your personal data you can also contact and are free to lodge a complaint with the Hungarian Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság, H-1125, Hungary, Budapest, Szilágyi Erzsébet fasor 22/C.; telephone: +36-1 391-1400; telefax: +36-1 391-1410; e-mail:

IV. How and why do we collect your personal data?

We collect your personal data in the following ways and for the following purposes:

  1. When you request we contact you - when you fill the form on our website in order to contact our team, we collect your name, organization, e-mail, and the reason you want to contact us. In this case we collect and use your personal data in order to communicate with you.
  2. When you sign up for our newsletter - we collect your e-mail address. In this case we collect and use your personal data in order to send you our newsletters.
  3. When you apply for a job - we collect your name, e-mail adrees, information regarding your motivation, your recent work experience, your qualification. In this case we collect and use your personal data to find the best applicant for our open positions, and – if we choose you for the position- to hire you.

The legal basis of data processing activities described in 4.1. and 4.2. section of this policy lies in Subsection (a) Paragraph (1) of Article 5 of Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information, i.e. based on your consent, and also Article 6 (1) (a) and Article 9 (2) (a) of the General Data Protection Regulation (Regulation No. 2016/679 of the European Parliament and of the Council) (hereinafter referred to as: "GDPR"), i.e. such processing activities will be based on your consent and in the case of data processing activities indicated in 4.3. section of this policy, the legal basis is Article 6 (1) (b) of the GDPR, i.e. such processing activities are necessary for the performance of contract or in order to take steps at the request of data subject to entering into a contract.

V. How long do we keep your personal data?

We process your personal data for the time required consistent with the purposes set out in this Privacy Policy or for the period of limitation prescribed in the relevant laws.

We store internet search data collected concerning you for four days.

In case of accounting documents, the retention period is 8 years from the closing of the financial year, in accordance with Section 169 of Act C of 2000 on Accounting.

If a court or disciplinary procedure is initiated, then the personal data will be retained until the termination of the proceedings, including the duration of any possible remedy, which data thereafter, in the case of civil claims, will be deleted after the civil law statute of limitation expires.

In the case of consent-based data processing, personal data will be processed until the consent is withdrawn.

In the case of data processing related to job application, your personal data will be destroyed upon your request if we do not hire you.

VI. How do we protect your personal data?

Turbine complies with its obligations under the applicable data protection laws by

  • • keeping personal data up to date;
  • • storing and destroying it securely;
  • • not collecting or retaining excessive amounts of data;
  • • protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.

We take appropriate technical and organizational measures to ensure the protection of your personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, in particular but not limited to where the processing involves the transmission of data over a network, and against all other unlawful forms of processing.

Turbine in line with this, among other things, applies different levels of access rights to the data, which ensures that only the appropriate authorized person has accesses to the data, whose knowledge of the data is necessary to fulfill his or her obligation arising out of or in connection with the performance of his or her job.

VII. Sharing your personal data

Turbine, in the course of its operation, may utilize the services of various data processors and external service providers to handle and process your personal data for specific purposes, on behalf of and in accordance with the instructions of Turbine. In addition, under the applicable laws Turbine is required to share your personal data with governmental bodies, authorities and other enforcement bodies. The data processors shall process the personal data at the most as long as the term of the data processing contract concluded with them is valid and in force, or until they are required to keep your data under the applicable data retention laws.

We may disclose your personal data to the following categories of third parties (recipients) for the purposes described below:

  • • third parties, such as law firms, courts, other bodies or service providers in order to enforce or apply any contract with you;
  • • government authorities or enforcement bodies such as the police and regulatory authorities, upon their request and only as required by the applicable law or to protect our rights or the safety of our customers, staff and assets.

VIII. Cookies

When you use our website, cookies are stored by your browser on your device. Read more about the cookies used by clicking here. Please note that if you disable cookies our website may not function properly on your browser.

IX. Changes to our privacy notice

If we change this Privacy Policy, we will publish the updated version of it on our website, . When we make material changes to this Policy, we will provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice or by sending you an email. We may notify you in advance.

X. Third party websites

The website provides links to other websites for your convenience and information. Please be aware that these sites may be owned and run by other companies and organizations and have different security and privacy policies. Turbine has no control over and takes no responsibility for any information, material, products or services contained on or accessible through those websites.

Turbine is not responsible for third parties’ use of your data. In such cases these third parties shall be considered data controllers, please consult their privacy policies for further information.

Thank you for reading our Privacy Policy. If you have any questions about this Policy, please contact us by using the ‘Contact Us’ form on the website or by writing to us at the following address: 1136 Budapest, Pannónia utca 32.

This Privacy Policy is effective from 25 May 2018.