Privacy Policy – Handling of Personal Data of Contractual Contact Persons and Individual Entrepreneur Partners

This Privacy Policy aims to provide clear and comprehensive information regarding the handling of your personal data by IK Batteries Holding KFT.

This Policy has been prepared in accordance with applicable laws, including but not limited to:

• Regulation (EU) 2016/679 of the European Parliament and of the Council (April 27, 2016) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation, “GDPR”);

• Act CXII of 2011 on the Right of Informational Self-Determination and Freedom of Information;

• Act V of 2013 on the Civil Code;

• Act C of 2000 on Accounting.

This Policy specifically applies to contract-related communications. For other data processing activities, please refer to our notices available at https://www.danrolfleet.hu.

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1. Key Definitions

The following definitions clarify the terms used in this Policy:

• Policy: this Privacy Policy.

• Personal Data: any information relating to an identified or identifiable natural person, such as name or contact details, by which the individual can be directly or indirectly identified.

• Data Subject: you, as a natural person (whether representing a company or acting as an individual entrepreneur) whose personal data is processed by the Data Controller.

• Data Controller / “IK Batteries Holding KFT.”: the entity that determines the purposes and means of processing personal data. The Data Controller is IK Batteries Holding KFT. (Registered office: 1036 Budapest, Perc u. 6.; Company Registration No.: 01-09-445390).

• Data Processing: any operation performed on personal data by the Data Controller, including collection, storage, transmission, modification, or deletion.

• Data Processor: an organization that processes personal data on behalf of the Data Controller under its instructions (see section 4.1).

• Recipient: any third party to whom personal data is disclosed or who otherwise has access to personal data (see section 4).

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2. Data Processing Principles

IK Batteries Holding KFT., as Data Controller, handles personal data in accordance with applicable laws, including the following principles:

• Personal data is processed lawfully, fairly, and transparently. Data Subjects are fully informed about the purposes and methods of processing and their rights.

• Data processing always has a legitimate, lawful purpose. Personal data is never processed for undefined or inappropriate purposes.

• Only data necessary to achieve the purposes described in section 3 is collected and stored.

• Data is not retained indefinitely; retention periods are clearly communicated. Data is permanently deleted once retention expires.

• All reasonable measures are taken to ensure that personal data is accurate, up to date, and protected against unauthorized access or disclosure.

• The rights of Data Subjects are respected, including prompt response to any requests, questions, or complaints regarding personal data.

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3. How We Handle Personal Data

This section outlines the types of data processing related to contractual communications, contract performance, invoicing, and potential legal claims.

3.1 Contact Persons (Non-Individual Entrepreneurs)

3.2 Individual Entrepreneur Partners

3.3 Data Required for Accounting

3.4 Data for Legal Claims

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4. Disclosure of Personal Data

4.1 Data Processors

External service providers may have access to personal data to perform tasks, under the instructions of IK Batteries Holding KFT., including:

• Tárhely.eu (Budapest): database hosting, maintenance, and operational tasks.
  
  

4.2 Recipients

Certain recipients may act as independent data controllers for their own purposes, including:

• Legal representatives (law firms providing legal or data protection services);

• Courts or authorities in case of legal proceedings;

• Auditors for financial audits;

• Postal service providers for contract-related mail delivery.

Personal data is never transferred outside the EU.

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5. Data Subject Rights

Data Subjects have the following GDPR rights:

• Access: Right to request information about data processing and obtain copies.

• Rectification: Right to correct inaccurate personal data.

• Erasure (“Right to be forgotten”): Right to request deletion of personal data under certain conditions.

• Restriction: Right to limit processing under certain conditions.

• Objection: Right to object to processing based on legitimate interests.

• Data portability: Right to receive personal data in a machine-readable format or transfer it to another controller.

• Complaint / Judicial Remedy: Right to lodge a complaint with the supervisory authority (NAIH in Hungary) or seek court remedy.

Contact for exercising rights:

• Email: hello@ikbatteries.com

• Address: 2741 Újlengyel, Kossuth Lajos u. 134.

• Data Protection Officer: [To be filled]

NAIH Contact:

• Website: http://naih.hu

• Address: 1055 Budapest, Falk Miksa utca 9-11

• Mail: 1374 Budapest, Pf.:603

• Phone: +36-1-391-1400

• Fax: +36-1-391-1410

• Email: ugyfelszolgalat@naih.hu

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6. Profiling

No profiling or automated decision-making is performed. Personal data is not analyzed to make decisions about individuals.

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Effective Date: September 30, 2025