PRIVACY POLICY

Effective Date: 2nd December 2025

This Privacy Policy (the “Policy”) explains how Krisztina Gyüre E.V. ("we," "us," or "the service provider") collects, uses, and protects your personal data when you use our website (https://krisztinagyure.com/) and engage in our Rapid Transformational Therapy (RTT) services, in compliance with the General Data Protection Regulation (GDPR).

1. Data Controller Details

The controller responsible for processing your personal data is: Krisztina Gyüre

Contact: hello@krisztinagyure.com

2. Data We Collect and Why

1. Data Category: Identity/Contact Data (Name, Email Address)

   Purpose of Processing: To respond to your contact form inquiries and book connection calls.

   Legal Basis (GDPR): Necessary for the performance of a contract (Art. 6(1)(b) GDPR) or Pre-contractual steps.

2. Data Category: Technical Data (IP Address, Browser Type)

   Purpose of Processing: To ensure website security, functionality, and performance optimization (via Hostinger analytics).

   Legal Basis (GDPR): Legitimate interests (Art. 6(1)(f) GDPR) in ensuring a functional website.

3. Data Category: Session/Health Data (Information shared during RTT/therapy sessions)

   Purpose of Processing: To provide the therapeutic service (RTT) and create bespoke audio recordings.

   Legal Basis (GDPR): Explicit consent (Art. 9(2)(a) GDPR) for processing sensitive data, as necessary for health services.

4. Data Category: Marketing Data (Consent for Newsletter)

   Purpose of Processing: To send marketing communications, if you explicitly opt-in.

   Legal Basis (GDPR): Consent (Art. 6(1)(a) GDPR).

3. How We Collect Data

We collect personal data through:

1. Direct Interactions: When you fill out the contact form or communicate with us via email.

2. Automated Technologies: Via the website hosting platform (Hostinger) which collects basic technical data (e.g., cookies for basic functionality, traffic data).

4. Confidentiality of Therapeutic Data (Sensitive Data)

Information shared during RTT sessions (Art. 9 GDPR) is treated with the highest level of confidentiality and professional secrecy. This data is never shared with third parties, except as required by law or professional ethical duties.

5. Your Data Protection Rights (GDPR)

Under GDPR, you have the right to:

1. Right of Access: Request copies of your personal data.

2. Right to Rectification: Request that we correct any information you believe is inaccurate or incomplete.

3. Right to Erasure ('Right to be Forgotten'): Request that we erase your personal data, under certain conditions.

4. Right to Restrict Processing: Request that we restrict the processing of your personal data, under certain conditions.

5. Right to Object to Processing: Object to our processing of your personal data, under certain conditions.

6. Right to Data Portability: Request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

7. Right to Withdraw Consent: Where we rely on consent to process your data, you have the right to withdraw that consent at any time.

6. Data Retention Period

Your personal data is retained only for as long as necessary to fulfil the purposes for which it was collected, including satisfying any legal, accounting, or reporting requirements.

• Therapeutic (Sensitive) Data: Health data collected during RTT sessions is retained for 10 years from the date of the last session, in accordance with our professional insurance obligations.

• General Communication Data: Data derived from general inquiries (name, email, phone number) that do not result in a client relationship is retained for a maximum of 3 years from the date of contact.

• Marketing Data: Marketing data based on consent is processed until you withdraw your consent

7. Data Security

We implement appropriate technical and organizational measures to ensure the security of your personal data, including secure transmission (SSL/HTTPS) and limited access to therapeutic records.

8. Third-Party Processors

We use third-party services that may process your data:

• Hostinger: For website hosting and basic analytics.

• Email Service Provider: For managing email communications.

• Booking Software (Calendly): If used, for scheduling appointments.

9. Changes to This Policy

We may update this policy periodically. We will notify you of any changes by posting the new Privacy Policy on this page.

10. Contact Information

If you have any questions about this Privacy Policy, please contact us at: hello@krisztinagyure.com

11. Right to Lodge a Complaint (Remedies)

If you feel that the processing of your personal data does not comply with the law, you have the right to lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH):

• Name: Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH)

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

• Website: https://naih.hu

Complementary Information for Therapy Clients

Please note that if you engage in Rapid Transformational Therapy® (RTT) or other therapeutic services, the processing of your data is governed not only by this general website policy but also by the specific “Data Protection Information for Therapy Clients.”

This separate document details the collection, storage, and retention period (which is 10 years due to professional insurance obligations) of special categories of personal data (health status, medications, session notes). The detailed information and the required Consent Form will be provided to you before the commencement of your sessions.