Version: 1.0 

Effective from: 1 August 2026

Data controllers: Ádám Ercsényi, sole trader, and C29 E-Bike Rent Kft.

1. Introduction and Scope of the Privacy Notice

The purpose of this Privacy Notice is to provide natural persons with transparent, clear and comprehensive information regarding the processing of personal data in connection with the use of the courierebike.hu website and the services presented on the website.

This Policy covers data processing relating to visiting and the technical operation of the website, making contact, enquiries regarding bicycle and scooter hire and servicing, the use of messaging services, any job applications, as well as cookies, statistical and advertising measurement services.

The website does not feature user registration, newsletter subscriptions or online payments. Should any of these functions be introduced in the future, the data controllers will amend this Privacy Notice accordingly before the function is made available.

The data controllers process personal data solely for specified, explicit and legitimate purposes, to the extent and for the duration necessary to achieve the relevant purpose. The following sections set out the data controller, purpose, legal basis, scope of personal data concerned, retention period and recipients for each data processing operation.

2. Details and responsibilities of data controllers

The following individuals and organisations act as data controllers in relation to the operation of the website and the services presented on it. The data controller for a given data processing operation is determined by its purpose and the actual circumstances.

Ádám Ercsényi, sole trader

Registered office: 1094 Budapest, Viola utca 23–25/A/201

Tax number: 57619886-1-43

Email: courierebikerent@gmail.com

Website: courierebike.hu

Service provider

C29 E-Bike Rent Kft.

Registered office: 1094 Budapest, Viola utca 23–25/A/201

Company registration number: 01-09-448845

Tax number: 32906730-2-43

Email: courierebikerent@gmail.com

2.1. Division of responsibilities
Ádám Ercsényi, a sole trader, is primarily responsible for data processing relating to the operation, technical functioning and security of the website, server logging, the management of cookies and statistical tracking, and technical enquiries concerning the website’s operation.
C29 E-Bike Rent Kft. is primarily the data controller for personal data relating to the bicycle and scooter hire, servicing and other services presented on the website, the provision of quotations, pre-contractual consultations, customer service communications, and advertisements promoting the services.
If an enquiry falls within the remit of the other data controller, the enquiry and the personal data necessary for handling the matter may be forwarded to the relevant data controller. The data subject may send their data protection request to either data controller via the joint contact email address.

3. Applicable legislation and data processing principles
Data controllers shall, in particular, apply the provisions of the following legislation, as in force at any given time:
● Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR);
● Act CXII of 2011 on the right to informational self-determination and freedom of information (Infotv.);
● Act CVIII of 2001 on certain aspects of electronic commerce services;
● Act C of 2003 on electronic communications;
● Act XLVIII of 2008 on commercial advertising;
● Act C of 2000 on accounting;
● Act CLV of 1997 on consumer protection;
● Act V of 2013 on the Civil Code.
Data controllers shall ensure that the processing of personal data is lawful, fair and transparent; that it is carried out solely for specified purposes; that it covers only the necessary data; the data is accurate and up to date; it is retained only for as long as is necessary; and appropriate technical and organisational measures ensure its confidentiality, integrity and availability. Data controllers are responsible for complying with these principles and for being able to demonstrate such compliance.

4. Data processing relating to the technical operation of the website
4.1. Server logs and IT security
Data controller: Ádám Ercsényi, sole trader.
Purpose of data processing: To ensure the secure and stable operation of the website, to detect and rectify errors, to detect misuse and unauthorised access attempts, and to protect the IT system.
Scope of personal data processed: IP address; date and time of the request; address of the page or file accessed; HTTP response code; referring page; technical details of the browser, operating system and device; and technical information relating to server operation and any errors.
Legal basis for data processing: Article 6(1)(f) of the GDPR: the data controller’s legitimate interest in the secure, reliable and fraud-proof operation of the website.
Duration of data processing: Log data is processed in accordance with the hosting provider’s technical settings, solely for the period necessary for security, fault-finding and the prevention of misuse. In the event of a security incident or a legal claim, the relevant data may be retained until the matter is resolved or until the period for enforcing the legal claim has expired.
Recipients of the data: Persons authorised to operate the website and BlazeArts Kft. (FORPSI), the hosting provider.
Nature of data processing: The processing of technical data is automatic when the website is accessed; without this, the secure operation of the website cannot be guaranteed.

5. Contact and service enquiries
The data controllers request that data subjects provide only the data necessary for handling their enquiry when contacting them. Please do not send copies of identity documents, health data or other special categories of personal data without a prior, explicit request.

5.1. Contact form
Data controller: Depending on the subject of the enquiry, either C29 E-Bike Rent Kft. or Ádám Ercsényi, a sole trader.
Purpose of data processing: To receive and respond to enquiries, provide information and quotations, make the necessary prior arrangements for the use of the service, and investigate any technical issues.
Scope of personal data processed: Name; email address; telephone number, if the form contains such a field; the subject of the enquiry; the content of the message; any additional data voluntarily provided by the data subject.
Legal basis for data processing: In the case of an enquiry regarding a service, Article 6(1)(b) of the GDPR; in the case of a general or technical enquiry, Article 6(1)(f) of the GDPR, based on the legitimate interest in responding to enquiries and ensuring the proper operation of the website.
Duration of data processing: If no contract is concluded, for a maximum of 12 months following the closure of the case. In the event of a contract being concluded, a complaint or a legal claim, the data necessary for the case may be processed until the end of the relevant retention, accounting or limitation periods.
Recipients of the data: The data controller’s staff and contractors authorised to handle the matter, the hosting provider and the email service provider.
Nature of data provision: Voluntary; in the absence of the contact details necessary to respond, the enquiry cannot be answered.

5.2. Contact via email
Data controller: Depending on the subject of the enquiry, either C29 E-Bike Rent Kft. or Ádám Ercsényi, a sole trader.
Purpose of data processing: To receive and respond to enquiries, provide quotations, arrange appointments, prepare contracts, and handle customer service or technical matters.
Scope of personal data processed: Name; email address; telephone number, if provided; the subject and content of the email; the date of the enquiry; attachments and the data contained therein.
Legal basis for data processing: Article 6(1)(b) of the GDPR in the case of enquiries regarding contractual services; Article 6(1)(f) of the GDPR in the case of other customer service or technical enquiries.
Duration of data processing: If no contract is concluded, for a maximum of 12 months following the closure of the case. Correspondence relating to a contract, a service provided, a complaint, a claim or a legal dispute may be retained until the relevant legal claim can no longer be enforced.
Recipients of the data: The data controller’s staff and contractors authorised to handle the matter, as well as Google Ireland Limited, which provides the Gmail service to consumers, in accordance with its own terms and conditions.

5.3. Contact by telephone
Data controller: Depending on the subject of the enquiry, either C29 E-Bike Rent Kft. or Ádám Ercsényi, a sole trader.
Purpose of data processing: Providing information, arranging appointments, issuing quotations, preparing contracts, handling customer service matters and making return calls.
Scope of personal data processed: Telephone number; the date and duration of the call; name, if provided; data voluntarily disclosed during the conversation; notes taken for administrative purposes, if any. Telephone conversations are not recorded.
Legal basis for data processing: Article 6(1)(b) of the GDPR in the case of enquiries regarding the conclusion of a contract or the provision of a service; Article 6(1)(f) of the GDPR in the case of other customer service enquiries.

Duration of data processing: Data contained in the device’s call log shall be retained for a maximum of 90 days, unless required for the handling of an ongoing matter. The retention period for any administrative records shall be determined by the nature of the matter.
Recipients of the data: The data controller’s staff and contractors authorised to handle administrative matters.
5.4. Contact via WhatsApp
Data controller: C29 E-Bike Rent Kft. With regard to its own data processing in connection with the operation of the WhatsApp service, WhatsApp Ireland Limited acts as the data controller.
Purpose of data processing: Responding to enquiries regarding hire and servicing, providing quotations, arranging appointments, communication prior to the conclusion of a contract and in relation to existing contracts, and handling customer service matters.
Scope of personal data processed: Telephone number; displayed name; profile picture, if visible; the content and date/time of messages; voice messages; images, videos and documents sent; additional data provided voluntarily.
Legal basis for data processing: Article 6(1)(b) of the GDPR in the case of communication prior to the conclusion of a contract or relating to the performance of a contract; Article 6(1)(f) of the GDPR in the case of general customer service, complaint handling or the handling of legal claims.

Duration of data processing: If no contract is concluded, for a maximum of 12 months following the closure of the case. Messages required for contractual purposes, settlement of accounts, complaints or legal claims may be retained until the end of the period during which the legal claim may be enforced. The duration of WhatsApp’s own data processing is determined by the service provider’s rules.
Recipients of the data: Persons authorised to handle administrative matters at C29 E-Bike Rent Kft., WhatsApp Ireland Limited, and companies involved in the operation of the service.
5.5. Enquiries received via Facebook Messenger
Data controller: C29 E-Bike Rent Kft. Meta Platforms Ireland Limited acts as the data controller in relation to its own data processing activities associated with the operation of the Facebook, Instagram and Messenger platforms.
Purpose of data processing: To respond to enquiries received via Facebook or Instagram adverts or directly via Messenger; to provide information; to make offers; to arrange appointments; to prepare contracts; and to handle customer service matters.
Scope of personal data processed: The name, username or profile ID appearing in the profile; profile picture, if visible; the content and date/time of messages; images and documents sent; source data for the advert or campaign, if displayed by the platform; and any additional data provided voluntarily.
Legal basis for data processing: Article 6(1)(b) of the GDPR in the case of an enquiry regarding the use of a service or the conclusion of a contract; Article 6(1)(f) of the GDPR in the case of other customer service communications.

Duration of data processing: If no contract is concluded, for a maximum of 12 months following the closure of the case. Messages relating to a contract, complaint, claim or legal dispute may be retained until the end of the relevant limitation period for legal claims. The duration of Meta’s own data processing is determined by the service provider’s rules.
Recipients of the data: Persons authorised to handle administrative matters at C29 E-Bike Rent Kft., Meta Platforms Ireland Limited, and companies involved in the operation of the platform.

5.6. Enquiries regarding hire and contract preparation
Data controller: C29 E-Bike Rent Kft.
Purpose of data processing: To provide information on bicycles and scooters available for hire, to discuss availability and terms and conditions, to make offers, to prepare contracts and to arrange personal administrative matters.
Scope of personal data processed: Name; telephone number; email address; messaging service identifiers; selected vehicle type; planned hire period; the content of the enquiry and related communications; additional data provided voluntarily.
Legal basis for data processing: Article 6(1)(b) of the GDPR, taking steps at the data subject’s request prior to entering into a contract.
Duration of data processing: If no rental contract is concluded, for a maximum of 12 months following the closure of the case. If a contract is concluded, the data will form part of a separate data processing operation relating to the rental relationship.
Recipients of the data: Persons authorised to handle administrative matters at C29 E-Bike Rent Kft. and the provider of the relevant communication channel.
Nature of data provision: Voluntary; however, in the absence of the data required to establish contact and provide a quotation, your enquiry cannot be processed. The data will not be automatically used for the purpose of sending newsletters or advertising.

5.7. Service enquiries and preparation for repairs
Data controller: C29 E-Bike Rent Kft.
Purpose of data processing: Preliminary assessment of the fault, provision of a quote, arranging an appointment, and preparation for and carrying out the repair.
Scope of personal data processed: Name; telephone number; email address; type of device; description of the fault; photographs and videos sent; communication relating to the repair and appointment scheduling; additional data provided voluntarily.
Legal basis for data processing: Article 6(1)(b) of the GDPR, measures taken at the data subject’s request prior to entering into a contract and the performance of the repair contract entered into.
Duration of data processing: If no repair takes place, for a maximum of 12 months following the closure of the case. In the event of a repair, data necessary for the handling of performance, warranty, guarantee, complaint or legal claims shall be retained until the end of the relevant period; data from accounting documents must be retained for at least 8 years.
Recipients of the data: Persons authorised to handle administrative matters at C29 E-Bike Rent Kft., the provider of the relevant communication channel, and, where required by law, an accountant, a regulatory authority or a legal representative.

5.8. Job Applications
Data controller: C29 E-Bike Rent Kft.
Purpose of data processing: To identify the applicant and maintain contact, assess professional suitability, organise interviews, make a selection decision and prepare an employment contract.
Scope of personal data processed: Name; telephone number; email address; place of residence or current address, if provided; details from CV and cover letter; qualifications, experience, language skills, references, salary expectations, availability to start work, and any other information provided during the interview that is necessary for the role.

Legal basis for data processing: Article 6(1)(b) of the GDPR when applying for the specific vacancy. In the case of data retention for the purpose of future recruitment opportunities, separate consent in accordance with Article 6(1)(a) of the GDPR.
Duration of data processing: Until the selection process is concluded, or for a maximum of 3 months following notification of the decision. In the case of separate consent, for a maximum of 12 months for the purpose of future job opportunities.
Recipients of the data: Managers and authorised staff involved in the selection process, the email service provider and any recruitment agency.
Nature of data provision: Voluntary; however, in the absence of the data required for assessment, the application cannot be evaluated. Applicants should not provide special categories of personal data without being asked to do so.
6. Cookies and similar technologies
A cookie is a small data file that may be placed in a visitor’s browser or on their device by the website or by an external service provider used by the website. Cookies may be session cookies or persistent cookies, and may be first-party or third-party cookies.

6.1. Categories of cookies and legal basis
Strictly necessary cookies: these ensure the basic and secure functioning of the website, the session, and the retention of cookie settings. No consent is required for their placement; the legal basis for the related processing of personal data is Article 6(1)(f) of the GDPR.
Statistical cookies: these are used to analyse website traffic and usage. They may only be used with the visitor’s prior consent, in accordance with Article 6(1)(a) of the GDPR.
Marketing cookies and measurement technologies: these may be used to measure visits and conversions from advertisements, as well as to analyse the effectiveness of campaigns. They may only be used with prior consent.
Technologies related to external content: these enable the loading of external services, such as Google Maps, and are only activated following the visitor’s prior consent.
6.2. Managing cookie settings
A cookie management interface appears when the website is first visited. The visitor may accept or reject all non-essential cookies, or make a separate decision for each category. The option to reject cookies must be just as easily accessible as the option to accept them.
Consent can be amended or withdrawn at any time via the ‘Cookie Settings’ page available on the website. Visitors may also delete or block cookies in their browser; however, blocking essential cookies at browser level may result in the website functioning incorrectly or with limited functionality.

6.3. The current list of cookies
The current list of cookies and similar technologies actually used on the website can be viewed in the cookie management interface. The list sets out the name, provider, purpose, category and retention period of each cookie or technology. The technical list displayed in the cookie management interface forms part of this Notice.

7. Google Services
7.1. Google Tag Manager
The website may use the Google Tag Manager tagging service provided by Google Ireland Limited. This service enables the centralised management of tags for measurement, statistics, advertising and consent management. Tags loaded via Tag Manager for statistical or marketing purposes may only be activated following prior consent for the relevant category, and Tag Manager cannot override the decision specified in the cookie management interface.
7.2. Google Analytics 4
Data controller: Ádám Ercsényi, sole trader. C29 E-Bike Rent Kft. may access aggregated statistical results necessary for service development.
Purpose: to compile visitor statistics; to analyse website usage, traffic sources, popular content and technical issues.
Data: online and cookie identifiers; time and duration of visit; pages viewed; traffic source; device, browser and operating system data; approximate geographical location; actions set for measurement. Google may use the IP address to determine the approximate location, but according to the service provider’s information, it does not log or store the unique IP addresses of visitors from the EEA.

Legal basis: prior consent pursuant to Article 6(1)(a) of the GDPR.

Retention: the duration of individual cookies can be viewed in the cookie management interface; the retention period for event- and user-level data is determined by the Analytics administration settings.

7.3. Google Ads conversion tracking

Data controller: the party that determines the purpose and means of the advertising campaign; in the case of campaigns promoting the services of C29 E-Bike Rent Kft., this is generally C29 E-Bike Rent Kft.

Purpose: to measure visits, enquiries and other pre-defined conversions generated by the adverts, and to evaluate and optimise campaign performance.

Data: cookies and online identifiers; ad click and campaign data; the time of the visit and conversion; device and browser data; the action set as a conversion.

Legal basis: prior consent pursuant to Article 6(1)(a) of the GDPR.

Retention period: the duration of individual cookies and technical identifiers can be viewed in the cookie management interface.

The free-text content of the contact form, details of identity documents or other personal data not required for conversion tracking must not be transmitted to the Google Ads system. Enhanced conversion tracking, remarketing or personalised advertising features may only be introduced following a separate data protection review and, where necessary, an amendment to this Privacy Notice.

7.4. Google Consent Mode v2

Google Consent Mode v2 transmits the decision made via the cookie management interface to Google tags as a technical consent signal. In the default operating mode used on the website, Google Analytics and Google Ads tags will not load and will not send measurement data to Google until the relevant consent has been given. Should consent be withdrawn, further data collection must be discontinued.

7.5. Google Maps
Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Google LLC may also be involved in certain service operations.
Purpose: to display the shop or premises on a map, and to facilitate contact and access.
Data: IP address; browser and device data; the website’s domain name; the time the map was loaded; actions performed on the map; data associated with a logged-in Google account in accordance with Google’s own terms and conditions.
Legal basis: prior consent pursuant to Article 6(1)(a) of the GDPR.
The Google Maps map does not load automatically when the website is opened. The map only establishes a connection with Google’s servers following consent to external content or separate activation via the alternative interface.
8. Recipients, data processors and external service providers
Personal data may only be accessed by those employees, managers, contractors and service providers for whom such access is necessary to handle the matter in question, to fulfil the service or to comply with a legal obligation. The data controllers do not sell or rent out personal data.

Service provider
Registered office / contact details
Role
Data protection role
BlazeArts Kft. – FORPSI
1096 Budapest, Thaly Kálmán utca 39; postal address: 6090 Kunszentmiklós, Szent Erzsébet tér 11; admin@forpsi.hu
Hosting, server infrastructure and technical availability
Data processor in the context of the hosting service
Google Ireland Limited
Gordon House, Barrow Street, Dublin 4, Ireland
Gmail, Tag Manager, Analytics, Ads, Consent Mode and Maps
Depending on the service and settings, data processor, recipient or independent data controller
Meta Platforms Ireland Limited
Merrion Road, Dublin 4, D04 X2K5, Ireland
Facebook, Instagram and Messenger
Independent data controller in its own data processing activities relating to the operation of the platform
WhatsApp Ireland Limited
Ireland
WhatsApp communication platform
Independent data controller in its own data processing activities relating to the operation of the platform