Privacy policy

Saphire is committed to safeguarding the privacy of the visitors of our Website. Please read the following privacy policy (the “Policy”) to understand how your information will be treated. This Policy may vary from time to time so please check it regularl. Any significant changes to this Policy will be clearly indicate at the homepage of this Site.

The information we collect and the purpose of data controlling activities

Visitors are not required to provide any personal information on the public areas of this Website. However, Visitors may choose to do so by completing the application form on the news feed (RSS or other news) service section of our Site (the “News Service”). The purpose of the data controlling activities of Saphire is the provision of News Service and the marketing of Saphire’s services and commercial activities.

IP addresses

When visitors visit our Website our server will record their IP address together with the date, time and duration to their visits. An IP address is an assigned number, similar to a telephone number, which allows the Visitor’s computer to communicate with our server(s) over the Internet. The IP address enables us to identify which organisations have visited the Website. We use this information to compile statistical data in relation to the use of the Site and to track how users navigate through the Website in order to evaluate and improve the Site.

Data controller and place of data controlling

Saphire shall be the data controller (adatkezelő) of any personal data provided by the Visitors in relation to the News Service. Saphire processes the personal data of the visitors by a third party data processors in Hungary. The handling of the visitors’ personal data is governed by Act CXII of 2011 on the right of self-determination in relation to personal data and the freedom of information (the “Data Protection Act”).

Legal basis of the data controlling

The basis of the handling of the Visitor’s personal data is his/her consent given under the application form in the framework of the registration process. The use of the personal data of the visitor shall be limited to the purpose of the data controlling as set out above.


Registration of the visitor and his/her personal data shall takes place by way of the submission of the application form for the News Service (or any other service that may be available at the Website from time to time). [NTD: please provide us with the registration form or the data you need so that we can mark-up/update the registration form] The visitors shall be entitled to provide his/her personal data only. The purpose of the registration is to enable Saphire to contact and to provide information with the data subject in relation to the News Service. The provision of the personal data of third parties may qualify as the violation of certain laws (including the Data Protection Act and the Criminal Code) and Saphire will co-operate with the administrative bodies or investigators by providing the personal data in order to assist them in the clarification of the violation of the applicable laws and the person who committed such violation.

Access to personal data

The personal data of the visitors may be accessible by third parties acting on behalf and in the interest of Saphire to the extent that it is necessary for their activities aimed at the satisfaction the purpose of the data controlling set out in this Privacy Policy above. The access to such data is subject to the consent of the registered visitors or the permission set out in the Data Protection Act or any other applicable law.

Data processors

Saphire shall be entitled to use data processors in relation to the technical measures in connection with the use the Visitors’ personal data (e.g. e-mail delivery of the News Service to the registered visitors, hosting) under this Privacy Policy. The data processor shall only be entitled to carry out actions in relation to the personal data of the visitors upon the instruction of Saphire and the involvement of any data processor shall not affect the liability of Saphire as a data controller.

Duration of the data controlling activities and the preservation of personal data

Unless a civil law relationship between the visitor and Saphire or other administrative law relationships (e.g. official procedures) require, the personal data of the visitor shall be handled until their deletion upon the occurrence of the following facts and/or circumstances: (i) the data controlling is declared as unlawful and/or non-compliant with the underlying laws; (ii) the request of the visitor in relation to the deletion of his/her data; (iii) the personal data stored prove to be inaccurate or incapable of serving the purpose of the data controlling; (iv) the purpose of the data controlling falls away; or (v) the competent court or administrative body orders the deletion.

Rights of the visitors (data subjects)

Registered visitors shall have the right to request the deletion of their personal data and their de-registration from the systems of Saphire (e.g. the cancellation of the News Service). Unless otherwise provided in this Privacy Policy, Saphire shall delete the personal data of the visitor within five business days of the receipt of such request. Furthermore, registered visitors shall be entitled to apply for a copy of the information Saphire holds about them and to have any inaccurate information corrected.


Saphire uses up-to-date storage, organisational and security techniques to protect the personal data of the registered visitors from unauthorised access, improper use or disclosure, unauthorised modification or unlawful destruction or accidental loss.

Right to object

In relation to their personal data, registered visitors shall be entitled:

  • to file a complaint with Saphire directly who shall investigate of the complaint in accordance with this Privacy Policy;
  • to file an objection in relation the controlling of their personal data in which case Saphire shall investigate and decide on the objection 15 days of the receipt of such request in accordance with Section 15 of the Data Protection Act;
  • to approach the Hungarian National Authority for Data Protection and Freedom of Information (the “Hungarian DPA”) (1530 Budapest, Pf.: 5., address: 1125 Budapest, Szilágyi Erzsébet fasor 22/c., tel: +36 (1) 391-1400; fax: +36 (1) 391-1410, e-mail:; or
  • to submit a claim in line with the Data Protection Act and other applicable laws, in particular, in front of the competent courts.

Data protection register

Saphire is registered with the Hungarian DPA in relation to the data controlling activity set out in this Privacy Policy.

Content of the Site

The contents of this Site are for information purposes only. Any information or opinions contained herein have been produced by Saphire based on information obtained from sources believed to be reliable but which it has not independently verified. Saphire makes no guarantee, representation or warranty (whether expressed or implied) and accepts no responsibility or liability as to the accuracy and completeness of the information available at the Site. Neither the information nor any opinion expressed herein constitutes an offer to buy or sell any investment. Such information and opinions are subject to change without notice. Saphire, its directors, officers or employees accept no liability for any damages or losses arising from the use of this Site or its contents. Visitors should be aware that the regulatory regimes and compensation arrangements in overseas locations will be different in each jurisdiction. Readers should not rely on any material contained herein and should seek independent advice wherever necessary.