Effective from 10th September 2018

Hungarian version

Please read the following

During your contact with Carbyne Kft. we process your personal data in accordance with the following. You can have resort to the services of Carbyne Kft. under the below detailed conditions.

You can find the text of this informant on the website

The Controller: Carbyne Kft.
1111 Budapest, Lágymányosi utca 12. fszt. 2.;
Company registration number: Cg. 01-09-293516;
Registered by the Company Registry Court of Budapest-Capital Regional Court;
Tax number: 25868593-2-43;
Community tax number: HU25868593

Represented by: Sitte Peter Managing Director

The Controller processes the data of the persons having resort to its services (hereinafter: “you“) in the course of its selection procedure in connection with personnel placement.

We may get in touch with you in the following ways:

  1. The Controller contacts you
    1. in the social media we ask you to contact and to confirm the contact; in this case the contact is established between the Controller and you according to your expressed intent;
    2. a third person provides the Controller with your data, in which case the Controller promptly contacts you after receiving the data; you may object to the processing or you may accept it when we contact you.
  2. You contact the Controller
    1. through the website of the Controller; in this case you may contact the Controller only after having read this Informant;
    2. you contact the Controller in the social media; in this case you may contact the Controller ultimately through the Controller’s website as well, after having read this Informant;
    3. the Controller receives your application and contacts you through another employment agency website;
    4. you contact the Controller per e-mail;

After contacting and informing you appropriately, you may indicate it on the website that you have resort to the services of the Controller. In case you have resort to the services, we record your personal data in our database. Thereafter, we process your personal data according to this Informant in order to provide you with the services also set out herein.

Goal of data processing:

  • The Controller offers you a long-term carrier counselling service. In the framework of this the Controller records you in its database for the purposes of
    • participating in an potential job application in the future, placement of staff;
    • application for the specific job advertised by the mediation of the Controller;
    • participating in a certain client’s Talent Mapping program
  • provides you carrier counselling in the form of newsletters;
  • ensures you personal counselling on an occasional basis;
  • forwarding your data to a certain client as part of the recruitment or Talent Mapping service

We process your personal data in order to ensure the above services, namely

  • we record and register them in our database;
  • we forward them to our client advertising the specific job corresponding with your demands or to our client, who requested the Talent Mapping (see below) service; in this case we inform you of the identity of the client in advance and ask for your consent to the placement off staff;
  • we send you carrier advises, personalised information on the opportunity of the participation in a job application;
  • by processing your personal data we enable your participation in the selection procedures conducted for our clients.

The Talent Mapping service is a tailor-made solution to our clients, where Carbyne introduces some highly skilled experts with well-defined experience and educational background without offering a certain job opportunity during the program. During Talent Mapping we proved a short summary of the selected experts detailing their background in the respected field. Talent Mapping is the preliminary stage of the recruitment process, does not mean application to an existing job. We ask the Candidate’s permission before inviting the Candidate to participate in the Talent Mapping program. In this case Carbyne and the Client are both considered as data controllers. During Talent Mappaing, we handle and retain the candidate’s data up to 26 months.

We do not process your personal data for dissimilar purposes than the purposes determined herein, unless we are obligated to a processing differing from the above in order to comply with a legal obligation.

The processing by the Controller does not qualify as online recruiting activity exercised without human interference, since we contact you individually.

We process the personal data provided by you (name, e-mail address, mobile number) and the personal data provided by you at your discretion in your curriculum vitae and recorded at the subsequent (personal or by telephone) interview and the reference data received from third persons given by you.

In addition, based on the interview with you, the Controller may add further comments, observations to the personal data provided by you, which qualify as personal data as well and the Controller processes them.

The Controller processes special data (e.g. data concerning health status, criminal personal data) solely with your previous written consent and only in case if it is necessary in the course of the selection to a specific job offer you applied for. The Controller shall not be liable for the processing of special data (e.g. included in the CV uploaded during the online registration), which it is informed about without the expressed request of the Controller.

We process your personal data for the purposes of providing you the personnel placement selection services (including Talent Mapping services) and contacting you before providing the service. The processing is necessary for providing the service, without it the Controller cannot provide you the service, so if you incidentally do not consent to the processing of your data, you cannot have resort to the services of the Controller.

In case the Controller gets your personal data from a third person, the legal basis of the processing necessary to the contact is the enforcement of the legitimate interest of the Controller. The legitimate interest of the Controller is the interest related to exercising its personnel placement services, which activity can be realized by contacting the persons participating in the job offers with potential result. The contact in the framework of its activity necessarily involves the processing of personal data, the Controller cannot exercise its activity without processing personal data.

In the latter case, bearing in mind the consideration of interests prescribed by law, you are contacted in a way so that your interests are not injured. In order to ensure this:

  • we obtain solely your name and phone number as your personal data from a third person recommending you;
  • we process your personal data obtained so for the possibly shortest period and we contact you as soon as possible;
  • we contact you at the most appropriate time possible, we do not disturb you during the working hours;
  • based on the contact, if you do not consent to the further processing, we promptly erase your personal data;

If the Controller contacts you by relying on data obtained from a third person, beside this Informant it informs you of the source of your personal data when contacting you.

We record your personal data obtained during the first contact in our database.
If we contact you per e-mail, then your data sent per e-mail is stored also by the mail system. Your data sent during the log-in through the website are directly recorded in our database.

Regarding the record, the registration in our database and the subsequent process of your personal data, solely the employees of the Controller proceed beside the addresses defined below, regarding whom the Controller ensures that their proceeding complies with the processing laws and this Informant.

We set our data base in a cloud-based CRM system, the compliance of which system with the laws on processing is ensured by the service provider. The provider of the CRM system records and processes your data as a processor. The name and contact of the processor:

Name: Workforce Cloud Tech, Inc.
Seat: 10490 Mira Vista Road,
Cupertino, CA, 95014. USA
E-mail address:

Our mail system is operated by Google LLC, it processes your personal data, which reach the Controller by using the mail system, as processor accordingly.

Name Google LLC;
Seat: 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA;
E-mail address: [*];


The cookies set out below are also operated by Google as processor.

The data recorded in the mail system and in the CRM system are recorded on a server in a third country, which third country shall be deemed as a secure third country under the relevant laws.

We record also the report of the personal interview, including your personal data in our CRM system.

We transmit your personal data stored in our CRM system to our client which advertised the job offer you are interested in and the identity of whom we inform you in writing (in e-mail) in advance in each case. Our client advertising the job application or using our Talent Mapping service shall be deemed also as a controller according to the laws, so the Controller and its client (“PartnerController”) qualify as joint controllers regarding your personal data.

The Controller uses cookies during the use of its website.

Name of the Cookie Life period Features
_ga 2 years It enables the users to be recognized.
_gid 24 hours It enables the users to be recognized.

When visiting the website, the Google Analytics system operating the website places files containing data (cookie) on your computer, which are read back by the system at the time of the next visit of the website in order to recognise you. By using cookies, the processor temporarily processes the IP address of your computer, which qualifies as personal data as well. When entering the website, the processor orders a randomly formed code number to the IP address of your computer. Thereafter your IP address qualifying as personal data is not stored; the Google Analytics system recognizes the log-in from your computer solely based on the randomly generated code.

You may delete and disable the above cookies in the setting of the browser. If you do not proceed so, the Google Analytics system used by us records the above mentioned cookies on your computer in the period indicated above and it collects and processes the behavioural data of the entering to the website from your computer in this period. However, these data do not qualify as personal data having regard to the fact that they are connected to a randomly generated code number and the IP address qualifying as personal data is not stored neither by the Controller nor by the processor and cannot be connected to the code number again. The cookies are essentially necessary to provide the service, which you expressly required by the registration and the acceptance of the service agreement, through the website, so the Controller has the opportunity for the application of cookies and the processing exercised by them based on its obligation to perform the contract, as a legal basis.

You can read about the rules in connection with the cookies ensured by the processor and the opportunity of their management by you here:

The Controller promptly terminates the processing in the framework of providing the service under this Informant, erases the data processed in connection with you during the provision of the service, if you indicate to the Controller in writing that you wish to terminate the service agreement concluded between us. You may send the disclaimer of the service to the Controller via e-mail:

You have the right to terminate the services related to private data handling described in Section 1. When the data controller (Carbyne) informs You about an employment opportunity or talent mapping program, you shall be informed about the client’s identity. If you wish to refrain from sending you private data to th 3rd party Client, you shall informed Carbyne during the personal meeting or e-mail correspondence.

During the Talent Mapping services you can request from Carbyne to delete your private data from their database up to 17 months from the date you have shared your information. Between 17 and 26 months you shall contact both Data Controllers (Carbyne and Client) directly

According to the above, you have the following rights in connection with the processing of the personal data which you provided us or which we became aware of during the processing, having regard to the legal bases set out in point 3.

You may exercise your rights so that you indicate to the Controller per e-mail or in a postal letter which of your rights regarding which of your data or all your data and how you intend to exercise. In case of such a notification, the Controller proceeds pursuant to the relevant laws and adjudges your request within 1 month at longest, which time-limit may be extended in the cases set out in the laws. The condition of sending the answer is that you shall be identifiable without any doubt based on the request. In order to enforce your rights, we ask you to contact the Controller via e-mail: We deliver you the answer in the same way as the request was sent (electronically or as a post mail).

In order to enforce your rights you may also contact the Partner Controller. We inform you of the contact of the Partner Controller in writing at the personal interview or in the Talent Mapping service agreement. Below, where we mention the Controller, it means the Partner Controller identically. You may enforce your rights towards both controllers.

You are entitled to receive the following information in connection with the processing performed by the Controller regarding your personal data:

  • Is your data processed at this moment? If yes, then:
  • What is the purpose of the processing?
  • What kind of data (categories) are processed?
  • Who are the addressees with whom the data will be disclosed?
  • For what period of time are the recorded data preserved?
  • You are entitled to request the rectification, erasure of data and the restriction of processing and to object to the processing.
  • You may lodge a complaint with the supervisory authority.
  • If the Controller did not collect your data from you, then their source.
  • In case of data transfer to a third country the guarantees to be ensured by Controller.

You are entitled to request a copy of your personal data processed by the Controller, which the Controller can provide you for free in a .csv form readable with excel program.

The Controller shall deliver you copy of the processed data only so that it may not violate other person’s right to personal data, other right and freedom. Namely, if applicable, the Controller is not obligated to give you the copy of the processed personal data which cannot be separated from another person’s personal data.

B. You have the right to the rectification of your data processed by the Controller
In case you experience that your personal data appear inaccurate in the record of the Controller, you have the right to request the rectification of your processed personal data. You can perform it in writing by sending the request to the above indicated contacts (in undersigned, scanned declaration per e-mail, perhaps by sending an electronic document with electronic signature or in a postal letter). In connection with the performability of the request for rectification it shall be always examined what is the essential purpose of the data processing and the Controller shall execute the request for rectification only if it is related to the purpose of the data processing.

If you request the rectification of your personal data, the Controller shall notify everybody to whom it transmitted your personal data according to this Informant thereof.

C. You are entitled to request the restriction and the erasure of your data processed by the Controller
You may request the restriction of the processing in case:

  • you think that your personal data processed by the Controller are not accurate, then you may request the restriction of the processing until your processed personal data are rectified;
  • if you may request the erasure of data otherwise but instead of it the restriction of the processing serves your interests better;
  • if the Controller may already erase your data, since the purpose of the processing ceased but it is in your interest in order to enforce a legal claim, if your data are not erased, only their process is restricted;
  • if you object to the processing based on the legitimate interest of the Controller, in the provisional period, until it is established whether or not the legitimate interest of the Controller has priority against your interest connected to personal data, you may request the restriction of the processing of your personal data.

Your personal data may be solely stored and processed for reasons of public interest during the restriction. The Controller shall notify you of the possible lifting of the restriction of the processing.

You may request the erasure of the processed personal data, if

  • the process conducted by the Controller is unlawful;
  • the personal data are no longer necessary for the reason due to which the Controller collected them;
  • the laws on the processing provides so.

Your personal data may not be erased, if the processing is necessary:

  • to exercise the freedom of expression and information;
  • to comply with the legal obligation concerning the Controller or for the purposes of public interest;
  • for the establishment of legal claims;
  • for public health in the public interest;
  • for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes.

If you request the restriction, the erasure of your personal data, the Controller shall notify all the persons to whom it transmitted your personal data according to this Informant thereof.

D. You may object to the processing of your personal data
You are entitled to object to the data processing established on the legitimate interest of the Controller (see point 1.1.b). You may exercise your right to object at the time of contacting. If this occurs, the Controller shall promptly terminate the data processing and erase your personal data according to as referred above. However, if you consent to the data processing when we contact you, then, having regard to the different legal basis of the subsequent data processing, in the framework of the data processing necessary to the performance of the agreement, in the case of which objection is not possible, you may exercise only your other rights under this point 6.

E. The portability of your personal data
Having regard to the fact that your personal data is not processed in an automatized way but in case of contacting you the associates of the Controller uniquely record and transmit your personal data, so you may not request the portability of your personal data based on the relevant laws.

F. You have the right to lodge a complaint
If you think that we violated the legislative provisions regarding the protection of your personal data by our data processing, you are entitled to lodge a complaint with the competent supervisory authority, which is the Hungarian National Authority for Data Protection and Freedom of Information (; 1125 Budapest, Szilágyi Erzsébet fasor 22/c.; +36 1 391 1400)

The Controller ensures the security of the processing of your personal data and takes those technical measures which guarantee that the recorded, stored and processed data are protected and do everything in order to prevent the destruction, the unauthorized use and unauthorized alteration thereof. Besides, the Controller obligates itself to invite also all third persons to whom it may transmit or deliver the data to perform their obligations in that regard.

The provisions of this Informant enter into force as of the date indicated on the first page, they regulate the activity of the Controller from that date. The Controller may amend this Informant at any time, which amendment concerns the data processing subsequent to its disclosure on the Controller’s website, it shall be in force regarding you from the disclosure on the website. Should you not agree with any amendment to this Informant, you may exercise your right to erasure and to restriction under this Informant, if the conditions thereof are met.