Information on data processing
Information on data processing in relation to the data requested in the course of the client due diligence by the Dr. Rácz Zoltán Ügyvédi Iroda.
Pursuant to Act LIII of 2017 on the preventing and combating of money laundering and terrorist financing (hereinafter: Money Laundering Act), companies providing certain services – including the Dr. Rácz Zoltán Ügyvédi Iroda (hereinafter: Law Firm) – shall carry out the control of future clients in a manner defined by the Money Laundering Act prior to the conclusion of the concerned contracts (hereinafter: client due diligence). Although the data provision in the course of such client due diligence is voluntary, in the lack thereof, pursuant to the Money Laundering Act, the Law Firm shall reject the contribution. Regarding due diligence, the legal basis of data processing shall be the provisions of law. The Law Firm shall be entitled to process the data accepted pursuant to Money Laundering Act on the basis of the said act, it shall continuously keep such data up to date and store the data for 8 (eight) years. In the course of the client due diligence, the client, the natural person acting on behalf of the client and the beneficial owner shall also be identified. We hereby inform you that, in contrast to the previous regulation, the scope of data to be provided mandatorily by the clients to the service providers subject to Money Laundering Act has been significantly extended. The Law Firm prepared its forms used at client due diligence accordingly, only the data falling within the scope of mandatory data provision are included thereon, thus, we are not able to dispense with filling out the applicable form. Furthermore, we hereby inform you that, pursuant to Paragraph (8) of Article 7 in the Money Laundering Act, the Law Firm shall make a copy of the documents presented in order to verify the data subject’s identity. Please be aware that, pursuant to Paragraph (1) of Article 25 in the Money Laundering Act, if the registry of the data of beneficial owners comes into existence, the service providers subject the Money Laundering Act shall transfer the data pertaining to the clients’ beneficial owner(s) to the central registry without delay.
The Law Firm shall use the personal data obtained in the course of client due diligence exclusively for the purposes of the due diligence in connection with the prevention of money laundering and of identifying the client. Only our expressly designated colleagues who participate at the service of the Law Firm provided to the given client and who control the compliance with the provisions on money laundering shall have access to the personal data. The data security is ensured by the Law Firm in compliance with the provisions of Act CXII of 2011 on informational self-determination and freedom of information (hereinafter: Information Act) thus, the Law Firm protects the personal data from unauthorized access, alteration, transfer, disclosure, erasure, destruction, accidental loss or deterioration, as well as from becoming inaccessible. The data may be transferred within the Law Firm with the prior consent of the data subject (representative), yet, a certain level of protection is ensured also in such case.
The data subjects shall be entitled to request information, at any time, regarding the personal data concerning them that are processed by the Law Firm, moreover, they shall be entitled to request the rectification, alteration, amendment, and – in case it is not restricted by law – the erasure of such data. The data subjects can submit their requests of the above content by sending a postal consignment to the registered seat of the Law Firm at the address H-1051 Budapest, Arany János u. 16. 2/1. The Law Firm shall provide information within 25 (twenty-five) days of the submission of the request, in writing.
The provisions of the Information Act regulate only the (personal) data of natural persons, thus, it shall not be governing regarding the data of organisations. The existing and erased data of the company registry are public pursuant to Act V of 2006 on public company information, company registration and winding up proceedings.
Budapest, 2 January 2019