Effective from: 8 September 2026

The purpose of this Privacy Notice is to provide visitors to the www.solbat.hu website and persons contacting SOLBAT through the website with clear and transparent information about the processing of their personal data.

SOLBAT Újrahasznosító és Kereskedelmi Kft. processes personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (the “GDPR”), Act CXII of 2011 on Informational Self-Determination and Freedom of Information, as well as other applicable Hungarian and European Union legislation.

1. Data Controller

Data Controller: SOLBAT Újrahasznosító és Kereskedelmi Kft.
Abbreviated name: SOLBAT Kft.
Registered office: 3527 Miskolc, Zsigmondy Vilmos utca 32., Hungary
Tax number: 32289925-2-05
Company registration number: 05-09-036700
E-mail: info@solbat.hu
Website: www.solbat.hu

Questions, requests and comments relating to the processing of personal data may be submitted to the Data Controller using the above e-mail address or by post.

2. Principles of Data Processing

SOLBAT processes personal data only for specified, explicit and lawful purposes and only collects data that is necessary for achieving the relevant purpose.

Personal data is retained only for as long as necessary to fulfil the purpose of processing or for the period required by applicable law. After this period, the data is deleted or, where possible, anonymised.

SOLBAT applies appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, loss or destruction.

3. General Enquiries

Personal data provided through contact forms on the website or through direct e-mail or telephone enquiries is processed by SOLBAT for the purpose of responding to the enquiry and handling the relevant matter.

Purpose of processing: communication, responding to questions and enquiries, and maintaining contact.

Categories of personal data: in particular name, e-mail address, telephone number, content of the message and any other information voluntarily provided by the data subject.

Legal basis: depending on the nature of the enquiry, Article 6(1)(b) GDPR – taking steps at the request of the data subject prior to entering into a contract – or Article 6(1)(f) GDPR – SOLBAT’s legitimate interest in handling and responding to enquiries received.

Retention period: where no further legal or contractual relationship is established, the data is retained for a maximum of 1 year following closure of the enquiry. Where a contractual or other legal relationship is established, the data may continue to be processed in accordance with the rules applicable to that relationship.

Providing information marked as mandatory is necessary in order for SOLBAT to properly process the enquiry.

4. Business and Commercial Enquiries

SOLBAT processes business and commercial enquiries submitted through the website – including, in particular, enquiries relating to recovered secondary raw materials, processing technologies, purchasing opportunities or potential cooperation – for the purpose of establishing and maintaining business relationships.

Purpose of processing: business contact, assessment of requirements, preparation of offers, professional and commercial consultation.

Categories of personal data: name, company name, position – where provided –, e-mail address, telephone number and the content of the enquiry.

Legal basis: Article 6(1)(b) GDPR or, in the case of a contact person acting on behalf of a legal entity, Article 6(1)(f) GDPR.

Legitimate interest: communication between SOLBAT and potential business partners, and the preparation and maintenance of business relationships.

Retention period: where the enquiry does not result in a business relationship, for a maximum of 1 year following closure of the matter. Where a business relationship is established, the data may be processed for the duration of the relationship and thereafter for the period required for the enforcement of contractual claims and compliance with legal obligations.

SOLBAT does not use contact details provided in this context for newsletters or unsolicited marketing communications without an appropriate separate legal basis.

5. Data Processing Related to the Collection Point Programme

Personal data provided during registration for SOLBAT’s battery and accumulator collection programme is processed for the purpose of handling the application, coordinating the location and requirements, arranging placement of the collection container, organising collection and transportation, and managing related administration.

Purpose of processing: collection point registration, communication, organisation of collection container placement, management and transportation.

Categories of personal data: in particular name, company or organisation name, e-mail address, telephone number, location and address details, and any additional information voluntarily provided through the form.

Legal basis: Article 6(1)(b) GDPR or, in the case of a contact person acting on behalf of a legal entity, Article 6(1)(f) GDPR.

Retention period: unsuccessful applications are retained for a maximum of 1 year. Where a partnership relationship is established, the data is retained for the duration of the relationship and thereafter for the period required to enforce claims arising from the relationship and comply with applicable legal obligations.

Applications Submitted via the WALORE Subpage

The Data Controller in respect of forms available on the WALORE programme-related subpage of the www.solbat.hu website is also SOLBAT Újrahasznosító és Kereskedelmi Kft.

Personal data necessary for registration and performance of the collection service may be transferred by SOLBAT, to the extent necessary for performance of the relevant tasks, to contractual partners involved in providing the service, including in particular WALORE SOLUTIONS Kft.

The purpose of such data transfer may include arranging placement of collection containers, collection and transportation of full containers, and related administration.

6. Contractual, Invoicing and Accounting Data

Where an enquiry results in a contractual or commercial relationship, SOLBAT may continue processing personal data necessary for performance of the contract, invoicing, accounting, enforcement of legal claims and compliance with statutory obligations.

The legal basis for such processing is Article 6(1)(b) and Article 6(1)(c) GDPR.

Accounting documents and related records that must be retained by law are stored by SOLBAT for the period prescribed by the applicable accounting legislation, generally for at least 8 years.

7. Technical Data and Server Logs

When using the website, certain technical data may be automatically recorded by the web server for technical and security purposes.

Such data may include:

• IP address;
• date and time of the request;
• pages visited;
• browser and operating system type;
• technical information relating to the device and connection;
• error and security log data.

Purpose of processing: ensuring secure and reliable operation of the website, identifying technical errors, preventing misuse and maintaining IT security.

Legal basis: Article 6(1)(f) GDPR – SOLBAT’s legitimate interest in ensuring the secure operation of the website.

Technical log data is retained only for the period necessary to fulfil the above purposes or in accordance with the technical retention rules of the hosting provider.

8. Hosting Provider

The hosting provider of the website is:

Tárhely.Eu Szolgáltató Kft.
Registered office: 1144 Budapest, Ormánság utca 4. X. em. 241., Hungary
Company registration number: 01-09-909968
Tax number: 14571332-2-42

The provider acts as a data processor and provides hosting for the website, its databases and related IT systems.

The hosting provider may access personal data stored on the servers only to the extent necessary for providing its services.

9. Website Forms

Forms available on the website are technically managed using the Fluent Forms plugin operating within SOLBAT’s WordPress system.

Data submitted through these forms may be stored in the SOLBAT website database and may also be transmitted to SOLBAT through the configured e-mail notification system.

The use of Fluent Forms does not alter the purpose or legal basis of the processing associated with the relevant form.

10. E-mail Delivery – SMTP2GO

SOLBAT uses the SMTP2GO service to deliver automated e-mail notifications, contact-form notifications and other system-generated messages sent through the website.

Provider: Sand Dune Mail Ltd
Service: SMTP2GO
Address: 96–106 Manchester Street, Christchurch 8011, New Zealand

SMTP2GO processes data on behalf of SOLBAT for the purpose of transmitting and delivering electronic communications.

The following types of data may in particular be processed when using SMTP2GO:

• sender and recipient e-mail addresses;
• e-mail headers;
• delivery and technical information;
• IP addresses and related technical data;
• personal data contained in the electronic message where such data forms part of the message content.

According to SMTP2GO’s privacy information, the default retention period for e-mail-related data is up to 35 days. Different retention periods may apply to certain paid service configurations.

SMTP2GO provides European infrastructure for customers registered in the European Union and the United Kingdom, including an Amsterdam data centre. According to the provider, accounts registered in the EU/UK region are automatically assigned to European infrastructure; the actual data-centre assignment can be checked within the SMTP2GO account.

Where personal data is transferred outside the European Economic Area, such transfer shall take place in accordance with Chapter V of the GDPR and subject to appropriate safeguards.

11. Google reCAPTCHA

SOLBAT uses Google reCAPTCHA to protect forms available on the website.

The purpose of the service is to determine whether a form is being used by a natural person or an automated system, and to prevent spam, automated abuse and malicious activity.

The relevant Google service provider within the European Economic Area is:

Google Ireland Limited
Gordon House, Barrow Street, Dublin 4, Ireland

During the operation of reCAPTCHA, Google may process technical information including IP addresses, browser and device information, and data relating to the use of the website.

The legal basis for this processing is SOLBAT’s legitimate interest in maintaining the secure operation of its website and forms. Where the service uses cookies or device identifiers for which prior consent is required by law, such technologies may only be activated following appropriate consent from the data subject.

Processing performed by Google is governed by Google’s applicable privacy policy and service terms.

12. Cookies and Similar Technologies

The website may use cookies and similar technologies.

Cookies that are strictly necessary for the operation of the website serve essential functions and help ensure the secure operation of the website.

Statistical, analytical, marketing or other non-essential cookies are used only after appropriate information has been provided to the visitor and, where required by law, only following the visitor’s prior consent.

Users may subsequently modify or withdraw their consent.

Detailed information about the cookies actually used on the website, their purpose, providers and duration is available in the separate Cookie Policy:

www.solbat.hu/cookie-policy/

13. Google Analytics – Currently Inactive, Planned Service

The website does not currently use Google Analytics.

SOLBAT may introduce Google Analytics in the future for the purpose of analysing website usage, visitor traffic and website performance.

If the service is activated, analytical data processing and associated non-essential cookies will only be activated after obtaining the data subject’s appropriate prior consent.

Refusing consent will not prevent use of the website’s essential functions.

Upon activation of Google Analytics, this Privacy Notice and the Cookie Policy will be updated to reflect the actual configuration used.

14. Meta Pixel – Currently Inactive, Planned Service

The website does not currently use Meta Pixel.

SOLBAT may introduce Meta Pixel in the future for the purpose of measuring the effectiveness of advertising campaigns, tracking conversions and optimising online marketing activities.

If the service is activated, related data processing and non-essential cookies will only be activated after obtaining the data subject’s appropriate prior consent.

The relevant provider in the European region is:

Meta Platforms Ireland Ltd.
Merrion Road, Dublin 4, D04 X2K5, Ireland

Upon activation of Meta Pixel, this Privacy Notice and the Cookie Policy will be updated to reflect the actual configuration used.

15. Transfers Outside the European Economic Area

The operation of certain external service providers may involve the transfer of personal data to countries outside the European Economic Area or access to personal data from such countries.

Such transfers will only take place in accordance with the requirements of Chapter V of the GDPR and subject to an appropriate legal basis and adequate data protection safeguards.

When selecting and configuring service providers, SOLBAT seeks to ensure that personal data is processed within the European Economic Area where possible, or that appropriate safeguards are in place for international data transfers.

16. Data Security

SOLBAT applies technical and organisational measures appropriate to the nature and risks of the processing in order to ensure an adequate level of security for personal data.

Personal data may only be accessed by employees and contractual partners who require such access for the performance of their duties.

SOLBAT applies appropriate measures to reduce the risk of unauthorised access, data loss, unauthorised alteration, disclosure or destruction.

17. Personal Data of Children

SOLBAT’s website and services are not intended for children.

SOLBAT does not knowingly request personal data from persons under the age of 16.

If SOLBAT becomes aware that a person under the age of 16 has provided personal data, SOLBAT will take the necessary steps to delete such data unless there is another lawful basis for its processing.

18. Automated Decision-Making and Profiling

SOLBAT does not use personal data submitted through website contact or registration forms for decision-making based solely on automated processing that produces legal effects concerning the data subject or similarly significantly affects them.

SOLBAT does not carry out profiling in connection with the processing activities described in this Privacy Notice.

19. Rights of Data Subjects

In accordance with the GDPR, data subjects have the right to:

• request information about and access to their personal data;
• request correction of inaccurate personal data;
• request deletion of personal data in the cases provided for by law;
• request restriction of processing;
• exercise the right to data portability where the statutory conditions are met;
• object to processing based on legitimate interests;
• withdraw consent at any time where processing is based on consent.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Requests relating to data-subject rights may be submitted by e-mail to info@solbat.hu or by post to SOLBAT’s registered office.

SOLBAT will respond to such requests without undue delay and, as a general rule, within one month of receipt.

Where justified under the GDPR, this period may be extended by a further two months. The data subject will be informed of any such extension.

20. Complaints and Legal Remedies

If a data subject considers that the processing of their personal data infringes applicable data-protection legislation, they may lodge a complaint with:

Hungarian National Authority for Data Protection and Freedom of Information (NAIH)

Address: 1055 Budapest, Falk Miksa utca 9–11., Hungary
Postal address: 1363 Budapest, Pf. 9., Hungary
E-mail: ugyfelszolgalat@naih.hu
Telephone: +36 (1) 391-1400

The data subject also has the right to seek judicial remedy if they consider that the processing of their personal data infringes the GDPR or other applicable data-protection legislation.

21. Amendments to this Privacy Notice

SOLBAT reserves the right to amend this Privacy Notice, in particular in the event of changes in legislation, the introduction of new services or processing activities, the use of new external service providers, or changes to the operation of the website.

The current version of this Privacy Notice is always available on the www.solbat.hu website.

Where material changes are made, SOLBAT will inform data subjects in an appropriate manner.