Privacy Policy

Effective from: 03 August 2026

1. Details of the Data Controller

S&M Parking Kft. is responsible for the data processing activities described in this notice.

Company name / Name of entrepreneur: S&M Parking Kft
Registered office: 4300 Nyírbátor, Zrínyi utca 14. 3/8
Tax number: 33055868-2-15
Company registration number / Registration number: 15 09 094672
Telephone number: +36 70 744 7772
E-mail address: info@nullterminal.hu
Website: https://www.nullterminal.hu/
Central administration / Location of the car park: Üllő, Pesti út 207

2. Principles and Legal Background of Data Processing

The Data Controller processes personal data in accordance with the principles of good faith, fairness and transparency. During data processing, it complies with the following main legislation:

Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR)
Act CXII of 2012 on Informational Self-Determination and Freedom of Information (Infotv.)
Act C of 2000 on Accounting (Accounting Act)

3. Scope of Data Processed, Purpose and Legal Basis of Data Processing

3.1. Online and Telephone Booking

Data processed: Surname, first name, e-mail address, telephone number, vehicle registration number, arrival and departure times, flight number of the return journey.
Purpose of data processing: Ordering and confirming the parking and transfer service, contacting the passenger, live flight tracking (based on Flightradar24 for handling delays), and performance of the service.
Legal basis of data processing: Performance of a contract [Article 6(1)(b) GDPR].
Data retention period: 5 years following performance of the contract (until the end of the civil-law limitation period).

3.2. On-site Administration and Key Storage

Data processed: Registration number, vehicle key identifier, data contained in the handover record.
Purpose of data processing: Assuming responsibility for vehicles and keys, enabling rearrangement of the car park and movement in emergencies, identifying the vehicle and releasing it to the authorised person.
Legal basis of data processing: Performance of a contract [Article 6(1)(b) GDPR].
Data retention period: Until the vehicle is released from the car park (in respect of the records, until the civil-law limitation period expires, for 5 years).

3.3. Video Surveillance System (Monitored Area)

Data processed: Images of persons entering the car park area, as well as vehicles and their registration numbers appearing in the video recordings.
Purpose of data processing: Asset protection, the safety of the guarded vehicles and Passengers, and the investigation of possible damage events and legal disputes.
Legal basis of data processing: Legitimate interest of the Data Controller [Article 6(1)(f) GDPR].
Data retention period: 8 (eight) days from the creation of the recording, unless the recording must be restricted due to an official or court proceeding.

3.4. Invoicing and Accounting

Data processed: Name, billing address, payment method, transaction amount (tax number in the case of a corporate purchase).
Purpose of data processing: Fulfilment of accounting and taxation obligations prescribed by law.
Legal basis of data processing: Compliance with a legal obligation [Article 6(1)(c) GDPR].
Data retention period: 8 years pursuant to Section 169(2) of the Accounting Act.

4. Data Processors and Data Transfers

The Data Controller does not sell or transfer your data to third parties for marketing purposes. Data is transferred exclusively to data processors essential for operation:

IT and hosting provider: Nethely Kft. (1115 Budapest, Halmi u. 29) (for operation of the website and e-mail system)
Accounting office: [Accounting Company/Name and Registered Office] (for fulfilment of statutory taxation obligations)
Online invoicing system: [e.g. KBOSS Kft. - Számlázz.hu / Billingo Technologies Zrt.] (for issuing invoices)
Authorities: In the event of an official request by an authority (e.g. Police, Court), camera recordings and data may be disclosed in accordance with statutory obligations.

5. Data Security Measures

Digital data: Online bookings and e-mails are protected by password-protected, encrypted servers and a website equipped with an SSL certificate.
Protection of keys: Vehicle ignition keys are stored in a locked, key-protected key cabinet in the office premises.
Camera recordings: Access to the recording unit of the surveillance system and the recordings is restricted exclusively to the designated managers of the Data Controller.

6. Rights of the Data Subject (Passenger)

The Passenger may exercise the following rights in relation to data processing by submitting a request to the Data Controller's e-mail address (info@nullterminal.hu):

Right of access: The Passenger may request information about which data is processed by the Data Controller, for what purpose and for how long.
Right to rectification: The Passenger may request the correction of inaccurate or changed data (e.g. change of registration number).
Right to erasure (“right to be forgotten”): The Passenger may request the deletion of their data, unless data processing is mandatory under the law (e.g. the Accounting Act).
Right to restriction of processing: The Passenger may request that their data be restricted (e.g. if they dispute the accuracy of the data or request that a camera recording not be deleted until a damage event has been investigated).
Right to object: The Passenger may object to data processing based on legitimate interest (e.g. camera recording).
Right to data portability: The Passenger may request the data they have provided in a structured, commonly used digital format.

7. Legal Remedies

If the Passenger believes that the Data Controller has infringed their rights relating to the protection of personal data, they may contact the following bodies:

Direct complaint: Please contact us first in order to achieve a quick and amicable resolution: info@nullterminal.hu or +36 70 744 7772
Authority proceedings:
- Hungarian National Authority for Data Protection and Freedom of Information (NAIH)
- Address: 1055 Budapest, Falk Miksa utca 9-11.
- Postal address: 1363 Budapest, P.O. Box 9.
- E-mail: ugyfelszolgalat@naih.hu
- Web: https://naih.hu
Court proceedings: In the event of an infringement of their rights, the data subject may bring proceedings before the Regional Court having jurisdiction according to the registered office of the Data Controller or according to their own place of residence or stay.