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Data Protection for Contractual Partners

Data Processing Notice for Contractual Partners

Data processing notice for landowners, persons granting usufruct or easement rights, lessors, sellers, other contractual partners, and persons involved in the conclusion and performance of contracts.

1. General Provisions

A und T Megújuló Energia Kft. (hereinafter: the “Company” or the “Data Controller”) processes personal data in the course of preparing, establishing, performing, managing and terminating contractual relationships.

The processing of personal data is carried out on the basis of Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation, hereinafter: the “GDPR”), as well as the applicable Hungarian legislation, in particular Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information.

The purpose of this notice is to provide transparent and comprehensible information on how and for what purposes we process the personal data of our contractual partners and other natural persons involved in contractual relationships.

2. Data Controller Details

A und T Megújuló Energia Korlátolt Felelősségű Társaság
Abbreviated name: A und T Megújuló Energia Kft.
Registered seat: 1024 Budapest, Lövőház utca 2-6.
Company registration number: 01-09-458395
Tax number: 33086464-2-41
Community tax number: HU33086464
Managing Director: Michael Keller, with independent representation rights
Email: info@at-energia.hu

3. Categories of Data Subjects

The data processing described in this notice may affect the following persons in particular:

  • natural person contractual partners and prospective contractual partners;
  • landowners, usufructuaries, persons granting usufruct or easement rights;
  • lessors, agricultural lessors, sellers, and other persons involved in real estate transactions;
  • representatives, contact persons, employees, and collaborators of legal entities;
  • authorized representatives, heirs, and other persons affected by the contractual relationship.

4. Purposes of Data Processing

The Company processes personal data for the following purposes in particular:

  • establishing contact and conducting pre-contractual negotiations;
  • identifying the contractual partner, representative, and contact person;
  • preparing, concluding, amending, performing, and terminating contracts;
  • communication and administration related to the contractual relationship;
  • payment of fees, purchase prices, rental or usage fees, and other amounts;
  • fulfilling accounting, tax, registration, and other legal obligations;
  • conducting permitting, land registry, and other administrative procedures;
  • development, financing, construction, operation, and potential sale of renewable energy projects;
  • bringing, enforcing, and defending legal claims;
  • safeguarding the Company's legitimate business and asset protection interests.

5. Categories of Personal Data Processed

Depending on the specific legal relationship and the purpose of data processing, the following personal data may be processed:

  • identification data, such as name, birth name, place and date of birth, and mother's name;
  • contact data, such as residential address, mailing address, telephone number, and email address;
  • document and identification data required for personal identification or administrative procedures;
  • tax identification number, tax number, company registration number, and data relating to representation rights;
  • bank account number, payment and settlement data;
  • data relating to real estate, ownership rights, usage rights, and other land registry rights;
  • contractual data, including the content, terms, and performance data of the contract;
  • data from correspondence, consultations, declarations, and other related documents;
  • data relating to claims, legal disputes, and enforcement of rights.

The Company processes only the personal data necessary to achieve the given purpose. The processing of special categories of personal data is not an objective of the Company, except where required by law in a given case or made necessary by the bringing, enforcement, or defense of legal claims.

6. Source of Personal Data

Personal data may originate from:

  • directly from the data subject;
  • from the contractual partner or its representative;
  • from an authorized representative, intermediary, or other person lawfully acting in the matter;
  • from authentic or publicly accessible registers, in particular the company register and the land register;
  • from authorities, courts, notaries, or other organizations authorized to provide data;
  • from lawfully accessible public business sources.

7. Legal Bases for Data Processing

7.1. Performance of a Contract

Where the data subject is a natural person who is the contractual partner, the legal basis for data processing is Article 6(1)(b) of the GDPR. In such cases, data processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

7.2. Compliance with a Legal Obligation

Pursuant to Article 6(1)(c) of the GDPR, the Company may process personal data in order to comply with accounting, tax, administrative, land registry, and other legal obligations to which it is subject.

7.3. Legitimate Interest

Pursuant to Article 6(1)(f) of the GDPR, a legitimate interest of the Company or a third party may include in particular communication with representatives and contact persons of legal entity contractual partners, secure and efficient management of contractual relationships, financing and evaluation of projects, and the bringing, enforcement, or defense of legal claims.

In the case of data processing based on legitimate interests, the Company balances its own or a third party's legitimate interests against the interests, fundamental rights, and freedoms of the data subject. The Company processes data only if the legitimate interest takes precedence under the given circumstances.

8. Provision of Data

The provision of certain personal data may be based on a statutory or contractual requirement, or may be necessary for the conclusion or performance of a contract.

In the absence of the necessary data, the Company may not be able to prepare, conclude, or perform the contract, make payments, or fulfill a legal or administrative obligation.

9. Data Retention Period

The Company processes personal data during the existence of the contractual relationship and, following its termination, for as long as necessary to fulfill the relevant legal obligations or to bring, enforce, or defend legal claims.

  • Contractual and contact data are generally retained until the end of the general limitation period from the termination of the legal relationship.
  • Accounting documents and the data on which they are based are retained for the retention period prescribed by accounting legislation, generally for at least 8 years.
  • In the event of administrative or judicial proceedings or legal disputes, data are processed until the final closure of the proceedings or dispute and until the end of the applicable retention period thereafter.

If multiple retention periods apply to the same data, the Company applies the longer retention period. Following the expiry of the retention period, personal data are deleted or anonymized, unless their further retention is lawfully necessary.

10. Data Transfer and Recipients

The Company may transfer or make personal data accessible only to the extent necessary and on an appropriate legal basis.

Recipients of personal data may include the following persons and organizations in particular:

  • companies belonging to the same group of companies as the Company;
  • lawyers, notaries, tax advisors, accountants, auditors, and other professional advisors;
  • banks, financiers, insurers, appraisers, and rating organizations;
  • technical designers, contractors, operators, and other service providers involved in the project;
  • state and local authorities, land registry authorities, tax authorities, courts, and other public bodies;
  • IT, hosting, document management, and other administrative service providers;
  • prospective or actual investors, financiers, purchasers, intermediaries, and their advisors, where data transfer is necessary for the preparation and execution of project financing, corporate, or project transactions.

Service providers acting as data processors may process personal data solely on the basis of the Company's instructions and the data processing agreement concluded with them.

Data transfer to a country outside the European Economic Area or to an international organization may take place only upon fulfillment of the conditions set out in Chapter V of the GDPR and with the application of appropriate safeguards.

11. Automated Decision-Making

The Company does not carry out solely automated decision-making or profiling based on personal data falling within the scope of this notice that would produce legal effects concerning the data subject or similarly significantly affect the data subject.

12. Rights of Data Subjects

The data subject is entitled, in accordance with the conditions of the GDPR, to:

  • request information and access to personal data processed about them;
  • request the rectification of inaccurate personal data and the completion of incomplete data;
  • request the erasure of their personal data if the legal conditions for such erasure are met;
  • request the restriction of processing;
  • exercise their right to data portability if the conditions for such right are met;
  • object to data processing based on legitimate interest;
  • lodge a complaint with the supervisory authority;
  • seek judicial remedy.

Following an objection, the Company will no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or the processing is for the establishment, exercise, or defense of legal claims.

Requests to exercise rights may be submitted to the Data Controller at the contact details specified in Section 2 of this notice.

The Company will respond to the request without undue delay and in any event within one month of receipt of the request. This period may be extended by a further two months in the cases specified in the GDPR.

13. Complaint and Remedy

If the data subject believes that the processing of their personal data infringes data protection legislation, we kindly ask them to first contact the Company so that we may investigate and resolve the matter.

The data subject is entitled to lodge a complaint with the National Authority for Data Protection and Freedom of Information or to seek judicial remedy.

National Authority for Data Protection and Freedom of Information (NAIH)
Registered seat: 1055 Budapest, Falk Miksa utca 9-11.
Mailing address: 1363 Budapest, P.O. Box 9.
Email: ugyfelszolgalat@naih.hu
Telephone: +36 1 391 1400
Website: www.naih.hu

14. Amendment of this Notice

The Company is entitled to amend this data processing notice in accordance with changes in legislation, supervisory practice, or its own data processing procedures.

The current version will be published on the Company's website and made accessible to data subjects in an appropriate manner.

Last updated: 16 July 2026.

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