Nap-Mandala Kft

Registered address: 

1046 Budapest, Kinizsi u. 11. Hungary

Tax number: 


Adult education registration number:





Privacy Policy

Privacy Policy

Nap-Mandala Kft (hereinafter referred to as: Service Provider) pays special attention that in the interest of the Client/Visitor in its data management it complies with the CXII. of 2011. Act on Informational Self-Determination and the Freedom of Information (hereinafter referred to as: Info Act) and any other effective laws related to data management.

Details of the data controller:

Name: Nap-Mandala Korlátolt Felelősségű Társaság (Limited Liability Company)

Head office: 11. Kinizsi utca, 1046 Budapest

E-mail address:

Data processor (hosting service provider):

Name: Oleander Informatikai Kft.

Head office: 7. Gőz utca, 3534 Miskolc

E-mail address:

The legal basis and definition of data management

Data management carried out by means of the website is done pursuant to Paragraph 5. Section 1/a of the Info. Act, with the voluntary consent of users. The consent is given by the user by using the website as well as by voluntarily providing their personal data when subscribing to the newsletter. The website contains links that point to other websites. The data management of such external websites is governed by the privacy statement of that particular website.

The scope of the managed data, the aim and term of privacy policy

The term of the data management: 180 calendar days following the termination of the Agreement.

The Data Controller informs the Visitors and Users of the website that the website uses cookies for efficient operation.

The Data Controller informs the Visitors and Users of the Website that Google Analytics helps the independent measuring of the traffic and other web analytics data of the Website. Google Analytics uses an additional cookie to identify visitors. Google Analytics does not record IP data that could be used to identify the Data Subject. Google provides detailed information about the measurement data and its management on the following page.


By using the website, everyone visiting the website allows the Data Controller to use the following cookies:






system general cookies

no need

basic cookie responsible for the operation of the web application

ensure the operation of the website

until browser is closed

system general cookies


after the web application has been loaded approving cookies is necessary to access further functions

allow the use of cookie and consent of a person over the age of 18

365 days

system function cookies

no need

cookies necessary for smoother operation and for tailor-made use

the user can access full functionality of the system, without these plenty of things do not function

until browser is closed

system tracking cookies


necessary for measuring and for developing user’s experience

drawing up statistics

365 days

tracking cookies

(coming from third party)

no need

 suitable for identifying new visitors and for web-tracking (some are system-integrated, others can be set individually) (Google, Facebook, Twitter, AddThis)

We measure the efficiency of adWords advertisements with google Adwords conversion-tracking cookies

exact expiry

Adwords: 30 days

Disable cookies:

The Data Controller informs the Visitors and Users of the website that they have the possibility to disable the use of cookies in the settings of their own user devices. This setting is usually available in the device browser settings under the menu Privacy and Security.


Quick menu >> Settings >> Special settings >> Content Settings in the Privacy and Security section >> Cookies >> Allow cookies to save and read data on websites (recommended) this feature can be turned on or off.

Browser url: chrome://settings/content/cookies

The description was prepared based on the 66.0.3359.181 (64 bites) version of Google Chrome.




Quick menu >> Settings >> Select the Privacy and Security menu from the side panel >> In the Cookies and page data section, you can turn on "Block cookies and page data (may cause a website error)".

Browser url: about:preferences#privacy

The description was prepared based on the 60.0 (64 bites) version of Firefox Quantum.




Quick menu >> Settings >> Open Special Settings >> In the Cookies section, you can enable or disable the use of cookies from the combobox

Browser url: non-existent

The description was prepared based on the 42.17134.1.0 version of Microsoft Edge.



The Service Provider's websites can be visited without providing any data. However, there are some types of services that require the provision of data. In the following you can see these cases in detail.

Name of activity and aim of data management

Legal basis

Data managed


Website visit

The aim is to ensure the high quality use of the website as intended,

the quality control and improvemenet of our services,

the identification of malicious visitors, those attacking our website,


the measuring of website traffic,

statistics purposes

the legitimate interest of our company

IP address

date of visit

data of the visited subsites,

the type of the browser and operation system used by You

not relevant

Sending in a form

providing the requested information


family and first name of the private person, e-mail address

180 days

Newsletter subscription
the Company prepares and sends tailor-made marketing offers to those who contribute to the service, contacts them for business acquisition purposes, and sends information about the products and services provided by the Company.


e-mail address

until unsubscribing from the newsletter

Comment on an article


e-mail address

until withdrawal

Comment on data sheet, guest book


e-mail address
IP address

until withdrawal

Direct marketing service

based on the analysis of Your shopping habits

we prepare and send tailor-made offers,

we contact You with the purpose of business acquisition

we send information about the products and services provided by us.



full name,

e-mail address,

phone number (optional)

other, optional data, e.g. interest, address, etc.

until unsubscribing from direct marketing services

Administration, complaint

o    response to any comments and complaints


o    legal obligation

o    full name

o    e-mail address

o    phone number

o    postal address

o    other personal message

o    for 5 years

If you have any questions regarding data management, you can request further information by e-mail on or on our postal address, and we will send you our answer to the contact details provided by you within a maximum of 28 days without undue delay.

In the above cases, the most necessary data will be recorded only for the purpose of carrying out the online transaction, invoicing or providing the service until the necessary date, including the case of a complaint, warranty and guarantee, that is the case of storage for the purpose of proving the terms of the contract at a later date. Thereafter, the data provided will be deleted on the 180th calendar day after the termination of the Agreement.

We cannot link personal information provided in connection with the use of our registration or marketing services, and it is not our goal to identify our visitors.

You do provide voluntarily the personal data to us during registration or contact with the Service Provider, which is why we ask you to pay special attention to the authenticity, correctness and accuracy of your data, because you are responsible for them. Incorrect, inaccurate or incomplete data may be an obstacle to using our services.

If you provide the personal information of someone else, not yours, we assume that you are authorized to do so.

You can withdraw your consent to data management at any time free of charge

o    by cancelling your registration

o    by withdrawing the consent to data management, as well as

o    by withdrawing or requesting the lock of consent to the use or management of any data to be necessarily filled in during the registration.


For technical reasons, we undertake to register the withdrawal of consent with a deadline of 3 days, however, we draw your attention to the fact that we may manage certain data after the withdrawal of consent in order to fulfill our legal obligation or enforce our legitimate interests.

In the event of the use of misleading personal data, or if one of our visitors commits a crime or attacks our Company's system, we will immediately delete or, if necessary, retain their data for the duration of the civil liability or criminal proceedings.

Other data management issues

We are allowed to transfer your data only within the limits set by law, and, in the case of our data processors, we ensure by stipulating contractual terms, that they may not use your personal data for purposes contrary to your consent.

Our company does not transfer data abroad.

The Court, the Public Prosecutor's Office and other authorities (e.g. the Police, the Tax office, The Hungarian National Authority for Data Protection and Freedom of Information may contact our Company for providing information, requesting disclosure or providing documents. In these cases, we must fulfill our obligation to provide information, but only to the extent strictly necessary to serve the purpose of the request.

The contributors and employees of the Service Provider participating in the data management and / or data processing are entitled to get to know your personal data to a previously agreed extent, subject to the obligation of confidentiality.

We will protect your personal information by means of appropriate technical and other measures, furthermore, we ensure the security and availability of the information, and we protect it from unauthorized access, alteration, damage or disclosure and any other unauthorized use.

Visitors’ rights and remedies

In connection with the data management, You have the right to

o    request information,

o    request the correction, modification or supplementation of your personal data managed by us,

o    object to the data management and request cancellation or lock of your data (except for the obligatory data management)

o    seek legal redress


Supervisory Authority: Hungarian National Authority for Data Protection and Freedom of Information

o    Head office: 22/c. Szilágyi Erzsébet fasor, 1125 Budapest

o    Postal address: 1530 Budapest, Pf.: 5.

o    Phone numbeer: +36 (1) 391-1400

o    Fax: +36 (1) 391-1410



At your request, we will provide information on the data managed by us or processed by us or our authorized data processor.

o    on the data

o    on the sources of this data

o    on the aim and legal basis of the data management

o    on its duration, or, if it is not possible, on the aspects of determining this duration

o    on the name, address and data management-related activities of our data processors

o    on the circumstances, effects of the data management incidents, on our measures taken to eliminate or prevent these,

o    on the legal basis and addressee of data transfer if your personal data has been transferred.


We will provide our information as soon as possible, within 28 days from the submission of the request. The information is free of charge unless you have already submitted an information request to us for the same data set in the current year. We will reimburse you for any costs you have already paid if the data has been processed unlawfully or if a request for information has involved correction. We may refuse to provide information only in cases provided by law, by indicating the place of law and by providing information on the possibility of legal redress or recourse to the Authority.

Our company will notify you of the rectification, locking, marking and deletion of personal data, as well as all those to whom the data has previously been transmitted for data processing purposes, unless the failure to notify does not harm your legitimate interests.

If we do not comply with your request for rectification, locking or cancellation, we will provide the reasons for our refusal in writing or, with your consent, electronically within 28 days of receipt of the request and inform you of the possibility of legal redress and recourse to the Authority.

If you object to processing your personal data, we will investigate the objection as soon as possible, within 28 days of the submission of the request, and will inform you in writing of our decision. If we have decided that your objection is well-grounded, we will terminate the processing of data, including further data collection and data transfer, and we lock the data notify of the objection and the action taken all persons to whom the personal data affected by the objection have been previously transmitted and who are required to take action to enforce the right of objection.

We will refuse to comply with your request if we can prove that the processing is justified by compelling legitimate reasons which have preference over your interests, rights and freedoms, or which relate to the submission, enforcement or defence of legal claims. If you do not agree with our decision, or if we miss the deadline, you can go to court within 30 days of the decision being announced or of the last day of the deadline.

Data protection lawsuits fall within the jurisdiction of the tribunal, which may - at the discretion of the affected person - be sued in the court of the affected person’s domicile or residence. A foreign citizen may also make a complaint with the competent supervisory authority competent based on his place of residence.

Please contact our Company in order to consult and resolve the problem as soon as possible before submitting your complaint to the supervisory authority or court.

The Service Provider is obliged to comply with the following legal regulations and recommendations related to data management:

o    Fundamental Law of Hungary Article VI.

o    Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data (GDPR)

o    Act CXII. of 2011. on Informational Self-Determination and the Freedom of Information (Info Act)

o    Act V. of 2013. on the Civil Code

o    Act CVIII. of 2001. – Act on E-commerce (On certain aspects of information society services),

o    Act C. of 2003. on electronic communication

o    Act CLV of 1997. on Consumer Protection

o    Act CLXV of 2013. on Complaints and Public Interest Disclosure

o    Act XLVIII of 2008. on the essential conditions and certain limitations of business advertising activity 

o    the recommendations of "Online Privacy Alliance".



Possibility to change the privacy statement

The data controller reserves the right to unilaterally amend this privacy statement with prior notice to users. After the modification takes effect, the user accepts the contents of the amended privacy statement by using the service with implied behaviour. Information related to data management is disclosed on the website management.



By accessing, you agree to comply with the following terms and conditions, even if you are not a registered user or subscriber to any of the system's services:

 The content on this website is the intellectual property of psychologist Ivett Schrammel and is protected on the whole by copyright, including advertisements. The owner has the exclusive right, under copyright protection, to make any use of the website, in whole or in part, and to authorize each use, whether it is of material or any other form.

Its use includes, in particular, reproduction (recording and copying in any form), distribution, communication to the public, reworking. No part of this site may be reproduced or transmitted in any form or by any means without the prior written permission of the owner.

A link to articles on the website may be freely placed on another website, however, the prior written consent of the owner is required for the publication of any part of the article shown. The article shown can be viewed on the website with a clickable hyperlink. The link can be a text or a graphic link.

If you have any questions, contact me at