Privacy Policy

General Terms
This “Privacy Policy” relates to how you use our website, www.modulux.hu (hereinafter also referred to as the/this “Website”) and any sub-domains and/or services that may be attached to it and any links we provide to other websites.
The information available on this Website is not intended to provide professional advice and should not be relied upon as such. Viewers are advised to obtain appropriate professional advice where necessary. This Website contains expressions of opinion, information, and material about current issues affecting the crypto-economic environment and financial markets that are subject to change without notice. G4C Projektszervező Kft. (hereinafter referred to as “MODULUX”) and its employees shall not be liable for any loss or damage arising as a result of your use of or reliance on such information. Your access or use of this Website constitutes your acceptance of any changes. While we apply every effort to ensure the accuracy of the information provided on this Website, neither MODULUX nor its staff takes any responsibility for the accuracy of the information provided, and the use of such information is at your sole discretion and risk.
All of the products and services provided by MODULUX are subject to the legislation in force in Hungary. Decisions to subscribe to any investment product mentioned on this Website should be made only on the basis of the information contained in the product prospectus and/or brochure and/or White paper. Nothing contained on this Website constitutes investment, legal, tax or other advice. You should obtain relevant and specific professional advice before making any investment decision. All products and services offered on this Website are subject to the general and specific terms and conditions of use, printed copies of which may be obtained from any branch of MODULUX which should be read by anybody who intends to subscribe to them. Persons accessing these pages from jurisdictions other than Switzerland should be aware that their local legislation may restrict their eligibility to some or all of the products and services promoted on this Website.

Data Handling
Personal Data
“Personal Data” is data that identifies an individual, including but not limited to
• Name
• Email address
• Postal address
• Contact number
• Date of birth and place
• ID number
• Passport number
• Photographic, telephonic, and other such electronic recordings
• your IP address and unique mobile device identification numbers (such as device ID, advertising ID, MAC address)
• data about your device, such as manufacturer, operating system, CPU, RAM, browser type and language;
• broad location data;
• data we collect with cookies and similar technologies;
• details of orders;
• data to fight fraud and data required by anti-money-laundering provisions;
• payment data (such as to verify payment);
• data for advertising and analytics purposes, so we can provide you a better service;
• your messages to the Website (such as chat logs and user support tickets) any feedback you submitted about your experience with us;
• other data you choose to give us.

The data we collect
We collect and process your personal data mainly to provide you with access
to our services and products, and to help us improve same.
We may collect personal data about you from different sources, data including the following:
• Data given to us directly by yourself
• Data collected automatically when you use our Website,
• Data collected from other publicly available sources

Data we share
Your personal data may be disclosed to or exchanged with all employees of MODULUX and its subsidiaries, and their consultants, associates, agents and processors acting on our behalf. We do not share personal data with companies, organisations and individuals outside of MODULUX unless one of the following circumstances applies:
• With your consent - We will share personal data with companies, organisations or individuals outside of MODULUX when we have your consent to do so.
• For external processing - We provide personal data to trusted businesses or persons to whom we may outsource certain functions from time to time such as other controllers, enabling/improving the service such a relevant Affiliates, payment agents, banks or other financial institutions, in order to provide you with the products or services you have requested, and in compliance with our Privacy Notice and any other appropriate confidentiality and security measures
• For legal reasons - We will share personal data with companies, organisations or individuals outside of MODULUX if we have a good-faith belief that access, use, preservation or disclosure of the data is reasonably necessary to:
• meet any applicable law, regulation, legal process or enforceable governmental request
• enforce applicable terms of service, including investigation of potential violations
• detect, prevent, or otherwise address fraud
• protect against harm to the rights, property or safety of MODULUX, our users or the public as required or permitted by law.
We may share non-personally identifiable data publicly. For example, we may share data publicly to show trends to about the general use of our services.
Scam emails
While MODULUX may from time to time send emails to its current and prospective customers, we will never ask you to disclose any of your personal or security details by email. Where possible, we will include certain basic information about you in any email correspondence in order to confirm the genuineness thereof. In the event that you receive emails that purport to originate from MODULUX asking you to disclose all or some of your security information, you are strongly advised not to disclose any such information or to click on any links included in such emails. If you receive an email from any person purporting to be from or connected with MODULUX and asking you to ‘verify your account’, ‘confirm your sign-in details’, or a similarly worded request, this would certainly be a scam and you are strongly advised not to follow any such instructions/requests. If you are ever in doubt about whether an email is genuine, do not click on its links or open any attachments. Still, please forward it to us at info@modulux.hu While we will not be able to reply individually, kindly be assured that we do investigate every email to make sure that the appropriate authorities are informed of any misuse of the internet and that the necessary action is taken whenever needed.
GDPR
Certain pages of the website which provide specific services may request personal data. In all cases, this personal data will only be processed for the purpose of delivering the service, in accordance with applicable local and EU legislation on data protection including the 'General Data Protection Regulation' - GDPR, Regulation (EU) 2016/679. This Privacy Policy covers only the MODULUX website www.MODULUXcircle.com. This privacy statement does not cover any links within the website to other websites.
RETENTION
We only process Personal Data for as long as it is necessary, especially in relation to the services and/or handling complaints. When the purpose of the data processing has been fulfilled, your Personal Data will be deleted in accordance with our data retention policy, unless we are legally required to retain it. In relation to the legal grounds of processing as mentioned above, Personal Data may be stored for the following periods of time:

in the event when data are necessary for the performance of the contract, for the duration of the contract and until the expiration of the claims resulting from this contract;
if the basis for data processing is the legitimate interest of the controller, until you file an effective objection;
for tax, accounting, anti-money-laundering purposes, to the extent and for a period of time compliant with the applicable law;
if Personal Data is being processed based on the consent you gave - to the moment of withdrawal, restriction or other action on your part restricting such consent.

COMPLAINTS
To exercise your rights or in case of any questions in relation to Personal Data processing, you can use the following contact information:
e-mail: info@modulux.hu
Your written request may be required for security reasons. We may decline the request if there are reasonable grounds to believe that it is fraudulent, unfeasible, or may jeopardize the privacy of others.
If you think that the way we process your personal information does not comply with applicable data protection laws, you have the right to lodge a complaint with a supervisory authority - The Federal Data Protection and Information Commissioner (FDPIC).
Information from Third Parties
This Website may include reports, analysis or information from third parties. MODULUX accepts no responsibility or liability for the accuracy of such material. No third party is permitted to link to this Website or any part of it without obtaining the prior written consent of the duly authorized representative/s of MODULUX. It reserves the right to modify, suspend or discontinue, temporarily or permanently, this Website or any part of it or any service that may be provided through it, with or without notice, at any time. You agree that MODULUX shall not be liable to you or to any third party for any such modification, suspension or discontinuance of this Website.
Industrial Property and Copyright
This Website is the property of MODULUX. The copyrights and operating and reproduction rights of this Website, its pages, screens, the information they contain, their appearance and design and the hyperlinks from it to other websites of any company belonging to the same group of companies of which MODULUX forms part are the exclusive property of MODULUX, unless otherwise specified. All the names, designs and/or logotypes which comprise this website are duly registered trademarks. Any undue use thereof by a person other than their legitimate owner may be prosecuted in accordance with current legislation. The copyrights and trademark rights of third parties are suitably highlighted and must be respected by anyone accessing this website. The contents may be downloaded and any page on this Website copied or printed for personal and private use only. It is prohibited to reproduce, transmit, modify or delete the information, content or notices on this Website without the prior written authorization of MODULUX.
Rights and Responsibility of Users
Your responsibility is to ensure that all Personal Data submitted to us are correct. We may maintain the accuracy and completeness of Personal Data and keep the data up to date.
To the extent required by the applicable law, you may have:
right to access your Personal Data, including receiving a copy thereof;
right of rectification of your Personal Data;
right of erasure (only in cases foreseen by GDPR) of your Personal Data;
right to object or restrict the processing of Personal Data;
right to withdraw your consent - applicable to the situations when your Personal Data are processed based on your consent. Remember that withdrawal of your consent does not impact on the lawfulness of processing before such withdrawal;
right to Personal Data portability, i.e. to receive your Personal Data from us in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, provided that the Personal Data are processed based on consent or in order to perform our services.
Cookies
Cookies are small pieces of data that the site transfers to the user’s computer hard drive when the user visits the website. We use cookies to facilitate and improve your experience of our website and to improve our products and services. This website makes limited use of cookies, and consequently, for any further information, you are being guided to visit our Cookies Policy.
You can manage or delete cookies based on your preferences. You can clear all the cookies stored on your device, while most of the web browsers provide the option of blocking cookies. However, by doing so, you have to change the user settings every time you visit our website. Find out how to manage cookies settings in your browser or on its dedicated website
Governing Law
This Privacy Policy is governed by and construed in accordance with the laws of Switzerland and relevant EU legislation. In the event of any conflict between this Policy and applicable laws and regulations, the latter shall prevail.
Feedback
Any comments or suggestions that you may have, and which may contribute to a better quality of service will be welcome and much appreciated.
Validity
This Policy shall be deemed effective as of July 2024 and valid until the upcoming modification. The latest version is always available on our website.
Company Information
G4C Projektszervező Kft. registered in Hungary (registration number CHE-460.051.983) with its registered office: HU-1055 Budapest, Stollár Béla str. 18.