Transparency is important to us, so in the policy below we present how we use and protect your personal data, as well as how you can exercise your related rights in connection with our services.


Our company name: digitalismunkatá Limited Liability Company (head office: 1091 Budapest, Üllői út 55.; company registration number: 01-09-389611; "digitalismunkatá")

Our website:

Our e-mail address:

Our phone number: +36704173926


Personal data: any information relating to an identified or identifiable natural person (the so-called "concerned"). A person is considered identifiable if the given personal data can be clearly linked to him, either directly or indirectly (ie in combination with other data). In this case, you are the person concerned.

Application: the SunMoney360 mobile application you downloaded.

Data management: any operation that we, as a Data Controller, perform on your personal data, e.g. their collection, storage, or connection with other data is therefore everything that happens with your Personal Data in connection with the use of the Application.


And when you read about the "legal basis" of data management, it is about "on what basis" (e.g. your consent, fulfillment of a contract with you, etc.) we process your Personal Data among those defined in the relevant legislation. The legislation lists several such possible legal grounds, and as a Data Controller it is our task to select and apply the appropriate one.


Data Controller: the person who determines the purpose and means of Data Management. In other words, he is the one who decides what and how to do with your Personal Data. In this case, the Data Controller is digitalismunkatá, i.e. we are.


Data processor: the person who processes data on behalf of and based on the instructions of the Data Controller. It does not decide on them independently, it follows the Data Controller's instructions in everything, essentially it provides technical assistance to the Data Controller.


Profiling: any form of automated (i.e. in a digital system, not paper-based) processing of Personal Data, during which Personal Data is used to draw conclusions about the concerned or to evaluate certain characteristics. Profiling can now be found in many areas of life, this is what happens, for example, when the application you use for listening to music tries to "figure out" what else you might like based on the tracks you have listened to before and recommends new tracks. A video sharing portal also throws up new offers based on the videos you have previously watched. In this policy, you can find out what Profiling means for us, and what is needed to be able to do it legally.


Data management is only transparent if it is clear to the concerned why it is necessary. Therefore, we briefly present how the Application works:

The Application counts your steps collected by your phone and shows you how many steps you have taken per day since you first downloaded the Application. It does this in such a way that your daily performances relative to each other can be easily compared.

It also shows the total number of steps taken by all users of the Application.

The application also converts the number of steps into points based on a specific algorithm, which may change over time.

The user of the Application can share the Application's link to the application stores with friends by scanning a QR code, via e-mail, SMS or other electronic communication channels.


In this chapter, we present all the cases in which we manage your Personal Data. You can see what Personal Data we process, for what purpose, the legal basis for Data Management and how long we store your Personal Data.

4.1 Data Management required for the use of the Application

What Personal Data do we process?

Your name, email address and the following logged information of your phone after installing the Application and registering:

•           Your number of steps broken down daily;

Why do we process Personal Data?

We need your email address so that we can confirm your registration in the Application and thereby create an agreement between us regarding the services provided in the Application. In addition, we will send you information about the operation of the Application and our contractual terms and conditions by email. We need your name so that we can communicate with you smoothly even while using the Application (or, if you have expressly consented to this, we can deliver our marketing messages to you.

These Personal Data are therefore necessary to be able to use the main function of the Application.

On what legal basis do we process your Personal Data?

When you accept the General Terms and Conditions during registration in the Application, an agreement is created between us, based on which we provide you with the service available in the Application. The legal basis for our data management is the fulfilment of this agreement.

How long do we process your Personal Data?

We will keep your e-mail address and name as long as you use the Application. According to our General Terms and Conditions, if you do not use the Application for 24 months, we will delete this data, unless you contact us with a complaint or question in the meantime, in which case we need them to handle the complaint or question.

Your other personal data mentioned above will be kept for a period of 3 (three) years from the date of your last use of the Application, in order to be able to fully investigate and respond to any complaint you may have (for details, see point 4.3), and subsequently we can also prove it. We will not use your data for any other purpose, unless you have expressly consented to the use for marketing purposes.

4.2 Marketing, sending customized offers

What personal data do we process?

Depending on your consent, we use your name and email address to send you marketing messages, e.g. newsletter, offers about our new services, advertisements, etc.

Why do we process your Personal Data?

We would like to stay in touch with you so that we can inform you about our current offers in the future.

We are also in contact with other companies who also want to send you personalized offers and newsletters based on Profile Creation. These external partners of ours will not receive your Personal Data, we will also send you their offers (possibly with the help of our marketing service provider), so our partners will not contact you directly!

On what legal basis do we process your Personal Data?

You decide who and what does with your Personal Data. You will not receive unsolicited advertising from us, we only send any marketing content based on your prior consent.

According to your choice, you can give consent with various contents, these are as follows:

•           You can agree to send simple (ie not personalized) marketing content. In this case, you will not receive customized offers, but you will receive general marketing materials (e.g. a newsletter about our services, information about a new service).

•           You can contribute that we use your Personal Data listed above in point 4.2 for the purpose of sending you customized offers based on your user habits that we believe may be particularly interesting for you.

•           If you want and consent, you can receive this kind of content not only about us, but also about our external partners and their products and services.

You can withdraw your consent at any time by clicking on the "Unsubscribe" button in the "Settings" menu of the Application or at the bottom of the marketing messages sent by email, in this case we will terminate the Data Management for marketing purposes and you will no longer receive such messages.

How long do we process your Personal Data?

We process your data until you withdraw your consent.

4.3 Handling complaints, answering questions, exercising concerned rights

What personal data do we process?

If you have questions, comments, or complaints about the Application, you can contact us at any time. In order to answer your question and handle your complaint, we need your name and email address, as well as a detailed description of the question or complaint. In order to fully investigate your complaint and answer your question, depending on the content of the complaint or question, we may need all of your data specified in point 4.1.

The same is true in the case when you want to exercise one of your concerned rights according to the GDPR, e.g. you request information about data management (you can read about your rights in point 7).

If we have to record the complaint due to our legal obligation, we can only do this if, in addition to the above, we also process the following personal data:

your name, address, place, time, and method of submitting the complaint, the list of documents, documents and other evidence presented by you in connection with the complaint, our statement on our position regarding your complaint, the unique identification number of the complaint, your response to the minutes.

Why do we process your Personal Data?

So that we can answer your questions, comments, and complaints, investigate them if necessary, and successfully represent our position in the event of a legal dispute. This is only possible if we know the content of the question or complaint, or if we can contact you, and we also have the data necessary to investigate the merits of the complaint and to subsequently support our position.

In some cases, we have a legal obligation to handle and investigate the complaint, and record it (Act CLV of 1997 on consumer protection).

On what legal basis do we process your Personal Data?

If you have questions or comments regarding the use of the Application or our services, we will process your Personal Data above in order to fulfil the agreement between us.

In the event of a complaint or the exercise of a concerned right under the GDPR, the legal basis for our Data Management is our legitimate interest in fulfilling our legal obligations in the GDPR and in consumer protection legislation regarding the provision of the concerned rights and the investigation and remedy of complaints, in addition to in the event of a possible legal dispute, we can verify the communication between us and protect our legal position.

If we have to record the complaint because it is required by the Consumer Protection Act referred to above, we will process your Personal Data contained in the report in order to fulfil our legal obligations.

How long do we process your Personal Data?

For a period of 5 (five) years from the time the question or comment was answered, or from the end of the communication related to the exercise of the concerned right, in order to be able to verify the communication between us and protect our legal position in the event of a possible later legal dispute.

If we have to take a record, we will keep it for 3 (three) years in accordance with the provisions of the Consumer Protection Act.


Our basic principle is to treat your Personal Data confidentially. In some cases, however, it may be necessary to share your Personal Data with other organizations. In the following, we list these cases and the recipient organizations.


5.1 Amazon Web Services EMEA SARL (head office: 38 Avenue John F. Kennedy. L-1885, Luxembourg)

Amazon operates the servers required to operate the Application and our IT systems that serve it. All Personal Data provided by you is stored on these servers.

Amazon only cooperates with us in the storage of your Personal Data, it has neither the purpose nor the interest in knowing their actual content, nor does it have the legal opportunity to do so.

The server park we use is located in Frankfurt, Germany, so your Personal Data will never leave the European Union. The data protection and data security rules of the European Union guarantee that your Personal Data is safe.


5.2 Google LLC (head office: Googleplex, Mountain View, California, U.S.)

Google helps us develop the App through Firebase. As part of this, Google collects statistical and other Personal data generated during the use of the Application about how you use it (e.g. how much time you spent on a specific screen, where you clicked from, how long you closed the Application after). Such Personal Data is necessary because any application can only be developed effectively if we are aware of how users actually use it in practice.

Google draws certain conclusions from this data that can be used to improve the Application and sends them to us.

You can read about how Google protects your data here:

Google only sends us conclusions drawn from the collected data, i.e. we will not be able to identify you based on them. We continue to develop the Application based on this policy.


5.3 Active Campaign (head office: 1 N Dearborn St, Chicago, IL 60602, United States)


We use the Active Campaign service to manage user data and activity, our marketing campaigns and our websites.

5.4 Limited Liability Company (headquarters: 1036 Budapest, Bécsi út 52. Building I. 19.) Kft. is our software development partner who is responsible for the development of the mobile app and the website as well as for conducting our marketing campaigns.


5.5 Our legal advisors, courts, authorities

If we have to defend our position in any official procedure or legal dispute related to the Application, it may happen that we have to hand over the Personal data we manage to our legal advisor or to the court or authority conducting the given procedure.

If we receive a relevant request based on a specific legal provision in the procedure of an authority, depending on the circumstances, it may be necessary to hand over files containing Personal Data to the authority, as we are obliged to cooperate with the authority.


Here we describe what rights you have in connection with the management of your Personal Data. The exercise of rights is always free of charge.

If you would like to exercise any of your rights, send us an email to the email address at the beginning of the policy, describing your request in detail.

Please endeavour to share with us only such Personal Data as is absolutely necessary to process the request when describing your request.

All questions, complaints and inquiries will be answered within 25 days of receipt.

6.1 Request for information (right of access)

You can request information about the management of your personal data from us at any time. Your request may cover the range of personal data processed, their source, the purpose, legal basis and duration of Data Management, the name and address of possible Data Processors, activities related to Data Management and your rights in connection with Data Management. And in the case of data transfer, to whom and for what purpose your Personal data was received or will be received (provided that the transfer of this information to us is permitted by law). So for everything that happens with your Personal Data.

As a general rule, we provide the information in the reply email sent to the email you sent.

We can consider your request for information as authentic if it comes from the e-mail address registered by us. If this is not what you are sending the inquiry for, then - in order to protect your personal data - we will not be able to answer it, since we cannot know who the inquiry actually came from.

6.2 Correction

You can request the correction or modification of your previously provided personal data at any time. If your contact email address has changed, we specifically ask that you let us know if possible!

6.3 Deletion ("right to be forgotten")

We will delete your Personal Data without delay if:

·         we no longer need the given Personal Data for the purpose for which they were collected;

·         it is a case of Data Processing that was based on your consent, but you withdrew this consent and the Data Processing has no other legal basis (in our case, this covers email communication for marketing purposes);

·         it is a case of Data Processing that was based on our legitimate interest, but you object to the Data Processing, and we have no overriding legitimate reason for data processing (we will consider the latter in each case);

·         if, despite all our efforts and best intentions, illegal Data Processing has taken place;

·         we are required to delete it by a rule prescribed by European Union or Hungarian law.

We would like to draw your attention to the fact that there may be cases when we are not obliged to delete your Personal Data, for example if Data Management is necessary for the submission, enforcement and protection of our legal claims.

6.4 Limitation

The limitation of Data Management means that we cannot process the Personal data affected by the limitation except for storage, or we can only process it in the scope to which you have consented.

In the following cases, you can request the restriction of the processing of your personal data:

·         you dispute the accuracy of your Personal Data that we manage - in this case, the limitation applies to the period that allows us to check the accuracy of your Personal Data;

·         the Data Management was illegal, but you object to the deletion of your Personal Data and instead request the restriction of their use;

·         we no longer need the Personal Data, but you request it to present, enforce or defend your legal claims; obsession

·         you objected to the Data Management - in this case, the restriction applies to the period until it is established whether there is a legal reason or interest on our part that overrides your objection. We will consider this in each case.

Even in the absence of consent, we can process the Personal data that is necessary for the submission, enforcement or defense of legal claims. We will inform you in advance about the lifting of restrictions on Data Management. If we have transferred the Personal Data subject to the restriction to another person (e.g. to our Data Processors listed above), we will immediately inform these persons of the restriction of Data Management, provided that it is not impossible or does not require a disproportionate effort from us. We will inform you about these recipients upon your request.

6.5 Objection

If the legal basis of Data Processing is our legitimate interest, you can object to this Data Processing. We are not obliged to accept the protest if we prove that

·         Data processing is justified by compelling legitimate reasons that take priority over your interests, rights and freedoms, or

·         Data Management is related to the submission, enforcement or protection of our legal claims.

At the same time, if none of the above is fulfilled, in the event of your objection, we will delete your Personal Data affected by it immediately, and we will inform you in advance about the consequences of the deletion.

6.6 Right to data portability

In practice, this right means that, if you request, we will send you all the data processed about you in a commonly used, readable format. In our case, this will mean an email or a pdf file attached to it.

If you request, you also have the option to transfer your Personal Data that we manage to another data controller you have indicated.

6.7 Right to complain, right to legal remedy

If you believe that we have violated the data protection laws by handling your Personal Data, you can file a complaint with the competent data protection supervisory authority of your usual place of residence, workplace or the Member State where the suspected violation occurred. In Hungary, complaints can be submitted to the National Data Protection and Freedom of Information Authority ("NAIH"). NAIH contact details:


Address: 1055 Budapest, Falk Miksa utca 9-11.

Postal address: 1374 Budapest, Pf.: 603.

Telephone: +36-1-391-1400

Fax: +36-1-391-1410


In the event of a violation of rights, regardless of your right to file a complaint, you can also go to court. You have the right to go to court against the legally binding decision of the supervisory authority regarding you. You are also entitled to a judicial remedy if the supervisory authority does not deal with your complaint or does not inform you within three months about the procedural developments related to your submitted complaint or its result.

But before you go to the authorities or the court, please write to our email address highlighted at the beginning of the policy. We will do our best to handle your complaint in a reassuring manner and answer your questions!

* * *