Privacy Policy

1. Introduction

COMWIN EUROPE KFT. (“Company”, “we”, “us”, or “our”) is committed to protecting and respecting your privacy.
This Privacy Policy explains how we collect, use, store, and protect personal data when you visit our website https://comwin-europe.com (the “Website”) or contact us.

We process personal data in accordance with:

• Regulation (EU) 2016/679 (General Data Protection Regulation – “GDPR”)
• Applicable Hungarian data protection laws

By using our Website, you acknowledge that you have read and understood this Privacy Policy.

2. Data Controller

The data controller responsible for processing your personal data is:

Company Name: COMWIN EUROPE KFT.
Registered Address: 1054 Budapest, Kálmán Imre utca 1., Hungary
Email: office@comwin-europe.com
Telephone: +36 70 7388288

Contact Person / Data Protection Officer (if appointed):
Name: Cui Fangliang
Email: fc@comwin-europe.com

3. Personal Data We Collect

We may collect and process the following categories of personal data:

3.1 Data You Provide Voluntarily

• Full name
• Company name
• Email address
• Telephone number
• Any information submitted via contact forms, email inquiries, or other communications

3.2 Automatically Collected Data

When you visit our Website, we may automatically collect:

• IP address
• Browser type and version
• Device information
• Operating system
• Referring URLs
• Pages visited and time spent on the Website

3.3 Cookies and Similar Technologies

We use cookies and similar technologies to ensure proper website functionality, analyze traffic, and improve user experience. Details are provided in Section 7.

4. Purpose of Data Processing

We process personal data for the following purposes:

• Responding to inquiries and business communications
• Providing information about our products and services
• Operating, maintaining, and improving our Website
• Website analytics and performance monitoring
• Ensuring security and preventing fraud
• Complying with legal and regulatory obligations

5. Legal Basis for Processing

We process personal data on one or more of the following legal bases under GDPR Article 6:

• Consent – where you have explicitly given consent (e.g., non-essential cookies)
• Contractual necessity – to respond to inquiries or business requests
• Legitimate interests – improving website performance, communication, and security
• Legal obligation – where processing is required by law

6. Data Sharing and Recipients

We do not sell personal data.

We may share personal data only with:

• IT and website hosting service providers
• Analytics and security service providers
• Professional advisers (legal, accounting)
• Public authorities where required by law

All third parties process data only on our instructions and are bound by confidentiality and data protection obligations.

7. Cookies and Third-Party Services

7.1 Cookies

Our Website uses:

• Essential cookies – required for website functionality
• Analytical cookies – to analyze traffic and usage patterns
• Functional cookies – to enhance user experience

Non-essential cookies are used only with your consent via a cookie banner.

You can manage or withdraw your cookie consent at any time through your browser settings or the cookie management tool on our Website.

7.2 Third-Party Services

We may use third-party services such as:

• Website analytics tools
• Hosting and security services

These providers may process limited technical data (e.g., IP address) on our behalf and in compliance with GDPR.

8. International Data Transfers

If personal data is transferred outside the European Union or European Economic Area (EU/EEA), we ensure appropriate safeguards, such as:

• Standard Contractual Clauses approved by the European Commission
• Transfers to countries recognized as providing adequate protection

9. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law.

Typical retention periods include:

• Contact inquiries: up to 3 years
• Legal or accounting records: as required by law

10. Data Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure.

11. Your Rights Under GDPR

You have the following rights regarding your personal data:

• Right of access
• Right to rectification
• Right to erasure (“right to be forgotten”)
• Right to restriction of processing
• Right to object to processing
• Right to data portability
• Right to withdraw consent at any time

To exercise your rights, please contact us at:
Email: office@comwin-europe.com

12. Right to Lodge a Complaint

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the competent supervisory authority, in particular:

Hungarian National Authority for Data Protection and Freedom of Information (NAIH)

13. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time.
The updated version will be published on this page with a revised “Last Updated” date.

14. Contact Us

If you have any questions about this Privacy Policy or our data processing practices, please contact us:

COMWIN EUROPE KFT.
Address: 1054 Budapest, Kálmán Imre utca 1., Hungary
Email: office@comwin-europe.com
Telephone: +36 70 7388288