Regarding the data processing activities of minervaintezet.hu and its public opinion research operations,
in accordance with the General Data Protection Regulation (GDPR).
Last modified: 24 June 2025
Previous version: 8 May 2025 – 24 June 2025.
This privacy policy summarises the data processing activities carried out by Minerva Intézet Nonprofit Kft. (registered address: 1115 Budapest, Bartók Béla út 105-113. Building 1/B, 4th floor; company registration number: Cg.01-09-941123) as data controller (hereinafter: "Controller") in relation to persons visiting the website www.minervaintezet.hu (hereinafter: "Website") and those using the Website and the Controller's services, with particular regard to telephone opinion polls and their publication.
Please read this privacy policy carefully and, if you have any questions regarding the processing of your personal data, do not hesitate to contact us using one of the contact details provided below.
Data Controller: Minerva Intézet Nonprofit Kft.
Registered address: 1115 Budapest, Bartók Béla út 105-113. Building 1/B, 4th floor
Postal address: 1115 Budapest, Bartók Béla út 105-113. Building 1/B, 4th floor
Electronic contact: info@minervaintezet.hu
The Controller, as an independent research provider, conducts AI-assisted telephone opinion polls (hereinafter: System). The System collects responses anonymously, objectively, and in real time via audio recordings during automated and random telephone calls, then records and interprets responses in writing by machine — without human intervention — which activity primarily serves opinion research, statistical, and social research purposes. The System does not link responses to specific individuals, however it may be possible to identify specific individuals from the responses. The Controller applies the results of its opinion polls in areas including political opinion research, market research/customer feedback, measuring the effectiveness of advertising campaigns, and customer satisfaction surveys, in some cases on the basis of a specific commission. The analysis, evaluation, and summary of results, as well as the drawing of conclusions, are not automated and involve human intervention; the machine-based nature of the System is not used for this purpose. The Controller publishes its research and results anonymously — in a form that does not allow identification of the subjects — on its website, which anyone may freely analyse, process, and verify.
| Name of data processing | Purpose of data processing | Legal basis for data processing | Scope of data processed | Duration of data processing | Recipients with whom data is shared | Measures taken to protect the data |
|---|---|---|---|---|---|---|
| Contact and responding to enquiries | The purpose of the data processing is for our company to contact you if you get in touch via our Website, at the info@minervaintezet.hu email address, or in any other way. The purpose of processing your data also includes answering your questions and discussing any needs, complaints, or requests you may raise. | Processing based on your consent (GDPR Art. 6(1)(a)). By contacting us or sending us a message, you consent to the processing of your personal data. | Name, contact email address and phone number, stated needs | Our company processes the data until your question has been answered or your request has been resolved to your satisfaction. After that, the data is deleted. | As a general rule, we do not share your personal data with others in connection with contacting us. | Messages sent to us are accessed via a password-protected computer. Access to our email system is password-protected. Only employees with the appropriate role have access to the messages. We only use software for which we consider your data security to be guaranteed. |
| Collection and generation of phone numbers | We may collect existing or non-existing phone numbers via a random number generator or from public sources for the purpose of contact during opinion polls. In some cases, we receive phone numbers from our partner or obtain them from other lawful sources. These existing or non-existing phone numbers are cross-checked against the NMHH (National Media and Infocommunications Authority) public number range list and the so-called Robinson list. Calls are initiated to the phone numbers verified in this way. | The Controller's legitimate interest in achieving its objectives, GDPR Art. 6(1)(f) | Phone number | Until the end of the opinion poll, i.e. until evaluation | Phone numbers are transferred to our partner operating the System (Wozavez Consulting Zrt.), or the data is stored directly on the server of Wozavez Consulting Zrt. | Phone numbers are not linked to evaluation results or data contained therein. Some phone numbers are randomly generated; the Controller does not record the name of the person authorised to use the phone number. Only authorised persons have access to the phone numbers. The Controller has concluded a data processing agreement with Wozavez Consulting Zrt. in accordance with GDPR Art. 28(3). |
| Initiating telephone calls and making contact for the purpose of conducting opinion polls | Initiating random calls via the System for the purpose of conducting the opinion poll, contacting subjects, enabling participation and response to the survey, and documenting consent and callback requests | The Controller's legitimate interest in achieving its objectives, GDPR Art. 6(1)(f) | Phone number, content of consent declaration, machine transcript of the conversation, technical metadata (e.g. time and duration of call) | Until the end of the opinion poll, i.e. until evaluation. If you do not provide consent to the processing of the audio recording, we will only retain your refusal statement for 30 days from the recording. | Personal data is transferred to our partner operating the System (Wozavez Consulting Zrt.). Call metadata may be shared with Opennetworks Kft., which provides the calling number. | Phone numbers are not linked to the evaluation results or data contained therein. Phone numbers are randomly generated; the Controller does not record the name of the person authorised to use the phone number. Only authorised persons have access to the phone numbers. The Controller has concluded a data processing agreement with Wozavez Consulting Zrt. in accordance with GDPR Art. 28(3). |
| Conducting and recording telephone calls (audio), transcribing, storing transcripts, conducting the opinion poll by telephone | Asking the questions forming the subject of the opinion poll, answering questions posed by the subject by machine, summarising and transcribing responses, collecting and recording research results in writing, and further developing the System. The purpose of recording audio is also to verify the accuracy of machine transcripts, thereby further developing the system, continuously training it on voice data to improve the fluency of communication, as well as protecting the Controller's rights and legitimate interests by enabling recordings to be listened to in the event of a dispute and used as evidence in the Controller's own defence. | Processing based on your consent (GDPR Art. 6(1)(a); for special category data, GDPR Art. 9(2)(a)). At the beginning of the telephone call, we request your express consent to the processing of data described in this row. | Caller's gender, year of birth, postcode of place of residence, content of the telephone conversation, content of opinion and machine transcript, level of education, technical metadata (e.g. time and duration of call, response timestamps) | Until consent is withdrawn, but audio recordings for at most 30 days from the date of recording, and transcripts for at most 5 years from the date of preparation. In the absence of consent, the Controller immediately deletes the data. | Personal data is transferred to our partner operating the System (Wozavez Consulting Zrt.) and to the partner commissioned to carry out transcription (SpeechTex Kft.). | During telephone calls, subjects receive appropriate prior notice regarding the processing of personal data. Only data strictly necessary for the research to yield results is processed. Data collected during the research is in no way linked to the phone number or the identity of the caller. As a general rule, participation is anonymous. During recording, responses are stored in encrypted, anonymous form with restricted access. |
| Requesting a callback | Enabling the option of a callback, thereby increasing the effectiveness of the opinion poll | Processing based on your consent (GDPR Art. 6(1)(a)) | Phone number, time of callback | Until the callback has taken place | Personal data is transferred to our partner operating the System (Wozavez Consulting Zrt.). Call metadata may be shared with Opennetworks Kft., which provides the calling number. | During telephone calls, subjects receive appropriate prior notice regarding the processing of personal data. In the case of a callback, only the phone number is recorded. Data collected during the research is not linked to the phone number, the identity, or the name of the caller. As a general rule, participation is anonymous. During recording, responses are stored in encrypted, anonymous form with restricted access. |
| Maintaining a prohibition ("Robinson") list | To ensure that the Controller only contacts persons who have not objected to the opinion poll, and for the purpose of documenting objections and deletions from the call list, and proving these after the fact. | Processing based on your consent (GDPR Art. 6(1)(a)) | Phone number (of persons who do not wish to participate in the research) | Until consent is withdrawn | No data is transferred | Only authorised persons have access to the list. The list records only phone numbers, separately from all other records, and is not linked to any other identifying data of the subjects. The register is stored in encrypted, anonymous form using server services and with data backup. |
| Evaluation, categorisation, and publication of opinion poll results, posting on www.minervaintezet.hu, and transfer to partners and clients | Publication of research results for the purpose of analysis, assessment, drawing conclusions, fulfilment of the Controller's contract with its clients, and informing the public | The Controller's legitimate interest in achieving its objectives, GDPR Art. 6(1)(f) | Gender, age, settlement type, content of opinion, level of education (typically anonymous, categorised data) | For 5 years following publication | Research results and thus data are published anonymously on www.minervaintezet.hu or transferred to a commissioning partner | The evaluation of opinion polls always takes place anonymously; results and responses are not linked to the identity of the respondent. |
| Including respondents in further research | To enable the Controller to contact the respondent — if they consent — by phone at a later date in connection with another study and ask for their opinion again. | Processing based on your consent (GDPR Art. 6(1)(a)) | Phone number, demographic group (gender, geographical location, age group) | Until consent is withdrawn, but at most until the Controller ceases operations | No data is transferred | The Controller stores the data on a secure server. The Controller keeps consents up to date and ensures they can be withdrawn. |
We share your personal data with Statistical Products Hungary Kft. due to common ownership and for the purpose of efficient cost and workforce management, to the extent that employees of the said company participate in the development of the System and thus in the processing of data.
In some cases, our company acts not as a data controller but as a so-called data processor in the processing of your personal data. This generally occurs when our company acts on behalf of a regular or occasional partner and processes personal data in their name, since we carry out the opinion poll according to the instructions of our partner/client and transfer the results to the partner. In such cases, our partner, not our company, is considered the data controller, and it is possible that your requests will be handled not by our company but by our partner. However, in such cases you may still contact us directly using the contact details provided in Section 1, and we will forward the request to our partner as appropriate, who will assess and handle it.
The data made available to us may, after evaluation and analysis, be shared with the public anonymously for further research and educational purposes by uploading to www.minervaintezet.hu.
During the opinion poll, we contact you via a random telephone call generated by the System. The storage of phone numbers and research results in the System, the operation of the System, as well as hosting and software services are provided by our partner Wozavez Consulting Zrt., while SpeechTex Kft. assists in the preparation of transcripts, so your personal data is also shared with these partners.
The phone number used by the Controller, from which calls are made, is provided by Opennetworks Kft. Opennetworks Kft. becomes aware of the metadata of the calls.
The hosting of the www.minervaintezet.hu website is provided by Rackforest, meaning that data stored on the website is stored on the provider's server. Additionally, we use Google's servers, located in Austria (Vienna), to store personal data.
The content of transcripts may be shared with OpenAI Ireland Limited for the purpose of having the provider categorise and interpret free-text responses; however, the data in the transcripts is anonymous and cannot be linked to the identity of the respondent by the provider.
Beyond those listed above, the personal data made available to us may be transferred to the competent authority, court, or applicant in the event of an official or judicial request, when reasonably necessary to protect our rights, those of our partners, or those of others, or for the purpose of fulfilling a legal obligation. If this occurs, we will notify you promptly, unless such notification is prohibited by law or an official decision.
The results of the research are published and transferred to third parties in a form that does not enable third parties to identify the subjects.
In addition to what is set out in Section 2, we take the following general measures to protect your data:
The Controller has assessed in a data protection impact assessment whether the technology used by the System (artificial intelligence) poses a high risk to the rights and freedoms of natural persons, and has concluded that the System in its current form is capable of not posing a high risk to the rights and freedoms of subjects, in particular due to the minimally invasive nature of AI-conducted interactions and the lack of subject identifiability.
In order to guarantee an appropriate level of data security, we have assessed the risks associated with our data processing activities and evaluated them in terms of the severity of the risks and the likelihood of their occurrence across various criteria.
In the operation of our IT systems, we use appropriate access management, internal organisational, and technical measures to ensure that your data does not fall into the hands of unauthorised persons and that unauthorised persons cannot delete, extract, or modify the data. We enforce data protection and data security requirements on our partners as well.
The System performs encryption, personal data is kept in separate records, and it is not the Controller's intention to identify the subject at any point during the process. The System performs data backups and data can be restored in the event of loss. Only authorised persons have access to the System, and we continuously monitor this access management.
Internet communication between our website and the visitor is encrypted end-to-end via https (http+ssl) protocol. We apply password protection to our computers and equip our IT devices with firewall protection. Our computers and IT equipment are protected with appropriate passwords and antivirus software; password updates are periodically enforced, and data storage devices are destroyed according to a dedicated decommissioning protocol.
You are entitled at any time to request information by post, email, or telephone via the contact details provided in this notice, about the personal data we process relating to you.
Upon request, we will inform you of:
The information will be provided in writing within one month of the submission of the request, either on paper or electronically, depending on the form of the information request.
You may at any time object to the processing of your personal data. We will examine the objection within the shortest possible time of its submission, but no later than within one month, make a decision on its merits, and inform you of the decision.
You are entitled at any time to request the deletion of personal data we process or the rectification of incorrectly recorded personal data.
In addition, we will restrict your personal data if you request this, or if, based on the information available to us, it is likely that deletion would harm your legitimate interests. We will process the restricted personal data for as long as the purpose of the data processing or the legitimate interest that precluded deletion persists.
You may request via the contact details provided in this notice that we restrict the processing of your personal data (with a clear indication of the restricted nature of the processing and ensuring it is handled separately from other data) if:
Via the contact details provided in this notice, you are entitled to receive the personal data relating to you that you have provided to our company in a structured, commonly used, machine-readable format, and you are also entitled to have this data transferred to another data controller.
We will comply with access, deletion, rectification, restriction, portability, and restriction requests as soon as possible given the circumstances, but no later than within one month, and will notify you accordingly. If we are unable to comply with your request, we will also notify you within one month.
If the data was transferred to another person based on your consent, we will also notify the recipient of the transfer of the necessary steps.
If we process your personal data on the basis of your consent, you are entitled at any time to withdraw your consent. You may withdraw your consent by contacting our company via the contact details provided in this notice, or, where otherwise appropriate, we will ensure that consent can be withdrawn in simpler ways.
If you are visually impaired or elderly, you may request that we provide the content of this Privacy Policy in Word (text) format or in a large-print version, via the contact details set out in this Privacy Policy.
You are also entitled to lodge a complaint with the:
National Authority for Data Protection and Freedom of Information (NAIH)
1055 Budapest, Falk Miksa utca 9-11;
www.naih.hu,
Phone: +36 1 391-1400
Email: ugyfelszolgalat@naih.hu
or to enforce your rights regarding the processing of your personal data before a court with jurisdiction under Act CXXX of 2016 on the Code of Civil Procedure.
You can find the competent court at the following link:
https://birosag.hu/birosag-kereso
You may exercise the rights listed in this notice at any time by contacting us in writing by email or other means. In connection with your request, we may ask you to identify yourself or provide other data relating to you that serve to verify your entitlement. The request will be handled in the manner specified in the "Contact" section of this privacy policy.
You may contact our company via the contact details provided in Section 1. We ask that, in the event of any official or judicial enforcement, you first attempt to resolve your data protection complaints through direct discussion with us. As the protection of personal data is of the utmost importance to our company, we are confident that we can provide a truly effective response and solution to your needs.
Signed,
Minerva Intézet Nonprofit Kft.
Data Controller