PRIVACY & COOKIE POLICY
Last updated: July 2026
This Privacy & Cookie Policy provides detailed information on how Smart Hub Hungary Kft. collects, uses, stores, and protects your personal data when you visit our website, use our automated luggage storage services, rent our mini-storage units (Budapest Mini Storage), or interact with us.
We are committed to respecting your privacy and ensuring full compliance with the European Union General Data Protection Regulation (GDPR – Regulation (EU) 2016/679), the Hungarian Act CXII of 2011 on Informational Self-Determination and Freedom of Information (Infotv.), and applicable ePrivacy regulations.
DATA CONTROLLER
The website, automated luggage storage system, and mini-storage facilities are operated and owned by:
- Company Name: Smart Hub Hungary Korlátolt Felelősségű Társaság (Smart Hub Hungary Kft.)
- Registered Address: 1137 Budapest, Radnóti Miklós utca 9., Hungary
- Company Registration Number (Cégjegyzékszám): 01-09-457452 (Fővárosi Törvényszék Cégbírósága)
- Tax Identification Number (Adószám): 33068815-2-42
- EU VAT Number: HU33068815
- EU Identifier (EUID): HUOCCSZ.01-09-457452
- Customer Service & Privacy Email: admin@smartluggage24.com
- Website: https://smartluggage24.com
LEGAL NOTICE & INTELLECTUAL PROPERTY
Smart Hub Hungary Kft. reserves the right to introduce adjustments in prices without prior notice as a result of increases in material, operational, and/or non-material costs. All prices indicated on this website are stated in HUF (Hungarian Forint) and include the applicable VAT at all times.
The content of this website—in particular all texts, images, graphics, logos, floor maps, software code, as well as their arrangement—is subject to copyright law and other laws protecting intellectual property. Unauthorized reproduction, distribution, or modification is strictly prohibited.
WHAT PERSONAL DATA WE COLLECT, WHY, AND ON WHAT LEGAL BASIS
We collect and process personal data depending on how you interact with our website, automated lockers, and micro-warehouse facilities:
A. Booking, Luggage Storage & Mini Storage Rental Services
- Data Collected: Full name, email address, phone number, billing address, payment confirmation details (processed securely via external payment gateways), selected locker/storage tier, booking start/end timestamps, duration, and assigned electronic access PIN code.
- Purpose: To fulfill your luggage storage or mini-storage reservation, process payments, issue your electronic access PIN code via automated email/SMS, manage lock access, and provide customer support.
- Legal Basis: Performance of a contract to which you are party (GDPR Article 6(1)(b)).
B. TTLock Access Control & Audit Logs
- Data Collected: Entry timestamps, assigned TTLock PIN code identifiers, door unlock/lock events, failed code attempts, and TTLock Wi-Fi Gateway synchronization logs.
- Purpose: Managing physical access control via the TTLock smart locking system, preventing unauthorized entry, ensuring premises security, verifying user access in case of technical issues, and resolving rental duration disputes.
- Legal Basis: Legitimate interest of Smart Hub Hungary Kft. and its users to secure property and verify service compliance (GDPR Article 6(1)(f)).
C. Video Surveillance (Xiaomi Smart IP Cameras)
- Data Collected: 24/7 video recordings of individuals accessing the physical locker and storage premises.
- Important Notice on Audio: The premises are monitored by Xiaomi Smart IP Security Cameras. The system operates on video-only recording. The camera’s two-way audio (microphone and speaker) is utilized exclusively during live, real-time customer support interactions and is never recorded or stored on background servers.
- Purpose: Ensuring property protection, preventing theft, burglary, or vandalism, verifying safety incidents, and protecting stored belongings.
- Legal Basis: Legitimate interest of Smart Hub Hungary Kft. and its users (GDPR Article 6(1)(f)).
D. Dispute Resolution, Chargeback & Fraud Prevention
- Data Collected: User IP addresses, booking timestamps, TTLock PIN code activation logs, and relevant CCTV video snapshots.
- Purpose: Defending against fraudulent chargeback claims, unauthorized payment disputes, or credit card fraud.
- Legal Basis: Legitimate interest of Smart Hub Hungary Kft. to establish, exercise, or defend legal claims (GDPR Article 6(1)(f)).
E. Emergency Locker Openings & Abandoned Items
- Data Collected: Inspection logs, photo/video documentation of locker openings, and inventory records of unclaimed or prohibited items.
- Purpose: Conducting emergency openings in case of safety risks, suspected prohibited items (e.g., hazardous or perishable goods), or unclaimed items post-rental expiration, and preserving inventory records.
- Legal Basis: Legitimate interest (GDPR Article 6(1)(f)) and legal obligation regarding property bailment and safety regulations.
F. Invoicing & Accounting
- Data Collected: Billing name, billing address, tax identification number (if applicable), payment transaction ID, and order details.
- Purpose: Issuing mandatory statutory tax invoices and complying with Hungarian financial and accounting laws.
- Legal Basis: Compliance with a legal obligation (GDPR Article 6(1)(c)).
G. Website Administration & Comments
- Data Collected: IP address, browser user-agent string, username, password hashes, and user submissions.
- Purpose: Website security, user account management, and spam prevention.
- Legal Basis: Performance of contract (GDPR Article 6(1)(b)) and legitimate interest to prevent cyber threats (GDPR Article 6(1)(f)).
DATA RETENTION PERIOD
We store your personal data only as long as necessary to fulfill the purposes outlined above:
- Booking & Rental Data: Retained for the duration of the service plus up to 5 years following fulfillment for customer support and civil law dispute limitation periods.
- TTLock Access Logs: Retained for 30 to 60 days, after which they are automatically overwritten or anonymized within the TTLock system.
- CCTV Video Recordings: Retained for 14 to 30 days, after which footage is automatically overwritten, unless required longer for police investigations, criminal proceedings, or active legal claims.
- Emergency Opening & Inventory Logs: Retained for up to 5 years under civil law limitation rules.
- Invoicing Data: Mandatory retention of 8 years under Hungarian accounting laws (Act C of 2000 on Accounting).
RECIPIENTS OF DATA & DATA PROCESSORS
We do not sell or rent your personal data. We only share data with trusted data processors who assist us in operating our business under strict data protection agreements:
- Hosting & IT Infrastructure Providers: Server hosting and cloud management providers.
- Payment Processors: Secure payment gateways (e.g., Stripe, OTP SimplePay, Apple Pay, Google Pay). We do not store full credit card details on our servers.
- Smart Lock & Communication Systems: TTLock Cloud API platform (Sciener Technology Co., Ltd.) and automated email/SMS dispatch gateways used solely to program access codes and send notifications.
- Law Enforcement & Authorities: Hungarian Police (Magyar Rendőrség), National Tax and Customs Administration (NAV), National Authority for Data Protection and Freedom of Information (NAIH), or judicial courts, solely upon official mandatory legal requests or criminal investigations.
EMBEDDED CONTENT & THIRD-PARTY SERVICES
Pages on this site may include embedded content (e.g., Google Maps, YouTube videos, social media widgets). Embedded content from other websites behaves in the exact same manner as if the visitor has visited the third-party website directly.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content.
YOUR DATA PROTECTION RIGHTS
Under the GDPR and Hungarian laws, you have the following rights regarding your personal data:
- Right of Access: You can request a copy of the personal data we hold about you.
- Right to Rectification: You can request that we correct inaccurate or incomplete data.
- Right to Erasure („Right to be Forgotten”): You can ask us to delete your personal data, provided there are no statutory retention requirements (e.g., accounting laws) forcing us to keep it.
- Right to Restriction of Processing: You can ask us to temporarily suspend processing your data.
- Right to Data Portability: You can request your data in a structured, commonly used, machine-readable format.
- Right to Object: You have the right to object to processing based on our legitimate interests.
- Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time.
To exercise any of these rights, please contact us at: admin@smartluggage24.com.
Legal Remedies / Supervisory Authority
If you believe your data protection rights have been violated, we encourage you to contact us first. You also have the right to lodge a formal complaint with the Hungarian supervisory authority:
- National Authority for Data Protection and Freedom of Information (NAIH)
- Address: 1055 Budapest, Falk Miksa utca 9-11., Hungary
- Postal Address: 1363 Budapest, Pf. 9.
- Phone: +36 (1) 391-1400
- Email: ugyfelszolgalat@naih.hu
- Website: https://www.naih.hu
COOKIE POLICY
What is a Cookie?
A cookie is a small text file stored on your computer or mobile device when accessing web pages. Cookies allow a website to recognize your device, maintain your session, and store user preferences.
Types of Cookies We Use
- Necessary / Session Cookies: Essential for navigating the website and utilizing booking functions (such as maintaining your shopping cart and locker booking session).
- Retention: Deleted automatically when your browser session is closed.
- Functional & Preference Cookies: Used to store login credentials or language/display preferences.
- Retention: Retained up to 1 year.
- Analytics Cookies (Google Analytics): We use Google Analytics (provided by Google LLC) to analyze visitor interactions anonymously.
- Data Collected: Visit duration, referring URL, page views, and anonymized IP address.
- Opt-Out: You can disable Google Analytics via the Google Analytics Opt-out Add-on (https://tools.google.com/dlpage/gaoptout).
- Marketing Cookies: Allow us and third-party partners to display relevant promotional ads to users who have expressed interest in our services.
How to Manage or Disable Cookies
You can restrict, block, or delete cookies at any time through your browser settings. Please note that blocking necessary cookies may impair website functionality and checkout capabilities.
UPDATES TO THIS POLICY
Smart Hub Hungary Kft. reserves the right to update or modify this Privacy & Cookie Policy at any time to reflect legal changes, technological advancements, or operational updates. Any updates will be published directly on this page with an updated revision date.