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HunBAN Privacy Notice

Version 2.0, effective 5 November 2026.

1. Introduction and scope

The Hungarian Business Angel Network Association ("HunBAN", "we") processes personal data to run an angel investor association and its wider community of investors, founders, mentors and ecosystem partners. This notice tells you what we collect, why, on what legal basis, who sees it, how long we keep it and what your rights are under the General Data Protection Regulation ((EU) 2016/679, "GDPR") and Hungarian Act CXII of 2011 on Informational Self-Determination and Freedom of Information ("Infotv.").

It covers our website, our membership and startup application forms, our CRM, our events (including Startup Arena and other event formats we are running on our own), our newsletter and every other HunBAN programme. Third-party sites we link to (for example Luma or LinkedIn) have their own privacy policies.

HunBAN itself does not invest. Our members make their own, independent investment decisions. We facilitate introductions and charge founders no fees at any stage.

2. Data controller and contact

ControllerHungarian Business Angel Network Association (Magyar Üzleti Angyal Egyesület)
Registered seat1053 Budapest, Ferenciek tere 2. fszt.
Court registration number01-02-0016487
Represented byPéter Csillag, President
Data protection contactÁdám Brándisz, Community & Operations Manager
Email for all privacy requestsinfo@hunban.eu
Websitehttps://hunban.eu

We have not appointed a Data Protection Officer, because our core activities do not involve large-scale, regular and systematic monitoring of people or large-scale processing of special categories of data or criminal offence data (GDPR Art. 37).

3. Who this notice applies to

This notice covers nine groups of people. Sections 4, 5 and 10 refer to them by letter.

GroupWho
A. MembersIndividual members of the Association and the natural persons representing a member organisation, including team members using a membership seat
B. Prospective membersAnyone who submits our investor or membership interest form or expresses firm interest in becoming a member in the association
C. Founders and startup applicantsAnyone who submits a startup through our application form, and founders we contact ourselves or receive through inbound or a referral
D. People named in startup materialsCo-founders, employees, advisors, shareholders and other people named in a pitch deck, one-pager or other material a founder or investor sends us
E. Network contactsNon-member investors, mentors, experts and other "success enablers" in our community database
F. Event participants and speakersAttendees, pitching founders, speakers, hosts and guests of HunBAN events, online or in person
G. Newsletter subscribersAnyone signed up to the HunBAN newsletter
H. Website visitorsVisitors to hunban.eu
I. Partner and supplier contactsContact persons at partner organisations, sponsors, venues, grant providers and service providers

4. What personal data we process

We collect only what we need for the purposes in Section 5. Information about a company is not personal data in itself, but in a small startup it often relates to identifiable founders, so we treat it with the same care.

GroupData we process
A. MembersIdentity and contact: name, email, phone, LinkedIn profile; (postal address, mother's name, date and place of birth, to identify members unambiguously in the member register and in applications for state funding or support). Membership: type, start and end dates, seats, fees and contributions paid, formal and informal roles in HunBAN, event participation. Billing: billing entity, address, VAT number, invoice email, payment records. Investor profile: current role and organisation, sector focus, preferred stage, typical ticket size, investment experience, mentoring interests, languages, city and country. Event and communication preferences, and anything else you choose to share for matchmaking.
B. Prospective membersContact details and the answers in the interest form: background, investment interests, experience and expected involvement. Our notes from the onboarding conversation.
C. Founders and applicantsContact person's name, role, email, phone and LinkedIn profile; founders' names. Company information: name, one-liner, year founded, incorporation status and country, HQ city, industry, business type, stage, revenue band, prototype status, target customers, funding ask. Uploaded materials: pitch deck, one-pager and links. Declarations: privacy notice acknowledgement, acknowledgement of sharing with HunBAN members, recording notice, confirmation that the people named in the materials were informed, accuracy declaration, pitching language and availability. Evaluation data: screening notes, evaluation call notes, recordings and transcripts of intro and evaluation calls, investor feedback, pipeline stage, introductions made, event participation and, where known, investment outcome. Correspondence with us.
D. People named in materialsWhatever the founder includes: typically name, role, photo, professional background, shareholding and sometimes contact details.
E. Network contactsName, organisation, role, contact details, LinkedIn profile, areas of expertise or investment interest, and a log of our introductions and interactions.
F. Event participants and speakersName, email, organisation, role, ticket type and attendance (usually collected through Luma or a co-organiser), questions and feedback, survey (NPS) answers. Photos, video and voice recordings (Section 12). For speakers: bio and portrait.
G. Newsletter subscribersEmail address, name if given, subscription status, open and click data.
H. Website visitorsTechnical data such as IP address, browser type and access time in server logs, and anonymous page-view statistics (page, referrer, country, device and browser type) from Vercel Web Analytics.
I. Partner and supplier contactsName, organisation, role, contact details and correspondence.

Please do not send us special categories of data (health, religion, political opinions and the like), ID card or passport numbers, or bank card details. We do not need them for any purpose in this notice and will delete them if received.

We name the legal basis we rely on for each purpose. Where we rely on legitimate interest, we have weighed our interest against yours and documented the result; you can ask for a summary and you can object at any time (Section 15).

#PurposeGroupsLegal basis
1Running the membership: admission, member register, seats, voting, member communicationsAContract (Art. 6(1)(b)); legal obligation (Art. 6(1)(c)) for the member register
2Invoicing, accounting, taxA, ILegal obligation (Art. 6(1)(c)): Act C of 2000 on Accounting and Act CXXVII of 2007 on VAT
3Reviewing membership applicationsBSteps taken at your request before membership (Art. 6(1)(b))
4Investor profiling for matchmaking with startupsA, EConsent (Art. 6(1)(a))
5Receiving, screening and evaluating startup applications, including evaluation callsCLegitimate interest (Art. 6(1)(f)): running the deal flow you asked to enter
6Sharing your startup profile and materials with the HunBAN board and membersC, DLegitimate interest (Art. 6(1)(f)): sharing with members is part of the process you apply for
7Introductions outside the membership: non-member investors, partner angel networks (for example EBAN members), consortium partnersC, DConsent (Art. 6(1)(a)), asked case by case
8Assessing the team behind a startup from names and profiles in its materialsDLegitimate interest (Art. 6(1)(f)) of HunBAN, the founders and investors in evaluating the team
9Follow-up, warm intros, mentoring, tracking how founders and portfolio companies progressC, ELegitimate interest (Art. 6(1)(f))
10Event registration, ticketing, attendance listsFContract (Art. 6(1)(b)) for ticketed events, otherwise legitimate interest (Art. 6(1)(f))
11Crowd photos and recordings of eventsFLegitimate interest (Art. 6(1)(f)) and Section 2:48(2) of the Hungarian Civil Code (Ptk.)
12Individual recordings and streaming of pitches, talks and panelsFConsent (Art. 6(1)(a)) and Ptk. 2:48(1)
13NewsletterGConsent (Art. 6(1)(a)); where an issue counts as commercial advertising, also Section 6 of Act XLVIII of 2008 on the basic requirements and certain restrictions of commercial advertising activities
14Satisfaction surveys (NPS) after events and programmesA, C, FLegitimate interest (Art. 6(1)(f))
15Reporting to funders of HunBAN projects (for example grants from the National Research, Development and Innovation Fund)A, C, FLegitimate interest (Art. 6(1)(f)) in meeting our grant obligations; legal obligation (Art. 6(1)(c)) only where a statute, not just the grant contract, requires it
16Anonymised statistics on Hungarian angel investment, including contributions to EBAN reportsAllLegitimate interest (Art. 6(1)(f)); outputs contain no personal data
17Website operation, security and anonymous visitor statistics (Vercel Web Analytics)HLegitimate interest (Art. 6(1)(f)); the site sets no cookies (Section 13)
18Establishing, exercising or defending legal claims; preventing misuse of the networkAllLegitimate interest (Art. 6(1)(f))
19Publishing profiles of members, founders and partners, and testimonials, on hunban.euA, C, E, IConsent (Art. 6(1)(a))
20Recording and transcribing intro and evaluation calls, so our notes are accurateCLegitimate interest (Art. 6(1)(f)); we tell you at the start of the call and don't record if you ask us not to

You can withdraw a consent as easily as you gave it. Withdrawal does not affect processing that happened before. If you don't provide data marked as required in a form, we may not be able to review your application or provide the service.

6. How we handle your startup application

Access to your application widens step by step, and only as you move forward in the process.

  1. Submission. You apply through our online form. Your answers and files go straight into our CRM. Only HunBAN staff can see them at this stage.
  2. Completeness and fit check. The HunBAN team checks that the application is complete and fits our criteria (for example a connection to Hungary and an angel-sized round). Where we need specialist input, we may consult an individual expert from our network, for example on a technology, market or regulatory question. We share only what the question needs, and ask the expert to keep it confidential. Every complete application gets a response.
  3. Evaluation call. If you pass, we invite you to a short call. We may record and transcribe it with Fathom so our notes are accurate; we tell you at the start, and we don't record if you ask us not to. Our notes, and any recording and transcript, are stored with your application.
  4. Investor review. Shortlisted startups are reviewed by HunBAN's board, who are themselves angel investors. We may also show your profile to individual members whose stated interests match yours.
  5. Exposure to the membership. If you are invited to pitch at Startup Arena, a Founder Q&A session or our internal deal flow platform, your profile and deck become available to all HunBAN members and non-member investors in the network. Startup Arena is a public event and pitches may be recorded or streamed (Section 12).
  6. Introductions. We make warm introductions to specific members, mentors or partners. Anyone outside the HunBAN membership gets your materials only with your prior agreement.
  7. Parked or declined. We keep your file for the period in Section 10 so we can reconnect when your stage fits better. You can ask us to delete it at any time.

No step is decided automatically by software. People decide at every stage.

7. How we handle startup materials

HunBAN and its members handle what you submit in your startup's interest. Forwarding decks and making introductions is how angel investing works, so we don't promise strict confidentiality. We promise good faith.

Who sees your materials

WhoWhenBound by
HunBAN staffFrom submissionTheir employment or service contract
HunBAN boardFrom the investor review stepThe HunBAN Member Code of Conduct
HunBAN membersFrom the investor review step, or when you accept an invitation to pitchThe HunBAN Member Code of Conduct
Experts we consult during evaluationOnly with your knowledgeAsked to keep it confidential
Investors and partners outside HunBANOnly with your agreementTheir own terms

What members commit to. Under the HunBAN Member Code of Conduct, members may use and pass on your materials to evaluate an investment, bring in co-investors or connect you with people who can help. When they do, they put your startup's interests first, act in good faith and stop if you ask them to. They never pass on information received under a separately signed NDA, and never use your materials to help a competing business.

What we don't do. We don't sell or publish your materials, and we don't use them for anything other than the purposes in this notice.

No NDAs at the application stage. In line with international angel and venture practice, neither HunBAN nor its members sign NDAs to review an application or a pitch. Keep trade secrets out of your application, such as source code, detailed technical architecture, unfiled patent details or customer contract terms. Share those later, in due diligence, directly with a specific investor and under an NDA if needed.

Public pitches are public. Anything you present on stage at Startup Arena or another public event, and anything recorded there, is not confidential.

If something goes wrong. Report suspected misuse of your information to info@hunban.eu. We handle it under the Member Code of Conduct, which can lead to a member's expulsion.

8. Recipients and data sharing

We never sell or rent personal data. Data leaves HunBAN only in the cases below.

Service providers (processors). They process data only on our instructions, under a data processing agreement. The exception is Vercel, which hosts hunban.eu on its free plan under its own terms of service and privacy policy.

ProviderWhat it does for usData location
ClickUpCRM, startup application forms, file storageUSA; EU-only hosting is offered on the Enterprise plan. Transfers: Standard Contractual Clauses in ClickUp's Data Processing Addendum (ClickUp's DPF listing is inactive)
Google WorkspaceEmail, calendar, documentsEU and USA. Transfers: EU-US Data Privacy Framework and SCCs in Google's
BrevoNewsletterEU (France, Germany, Belgium); no transfer outside the EU for core storage
LumaEvent registration and ticketingUSA, no EU data residency option. Transfers: Standard Contractual Clauses in Luma's DPA
GoDaddyDomain name and DNS for hunban.euUSA. GoDaddy.com, LLC is certified under the EU-US Data Privacy Framework
Accounting firm and invoicing software (Aurum Accounting and Quick software)Bookkeeping, invoicesHungary
VercelHosting hunban.eu, server logs, anonymous visitor statisticsUSA; Vercel is certified under the EU-US Data Privacy Framework
FathomRecording, transcription and AI summaries of video callsUSA; Fathom is certified under the EU-US Data Privacy Framework, with Standard Contractual Clauses as a fallback
SupabaseWebsite database (events, public profiles, testimonials) and document storageEU (Frankfurt)

Independent recipients. These parties decide for themselves how to use what they receive, under their own privacy notices:

We also use Claude Pro by Anthropic as an AI assistant (Section 11). Anthropic processes what we enter under its own consumer terms, in the USA.

9. Transfers outside the EU/EEA

We keep data in the EU/EEA where we can, but some of our service providers are based in the USA, and our community includes Hungarian investors living abroad.

You can ask us for a copy of the safeguards that apply to a transfer.

10. How long we keep data

When a period ends, we delete the data or anonymise it so it can only feed statistics.

DataRetention periodBasis for the period
Membership records (A)5 years after membership endsGeneral limitation period, Civil Code (Ptk.) 6:22
Invoices and accounting recordsAt least 8 yearsAct C of 2000 on Accounting, Section 169(2), a minimum period
Membership applications not accepted (B)1 year after the decisionHandling questions or a reapplication
Startup applications, declined or inactive (C, D)3 years after the last contact, then company name and outcome kept anonymised for statisticsReconnecting when the startup's stage fits; typical early-stage cycle
Call recordings and transcripts (C)Kept with the application file and deleted with itAccurate evaluation notes
Startups that raised from HunBAN members (C, D)For the duration of the relationship plus 5 yearsPortfolio follow-up, limitation period
Investor profiles for matchmaking (A, E)Until consent is withdrawn or membership endsConsent
Network contacts (E)3 years after the last interactionKeeping the community database current
Event participation lists (F)3 yearsEvent follow-up, grant audits
Published photos and recordingsAs long as the content serves HunBAN's archive and communication; removed on a justified requestLegitimate interest, consent
Unused raw footage1 yearSelecting content
Newsletter data (G)Until you unsubscribe; open and click data for up to 2 yearsConsent
Records of consents and their withdrawalWhile the processing lasts, plus 5 yearsProving compliance
Privacy requests and our replies5 yearsProving compliance
Website server logs (H)As set by our hosting provider, typically up to 30 daysSecurity
Website visitor statistics (H)Aggregated statistics only; the visitor hash is discarded after 24 hoursLegitimate interest
Public profiles and testimonialsUntil you ask us to remove them, or your membership or cooperation with HunBAN endsConsent

11. Where data comes from, automated decisions and AI tools

Sources. Most data comes directly from you. We also receive or look up data from:

People named in startup materials. We usually don't collect your data from you directly (GDPR Art. 14). Founders confirm on the application form that they have told the people named in their materials about this notice. When we contact you, or share materials containing your data beyond the HunBAN team, we inform you directly, at the latest within one month (Art. 14(3)). You have the same rights as everyone else, including the right to object.

No automated decisions. We make no decisions with legal or similarly significant effects based solely on automated processing, including profiling (GDPR Art. 22). Matchmaking suggestions are made and checked by people.

AI-assisted tools. We use Claude Pro by Anthropic to help summarise applications, sort email and draft replies, and Fathom to record, transcribe and summarise calls (Section 6). A HunBAN team member reviews every output and takes every decision. We keep Claude's model training setting switched off, so our chats are not used to train Anthropic's models.

12. Photos, recordings and streaming at events

HunBAN events, including Startup Arena, may be photographed, filmed, recorded or streamed. We use this content on hunban.eu, LinkedIn, Facebook and in our newsletter, share recordings of pitches with investors, and include it in reports to the funders of our events.

Removing content already shared by third parties on their own channels may be outside our control, but we will ask them to do so.

13. Website, cookies and newsletter

Website. hunban.eu sets no cookies, so there is no cookie banner. We use Vercel Web Analytics to count page views: it works without cookies, identifies visits only by a temporary hash that is discarded after 24 hours, and gives us aggregated statistics, not individual profiles. Our hosting provider, Vercel, keeps basic technical server logs for security.

Public profiles and testimonials. hunban.eu shows members, founders we support and partners, with name, photo, role, organisation and LinkedIn link, and quotes from founders and investors. We publish these only with the person's consent, and remove them on request to info@hunban.eu.

Embedded forms and links. Our startup application form is hosted by ClickUp, and event registration by Luma. When you open them through our links, these services may set their own cookies under their own policies. The ecosystem map on hunban.eu loads its background map from OpenFreeMap, which receives your IP address and basic browser data when the map loads, so it can deliver the map tiles. OpenFreeMap sets no cookies.

Newsletter. We send it only to people who signed up. Every issue has an unsubscribe link, and unsubscribing never affects your membership or application. We measure opens and clicks to improve content; you can block this by disabling images in your email client.

14. Data security and breaches

We protect personal data with technical and organisational measures that fit a small association handling confidential deal flow:

If a personal data breach occurs, we report it to the Hungarian data protection authority (NAIH) without undue delay and, where feasible, within 72 hours of becoming aware of it, unless it is unlikely to put anyone's rights at risk (Art. 33), and inform you without delay if it is likely to put your rights at high risk (Art. 34).

15. Your rights and how to use them

Email info@hunban.eu to use any of these rights. It is free. We may ask you to confirm your identity, and we reply without undue delay and within one month. For complex or numerous requests we may extend this by two months, and tell you why within the first month (GDPR Art. 12(3)).

RightWhat it means
Access (Art. 15)Get a copy of your data and information about how we use it
Rectification (Art. 16)Have inaccurate or incomplete data corrected
Erasure (Art. 17)Have your data deleted, unless we must keep it, for example invoices
Restriction (Art. 18)Have us store but not otherwise use your data in the cases set out in Art. 18, for example while we check its accuracy
Portability (Art. 20)Receive data you gave us in a common machine-readable format, where we process it by automated means on the basis of consent or contract
Objection (Art. 21)Object to processing based on legitimate interest; we stop unless we have compelling grounds. You can always object to direct marketing
Withdrawing consent (Art. 7(3))Withdraw any consent at any time, as easily as you gave it, with effect for the future

Complaints. You can complain to the Hungarian National Authority for Data Protection and Freedom of Information (NAIH): 1055 Budapest, Falk Miksa utca 9-11; postal address 1363 Budapest, Pf. 9; phone +36 1 391 1400; ugyfelszolgalat@naih.hu; www.naih.hu. You can also complain to the data protection authority of the EU country where you live or work, or go to court. In Hungary you can choose the regional court (törvényszék) of your place of residence or place of stay (Infotv. Section 23(3)). We'd appreciate the chance to fix the issue first at info@hunban.eu.

16. Changes and effective date

We review this notice at least once a year and whenever our processing changes. We announce material changes on hunban.eu and by email to members and to founders with an active application. Earlier versions are available on request.

Version 2.0. Effective date: 5 November 2026. Replaces the version effective 1 January 2026. This notice is published in English.

Questions about this document? Write to us at info@hunban.eu.